ML20155F649

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Proposed Tech Specs,Allowing Entry Into Mode 3 Before Performance of Response Time & Actuation Signal Testing for turbine-driven Auxiliary Feedwater Pump
ML20155F649
Person / Time
Site: Sequoyah  Tennessee Valley Authority icon.png
Issue date: 06/13/1988
From:
TENNESSEE VALLEY AUTHORITY
To:
Shared Package
ML20155F646 List:
References
NUDOCS 8806170005
Download: ML20155F649 (18)
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Text

._

TABLE 3.3-5 ENGINEEREO SAFETY FEATURES RESPONSE TIMES INITIA',.'NG SIGNAL AND FUNCTION RESPONSE TIME IN SECONOS

1. Manual
a. Safety Injection (ECCS) Not Applicable Feedwater Isolation I Not Applicable Reactor Trip (SI) Not Applicable Containment Isolation-Phase "A" Not Applicable Containment Ventilation Isolation Not Applicable Auxiliary Feedwater Pumps Not Applicable Essential Raw Cooling Water System Not Applicable Emergency Gas Treatment System Not Applicable
b. Containment Spray Not Applicable Containment Isolation-Phase "B" Not Applicable Containment Ventilation Isolation Not Applicable Containment Air Return Fan Not Applicable j c. Containment Isolation-Phase "A" Not Applicable Emergency Gas Treatment System Not Applicable Containment Ventilation Isolation' Not Applicable
d. Steam Line Isolation Not Applicable
2. Containment Pressure-High
a. Safety Injection (ECCS) 1 32.0(1) f.59
b. Reactor Trip (from SI) 13.0
c. Feedwater Isolation

< 8.0(2) d.

Containment Isolation-Phase "A"( ) i 18.0(8)/28.0(9) e.

Containment Ventilation Isolation Not Applicable

f. Auxiliary Feedwater Pumps 1 60
g. Essential Raw Cooling Water System 1 65.0(8)/75.0(9)
h. Emergency Gas Treatment System 1 38.0(9)

\

8806170005 880613 DR ADOCK 0500 7 gj 3 37 SEQUOYAH - UNIT 1 3/4 3-29 -Amendment He. ;s-i

~~  !

TABLE 3.3-5 (Continu*d) i i

ENGINEERED SAFETY FEATURES RESPONSE TIMES INITIATING SIGNAL AND FUNCTION RESPON$E TIME IN SECONOS

3. Pressurizer Pressure-Low
a. Safety Injection (ECCS) .

1 32.0(1)/28.0(7) R59

b. Reactor Trip (from SI) 1 3.0 I
c. Feedwater Isolation < 8.0(2)
d. Containment Isolation-Phase "A"(3) 18.0(8)
e. Containment Ventilation Isolation Not Applicable
f. Auxiliary Feedwater Pumps 1 60
g. Essential Raw Cooling Water System 1 65.0(8)/75.0C9)
h. Emergency Gas Treatment System 1 28.0(8)
4. Differential Pressure Between Steam Lines-Hiah
a. Safety Injection (ECCS) 1 28.0(7)/28.0(1) R59
b. Reactor Trip (from SI) 1 3.0 I
c. Feedwater Isolation < 8.0(2)
d. Containment Isolation-Phase "A"(3) 18.0(8)/28.0(9) i
e. Containment Ventilation Isolation Not Applicable i
f. Auxiliary Feedwater Pumps < 60( I
g. Essential Raw Cooling Water System 65.0(8)/75.0(9) I
h. Emergency Gas Treatment System 1 38.0(9)
5. . Steam Flow in Two Steam Lines - High Coincident with T --Low-Low
a. Sa ty Injection (ECCS) s 30.0(7)/30.0(1) R59
b. Reactor Trip (from SI)~ 15.0
c. Feedwater Isolation < 10.0(2)
d. Containment Isolation-Phase "A"(3) 20,0(8)/30.0(9)
e. Containment Ventilation Isolation Not Applicable
f. Auxiliary Feedwater Pumps C 1 60 ,
g. Essential Raw Cooling Water System 1 67.0(8)/77.0(9)
h. Steam Line Isolation < 10.0
1. Emergency Gas Treatment System 40.0(9)

_Umaa j $ 1O@$

SEQUO,YAH - UNIT 1 3/4 3-30 tA%, -

a TABLE 3.3-5 (Continued)

ENGINEERED SAFETY FEATURES RESPONSE TIMES INITIATING $1GNAL AND FUNCTION RESPONSE TIME IN SECONOS ,

6, Steam Flow in Two Steam Lints-High Coincident with Steam Line Pressure-Low ,

a. Safety Injection (ECCS) 1 28.0(7)/28.0(1)

. b. Reactor Trip (from SI) < 3.0

c. Feedwater Isolation 8.0(2)
d. Containment Isolation-Phase "A"(3) 1 18.0(8)/28.0(9)
e. Containment Ventilation Isolation Not Applicable
f. Auxiliary Feedwater Pumps 160(#h
g. Essential Raw Cooling Water System 1 65.0(8)/75.0(9) [
h. Steam Line Isolation s 8.0  ;
i. Emergency Gas Treatment System 5 38.0(9) -
7. Containment Pressure--)ligh-High i R63 -
a. Containment Spray 1 208(9)
b. Coritainment Isolation-Phase "B" 1 65(8)/75(9)  ;
c. Steam Line Isolation 1 7.0 R16
d. Containment Air Return Fan > 540.0 and 1 660
8. Steim Generator Water Level--High-High
a. Turbine Trip --

1 2.5 lR67

b. Feedwater Isolation 1 11.0(2)
9. Main Steam Generetor Water Level -

Low-Low l

a. Motor-driven Auxiliary 1 60.0 [

Feedwater Pumps (4)  ;

b. Turbine-driven Auxiliary -< 60.0 l Feedwater Pumps (5)D3) l SEQUOYAH - UNIT 1 3/4 3-31 fr : d -t h IE n==s= n . m' EE 63-

y-TABLE 3.3-5 (Continued)

ENGINEERED SAFETY FEATURES RESPONSE TIMES INITIATING SIGNAL AND FUNCTION RESPONSE TIME IN SECONDS

10. Station Blackout '
a. Auxiliary Feedwater Pumps 1 60
11. Trip of Main Feedwater Pumps i .
a. Auxiliary Feedwater Pun.ps 5 60 (13) g/12. Loss of Power '

R33

a. 6.9 kv Shutdown Board - Degraded 5 10(10)

Voltage or loss of Voltage

13. RWST Level-Low Coincident with Containment Sump '

Level-High and Safety Injection

a. Automatic Switchever to Containment Sump i 250
14. Containment Purge Air Exhaust Radioactivity - High l
a. Containment Ventilation Isolation 5 10(6)
15. Containment Gas Monitor Radioactivity High

, a. Containment Ventilation Isolation i 10(6) 4 1

16. Containment Particulate Activity High
a. Containment Ventilation Isolation 5 10(6) j 1 NOTE- This-technica!- specification te be imp! rented at the etertup f 011
wing R33

{

l 4he-second-refveWg-outcge Or foi-lowing completion-of-the-modific0tien - i d ichever f ca v44ee,- 1 l

SEQt10YAH - UNIT 1 3/4 3-32 ^::nd ent 90. 24-

! -May-Gr 19&3-  !

l

INSTRUMENTATION TABLE 3.3-5 (Continued)

TABLE NOTATION

/(19) The response time for loss of voltage is measured from the time vo is lost until the time full voltage is restored by the diesel. The response time for degra.ie d voltage is measured from the time the load R33 shedding signal is generated, either from the degraded voltage or the SI enable timer, to the time full voltage is restored by the diesel. The response time of the timers is covered by the requirements on their setpoints.

No b ll Q Wck l by TJ f7-38 , 4 bo m S W S'f l' b'# N, /917 Ne /d <t WA / by 7J~ 88-O/ .ta/m/Ned (l3) 7da jroyhiosu o/' .Spci8a 6 , M O. Y see naV ogs4haSt$

,4 e., /y' en woos 3 d.- M: . 7~<Aa -ke< n Am.h.y Ac/amd< Aoy.

i l

. I

. NOTE +--This-techhicabspecif.icatlon +^ha implamented at th :tactup-4eH ovi ng-t he-second- re fue ling 4utage-or-follow 4momplet% F- the- R33

-modif-icationr -whicheven-is-earlier.

SEQUOYAH - UNIT 1 3/4 3-33a ^::,,d:c.,t Nc. 29

":y 5, .199-

PLANT SYSTEMS SURVELLLANCE REQUIREMENTS (Continued)

CAu c (At hasI c< rec per Ji rty 4j va<ifyu,s th)

R16 fufm,//

'/'O 4' we r?O l ct/ $ $/e .$,. en by 44 MODE 3 ,4. iM 7;;<k - d,.vc,f <aAmiA.3 , l Fe A ~fc'- Pu-p.  ; i 44AR 251002 l SEQUOYAH - UNIT 1 3/47-6 .Amerie nt Tiu. l' i I TABLE 3.3-5 ENGINEERED SAFETY FEATURES RESPONSE TIMES INITIATING SIGNAL AND FUNCTION RESPONSE TIME IN SECONOS

1. Manual
a. Safety Injection (ECCS) Not Applicable Feedwater Isolation l Not Applicable Reactor Trip (SI) Not Applicable

. Containment Isolation-Phase "A" Not Applicable Containment Ventilation Isolation Not Applicable Auxiliary Feedwater Pumps Not Applicable Essential Raw Cooling Water System Not Applicable Emergency Gas Treatment System Not Applicable

b. Ccntainment Spray Not Applicable Containment Isolation-Phase "B" Not Applicable Containment Ventilation Isolation Not Applicable Containment Air Returt: Fan Not Applicable

} c. Containment Isolation-Phase "A" Not Applicable Emergency Gas Treat. ment System Not Applicable Containment Ventilation Isolatiori Not Applicable l

d. Steam Line Isolation Not Applicable
2. Containment Pressure-High
a. Safety Injection (ECCS) 1 32.0(1)
b. Reactor Trip (from SI) 13.0
c. Feedwater Isolation <8.0(2)
d. Containment Isolation-Phase "A"(3) 118.0(8)/28.0(9) L
e. Containment Ventilation Isolation Not Applicable
f. Auxiliary Feedwater Pumps 160
g. Essential Raw Cooling Water System 165.0(8)/75.0(9)
h. Emergency Gas Treatment System 138.0(9) l t

u_.. i, i n o ,- SEQUOYAH - UNIT 2 3/4 3-29 M nUmentM M , i 1 _ TABLE 3.3-5 (Continued) ENGINEERED SAFETY FEATURES RESPONSE TIMES INITIATING SIGNAL AND FUNCTION RESPONSE TIME IN SECONOS

3. Pressurizer Pressure-Low
a. Safety Injection (ECCS)' R47 132.0(1)/28.0(7)
b. Reactor Trip (from SI) 1 3.0
c. Feedwater Isolation < 8.0(2)
d. Containment Isolation-Phase "A"( ) 18.0(8)
e. Containment Ventilation Isolation Not Ap licable
f. Auxiliary Feedwater Pumps <60 I#3
g. Essential Raw Cooling Water System 65.0(8)/75.0(9)
h. Emergency Gas Treatment System 128.0(8)
4. Differential Pressure Between Steam Lines-High
a. Safety Injection (ECCS) R47 128.0(7)/28.0(1)
b. Reactor Trip (from SI) <3.0
c. Feedwater Isolation 8.0(2)
d. Containment Isolation-Phase "A"(3) 18.0(8)/28.0(9)
e. Containment Ventilation Isolation Not Applicable
f. Auxiliary Feedwater Pumps <60(#
g. Essential Raw Cooling Water System 65.0(8)/75.0(9)
h. Emergency Gas Treatment System 138.0(9)
5. Stemi Flow in Two Steam Lines - High Coincident with T --Low-Low
a. Safety Injection (ECCS) R47 130.0( )/30.0(1)
b. Reactor Trip (from SI) <5.0
c. Feedwater Isolation 10.0(2)
d. Containment Isolation-Phase "A"(3) 20.0(8)/30.0(9) e.

Containment Ventilation Isolation Not Appliccble

f. Auxiliary Feedwater Pumps I t 160 '3)
g. Essential Raw Cooling Water System 167.0(8)/77.0(9)
h. Steam Line Isolation <10.0
f. Emergency Gas Treatment System 40.0(9) 1 SEQUO,YAH - UNIT 2 4Iay- I 7, ' 9 R 7*

3/4 3-30 .-Amendmen t-NoH7 l _ _ ,J _ _ _ , , - _ _ _ . - - _ _ _ _ . . ~ - . __ . . _ . _ - . . . _ _ . _ _ _ - - - - - - - - - TABL'E 3.3-5 (Continued) ENGINEERED SAFETY FEATURES RESPONSE TIMES INITIATING SIGNAL AND FUNCTION RESPONSE TIME IN SECONDS-

6. Steam Flow in Two Steam Lines-High Coincident with Steam Line Pressuro-Low ,
a. Safety Injection (ECCS)

~ RU 5 28.0(7)/28.0(1) . b. Reactor Trip (from SI) l 5 3.0

c. Feedwater Isolation < 8.0(2)
d. Containment Isolation-Phase "A"(3) k18.0(8)/28.0(9)
e. Containment Ventilation Isolation Not Applicable'
f. Auxiliary Feedwater Pumps 160
g. Essential Raw Cooling Water System 1 65.0(8)/75.0(9)
h. Steam Line Isolation < 8.0
i. Emergency' Gas Treatment. System 38.0(9)
7. Containment Pressure--High-High R51
a. Containment Spray < 2'08(9)
b. Containment Isolation-Phase "B" 65(8)/75(9)
c. Steam Line Isolation 1 7.0
d. Containment Air Return Fan > 540.'O and 1660
8. Steam Generator Water Level--High-High I
a. Turbine Trip < 2.5 lR55
b. Feedwater Isolation 1 11.0(2)
9. Main Steam Generator Water level - '

-l Low-Low l

a. Motor-driven Auxiliary ~< 60.0 Feedwater Pumps (4)
b. Turbine-driven Auxiliary -< 60.0 Feedwater Pumps (5) W f

~ -t l i i SEQUOYAH - UNIT 2 3/4 3-31 DC^dment N^. # , SA - m n . m. I I _ _ _ - , , - ~ . . . . _ , . _ _ - _ _ . . _ . . l_ , , _ , . _ . . _ _ _ _ _ _ . _ . . . , _ . . . , , . . . . _ , _ - _ , - . . _ . _ . . - _ _ _ . - _ - _ TABLE 3.3-5 (Continued) ENGINEERED SAFETY FEATURES RESPONSE TIMES W11ATING SIGNAL AND FUNCTION RESPONSE TIME IN SECON05

10. Station Blackout Auxiliary Feedwater Pumps 1 60
11. Trio of Hain Feedwater Pumps I
3. Auxiliary Feedwater Pumps 1 60(/3.) t

/12.LossofPower

1. 6.9 kv Shutdown Board - Degraded Voltage or loss of 5 10(.0) pig Voltage- l

- l'

13. RUST Level-Low Coincident with Containment Sump

, Level-High and Safety Injection

a. Automatic Switchover to Containment Sump 1 250
14. _;0nttinment Purge Air Exhaust.

'bdioactivity - High. 1. Containment Ventilation Isolation 1 10(6)

15. ,'s' tainment Gas Monitor Padioactivity High a

Containment Ventilation Isolation i 10(6)

16. Containment Particulate Activity High
e. Containment Ventilation Isolation i 10(6)

R18 a40TE: This technicM-spet#4eatien i: to-be-4mfd emented during the startup l - m 9,1ng 9e '4 :; cfue1ing-out-ager SEQLK)YAH - UNIT 2 3/4 3-32 -Amendment M0. 18 ---- my 5, 1983- [- . - - . . - . _ _ . = - . - . .- =. . . _ .. l . I INSTRUMENTATION TABLE'3.3-5 (Continued) TABLE NOTATION /(10) The response time for loss of voltage is measured from the t ~ is lost until the time full voltage is restored g by the diesel. The response time for degraded voltage is measured from the time the load R18 shedding signal is generated, either from the ' degraded voltage or the 51 enable timer, to the time full voltage is restored by the diesel. The response time of the timers is covered by the requirements on their setpoints. YOfe // dl l by l'J* 8)d$ 14lMikW Jy nbw /f /fD Nk N s/d/ by 7J 88-0/ re/mi1%/ (/3) The of fec;duh- 'l o, y see A picysum no/ sphad4 e /,y i%f Ot)E 3 8 17le & 4;.,c - <;n,, It kaxib'ay bedwake knpf, ' MTE : Thi; technica! :pec-i44 cat 4on is to be--implemented-dueing-t+c startup- R18 -following-the 'i r;t refueMog-outager i SEQUOYAH - UNIT 2 3/4 3-33a ^ c"dm t "^ ler -MAY 5 r23 -- i PLANT SYSTEMS SURVEILLANCE' REQUIREMENTS (Continued) Cfs,y,e f 4} /esd cru e per 3/ Ap by wa/}sjj >"I'"Ed dj 3 d each automatic control valve in the flow path is OPERABLE TJ 87-/7 whenever the auxiliary feedwater system is placed in automatic control or when above 10% of RATED THERMAL POWER.

b. Atleastonceper18monthsduringshutdow[by:

, 1. Verifying that each automatici valve in the flow path actuates to its correct position upon receipt of an auxiliary feedwater actuation test signal and a low auxiliary feedwater pump suction pressure test signal. 2. Verifying that each auxiliary feedwater pump starts as designed automatically upon receipt of eaeh-auxiliary feedwater actuation test signal. 40 l i

c. At least once per 7 days by verifying that each non-automatic valve in the auxiliary feedwater system flowpath is in its correct position.  ;

I i l l l l \ WThe roahns o f hecide.6 t'act s,2 ,rs / <p a/L p Af,- &t *y id ,WoQE 3 -A?< 7/'$ 74~di.,a -Aivu, Afw,4 ey 4 dam /- 4,.y. SEQUOYAH - UNIT 2 3/4 7-6 f e e o ENCLOSURE 2 PROPOSED TECHNICAL SPECIFICATION CHANGE SEQUOYAH NUCLEAR PLANT UNITS 1 AND 2 DOCKET NOS. 50-327 AND 50-328 (TVA-SQN-TS-88-10) DESCRIPTION AND JUSTIFICATION FOR PROPOSED CHANGE TO TDAFWP RESPONSE TIME AND ACTUATION SIGNAL TESTING i 4 t r ENCLOSURE 2 Description of Change Tennessee Valley Authority proposes to modify the SQN units 1 and 2 technical specifications to revise'the testing requirements for the TDAFWP. In addition, an outdated footnote is being deleted. Each change > is described in detail below.

1. Footnote _13 is being added to table 3.3-5. It will apply to functional items 2.f, 3.f 4.f 5.f. 6.f 9.b, 10.a. and 11.a. The footnote indicates that the provisions of specification 4.0.4 are not applicable for entry into mode 3 for the TDAFWP.
2. A footnote is being added to surveillance requirement (SR) 4.7.1'.2.b to indicate that the provisions of specification 4.0.4 are not applicable for entry into mode 3 for the TDAFWP.
3. An outdated footnote is being deleted from table 3.3-5, item 12, and note 10. This footnote identified scheduling requirements for a modification that is now complete.
4. The wording of unit 2 SR 4.7.1.2.b.2 is revised. The change makes the unit 2 SR wording consistent with unit 1 and the Westinghouse Standard Technical Specifications (STS).

Reason for Change Two of the changes are necessary to resolve inconsistencies in the technical specification requirements for the TDAFWP. One of the changes is made as a convenience to remove an outdated footnote. Another cf che changes is made as a convenience to correct inconsistent wording between the unit i and unit 2 technical specifications. The TDAFWP must have a secondary steam supply pressure greater than 842 pounds per square inch (psig) in order to operate at rated conditions. The reactor coolant system temperature must be greater than 525 degrees F to generate the necessary secondary steam supply system pressure. From a thermodynamic point of view, the steam generator operates at saturated conditions. The reactor coolant system must operate at a temperature greater than the saturation temperature associated with the steam generator pressure in order to transfer energy to the secondary system. The saturation temperature for 842 psig is between 524 degrees F and 525 degrees F. The reactor must be in mode 3 in order to achieve the necessary steam conditions to operate the TDAFWP at rated conditions. SR 4.7.1.2.a.2 recognizes this' fact and allows entry into mode 3 te pertorm TDAFWP testing. The response time testing requirements in table 3.3-5 and SR 4.7.1.2.b do not clearly allow for entry into mode 3 to perform the 1 special testing. No specific exemption to specification 4.0.4 is identified. Specification 4.0.4 requires performance of the SR before entry into the applicable modes. For auxiliary feedwater, the applicable modes are 1, 2, and 3. l I ~ l The mode change exemption for TDAFWP testing is only used during return to service from an outage, typically a refueling outage for SRs l with an 18-month frequency. The decay heat levels are much lower on a return to service from an outage because of the decay time-during the outage. In addition, the technical specifications do not allow the reactor to be critical in mode 3. This restriction also serves to limit the decay heat level. The auxiliary feedwater system is designed to remove full decay heat levels immediately following a reactor trip. As identified in Final Safety Analysis Report (FSAR) Section 10.4.7.2.3, 440 gallons per minute (gal / min) to two steam generators is sufficient to remove this decay heat level. The SQN auxiliary feedwater system consists of two motor-driven auxiliary feedwater pumps (MDAFWPs)(each sized to deliver a minimum of 440 gal / min) and one TDAFWP (nominal capacity of 880 gal / min) for each unit. Technical specification 3.7.1.2 requires three operable auxiliary feedwater pumps in modes 1, 2, and 3. In addition, the two MDAFWPs must be fully tested before entry into mode 3. The TDAFWP is available, but not fully tested in mode 3. In summary, the changes to table 3.3-5 and SR 4.7.1.2.b to permit entry into mode 3 to perform TDAFWP testing are appropriate and justified. The changes are consistent with the administrative provisions that already exist for other TDAFWP testing requirements, namely SR 4.7.1.2.a. The technical specifications require two redundant, 100-percent capacity, fully tested MDAFWPs in mode 3. The TDAFWP is also available, but not fully tested. This configuration is more than sufficient to remove the reduced decay heat levels present whenever the mode change provisions are used. The deletion of the outdated footnote is administrative in nature. The modification discussed in the footnote is complete. This change will remove extraneous information and make t'he document more user-friendly. The wording change made to unit 2 SR 4.7.1.2.b.2 is also an administrative change. The revised wording will make the unit 2 SR consistent with the wording of the unit 1 and STS SR wording. . I l l 9 6 4 ENCLOSURE 3 PROPOSED TECHNICAL SPECIFICATION CHANGES SEQUOYAH NUCLEAR PLANT UNITS 1 AND 2 DOCKET NOS. 50-327 AND 50-328 (TVA-SQN-TS-88-10) DETERMINATIONOFNOSIGNIFICfNTHAZARDSCONSIDERATIONS 1 \ I f ~ P y ENCLOSURE 3 Page 1 of 2 Significant Hazards Evaluation TVA has evaluated the proposed technical specification change and determined that it does not represent a significant hazards consideration based on criteria established in 10 CFR 50.92(c). Operation of SQN in accordance with the proposed amendment will not: (1) involve a significant increase in the probability or consequences of an accident previously evaluated. The proposed changes to table 3.3-5 and SR 4.7.1.2.b correct an inconsistency in the SRs for the TDAFWP. The proposed changes allow for entry into mode 3 to perform response time and actuation signal testing for the TDAFWP. Valid testing cannot be performed until the necessary secondary steam supply conditions are present in mode 3. The proposed changes do not reduce the overall system requirements for the TDAFWP because SR 4.7.1.2.a already has the provisions for entry into mode 3 to perform TDAFWP testing. Because the overall system requirements for the TDAFWP are not reduced, the change does not increase the p.nbability or consequences of any accident previously evaluated. Testing the TDAFWP under conditions that are representative of the plant conditions that would be present whenever the TDAFWP would be expected to perform its safety-related function may actually improve system reliability and possibly decrease the probability or consequences of any accident previously evaluated. The deletion of the outdated footnote is administrative in nature. The footnote serves no purpose now that the modification discussed in the footnote is installed. The wording change made to the unit 2 SR is also administrative. The revised wording is consistent with the ' unit 1 and STS SR wording. These proposed changes have no effect on any plant system. Because no plant system is affected, the changes j do not increase the probability .3r consequences of any accident ' previously evaluated. (2) create the possibility of a new or different kind of accident from any previously analyzed. The proposed changes to table 3.3-5 and  ; SR 4.7.1.2.b correct an inconsistency in the SRs for the TDAFWP. The  ; proposed changes allow for entry into mode 3 to perform response time  ! and actuation signal testing for the TDAFWP. Valid testing cannot be I performed until the necessary secondary steam supply conditions are  ! present in mode 3. The proposed changes do not reduce the overall l system requirements for the TDAFWP because SR 4.7.1.2.a already;has ' the provisions for entry into mode 3 to perform TDAFWP testing. Because the overall system requirements for the TDAFWP are not reduced, the change does not create the possibility of a new or different kind of accident from any previously analyzed. 1 The deletion of the outdated footnote is administrative in nature. The footnote serves no purpose now that the modification discussed.in the footnote is installed. .The wording change made to the unit 2 SR is also administrative. The revised wording-is consistent with the unit 1 and STS SR wording. These proposed changes have no effect on any plant system. Because no plant system is affected, the changes do not create the possibility of a new or different kind of accident from any previously analyzed. (3) 'involve a significant reduction'in a margin of safety. The proposed changes to table 3.3-5 and SR 4.7.J.2.b correct an inconsistency in the SRs for the TDAFWP. The propo' sed changes allow for entry into mode 3 to perform response time and actuation signal testing for the TDAFWP. Valid testing cannot be performed until the necessary secondary steam supply conditions are present in mode 3. The proposed changes do not reduce the overall system requiremants for the TDAFWP because SR 4.7.1.2.a already has the provisions for entry into mode 3 to perform TDAFWP testing. Because the overall system requirements for the TDAFWP are not reduced, the change does not reduce the margin of safety. Testing the TDAFWP under conditions that are representative of the plant conditions that would be present whenever the TDAFWP would be expected to perform its safety-related function may actually improve system reliability and possibly increase the margin of safety. The deletion of the outdated footnote and the wording change are administrative in nature. Because no plant system is affected, the change has no impact on the margin of safety. \ l I i I I - . _ _ _ _ _ - _ _ _ _ _ _ _ _ _ _ .

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