ML20196G616
| ML20196G616 | |
| Person / Time | |
|---|---|
| Site: | Wolf Creek  |
| Issue date: | 12/02/1998 |
| From: | WOLF CREEK NUCLEAR OPERATING CORP. |
| To: | |
| Shared Package | |
| ML20196G614 | List: |
| References | |
| NUDOCS 9812080044 | |
| Download: ML20196G616 (800) | |
Text
{{#Wiki_filter:. _ - . . -- _. .- - .. -- . - -. .- - -. RTS Instrumentaticn B 3.3.1 . BASES _ BACKGROUND Accidents are events that are analyzed even though they are not (continued) expected to occur during the unit life. The acceptable limit during accidents is that offsite dose shall be maintained within an acceptable fraction of 10 CFR 100 limits. Different accident categories are allowed a different fraction of these limits, based on probability of occurrence. Meeting the acceptable dose limit for an accident category is considered having acceptable consequences for that event. ' The RTS instrumentation is sepented into four distinct but interconnected modules ;; ill;;tr;td ir. ."igur; [ ], g 5Heritiliil , Chapter 7 (Ref.1), and as identified below:
- t. r.a W uin M .A.) ta 3.3h-11
- 1. Field transmitters or process sensors: provide a measurable electronic signal based upon the physical characteristics of the parameter being measured:
- 2. Signal Process Control and Protection System, including B28ings Aneleg Protection System, Nuclear Instrumentation System (NIS), field contacts, and protection channel sets: provides signal conditioning, histable setpoint comparison, process algorithm actuation.
compatible electrical signal output to protection system devices, and control board / control room / miscellaneous indications: ;
- 3. Solid State Protection Systee. (SSPS), including input, !
logic, and output bays: initiates proper unit shutdown l and/or ESF actuation in accordance with the defined logic, ! which is based on the bistable outputs from the signal l process control and protection system; and
- 4. Reactor trip switchgear, including reactor trip breakers (RTBs) and bypass breakers: provides the means to interrupt power to the control rod drive mechanisms (CRDMs) and allows the rod cluster control assemblies (RCCAs), or " rods," to fall into the core and shut down the reactor. The bypass breakers allow testing of the RTBs at power.
i 9812080044 981202 DR ADOCK 050 2 (continued) WCGS-Mark-up ofNUREG-1431-Bases 3.3 B 3.3 2 5/15l97 j
RTS Instrumentation B 3.3.1 BASES . BACKGROUND Reactor Trio Switchoer (continued) the undervoltage coil or the shunt trip mechanism is sufficient by itself. thus providing a diverse trip mechanism. , reA%e. The decision logic matrix Functions are di bed in the functional diagrams included in Reference r1 In addition to the reactor trip or ESF acteation, these diagrams also describe the pas.(r-l } various " permissive interlocks' that are associated with unit ~ conditio CEach Mtrain has a built in testing device that can cutcmatically test the decision logic matrix Functions and the actuation devices while the unit is at power. When any one train is taken out of service for testing, the other train is capable of providing unit monitoring and protection until the testing has been completed. The testing device is semiautomatic to minimize testing time. APPLICABLE The RTS functions to maintain the applicable W 1Tatts during SAFETY ANALYSES, all A00s and mitigates the consequences of DBAs in all H0 DES in LCO. and ich the RTBs RodT,ontrol' System 3s" capable of rod withdrawalior APPLICABILITY ~r 6dgiNEnotXu]13,; inserted; crc cicscd. --o 3-a.ow
- ne fe m,@ Tu sm ; -
Each of the analyzed accidents and transients can be detected by one or more RTS Functions. The accident analysis described in Reference B 2 takes credit for most RTS trip Functions. RTS trip Functions not specifically credited in the accident analysis are qualitatively credited in the safety analysis and the NRC staff approved licensing basis for the unit. These RTS trip Functions may provide protection for conditions that do not require dynamic transient analysis to demonstrate Function performance. They may 0 also serve as backups to RTS trip Functions that were credited in the accident analysis. The LCO requires all instrumentation performing an RTS Function, listed in Table 3.3.11 in the accompanying LCO, to be OPERABLE. Failure of any ir.atrument renders the affected channel (s) inoperable and reduces the reliability of the affected Functions. The LCO generally requires OPERABILITY of four or three channels in each instrumentation Function, two channels of Manual Reactor (continued) WCGS-Mark-up ofb71 REG-14)1-Bases 3.3 B 3.3-7 5/15l97
RTS Instrtamentation B 3.3.1 BASES APPLICABLE 14. steam Generator Water Level - Inw Low (continued) SAFETY ANALYSES, i LCO, and withstand an input failure to the control system, APPLICABILITY which may then require the protection function actuation, and a single failure in the other channels providing the protection function actuation. This Function also i performs the ESFAS function of starting the AFW ptsups on low low SG 1evel. The LCO requires four channels of SG Water Level-4.ow Low per SG to be OPERABLE fa f s- 1;,;, mit; in 2.i;t M these channels are shared between protection and control. In ta, tr ;; c.d far les,,, =1t; d c; tt.ce; 00 '.;ter
;si; re d;di;;ted t; tM 't", ;;1y tt e; et..c 1; i,.- .
00 ..; r;,, ired t; h 0"0" C . We N W W6 M ,=wn:- y _- -.
;lrskhZfThe a tion logi must be able tot N# 3** d grit an -pput fa ure to the rol s es, h 1re t protect 1 unction uati ,anda}
ngle f ure i he other nnels viding I pro on f ion actua . Th Functi also I orms t ESFAS f on of rting t AFW low 1 SG 1evel. EF C0 requ s four nds hf ater Level Low Low r SG to OPERARI l In MODE 1 or 2, when the reactor requires a heat sink, the SG Water Level-Low Low trip must be OPERABLE. The normal source of water for the SGs is priMtisidWjthe Main Feedwater (MFW) M System (not safety related). The MFW W3ystem4s only in operation in MODE 1 or 2 l M ' W ]hdRitW 11 hat. The AFW System is the ! safety related backup source of water to ensure that the SGs remain the heat sink for the reactor. During nonnal startups and shutdowns Q132:hjC5~1mmaratungshW R, the !".! Sy;ts melter 3RftenermlBip i provides feedwater to maintain SG 1evel. In MODE 3, 4, 5. or 6, the SG Water Level-Low Low REsaWoFTeWTFunction does not have to be OPERABLE because the ""' Sy;ta i; c.et in ;;,g;ti;n ;r.: tk reactor is not operating or even critical Milje1~4facff1icktfon3532MarTJB@clerflityjieff]E MiW-MIowiWlencticrisl. L Decay heat removal is accomplished by the Startup~Jeedfuup;orgjf (continued) WCGS-Mark-agp ofNUREG-H31-Basa 3.3 B 3.3 28 5/15/97
- RTS Instrimentation ;
B 3.3.1 , BASES , l. I . APPLICABLE -b. Low Power Reactor Trios Block. P 7 (continued) SAFETY ANALYSES, LCO. and *
"C" "raicr ";;;itim (T= L;,;,,,;;', . ,
' APPLICABILITY
. Undervoltage RCPs: and r e
. Underfrequency RCPs. l
-,. g g t 2 4 le3.3.(s-lj l
- Allowable ValueCare not applicable to the P 7 '
interlock because it is a logic Function and thus I has no parameter with which to associate an LSSS. . The P 7 interlock is a logic Function with train and i not channel identity. Therefore, the LCO requires one ;T r.21 ;a train of Low Power Reactor Trips [QM-443 Block, P 7 interlock to be OPERABLE in MODE 1.
~
The low power trips are blocked below the P 7 setpoint and unblocked above the P 7 setpoint. In MODE 2, 3, 4, 5. or 6 this Function does not have i to be OPERABLE because the interlock performs its l Function when power level drops below 10% power, ! which is in MODE 1.
- c. Power Ranae Neutron Flux. P 8 i
The Power Range Neutron Flux, P 8 interlock is actuated at ,,,,re,,i ;;1y 48% power as detemined by l- ";.;,;. "; t. a. fl ,. " " two out of four NIS power range chpanels deteeters. The P 8 interlock automatically enables the Reacto' Coolant Flow-Low Ms.3-ro\
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reactor trips on low flow in one or more RCS loops on increasing power. The LCO requirement for this trip Function ensures that protection is provided against a loss of flow in any RCS loop that could result in De conditions in the core when greater than ;.;,;,.exi;;.;.tcly 48% power. On decreasing power, the reactor trip on low flow in any loop is automatically blocked. l I ? f (continued) l. FCE% Mark-agp ofNUAEG-NJ1-Baser J.3 B 3.3 35 5/15/97 t
m _ _ _ _ _ _ _ _ _ _ _ _ _ . _ . . . . _ . . . . _ _ _ _ _ . _ . _ _ _ - . _ _ _ . _ _ . _ I RTS Instrumentation B 3.3.1 l BASES ! ACTIONS (continued) instrument loop, signal processing electronics, or bistable is - found inoperable, then all affected FunctionsWTs provided by that channel must be declared inoperable and the LCO Condition (s) entered for the protection FunctionM cgegjRis affected. IGbn'18uC9eguiri!staanne1MaiTaMeDrmre 81K1984"41fWlBlirNTperWylnu JilE3ms!E3MICMLE OgnifMos WaitTesttatred separa_teliJor_3anch3lll!pJ13E3p[N, hEMMDHW3] When the number of inoperable channels in a trip Function exceed those specified in one or other related Conditions associated with a trip Function, then the unit is outside the safety analysis. Therefore, LCO 3.0.3 must be immediately entered if applicable in the current MODE of operation. es usM M uswi.] Condition A applies to all RTS protection Functions. Condit addresses the situation where one or more required for channels /o one or more Functions are inoperable at the same time. The Required Action is to refer to Table 3.3.1-1 and to take the Required Actions for the protection functions affected. The Completion Times are those from fohhdTn7the referenced Conditions and Required Actions. 4. I B.1, B.2. -0 . 2.! _ 1 0 1 '- 14 3.3.&-1 j l Condition B applies to the Manual Reactor Trip in MODE 1 or 2. This action addresses the train orientation of the SSPS for this i Function. With one channel inoperable, the inoperable channel j must be restored to OPERABLE status within 48 hours. In this Condition, the remaining OPERABLE channel is adequate to perform the safety function. The Completion Time of 48 hours is reasonable considering that there are two automatic actuation trains and another manual initiation channel OPERABLE, and the low probability of an event occurring during this interval. l } (continued) WCGS-Mark-agp ofNUREG-1431-Bases 3.3 B 3.3 41 5115/97 _ _ _ __ ~ __ _ _ _
. . _ _ , _ . . _ . _ _ - ~ _ _ _ _ _ _ _ . _ . . _ _ ._ __ _ _ . _ . . _ . _ _ _ . RTS Instrumentation B 3.3.1 BASES - ACTIONS P.1 and P.2 (continued) on1 ne.mdtfitional chann61 isiedifu1r~ ed Aw1nitiakr1i' rem [q3.3-o2.} If the channet cannot be restored to OPERABLE status or placed in the trip condition, then power must be reduced below (:5) the P-9 setpoint within the next 4 hours. The 6 hours allowed to place the inoperable channel in the tripped condition and thegpc.u ED] 4 hours allowed for reducing power are justified in Referenceift ing able 7 cha i he bypass condit for up hours e perfo ro j s illanc esting of other nnels. T 4 hou ime (initi ustified Referenc- 7. f l 0.1 and 0.2 Condition Q applies to the SI Input from ESFAS reactor trip and the RTS Automatic Trip Logic in MODES 1 and 2. These actions , address the train orientation of the RTS for these Functions, i With one train inoperable, 6 hours are allowed to restore the train to OPERABLE status (Required Action Q.1) or the unit must be placed in MODE 3 within the next 6 hours. The Completion Time of 6 hours (Required Action 0.1) is reasonable considering that in this Condition, the remaining OPERABLE train is adequate to perform the safety function and given the low probability of an l event during this interval. The Completion Time of 6 hours (Required Action Q.2) is reasonable, based on operating experience, to reach MODE 3 from full power in an orderly manner and without challenging unit systems. The Required Actions have been modified by a Note that allows bypassing one train up to@urs for surveillance testing. provided the other train is OPERABLE. w redhk (brukded.) { Q3.Mr-3 } R.1 and R.2 Condition R applies to the RTBs in MODES 1 and 2. These actions address the train orientation of the RTS for the RTBs. With one train inoperable. I hour is allowed to restore the train to OPERABLE status or the unit must be placed in MODE 3 within the next 6 hours. The Completion Time of 6 hours is reasonable. (continued) WCGS-Mark-sqp ofNUREG-1431-Bases 3.3 8 3.3-52 5/15197
-=. . .- -. . - . - -. . .- -. - - .. - - _ -
i l i l 4 RTS Instrumentation B 3.3.1 1 4 BASES SURVEILLANCE SR 3.3.1.6 (continued) l The Frequency of 92 EFPD is adequate. It is based on industry operating experience considering instrument reliability and l operating history data for instrument drift. 5 SR 3.3.1.7 1 SR 3.3.1.7 is the performance of a COT every 92 days. A COT is performed on each required channel to ensure the ent+re channel will perform the intended Function. l Setpoints must be within the Allowable Values specified in Table 3.3.1 1.
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L . = :. hisskry.t -ep-t a 3.3-ej days is justified in Referenc pc,33.go] The Frequency of @tredKne(bru1: . 4ted) }G3.34r l l SR 3.3.1.8 a r4*te. SR 3.3.1.8 is the performance of a COT as described in os.3 -4e} SR 3.3.1.7. except and;1t is modified byfe,.4m6'Jote0 ARF $e D
@EFs that this test shall include verification that the P 6 and
~
P 10 interlocks are in thei required state for the existing unit (continued) WCGS-Mark-up ofNUREG-H31-Bases 3.3 B 3.3 59 5115l97
l 4 RTS Instrimentation
- B 3.3.1 BASES SURVEILLANCE SR 3.3.1.8 (continued)
{ conditionsJy1 observation of._the as. socia _tedJer_stssive i annRJcTitiorJtndow.~The Frequency is modified by a Note that 4 . allows this surveillance to be satisfied if it has been performed
- Nia.) ~ within[9 days of the Frequencies prior to reactor startup, 12
- ps.u-i_] hoor _ ?reducig power;below PJ10gand four hours after reducing power below P 10 ;id P 6. The Frequency of " prior to l startup* ensures this surveillance is performed prior to critical operations and applies to the source, intermediate and power ) range low instrument channels. The Frequency of "412 hours after reducing power below P-10" (applicable to intermediate and power j range low channels) and "4 hours after reducing power below P 6" l 1 (applicable to source range channels) allows a nonnal shutdown to ! l be completed and the unit removed from the MODE of Applicability 3 for this surveillance without a delay to perform the testing
- required by this surveillance. The Frequency of every 92 days thereafter applies if the plant remains in the MODE of Applicability after the initial performances of prior to reactor 1
startup~JEliours17ter;redut:Trkindlifer'WeleWM and four hours
- after reducing power below P 10 er P 6. The MODE of Ann 11cah111tv for this surveillance islWE~1Spztypr
- \q3'3,43} ]
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. l%_% , . . _ve l :135' v,,,;sil'W:PM c-LMcM*k 3'YC I[.0 70i 1. yGWO..076 IOuCid'*gyakgW h iate range channels '==- : --* m--- M2 h (1R)1nternec ano -- 4P 6Mr the source range channels;.aussand
( Gm f6, fg.R LW jistirRIsf _Once the unit is in MODE 3 _ l g 3gedalRe # rate UC '- V M i * 'd r ed l C#ft11s surveillance is no longer required. If power is to be maintained < P 10 for moreitharE121hoursjor < P 6 for more than 4 hours, then the testing required by this surveillance must be performed prior to the expiration of the 12]iourfoirM4 hour limit. I;ur heur; is e Theselttae71mits;are; reasonable, t4me based ~on~ operating.~egperience;to complete the required testing or place the unit in a MODE where this surveillance is no longer required. This test ensures that the NIS source, intermediate, and power range few channels are OPERABLE prior to taking the reactor critical and after reducing power into the applicable
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[os.3-Mb] ( 4 P-lbyr E'P- i.) for 4hc pc.rtcds dS CM**dd 8l*jV' (continued) WCGS-Mark-up ofNUREG-H31-Bases 3.3 B 3.3 60 5/15/97
e RTS Instrumentation B;3~.3.1 BASES SURVEILLANCE SR 3.3.1.9 REQUIREMENTS (continued) Sr 3.3.1.9 is the performance of a TADOT and is performed every rah 4 days, as justified in Reference 6 7. t wrum.% N#~' I This SR is modified by a Note that excludes verification of setpoints from the TADOT. Since this SR applies to RCP undervoltage and underfrequency relays, setpoint verification requires elaborate bench calibration and is accomplished during i the CHANNEL CALIBRATION. ) I SR 3.3.1.10 g. ggg I A CHANNEL CALIBRATION is performed every 18 months or approximately at every refueling. CHANNEL CALIBRATION is a , complete check of the instrument loop including the sensor. The l test verifies that the channel responds to a measured parameter ! within the necessary range and accuracy. CHANNEL CALIBRATIONS must be performed consistent with the ! assumptions of the mit ;psific setpoint methodology. Be ! differ;re; Mtuur, tra s. rat 'e; fard" vela; eri tre pr;?'.a; ) tut ";; 1;ft"_.v;l;; n;t k c r.;i; tat .itt, tra drift aHowenee !
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The Frequency of 18 months is based on the ;;;;ptier. Of er. 16-eenth assumed calibration intervcl in the determination of the magnitude of equipment drift in the setpoint methodology. SR 3.3.1.10 is modified by a Note stating that this test shall include verification that the time constants are adjusted to the prescribed values where applicable. This does not-include verification of' time delay relays. These are verified by response time testing per SR 3.3.L16. a s. 9[Ta s.$.cos ] SR 3.3.1.11 r, , raa g,u,,,q SR 3.3.1.11 is the perfomance of a CHANNEL CALIBRATION, as described in SR 3.3.1.10. every 18 months. This SR is modified by e two three Notes, stetwJ Note 1. states that neutron detectors are excluded from the CHANNEL CALIBRATION. Note 2' (continued) WCGS-Mark-up ofNUREG-1431-Bases 3.3 8 3.3 61 5115197
RTS Instrumentation B 3.3.1 l BASES .. SURVEILLANCE tre RCS rai; tere; ter.v;retur; d; tater 'n"' bip;; leep ;W REQUIREMENTS rete-(continued) Thi; tut .;ill verify the ret; 1;; co -Ar.;; tion for 'l;w frer., the cer; t; the n";. The Trcqarey i; ju;tified by th; a:=;-tion of ;n 10 cc,ath celibr;ti;n intervel in the deter.;.intien of the nenitud; ef
;;;ip;;.t drift in th;. ntg, int :.r.;'.y;i;.
SR 3.3.1.13 SR 3.3.1.13 is the performance of a COT of RTS interlocks every 18 nths. reAhhe (backet4 b 3srsa \ The Frequency is based on the known reliability of the interlocks and the multichannel redundancy available, and has been shown to be acceptable through operating experience.
' ~
G ara.the Rex.iorTn'e SR 3.3.1.14 p m ** B"***'. e chesm o.- - _ ___ j ( fn/P# l Reactor-SR 3.3.1.14 is the performance Tri@rOrnk;rPe;iti;hmontns. and the SI Input from ESFAS rh lb e**
- A* *~' I of a TADOT of t y u D (TADOT is performed every --
ng~TAcorj The h shall independently verify the OPERABILITY of thebh85dtM undervoltage and shunt trip Let'haffists13rtheilan63VBesetbr contads & Trig 41inef.4ctiJo]r the Reactor Trip Breakers and Reactor Trip ICA ba* Bypass Breakers. The Reactor Trip Bypass Breaker test shall include testing of the automatic undervolta trip. Cmec6% The Frequency is based on the known reliability of the Functions and the multichannel redundancy available, and has been shown to be acceptable through operating experience. The SR is modified by a Note that excludes verification of setpoints from the TADOT. The Functions affected have no setpoints associated with them. i l (continued) WCGS-Mark-up ofNUREG-1431-Bases 3.3 B 3.3 63 5/15l97 1
- . - - . . - - - - . - - _ . - - .. . - . - . - . . - - . - . - . - - .. . . . .=
l RTS Instrumentation B 3.3.1 l BASES
~
l l SURVEILL.ANCE SR 3.3.1.16 (continued) I REQUIREMENTS WMliMctualhWtestsion~~ttie' rtmaingleug39th1r MBRutStelEERDs!I!Blonsem.JBirottraIggg!rinsI I I R B M I B B H B a m B a isii 0 la s cis t e w i m m m N7 6 M 1 m. EREosat3mesmanniierancemetnessarqsAMIEEEEEE5 M N 6fng a; .c a.; , m y;3;;.;3;s G- . . . ,F i:- i e , y) . i, ., .. <, . XM:- IREm331IEiiiM#sEMLsairotrerrespreitsmirssgi - delilmstrilusitMIEslitt; IIgLWWecstais5llr;aiensor7 tesponsertta!!s' asstysymfugmpr tOMetarpieTaiteorient~1mioperationaTrsaristlicaganFammaal fielloiiMasTr~2thitTaareiliiersely'~aifficKTtjmWhenMZ mesmamaramannumsmaw:mmecamane 7.; .j p .- :
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- g. As appropriate. each M channel's response tgge must oe duaura. verified every 18 mon %s on a STAGGERED TEST BASIS. Eact!
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veriff cafian] sha117 include ~ atTeast 'one~ train isuchlthatM tggianf 4r6lBrifisOtliLhLstDMW3dgiif.7JTesting of the final actuation devices is included in the Vgrf1"k3lt_icatesteg. Response times cannot be determined during unit operation because equipment operation is required to measure response times. Experience has shown that these components usually pass this surveillance when perfonned at the 18 month Frequency. Therefore, the Frequency was concluded to be acceptable from a reliability standpoint. SR 3.3.1.16 is modified by a Note stating that neutron detectors are excluded from RTS RESPONSE TIME testing. This Note is i necessary because of the difficulty in generating an appropriate l detector input signal. Excluding the detectors is acceptable because the principles of detector operation ensure a virtually instantaneous response. Response tipe of m the neutron. flgsignal l (continued) WCGS-Mark-qp ofNUREG-1431-Bases 3.3 B 3.3 65 5115l97 1
ESFAS Instrumentation B 3.3.2 BASES APPLICABLE c. Safety Iniection - Contairmant Pressure - Hiah 1 SAFETY ANALYSES, (continued) LCO, and APPLICABILITY pressure si f the transmitter) located 11 side containment. s, the high pressure Function will not experience any adverse environmental conditions and the Trip Setpoint reflects only steady state instrument uncertainties. The~TtWSBtpo1C1Ys 3 X psig. Containment Pressure-High 1 must be OPERABLE in MODES 1, 2, and 3 when there is sufficient energy in the primary and secondary systems to pressurize the containment following a pipe break. In MODES 4, 5, and 6, there is insufficient energy in the primary or secondary systems to pressurize the containment following.a~primaryTorisecondary]!ipe break.
- d. Safety Injection Practurizer Preccure . Law This signal provides protection against the following accidents:
. Inadvertent opening of a steam generator (SG) relief or safety valve:
SLB: A spectrum of rod cluster control assembly ejection accidents (rod ejection): l Inadvertent opening of a pressurizer relief or safety valve:
=
LOCAs: and !
- SG Tube Rupture.
I 4_ --4 % The pressurizer pressure provides both control and l protection functions: input to the Pressurizer l N "^ Pressure Control Syctem, reactor trip, and SI. Therefore, the actuation logic must be able to withstand both an input failure to control system, ' which may then require the protection function (continued) i WCGS-Mark-no ofNUREG-H31-Bam 3.3 8 3.3 79 5/15/97
i i ESFAS Instrumentation ! B 3.3.2 j l l r BASES APPLICABLE b. Turbine Trio and Faadmter Isolation Steam J SAFETY ANALYSES, Generator Water Level - Hiah Hiah (P 14) LCO, and- (continued) APPLICABILITY The transmitters (d/p cells) are located inside containment. However, the events that this Function protects against cannot cause a severe environment in containment. Therefore, the Trip Setpoint reflects only steady state instrtment uncertainties. Ike M M ]ntlsJ p #stingB W M
- c. Turbine Trio and Feessater Isolation .Saffiy In.iection asT. shl A"N9 Turbine Trio and Feedwater Isolation are also M33# I sr is, M + M - ) initiatedb611F ions tinyatep.
(F te sol on F on 5 s fo he sa the s as the or r SI 1 . The ore, t r% -h.6arenot [ at in Tabl 3.3.2 1. Ins [ Function 1, SI, 5 4 ,il w = 4 = M (1s tin @eGod)for all initiati ions and
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- M "
requirements. M g ,3 3 q ! Tn' s - A. **h***~ '4 @fM'h l I*' " > ""
- 1 ~
a 3.s.En\ 1 Turbine Trip and Feedwater Isol s musc be OPERABLE in MODI @l and'2 xcept l 542sEp!Wasonstr3 MW al s, , ici ; :e:1;t;4 :;,An des are closedi and j de e;tivated t.;n tr "".: Cyets is in eg etica er.d gt%t.Q _ tk t;-, ire e..;r;ter ny h in ;gr;ti;n. In 9 3 3 .cr-i i MODES []) 4, 5, and 6, the MFW System and the turbine generator are not in service and this Function is
~
l not required to be OPERABLE.
- 6. Auxiliary Feedwater The AFW System is designed to provide i secondary side l l heat sink for the reactor in the event that the MFW System is not available.Whenirea~ctor_pouer5ETesUttenTm.
The system has two motor driven pimps and a turbine driven puep, making it available during normal unit operation L . ^.M.TL^.-. "i), during a loss of AC power, a loss of MFW and during a Feedwater System pipe break. The
- normal source of water for the AFW System is the condensate storage tank (CST) 'r.c,.- 11y r.;t n f;ty l l
(continued) FCGS-Mark-aqp ofNUJtEG-N31-Baser 3.3 B 3.3 103 5/15/97
ESFAS Instrumentation B 3.3.2 BASES ACTIONS G.I. G.2.1 and G.2.2 (continued) j The action addresses the train orientation of the SSPS and the master and slave relays for these functions. If one train is ! inoperable, 6 hours are allowed to restore the train to OPERABLE l status. The Completion Time for restoring a train to OPERABLE l status is reasonable considering that there is another train OPERABLE, and the low probability of an event occurring during , this interval. If the train cannot be returned to OPERABLE { status, the unit must be brought to NODE 3 within the next ! 6 hours and NODE 4 within the following 6 hours. The allowed I completion Times are reasonable, based on operating experience, to reach the required unit conditions from full power conditions in an orderly manner and without challenging unit systems. Placing the unit in NODE 4 removes all requirements for OPERABILITY of the protection channels and actuation functions. l In this HDDE, the unit does not have analyzed transients or t conditions that require the explicit use of the protection functions noted above. The Required Actions are modified by a Note that allows one train to be bypassed for up to 4 hours for surveillance testing provided the other train is OPERABLE. This allowance is based on the reliability analysis (Ref. 6 7) assumption that 4 hours is the average time required to perform channel surveillance.
,a iAc(cana s 4 bru M (H.1andH.2 jo 33 is-13 Condition H applies to the automatic actuation logic and actuation relays for the Turbine Trip and Feedwater Isolation !
Function. l l This action addresses the train orientation of the SSPS and the ! master and slave relays for this Function. If one train is i inoperable, 6 hours are allowed to restore the train to OPERABLE l status or the unit must be placed in NODE 3 within the following 6 hours. The Completion Time for restoring a train to OPERABLE : status is reasonable considering that there is another train OPERABLE, and the low probability of an event occurring during this interval. The allowed Completion Time of 6 hours is reasonable, based on operating experience, to reach MODE 3 from full power conditions in an orderly mannr and without (continued) I WCGS-Mark-aqp ofNUREG-1431-Baa3.3 8 3.3-121 5/15l97
i ESFAS Instrimentation B 3.3.2 BASES ACTIONS K.1. K.2.1. and K.2.2 (continued) requires the bistables to energize to perform their required action. The failure of up to two channels will not prevent the operation of this Function. However, placing a failed channel in the tripped condition could result in a premature switchover to the simp, prior to the injection of the minimum voltme from the RWST. Placing the inoperable channel in bypass results in a two out of three logic configuration, which satisfies the requirement to allow another failure without disabling actuation of the switchover when required. Restoring the channel to OPERABLE status or placing the inoperable channel in the bypass condition within 6 hours is sufficient to ensure that the Function remains OPERABLE, and minimizes the time that the Function may be in a partial trip condition (assiming the 'N. inoperable channel has failed high). Tije 6 hour CNetidhN
@is jestiffatila@pference'7] If the channel cannot be returned to OPERABLE status or placed in the bypass condition within 6 hours the unit must be brought to MODE 3 within the following 6 hours and MODE 5 within the next 30 hours. The allowed Completion Times are reasonable, based on operating experience, to reach the required unit conditions from full power conditions in an orderly manner and without challenging unit systems. In MODE 5, the unit does not have any analyzed transients or conditions that require the explicit use of the protection functions no above.
4n The Required Actions "are modified by a Note that allows placing a second channel in the condition for up to urs for surveillance testing . TP.; t;t;l .f 12 Pa r; t;
=--
1 ,.'. ..K',.. """ 1.,""".1"_'"'.,". T_'. . .... .. b '"" [ L.1. L.2.1 and L.2.2 Condition L applies to the P-11. P 12 Dr4 P 14] interlocks. With one olr aorfrigouiredlchannel(s) inoperable, the operator must verify that the interlock is in the required state for the existing unit condition bylobservation 3 fitheLassoci_ated permi_ss1 ( annunciator.Ewindow. This action manually accomplishes the function of the interlock. Determination must be made within 1 hour. The 1 hour Comp?etion Time is equal to the time allowed (continued) WCGS-Mark-aqp ofNUREG-1431-Bases 3.3 B 3.3124 5/15l97
ESFAS Instrumentation ! B 3.3.2 BASES SURVEILLANCE SR 3.3.2.5 REQUIREMENTS (continued) Sr 3.3.2.5 is the performance of a COT. A COT is performed on each required channel to ensure the enttre channel will perform the intended Function. Setpoints must be found within the Allowable Values specified in Table 3.3.11. 3"J2-Tf
";; differcre; bctacn th; currcat ";s found" velucs and tra picvious tcst ";s left" volucs nust bc ;;nsistcat with the drift clic = rec uscd in tF setp;;nt calculation. The setpoint shall be left set consistent with the assumptions of the current unit specific setpoint methodology.
The ";s f;und" r.ad ";s icft" valucs .T.ust ;is; bc rccerdcd 7.nd revir.cd for censi';tcrey with th; es ;unptiens of the survcilience f intcrvel cxtcasion 7.relysis (."af. 5 0 Jan applic;bic. The Frequency of 92 days is justified in Reference 6 7. SR 3.3.2.6 SR 3.3.2.6 is the performance of a SLAVE RELAY TEST. The SLAVE RELAY TEST is the energizing of the slave relays. Contact operation is verified in one of two ways. Actuation equipment that may be operated in the design mitigation H0DE is either allowed to function, or is placed in a condition where the relay contact operation can be verified without operation of the equipment. Actuation equipment that may not be operated in the design mitigation H0DE is prevented from operation by the SLAVE RELAY BLOCKDEJEST circuit. For this latter case, contact operation is verified by a continuity check of the circuit g a g ,A g ntaining the slave relay. This test is performed every (o 3,3.u -i ) U92 day rel ___ m , M 4r ,1 u w 2 3 W 7 O _bN
._~ _
_ _ JDn.$Ls1 _u __ __ __ .. . RF 1._ : w .w- _ _ _ _ Tfdr~gre,_L MK Ja_s2 ~ 71n I
@ lr teC_. Jour _unless; Khanf __
_ MWW SEda _ . _1 . "12E _ ._ _ . f l _Ji' frelty! . _. _ does, incl _ the:ci _ itry / tassociatd8Trtth1 tie in'f . ater? . ' trip ~ serieno1~ds~ nce'that I (continued) WCGS-Mark-up ofNUREG-1431-Bases 3.3 B 3.3 128 5/15/97
ESFAS Instrumentation B 3.3.2 BASES SURVEILLANCE SR 3.3.2.6 (continued) REQUIREMENTS _ _ MyJstrues-116 regdped safet1.JimetioDThe Frequency is adequate, based on industry operating experience, considering instrument reliability and operating history data. 4 gep3,3.ig\ ( The sR ie, modifisa lo a N1ote ht eu.Ludes slave.relap Ktc2., (K6 20, ._ K.e 2.2, Kd=2 , K6 3C), K740, ami.K74) Mch are. SR 3.3.2.7 gered $ SR 3.3.2 13 maa SR 3 3.2.14 SR3.3.2.7istheperformanceofaTADOTevery3E92 days. This test is a check of tM Loss of Offsite Power fimetTori.N tHe arctuaMsgZdeKcZes 4edTrithinEthe!sc@Ze drX3.s.wiarelthG sa dme 1.D EPstarticycuitsitesteLunder M3.E -
'Jadcrvelt;gc P,CP, ;nd m . ,, _ ion Tr;n;fcr en Suction Prc;;urc L;W furetion;. C;;h Turati;n i; tc;ted up t; ;nd ircluding. tre re;tcr tr;n;fer rel;y ceil;.
S.; tc;t el;; includ;; trip devicc; that providc ectu; tion
;ig el; dircctly t; tre SS"S. Oc SPs i; :. edified by ; Otc th;t cxcludc; verific;tien ;f ;ctp; int; fer reley;. Relay setpoints require elaborate bench calibration and are verified during CHANNEL CALIBRATION. The Frequency is adequate. It is based on industry operating experience, considering instrument reliability and operating history dat_a.
'the r1anual s.fe+3 l inhin Ters6il edependea41 cA g,3.cos
' verify opesa sia.ity orf We. hmAsditch tundervol 1
! and, shan} 4 rip contacts Ge boS +he. EcAch"'To,to SR 3.3.2.81 g w 3 g % # n.j , s p ., e,re , % a.o.
pett asJhe cm.,ta. cts 6r.saq d9ectivn o.chut im . SR 3.3.2.8 is the performance of a TADOT. This test is a check of the Manual Actuation Functions (SSPS)and AFW pump start on h(pdut 0 t ip of all MFW pumps BOP _Efs AS. It is perforued every
-g ,3.q 18 months. Each Manual Actuation Function is tested up to, and including, the master relay coils. In some instances, the test includes actuation of the end device (i.e., pump starts, valve cycles, etc.). The Frequency is adequate, based on industry operating experience and is consistent with the typical refueling cycle. The SR is modified by a Note that excludes verification of setpoints during the TADOT for manual initiation Functions.
The manual initiation Functions have no associated setpoints. (continued) WCGS-Mark-up ofNUREG-1431-Bases 3.3 B 3.3 129 5/15l97
' ESFAS Instrtmentatien B 3.3.2 I BASES i' SURVEILLANCE SR 3.3.2.9 REQUIREMENTS (continued) Sr 3.3.2.9 is the perfonnance of a CHANNEL CALIBRATION. nAh.(doould)Q13.Cs-l \ A CHANNEL CALIBRATION is perfonned every nths, or approximately at every refueling. CHANNE CALIBRATION is a complete check of the instrtment loop, including the sensor. Tt.e test verifies that the channel responds to measured parameter within the necessary range and accuracy. CHANNEL CALIBRATIONS must be perfonned con::1 stent with the asstaptions of the unit specific setpoint methodology. Oe differ;na ktuna tre current * = f r.d' v;1;u ;nd tre yr;;i a ; t ut "a 1;ft" ;;lan e s t M cerei; tint with tre drift ;11c r e; e xd ir. tre x^.rc int reA16 (backded.). {Q3.3.G-n I i The Frequency of months is based on the u s.rti;n of = 36-month maaillin calibration interval in the determination of the magnitude of equipment drift in the setpoint methodology. This SR is modified by a Note stating that this test en)XshowM include verification that the time constants are adjusted to the prescribed values where applicable. W tkfas W M marmtatioifwetwe:arlaneres;weriewerswanw ggpwentierattieggreyra r aie rai. s 2.3.2-2. rwte. s s.s.z 2 kmA ps.s-ss-SR 3.3.2.1C s bassa.,n h M+/atin3 %y si3nal. , [os.?.S51 - This SR verifies the individual channel ESF RESPONSE TIMES are less than o@r equai to the maximum values as accident analysis. Respone Time verification acceptance criteria are included in the T;;t.aini n;quirxe ;t ."cr.21 (Ref. 8 Individual component response times are not modeled in the analyses. The analyses model the overall or total elapsed time, from the point at which the parameter exceeds the Trip Setpoint value at the sensor, to the point at which the equipment in both trains reaches the required functional state (e.g., pumps at rated discharge pressure, valves in full open or closed position). For channels that include dynamic transfer functions (e.g., lag, lead / lag, rate / lag, etc.), the response time verification is may be performed with the tr; refer furetiere nt t; era with the (continued) WCGS-Mark-up ofNUREG-1431-Bases 3.3 B 3.3 130 5/15/97
ESFAS Instrumentation B 3.3.2 BASES SURVEILLANCE SR T3"2 ~10 (continued) REQUIREMENTS i r;;ultirs naur;d r;;ps; tin ;c--3 ;d t; th; ep,,regi;t; IS'a r;; p x; ti n . Alterret:ly. the caps; tin tut ;;n b;
,,;r'er a d d th th; ti a ce n t s t; ,ct t; th;ir 7.e mi 'i 12 FeJided th; r;;eired rspr,.; tin i; ;rel 3tic;11y ;;l;;l;ted.
en= irs th; time constants are set at their nominal values. The response time may be verified by a series of overlapping tests, otT483lI!rlietifications,(e;g.",- Ref~ . such that the entire resnonse time is measured. g p,3,593 RMiliaieTMMTmirffiedRaicteaTEijeMilt3MEtdstC1H angasresTerman!!stan overlassiga;erwestamannel NJtle'BuuustinriToGiBHicaWGBHggCrp~sege_ tEIE5'5 Nth!W!RSOhggkhsWDhe';testsDM__Tof% M=rmspperst.is~3sr'M7mm3MEeI28Islill l gginC"BBIREllericaR1stegLrtis~belmed!cri10conglatA4CresgfonseJgg teemingsresticEnotteror:powerJnterrist7mstsnviipLaceT EMjaMI@rvendof1" test'M EYlK TJ) 6~siticfEm13illasEEEE2ilEEM
.F a.1 ?. e. a QcNJggglig'SueMng RangimmsEntmensie iastrem3ll!aggBREE!Disin; I N3k!flKdhpe'tthes"W1SNiTc]peraTFinerificultich'Ut 136DNr igittTic'aignicrtNesttenW1hw I IEE2igl!!andRALW$mrifscat.itrigesmerrsensor;tspels emt?ie NM i TuiFBBi!campisTraeensor:resehse; times m must;bgverifieendir l toMycinytsie coeponentiin:operationrservicerand~re:-yertfled l MTtturtEasyTaihetseTraffhggW'1:8ame7 l 15~ERBriR3Neitt:retsrrmairMdgeisTielt'llunact~ tigposise3eme !
liregRac3363nrts3mliir furIrspliitwopgiezsliniewacd val 3GWNmitiNhere responselttae~gtild_Mffected21s m neigassettersensitirassemb1Locayansmitter; mg h5 3.3-ISD - I m-ssl tw Rt5PONSE TIME verification is performed on anQ8) month A gq 3.wri _1 STAGGERED TEST BASIS. %3_er,1_ficati_orEshalL;1acludelatleast caeWaitiFisk$ilth'at~ bot [trajnCarje VetMeidW'eastMpK36 unnuisgesting of the final actuation devices, which make up the bulk of the response time, is included in the testing of each channel. The final actuation device in one train is tested with each channel. Therefore, staggered testing results ti response time verification of these devices every 1 nths. The 18 month ak(fxxVud\&nk \ (continued) WCGS-Mark-up ofNUREG-1431-Bases 3.3 B 3.3131 5/15/97 i
. PAM Instrumentation B 3.3.3 4 BASES i ! SURVEILLANCE SR 3.3.3.1 (continued)
- REQUIREMENTS i or of something even more serious. A CHANNEL CHECK will detect gross channel failure: thus, it is key to verifying the instrumentation continues to operate properly between each I CHANNEL CALIBRATION. The high radiation instrumentation should
} be compared to similar unit instruments located throughout the j 4 unit. i
- Agi n .it criteria are determined by the unit staff, based on a i
combination of the channel instrument uncertainties, including
- i. 1 solation, indication, and readability. If a channel is outside j the criteria, it may be an indication that the sensor or the signal processing equipment has drifted outside its limit. If the channels are within the criteria, it is an indication that the channels are OPERABLE.
As specified in the SR, a CHANNEL CHECK is only required for those channels that are normally energized. The Frequency of 31 days is based on operating experience that demonstrates that channel failure is rare. The CHANNEL CHECK supplements less formal, but more frequent, checks of channels during normal operational use of the displays associated with the LCO required channels. SR 3.3.3.2 g,A4(wiuhA.) lo3.3.0-tj ! A CHANNEL CALIBRATION 1s performed every nths, or approximately at every refueling. CHANNEL CALIBRATION is a complete check of the instrument loop, including the sensor. The test verifies that the channel responds to measure parameter with the necessary range and accuracy. This SR is modified by a Note that excludes neutron detectors. ?,; c;1 0 r;ti;r, C 'er ,
. t 5.t ;
~
}_ h 1 Mhe Frequency is based on operating experience and 4D
, _. cons 1stency with the typical industry refueling cycle. " __
knhinment Radiatio'n Level (High Ry) cHAuusi cat.isa.Eriod mg I comid e4 in elec.ironi c- car ben h,en af +he chand, me+ &ctud % c. cestector. -for r& dac4Aea a. bare to sa./ar wd. a. en c. p, M c.). b re.t s ch ck. 4 me a s.+eche be.tw lo sa./h.- id.+h an i.; sfalled er pe,etal4a we sowca _. ____ _ - - Tcontinueyd ! WCGS-Mark-sqp ofNUREG-1431-Baset 3.3 B 3.3 152 QER,T En 3.3-152.] 5115197 ra 3.$-004 1
l f Remote Shutdown System I B 3.3.4 r B 3.3 INSTRUMENTATION i B 3.3.4 Remote Shutdown System f BASES BACKGROUND The_ Remote _St!utdown System.providesLthe_ control 1 room _qggratpr 9 losM 0 I with; sufficient instrtmentation Land controls;tofp) ace;and ev & - maintain the plant 11n,a_ safe,,s_huten_cgDdition from a~1ocation Olber. plan,_tlLelcontr.o]_ room s ,T_Ms_,capab111tlL,11gggssa Dg l
'*'$jh ptdtect,'$aij4).,theJossib111ty,that_the_cMtioDgpsyecops J ;
iggcespjplp;A safe shutdown condition is defined as HODE 3. . With the unit in H0DE 3, the Auxiliary Feedwater (AFW) System and the steam generator (SG) safety velves or the SG atmospheric reJief dump valves (AR9Vs) can be used to remove core decay heat and meet all safety requirements. The long term supply of water for the AFW System and the ability to borate the Reactor Coolant System (RCS) from outside the control room allows extended L operation in H0DE 3. If the control room becomes ina sible, opera can I C W I -
)
establish control at the 111ary t nel (gD, i and place and maintain the unit H0DE 3. t all trols and L necessary transfer switches are located at the cemete auxiljgy shutdown panel. Some controls and transfer switches will have to be operated locally at the switchgear, motor control panels, or i other local stations. The ellt automatically reaches H0DE 3 j following a unit shutdown anct can be maintained safely in H0DE 3 ' for an extended period of time-W& The OPERABILI1Y o_fothe 6ddirtWDremote shutdown control and pas-z41 instrumentation (Nstj&., ensures there is sufficient information available on selected unit parameters to place and maintain the unit in MODE 3 should the control room become inaccessible: 9 TOTAL NO. READOUT (medttis]tr 0F CHANNELS L0ddidN N33-M l l k l RCS. Pressure - Wide Range - 2 Auxiliary Shutdown Panel l E. Reactor Coolant Temperature - 4 Auxiliary Shutdown Panel j Cold Leg Source Range, Neutron Flux 2 Auxiliary Shutdown Panel i a (continued) i WCGS-Mark-up ofNUREG.H31-Bases 3.3 B 3.3 154 5l15l97 i J
-y _ - - - , , , - . . . - . - , - - - - - , - - -
y.~. - -,
Remote Shutdown System B 3.3.4 BASES SURVEILLANCE SR 3.3.4.2 (continued) necessary. The Surveillance can be satisfied by performance of a l continuity check. This will ensure that if the control room becomes inaccessible, the unit c be plac and maintained in i g kfHary utdown anel and the local MODE 3fromther;;et;@Omonth ,,ag,.(druwd 4 ~ centrol stations. TheQ requency 1 based on the need to g 3.3.ce- O perform this Surveillance under the conditions that apply during a plant outage and the potential for an unplanned transient if the Surveillance were performed with the reactor at power. (However, this Surveillance is not required to be performed only during a unit outage.) Operating experience demonstrates that remote shutdown control channels usually pass the Surveillance test when performed at the 1 month Frequency. redivAa. (brah.tecQ b 3.1 Cr-l] SR 3.3.4.3 CHANNEL CALIBRATION is a complete check of the instrument loop and the sensor. The test verifies that the channel responds to a measured parameter within the necessary range and accuracy. redths.cbr, cute 4 p:s.3.cc i g The Frequency of months is based upon operating experience and consistency with the typical industry refueling cycle. No_tesXend_Khave,been..added;to_excludelthelNeutron_ detectors (Note ~11,11thireactor trip, breakers ~ and:RCPfbreakers TNot.e]). fnam'DUNEI.1031_ BRA _ TIE
- lTR 3.3-004 }
5" 2.2.4.4 5" 3.3.4.t is tre grie ;ere; cf ; T=T cv;ry 1" senths. Si; t;;t should verify the 0"C"XILI"I ;f th; r;;;ter tip br;;k;rs (""s' egn end ci;;;d indic; tion ;t~ttrM= lip;;Jt;I.;;.;l en th; r;;et; shutdow , gral, by ;;tuating the "";. Th; fre acncy is be;;d upon egr; ting cgricre; ;nd ;;nsist;ncy with the typi;;.1 industry refueling cut;;;. PIFERENCES 1. 10 CFR 50. Appendix A, GDC 19. WCGS-Mark-up ofNUREG-1431-Bases 3.3 B 3.3 159 5115l97
i LOP DG Start 2nstrumentation l B 3.3.5 i BASES 1
'6c;;. at criteri; er; iter;; ired by the ur.it ;t:ff. b;xd en e
- 'iratis ;f tt.; ds..;l in;t ; eM u..;;rt;intic;. ireludirs indi;;ti s ad r; N ility. If ; da.el i; eat;id; the criteri;. it s , b; en ir.di;etica trat tre crer, er tre ;i ral j pre;;nir6 ;quis M P.n drift;d cut;ii it; li;;;it.
l l We Ir;;.ca;, i; bs;d ;n q,;r;tirs ;gricre; trat d, ,a;tri.t;; l 1;a.41 f;ilui- i; r;r;. Se 0".'" $ L 0ll00X :;;ppi, C ; i n ; i l fr, ;;el, but cer; fr;;.,.at. ;ted; cf dsaci; durirs rer;;el 7,p;retgrel un of the di:;pi;y; n:;;;i;t;d .;itt, the LOO .;;;; red l SR 3.3.5.2 r.Ala (bachde.O l43.3.0.-t } SR 3.3.5.2 is the performance of a TADOT. This test is performed every 31 day The test checks trip devices that provide actuation signals directly, bypassing the analog process control equipment. For these tests, the relay Trip Setpoints are verified and adjusted as necessary. The Frequency is based on the known reliability of tht relays and controls and the multichannel redundancy available., and has been shown to be acc able through operating experience.fif the measwecL'g33,w ( setpo M l -tv-ip da.vsc,dop nd e,u:.eed. OPER.ABLE
- a. u ccmsd.uu.d_ the. Allot cabh.
, Valua., ib. i SR 3.3.5.3 SR 3.3.5.3 is the performance of a CHANNEL CALIBRATION.
l ( ~ - - _
\ (W. 3.3.ED)
The s int s well the re se to oss of vditage a ' aded tage t , shall ~ lude a ngle t , erif tion t the tri occurs in t _ equired imeddy./ ' g3,g g A CHANNEL CALIBRATION is performed every 18 months, or , approximately at every refueling. CHANNEL CALIBRATION is a i i complete check of the instrument loop including the sensor. The test verifies that the channel responds to a measured parameter
.within the necessary range and accuracy. ,
i l (continued) WCGS-Mark-up ofNUREG-1431-Bases 3.3 B 3.3165 5115197 :
LOP DG Start Instrumentation B 3.3.5 BASES SURVEILLANCE SR 3.3.5.3 (continued) REQUIREMENTS reduc bracM @3 3 613 The Frequency of h8 months is based on operating experience and consistency with the typical industry refueling cycle and is justified by the assumption of an nth calibration interval in the determination of the magnit of equipment drift in the setpoint analysis. (d\me. (bmtdcA)lQ3.341\ REFERENCES 1. fUSAR, Section 8.3.
- 2. RISAR, Chapter 15. IC *h*^O'M
-J {c? 2-0 \
3.
'O;jt Spccific RTS/Esrb _ _ . _ eari. y Ana _ .
gogy p e sm; the j_ 3T _p_ memw r- w 4 do.7 3 5s 6R 3.3.54 G> ha pkmmca d She qtMed. respons
+iec verificahon eveg to montN on a srAusem.c, naw Basis . Res gonw~firse. VeriO ca%n aQmu criteri> are:
nusTs ATid(.c SitrNAL AWD s:uuc.Tiou RNOW'ME Loss ON VMt.f a, . 4ky Be unde <volby. - 114 e nds t , .f vontge,
- b. 4kv En lindervolfy-- (at44 p ads 6ria. O g aAed Wihy.
Each vuific:stih s61l ade. al \ cad anciv$n wh 4kt bok iv4 ins are verified at least onca. per % vnenb.
%. .s -
WCGS-Mark-up ofNUREG-1431-Bases 3.3 8 3.3-166 5/15197
ADDITIONAL INFORMATION COVER SHEET ADDITIONAL INFORMATION NO: O 1-A GEN APPLICABILITY: DC, CP, WC, CA REQUEST: Generic Administrative Changes Comment: Provide one DOC for each LCO to justify CTS changes that involve reformatting or word differences without any change in meaning or operation of the plant. FLOG RESPONSE: As discussed in the transmittal letter and the " Methodology For Mark-Up of Current TS"in the back of Enclosure 2, the CTS has been marked up to reflect the substance of NUREG-1431, Revision 1. In general, only technical changes have been identified. However, some non-technical changes have also been included when the changes cannot easily be determined to be non-technical by a reviewer, or if an explanation is required to demonstrate that the change is non-technical. DOC 1-63-A was created and added to the top of the page for each CTS Section 3.3 Specification. DOC 1-63-A states:
"All reformatting, renumbering, and editorial rewording is in accordance with the Westinghouse Standard Technical Specifications, NUREG-1431.
During the development certain wording preferences or English language conventions were adopted. As a result, the Technical Specifications (TS) should be more readily readable, and therefore understandable, by plant operators and other users. During the reformatting, renumbering, and rewording process, no technical changes (either actual or interpretational) to the TS were made unless they were identified and justified". ATTACHED PAGES: Encl. 2 3-1,3-13,3-39,3-43,3-46 Encl.3A 14 Encl. 3B 14 l l l i
+
3/4 3 INSTRUMENTATION 3/4 3.1 REACTOR TRIP SYSTEM INSTRUMENTATION - l-O-4 i LIMITING CONDITION FOR OPERATION O 3.3.1.^.:: . : : r. The Reactor Trip System instrumentation (Yor each functiob'--- '- - '
- r!:d: of Table 3.3-1 shall be OPERABLE.
APPLICABILITY: ^ : de c'- in Table 3.3-1. ACTION: As shown in Table 3.3-lb vt41.A~~
- a. a_n i SURVEILLANCE REQUIREMENTS 4.3.1.1 Each Reactor Trip System instrumentation channel and interlock and I the automatic trip logic shall be demonstrated OPERABLE by the performance of the Reactor Trip System Instrumentation Surveillance Requirements specified in Table 4.3-1. ge;QA, lQS.3-55]
4.3.1.2 Theh REACTOR TRIP SYSTEM RESPONSE TIME of each Reactor trip function shall be demonswesetw6ffs@to be within its limit at least once per 18 months @ 7T-02-I'G1 ~ < CSTAGGERED TEST BASIS) Neutron detectors are exempt from response time testing. Erh : :: 6:!! b~""
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t l INSTRUMENTATION 1-bS-A 3/4.3.2 ENGINEERED SAFETY FEATURES ACTUATION SYSTEM INSTRUMENTATION LIMITING CONDITION FOR OPERATION - l-A GEkil 3.3.2 The Engineered Safety Features Actuation System (ESFAS) instrumentation 2-01-A for each function *-- '- ' ' ^ '- ' shown:.Lin.L.Table 3.3-3 shall be OPERABLE 2-03-LG
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- c. With an ESFAS instrumentation channel or interlock inoperable, take the l ACTION shown in Table 3.3-3.
3 1-01-A
- Separate Condition entry is allowed for each Functh WOLF CREEK- UNIT 1 3M 3-13 Amendment No. S4,93 Mark-up ofCTS3M,3 5/15M7 i
l l INSTRUMENTATION 3/4 3.3 MONITORING INSTRUMENTATION . g RADIATION MONITORING FOR PLANT OPERATIONS g g,qgQ g LIMITING CONDITION FOR OPERATION 3-01-A 3.3.3.1 The radiation rnonitoring instrurnentation channels for plant operations l shown in Table 3.3-6 shall be OPERABLE with their Alarm / Trip Setpoints within the specified limits. j APPLICABILITY: As shown in Table 3.3-6. ACTION: .
- a. l With a radiation monitoring channel Alarm / Trip Setpoint for plant 3-02-M . I i
operations exceeding the value shown in Table 3.34, edsusHhe - - - -
? ';: t ..:^2.:- 5 P '" ' ' ' 5:= Or declare the channel inoperable.
l
- b. With one or more radiation monitoring channels for ptsnt operations inoperable, take the ACTION shown in Table 3.3-6.
j c. _The provisions of Specificatioc- 3.0.3 rd 3.0.4 are not applicable 3-06-A
- (the RCS Laekage C;^_
- E--. instru .;. 6 son..
- d. The provisions of Specification 3.0.3 are not applicable to the Fuel ' 3-06-A Building Exhaust Gaseous Radioactivity instrumentation. - -
I l l SURVEILLANCE REQUIREMENTS 4.3.3.1 Each radiation monitoring instrumentation channel for plant operations shall be demonstrated OPERABLE by the performance of the CHANNEL CHECK. CHANNEL CALIBRATION and ANALOG CHANNEL OPERATIONAL TEST for the MODES and at the fre-quencies shown in Table 4.3-3. l l-l l l I i a WOLF CREEK- UNIT 1 3/4 3-39 Amendment No. Mark-up ofCTS3M. 3 $/1$/97
l l INSTRUMENTATION _ REMOTE SHUTDOWN INSTRUMENTA' ION LIMITING CONDITION FOR OPERATION 3.3 3 5 The Remote Shutd S stem .. n!!:in;;in:!r_r:nt:t!:n for 7-01-A
^
(each Functio]n iven in Table 3.3- 2nd 5: :r "!: ; hrtf: m pen:!'ASPQ umda leh- ' 7-06-LG
, eenwe6s shaII be OPERABLE '. " r:12 !: ;^;!: d : .:r:! to the - nt=! re-( m4*leta. p 3,g g APPLICABILITY: MODES 1,2, and 3.
ACTIONC 101-A ~
.. u -w. a f a. With the number of OPERABLE Remote Shutdown 7-01-A7
~ ' ' ' " ' ~~ ~
ehennels less than the Required number of Functions ?" '- .rm Ch:nn:.; as required by Table 3.3-9, r e the inoperable channel (s) Functions o OPERABLE status within 744-LS-15] ays; otherwise, ~~ - ~ ~ be in at least HOT STANDBY within the next 6 hours and in HOT SHUTDOWN within the following 6 hours. l
- b. With the ASP controls in , restore the inoperable ASP controls to OPERABLE status within ays; otherwise, be in at least HOT 7 04.LS.15 -
STANDBY within the next 6 urs and in HOT SHUTDOWN within the - - following 6 hours.
- c. The provisions of Specification 3.0.4 are not applicable.
I i SURVEILLANCE REQUIREMENTS 4.3.3.5.1 Each remote shutdown monitoring instrumentation channel s ll be demonstrated OPERABLE by performance of the CHANNEL CHEC nd CHANNEL '7-09-LS-43 CAllBRATION at the frequencies given in Table 4.3-6. ^ f,q 4.3.3.5.2 The ASP controtsk redr's/tMhall be demonstrated O_PERABLE at least once per 18 months (byyptrattpr 91stch aptejl.s6mporten_tJr6 MAG e5P) '1"13*L N 12.3.S.2 Se ;= ::': : ' ?;::T::!:n 10M := n:t :;;"::r: fer :ntr; H: ?.'^M ? f-' 5: trin; dir:n er!!!:r; f::f;;;t:: pum; : th: :!: :: ':j: _.
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? V2 20-604 rkuiral. ASPewds) LR O Separate Condition entry is allowed for each Functionb p 3,3_q 4 l 1-01-A
" For each required instrumentation channel that is normally energized. 7-09-LS-43 l
l WOLF CREEK- UNIT 1 3M 3-43 Amendment No. 89 Mark-up ofCTS3M. 3 S/15/97 l
INSTRUMENTATION POST ACCIDENTMONITORING INSTRUMENTATION Q l-A GEd ] LIMITING CONDITION FOR OPERATION l l 3.3.3.6 T pos ccident monitoring instrumentatiohr each Funchdenne!: [841-A] ~ ~ shown in Ta e .3-10 shall be OPERABLE.
~ ~
APPLICABILITY: MODES 1,2, and 3. ACTION: (separate Condition Entry is a: lowed for each Functioh 93g 2._ a - ..
- a. VAIC': nuri:: Of OPEP/?LE ^'f f:n' m:n52:!n; inct=m:ntz'J: . d:nn;!:' ::
^2n S Ter! '! uni : M C5:nn: : :t:: - " Td': 2.210.5Wsth one or more . . . . _ _ _ .
Functicns with one required Channel inoperable, except for Functions 8 and 3 8-03-A . restore the snoperable dannel(s) to OPERABLE status within 30 days or prepare and X8_0S-A _ . submit a Special Report to the Commission pursuant to Technical Specification 6.9.2 within the following 14 days outlining the preplanned attemate method of monitoring, the cause of the inoperability, and the plans and schedule for restoring the channels to OPERABLE status.
- b. V."' te rumt:: M CPEP/SLE :::'f:" m:n!!;.-In;;inehmentationehennels, Jg.03.A (one or more Function with two Required Channels inoperable.)except the for 8-05-A enehment Functions 10,16 and 18 (Gontainment hydrogen Concentration Level Containment Radiation Level and the Reactor Vessel Level Indicating System),h CFuncbon 8 or 11 with one Required Channel per SG inoperable;' :: Sen S: Mamum CP:nn:2 CPEPf?LE r x :..cn Of Td'r 2.210, restore one channel to OPERABLE status within 7 days; otherwise, be in at least HOT STANDBY within the next 6 hours and in HOT SHUTDOWN within the following 6 hours.
- c. With two the-number-eW4iiRABL.E channels for inetsume4 Functions 16 and 18 (Containment Radiation Level and the Reactor Vessel Level Indicating System) ,
!::: Sen 5 - " mum C' nn : OPEP/SLE r;rnm:nt M Td!: 2.2 t0, ""j:!:
t: pr?': n:d :": met n;"cd Of men":Mn; S: 0;;re; Met: ; :: :' $} ;"'" 72 M32A' 5 l 50 = nd eithei estore one inoperable channel to OPERABLE status within 7 days, or 8-04-LS-17 prepare and subn..t a Special Report to the Commission pursuant to Technical Specification 6.9.2 within the following 14 days outlining the preplanned attemate method of monitoring, the cause of the inoperability, and the plans and schedule for restoring the channels to OPERABLE status.
- d. With S: number Of OPEP/S' " "'enn:!: fer t two ntainment hydrogen concentration level monito _ .. ._. . he . 'm u- . . .8-03-A
~~~ ~~
C5:nne!: OPEPfSLE r;d:r:nt _. . die 3.210, restore one channe! to l OPERABLE status within 72 hours; otherwise, be in at least HOT STANDBY l within the next 6 hours and in HOT SHUTDOWN within the following 6 hours.
- e. The provisions of Specification 3.0.4 are not applicable.
SURVEILLANCE REQUIREMENTS 4.3.3.6 Each accident monitoring instrumentation channel shall be demonstrated OPERABLE by performance of the CHANNEL CHECK *and CHANNEL CALIBRATION at the frequencies shown in Table 4.3-7. For each required instrumentation channel that is normally energiz 7-09-LS-43 l l WOLF CREEK- UNIT 1 3M 3 46 Amendment No. 89 Mark-up ofCTS3M. 3 S/lSR7
CHANGE MutBEB MSE DESCRfPTION 1 54 LS 37 Not applicable to Wolf Creek. See Conversion Comparison Table (Enclosure 3B). 1 55 LS 39 Applicability Note [*] and ACTION Statements [5.a and 10] for Functional Units [1. 6.b. 19. and 20] of current TS Table 3.31 are modified to provide an alternative to opening the reactor trip breakers (RTBs) while still assuring that the function and intent of opening the RTBs is met. As currently worded, these ACTION Statements result in a feedwater isolation signal (FWIS) when in MODE 3 with a T, less than [564*F. USAR Table 7.3-14 and USAR Figure 7.2-1 (sht.13) detail the FWIS generation on the coincidence i du of P 4 and low T.,.] A more generic action, which I cwh5a *#M assurMhe rods are' fully inserted and cannot be
- withdrawn, replaces the specific method of precluding Wa.ts.eed i rod withdrawal. The revised Applicability and ACTION
} rg. .sJ M Statements still assure rod withdrawal is precluded.
This change does not involve any safety impact and is consistent with traveler. j 1-56 h Not applicable to Wolf Creek. Comparison Table (Enclosure 38). See Conversion W ,-sM l 1 57 LG Current TS Table 3.31 Functional Units [12.a and 12.b] ; are combined per traveler TSTF - 169. The Required Channels. ACTION Statement, and Surveillance ! Requirements are the same for both Functional Units. j The only difference between the two is the ' Applicability which could lead to entry into ACTION ; Statement 6 for Functional Unit [12.a]. followed by a i power reduction below P 8 exiting the Applicability and required actions for that Functional Unit, and subsequent re entry in ACTION Statement 6 for l Functional Unit [12.b]. This would involve an improper cumulative A0T of 12 hours before tripping an inoperable channel, beyond that evlauated in WCAP 10271 and its Supplements. The relationships between these l Functional Units and permissives P 7 and P 8 are moved l to the ITS 3.3.1 Bases. 1 58 A Not applicable to Wolf Creek. See Conversion Comparison Table (Enclosure 3B). 1 59 h Not =glic2A b LMf Crer.k. 5 G,mnia, . c.#,..mm. u.,m , i.s o j 1 60 Not used. ! 1 61 M Not applicable to Wolf Creek. See Conversion ( Comparison Table (Enclosure 3B). l hasa=r 3A -L4-) l WCGS-Description of' changes to CTS 3M.3 14 S/2S/97
INSERT 3A-14 1-62 A Not applicable to Wolf Creek. See Conversion Comparison Table (Enclosure 3B). 1-63 A All reformatting, renumbering, and editorial rewording is in accordance with the Westinghouse Standard Technical Specifications, NUREG-1431. During the development certain wording preferences or English language conventions were adopted. As a result, the Technical Specifications (TS) should be more readily readable, and therefore understandable, by plant operators and other users. During the reformatting, renumbt ring, and rewording process, no technical changes (either actual or interpretational) to the TS were made unless they were identified and justified.
} Q1-23 J 1-64 A The refueling interval TADOTs for Functional Units [1 and 17] in CTS Table 4.3-1 have been revised to include existing Note [10, "Setpoint verification is not required."] Likewise, refueling interval TADOTs for Functional Units [1.a. 2.a. 3.a.1), 3.b.1), 3.c.1), 4.a. 6.a. 9.a and 11.b] in CTS Table 4.3-2 have been revised to add a new Note [5],
" Verification of setpoint not required." This change is administrative in nature since the subject Functional Units have no setpoints associated with them. This change does not affect the operating limits or manner in which the plant is oper6ted. There are no changes to current plant practices for the performance of these TADOTs since there are no setpoints to verify for these Functional Units. This change is strictly an acknowledgement that the corresponding ITS SRs 3.3.1.14, 3.3.2.8 and 3.3.2.11 have an explicit Note to this effect. .
1-65 A Seven slave relays are listed in Note (3) to CTS Table 4.3-2 for an exception to the quarterly SLAVE RELAY TEST. These slave relays are associated with the following ESF actuation signals: K602 (SIS); K620 (turbine trip and main feedwater pump trip); K622 (CIS-A): K624 (CIS-A): K630 (CIS-A and the CIS-A input to containment purge isolation and control room ventilation isolation); K740 (SIS, RWST low-low): and K741 (SIS, RWST low-low). ITS SR 3.3.2.6 has been revised with a Note per JFD 3.3-19 that excludes these seven slave relays from the quarterly surveillance. Based on the differing Functional Unit MODE Applicabilities, new ITS SRs 3.3.2.13 and 3.3.2.14 have been added under JFD 3.3-19 to cover the surveillance frequency applicable to these slave relays. The only slave relay associated with containment purge isolation and control room ventilation isolation, K630, has the extended surveillance frequency under new ITS SR 3.3.2.13. Based on feedback received from the NRC reviewer at a meeting on September 16. , 1998, the 90 days cited in Note (3) has been changed to 92 days to { j follow standard convention for an exception to a quarterly l surveillance frequency. 1 1 1
- - _ - _ _ . . _ _ _ . ~ _ _ . . _ . _ _ _ _ - - . . . _ - - ..__ _ _ ___. __.m- _ . ._. __ _ ._
INSERT 3A-14 (continued) Q 3-Q\ 1-66 LS-45 The CTS allows certain inoperable channels, or for some plants one other channel, to be bypassed for testing per Specification 4.3.1.1 or 4.3.2.1. The intent of the bypass is to allow testing that will verify that the channel has been restored to an OPERABLE condition and can be returned to service. The allowed bypass time for testing i has been evaluated for its impact on the safety analyses. It has been determined that the impact of the allowed bypasses is minimal. Whether the bypass is for setpoint verification or response time verification has no impact on the safety analysis. This change would delete the reference to Specification 4.3.1.1 and 4.3.2.1 in the allowed bypass notes contained in certain CTS ACTION statements, thus permitting any testing needed for restoration of the inoperable j function. l l I l L 1 1 1 l I I i 4 l-I
- . - , - - _ . - , - , , . . - . - . . - - . - - -- -m- - _
mmgT 3B-14 f CONVERSION COM PARISON TABLE - CURRENT TS 3/4.3 rage 14 of 3e TECll SPEC CllANGE APPLICABit ITY NtlMBFR DESCRIPTN)N DIABLO CANYON COMANCHE PEAE WOI.F CREEK CAI.IAWAY 1 61 If the requirements of current CPSES ACTION Statement 6 are No see Yes No - see 'No - see-M not met. LCO 3.0.3 would be entered. In accordance with CNf 1-19-LS-8. CNf 1 19 LS 8. CNf 1-19 LS 8. the ISTS. this ACTION Statement is revised to state that. if the ACTION requirements are not met, the plant must be taken below the P-7 interlock setpoint within the next 6 e hours. 2 01 The Engineered Safety Features Actuation System Yes Yes Yes Yes A Instrumentation [] Allowable Values are moved to ITS Table 3.3.2-1. 2 02 CTS ACTION b.1. Equation 2.2-1, and the values for Total No - not in current No - not in current Yes Yes A Allowance (TA). Z, and Sensor Error (S) are deleted. TS. TS. consistent with NUREG 1431 Rev. 1. 2 03 tie Engineered Safety Features Actuation System No - retain in ITS. Yes - moved to Yes - Moved to ITS Yes - Moved to ITS LG Instrumentation Trip Setpoints are moved to a licensee Bases. 3.3.2 Bases. 3.3.2 Bases controlled document. i The requirements stipulated in ACTIONS a and b are moved to Yes Yes Yes Yes 2-04 LG ITS Table 3.3.2-1. with explicit direction contained in the ITS ACTIONS Bases. TheFunctionalUnitforContainment@ urge] Isolation. CTS. No - see Yes Yes 2 05 Qhr<MC3HL.38 A') M 3.c. is moved to improved TS 3.3.6. Improved TS 3.3.6 adds CN 02 20-A W2-os) C5 requirements on the OPERABILITY of the containment { purge radiation] monitors and extends the Applicability for the , [ Manual Initiation and BOP ESFASlactuation logic to include during movement of irradiated fuel assemblies within containmentQndCoreAlterations} _ - . = - - - - _-___ 2-06 Functional Unit 4.a.1 of current TS Tabl .3-33 s been No - retain CTS -JV- Ws mat 4CIGfQPA Yes
-25"]
LS-33 deleted. C 2 W4 S/1S/97 WCGS-CONVERSION TABLE- C153M.3
INSERT 3B-14 TECH SPEC CHANGE APPLICABILITY NUMBER DESCRIPTION DIABLO CANYON COMMANCHE PEAK WOLF CREEK CALLAWAY 1-62 In a Callaway-specific change, ACTION 7 in No No No Yes A CTS Table 3.3-1 is moved from Functional lGyasrest) Units 13.a and 13.b to Functional Unit 13.c 1-63 All reformatting, renumbering, and Yes Yes Yes Yes A editorial wording is in accordance with the Westinghouse Standard Technical {G?O-AGEbal Specifications, NUREG-1431. 1-64 Notes are added to Tables 4.3-1 and 4.3-2 Yes Yes Yes Yes A to exclude setpoint verifications during TADOTs on Functional Units that do not have gp.g3, } setpoints associated with them. 1-65 Explanation of ITS treatment of seven slave No No Yes Yes A relays with extended surveillance frequency. d>2-4El 1-66 This change would delete the reference to Yes Yes Yes Yes LS-45 Specification 4.3.1.1 and 4.3.2.1 in the l 3 allowed bypass notes contained in certain . Q 3633 CTS ACTION statements, thus permitting any testing needed for restoration of the inoperable function. 1-67 This change revises DCPP CTS ACTIONS 13 and Yes No No No M 29 to provide specific shutdown requirements to exit Applicability, in lieu kf>3 3-4C \ of applying CTS.
l ! ADDITIONAL INFORMATION COVER SHEET l l ADDITIONAL INFORMATION NO: O 2-LS GEN APPLICABILITY: DC, CP, WC, CA i i ; REQUEST: Generic LS DOCS i Comment: For each proposed less restrictive change discussion include a clear l l statement of the CTS requirement, the CTS reference, a statement of the proposed ITS i requirement, and the proposed ITS reference. For an example of this problem, refer to the first paragraph of LS-17. Based on 8/14/98 meeting comment responses will be addressed in individual LS NSHC. ! FLOG RESPONSE: No specific response will be given to the comment; however, this RAI ! number will be used for tracking purposes where NSHCs in Enclosure 4 were revised outside of a specific comment (e.g., the response to , l Comment Number Q 8-04 addresses the NSHC cited in the comment). See attached revisions. ATTACHED PAGES: l Encl. 4 LS-8 page 34 LS-11 page 40 LS-40 page 62 1 1 I l i
IV. SPECIFIC NO SIGNIFICANT HAZARDS CONSIDERATIONS
~ '
NSHC LS 8 10 CFR 50.92 EVALUATION l FOR I TECHNICAL CHANGES THAT IMPOSE LESS RESTRICTIVE REQUIREMENTS WITHIN THE TECHNICAL SPECIFICATIONS kg ) I 4tl. win 3 hh exA&e ApphesHhkh This change ref ects a revision to current ACTION Statement (6] If the requirements of current ACTION tatement[6]are not met. LCO 3.0.3 would be entered. This ACTION Statement is vised to state that, if the ACTION requirements are not met. THERMAL POWER must reduced to below the P 7 interlock setpoint within the next 6 hours c f-FAM)the unctional Units that impose ACTION Statement [6 Pressurizer Pressure - l Low. Pressurizer Water Level - High. Reactor Coolant Flow -) Low. Two LoopI and below P 8). RCP Undervoltage, and RCP Underfrequency, are automatically blocked below P-7 and an Applicability Note has been added accor ngly. The Reactor Coolant , Flow Low (Single Loop) reactor trip function does not ave to be OPERABLE below the i P 8 setpoint: however, the Required Action must take t plant below the P 7 setpoint, if an inoperable channel is not tripped within 6 hours, due to the shared components between this function and the Reactor Coolant Flow - L (Two Loops) trip function. The.se fune.tsom The proposed TS change has been evaluated and it has been determined that it involves no significant hazards consideration. This determination has been performed in accordance with the criteria set forth in 10 CFR 50.92(c) as quoted below:
"The Comission may make a final determination. pursuant to the procedures in 50.91. that a proposed amendnent to an operating license for a facility :
licensed under 50.21(b) or 50.22 or for a testing facility involves no significant hazards consideration. if operation of the facility in accordance with the proposed amendnent would not:
- 1. Involve a significant increase in the probability or consequences of an accident previously evaluated; or
- 2. Create the possibility of a new or different kind of accident frw any accident previously evaluated; or
- 3. Involve a significant reduction in a margin of safety."
The following evaluation is provided for the three categories of the significant hazards consideration standards:
- 1. Does the change involve a significant increase in the probability or consequences of an accident previously evaluated? -
1 Overall protection system performance will remain within the bounds of the previously performed accident analyses since no hardware changes are proposed. The proposed change adds a relaxation to the ACTION Statement associated with an inoperable channel in CTS Table 3.31 Functional Units 9,11,12.a.14. and 15 by keeping the end point WCGS- NSHCs - CTS 3M.2 34 S/1SM7
IV. SPECIFIC NO SIGNIFICANT HAZARDS CONSIDERATIONS NSHC LS-11 10 CFR 50.92 EVALUATION FOR , TECHNICAL CHANGES THAT IMPOSE LESS RESTRICTIVE I REQUIREMENTS WITHIN THE TECHNICAL SPECIFICATIONS hn 'alttahin AstrumenbCw i. n* uudd s be.operg la 2-u.cM te (a) is added o current TS Tabie 3.3 3 for the Steam Line Isolation Function to state that the(C&fectnrememre aet appntabhDin H0 DES 2 and 3 when the MSIVs are l closed []. Note (b) is added to current TS Table [3.3 3] for the Feedwater Isolation and Turbine Trip Function to state that the LCO requirements are not applicable when the [HFIVs]. main feedwater regulating valves. and main feedwater regulating bypass valves are closed []d-@en the r se yaWess6 close8. tWare alregyterfe aminertheir l safet? functionJftJnen tw v,tn.* w.ctoseA. t 1 m.e is.ia.m 4 ,eten .. e,+es.
@ wore, Wu, ce n.cMor 6. -ha acwribn .Awu_mee_ tiwH= eperota.
The proposeiTS change has been evaluated and it has been determined that it involves no significant hazards consideration. This determination has been performed in l , accordance with the criteria set forth in 10 CFR 50.92(c) as quoted below:
**The Comission may make a final determination, pursuant to the procedures in 50.91. that a proposed amendment to an operating license for a facility licensed under 50.21(b) or 50.22 or for a testing facility involves no significant hazards consideration. if operation of the facility in accordance with the proposed amendment would not:
1
- 1. Involve a significant increase in the probability or consequences of an acc1 dent previously evaluated; or
- 2. Create the possibiltty of a new or different kind of accident from any accident previously evaluated: or
- 3. Involve a significant reduction in a margin of safety.
- The following evaluation is provided for the three categories of the significant I hazards consideration standards:
1
- 1. Does the change involve a significant increase in the probability or consequences of an accident previously evaluated?
Overall protection system performance will remain within th bounds of the previously performed accident analyses since no hardware changes are p oposed. The proposed change adds a relaxation to the Applicability associated w'th the [ Steam Line Isolatior. and] Feedwater Isolation ESFAS functions. Those functions are accomplished when the associated valves are closed [], whether that closure is as a result of automatic isolation (2rcen#b or operator action. Operability requirements on actuation (pants are Wot applicable if the valves are closed []. The proposed change will not af ect any of the analysis assumptions for any of the accidents previously evaluat . he_ proposed change will not affect the probability of any AstrumentAib3 H SMS/97 WCGS - NSHCs - CTS JM.2
i IV SPECIFIC NO SIGNIFICANT HAZARDS CONSIDERATIONS NSHC LS-40 10 CFR 50.92 EVALUATION FOR TECHNICAL CHANGES THAT IMPOSE LESS RESTRICTIVE REQUIREMENTS WITHIN THE TECHNICAL SPECIFICATIONS The current TS require that the setpoints be verified during the quarterly TADOTS for the Reactor Coolant Pump (RCP) Underfrequency [and RCP Undervoltage] functions. The setpoint is adequately confirmed during the 18 month calibrations. _ g g.u.ac t This proposed TS change has been evaluated and it has been determined that it involves no significant hazards consideration. This determination has been performed in accordance with the criteria set forth in 10 CFR 50.92(c) as quoted below: l "The Cornmission may make a final determination, pursuant to the procedures in 50.91. that a proposed amendnent to an operating license for a facility 1 licensed under 50.21(b) or 50.22 or for a testing facility involves no significant hazards consideratton. 1f operation of the fac11ity in accordance with the proposed amendnent wuld not:
- 1. Involve a significant increase in the probability or consequences of an accident previously evaluated; or
- 2. Create the possibility of a new or different kind of accident frorn any accident previously evaluated; or
- 3. Involve a significant reduction in a margin of safety."
I The following evaluation is provided for the three categories of the significant l hazards consideration standards:
- 1. Does the change involve a significant increase in the probability or consequences of an accident previously evaluated?
, The setpoint for the RCP Underfrequency [and RCP Undervoltage functions are] selected l such that the Allowable Value is not expected to be exceeded during the 18 months ! l between calibrations. This function is not an initiator for an accident previously l l analyzed but the function is used to provide a reactor trip signal to mitigate certain ' i accidents. However, because the function is not expected to exceed its Allowable Value based on the 18 month calibration, it is concluded the proposed change would not involve a significant increase in the consequences of any accident previously analyzed.
- 2. Does the change create the possibility of a new or different kind of accident !
from any accident previously evaluated? l l WCGS- NSHCs - CTS 3N.2 62 S/1SM
INSERT LS-40 0 2-LS-GEN Therefore. Table 4.3-1 is revised to add Note [(10)] to the TADOTs of Functional Unit [s 14 and 15] such that setpoint verification during the quarterly TAD 0T is not required. This is acceptable because operating experience has shown that these relay setpoints demonstrate such low drift that if the setpoints were verified only during the 18 month calibrations there would be no effect on system performance and the Allowable Values for these Functions in current TS Table 2.2-I would not be challenged.
ADDITIONAL INFORMATION COVER SHEET ADDITIONAL INFORMATION NO: O 3-LS GEN APPLICABILITY: DC, CP, WC, CA REQUEST: TSTF-135 changes Comment: TSTF-135 was rejected except for the traveler changes identified by the following justifications: DOC 3 which deletes STS Condition V for two inoperable trains; DOC 4 which makes changes STS T3.3.1-1 Note (b); DOC 5 which dietes Source Range Flux for Applicabilities in T3.3.1-1 with Note (f); and DOC 7 which deletes Intermediate Range Flux for Applicabilities in T3.3.1-1 with Note (e). Revise the submittal to delete all other TSTF-135 proposed changes. FLOG RESPONSE: This traveler was discussed during meetings with the NRC staff during the week of August 10,1998. The attached pages represent changes, including revised DOCS and JFDs, that we believe are acceptable to NRC. These changes are marked with the change code "TR-3.3-006" since the majority of these mark-ups were self-identified and pre-date the RAl. Mark-ups are based on TSTF-135 Rev. 3. ATTACHED PAGES: Encl. 2 3-5, 3-6, 3-12a Encl. 3A 10,14 Encl.3B 4 Encl. 4 38,60 Encl. 5A Traveler Status page, 3.3-1, 3.3-2,3.3-4,3.3-5,3.3-17,3.3-18,3.3-22 Encl. SB B 3.3-7, B 3.3-9, B 3.3-14, B 3.3-15, B 3.3-16, B 3.3-39, B 3.3-40, B 3.3-41, B 3.3-42, B 3.3-43, B 3.3-47, 8 3.3-48, B 3.3-53, B 3.3-54 Encl.6A 11,14,15,16 Encl. 6B 15,20,23 I i
TABLE 3.3-1 (Continued) TABLE NOTATIONS
*Only if the "-- r- T4 Sy- -- i: '- ig;:: :: 5: h S: 9xf pr." -f i: 1-55-LS-39 ods are not fully inserted. Lar mer3D--- 1 ~.
Control "S 7. . . Rod ~: : f Drive S;:"- ":System 2 ^.' - :::is - capable
;"--t': of rod withdrawal 0.'b o@Ls<.N Mons l 1-05-A
##Below the P-6 (Intermediate Range Neutron Flux Interlock) Setpoint. l " 15 '" I ~ ;~
###Below the P-10 (Low Setpoint Power Range Neutron Flux Interlock) Setpoint.
(1) The applicable MODES for these channels noted in Table 3.3-3 are more restrictive and therefore applicable. ACTION STATEMENTS ACTION 1 - W' e mmber of OPERABLE channels one less than the Mmunum III-04-LG - ^ uired hannels O"E" ^"LE r;:- _ - . restore the inoperable channel 311:43-A,__ to OrtxABLE status within 48 hours or be in HOT STANDBY within the next 6 hours. ACTION 2 -
~
With the n f OPERABLE channels one less than the Total P IW.Lo '
"xtr :m qui hannels, STARTUP andh.c POWER OPERATION may
~
3-43-A - proceed provided the following conditions are satisfied: g .)
- a. The inoperable channel is placed in the tripped condition within 6 hours;
- 5. S : "' " "'----h ^*E" ^"' E :_; -__: : S r i:.._ r , I-M*L5-h Note-the ' ble channel may be bypassed for up to 4 hours for surveillanc ;11'-04-LG J testing ad setpoint adjustmenDf other channels @er$gpafirayosr(JA- and % 1-17-A be. Either. THERMAL POWER is restricted to less than or equal to ow ot RATED THERMAL POWER --f i: " ::r "- ; "un;. "': : T4 S:;i: ' 31!!8-LS-7 '
; m g ._ i___ .< _.._ , e gf., f n i wn """l'.^.L *^"!E" w thin
" " " ^
_ 12 hours; he power range neutros flux input to), the QUADRANT WER 1 TILT RATI _ inoperable, the OPTR)is monitored at least once per 1 e) A3.512 per Specification 414.2. ,
- c. Otherwise, be in HOT STANDBY within 12 hours )
dNSERT 3/4 3-5Aj W04-LG ~ XCTION 3 - With the number of channels OPERABLE one less than the Mounum 71-43-A CRequir@ Channels and with the THERMAL POWER level: I
- . "in 1: " 5 C:n.--- : fir: P- ;;"rn..fieMew::Si) S:;i:, rrr A. ' :; l': ^ --- '. e ^*"".^. ELE :rt: pi: :: h;n __" ; "EP2'.^.L
,1707.Ls.3
" - - i
"^"!5" d:;; i: " 5 S:;i:; ::
ab. Above the P-6 (Intermediate Range Neutron Flux interlock) Setpoint but below 10% of RATED THERMAL POWER,fithia'24 hou2. f:x i: h:;: db . _ m.__ ._ m _ _ _ _. ._ noco i o, e . .__z_.__1_-- - a_ _ m. . .r o u i ,___. .._ o n. u..rr_o. .1 7.... ._ _ 07.Ls.3 _ ,. , _ .___..,....._.v ecrease THERMAL POWER to < P6 or) {
/facrease to > P10. ) i 3-55.2 !
ACTION 4 - e number of OPERABLE channels o e less than the Misunum ui els ^"E" ^. ELE :: ;r' : suspend all 7143-A operations involving positive reactivity changes. 3-08-M dNSERT 3/4 3-34 _ - - - - (a) Above the P-9 (Power Range Neutron Flux laterlock) Setpoint
- ~ "I-15 A ~
(b) ciuding any reactor trip bypass breakers test are e acked in and closed A o bypassing an RTB. .,' Above the P-7 (Low Power Reactor Trip Block) interlock. (c) (el M required to be performedtaseirTMbarir ------- - loTver Range j "N estron FluxMEie'bto QPTR is inoperable g7,-ig u.Ty-[4 3.3-laoj t Qd.) ~ Ab.4 &a. 9-4 (ldsemetide. Rwp., deh % ) iMerlocGb Q-oT-t.5 3)c2.s.wSl ! WOLF CREEK- UNIT 1 3M 3-5 Amendment No. .-lk43 96 Mark-ap ofCTS3M. 3 5/ ISM 7 m _ , . , - _ _ -- ,
. . . . _ . ~ - - - . . . ~ . . ~ . - - ._ - - _ _ - ..~ -.-. - - . . . - - - - - . - - - - . i l f il - w .i up w w n T -- .- W m
,,- L. ,g..
_ .- - = l TABLE 3.3-1 (Continued] ' ACTION STATEMENTS (Cr,nt'nued) ACTION 5 s e u d e 6 0 ---W,j-M F or M With the number ofi PERABLE channels one less than the Mounum
.,.:1 43-A f4 M5488 Q 3% [l, idhite. N (Requis2 Char nelsp?EE_^ "' E ::;1. -^ restore the inoperable channel I'* *" *M*
I to OPERABLh=4rm rutnarner 2n ths.ecuwd-dully insert ' (all rods, and place the Rod Control System in a condit6on ineapable of rod ? ( lwithdrawa@ t .".1 '" p ". _" n, --d - _:;::d :!' :;:2:x "ll-55-LS-39 "" " i
._._____...____..:.a____
1.u _ .t _ _ __. . t _ _ . . . . _ . ._. g g_3_3;R'? b.. 3 With no channels OPERABLE, (open the Reactor Trip Breakers), JM 1 gg, ,:m-___.__f.
;:sf .'! :;:. .__ ^ : _r',._ih;;;:_7
- : x: Sj 3.t g; etr ,m n m , q goe.'"
~
- : :f[;:::f-bt : 3.' ' ' dii ! br - ': : j l2 En iQ148-R7"
~
ahesenAer, ACTION 6 - With the number of OPERABLE channels one less than the Total Nanber ofGtequireiDChannels, STARTUP and/or POWER OPERATION may proceed provided the following conditions are satisfied: @y,liI5-A .,y{4STA
- a. The inoperable channel is placed in the tripped condition pju.B.S_-5_-'
within 6 hours; and
- b. '": ? 'nx ' -- t O."E" ' ELE ::;r* _ : - E :- ; however,
~IF6RD'"
the inoperable channel may be bypassed for up to 4 hours ^ ' - - ' for surveillance testing of other channelsg -
-[Q 3.N]
Sneelfaeffion47#f]or
. (c.
ACTION 7 - Reduce Thermal Power to < P-7 within 12 hourG [ h S-8 } With the number of OPERABLE Channels one less than theM .gg- , Maimuse-Channels OPE" ^ "' E ::;n - -^. restore the inoperable channel to JLsadis!4 i OPERABLE status within 6 hours or be in at least HOT STANDBY within ___ p' g the next 6 hours; however, one channel may be bypwd for up to 4 hours for /[.M,-ts-surveillance testingWiSc==st 4#MIprovided the other channel is operable? -- ACTION 8 - With less than the ?' = "-"r :' NeireiDChanne!s /p3 6 OPERABLE, within I hour determinety gpservapen ot)me useciated J - -M fpepnfssiv3.adnugoedor wjndowls6 mat me amenocx is in its req'.iired state forthe existing plant condition, oir :;;h ?;i:'f- ' : 3f.3. k la at least W-@E ; FHot Standby withia 7 hourD I ACTION 8.1 With less than the Required Channels OPERABLE, within I ho%ur -Q 12-M < -
.5wu .
deteraniaefy TZgMof thef:i- _ = _. _ JG asSuptthier L- OC. 3.3 00'1 j ha,t the interlock is in its required state for the existing plant-condition, or be is at least MODE 2 withia 7 hours. ACTION 9 - With the number of UrtRABLE Reactor Trip Breakers one less_than fg3,g- .7 the$tequireRB" '---- Channels O"E." ^ "' E n;._ n . (estore thD kgd? (inoperable breaker to OPERABLE status la i bour olbe in at least HOT STANDBY within 6(7Jhours; however, one breaker may be_ bypassed for - - ggggp,q - I up to 2 hours forimaintenance or foBsurveillance testingW=*=5M"R provided the other breaker is OPERABLE. fhh_463*wD QQ{ (M'0 ACTION 10 - With the number of OPERABLE channels on : less than IIe ' l~~43=fj. (Requir@ Channels,^PE" ^ ELE n;1._. ::!,' restore the ino . ble channel M5;LS-391 to OPERABLE statushatKinD1stiFhor : :: i: "-- ^: . "ully insert all [ rods and place the Rod Control System in a condition incapable of rod (withdrawalbreakers within the next hour. ACTION 11 - With the number of OPERABLE channels less than the Total Number Snot Used" of Channels, operation may continue provided the inoperable "## channels are placed in the tripped condition within 6 hours. WOLF CREEK- UNIT I JN 3-6 Amendment No. G,25,13, S2,96 Mark-up ofCTS3M. 3 5A5M 4
, - . _ ., , . . , , . . . . , , , , _. - - - . , ,m_ _ - _ - s ..,., m . . _ . . .-
TABLE 4 3-1 (Continued) TABLE NOTATIONS (13) DELETED. (14) DELETED. (15) The MODES specified for these channels in Table 4.3-2 are more restrictive and, therefore, applicable. p i 32l (16) ThgpTfflP AC ING D CE OPE lONAL T shall ' epende vpWf ' 1-32-LG ArTe OPE LITY of undervo ands trip ents e React tip Br rs. -- (17) Local manual shunt trip prior to placing breaker in service. h8) MJastl6ungervt5ltagepbH # '_~ 3 M __
,1-32-LG New (19) The ANALOG CHANNEL OPERATIONAL TEST shall be performed within 12 hours after reducing power below P-10 for the power range and '122-M intermediate range instrumentation and within 4 hours after reducing power 1-27-LS-10 below P-6 for the source sange instrumentation, if not performed within the previous 92 da New (20) Surveillance shall also include verification that permissives P-6 and P-10 1-22-M are in their required state for existing plant conditions. --
includes verification of time constants, where applicable. New (21)
]{A"
_~ e+h %s Red f.edro\ Qstem cayah\s *{voa siskersuss\ er
.A..A<A , w. Acct e nek
,n e -,& roa not- M reqtitrid yrthe te ente /mg 3 from tiobe 2 whI [3[Q'd
{4 hours affer entcrmy McDr. 3, M'OLF CREEK- UNIT 1 3M 312a Amendment No.12, E, '?, $2 Mark-up ofCTS3M. 3 S/15/97
CHANGE NUMBER HSliC DESCRIPTION exceeding a specified power level. With the deletion of the current TS 4.0.4 exception, the specified power level in ITS SR 3.3.1.3 should reflect the applicable safety analysis basis consistent with the [ Applicability and] Required Actions of ITS LC0 3.2.3 (AFD) and LCO 3.2.4 (QPTR). As with the changes discussed above, there is no need to retain the current TS 4.0.4 exception as long as the Its Surveillance Notes allow the plant to reach conditions appropriate for the performance of_the surveillances. p m. restrictive; .s. nu. These changes are Fapstderfd.adihindtKtDib in nat e Qn, that,.!Dey stgrry re,pett tbe 1ncorporaMoni@ helqi-24 current 6s 4.0.4 exceptions w 7 + " -~~ R.
@ ~+ i.w.t.d 1-26 LG This change moves the detail concerning NIS detector calibration to the BASES for ITS SR 3.3.1.11, consistent with NUREG - 1431. Rev.1. This information is more appropriately controlled outside of the TS while the calibration requirement itself and its Frequency are unchanged.
1-27 LS 10 Surveillances on the Source Range Neutron Flux trip function are reorganized to reflect plant status in accordance with NUREG 1431 Rev. 1. New Note [(19)] requires that the quarterly COT be performed within 4 hours after reducing power below the respective g gg g% g a gg source range instrumentation Applicabilities, if not performed within the previous [92] days. Since the COT ggq% is valid for [92] days, there is no need to repeat it 6, rerdered. ibeapM.4-. if one has been performed within the prior [92 days). o rod wahdrM,aftn The 4 hour allowance penoits a normal shutdown to Y{ ha _
. proceed without a delay for t_esting 1_n H0DE 2 and for a J short time in MODE 3 until[tbe-Mactop-mWair. erb I 03-Ls-dE4 i '-
Wan!lDthis trip function no longer provides M 3 '5-o' l protection. Since the current TS has no Specification 4.0.4 exception, this 4 hour allowance is less restrictive. 1-28 A Note [9] is revised to require the P 6 and P 10 interlock verification to be performed during all source range COTS. These permissives are verified to be in their correct state prior to entry into MODES 3. 4 and 5 during shutdown and after leaving MODES 3. 4. and 5 during startup. This change is consistent with NUREG - 1431. Rev. 1. 1-29 LG Not applicable to Wolf Creek. See Conversion Comparison Table (Enclosure 3B). WCGS-Description ofchanges to CTS 3M.3 10 S/15/97
CHANGE NUMBER MSliC DESCRIPT10N ' 1-54 LS 37 Not applicable to Wolf Creek. See Conversion Comparison Table (Enclosure 3B). 1 55 LS 39 Applicability Note [*] and ACTION Statements [5.a and 10] for Functional Units [1, 6.b 19, and 20] of , current TS Table 3.31 are modified to provide an ' ; alternative to opening the reactor trip breakers (RTBs) while still assuring that the function and intent of opening the RTBs is met. As currently worded, these ACTION Statements result in a feedwater isolation signal (FWIS) when in H0DE 3 with a T., less than l 4 [564"F. USAR Table 7.3 14 and USAR Figure 7.2 1 l g -- (sht.13) detail the FWIS generation on the coincidence ! (a.ch6n Mreqde 9 of P 4 and low T,,.] A more generic action, which I 2 assure @he rods are fully inserted and cannot be l
- withdrawn, replaces the specific method of precluding tq3.is-ase! rod withdrawal. The revised Applicability and ACTION
- OR s3M '
Statements still assure rod withdrawal is precluded, l This change does not involve any safety impact and is consistent with traveler. 1 56 Not applicable to Wolf Creek. See Conversion W n-54 Comparison Table (Enclosure 3B). 1-57 LG Current TS Table 3.3-1 Functional Units [12.a and 12.b] , are combined per traveler TSTF 759. The Required j Channels. ACTION Statement, and surveillance ! Requirements are the same for both Functional Units. l The only difference between the two is the l Applicability which could lead to entry into ACTION l Statement 6 for Functional Unit [12.a], followed by a power reduction below P 8 exiting the Applicability and ! required actions for that Functional Unit, and I subsequent re entry in ACTION Statement 6 for Functional Unit [12.b]. This would involve an improper cumulative A0T of 12 hours before tripping an inoperable channel, beyond that evlauated in WCAP 10271 ; and its Supplements. The relationships between these Functional Units and permissives P 7 and P 8 are moved to the ITS 3.3.1 Bases.
- 1 58 A Not applicable to Wolf Creek. See Conversion Comparison Table (Enclosure 3B).
1 59 No
@ c.s.t_ ,ppu c2W.
-re.% b tMf.&cek. % Gm,. .,, . .s,i 1 60 Not used.
1 61 M Not applicable to Wolf Creek. See Conversion
- - -_ Comparison Table (Enclosure 3B).
hsRT* 3A - Lt4-) WCGS-Description ofchanges to CTS 3M.3 14 S/1S/97 m
- - - _ - ..- . - - - . - - - . - . - ~ . - - - - - - - .- - - .
I i i INSERT 3A-14 1-62 A Not applicable to Wolf Creek. See Conversion Comparison Table _ ; l (Enclosure 3B). : l 1-63 A All reformatting, renumbering, and editorial rewording is in Ql'A GE4jJ j accordance with the Westinghouse Standard Technical Specifications, i NUREG-1431. During the development certain wording preferences or l English : language conventions were adopted. As a result, the ; Technical Specifications (TS) should be more readily readable, and l l therefore understandable, by plant operators and other users. During ! the reformatting, renumbering, and rewording process, no technical 3 changes (either actual or interpretational) to the TS were made l unless they were identified and justified. l
} Ot 23 ] l l 1-64 A The refueling interval TADOTs for Functional Units [1 and 17] in CTS )
Table 4.3-1 have been revised to include existing Note [10. "Setpoint ! verification is not required."] Likewise, refueling interval TAD 0Ts i for Functional Units [1.a. 2.a. 3.a.1). 3.b.1),~3.c.1), 4.a. 6.a. 9.a , and 11.b] in CTS Table 4.3-2 have been revised to add a new Note [5], )
" Verification of setpoint not required." This change is {
l administrative in nature since the subject Functional Units have no ' setpoints associated with them. This change does not affect the 4 operating limits or manner in which the plant is operated. There are I no changes to current plant practices for the performance of these l TADOTs since there are no setpoints to verify for these Functional Units. This change is strictly an acknowledgement that the l corresponding ITS SRs 3.3.1.14, 3.3.2.8, and 3.3.2.11 have an explicit Note to this effect. 1-65 A Seven slave relays are listed in Note (3) to CTS Table 4.3-2 for an exception to the quarterly SLAVE RELAY TEST. These slave relays are associated with the following ESF actuation signals: K602 (SIS): K620 (turbine trip and main feedwater pump trip): K622 (CIS-A); K624 (CIS-A): K630 (CIS-A and the CIS-A input to containment purge isolation and control room ventilation isolation): K740 (SIS, RWST low-low); and K741 (SIS. RWST low-low). ITS SR 3.3.2.6 has been revised with a Note per JFD 3.3-19 that excludes these seven slave relays from the quarterly surveillance. Based on the differing Functional Unit MODE t Applicabilities, new ITS SRs 3.3.2.13 and 3.3.2.14 have been added under JF0 3.3-19 to cover the surveillance frequency applicable to these slave relays. The only slave relay associated with containment purge isolation and control room ventilation isolation. K630, has the extended surveillance frequency under new ITS SR 3.3.2.13. Based on feedback received from the NRC reviewer at a meeting on September 16, 1998, the 90 days cited in Note (3) has been changed to 92 days to ) L follow standard convention for an exception to a quarterly ! surveillance frequency. i l
1 INSERT 3A-14 (continued) Q 3.sj \ 1-66 LS-45 The CTS allows certain inoperable channels, or for some plants one other channel, to be bypassed for testing per Specification 4.3.1.1 or 4.3.2.1. The intent of the bypass is to allow testing that will verify that the channel has been restored to an OPERABLE condition and can be returned to service. The allowed bypass time for testing has been evaluated for its impact on the safety analyses. It has been determined that the impact of the allowed bypasses is minimal. Whether the bypass is for setpoint verification or response time verification has no impact on the safety analysis. This change would delete the reference to Specification 4.3.1.1 and 4.3.2.1 in the allowed bypass notes contained in certain CTS ACTION statements, thus permitting any testing needed for restoration of the inoperable function. l i l
CONVERSION COMPARISON TABLE - CURRENT TS 3/4.3 race 4 orso TECil SPEC CIIANGE AFFLICABILITY COMANCllE FEAK WOR.F CREEK cal,LAWAY NUMBER DESCRIPTION DIABif) CANYON No No Yes 1-10 This Callaway specific change redefines Actions for the No LS-32 source range neutron flux channels in M00ES 3. 4. and 5. The source range neutron flux channels are required to provide input to the Reactor Trip System to mitigate potential uncontrolled rod withdrawal events only when the Rod Control System is capable of rod withdrawal or s e are not fully inserted (see CN 155 LS-39). ("*[ '"8'8 If one source range neutron flux channel is inoperable in MODES 3. 4. and 5 when rod motion is possible. ACTION W ~ IIR 3 3 ~" Statement 5.a is entered. If the channel is not res ed within 48 hours, the Applicability is exited by all rods and precluding rod withdrawal. If both source N.-[{J inseri-Inihk ashh h range channels are inoperable when rod motion is possible. - _ new ACTION Statement 4.1 is entered and the reactor trip breakers are inmediately opened.
% current Action Statement 5.a requirements regarding the suspension si r eitive reactivity changes and closure of dilution source valves are deleted since they are not _
related to the reactor trip function. [Ei3adI3.lforQ t Yes Yes Yes Q 3.3r02. } 1-11 [New] ACTION Statement applied to the Low Fluid Oil No-see LS 5 Pressure and Turbine Stop a ve Closure trip functions. CN 1 48 LS-4. Rather than entry into LCO 3.0.3 if current ACTION Statements [6 and 11] are not met.QlufttMTeAdG411Iid oik pressocr tbanne W ace-Inspere le] the new ACTION
~
requires 1noperable channels to be tripped within 6 hours, ! or power reduced below P-9 within 10 hours. i S/1587 WCGS-CONVERSION TABLE- CTS 3M.3 i I ___...___m. _____m._.___..________.._..____-______.__..___.._._____-__._______..___.___m__m____-.._.____m.____.m _..__m.__
IV. SPECIFIC N0 SIGNIFICANT HAZARDS CONSIDERATIONS NSHC LS 10 I 10 CFR 50.92 EVALUATION FOR ! TECHNICAL CHANGES THAT IMPOSE LESS RESTRICTIVE RE0VIREMENTS WITHIN THE TECHNICAL SPECIFICATIONS _ [.ait rods ><e full maerted a-tm. h. co+ L 6 sta - is r=~w
%3j f
@capatAa_ of r hi N r.>4 after whics, Surveillances on the Source Range Neutron Flux trip function are reorganized to reflect plant status. New Note (19) requires that the quarterly COT be performed within 4 hours after reducing power below the respective source range instrumentation if not performed within' the previous 92 days. Since the COT is valid for 92 days, there is no need to repeat it if one has been performed within the prior quarter. The 4 hour allowance permits a normal shutdown to proceed without a delay for testing in H0DE 2 and for a short time in H0DE 3 until(the.Afact3rdip,Breakpar1treM this trip function no longer provides protection. 51nce the current T5 has no Specification 4.0.4 exception, this 4 hour allowance is less restrictive.
The proposed TS change has been evaluated and it has been determined that it involves no significant hazards consideration. This determination has been performed in accordance with the criteria set forth in 10 CFR 50.92(c) as quoted below:
"The Carrinission may make a final determination, pursuant to the procedures in 50.91. that a proposed amendrnent to an operating license for a facility licensed under 50.21(b) or 50.22 or for a testing facility involves no significant hazards consideration. if operation of the facility in accordance with the proposed amendrnent would not:
- 1. Invols'e a significant increase in the provability or consequences of an accident previously evaluated; or
- 2. Create the possibility of a new or different kind of accident frorn any accident previously evaluated; or
- 3. Involve a significant reduction in a margin of safety.**
The following evaluation is provided for the three categories of the significant hazards consideration standards:
- 1. Does the change involve a significant increase in the probability or consequences of an accident previously evaluated?
Overall protection system performance will remain within the bounds of the previously performed accident analyses since no hardware changes are proposed. This change allows a 4 hour deferral of a Channel Operational Test after entering the Applicability of the source range trip. This will not affect the operability or functionality of the source range channels. Their calibration is still valid and daily channel checks are still performed. The probability that an accident would occur during the 4 hour extension allowed by the proposed change is extremely small. WCGS- NSHCs - CTS 3M.2 38 5/15/97
IV. SPECIFIC NO SIGNIFICANT HAZARDS CONSIDERATIONS NSHC LS 39 10 CFR 50.92 EVALUATION FOR TECHNICAL CHANGES THAT IMPOSE LESS RESTRICTIVE ps.u.m REQUIREMENTS WITHIN THE TECHNICAL SPECIFICATIONS i mw'- re fcn%gseMubbIw. ta.+= Applicability Note [*] and ACTION Statements [5.a and 10] for Funclional Units [1, 6.b.19 and 20] of current TS Table 3.31 are modified to provide an alternative to opening the reactor trip breakers (RTBs) while still assuring that the function and intent of opening the RTBs is met. As currently worded, these ACTION Statements result in a feedwater isolation signal (FWIS) when in H0DE 3 with a T,,, less tha [564*F. USAR Table 7.3-14 and USAR Figure 7.21 (sht.13) detail the FW ration on the coincidence of P 4 and low T ,,.] A more generic action, which ssur the rods are fully inserted and cannot be withdrawn, replaces the specific method of precluding rod withdrawal. The revised Applicability and ACTION Statements still assure rod withdrawal is procluded. This change does not involve any safety impact and is consistent with traveler TSTF-135. The proposed change allows more freedom in how rod withdrawal is precluded and is thus less restrictive. However. the intent of using l physical plant characteristics to prevent rod withdrawal is not diminished. The specification now acknowledges that the _ Rod Control System can be effectively disabled by means other than openino the RTBsp.g~., 3b de-o imi g
& RT es,~or de energiain3 % -,+.r S n =e.+-f5G s@g A cRiiPGI, . -
- ppenm l This proposed TS change has been evaluated and it has been determined that it involves no significant hazards consideration. This determination has been performed in j accordance with the criteria set forth in 10 CFR 50.92(c) as quoted below:
"The Comission may make a final determination. pursuant to the procedures in 50.91. that a proposed amendnent to an operating license for a facility licensed under 50.21(b) or 50.22 or for a testing facility involves no significant hazards consideration. if operation af the faci 1ity in accordance with the proposed amendnent would not:
- 1. Involve a significant increase in the probability or consequences of an accident previously evaluated; or
- 2. Create the possibility of a new or different kind of accident frorn any accident previously evaluated; or
- 3. Involve a significant reduction in a margin of safety. "
, The following evaluation is provided for the three categories of the significant ! hazards consideration standards: I
- 1. Does the change involve a significant increase in the probability or consequences of an accident previously evaluated?
WCGS-NSHCs - CTS 3M.2 60 5/1S/97
1 INDUSTRY TRAVELERS APPLICABLE TO SECTION 3.3 TRAVELER # STATIJS DIFFERENCE # COMMENTS hCchYp wh TSTF-19, Rev.1 @ Incorporated N/A @NRC ap_ proved s (rMr;: art oJFtf_ f As.34 h-J6 ffeM Mog M.3334 IG 3.3- 341 TSTF-37, Rev.1 Not Incorporated NA ITS 5.6.8 still addresses PAM reports. Sections after ITS 5.6.7 were not renumbered. TSTF-51 Not incorporated NA Requires plant-specific reanalysis to establish decay time dependence for fuel handling accident. [@ _ _ Nof' lac 6 @ Nk oi a ] 3 3*/ volt an ed It/g I ( re in ~ e . TSTF-111 Rev.1 Incorporated NA TSTF-13 kM Incorporated 33-41,h 3 3-93 (in atur i fray ri 7s~ ho dh ebee ad h 3 3-95 eve sep te vele . m,3 33- Po ions f the ravel that L4 2. gni antly al * *
,3,3.w o bili requ' me s (j,-},7h e n inc o ed.
TSTF-161{Q Incorporated 3 3-79 Qgfgg #"*3 TSTF-168 Incorporated 3.3.43 [ h 1,[os ]r. Ie n-431 TSTF-169 , Incorporated 3.3-42 @ gra d ) uff) fTA3.3-ord l CW-J8[6 Ncorporated 3 3-49 {e as-d r s' 5*
- Incorporated 3 3-107 mJteE1@
'e [ cp s.3.io 1]
5/15/97 l . . i
RTS Instrumentation ! 3.3.1 j 1 3.3 INSTRUENTATION
. . i 3.3.1 Reactor Trip System (RTS) Instrumentation i LCO 3.3.1 The RTS instrumentatiion for each Function in Table 3.3.1-1 shall be OPERABLE.
l APPLICABILITY: According to Table 3.3.11. l ACTIONS
........................................N0TE -- -------- ------ ---- -- - - - -
l Separate Condition entry is allowed for each Function. 1 I! i CONDITION REQUIRED ACTION COMPLETION TIME l l l A. One or more Functions A.1 Enter the Condition Ilumediately l with one or more. referenced in i
, fr.in4 required channels Table 3.3.1 1 for the 3.5.ar inoperable.
channel (s). /L 4 3-Lb 6EA) i
+ ram. ra s.s.mL1 B. One Manual Reactor B.1 Restore channel to 48 hours Trip channel OPERABLE status.
inoperable. l QB B.2-1 Be in H00E 3. 54 hours NG S.2.2 Op;r. r;;;ter trip 55 h;;T3
$433s1963 l 57;i;r; ""0;).
l l l (continued) + r i d i a WCGS-Mark-qp ofNUREG-1431 -ITS 3.3 3.3 1 5/1Si97 ?
RTS Instrumentation 3.3.1 ACTIONS (continued) ! CONDITION REQUIRED ACTION COMPLt. TION TIME
. . . . . . . CN(iTE - - - - - - - - - -MIA l fWhile this LC0 is not met N3 3~ "N i L for Function 19, 20. or 2 i
in MODE G, makiy +hn Rod- g3;1353
'Ent i oo "' f Con +rol s$ stow capVh,drol E is t m ed witharaw.E is h* pmuel.
e ir an cep o I , ddi on t r r t (o CO . 0.4 - q................... , C. One channel or train C.1 Restore channel or train 48 hours inoperable. to OPERABLE status. E hihW. albm3 NM-6'd m s.sw. I C. 2. 1 0g r. R [.lyinsert hours p3 34 m g rods. m l CI212 PJRMContrtil"Sistem 49Wis ! inXconditimincapable oOodwithdrawa]I (continued) l I l WCGS-Mark-up ofNUREG.101 -ITS 3.3 3.3-2 S/1587
l RTS Instrumentation 3.3.1 l 1 ACTIONS (continued) , I l . CONDITION. REQUIRED ACTION COMPLETION TIME l 1 1 4 l E. One channe1 - --
-- NOTE - - - -
ex l inoperable. The inoperable channel may be gy) j l bypassed for up to 4 hours for v ! surveillance testingot@her [Q3.S.4D) satedlnt4tutestment3f l channels. l E.1 Place channel in trip. 6 hours E i j E.2 Be in MODE 3. 12 hours l F. p3 F.1 Reduce TliERMAL POWER to E 24._ hours g(3107J. Jpne < P 6. ( ( Intermediate Range - Neutron Flux channel E q s-u-ero 1 inoperable. "8 3* J F.2 Increase E ERMAL POWER to 2 24 hours ;g3;341073
> P 10.
I G. P Ep[@ G.1 Suspend operations Immediately N n&< 10(1/wo involving positive , i reactivity additions.
~
Intermediate Range I 7g3 Q 3-L5.GDJ 3 c, l Neutron Flux channels inoperable. AND G.2 Reduce THERMAL POWER to 2 hours ; i < P 6. I , H. Not used. li.1 Rc;terc chenaci';) to Prior to 3.3;95. THEW %L-~J R : I S. OPERACLE status 4ftveesiftg ! enc or tw EER",AL- P"'CR
- to Inter;.; dict; Renge W 4 Ncutica Ilux chenacis iregrabic.
(continued) If' CGS-Mark.up ofNUREG-1431 - ITS 3.3 3.3.A S/1587
RTS Instrumentation 3.3.1 1 ACTIONS (continued) CONDITION REQUIRED ACTION COMPLETION TIME I. One Source Range I.1 Suspend operations Immediately Neutron Flux channel involving positive inoperable. reactivity additions. J. Two Source Range J.1 en Innediately Neutron Flux channels Op/(RTBs g inoperable.
- M fbmaks ! ,3,ts.,g3 g .
pm.s.s-cot. ) l K. One Source Range K.1 Restore channel to 48 hours Neutron Flux channel OPERABLE status. inoperable. E Q3.u-na \ ar. s.s-o%_) K.2.1 Opr. ."" 11y_jnsert 39 hours . . _ alLrods. 46
$$$2sl AND K2;2 Place _ the RodiCor!tra] 49; hours _ . _ . .
Systemiinial~coridttion I!$3@@ incapable oGrod withdrawal. (continued) l l WCGS-Mark-up ofNUREG-1431 -ITf3.3 3.3 5 S/15/97 l
RTS Instrumentation 3.3.1 Tabte 3.3.1 1 (page 1 of 8) ~ Reactor Trip System Instrumentation APPLICABLE MODES f*te OR OTHER GE4996#4" y'13%g SPECIFIED REQUIRED SURVE!LLANCE ALLOWABLE FUNCTION CONDITIONS CHANNELS CONDITIONS REQUIREMENTS VALUE *
- 1. Manual Reactor 1,2 2 B SR 3.3.1.14 NA NA Trip 3 *', 4 *) , 5 *) 2 C SR 3.3.1.14 NA NA
- 2. Power Range Neutron Flux
- c. High 1,2 4 SR 3.3.1.1 D
SR 3.3.1.2 s!112.3% RTP
. ;^^^; :T-
{g.p$4g SR 3.3.1.f N 44 h t p r.5-4el SR 3.3.1.11
$P3Jd,3s] -l q s.3-5sr 1
- b. Low 1(C), 2 4 E SR 3.3.1.1 . 5: ::-
SR 3.3.1.5
!%hPSPN sl28.~3% RTP SJL 3.3.1.11 ihhe CS N M -l 9 3 3.SSil h gr
- 3. Power Range Neutron Flux Rate
[Q3.5-461
- c. High Positive 1,2 4 E SR3.3.1.f@ s T.3 b6 .: i~ 77 Rate SR 3.3.1.11 % RTP . . . . -
with time conetont constant a 2 sec e-9-see
% PShd T
- b. High Negative Rate 1,2 4 E SR3.3.1.7@ s-fke}6.3% W M ts-W^
SR 3.3.1.11 RTP with 4 077 ... - { Q s .3-SS _} W,46) time t+me {g constant corweent a [2] see . ;;; e ;
- 4. Intermediate Range 1", 2'* 2 F,G SR 3.3.1.1 s]5'.3% . 5"; "T Neutron Flux SR 3.3.1.8 5tX RTP gggg;pg
* "w SR 3.3.1.11 3" 9 tt :: :. .;_; t-3!Mit 5~ :!"
- 2. .;.0 5HHtft 43;g'.;
^; :.3.;.;;
(continued) (c) L......' ;.;.. ;;. . ; . '
.r.. . ' ; e . v;- . ..; ; - -, . . . . . . . . . . , ;. ; '. . .L L 'J . ; _ a . : . . , . :; ; ,~ . ;
r n _ , ;.. _ ;. ,, _ Bones fsr~thfTripisetpoints'. L, .:.. .'.. The. Allouable Value ' defines the Lietting Safety system Setting. See the !Q^ 3i08 2- ~ (b) With : _ ;.. .- ;r ~.. .ek.. . ;;TL; ; ...; - : Rod Control System capable of rod withdrawal or ods not fut1y~1neer:ed. ! (c) Below the P 10 (Power Range Neutron Flux) interlocks. -- [ - e3;3ga (d) Above the P-6 (Intermediate Range Neutron Flux) interlocks,
;;; n: .:.. r :........ -a..;.:... .... . '.._; ;..; i..
h 0# ## q a. mew %3t95ii. re 2.3.e%_ WCGS-Mark-up ofNUREG-1431 -ITS 3.3 3.3-17 5/158 7
2 s.s A u - s., - s + . 4 a., ^- RTS Instrlssentation 3.3.1 Table 3.3.1-1 (page 2 of 8) Reactor Trip System Instrumentation ~~ APPLICABLE MODES FUNCTION OR OTHER SPECIFIED REQUIRED SURVE!LLANCE ALLOWABLE N N pg-g'g CONDITIONS CHANNELS CONDITIONS REQUIREMENTS VALUE *
- 5. Source Range 2" Neutron Flux 2 1.J SR 3.3.1.1 D:lE M , O ;;
SR 3. 1.8 E5 cps eye
= ', . : . " . M '
3",4",5" i J,K SR 3.3.1. dM M @ ' ^W'&3
^ db; l SR 3.3.1. E5 cpe ope SR 3
_ . 3. 1.1 gg,3 46} 3*r-4*v-4* E t- Z ',.:."." #fA -#fA -
= !. .".""
- 6. Overtemperature af 1,2 4 E SR 3.3.1.1 Refer to L l. . i. 1.
N SR 3.3.1.3 Note 1 Note-+ ?- wN SR 3.3.1.6 (Page teege SR 3.3.1.7 3.3 22) 5.4 e6t srs. i:Jac
. =J m;.;; y y ;d,2ey lO3.55r] -
- 7. Overpower AT 1,2 4 SR 3.3.1.1 E Refer to L l.. ;. r. W hs;*
SR 3.3.1.7 Note 2 #ete-E 6 N$ 3R;'3.*3;1!10 (Page fPope
= . ."."; 3.3 23) 5:5-e59 H Q3.3-55T l -*
@:") -
(continued) (a) L . . . . . L;. . .. ; m- l; . .v'-....;.
. -, . .;. . .. .; , ;.; ; ;/.. L ;
n ;, _ ;. _ . .,, , _ _ _ f ' ,. ;; .. . '. ; . ThE A11oirsibTsyelGe: defines;the~LlefHviiYefsti"99Efes(setfT4s'aise
, . J.. , . L ;r. ; . .; NNM$
t W Be K fsrithe 3 IgESet#6]M si enc ermerug . (b) With afte-etened-end Rod control System cepeble of rod withdrawal ori 4 3.g g g
. _ _po yt ty Jame_rtid. gg,3,g.gg,
$M{$4 (0) Selow the P-6 (Intermediate Range Neutron Flux) interlocks.
m . . . .:.. n;;. .,. .
. . . .. . .;;;: ., . ... . .. i .. . s . . ; r..../ .. ;.. ; . . ,. ; ; c JM@
E%3341M i I l i i WCGS-Mark-sqp ofNUREG-1431 - ITS 3.3 3.3-18 S/1587 l i l i
I RTS Instrlaentation 3.3.1 Table 3.3.1-1 (page 6 of 8) Reactor Trip System InstrLuentation ~ APPLICABLE MODES OR OTHER SPECIFIED REQUIRED SURVEILLANC ALLOWABLE 99te FUNCTION CONDITIONS CHANNELS CONDITIONS E VALUE
- GE#G4M" gem:.g
^g "
REQUIREMENT S
- 18. (continued) sggg g
- d. Power Range 1 4 4 T SR 3.3.1.11 SE-E r-505-*fe e Neutron Flux, SR 3.3.1.13 s;53.3E RTP P-9 g
\45.S-441 Power Range 1
- 0. 1,2 4 s SR 3.3.1.11 7:6 e-991Htfe Neutron Flux, 21 3.3.1.13 a 6'7E RTP ggg!.pgjfg ]
i P 10 and hh9 s;13;3ERTP {.Lg]1 ~ l
- f. Turbine 2 0; 3.3.;." +ibe r-495 impulse 1 T pyS;PS3 i SR 3.3.1.1D s ;1,2[41 turMne J Pressure, P-13 SR 3.3.1.13 turbine power power I
- 19. Reactorgp 1,2 2 trains R SR 3.3.1.4 NA m '
Breakers 48MEM 3 *', 4 *', $ *' 2 trains C SR 3.3.1.4 NA m i (RTBs) p.ssowl '
- 20. Reactor Trip 1,2 1 each U SR 3.3.1.4 NA m Breaker j per RTB Undervoltage and i
Shunt Trip 3*', 4*', 5*) 1 each C SR 3.3.1.4 m Nechanisms " per RTB NA eyggy
* ~-
)
i j 21. Automatic Trip 1,2 2 trains 0 SR 3.3.1.5 NA m j l Logic l 3*, 4*', 5 *' 2 trains C SR 3.3.1.5 NA m l i I (c) ;....-.'. ; ;.. ;. . '. . .r.. . f . e . v ' __ . . . i . - - , e . ; . . . . - . ; , M L -__ ; . . . '. J.r :.., 0. . r. . . ;
;;.J, ;.._; , - M L, .... .: .. The:Allowabl.eivalueidefines:the ~ Limiting Safety system Setting!See , g' 3g
the; teses~fst ths3f!ESFtifoTntsi.' = g, m o 3.LS.(M l (b) With C;. ..' e.e4 mt.24-ocs 1
.J Rod Control System capable of rod with frawal o Mrods not fully inserted. i3.34122a
! (k) Incitxting any reactor trip bypass breakers that are racked in and closed for bypassing an RTB. i l WCGS-Mark-up ofNUREG-1431 -ITS 3.3 3.3 22 S/1S/97 i i I
RTS Instrumentation > B 3.3.1 BASES . BACKGt0UE) Reactor Trio Switchamar (continued) i the undervoltage coil or the shunt trip mechanism is sufficient ! by itself, thus providing a diverse trip mechanism. . c mat m.
- The decision logic matrix funcions are bed in the i functional diagrams included in Reference r1 In addition to the l
' reactor trip or ESF agggaggg, these diagrams also describe the @21(r-l j various " permissive interlocks" that are associated with unit ~ condition
- CEach Etrain has a built in testing device that can ~
- c t '.icelly test the decision logic matrix Functions and the l
actuation devices while the unit is at power. When any one trait is taken out of service for testing, the other train is capable of providing unit monitoring and protection until the testing has been completed. The testing device is semiautomatic to minimize j testing time. APPLICABLE The RTS functions to maintain the applicable Sie lggs during SAFETY ANALYSES, all A00s and mitigates the consequences of DBAs in all MODES in LCO, and ich the RfBs Llo@uptis13rgg;1ricaniable* erred %ItlurmOor APPLICABILITY W oot M ;1nserted y cien d. o w w.
,e w4 TES3 %
Each of the analyzed accidents and transients ceri be detected by one or more RTS Functions. The accident analysis oescribed in , Reference 3 2 takes credit for most RTS trip Functions. RTS trip i Functions not specifically credited in the accident analysis are qualitatively credited in the safety analysis and the NRC staff approved licensing basis for the unit. These RTS trip Functions may provide protection for conditions that do not require dynamic transient analysis to demonstrate Function performance. They may also serve as backups to RTS trip Functions that were credited in the accident analysis. The LCO requires all instrtmentation performing an RTS Function, listed in Table 3.3.11 in the accompanying LCO to be OPERABLE. Failure of any instrument renders the affected channel (s)
- inoperable and reduces the reliability of the affected Functions.
5 The LCO generally requires OPERABILITY of four or three channels in each instrtamentation Function, two channels of Manual Reactor a E _ (continued) ! WCGS-Mark-qp ofNUREG-H31-Bases 3.3 8 3.3 7 5115/97 l
RTS Instrumentation B 3.3.1 BASES APPLICABLE 1. Manual Reactor Trio (continued) SAFELY ANALYSES, LCO, and The LCO requires two Manual Reactor Trip channels to be APPLICABILITY OPERABLE. Each channel is controlled by a manual reactor trip switch. Each channel activates the reactor trip breaker in both trains. Two independent channels are required to be OPERABLE so that no single random failure will disable the Manual Reactor Trip Function. In MODE 1 or 2, manual initiation of a reactor trip must be OPERABLE. These are the MODES in which the shutdown rods and/or control rods are partially or fully withdrawn g;gm ' from the core. In MODE 3. 4. or 5. the manual initiation Function must also be OPERABLE iMS) shutdown rods or l OLwso control rods are withdrawn or the@ontrpl RbdfyelCRlDNN blGnbl ~ System is capable of withdrawing the shutdown rods or the control rods. In this condition inadvertent control rod withdrawal is possible. In MODE 3, 4. or 5, manual initiati of a reactor trip does not have to be OPERABLE 17 thf System is not capable of withdrawing the shutdown rods or control rods ahiE1DWMDM rods cmn.Y be. impe@pd.j If tk id; sr.r.et k dtt.d. s . fra tM are, d*{Q uWrma b " c]a"- - ar; u r.; nd t; M ;bi; t; trip tM renter Man; ' - and all O* " A ^ ;11 ef tk rd; ;r; inertd. In MODE 6, rait Mr tM , Q 3surteA Nr= 3 G no '.2__ __;- --i'--m--,
~
_ 2- ------u; i '- i
" *d * *
- hi b s k b.b the Cb Ms a h disconnecke Ef N khe cob rol O *-3* -
rods and shutdown rods. Therefore, the manual initiation Function is not required.
- 2. Power Ranoe Neutron Flux The NIS power range detectors are located external to the reactor vessel and measure neutrons leaking from the core.
The NIS power range detectors provide input to the Rod Control System 7.r.d tM St;= 0;mr;ter 'S0) '.let;r Ls;l Ostrel Systs. Therefore, the actuation logic must be , able to withstar.d an input failure to the control system, which may then require the protection function actuation, and a single failure in the other channels providing the protection function actuation. Note that this Function also provides a signal to prevent automatic and manual rod withdrawal prior to initiating a reactor trip. Limiting (continued) WCGS-Mark-up ofNUREG-1431-Bases 3.3 B 3.3 9 5/15l97 i
RTS Instnmentatisn B 3.3.1 BASES APPLICABLE 4. Intennediate Ranoe Neutron Flux (continued) SAFETY ANALYSES, LCO, and sufficient to ensure no single random failure will APPLICABILITY disable this trip Function. TWTrip 5AtdidiintI4sy25% RE Because this trip Function is inportant only during startup, there is generally no need to disable channels for testing while the Function is required to be OPERABLE. Therefore, a third channel is unnecessary. In MODE 1 below the P-10 setpoint, and in MODE 2,8b69e the 19EbiglRBMht when there is a potential for an uncontrolled RCCA bank rod withdrawal accident during reactor startup, the Intermediate Range Neutron Flux trip must be OPERABLE. Above the P 10 setpoint, the Power Range Neutron Flux-High Setpoint trip and the Power Range Neutron Flux-High Positive Rate trip provide core protection for %hQk N ir.'p Fumelien a rod withdrawal accident. InLNoRn G l ial M N Zi5
" - +~
pru w core pn &rh 6 MMDRM1.' k-lO
' I j
~ '
Or resckW'sk A& Odd.
~
PrWfummuseussunw;ppgsime Nadau.- In = 0, 4 ;r 5. tre :nt;cadi;t; " erg t';=rs ria I o 2.u,-6al l trip da; ret tes; t; k 0"C"ZC kaux th; centrol red; Te. s.3 -ock, i ;;;;;;t k fally in;;7ted ;;d ;nly th; ;hatd; 7, red; ;;;;y M
.;ithdrLT.. ";; renter caret k ;ted;d up in thi; eendHien. Se ar; ;12 h;; th; r;;; ired 1"i to ;itiget; th; anxg--:ree; cf ; p;;itiv; r;xtivity ;dditia actint. In = 0, eli reda er; fully in;;rted and tk wr; ha ; r;;;ir;d ircre;xd L'"i. Al;;, tk t' 0
-ist;raediet; rag; ituter;; saret itut metren 1;;;1; prs;nt in thi; *:00.
- 5. Source Ranoe Neutron Flux The LCO requirement for the Source Range Neutron Flux trip Function ensures that protection is provided against an uncontrolled RCCA bank rod withdrawal accident from a suberitical condition during :;tertup. This trip Function provides redundant protection to the Power Range Neutron Flux-Low @3sd Int;radi;t "eng; t'cutra ria I 4 s - u - m. -
Mp Fiundern ,m34 (continued) WCGS-Mark-qp ofNUREG-1431-Bases .5.3 B 3.3-14 5/15/97 1
l RTS Instrumentation i B 3.3.1 BASES L APPLICABLE 5. Source Ranae Neutron Flux (continued) i SAFETY ANALYSES, j -LCO, and trip T.at t a. In MODES 3, 4, and 5. administrative APPLICABILITY controls also prevent the uncontrolled withdrawal of rods.
- The NIS source range detectors are located external to the reactor vessel and measure neutrons leaking from the core.
' The NIS source range detectors do not provide any inputs to control systems. The source range trip is the only RTS automatic protection function required in MODES 3, 4 l and 5
.M'SupseM.JW Therefore, the l functional capabi t the specified Trip Setooint is i
assumed to be available. }ary] 4 E54W T4. 3.%h The LCO requires two channels of Source Range Neutron Flux to be OPERABLE. Two OPERABLE channels are sufficient to ensure no single random failure will disable this trip Function. The TrioJetpgigtA118h;Tifhe 4:60
;l n . e,.^i. n sa M ;t al; ;f tra 5::: a L. 6 "^;tra.
Tia t ta C'EC ir. lZ- 0, 4. ; 5 dtt. 7"; :; 7. E tr.;; c-:-:--:, tra ::: ;; rue T atis i; t; p.sii a.:..el re, i../ stia.r4 ig/.t t tra %7e.011 12 .__ - ; Pretati= Sy;ts ;MO-;). The outputs of the Function to RTS logic are not required OPERABLE M.5 l or when tra PJL n; ga.7 a112rodrar1FM1fthsetBElW - ! tdWJWillhotrEon tem 3t t 3ec g um S W lXRN 6 ' ; The Source Range Neutron Flux Function provides protection for control rod withdrawal from suberitical beren dHteen and control rod ejection events. ol , [3j$ (([ufppgigpati, in j In MODE 2,' when below the P 6 setpoint; irir.; ; r;nter
;tatg. the Source Range Neutron Flux trip must be OPERABLE. Above the P 6 setpoint, the Intermediate Range Neutron Flux trip and the Power Range Neutron Flux-Low l Le 3-ts4W Mtrip will provide core protection for reactivity i W3% accidents. Above the P 6 setpoint, the NIS source range i
detectors are de energizedpriS ilasperAtrle) a i i
- (continued)
WCGMark-sp ofNUREG-1431-Bases 3.3 8 3.3 15 5115/97 i
- .~ . -- -- - - - - - ,-, ~ , - . - - .
_ ~ m._ l l i l RTS Instrumentation l B 3.3.1 i ! i BASES l APPLICABLE 5. Source Ranoe Neutron Flux (conti o m.6a3 \ SAFE 1Y ANALYSES, o"f * " 2 2-oo H 1 LCO, and In H0DE 3, 4, or 5 with the 1JodIontroT[SM ! APPLICABILITY capable ~ioffrodMthdrawarlor rodsTnotMy1Lhsertred3htst- l down, the Source Range Neutr n Flux trip Function must also be OPERABLE. If the, System is capable of rod ! withdrawal, the Source Range Neutron Flux trip must be i uw OPERABLE to provide core protection against a rod I withdrawal accident. If the% System is not capable of q s.u-ak rod withdrawalEwi_thirods,~N11yliinserted, the source range m 2.2 m detectors are not required to trip the reactor. However, their monitoring Function must be OPERABLE to monitor core neutron levels and provide indication of reactivity changes that may occur. es . result of ;;;nts lik; ; krer, d+ktion. Res; inputs .r; previ _ m __ The requirements for the NIS source range detectors in MODE 6 are addressed in LCO 3.9.3, " Nuclear Instrumentation."
- 6. Overtemnerature AT l
The Overtemperature aT trip Function is provided to ensure that the design limit DNBR is met. This trip Function also limits the range over which the Overpower AT trip Function must provide protection. The inputs to the Overtemperature aT trip include eH pressure, coolant temperature, axial power distribution, and reactor power as indicated by loop AT assuming full reactor coolant flow. Protection from violating the DNBR limit is assured for those transients that are slow with respect to delays from the core to the measurement system. Oc Furation
;.eniters kth veri;tien in p;.cr .ad 'l;W sire; e decrease ir. 'ic.e has the 3;. e effect er. eT as a p;.ar ireree3e.
The Overtemperature AT trip Function uses each loop's aT is a measure of reactor power and is compared with a l setpoint that is automatically varied with the following l parameters: l l reactor coolant average temperature - tie Trip l Setpoint is varied to correct for changes in coolant f density and specific heat capacity with changes in coolant temperature: (continued) WCGS-Mark-up ofNUREG-1431-Bases 3.3 B 3.3 16 5/15/97 l l l
- . _ _ _ ~. _ _ _ .._
i i l RTS Instrumentation B 3.3.1 i BASES i i APPLICABLE f. Turbine Imoulse Pressure. P-13 (continued) SAFETY ANALYSES, l LCO, and OPERABLE in H0DE 2. 3, 4, 5, or 6 because the l APPLICABILITY turbine generator is not operating. . 19. Reactor Trio Breakers l This trip Function applies to the RTBs exclusive of l individual trip mechanisms. The LCO requires two OPERABLE l trains of trip breakers. A trip breaker train consists of l all trip breakers associated with a single RTS logic train i g that are racked in, closed, and capable of supplying power d to th @ System. Thus, the train may consist of the o s-'ww main breaker or bypass breaker. cr min brakcr end bip;a
- w. a.m l bra ker. d; g r2ing u pr, . .
, .. m...ig ration. Two OPERABLE trains ensure no single random failure can disable the RTS trip capability.
, These trip Functions must be OPERABLE in H0DE 1 or 2 when ! the reactor is critical. In H0DE 3, 4, or 5, these RTS l trip Functions must be OPERABLE when the RBe-er l :s;xi;ted b3p;ss brahcrs are cles;d. end th CPO Rod Control System is capable of rod withdrawal o $ rods areinot; fully]nserted. , I os.n.nua ( ' _ p.s.s-604- )
- 20. Reactor Trio Breaker Undervoltaoe and Shunt Trio Mechanisms l The LC0 requires both the Undervoltage and Shunt Trip i Hechanisms to be OPERABLE for each RB that is in service.
The trip mechanisms are not required to be OPERABLE for g trip breakers that are o n, racked out, incapable of supplying power to the System, or declared inoperable I q s u-c, A under Function 19 above. OPERABILITY of both trip n o .2-o n l mechanisms on each breaker ensures that no single trip mechanism failure will prevent opening any breaker on a i valid signal. These trip Functions must be OPERABLE in H0DE 1 or 2 when I the reactor is critical. In H0DE 3, 4 or 5, these RTS ! trip Functions must be OPERABLE when the "JS and : i essoci;ted byp;ss br;;kcr; crc closed. ;nd the CPO Rod I (continued) l WCGS-Mark-up ofNUREG-H31-Bases 3.3 B 3.3 39 5/15/97 i
RTS Instrumentation B 3.3.1 BASES APPLICABLE 20. Reactor Trio Breaker Undervoltaae and Shunt Trio SAFETY ANALYSES, Mechanisms (continued) LCO, and APPLICABILITY r ControTSystem
~
is capable of rod withdrawal a.r. e n. ot.i..fu.lly~~ inserted. o/@. rods
. -. 43eed 21, Automatic Trio Loaic I
The LCO requirement for the RTBs (Functions 19 and 20) and Automatic Trip Logic (Function 21) ensures that means are provided to interrupt the power to allow the rods to fall into the reactor core. Each RTB is equipped with an
- undervoltage coil and a shunt trip coil to trip the i breaker open when needed. Each RTB is equipped with a bypass breaker to allow testing of the trip breaker while the unit is at power. The reactor trip signals generated by the RTS Automatic Trip Logic cause the RTBs and associated bypass breakers to open and shut down the l reactor.
i The LCO requires two trains of RTS Automatic Trip Logic to be OPERABLE. Having two OPERABLE channels ensures that random failure of a single logic channel will not prevent reactor trip. l l These trip Functions must be OPERABLE in H0DE 1 or 2 when ! the reactor is critical. In H0DE 3, 4, or 5, these RTS trip Functions must be OPERABLE when the IHBs-and nn;;;ted bg;n bin' c r; er; ciend. r. the CC Rod n,3.m g Control: a g notT.911/11 System W . is capable of rod withdrawal mmj org The RTS instrimentation satisfies Criterion 3 of th OC 'clicy l Statement 101CFR 50.36(c)(2)(11). l l 1 l ACTIONS A Note has been added to the ACTIONS to clarify the application l i of Completion Time rules. The Conditions of this Specification l may be entered independently for each Function listed in Table 3.3.1-1. i ! l
- In the event a channel's Trip Setpoint is found nonconservative 1 with respect to the Allowable Value, or the transmitter, i
- (continued)
WCGS-Mark-sp ofNUREG-1431-Bases 3.3 B 3.3 40 5/15197 l , i
RTS Instrumentation i B 3.3.1 BASES ! ACTIONS I (continued) instrument loop, signal processing electronics, or bistable is j found inoperable, then all affected Functions 49tqt]! provided by that channel must be declared inoperable and the LCO Condition (s) entered for the protection FunctionM chusdj affacted. thittlehnsd:QsunelsM73333eg _ 6 .D r D W W M M A M EZ.MleL M
!WBBaumidte: entered 'superatehlflot's@lM!PIKMh !
i F M !IsfM!E i When the nimber of inoperable channels in a trip Function exceed i those specified in one or other related Conditions associated I with a trip Function, then the unit is outside the safety analys1s. Therefore. LCO 3.0.3 must be immediately entered if ; applicable in the current MODE of operation. es usC Q M3.1e%j Condition A applies to all RTS protection Functions. Condi on A . addresses the situation where one or more required channels r one or more Functions are inoperable at the same time. The Required Action is to refer to Table 3.3.1-1 and to take the , Required Actions for the protection functions affected. The Completion Times are those hem foundWthe referenced Conditions and Required Actions. B . it+B . 2 . S.:..' 1 i S.2 1 1431&-l j Condition B applies to the Manual Reactor Trip in MODE 1 or 2. This action addresses the train orientation of the SSPS for this Function. With one channel inoperable, the inoperable channel must be restored to OPERABLE status within 48 hours. In this Condition, the remaining OPERABLE channel is adequate to perform the safety function. The Completion Time of 48 hours is reasonable considering that there are two automatic actuation trains and another manual initiation channel OPERABLE, and the low probability of an event occurring during this interval. (continued) WCGS-Mark-agp ofNUREG-1431-Baset 3.3 8 3.3 41 5/15/97
RTS Instrumentation B 3.3.1 BASES ACTIONS LL B.2. (continued) If the Manual Reactor Trip Function cannot be restored to OPERABLE status within the allowed 48 hour Completion Time, the unit must be brought to a H0DE in which the requirement does not apply. To achieve this status, the unit must be brought to at least H00E 3 within 6 additional hours (54 hours total time). foll;n d by egnia;; th; ",0 ; .;ithin 1 ;dditien;l hear $5 hour; tet;l ti;;d. The 6 additional hours to reach MODE 3 ;r.d th;
..~.m m .. ..~ ... . isJreasonable, based on operating experience, to reach MODE 3 ;r.d aga th; "5; from full power operation in an orderly manner and without challenging unit systems. With the RTBs egn ;nd th; unit in N0DE 3 thi; tri)i Turetica i; n; len,,.c r; quired t; b; ^^C",f."L CogM_tionEs entemd"ff;the' ManuarReactortiATunctionDhas~riotW,testored ari!"the
- - - RodT4nt~roTSystem'.is~ capable ~ormd Withi3 rant;-
m.---- oy e or rnore, reels art, rsol-b i ns.u.m \ g .33. coy C.1 purC.2.1 M C.t.2. mur + eA Condition C applies to the following reactor trip Functions in N3DE 3, 4, or 5 with the "0; ci;;;d end th: 0"O R6dThntiW System capable of rod withdrawal ~or prods ~not: fully; inserted: one. or sort) a2-u-*N Manual Reactor Trip: -- N *# #- RTBs: RTB Undervoltage and Shunt Trip Hechanisms: and Automatic Trip Logic. This action addresses the train orientation of the SSPS for these Functions. With one channel or train inoperable, the inoperable channel or train must be restored to OPERABLE status within ggw 48 hours. If the affected Function (s) cannot be restored to
,ga,aca g4hiw ma. OPERABLE status within the allowed 48 hour Completion Time, the same 40iheursio unit must be placed in a MODE in which the requirement does not falg mfertall rods apply. To achieve this status,'@2; ;;;u:;t b; egn;d(28@MErb G3 h>1upf-F W1)and;the_ Rod .ControTSysten/enderedTncapab
* *
- The additional nour t orrod~ withdrawal provides sufdcient within the time to accomplis thenext actionhou[r in an orderly
.G,,h lAv manner. _With the rods fully inserted, and Rod Control l System.
-~
[eg., b[de-ener g saihj nu CRDMs, lo3 openinpie. se 3.3 - 122.j or duner3.e.shgthe. mobr c3enerffee (MM seh . (continued) WCGS-Mark-up ofNUREG-H31-Bases 3.3 B 3.3 42 5/15/97
RTS Instrumentation B 3.3.1 BASES _ -m M C.2 1 -q 3-e agot ACTIONS C.1%_C.2.1(continued) e Tw. s.ser. i ig;apableJLtod ~ withdrawal "sT"; open, these Functions are no longer required. The Completion Time is reasonable considering that in this Condition, the remaining OPERABLE train is adequate to perform the safety function, and given the low probability of an event occurring during this interval. agge watw Wr" rittan wi 5 th Rod k mht61Wemhl~e~efftodytWamDr*Wnst"StflD i ic i= -- - - Ju.ed*fbrio.% 3(."KW'21YmJls
- is mi ~#
ot 1 3t$13'12k % : 2
--a han ? --- aimiYtM AnollcabiMtinilh11r11.
Y t f505)EPfTh arsNW F ontT19 E ' g, 7 wherf D ._ T smesmc meer a 3.3-4s J D.1.1. D.1.2. D.2.1. D.2.2. and D.3 Condition D applies to the Power Range Neutron Flux-High Function. l43-ts-seu \ MW bw3 3-oor _ ) The NIS power range detectors provide input to t System end the Z cter Lcycl Centrol Sy;tc;;; and, therefore, have a two out of four trip logic. A known inoperable channel must be placed in the tripped condition. This results in a partial trip condition requiring only one out of three logic for actuation. The 6 hours allowed to place the inoperable channel in the tripped condition is justified in WCAP-10271 P-A (Ref. 6 7). In additior. to placing the inoperable channel in the tripped conditime. THERMAL POWER must be reduced to s 75% RTP within 12 hours. Reducing the power level prevents operation of the core with radial power distributions beyond the design limits at a power level where DNB conditions may exist. With one of the NIS power range detectors inoperable.1/4 of the radial power distribution monitoring capability is lost. (continued) WCGS-Mark-up ofNUREG-1431-Bases 3.3 B 3.3 43 5115197
1 l INSERT B 3.3-43 0 3.3-135 Condition C is modified by a Note stating that while this LCO is not met for l Function 19, 20, or 21 in MODF 5. making the Rod Control System capable of rod withdrawal is not permitted. This Note specifies an exception to LCO 3.0.4 for j this MODE 5 transition and avoids placing the plant in a condition where contrei j rods can be withdrawn or not fully inserted while the reactor trip system is degraded. This Note is in addition to the requirements of LC0 3.0.4 which preclude the transition from either MODE 3 or MODE 4 to MODE 3 or MODE 4 with the Rod Control System capable of rod withdrawal or all rods not fully inserted for Functions 19, 20, or 21 with one channel or train inoperable. I l 1 i I l 1 l 1 l l l l l
RTS Instrumentation B 3.3.1 BASES ACTIONS G.1 and G.2 (continued) will allow a ;l;w er.d controlled power reduction to less than the P 6 setpoint and takes into account the low probability of occurrence of an event during this period that may require the protection afforded by the NIS Intermediate Range Neutron Flux trip. H:1 m W used Cendition :: ;pplic; t; th; Inter;; dict; ",eng; lcutren Ila trip can ".lC"Ed. POWE", i; bcisw th; " 0 ;ctp; int and ere er tw; crenrel; er; inegretic. "ci;w the ." 0 ;ctp; int, the llIS ;;ur;; r;n;c grfer;; tk renitoring r.nd pretection fureti;n;. He iregr;bic l?IS interadi;t; rs,; charel(;' au;t k r;turred to 0"C."XLE ;t;tu; prior to ice.;;;ing p;;;r ;beve th; " 0 ;;tp; int. Thc i'!S ir.tcr;;diete rang; charel; nu;t k 0"C"XL .; ten the p;;;r i n ci i; stev; t k a pbility of the ;;ur a r a g;, ." 0, ed ki;w the sphility of tk gw;r rer.g;, " 10. L.1 Condition I applies to one inoperable Source Range Neutron Flux trip channel when in MODE 2, below the P 6 setpoint .' end pericr;ing a ractor ;t;rtup or in tiOOE 3, 4, or 5 with th ""; ci;;cd ad the C"" Sy;t a s pbic ;f red withdi a:1. With the unit in this Condition, below P 6, the NIS source range perfoms the monitoring and protection functions. With one of the two channels inoperable, operations involving positive reactivity additions shall be suspended inmediately. This will preclude any power escalation. With only one source range channel OPERABLE, core protection is severely reduced and any actions that add positive reactivity to the core must be suspended immediately. 11 Condition J applies to two inoperable Source Range Neutron Flux trip channels when in MODE 2, below the P 6 setpoint, and performing a reactor startup, or in MODE 3, 4, or 5 with thek closWd.adif thiIKdfystem capable of rod withdrawal. With_the b%1 or one o e rods no m 2.s.cor. 1 Q h ertek (conti?ued) WCGS-Mark-up ofNUREG-1431-Bases 3.3 B 3.3 47 5/15197
RTS Instrumentation B 3.3.1 BASES ACTIONS L1 (continued) unit in this Condition, below P 6, the NIS source range performs the monitoring and protection functions. With both source range channels inoperable, the RTBs must be opened immediately. With the RTBs open, the core is in a more stable condition; end tM unit enter; 0;nditi a L. , m aoi aaA K.9..t -
$s.t.oorl K.ly K.2.1 tiiS r
h La (Wrdt h*W capW.afr rod t4ihArm
- c. e x e not Etb sei M cA.
Condition K app' 1es to one inoperable source range channel in MODE 3, 4. or 5"with tk RO : ci;;;d ad tM ORO Sy;t s a p ti:
;f red withdr;.;;1. With the unit in this Condition, below P 6, the NIS source range performs the monitoring and protection functions. With one of the source range channels inoperable.
oc. Hon mune. 48 hours is allowed to restore it to an OPERABLE status. If the
'^'g gg;n h - channel cannot be returned to an OPERABLE statuf. I additional
, 4 % .h hour is allowed to @HyJgoiltpdj,4GseaMisceM11sTd i3
, is in a more stable condition aWodtsfidsFtist~4 ppt 1ipW11143Def
[All iwrt y W@ tilegitlan~;...d tM mit .c.tc. ; %;; ired f; tim X.0, L 0.c.ditix L. The allowance of 48 hours to restore the channel to , g,g g urt.xABLE statuf, and the additional hour todEfdT3aHmiert?M nt. 3.3-%- MWWWWWstem$n a~MnWhg ruavithdrawalh.EoMpattenunciskin :I?t; IMU h=J.us@egn tM RO;, are justified in Reference 6 7* r -
-J l (e.g., i 3de-ener3i a'i$,all CR0th,b-39n$
ibe. RW, av de-ener3 aij h mahw' L.1. L.2. and L.3 (3ener4*r (Pter) octq* a n.nt.( lisOled 0;r.dition L ;ppli s d.;n tk r;;;ir;d r " ;r c' 0"C"X LE % ;r;;
%..g %;tren .'1;;; ;Mrc.;l; i; .et at in .".00: 2, 4. er 5 with tk RO; egn. With t k unit in thi; 0;nditi;n. th; M S nur a rug per%r ; tk ;r.iterin; ;nd pretatien function. Mith 1;;;
tMa tk r;;;ir;d r;*:r ;f zur;; re;; ;Mn .;11,0fff=LE.
;g r;ti;n; involving p ;itiv; r;ectivity ;ddition; ; hell k
- -r-5..ded ir.-a dt;ttiy. Thi; will p ;;lud; my p;.;;r ;;Gl; tion.
(continued) WCGS-Mark-up ofNUREG-1431-Bases 3.3 8 3.3 48 5/15/97
RTS Instrumentation B 3.3.1 BASES , - - - -- -
- n=3ait, A c,~uw c.q a ACTIONS R.1 and R.2 (continued) (stre -tra.y.i~e.=A. _
based on operating experience, to reach H00E 3 from full power in l an orderly manner and without challenging unit systems. The 1 hour and 6 hour Completion Times are equal to the time allowed by LCO 3.0.3 for shutdown actions in the event of a complete loss; of RTS Function. Placing _the unit in MODE 3Cemoves.t.h_e7# fegutfemenffordhi&13ct4cWEunctioTQ @3* ** rn. s.1-car N The Reouired Actions have been modified by two Notes. Note 1 allows one*chenrel @to be bypassed for up to 2 hours for g;, s.2 -43. j g,A*O - surveillance testing, provided the other train ;henral is OPERABLE. Note 2 allows one RTB to be bypassed for up t; 2 h;urs f6r-the time' required for maintenance on undervoltage or shunt trip mechanisms:up to the limit of" time allowed;in the-Completion Time-of" Condition U provided 4f the other RB train is OPERABLE.
";; 2 he.r tit 4 li;;;it de;; .et eit;r t.'i_7;Wirid Cwl;tica S.;; for ;n irep;reble trein and is Justified in "ef;rcre; 7.
S.1 and S.2 Condition 5 applies to the P 6 and P 10 interlocks. With one or moref required channel (s) inoperable, for ecc cut of ta or tw cut of f;;r ;;irciden;; ;;;ic, the associated interlock must be verified by observation of the-associatedfpermissive annunciator window-to be in its required state for the existing unit condition within 1 hour or the unit must be placed in H0DE 3 within the next 6 hours. Verifying the interlock status manually accomplishes the interlock's Function. The Completion Time of 1 hour is based on operating experience. and the minimum amount of time allowed for manual operator actions. The Completion Time of 6 hours is reasonable. based on operating experience to reach H0DE 3 from full power in an orderly manner and without challenging unit systems. The 1 hour and 6 hour Completion Times are equal to the time allowed by LC0 3.0.3 for shutdown actions in the event of a complete loss of RTS Function. l T.1 and T.2 Condition T applies to the P 7. P 8. P 9, and P 13 interlocks. With one or more channel (s) or train inoperable, for era cut-of tw or tit; cut of f;ur ;;incid;re; logic, the (continued) WCGS-Mark-up ofNUREG-1431-Bases 3.3 B 3.3-53 5115l97
RTS Znstrtmentation B 3.3.1 BASES _ ACTIONS T.1 and T.2 (continued) associated interlock must be verified byL~ob;servationlofm the associatedfpensis_slyelannunciator_w1ndow;to be in its required state for the existing unit condition within I hour or the unit must be placed in MODE 2 within the next 6 hours. These actions-are conservative for the case where power level is being raised. Verifying the interlock status manually accomplishes the interlock's Function. The Completion Time of 1 hour is based on operating experience and the minista amount of time allowed for manual operator actions. The Completion Time of 6 hours is reasonable, based on operating experience, to reach MODE 2 from full ocwer in an orderly manner and without challenging unit systems. U.1. and~U.2-4. rd ".2.2 Condition U applies to the RTB Undervoltage and Shunt Trip Mechanisms, or diverse trip features, in MODES 1 and 2. With one of the diverse trip features inoperable, it must be restured to an OPERABLE status within 48 hours or the unit must be placed in a MODE where the requirement does not apply. This is accomplished by placing the unit in MODE 3 within the next 6 hours (54 hours total time) f;11ced by ; gain; tra P,2; in 1 ;dditiesi hour (55 h;;r; t;tel tin'. The Completion Time of 6 hours is a reasonable time, based on operating experience, to reach MODE 3 from full power in an orderly manner and without . challenging unit systems. 4 3 L5" m er svwrc. TR 34'0Wa l With the P,0; ega r.r.d th; unit in MODE 3. Condit1NC is~inYeijed iCWingperableJ,triimechanism;has' not 1xuinje!Lt :andithe RbdTantrol,IERstealsicapable~of~ rod ~withdrawalv late not~imlyftnserted. thi; tr4 rur.;ti= i; a; la.;c rquired :: ; be-OPEM8bE. The affected RTB shall not be bypassed while one of the diverse features is inoperable except for the time required i to perform maintenance to ,Whinoperableltripi@sm toiOPGtMILEist[atusZaa of 02 diurn futur;;. Oa ;11cil; , j tin fa grfe.-..ir.; mir.t;xx; cf th; dinrx futur;; i; 2 h ar; fa tra ru na; ;t;ted unda Og.diti a Ps. The Completion Time of 48 hours for Required Action U.1 is ' reasonable considering that in this Condition there is one i
- (continued)
WCGS-Mark-up ofNUREG-1131-Bases 3.3 B 3.3 54 5/15/97
CHANGE NUEER JUSTIFICATION 3.3 86 Not applicable to Wolf Creek. See Conversion Comparison Table (Enclosure 6B). 3.3-87 Not Used. 3.3-88 Not Applicable to Wolf Creek. See Conversion Comparison Table (Enclosure 6B). 3.3 89 Not Applicable to Wolf Creek. See Conversion Comparison Table (Enclosure 68). 3.3 90 Not Applicable to Wolf Creek. See Conversion Comparison Table (Enclosure 6B). 3.3 91 Not Applicable to Wolf Creek. See Conversion Comparison Table (Enclosure 6B). 3.3 92 Not Applicable to Wolf Creek. See Conversion Comparison Table (Enclosure 6B). 3.3 93 ITS 3.3.1 Condition V is deleted. It is not entered froa Table 3.3.1-1 nor do the Bases clarify when it would be needed. raising the concern of misinterpretation. Condition V does not replace LCO 3.0.3 requirements to assess when the plant is outside the licensing basis. There is no similar ACTION Statement in the current TS for the Reactor Trip System. This change is consistent with traveler TSTF - 135.
--- A9:5.3-% 1 3.3-95 ITS 3.3.1 Condition H. Required ACTION H.1. and the second part of Function 4 Applicability (HODE 2 below P 6) in ITS Table 3.3.1 are deleted since they provide no real compensatory measures. [].
In accordance with LCO 3.0.4. the intermediate range detectors NW must be OPERABLE prior to entering the Applicability of the retained part of Function 4 (i.e. H0DE 2 above P-6). Condition H and Required ACTION H.1 ensure the same thing and, therefore. _can be deleted. This change is consistent with TSTF-135. _W +he* deleton. **m b no need in vt h > No pplicga A Con &hdas F.wd.cr. 3.3 96 [ Note 2 for ITS SR 3.3.1.2 is revised to replace the bracketed 12 hour time constraint with 24 hours. No such time limit is contained in the current TS which has an SR 4.0.4 exception. S/15/97 WCGS-Differencesfrom NUREG-1431-ITS 3.3 11
INSERT 6A-11a 0 3.3-94 ITS 3.3.4 is revised per current TS (3.3.3.5) with regard to [ auxiliary shutdown panel, ASP) controls. [ ASP] controls are added to the 1.C0, Condition A. and SR 3.3.4.2. By explicitly including the controls, the specification is clarified to be more than instrumentation. This change is acceptable because it does not change the meaning while retaining the clarity of the current TS. I 1
)
l l b i l l l
- i i
i l l I
l I i i NUMBER JUSTIFICATION 3.3 106 ISTS 3.3.1 Required Actions B.2.2 and U.2.2 are not used, consistent with the current TS requirements of LCO 3.3.1 ACTION Statements [1.9.10, and 12] and the Applicability for ITS Table 3.3.1-1 Functions 1 and 20. The current TS provides for these Functions to be restored to OPERABLE status within 48 hours or the plant must be in HOT STANDBY within the next 6 hours when the i plant is initially in H0 DES 1 or 2. Once HOT STANDBY has been reached, the shutdown mode applicabilities, i.e. MODES 3.4, and i 5, prevail. When in these MODES, another 48 hour A0T is allowed by the current TS or rod withdrawal must be precluded in the next one hour. Therefore, ISTS Required Actions B.2.2 and U.2.2 for Functions 1 and 20 in Table 3.3.1-1 are not necessary since the performance of Required Action B.2.1 and U.2.1 takes the plant to I H0DE 3, exits the Anplicability, and requires entry into l Condition C. This change is consistent with ITS 1.3 and 3.0.4g'- l
%d.Qve.lcr T5TF- 135Q %J-L5,ito l l 3.3 107 Based upon operating experience to change Thermal Power in a l controlled fashion without challenging the plant and consistent l with current TS which does not have a Completion Time for restoring one channel to Operable status; but does prevent loing above P-10 until it is restore, the Completion Time for ITS 3.3.1 Required Actions F.1 and F.2 should be increased to 24 hours.
Condition F of ITS 3.3.1 is for one Intermediate Range Neutron Flux channel inoperable. Reactor protection would be provided by the Operable Intermediate Range Neutron Flux channel and Operable Power Range Neutron Flux channels. Indication would be available from the Operable Intermediate Range Neutron Flux channel, [from ! Operable NIS detectors], and from Operable Power Range Neutron Flux channels with _ power approaching P-10.jfhe sting us Owner roup is nsiderin a gener' chang n this sue A. d ration ere not let the of ou ubmittal. 3.3 108 Not Used. 3.3 109 Not Used. 3.3-110 Not Used. 3.3 111 No 01f Cc6ek. Se(ConvermtfiiCodis 43 3 ~* I clos - 6 . IMGRT GA-i4u - 3.3-112 Not Used. 3.3 113 Not Useo. } WCGS-Differencesfrom NUREG-1431-ITS 3.3 14 S/1587
l INSERT 6A-14a 0 3.3-48 l This change adds a note to ITS SR 3.3.1.7 for source range instrumentation to verify interlocks P-6 and P-10 are in their required state for existing unit. conditions. This is consistent with the current TS and is an enhancement which is easily performed and provides additional assurance that the interlocks are functioning correctly. l i
CHANGE NUMBER JUSTIFICATION 3.3-114 Not Used. , l 3.3-115 Not Used. ! 3.3 116 Not Applicable to Wolf Creek. See Conversion Comparison Table (Enclosure 6B). 3.3 117 This change to ITS 3.3.1 Condition R reflects current TS Table [3.31. ACTION Statement 12] which was based on NRC Generic Letter 85 09. < 3.3-118 This change is for consistency with ITS 3.7.10 Condition [0 and l E]. 3.3 119 Not Applicable to Wolf Creek. See Conversion Comparison Table (Enclosure 6B). , ,lo 3.3-@ \ 3.3-120 S3 s edgo ecf IT8'5R 3f4.2'and CN 3.3 121 Not Applicable to Wolf Creek. See Conversion Comparison Table (Enclosure 68). l l 3.3 122 ITS 3.3.1 Applicability Note (b) for Functions 1, 5. 19-21 and Conditions C and K are revised to replace Actions requiring the RTBs to be opened with actions that ensure subcriticality is t q ,3,3,g Wh* all rods and ensuring the nes.s-occ.
#" maintained Rod Control System (i.e.,is bf fully insert incapable o @f rod withdrawal) yet do not)
~
initiate a feedwater isolation (P 4 and low Tm) in MODE 3 consistent with traveler TSTF-135. 3.3 123 Not Applicable to Wolf Creek. See Conversion Comparison Table (Enclosure 6B). ! 3.3 124 Consistent with the current TS Table 4.31. Note [17] the notes i for ITS SR 3.3.1.4 and Table 3.3.11. Function 20 are modified to l clarify that the SR is required for the reactor trip byoass j breaker local manual shunt trip only. The Bases for SR 3.3.1.14 , l clearly state that SR includes the automatic undervoltage trip of I the reactor trip bypass breakers. The Note (k) added to Table l 3.3.1-1 Function 20 clarifies the Applicability of the undervoltage and shunt trip mechanisms to include those functions of the reactor trip bypass breakers when in use. WCGS-Differencesfrom NUREG-1431-ITS 3.3 1S S/15/97
j CHANGE NLMER JUSTIFICATION , 3.3 125 ITS SR 3.3.1.11 is modified by a Note that requires verification that the time constants are adjusted to the prescribed values. The addition of this Note is consistent with SR 3.3.1.10 and is ; required because SR 3.3.1.11 is used for the Power Range Neutron Flux - High Positive Rate O trip function which has a time constant associated with its calibration. 3.3 126 Not Applicable to Wolf Creek. See Conversion Comparison Table (Enclosure 6B). 3.3-127 Not Applicable to Wolf Creek. See Conversion Comparison Table (Enclosure 6B). 3.3-128 Not Applicable to Wolf Creek. See Conversion Comparison Table (Enclosure 6B). 3.3-129 Not Applicable to Wolf Creek. See Conversion Comparison Table ! (Enclosure 6B). l 3.3-130 Not Applicable to Wolf Creek. See Conversion Comparison Table f (Enclosure 6B). i 3.3 131 Not Applicable to Wolf Creek. See Conversion Comparison Table (Enclosure 68). 3.3-132 Not Applicable to Wolf Cred. See Conversion Comparison Table { (Enclosure 6B). ! 3.3 133 Not Applicable to Wolf Creek. See Conversion Comparison Table I (Enclosure 6B). WC 3SotD _ 3.3 134 The in nidt Ko TS 3 .2 ha n is onsi ent) w curr t TS able .3 ion [ for ncti 7b t 43 pro 'de 4 urs f the add ona han to be aced byp for rveil nce t ting oth ch NseRT s.A-iw ,- _ - - 3.3-135 A H0DE change restriction has been added to ITS 3.3.1 Condition C per the matrix discussed in CN 102 LS 1 of the 3.0 package. (See the LS 1 NSHC in the CTS Section 3/4.0. ITS Section 3.0 package). 3.3 136 The TAD 0T performed under ITS SR 3.3.2 7 includes verification of relay setpoints since the trip actuating devices being tested are i 1 the same circuits tested under ITS SR 3.3.5.2. [iM5&Jt.T (4-/(.,l WCGS-Dsfferencesfrom NUREG-1431-ITS 3.3 16 S/15/97
9 INSERT 6A-16 CHANGE - NUMBER JUSTIFICATION l 3.3-137 Not Applicable to Wolf Creek. See Conversion Comparison Table (Enclosure 6B). i ICP'A S -oo3 ] 3.3-138 Not Applicable to Wolf Creek. See Conversion Comparison table (Enclosure 6B). I oc Au.-oo 2.1 3.3-139 Not Applicable to Wolf Creek. See Conversion Comparison Table (Enclosure 6B). (cA 3.5-co 1] 3.3-140 Not Applicable to Wolf Creek. See Conversion Comparison Table ; (Enclosure 6B).
\cs p -san 1 3.3-141 Not Applicable to Wolf Creek. See Conversion Comparison Table (Enclosure 6B). , 3,, ,
Ta, :s .s . cod. l-3.3-142 Adds "or trains" to ITS Condition A, consistent with ITS 3.3.2 and traveler TSTF-135. . , 3.3-143 Not used. i
\ Q 3.3.i u \
3.3-144 Not Applicable to Wolf Creek. See Conversion Comparison Table (Enclosure 6B). . l t
=
_ . _ . _ .__ _ . . _ . . . . _ . . _ _. _. _.. ._. __ . _ _._ ._. ...._..__.__._._._m._. __ t INSERTL6A-16a WC 3.3-018
' The NOTE in Condition K of ITS 3.3.2 has been revised consistent with current TS Tab l e:3.3-3. Action Statement 30 for Funct i onal Unit 7.b., Refueling Water Storage Tank Level (RWST) - Low-Low Coincident with Safety Injection. Amendment No. 117 dated.May 28, 1998, added a new Action Statement to CTS 3/4.3.2, Table ;
' 3.3-3, Functional Unit 7.b., Refueling Water Storage Tank Level . (RWST) - Low-low :
Coincident with Safety Injection. The changes made to Condition K and associated Bases are consistent with those provided'in the License Amendment-Request that resulted in Amendment No. 117. j i l l i i l l
-1 l
I I 1
%--*i ,. y - w - . .- _ ,--.-.r -
----w-+ w - - . - -- - e
I Page 15 of 23 CONVERSION COMPARISON TABLE FOR DIFFERENCES FROM NUREG-1431 SECTION 3.3 TECH SPEC CHANGE APPLICABILITY DIABLO CANYON COMANCHE PEAK WOLF CREEK CALLAWAY NUMBER DESCRIPTION Revise ITS 3.3.9 to apply in HDDE 2 only below P-6 and to No - not in current No - not in current No not in current Yes 3.3-88 TS. reflect ACTION Statement 5.b per current TS Table 3.3-1. TS. TS. No not in current No - not in current No not in current Yes 3.3 89 Revise COT in ITS SR 3.3.9.3 to add the 4 hour allowance TS. TS. TS. from ITS SR 3.3.1.7. No - not in current No - not in current No - not in current Yes 3.3-90 Exclude neutron detectors from CHANNEL CALIBRATION ITS I QJ-ts 6su I TS. TS. TS. SR 3.3.9.4 per current TS Table 4.3-1. Functional Unit 6. J 8 3 3-o64 1 Note t4c.-@TSrG-ISG Add CHANNEL CHECK and response time surveillances (ITS No - not in current No - not in current No - not in current Yes 3.3-91 TS. ! Q 3-1,5-464 per current TS Table 4.3 1, is. TS. IT83 3.3 cob SR 3.3.9.1 Functional Unit 6.and Note 12 SR 3.3.9.5)M_TSTF- lO No adopted ISTS No not in current No adopted ISTS Yes 3.3-92 Adds SR 3.3.4.2_ Note that the ASP controls for the TDAFW pump (mO&%gt)are not required to be verified prior to format. TS. format. p g_ng entry into N DE 3. consistent with current TS SR 4.3.3.5.3. Yes Yes Yes ITS 3.3.1 Condition V is deleted. It is not entered from Yes 3.3-93 Table 3.3.1-1 nor do the Bases clarify when it would be t needed, raising the concern of misinterpretation. Condition V does not replace LC0 3.0.3 requirements to assess when the plant is outside the licensing basis. - - ( Ng Yes 3.3 94 ITS 3.3.4 is revised per current TS [3.3.3.5] with regard Qigs, t4o) Yes (fo Yes to [ ASP] controls. S/IS/97 c WCGS-Conversion Comparison Tame-ITS3.3
CONVERSION COMPARISON TABLE FOR DIFFERENCES FROM NUREG-1431 Page 29 of 23 SECTION 3.3 TECH SPEC CHANGE APPLICABILITY NUMBER DESCRIPTION DIABLO CANYON COMANCHE PEAK WOLF CREEK CALLAWAY 3.3-122 ITS 3.3.1 Applicability Mote (b) for Functions 1, 5, 19 21 Yes Yes Yes Yes and Conditions C and K are revised to replace Actions requiring the RTBs to be opened with actions that ensure . Iss.Ls-ce.sj ] suberiticality is maintained (i.e., by* fully insert @ all ,.g.gD g, Tre. u-oor. l rods and ensuring the Rod Control System is incapable of -- - rod withdrawal) yet do not initiate a feedwater isolation (P-4 and low T,) in MODE 3, consistent with traveler TSTF 135. 3.3-123 This change deletes ACTION L.2 and renumbers L.3 since the Yes - refer to LA No - see CN 3.3-41. No - see CN 3.3 41. No - see CN 3.3 41. requirement to close the unborated water source valves is 28/27. not in the CTS. 3.3-124 Consistent with the current TS (Table 4.3-1, Note [17]). Yes Yes Yes Yes the Note on ITS SR 3.3.1.4 and Table 3.3.1-1 Function 20 are modified to clarify that the SR is required for the reactor trip bypass breaker local manual shunt trip only. The Bases for SR 3.3.1.14 clearly state that SR includes the automatic undervoltage trip of the reactor trip bypass > breakers. The Note (k) added to Table 3.3.1 1, Function 20 clarifies the Applicability of the undervoltage and shunt trip mechanisms to include those functions of the reactor trip bypass breakers when in use. 3.3-125 ITS SR 3.3.1.11 is modified by a Note that requires Yes Yes Yes Yes verification that the time constants are adjusted to the prescribed values. The addition of this Note is consistent with SR 3.3.1.10 and is required because SR 3.3.1.11 is used for the Power Range Neutron Flux - High Positive Rate trip function which has a time constant associated with its calibration. WCGS-Conversion Comparison Tame-ITS3.3 S/15/97
t CONVERSION COMPARISON TABLE FOR DIFFERENCES FROM NUREG-1431 Page 23 of 23 SECTION 3 3 TECH SPEC CHANGE APPLICABILITY NUMBER DESCRIPTION DIABLO CANYON COMANCHE PEAK WOLF CREEK CALLAWAY 3.3-134 This change is Wolf Creek specific to revise the NOTE in No No Yes No see CN 3.3 18. Condition K of ITS 3.3.2 consistent with current TS Table + -- - - - 30 f* { g3,ga 1 tio -for tion and l .' . 4J - 3 3-3. Ae t*M p.3.3 f gypa, ide or srseilla_an a esti o of o _h pl nels n N '7 1 3.3-135 A MODE change restriction has been added to ITS 3.3.1 Yes Yes Yes Yes Condition C per the matrix discussed in CN 1-02.LS-1 of the 3.0 package. 3.3 136 The TADOT performed under ITS SR 3.3.2.7 includes No - adopted ISTS' No adopted ISTS Yes Yes verification of relay setpoints since the trip actuating format. format. devices being tested are the same circuits tested under ITS SR 3.3.5.2. iusutr 4.s '2 3 b WCGS-Conversion Comparison Table-ITS3.3 5/15/97 '
INSERT 6B-23 i TECH SPEC CHANGE APPLICABILITY DIABLO CANYON COMMANCHE PEAK WOLF-CREEK CALLAWAY ! NUMBER _ DESCRIPTION ' The Condition for Function 4.c is changed Yes No - Insert 1 No - Insert 1 No - Insert 3.3-137 from Condition D to E consistent with DCPP hA3.3.m2.I CTS ! Yes No No 3.3- This CPSES-specific change revises Table No 138 3.3.1-1. Note 1 to reflect new Overtemperature N-16 parameters approve for ' Unit 2 in' Amendment 55/41, and submitted [ce s,3_oo3\ l for Unit 1 in LAR 97-003. , 6 No No 3.3- This change adds new SR 3.3.2.13 which is Yes No , 139 the performance of an 18 month TA00T. SR %me2 { 3.3.28 is the performance of a TADOT every 24 months for DCPP. Changes to RTS and ESFAS delta T Functions No No No Yes ; 3.3-140 are made to reflect Callaway OL Amendment gg , No. 125 dated 4/13/98. Ctanges to ESFAS Feedwater Isolation No , No No Yes 3.3- ! 141 Functions are made to reflect Callaway OL~ %A '3.S -co2.} < Amendaient No.126 dated 4/23/98.
- Yes Yes Yes e yt:s-cas.o 3.3- Adds "or trains" to ITS Condition A. Yes 1W 3 3-oo' _
, 142 Consistent with ITS 3.3.2 and TSTF-13E. l Not used. N/A N/A N/A N/A 3.3-143 No No I 3.3- SR 3.3.7.3 and 3.3.7.4 are deleted for DCPP Yes No 144 since there are no actuation logic or i master relays associated with the CRVS i pressurization system actuation via the Q 3.3-lM , CRVS atmosphere intake radiation monitors. [ f Insert 1: Bypae.s Action applies to containment pressure High-3. not High-2 (different design). ;. h i l ! I
ADDITIONAL INFORMATION COVER SHEET i l ADDITIONAL INFORMATION NO: Q 1-B GEN APPLICABILITY: DC, CP, WC, CA REQUEST: Generic Bases Changes RAI Comment: (1) For all topical reports listed in the Section 3.3 Bases provide documentation of an NRC staff letter approving plant-specific use of topical report TS changes. (2) Respond to reviewer comments on ITS Bases deviations from ITS which will be provided once agreement is reached on the LCO requirements and the supporting Bases changes are provided to the reviewer. Based on 8/14/98 no response is required to item (2). ; FLO3 RESPONSE: This RAI must be addressed on a plant-specific basis. i Plant Specific Discussion The Wolf Creek ITS Bases for RTS and ESFAS reference 3 WCAPs. WCAP-9226 is taken from the current TS Bases page B 2-5; it discusses small steamline breaks for which the overpower AT trip provide protection. WCAP-10271-P-A was approved for Wolf Creek in Amendment Nos.12 - l dated November 2,1987 and 43 dated March 29,1991. WCAP-13632-P- , A was approved for Wolf Creek in Amendment No.113 dated October 20, 1997. It is noted that this issue is also the subject of traveler TSTF-111 l Rev. 4. ATTACHED PAGES: None l 1 I i I i
i ADDITIONAL INFORMATION COVER SHEET ADDITIONAL INFORMATION NO: O 1-01 APPLICABILITY: DC, CP, WC, CA REQUEST: A Note, " Separate Condition entry is allowed for each Function," is added to the ACTIONS for the Reactor Trip System, ESFAS, (Remote Shutdown, including each required i ASP control], and Accident Monitoring instrumentation. This change clarifies those situations i where the current TS ACTION Statements are not uniquely associated with a particular Function , or where the required channels are specified on a per steam line, per loop, per SG, per bus, etc., basis. Comment: The new note Separate Condition entry allowed for each function is justified as an administrative change reflecting the current interpretation of the technical specification requirements. This is inconsistent wlth the fact that CTS LCO 3.3.3.5 explicitly provides for separate condition entry (Action c). If separate condition entry is the general practice, one would expect that explicit provision for this would be unnecessary in LCO 3.3.3.5. Thus, adopting " separate condition entry" where CTS actions are not uniquely associated with a particular Function can not be evaluated as
" administrative changes" as stated in this DOC. Evidence that separate condition entry l is the current interpretation for the other LCOs should be provided.
FLOG RESPONSE: The reference to CTS LCO 3.3.3.5 Action c applies to DCPP only. DCPP received an amendment in 1994 (LA 94/93 for Units 1 and 2, respectively) that was based on adopting some of the language of NUREG-1431 regarding separate Condition entry. The separate Action or Condition ; entry language is not found in the old STS, NUREG-0452. Separate Condition entry is, in fact, the established plant practice at all FLOG plants where required Functions are listed in tables and often use common Action Statements. DOC 1-01-A has been revised to provide further l discussion. ATTACHED PAGES: Encl.3A 1 Encl. 5B B 3.3-157 r A r -
l DESCRIPTION OF CHANGES TO CURRENT TS SECTION 3/4.3 This enclosure contains a brief description / justification for each marked up change to the current Technical Specifications. The changes are identified by change numbers contained in enclosure 2 (Mark-up of the curre.nt Technical Specifications) . In addition, the referenced No Significant Hazards Considerations (NSHCs) are contained in enclosure 4. Only technical changes are discussed: administrative changes (i.e. format, presentation, and editorial changes) made to conform to NUREG 1431 Revision 1 are not discussed. For enclosures 3A, 38, 4, 6A. and 6B, text in brackets "[]" indicates the information is plant specific and is not common to all the Joint Licensing Subcommittee (JLS) plants. Empty brackets indicate that other JLS plants may have plant specific information in that bracket. CHANGE NUMBER ESE DESCRIPTION 1 01 A A Note, " Separate Condition entry is allowed for each Function." is added to the ACTIONS for the Reactor Trip System. ESFAS, [ Remote Shutdown Instrumentation), and Accident Honitoring Instrumentation. This change clarifies those situations where the current TS ACTION Statements are not uniquely associated with a particular Function or where the required channels are specified on a per stecm line, per loop, per SG. per bus, etc., basis. This change is consistent with current operating practices and NUREG-1431 Rev. 1. [ Relaxations associated with this change are discussed
~
in CN 2 46-LS 42.] Gbwtr .si-s ay.f a :-o s l 1 02 LG The current TS requires that response time testing be performed on each reactor trip and ESFAS function every 18 months and that alternate trains be tested in successive tests. The current TS description of the channel testing protocol matches the improved TS definition of STAGGERED TEST BASIS. However, several trip functions do not require response time testing, as indicated by N.A. in the tables of response time limits [previously relocated to a licensee controlled _ ,4 document]. The improved TS specify thatteg5eef) response time testing be performed on a STAGCiERED TEST BASIS and does not impose any requirements as _to_.which_g3,3,ss-( train should be tested. Therefore. Ethe%cflPfectIwf# McurrEnt'T54D@the requirement to ensure that each train is tested every 36 months is moved to the Bases for ITS SR 3.3.1.16 and SR 3.3.2.10.
}w. 3.3&ij 1-03 LS 1 In curr S SR 4.3 .2andf3.7.2,t active v b e4 d g 11c M e b W f & cek. i is nged from " nstr t6d" to "v 1fied". 1s ows React rip S em and S senso esponse se. swsn Cof ow Ah. (Enda.unn.3B),
i time ver' cation be perf d in re rence to j WCAP- 632-P- evision Eliminatj - of Pre are ) QensorR_es nse Time Testing requirements" is cha gn e WCGS-Description ofchanges to CTS 3M.3 1 S/1S/97 1
INSERT 3A-la 0 1-01 1 Separate Condition entry is the established plant practice at all FLOG plants where required instrument Functions are listed in tabular format. The L inoperability of one instrument Function has no impact on the operability of unrelated instrument Functions. The tabular format of the instrumentation tables with. common Action Statements for many Functions mandate separate Condition entry, otherwise a single isolated problem with one instrument channel could unduly restrict plant operation. Unless separate Condition entry were the current practice, no plant could have more than a single inoperable channel for all of the RTS Functions. Likewise, the inoperability of a channel in one loop for a Function specified on a "per loop" required channel basis has nothing to do with other channels in other loops of that Function (barring a common mode failure which is addressed by LCO 3.0.3). Since this change does not affect the operating limits or manner in which the plant is currently operated, this is an administrative' change. i
)
i I l 4 l j l 1 i I'
- - . . - - . _ . . . ~ - - - - - . - - - -.- - ..-. - ..-.- - -. - -
Remote Shutdown System B 3.3.4 BASES (continued) ACTIONS Note 1 is included which excludes the MODE change restriction of LCO 3.0.4. This exception allows entry into an applicable MODE j while relying on the ACTIONS even though the ACTIONS may eventually require a unit shutdown. This exception is acceptable due to the low probability of an event requiring the Remote Shutdown System and because the equipment can generally be repaired during operation without significant risk of spurious trip. Note 2 has been added to the ACTIONS to clarify the application of Completion Time rules. Separate Condition entry.is allowed for each Function listed on Table 3.3.4-1(* The Completion Time (s) of the inoperable channel (s)/ train ( of a Function will be tracked separately for each Function sta ing from the time the Condition was entered for_that Function. gq 33qq,g j sused 63/5151 kp e reguded. ASPcontr)ed. l' g :-os 1 Condition A addresses the situation where one or more requir_ed Functions of the Remote _ Shutdown Systen M N _ [4 3,3. w g L 1.ppe M9 Eunefinn-N*whin Table 3.3.41 gas-en!11-es-the l conWane';pensferAut$chesMr oneer more requ. l cAspe,ntrota see mooeratAa_ . _ l' The Required Action is to restore the required Functio o OPERABLE status within 30 days. The Completion Time is based on operating experience and the low probability of an event that would require evacuation of the control room. I B.1 and B.2 l l If the Required Action and associated Completion Time of l Condition A is not met, the unit must be brought to a MODE in which the LCO does not apply. To achieve this status, the unit must be brought to at least MODE 3 within 6 hours and to MODE 4 within 12 hours. The allowed Completion Times are reasonable, based on operating experience to reach .the required unit conditions from full power conditions in an orderly manner and without challenging unit systems.
- (continued) ;
l WCGS-Mark-gp ofNUREG-1431-Bases 3.3 B 3.3157 5/15/97
r I l ! INSERT B 3.3-157 0 1-01 i ( When the Required Channels in Table 3.3.4-1 are specified on a per trip breaker. per SG, or per pump basis, the Condition may be entered separately for each trip breaker, SG, pump, etc., as appropriate." 1 I l l I l l I l i r l l l i T.
l l l ADDITIONAL INFORMATION COVER SHEET ADDITIONAL INFORMATION NO: O 1-02 APPLICABILITY: DC,WC REQUEST: The improved TS specify that required response time testing be performed on a STAGGERED TEST BASIS and do not impose any requirements as to which train should be tested. The requirement to ensure that each train is tested every 36 months is moved to the Bases for SR 3.3.1.16 and SR 3.3.2.10. Comment: The discussion is inaccurate. The requirement defining STAGGERED TESTING is a definition in Section 1.0 of ITS. Revise the LG DOC. Rev 0 accepted based on 8/14/98 meeting which clarified CTS markup. Errata sheets were provided to the CTS markup and the ITS to incorporate a previously approved license change application to extend the refueling cycle from 18 to 24 months. Since that previous application is unavailable TSB cannot confirm that the previously approved changes have been faithfully incorporated into the ITS. In some cases the ITS markup does not reflect changes that one would expect to result from a cycle extension. For example, channel calibrations appear to still be required on a 18 month frequency. Review the ITS markup against the cycle extension application to confirm that those , changes are properly incorporated into the ITS. The surveillance frequency for the TADOT of function 1 (manual trip) and several other functions appears to reference a note 24 which is not provided. It may be that the note is intended to indicate that these surveillances are on a 24 month interval. If so, that should be clearly indicated. See also comment CTS 3.3.1-1. Rev 0 accepted based on 8/14/98 meeting which clarified CTS markup {WC} CTS SR 4.3.2.2 Note
- becomes notation to ITS SR 3.3.2.10. The ITS includes allowances for minimum times and pressure for performing the required SR. These changes are not identified or evaluated. Provide additionaljustification. j FLOG RESPONSE: For DCPP, the CTS errata sheets provided were for the changes due the issuance of the 24-month fuel cycle extension License Amendments l 118/116 and 119/117. There were a total of five LARS submitted for the 24-month fuel cycle extension; thus not all 24-month fuel cycle extension revisions were included in the errata. LA 122/120 was issued on February 17,1998, LA 123/121 was issued on February 27,1998 and LA 126/124 was issued on June 5,1998. The markups to incorporate these latest approved revisions are enclosed as Addition information Number DC ALL-005. The CTS and the ITS markups as revised by the five LARS and their respective LA a has been reviewed and verified to be consistent.
The 24 following the refueling frequency designation "R" is not a note, but a means to differentiate between those surveillances remaining on an 18-month frequency, *R", and those being revised to an 24-month frequency,
*R24". The frequency designation was explained in the 24-month License Amendment Requests and incorporated into the CTS DEFINITIONS.
For the WCGS item regarding CTS SR 4.3.2.2 Note *, see the response to Comment Number Q 2-40. ATTACHED PAGES: None ; i
ADDITIONAL INFORMATION COVER SHEET ADDITIONAL INFORMATION NO: O 1 03 APPLICABILITY: DC,CA REQUEST: Changing " demonstrated" to " verified" allows Reactor Trip System and ESFAS sensor response time verifications to be performed per WCAP-13632-P-A Revision 2. This change is consistent with traveler TSTF-111. Comment: Reject - (OOS] The ITS proposes generic changes to the STS that are not included in an approved TSTF. Adoption of WCAP-13632 for eliminating selected sensor response time testing requires staff review independent of the Conversion TS review. FLOG RESPONSE: This change is the subject of TSTF-111 Pev. 4, currently under active NRC and TSTF discussion. This DOC no longer applies to WCNOC based on Amendment No.113 dated October 20,1997 (see their licensee identified change WC-3.3-009). The response to Comment Number Q 1-B-GEN provides additional discussion. ATTACHED PAGES: Encl. 5A Traveler Status page { - -
INDUSTRY TRAVELERS APPLICABLE TO SECTION 3.3 TRAVELER # STATUS DIFFERENCE # COMMENTS l TSTF-19, Rev.1 @ Incorporated N/A @NRC approved. Org 3.34
% -) H fe M Mog - T3,3]4- IG 3.3-34 I l
TSTF-37, Rev.1 Not Incorporated NA ITS 5.6.8 still addresses PAM reports. Sections afterITS 5.6.7 were not renumbered. TSTF-51 Not Incorporated NA Requires plant-specific ,
- reanalysis to establish decay i time dependence for fuel i handling accident.
[6 [_ W@_ 6 [ oi a ] I b a for ss h 13-WI_ volt an eg ed It/ge l M1 re in
- e .
TSTF-111 Revh Incorporated NA W t-os J TSTF-13 @M Incorporated 33-41,h 3 3-93 ray ris in atur she dh e bee b ad h 3 3-95 eve sep te vele . l .rg 31 Q 33- Po ens f the ravel that gni antly al ' - I42-a ,3.g o op bili requ' eme s d$~1,) e n inc ed. Incorporated e TSTF-161Q 3 3-79 ej TSTF-168 Incorporated 3 3.43 Q .M I,5Vg]c. le24-e1 TSTF-169 porporated 3 3-42 k dg y,ic][rs.3.3-ag l (W O W 19 [6 Tcorporated 3 3-49 le 18-d ro s Incorporated 3 3-107 @[AettiinkifiDD ep [ca s.3-to7] i i 5/15/97 l
-- - - . _ - . . . . _ _ - - _ ~ _ . _
l l t ADDITIONAL INFORMATION COVER SHEET I ADDITIONAL INFORMATION NO: Q 1-04 APPLICABILITY: WC REQUEST: In current TS Tables [3.3-1 and 3.3-3], the [" Channels to Trip" and] " Minimum Channels OPERABLE" columns are deleted. [In current TS Table 3.3-6, the " Channels to Trip / Alarm" column is deleted.) The Action Statements have been revised accordingly. Comment: Rev 0 accepted based on 8/14/98 meeting. [WC move ODCM sections to Bases] l FLOG RESPONSE: This comment is applicable only to WCGS. As discussed during meetings ! with the NRC staff on September 17,1998, the CTS Table notation "###" discussion regarding increasing the setpoint value to the limits in the : ODCM are moved to the ITS SR Bases using DOC 1-04-LG. See also the response to Comment Number O 3.3-32. I ATTACHED PAGES: See attached pages in the response to Comment Number Q 3.3-32. I 1 J l l l l
l ADDITIONAL INFORMATION COVER SHEET ADDITIONAL INFORMATION NO: Q 1-05 APPLICABILITY: DC, WC, CA REQUEST: The LCO 3.0.4 exception [ footnote #] in current TS Table 3.3-1 is deleted entirely. ACTION Statements [2,6,11, and 13]in current TS Table 3.3-1 permit continued operation for an unlimited period of time. Therefore, no exception to ITS LCO 3.0.4 is needed for these ACTION Statements. [The LCO 3.0.4 exception [ footnote *] in current TS Table 3.3-3 is deleted for ACTION Statements [19,33,36, and 37 ] As above, these ACTION Statements permit continued operation for an unlimited period of time and no exception to ITS LCO 3.0.4 is needed. ACTION Statement [15 for Functional Unit 6.h] will retain the LCO 3.0.4 exception [ footnote *] in current TS Table 3.3-3 since this ACTION Statement allows operation for only a limited period of time.] Comment: {WC, CW, DC} The LCO 3.0.4 exception is deleted in ITS LCO 3.3.5. l This change is not evaluated in 1-05A. For this change, explain the administrative nature of the change per the guidance provided at the 8/14/98 meeting. i FLOG RESPONSE: This DOC is correct as submitted for Callaway and Wolf Creek. For those plants, current TS Tab!a 3.3-3 contains ACTION 19* for Functional Units 8.a and 8.b. The
- tootnote provides an exception to LCO 3.0.4. Based on the wording of LCO 3.0.4 in the current TS, this exception would allow entry into the Applicability of Functional Units 8.a and 8.b while relying on provisions contained in ACTION 19, i.e., the plant could enter the Applicability with one inoperable channel in trip.
Further, based on the wording of LCO 3.0.4 in the improved TS, the plant is allowed to enter the Applicability of ITS LCO 3.3.5 when the
" associated ACTIONS to be entered permit continued operation ...for an unlimited period of time." In this case, LCO 3.3.5 Applicability may be entered for one inoperable channel under Condition A since the plant can operate in that Condition indefinitely.
The plant can not enter ITS LCO 3.3.5 Applicability with multiple channels i inoperable since restoration activities must be completed. Likewise, the mark-ups to current TS ACTION 19, which did not originally address multiple channel inoperability, do not provide an LCO 3.0.4 exception. Since DOC 1-18-LS-5 in the ITS 3.0 package (accepted by the NRC staff reviewer) addressed the changes associated with revising CTS LCO 3.0.4 to match ITS LCO 3.0.4, no further discussion should be needed here in ITS 3.3. For DCPP, the loss of Power Functional Unit in Table 3.3-3 has no CTS 3.0.4 exception. , ATTACHED PAGES: None I
ADDITIONAL INFORMATION COVER SHEET ADDITIONAL INFORMATION NO: O 1-06 APPLICABILITY: DC, CP, WC, CA REQUEST: A new ACTION Statement [2.1) is created which does not require a reduction in THERMAL POWER to less than 75% RTP or the measurement of the QPTR if above 75% RTP. Comment: The new action referenced for the power range low setpoint and the two flux rate trips (functions 3 & 4) no longer require a reduction in power. The Discussion of Change (DOC) and No Significant Hazards Consideration (NSHC) justify this on the basis that the rate trips are not sensitive to the initial power level. This is true. However, the rate trips may be sensitive to the fact that with one channel inoperable one core quadrant is not directly monitored by the power range neutron flux function. Neither the DOC nor the NSHC discuss the impact of this on the possible need to reduce power. Revise the justification. FLOG RESPONSE: NSHC LS-2 has been revised to provide additional discussion. The impact on the rate trip Function is of no consequence since other Functions provide the required protection. ATTACHED PAGES: Encl. 4 22
IV. SPECIFIC N0 SIGNIFICANT HAZARDS CONSIDERATION NSHC LS 2 (continued) *** I"N The high positive rate [] trip function is insensitive to the static power level. The proposed change will not affect any of the analysis assumptions for 1ny of the accidents previously evaluated. [No USAR Chapter 15 analyses specifi cally credit this trip function. It provides backup protection for an RCCA Ejection.]1'The proposed change will not affect the probability of any event initiators nor will the proposed change affect the ability of any safety related equipment to perform its intended function. There will be no degradation in the performance of nor an increase in the number of challenges imposed on safety related equipment assumed to function during an accident situation. Therefore. the proposed change does not involve a significant increase in the probability or consequences of an accident previously evaluated.
- 2. Does the change create the possibility of a new or different kind of accident from any accident previously evaluated?
There are no hardware changes nor are there any changes in the method by which any safety related plant system performs its safety function. The change in required ACTION will not affect the normal method of plant operation and, in fact, will relieve the operators from performing actions not required for plant safety. No new accident scenarios, transient precursors, failure mechanisms, or limiting single failures are introduced as a result of this change. Therefore, the proposed change does not create the possibility of a new or different kind of accident from any previously evaluated.
- 3. Does this change involve a significant reduction in a margin of safety?
The proposed change does not affect the acceptance criteria for any analyzed event. There will be no effect on the manner in which safety limits or limiting safety system settings are determined nor will there be any effect on those plant systems necessary to assure the accomplishment of protection functions. There will be no impact on any margin of safety. NO SIGNIFICANT HA71.'lDS CONSIDERATION DETERMINATION Based on the above evaluation, it is concluded that the activities associated with NSHC "LS 2" resulting from the conversion to the improved TS format satisfy the no significant hazards consideration standards of 10 CFR 50.92(c): and accordingly, a no significant hazards consideration finding is justified. WCGS- NSHCs - CTS 3N.2 22 S/15/97
INSERT LS-2 0 1-06 Asymmetric reactivity transients that could be postulated to occur in the core
. quadrant with an inoperable high positive rate channel (e.g., uncontrolled RCCA bank withdrawal from a subcritical or low power startup condition, uncontrolled RCCA bank withdrawal at power, withdrawal of a single RCCA, and RCCA ejection) are mitigated in.the accident analyses by other reactor trip functions (e.g.,
power range neutron flux - low, power range neutron flux - high, or overtemperature [AT)), depending upon analysis assumptions regarding. initial power level and reactivity insertion rate.
ADDITIONAL INFORMATION COVER SHEET ADDITIONAL INFORMATION NO: O 1-07 APPLICABILITY: DC, CP, WC, CA REQUEST: With one intermediate range neutron flux channel inoperable when the plant is : above P-6 but below 10% RTP (the P-10 interlock setpoint), current ACTION Statement [3.b) is ; revised to establish a 24 hour Completion Time for channel restoration or changing the power level to either below P-6 or above P-10. Although this change is less restrictive since a power , increase is an allowed option, the ACTION Statement would ensure protection by entering the I range of the four power range neutron flux channels. The Applicability for Functional Unit 5 is revised such that current ACTION 1tatement [3.a) can be deleted. With both intermediate range neutron flux channels inoperable when the plant is above P-6 but below P-10, LCO 3.0.3 would be entered under the current TS and the plant would have to be in i MODE 3 within 7 hours. New ACTION Statement [3.1) requires immediate suspension of ; operations involving positive reactivity additions and a power reduction below P-6 within 2 hours. l r Comment: Explain how the 2 hour and 24 hour repair times provide protection and ; ensure the low probability of occurrence of a reactivity transient that would require the need for an IR flux trip. Explain why the ITS actions will provide for continued safe ' operation of the plant. This change references TSTF-135 which is not approved by the t staff. Provide discussion to explain the relation of this change to proposed TSTF-135 changes. Note that not all proposed TSTF-135 changes are acceptable to the staff for implementation in ITS. FLOG RESPONSE: DOC 1-07-LS-3 and NSHC LS-3 have been revised to clarify the suspect wording. This DOC is unrelated to TSTF-135, discussed under Comment Number Q 3-LS-GEN. The 24 hour Completion Time is taken from TSTF- ; 246. See the response to Comment Number Q 3.3-107 for additional discussion of TSTF-246. ATTACHED PAGES: Encl.3A 3 Encl. 4 23
' CHANGE NUMBER H2iC DESCRfPTION 1 07 LS 3 With one intermediate range neutron flux channel ;
inoperable, current ACTION Statement [3.a] applies below the P 6 interlock. For those" times that the i plant is above P 6 but below 10% RTP (the P 10 interlock setpoint), current ACTION Statement [3.b] applies. ACTION Statement [3.b] is revised to establish a 24 hour Completion Time for channel restoration or changing the power level to either below 4 i P 6 or above P 10. The intermediate range neutron flux channels provide protection intween these power levels and the APPLICABLE H0 DES have bean revised to indicate this via new footnote [c and d]. With the revised i Applicability, current ACTION Statement [3.a] is deleted since it is outside the new applicability. The source rar,ge neutron flux detectors provide protection below P 6 and the power range neutron flux detectors provide protection above P 10. The addition of the 24 hour completion time (current TS has no completion time) limits the window of operation during which the intermediate range neutron flux trip function _prov_ ides
- _ _e rotection in a 1 of 1 logic configuration.@4nsur4h kwho thans. Ah low probability of occurrence of a reactivity transient during this time period that would require an T# *' I intermediate range flux trip. Although this change is less restrictive since a power increase is an allowed i option, the ACTION would ensure protection by entering I the range of the four power range neutron flux channels.
With both intennediate range neutron flux channels ; inoperable in H0DE 1 (below P-10) and H0DE 2. (above P- ; 6), LC0 3.0.3 would be entered under the current TS and the plant would have to be in H0DE 3 within 7 hours. With both intermediate channels inoperable, new ACTION Statement [3.1] requires imediate suspension of operations involving positive reactivity additions and a power reduction below P 6 within 2 hours. New ACTION Statement [3.1) is less restrictive since a reduction to MODE 3 would no longer be required: however, the current TS are overly conservative in this area. Below P 6 the source range channels provide protection: therefore, the required action for both intermediate range channels inoperable should be to exit plant conditions where this trip function provides protection. New ACTION Statement [3.1] will preclude any power level increase and require a controlled power reduction to less than P 6 where the source range channels provide protection. The 2 hour completion time ensures the low probability of occurrence of an event during this period that may require the WCGS-Description ofchanges to CTS 3M.3 3 S/158 7
- - - . .l l
IV. SPECIFIC NO SIGNIFICANT HAZARDS CONSIDERATIONS NSHC LS 3 10 CFR 50.92 EVALUATION i FOR TECHNICAL CHANGES THAT IMPOSE LESS RESTRICTIVE REQUIREMENTS WITHIN THE TECHNICAL SPECIFICATIONS With one intermediate range neutron flux channel inoperable, current ACTION I Statement [3.a] applies below the P 6 interlock. For those times that the plant is above P 6 but below 10% RTP (the P-10 interlock setpoint), current ACTION Statement [3.b] applies. ACTION Statement [3.b] is revised to establish a 24 hour ) Completion Time for channel restoration or changing the power level to either below P 6 or above P 10. The intermediate range neutron flux channels provide protection between these power levels and the APPLICABLE H0 DES have been revised accordingly. The source range neutron flux detectors provide protection below P 6 and the power range neutron flux detectors provide protection above P 10. The addition of the 24 hour Completion Time (current TS has no Completion Time) limits the window of operation during which the intermediate ra neutron _ flux trip function provides protection in a 1 of 1 logic configuration. - _ _ low probability of l4 8-07 occurrence of a reactivity transient occurring during thi ime period that would require an intermediate range flux trip. Although this c ange is less restrictive since a power increase is an allowed option, the ACTION Satement would ensure protection by entering the range of the four power rance/ neutron flux channels. Cf u er, m ere. s A With both intermediate range neutron flux channels inoperable in MODE 1 (below P 10) . and MODE 2 (above P 6). LC0 3.0.3 would be entered under the current TS and the plant l would have to be in MODE 3 within 7 hours. With both intermediate channels inoperable, new ACTION Statement [3.1] requires immediate suspension of operations involving positive reactivity additions and a power reduction below P 6 within 2 hours. New ACTION Statement [3.1) is less restrictive since a reduction to MODE 3 would no longer be required; however, the current TS are overly conservative in this area. Below P 6 the source range channels provide protection: therefore, the required action for both intermediate range channels inoperable should be to exit plant conditions where this trip function provides protection. New ACTION Statement [3.1] ) will preclude any power level increase and require a controlled power reduction to less than P 6 where the source range channels provide protection. The 2 hour Completion Time ensures the low probability of occurrence of an event during this period that may require the protection afforded by the intermediate range neutron flux trip. These actions actually provide a more timely and appropriate redress to the condition than entering LC0 3.0.3. The proposed TS change has been evaluated and it has been determined that it involves no significant hazards consideration. This determination has been performed in accordance with the criteria set forth in 10 CFR 50.92(c) as quoted below:
"The Camission may make a final determination. pursuant to the procedures in 50.91. that a proposed amendment to an operating license for a facility licensed under 50.21(b) or 50.22 or for a testing facility involves no WCGS- NSHCs - CTS 3N.2 23 SH587
ADDITIONAL INFORMATION COVER SHEET ADDITIONAL INFORMATION NO: Q 1-11 APPLICABILITY: CP, WC, CA REQUEST: [New] ACTION Statement [39] is applied to the low fluid oil pressure and turbine stop valve closure trip functions. Rather than entry into LCO 3.0.3 if current ACTION Statements [6 and 11] are not met or if multiple low fluid oil pressure channels are inoperable, the new ACTION Statement requires inoperable channels to be tripped within 6 hours or power reduced below P-9 within 10 hours. Comment: By adopting the STS, Turbine Stop Valve Closure channels are given a 4 hour bypass allowance which is related to WCAP-10271. The ITS proposed is not evaluated. Provide additionaljustification. Based on 8/14/98 meeting this comment will be responded to as part of the JFD 3.3-02 comment response. FLOG RESPONSE: See the response to Comment Number Q 3.3-02. ATTACHED PAGES: None
ADDITIONAL INFORMATION COVER SHEET ADDITIONAL INFORMATION NO: O 1-13 APPLICABILITY: DC, CP, WC, CA REQUEST: [ ACTION Statement [9] is revised to note that the 2 hour [] reactor trip breaker bypass allowance for [ ] breaker surveillance testing can also be used for maintenance.) ACTION Statement [9] is [also) revised to require restoration of an inoperable RTB within 1 hour or the plant must be in HOT STANDBY within the next 6 hours. This is less restrictive since an i additional hour is provided for the transition to MODE 3. l Comment: Pending TSTF review - this DOC discusses adding a 2-hour AOT for ! instrument maintenance. Use of maintenance AOTs have not been approved by the staff. TSTF-168 for maintenance bypass is not approved by the staff. Revise the ITS to adopt the STS note to Action R for reactor trip breakers in Modes 1 and 2. Based on 8/14/98 meeting this comment will be responded to as part of the JFD 3.3-43 comment response. CTS requires 2 channels of RTBs to be operable. ITS requires 2 trains of RTBs to be operable. The ITS action R Notes 1 and 2 address both channel and train inoperabilities. Provide DOC discussion for each CTS change. 1 FLOG RESPONSE: See the responses to Comment Numbers Q 3.3-03, Q 3.3-43, and Q 3.3- ! 117. Although the ITS will use the *RTB train" wording, the words
" channel" and " train" mean the same thing when there are only two separate entities involved. This wording is an artifact of the last STS, NUREG-0452.
ATTACHED PAGES: l None i ) 1
ADDITIONAL INFORMATION COVER SHEET ADDITIONAL INFORMATION NO: Q 1-14 APPLICABILITY: DC, CP, WC, CA REQUEST: In the ISTS Table 3.3.1-1, Function 20, the reactor trip breaker (RTB) undervoltage and shunt trip mechanisms are separate from the RTB Functional Unit. The , current TS have been revised to reflect these requirements. New (footnote (d) has) been added to the RTB Functional Unit to note that the same ! OPERABILITY requirements and ACTIONS apply to a bypass breaker if it is racked in and closed for bypassing an RTB. The bypass breakers were already handled in this fashion. ACTION Statement [12) in current TS Table 3.3-1 has been revised accordingly. Comment: 1) Adopting a current practice as a TS is not an administrative change to i current TS. Provide a separate DOC for the footnote change which is consistent with the
" change" in current TS requirements that results from adopting the NUREG STS.
l 2) The staff presumes that the CTS were retyped and that the CTS markup represents a
- comparison between the retype and the additions made to the CTS to adopt the ISTS. ,
j The staff continues to find mistakes in the retype, changes that are neither redlined or shown in strike out but which are obviously not consistent with the CTS. For example, T3.3-1 Function 19 (RTBs) the applicability in Mode 5 has footnote "k" whereas the other 1 applicable Modes have footnote "a." Footnote "k" does not exist. I Based on 8/14/98 meeting Rev 0 is accepted and this comment does not need a l response. l
- 3) CTS action [12) contains a requirement not to bypass the breaker while one of the diverse trip features is inoperable. This prohibition is not included in the actions for Condition U. Neither the CTS markup nor the DOC cover this deletion.
FLOG RESPONSE: DOC 1-14-A has been revised to demonstrate that this change does not just formalize " current practice", rather it is consistent with the current TS. The CTS ACTION Statement allows the RTB to be bypassed for the time required to restore an inoperable trip attachment to OPERABLE status. This is covered by ITS 3.3.1 Condition R Note 2. See also Comment Number O 3.3-117. ATTACHED PAGES: Encl. 3A 6 1 I
I CHANGE i hlREER ! gig DESCRIPTION l an additional hour is provided for the transition to , MODE 3. l 1 14 A In the ISTS Table 3.3.11 Function 20. the Reactor Trip Breaker (RTB) Undervoltage and Shunt Trip Mechanisms are separate from the RTB Functional Unit. The current TS have been revised to reflect these requirements. new [ footnote (b)] has been added to the RTB Functional Unit to note that the same OPERABILITY requirements and ACTIONS apply to a bypass breaker if it is racked in and closed for bvpassing an RTB. The bypass breakers were already handles in this fashion. Action Statement [12] in current T Jab.le 3.31 has been revised accordingly. u.w.cr .s A -4,c l 4 i_ 4 l 1 15 A The Applicability for the Reactor Trip on Turbine Trip function is modified by a new footnote [(a)] such that l this function is only required to be OPERABLE above the P 9 interlock setpoint (50% RTP). This is acceptable since the trin function locked below P 9. [New] \43.3421 Y_D ACTIONStatement[1f.I ied to the Low Fluid Oil Pressure and Turbine Stop Valve Closure trip functions. l These are consistent with NUREG 1431, Rev.1. l 1 16 LS 40 The requirement to verify the setpoint during the quarterly TADOT for RCP Underfrequency [and RCP Undervoltage] is deleted, consistent with NUREG 1431, ; Rev. 1. 1 17 A Consistent with NUREG 1431 Rev.1, 3.3.1 Requi' l Action D and E Note, the current TS Table 3.3- L ACTION j Statement 2@dineHUJORJtiltsetntEldSv$been [q3.34Dj l modified by a NOTE that allows the bypass to be used ! for surveillance testing or setpoint adju.stment. ! Setpoint adjustment can be performed at power and may be required by other Technical Specifications. The j reason for placing the channel in bypass does not effect the impact of having the channel in bypass. ! 1 18 LS-7 The current TS requirement to reduce the Power Range l Neutron Flux Trip setpoint in the event a power range j- flux channel is inoperable, is deleted. This deletion i is consistent with NUREG 1431. Rev.1 and is justified by:
- 1) The loss of one channel does not impact the reliability of the Reactor Trip System because the affected channel is placed in trip. It may, WCGS-Description ofchanges to CTS 3M.3 6 5/15/97
INSERT 3A-6a 0 1-14 , This change is administrative in nature since the current TS already specifies operability and surveillance requirements on the diverse trip attachments and the bypass breakers (when racked in and closed), as evidenced by CTS Table 3.3-1 ACTIONS [9 and 12] for Functional Unit [19], [ Table 3.3-1 ACTION 7 for Functional Unit 20], Table 4.3-1 Note [(11)] for Functional Unit 1. Table 4.3-1 Notes [(7) and (16)] for. Functional Unit [19], and Table 4.3-1 Notes [(17)- and (18)] for Functional Unit [21]. t
i l ADDITIONAL INFORMATION COVER SHEET l l ADDITIONAL INFORMATION NO: O 1-15 APPLICABILITY: WC ! l REQUEST: The Applicability for the reactor trip on turbine trip function is modified by new ' footnote ((c)] such that this function is only required to be OPERABLE above the P-9 interlock b setpoint (50% RTP). This is acceptable since the trip function is blocked below P-9. (New] ACTION Statement (39] is applied to the low fluid oil pressure and turbine stop valve closure trip l l functions. l Comment: {WC) No justification is provided for item (e) of insert 3/4 3-4 (CTS page 3/4-5, T3.3-1) ! FLOG RESPONSE: The WCGS markup should have indicated DOC 1-53-A next to this change. It is unrelated to DOC 1-15-A. The response to Comment Number Q 3.3-120 results in the deletion of DOC 1-53-A. Therefore, no i CTS mark-ups are associated with this response. This comment does not apply to Callaway. ATTACHED PAGES: None i I l i 6 l F l i i
l 4 ADDITIONAL INFORMATION COVER SHEET ; ADDITIONAL INFORMATION NO: O 1-16 APPLICABILITY: DC, CP, WC, CA REQUEST: The requirement to verify the setpoint dunng the quarterly TADOT for RCP Underfrequency (and RCP Undervoltage] is deleted. Comment: Based on 8/14/98 meeting a 2 LS GEN response will be provided. The extension of the allowed outage time for one CRVS channelinoperable from 1 hour l to 7 days is justified based upon the fact that the AOT for a single inoperable mechanical l train is 7 days. The bases. however, indicate that the two channels are used in a one-out-of-two logic to start both CRVS trains. A single inoperable instrumentation channel, therefore, degrades the operability of both mechanical trains. This is a different condition than inoperability of a single inoperable mechanical train thus the justification provided I for the 7 day AOT is not germane. FLOG RESPONSE: LS-40 is revised in the response to Comment Number Q 2-LS GEN. The j remainder of the comment does not apply to this DOC, as discussed in Reference 5. It applies to DOCS 2-16-LS-12 and 3-05-LS-14. See the responses to the comments on those DOCS. ATTACHED PAGES: None 1 i
l ADDITIONAL INFORMATION COVER SHEET
- I l ADDITIONAL INFORMATION NO: O 1-18 APPLICABILITY: DC, CP, 'NC, CA
- REQUEST: The current TS requirement to reduce the power range neutron flux trip setpoints
, in the event a power range flux channelis inoperable is deleted. The time to reduce power j l below 75% RTP is increased from 4 hours to 12 hours and, if actions are not completed as required, the unit must be in MODE 3 in 12 hours. (See also CN 1-53-A.) l Comment: (1) The CTS requires OPTR to be monitored per SR 4.2.4.2 if one i channel is inoperable and power is not reduced to less than 75%. The markup relaxes l this requirement to only require OPTR monitoring if the input to the OPTR function is inoperable. This change has not been justified. The justification provided for not reducing power presumes that the OPTR is being surveilled, it is likely that what is intended here is that QPTR be surveilled in all cases where power is not reduced below 75%, however if the input to the OPTR monitoring function is OPERABLE then that 1 monitoring may be accomplished via that function using the power range inputs. If the OPTR input is inoperable then QPTR must be monitored per SR 4.2.4.2. The ITS t actions should reflect the NUREG-1431 STS and the CTS changes should be discussed. l (2) The CTS markup eliminates the requirement to change the power range trip setpoint ! after power is reduced. The DOC justifies this on the basis that the loss of a channel does not indicate an abnormal flux tilt. The proposed change also places the power limitation under administrative control rather than enforcing it by changing trip setpoints. The basis for this change should be discussed. Provide a technical basis for changing the power reduction completion time from 4 to 12 hours. (3) The CTS requires resetting the power range neutron flux trip setpoint to 85% of rated thermal power on loss of one channel of power range neutron flux - high setpoint. The ITS markup requires restricting power to 75% of rated thermal power. No justification is I provided for change in power level or from change from " trip setpoint at 85% power" to ,
" restriction to 75% power".
Neither the DOC nor the NSHC provide specific justification for extending the AOT for two inoperable channels by 11 hours (or by 3 hours when a tie breaker is closed). FLOG RESPONSE: Comment (1) is addressed in the response to Comment Number Q 3.3-120. NSHC LS-7 has been revised to address comments (2) and (3). The last paragraph is written against the wrong DOC as discussed in Reference 5, see the response to Comment Number Q 2-18. ATTACHED PAGES: Encl.4 31 l l
IV. SPECIFIC NO SIGNIFICANT HAZARDS CONSIDERATIONS NSHC LS 7 10 CFR 50.92 EVALUATION FOR TECHNICAL CHANGES THAT IMPOSE LESS RESTRICTIVE REQUIREMENTS WITHIN THE TECHNICAL SPECIFICATIONS In current ACTION Statement [2c], the requirement to reduce the power range neutron flux high trip setpoint is deleted. The loss of one power range neutron flux channel does not impact the reliability of the reactor trip system because the channel is required to be placed in trip. With an NIS power range channel inoperable, tilt monitoring for a portion of the reactor core becomes degraded. To address the impact on measuring QPTR, the OPTR TS provides conditional notes to the surveillances that verify 0PTR. Although the loss of one power range channel may affect the ability to measure OPTR, there is no basis for reducing the power range high flux trip setpoint and increasing the potential for an inadvertent reactor trip.a The existing surveillance requirements in the OPTR TS provide adequate remedial measures (increased surveillance frequency and/or different method for monitoring QPTR) when an inoperable power range channel affects the input to OPTR. gr ts.g_ g ,_ie, j In addition, monitoring of OPTR every 12 hours will no longer be required if the input to the OPTR from the power range neutron flux channels remains OPERABLE. A consistent completion time of 12 hours is imposed on either of the thr r uired actions, i.e. power derate, OPTR surveillance, or shutdown to H0DE 3. iusenT ts -% p ge, j The proposed TS change has been evaluated and it has been determined that it involves no significant hazards consideration. This determination has been performed in accordance with the criteria set forth in 10 CFR 50.92 (c) as quoted below:
"The Cartmission may make a final determination. pursuant to the procedures in 50.91. that a proposed amenament to an operating license for a facility licensed under 50.21(b) or 50.22 or for a testing facility involves no significant hazards consideration. if operation of the facility in accordance with the proposed amendnent would not:
- 1. Involve a significant increase in the probability or consequences of an accident previously evaluated; or
- 2. Create the possibility of a new or different kind of accident fro 71 any accident previously evaluated; or
- 3. Involve a significant reduction in a margin of safety. "
' The following evaluation is provided for the three categories of the significant hazards consideration standards: WCGS- NSHCs - CTS 3M.2 31 S/15 8 7
1 INSERT LS-7a 0 1-18 There is no accident analysis basis frr a setpoint reduction to 85% RTP with one j inoperable channel in trip. All accident analyses crediting power range neutron i flux high are based on meeting a safety analysis limit of 118% RTP (109% RTP trip setpoint plus instrument errors). Reducing the power level to f 75% RTP prevents operation of the core with radial power distributions beyond the design limits at a power level where DNB conditions may exist. Placing the current TS Action Statement's option for a power reduction under administrative control, rather , than enforcing it by a reduced trip setpoint, does not render the requirement any I less valid. The vast majority of Technical Specification Action requirements are enforced administratively, not by equipment changes. INSERT LS-7b 0 1-18 The relaxation from 4 hours to 12 hours to reduce power below 75% RTP is acceptable based on this being a more controlled evolution to take load off at a reduced rate when it is known the power range monitoring capability is degraded This is a reasonable time to reduce power given that OPTR changes relatively slowly at full power. The action to place the inoperable channel in trip within 6 hours already addresses the RTS unavailability concern. This change ensures the power reduction is performed in an orderly manner without challenging plant systems. l l l l
l I ADDITIONAL INFORMATION COVER SHEET I ADDITIONAL INFORMATION NO: O 1-23 APPLICABILITY: DC, CP, WC, CA REQUEST: This change adds notes to the RTS and ESFAS SR Tables 4.3-1 and 4.3-2 that explicitly require the 18-month calibrations to include verifications of affected time constants where applicable. Comment: Provide CTS Table 4.3-2 and Note (5) for staff review of proposed changes. The A-DOC discusses additional requirements and should be discussed as an M-DOC. : 1 The A-DOC discusses the addition of surveillance requirements to include time 1 constants and should be evaluated as an M-DOC. Amendments 126/124 include 24 month surveillances for CTS function 1.b,11.c,1.d,1 e, 2.c, 3.a.2, 3.b.2, 3.b.3, 3.c.1, 3.c.4,4.c, 4.d, 4.e, 5.a, 5.b,6.b, 6.c.1, 6.c.26.d, and 8a which are shown as 18 months in ITS SRs 3.3.2.9 and 3.3.6.7. Provide CTS /ITS markup revisions. {WC, CW, DC, CP) CTS TADOT surveillances are modified in the ITS with a note that
" verification of setpoint not required." This change is not evaluated. For CW this change is also not identified in the CTS markup. Provide justification for all proposed changes to CTS as they are reflected in the ITS.
l FLOG RESPONSE: The first and second comments were discussed with NRC staff during a meeting on 8/14/98 whereupon NRC agreed with the FLOG's contention l that, since this represented current plant practice, the DOC was indeed i administrative in nature. NRC concurred in the meeting minutes i (Reference 3 to the cover letter). I In response to the third comment, the changes to the DCPP CTS and ITS l associated with Amendments 126/124 are provided via Additional ! Information item DC-ALL-005. Please note that the Functions listed in the comment include Functions revised via LA 122/120 and LA 123/121 as , well. Not all of the Functions revised by these LAs are listed. Additional ' l Information Number DC-ALL-005 includes all of the revised Functions and l the revised SRs 3.3.2.9 and 3.3.6.7 as well as other affected SRs. l In response to the last comment, new DOC 1-64-A has been generated as well as the associated CTS mark-ups. l ATTACHED PAGES: Encl. 2 3-9,3-10,3-34, 3-35,3-36,3-38 Encl.3A 14 ! Encl.3B 14 l i n
TABLE 4.3-1 REACTOR TRIP SYSTEM INSTRUMENTATION SURVEILLANCE REQUIREMENTS TRIP ANALOG ACTUATING MODES-FOR CHANNEL DEVICE UM4CH CHANNEL CHANNEL OPERATIONAL OPERATIONAL ACTUATION SURVEl& LANCE i 1-44-A . -
'~
FUNCTIONAL UNIT CHECK CAllBRATION TEST TEST LOGIC TEST MAEQUIRED f 32-I'G
- 1. Manual Reactor Trip NA NA NA R ) NA
- 2, 2*, '*, 5 (IM l-69-A
- 2. Power Range, Neutron Flux I e - a.s 1
- a. High Setpoint S D(2,4) Q NA NA w I M M(4:4) l- 1-A -
N 3-26-LG R(4,5) 1-24-LS-9
- b. Low Setpoint S R(4 S/U(1 Q(19,20) N.A. NA 4###r3 I[, ,
- 3. Power Range, Neutron Flux, N.A. R(4 O NA N.A. 43 7 1-39-A -
High Positive Rate 1-39-A
- 4. Power Range, Neutron flux. N.A. R(4)(5) Q N.A. N.A. 4r3 High Negative Rate ,
R(4,5) NA N.A. 4###r3 I-22-M -
- 5. Intermediate Range, S 8 Neutron Flux Q(19' l-26-LG
- 6. Source Range, Neutron Flux S R(4,5) S/U(1),0(9h NA NA " ,2,',5
. 1 -2 10' Q N.A. NA 4r3 1-23-A
- 7. Overtemperature AT S 21) 3)
I-21-A 6 , I 40-LS-41 *
- 8. Overpower AT S R[21) Q NA NA 4r3 ,
l-23-A -
- 9. Pressuri7er Pressure-Low S R 21) Q N.A. NA 4 l-23-A
- 10. Pressurizer Pressure-High S R 21) Q NA NA 4r3 1-23-A
- 11. Pressurizer Water Level-High S R1 21) Q NA NA 4 , 1-23-A
~^
- 12. Reactor Coolant Flow-Low S R O NA NA 4 t
i i N'OLF CREEK- UNITI JH 3-9 Amendment No. '2,25, '?,52,96 MarA-up ofCTS 3M. 3 3/13M7 i
TABLE 4.3-1 (Contmuod) REACTOR TRIP SYSTEM INSTRUMENTATION SURVEILLANCE REQUIREMENTS TRIP ANALOG ACTUATING MODESFOR ' CHANNEL DEVICE WMIGH CHANNEL CHANNEL OPERATIONAL OPERATIONAL ACTUATION SWRVlii4bkANGE FUNCTIONAL UNIT CHECK C181RRATION TEST TEST LOGIC TEST ISREiGUIRED 1-44-A
- 13. Steam Generator Waler Level- S (21)T Q(15) NA NA 4r3 s
' l-23-A-to,_to, }
l-23-A
- 14. Undervoltage - Reactor N.A. R '21) NA 10) NA 4 Coolant Pumps I-16N ,
4 ' 1-23-A
- 15. Underfrequency - Reactor N.A. R 21) NA (10) NA Coolant Pumps e!-l&LS-40 o 6
- 16. Turbine Trip
- a. Low Fluid Oil Pressure NA Ri 21) NA S/U( ,
- 10) NA 4 1-23-A
- b. Turbine Stop Valve N.A. Ri 21) NA S/U( 10) NA 4 .1-23-A i Closure
- 17. Safety injechon input from N.A. NA NA R NA 4r3 - ;
QO) ESF
- 18. Reactor Trip System lnterlocks ' l9 Wl -
- a. Intermediate Range Neutron flux, P-6 NA R(4) R N.A. N.A. 2N ,
- b. Power Range Neutron Flux, P-8 N.A. R(4) R N.A. NA 4
- c. Power Range Neutron ;
Flux, P-9 N.A. R(4) R NA N.A. 4 3/4 3-10 Amendment No. 43;- 43 ; WOLF CREEK- UNITI ' Mark-up ofCTSJM. 3 5M597 ___-_.________m.--- _ _ _ _ _ m__ _ _ _ _ _ _ . _ ____ -- _ - - , - + ~ . --
,ite - - , . - - . - . - - = - -e
_ ,
- w e t. ws--;- ,m-_m , - - , + , mww.._ .--*em ,c, . - --- - w - --A_ _ - -_ ___.____ . --
TABLE 4.3-2 ENGINEERED SAFETY FEATURES ACTUATION SYSTEM INSTRUMENTATION SURVEILLANCE REQUIREMENTS TRIP ANALOG ACTUATING MODES CHANNEL DEVICE MASTER. SLAVE FOR-WH4CH CHANNEL CHANNEL OPERATIONAL OPERATIONAL ACTUATION RELAY RELAY SURVE4L4ANCE FUNCTIONAL UNIT CHECK CALIBRATION TEST TEST LOGIC TEST TEST TEST IS-REQUIRED
- 1. Safety injection %
1 44-A
'."::f;;&r f;, '"- ::?::!;:. "^" ?:: x,
' .JJ;n, hb:~ 3' k75?_7 2-19 LG
;:: 9::GL:G '.
9 -
;;~ :::r;;;= ._,
EN5EE-5555E I-64-A 5 : "--; -23
- c. ManualInitiation N.A. N.A. N.A. R N.A. NA N A.
- 2, 3. '
- b. Automatic Actuation N.A. N A. N.A. N.A. M(1) M(1) O(3)
- 2, 3, '
Logic and Actuation Relays (SSPS)
- c. Containment Pressure- S R Q
'4) . Q N.A. N.A. N.A. N.A. W I 23-A H;gh-1
- d. Pressurizer Pressure- S R 4) Q N.A. N A. NA N.A. 4 rara 1-23-A Low
- c. Steam Line Pressure. S R 4) Q N.A. NA N.A. N.A. 4r373 1-23 A
-{Qt-2.5[
- 2. Containment Spray g)
- a. Manualinitiation N.A. N.A. NA R N.A. NA N.A.
- 2, 3. '
- b. Automatic Actuation N.A. N.A. N.A N.A. M(1) M(1) O(4)
- 2,3 ' ,
, 2-30-A Logic and Actuation Relays (SSPS)
- c. Containment Pressure. S R 4) O N.A N.A. N.A. N.A. 4rar3 1-23-A High-3 WOLF CREEK- UNIT I 3M 3-34 Amendment No. 43 Mark-up ofCTSJH. 3 5/15/97
TABLE 4.3-2 ENGINEERED SAFETY FEATURES ACTUATION SYSTEM INSTRUMENTATION SURVEILLANCE REQUIREMENTS , TRIP ANALOG ACTUATING MODES MASTER SLAVE FO R.W HIGH CHANNEL DEMCE RELAY RELAY SURVEELANCE CHANNEL CHANNEL OPERATIONAL OPERATIONAL ACTUATION !S "C ^' "r TEST LOGIC TESI TEST TEST FUNCTIONAL UNIT CHECK CAllBRATION TEST
- 3. Containment isolation Q g i.2.3 l A@ ,
- a. Phase *A" Isolation NA R5 N.A. NA N.A. 4r3r3r4
- 1) ManualInitiation N.A. N.A. * ' ' ' ' '
NA NA- NA M(1) M(1) Q(3)
- 2) Automatic Actuation N.A Logic and Actuation Relays (SSPS)
- 3) Safety injection See item 1. above for all Safety injection Surveillance Requirements.
OptAA b i-231 '
- b. Phase 'B' Isolation N A. NA NA
- 2, 3, '
NA R ,
- 1) ManualInitiation N.A. N.A. O
- 2, 3, '
N.A. NA NA NA M(1) M(1) ,
- 2) Automatic Actuation Logicand Actuation .I.
Relays (SSPS) NA N A. 4r raa ; S R[4) O NA N.A.
- 3) Containment Pressure-Htgh-3 gi u}
- c. Containment Purge isolation N.A. N.A. 5) NA NA > A. m
- 2, 3. '
, J-Og f "
- 1) Manum Initiation
^*'" " W N.A. _
W W f f f ff l 4 a s.s2.f s PS N.A. M(1)(2) N.A. N.A.
- 2.
N.A. N.A. N.A.
- 3) Automatic Actuation Logicand Actuation Relays (BOP ESFAS)
See item 3 a. above for all Phase "A" Isolation Surveillance Requirements. t;N$.2
- 4) Phase "A" Isolation 4
3M 3-35 Amendment No. 43 MDLFCREEA*- UNITI 5/1W7 MerA-up of CTS 3M. 3 l _____ _ _ _ _ ________ ___ __._._____________ _ _ __.______.___.__ _ _ __ _ _ _ _ _ _ _ _ _ _ _ _ _ _ _ _ _ _ _ _ _ _ ~ - _ _ _ . . . . - _ . , . . - - _ _ - . _ . ~ _ . . _ _ . _ . _ _ . .
TABLE 4 3-2 ENGINEERED SAFETY FEATURES ACTUATION SYSTEM INSTRUMENTATION SURVEILLANCE REQUIREMENTS 1-44-A '- TRIP : ANALOG ACTUATING MODES -! CHANNEL ' DEVICE MASTER SLAVE FOR-WHIGH CHANNEL CHANNEL OPERATIONAL OPERATIONAL ACTUATION RELAY RELAY SURVE4LLANCE FUNCTIONAL UNIT CHECK CAllBRATION TEST TEST LOGIC TEST TEST _ TEST IS REQUIRED. I
- 4. Steam Line Isolation s
- e. ManualInitiation N.A. NA N.A. R N.A. N.A. N.A. 4r373 ,
- b. Automatic Actuation N.A. NA N.A. N.A. M(1) M(1) Q 4rar3 I Logic and Actuation Relays (SSPS)
- c. Containment Pressure- S Ri 4) Q NA N.A. NA NA 4r raa '
1-23-A l High-2 l
- d. Steam Line Pressure- S R 4) Q NA N.A. N.A. N.A. 433 i 7 7 23-A LOW t-23.A
- o. Steam Line Pressure- S RI4) Q N.A N.A. NA N.A. 3 Negative Rate-High
- 5. Turbine Trip and Feedwater ,
Isolation
- a. Automatic Actuation NA NA N.A. NA M(1) M(1) Q(3) 4r,*l Logic and Actuation Relay (SSPS)
- b. Steam Generator Water S R4 Q NA NA NA N.A. 4r3 1 23-A Level-High-High
- c. Safety injection See item 1. above for all Safety injection Surveillance Requwements.
g -u-4 -[a t-23] g mm sMka.h mf
- o. Automaucactuanon N ^..
N.A. N? N.A. N? N.A. NA
"^
_. M(1) MU) u
- 2, 3 4r3r3 D'
M 2-Ml , Logic and Actuation Relays (SSPS) L M*0LF CREEK - UNIT I JM 3-36 Amendment No. 43 MarA-up ofCTS3/4. 3 5/13M7
J TABLE 4.3-2 ENGINEERED SAFETY FEATURES ACTUATION SYSTEM INSTRUMENTATION SURVEILLANCE REQUIREMENTS TRIP ANALOG ACTUATING MODES CHANNEL DEVICE MASTER SLAVE FOIMANCH CHANNEL CHANNEL OPERATIONAL OPERATIONAL ACTUATION RELAY RELAY SURVE4L4ANCE CALIBRATION TEST TEST LOGIC TEST TEST TEST IS-REQUIRED-FUNCTIONAL UNIT CHECK
- 9. Contr01 Room isolation NO 5 " 5 N.A. N.A. N A. R N A. N.A. N A. All l413-32) a ManualInitiation _
- - ld2,3{p All N.A.
(2'57-]A
- c. Automatic Actuateon N.A. NA N.A. NA M(1)(3) N.A.
Logic and Actuation Relays (BOP ESFAS)
- d. Phase 'A' Isolation See item 3.a. above for all Phase *A" Isolation Surveillance Requirements.
10 S:M Stet: Le
- S:;rn= NA N? M? N? "(1)(2) N? N? ? , 2, 2, ' g-Ag
- 11. Engineered Safety Features Actuation System Interlocks c.. 1.23-Aws w .g, 4
- a. Pressurizer Pressure, N A. 4) Q NA NA NA N.A. 473r3 :
P- 11 gg N.A. N A. N.A. NA N.A. 433 7 7 ;
- b. Reactor Trip, P-4 N A. R (5) t TABLE NOTATIONS (1) Each train shall be tested at least every 62 days on a STAGGERED TEST BASIS Continuity check may be excluded from the ACTUATION LOGIC TEST.
(3) (3) Except Relays K602, K620, K622. K624 K630, K740, and K741, which shall be tested at least once per 18 months nd during each COLD SHUTDOWN exceeding 24 hours unless they have been tested within the g,gg { l gd - (4) locludes verification of time constants, where applicable. 2-45-LG t *4 * $3 tk , (5) Verification of setpoint not required. ~' A *f ' I- M-A
\ Q t ~G l N OLF CREEK - UNIT I 3M 3-38 Amendment No. 43 '
MarA-up ofCTS 3M. 3 $M5M7
CHANGE NUMBER N_SBC DESCRIPT10N 1 54 LS 37 Not applicable to Wolf Creek. See Conversion Comparison Table (Enclosure 3B). 1-55 LS 39 Applicability Note [*] and ACTION Statements [5.a and 10] for Functional Units [1. 6.b, 19 and 20] of -
- current TS Table 3.3-1 are modified to provide an
! alternative to opening the reactor trip breakers (RTBs) l while still assuring that the function and intent of l opening the RTBs is met. As currently worded, these l ACTION Statements result in a feedwater isolation l signal (FWIS) when in H0DE 3 with a T., less than [564*F. USAR Table 7.314 and USAR Figure 7.2-1 (sht.13) detail the FWIS generation on the coincidence dus- of P 4 and low T, .] A more generic action, which r (wh5a *" -e assurMhe rods are fully inserted and cannot be
- withdrawn, replaces the specific method of precluding l
Q.3.ts-esef rod withdrawal. The revised 4plicability and ACTION l lin 3.3M l Statements still assure rod withdrawal is precluded. l This change does not involve any safety impact and is consistent with traveler. 1 56 Not applicable to Wolf Creek. See Conversion W i-s4 Comparison Table (Enclosure 38). 1-57 LG Current TS Table 3.31 Functional Units [12.a and 12.b] are combined per traveler TSTF 169. The Required Channels ACTION Statement, and Surveillance Requirements are the same for both Functional Units. The only difference between the two is the Applicability which could lead to entry into ACTION Statement 6 for Functional Unit [12.a], followed by a power reduction below P 8 exiting the Applicability and required actions for that Functional Unit, and subsequent re entry in ACTION Statement 6 for Functional Unit [12.b]. This would involve an improper cumulative A0T of 12 hours before tripping an inoperable channel, beyond that evlausted in WCAP 10271 and its Supplementse The relationships between these l Functional Units and permissives P 7 and P-8 are moved ! to the ITS 3.3.1 Bases. ! 1 58 A Not applicable to Wolf Creek. See Conversion Comparison Table (Enclosure 3B). 1 59
@#, Not.m-e._
- c. m
,ppu c2W. 6 WW.Cvez.k. hGm,,,e,
. .s,i 1 60 Not used.
1-61 M Not applicable to Wolf Creek. See Conversion Comparison Table (Enclosure 3B). hERT 3A - M-) WCGS-Description ofchanges to CIS 3N.3 14 S/2S/97
I INSERT 3A-14 l 1-62 A Not applicable to Wolf Creek. See Conversion Comparison Table 1
]
(Enclosure 3B). j 1-63 A All reformatting, renumbering, and editorial rewording is in QPA(sf.4]3 - i accordance with the Westinghouse Standard Technical Specifications. l NUREG-1431. During the development certain wording preferences or l l English language conventions nere adopted. As a result, the i Technical Specifications (TS) should be more readily readable, and ' therefore understandable. Dy piant operators and other users. During i the reformatting, renumbering, and rewording process, no technical ) changes (either actual or interpretational) to the TS were made j unless they were identified and justified. 1
) Gl-23 J 1-64 A The refueling interval TAD 0Ts for Functional Units [1 and 17] in CTS Table 4.3-1 have been revised to include existing Note [10, "Setpoint .
verification is not required."] Likewise, refueling interval TADOTs l for Functional Units [1.a. 2.a. 3.a.1), 3.b.1), 3.c.1), 4.a. 6.a. 9.a j and 11.b] in CTS Table 4.3-2 have been revised to add a new Note [5]. l
" Verification of setpoint not required." This change is administrative in nature since the subject Functional Units have no l setpoints associated with them. This change does not affect the operating limits or manner in which the plant is operated. There are 3 no changes to current plant practices for the performance of these i TADOTs since there are no setpoints to verify for these Functional Units. This change is strictly an acknowledgement that the .
corresponding ITS SRs 3.3.1.14, 3.3.2.8, and 3.3.2.11 have an j explicit Note to this effect. l I Q2-nl i 1-65 A Seven slave relays are listed in Note (3) to CTS Table 4.3-2 for an exception to the quarterly SLAVE REl AY TEST. These slave relays are associated with the following ESF actuation signals: K602 (SIS): K620 l (turbine trip and main feedwater pump trip); K622 (CIS-A): K624 (CIS-A); K630 (CIS-A and the CIS-A input to containment purge isolation and control room ventilation isolation): K740 (SIS, RWST low-low); and K741 (SIS, RWST low-low). ITS SR 3.3.2.6 has been revised with a Note per JFD 3.3-19 that excludes these seven slave relays from the quarterly surveillance. Based on the differing Functional Unit MODE Applicabilities, new ITS SRs 3.3.2.13 and 3.3.2.14 have been added under JFD 3.3-19 to cover the surveillance frequency applicable to l these slave relays. The only slave relay associated with containment purge isolation and control room ventilation isolation, K630, has the extended surveillance frequency under new ITS SR 3.3.2.13. Based on feedback received from the NRC reviewer at a meeting on September 16, ! 1998, the 90 days cited in Note (3) has been changed to 92 days to follow standard convention for an exception to a quarterly surveillance frequency. l l 1
, - , . c _ --, -- ,
r INSERT 3A-14 (continued) Q 3.5j \ 1-66 LS-45 The CTS allows ~ certain inoperable channels, or for some plants one other channel, to be bypassed for testing per Specification 4.3.1.1 or 4.3.2.1. The intent of the bypass is to allow testing that will verify that the channel has been restored to an OPERABLE condition and can be returned to service. The allowed bypass time for testing has been evaluated for its impact on the safety analyses. It has been determined that the impact of the allowed bypasses is minimal. l Whether the bypass is for setpoint verification or response time I verification has no impact on the safety analysis. This change would delete the reference to Specification 4.3.1.1 and 4.3.2.1 in the allowed bypass notes contained in certain CTS ACTION statements, thus permitting any testing needed for restoration of the inoperable function. l I l l' r l l I ! I i i
inmRT 3 CONVERSION COM PARISON TABLE - CURRENT TS 3/4.3 rage 14 or30 TECll SPEC CllANGE APPI,ICABII ITY NUnlin R DESCRIPTRON DIABLO CANYON COMANCIIE FEAK WOI.F CREEK cal.l.AWAY 1-61 If the requirements of current CPSES ACTION Statement 6 are No - see Yes No see No - see M not met. LCO 3.0.3 would be entered. In accordance with CN# 1-19-LS 8. CNf 1 19 LS-8. CNf 1-19 LS-8. the ISTS. this ACTION Statement is revised to state that, if the ACTION requirements are not met, the plant must be taken below the P 7 interlock setpoint within the r. ext 6 e hours. 2-01 The Engineered Safety Features Actuation System Yes Yes Yes Yes A Instrumentation [] Allowable Values are moved to ITS Table 3.3.2-1. 2 02 CTS ACTION b.1. Equation 2.2 1, and the values for Total No - not in current No not in current Yes Yes A Allowance (TA). Z, and Sensor Error (5) are deleted. TS. TS. consistent with NUREG-1431 Rev. 1. 2 03 The Engineered Safety Features Actuation System No - retain in ITS. Yes moved to Yes - Hoved to ITS Yes - Moved to ITS LG Instrumentation Trip Setpoints are moved to a licensee Bases. 3.3.2 Bases. 3.3.2 Bases controlled document. 2 04 The requirements stipulated in ACTIONS a and b are moved to Yes Yes Yes Yes LG ITS Table 3.3.2-1 with explicit direction contained in the ITS ACTIONS Bases. 2-05 TheFunctionalUnitforContainment(, urge] P Isolation. CTS No - see (MMCN1.,20 A) Yes Yes H 3.c. is moved to inproved TS 3.3.6. Isproved TS 3.3.6 adds CN 02-20 A C5 pg.og} requirements on the OPERABILITY of the containment { purge radiation] monitors and extends the Applicability for the [ Manual Initiation and BOP ESFASlactuation logic to include during movement of irradiated fuel assenblies within containmentQndCoreAlterations} 2 06 Functional Unit 4.a.1 of current TS Tabl s been No - retain CIS Yes M Yes g,p LS 33 deleted. C 2 'n Yes _ j WCGS-CONVERSION TABLE- CTS 3M.3 S/15/97
t INSERT 3B-14 , TECH SPEC CHANGE APPLICABILITY NUMBER DESCRIPTION DIABLO CANYON COMMANCHE PEAK WOLF CREEK CALLAWAY t 1-62 In a Callaway-specific change ACTION 7 in No No No Yes A CTS Table 3.3-1 is moved from Functional lGUhsres4 } Units 13.a and 13.b to Functional Unit 13.c i 1-63 All reformatting, renumbering, and Yes Yes Yes Yes A editorial wording is in accordance with the Westinghouse Standard Technical {cpt-AGEo1} . Specifications. NUREG-1431. ' 1-64 Notes are added to Tables 4.3-1 and 4.3-2 Yes Yes Yes Yes. A to exclude setpoint verifications during TADOTs on Functional Units that do not have setpoints associated with them. (gi.z,;5 } t 1-65 Explanation of ITS treatment of seven slave No No Yes Yes A relays with extended surveillance frequency. 4> 2 }
- 1-66 This change would delete the reference to Yes Yes Yes Yes LS-45 Specification 4.3.1.1 and 4.3.2.1 in the ,3 allowed bypass notes contained in certain d%2L3,3 CTS ACTION statements, thus permitting any
~
testing needed for restoration of the inoperable function. , i 1-67 This change revises DCPP CTS ACTIONS 13 and Yes No No No & M 29 to provide specific shutdown requirements to exit Applicability, in lieu k d>3'3-4 b k : of applying CTS. k t P
ADDITIONAL INFORMATION COVER SHEET ADDITIONAL INFORMATION NO: O 1-25 APPLICABILITY: DC, CP, WC, CA
" EQUEST: NUREG-1431, Rev.1 incorporates the current TS 4.0.4 exception from Table 4.3-1 Notes (2), (3), and (6) into the ITS SR 3.3.1.2,3.3.1.3, and 3.3.1.6 surveillance frequencies.
Comment: No justification has been provided for changing the power level in CTS Table 4.3-1 note 3 from 15% to 50%. For note (2) the addition of the time period for completion of the CHANNEL CALIBPATION does not provide clarification to this surveillance as this is a daily surveillance and if not performed within 24 hours, this functional unit would be declared inoperable. Furthermore, this change is categorized as an administrative change when, in fact, the change results in less restrictive TS requirements. FLOG RESPONSE: The 50% RTP level establishes the lower safety analysis boundary for the AFD and QPTR LCOs. Below 50% RTP there are no corrective actions required for off-normal power distributions. DOC 1-25-A has been revised and changed to an *M" DOC, since the new limitations are more restrictive than the current TS with its SR 4.0.4 exception. For DCPP, the CTS specifies the conditions and time requirements for performance of this surveillance, thus the exception from CTS 4.0.4 is not required in the ITS. Note (2) specifies >15% RTP and a completion time of <24 hours or before increasing power above 30% RTP. 1 i ATTACHED PAGES: i Encl. 2 3-9,3-12 l Encl.3A 8,9,10 Encl. 3B 7 l
TABLE 4 3-1 REACTOR TRIP SYSTEM INSTRUMENTATION SURVEILLANCE REQUIREMENTS TRIP ANALOG ACTUATING MODESFOR CHANNEL DEVICE WHIGH CHANNEL CHANNEL OPERATIONAL OPERATIONAL ACTUATION SURVE46 LANCE l-44-A . FUNCTIONAL UNIT CHECK CAllBRATION TEST TEST LOGIC TEST IS44iQUIRED
- 1. Manual Reactor Trip N.A. NA. N.A. N.A. t 2 ?*, '*, 5 1-32G
- 2. Power Range Neutron Flux t-H -A le -as I
- a. High Setpoint S D(2,4) Q N.A. N.A. w I M W) 1-21-A -
W R(4,5) ' l-26-LG - 1-2RM -
- b. Low Setpoint S R(4 S/U(1 Q(19,20) NA. N.A. 4###r3
~
[,39,'
- 3. Power Ranga Neutron Flux, NA. R(4 Q N.A. N.A. 4r3 1-39-A High Positwe Rate
- 4. Power Range, Neutron flux, N.A. R(4)(5) Q N.A. NA. 4r3 1-39-A H@ Negah Re 1-26-LO
- 5. Intermediate Range, S R(4,5) N.A. N.A. 4###ra 1-22-M Neutron Flux Q(19, ;_ , 1-26-LG
- 6. Source Range, Neutron Flux S R(4,5) S/U(1),0(9h N.A. N.A. """ 3, ' , 5 h
I 10
- 7. Overtemperature AT S 21) Q NA. N.A. 4ra 1-23-A
- 3) 1-21-A '
6 , 1 40-LS-41
- 8. Overpower AT S B [21) Q NA. NA. 4r3 1-23-A
- 9. Pressurizer Pressure-Low S R 21) Q N.A. N.A. 4 I-23-A
- 10. Pressurizer Pressure-High- S R' 21) Q N.A. NA. 4r4 I-23-A
- 11. PressurizerWater Level-High S Ri21) Q NA. NA. 4 , .1-23-A
- 12. Reactor Coolant Flow-Low S R Q N.A. N.A. 4 WOLFCREEK- UNITI JN 3-9 Amendment No. !2,25, '3,52, %
Marn-up ofCTSJN. 3 $/15M7 I
]
. - _ _ _ _ _ _ _ _ _ . .-.m__.___. ._ _ _.- ._._.-._ _ . . . . . . _ . . _ _ _ _ _ . . . _ . . . . _
)
s 1 l TABLE 4.3-1 (Continued) { TABLE NOTATIONS 1
*Only if the Reactor Trip System breakers happen to be closed and the control l l rod drive system is capable of rod withdrawal.
t MBelow P-6 (intermediate Range Neutron Flux interlock) Setpoint. I I
#M8elow P-10 (Low Setpoint Power Ranaa_ Neutron Flux Interlock) Setpoint. 1 (1)- if not performed in preveus 34 @2 days] ~fl.MLS 9i' if not performed in proveus 31 days. - ~ " '
(1a) (2) Compenson of colonmotoc to excore power indicaten above 15% of RATED THERMAL POWER. Adj st excore channel gains consistent with calonmetric power if absolute m difference ._.. is gre._ater _ _ _ ~ _ . . _ _ _ , . . . _ _ .. . . - _ _ . _ . . than 2%. 5 ;:r; - n: M ?;: ^^ ~t?? 1-25 d et d ! ' (3) Smgle point compenson of incore to excore AXtAL F X DIFFERENCE within ., p i 24 hour after THERMAL POWER is . > ::RATED :: '~THERMAL
.1 - i-26~)
POWER. Recolibrate if the absolute difference is greater then or equal to 3%. ?O n
" rr!^ * ^ : ' *: _ '" - -- toA = - ' L ;' - 2: ^:: 2 '? " 2 = * 'l-40-L5-41 or the purpose of this surveillance, the 6nterval is defined as 31 effective full power]
days (EFPD). i l (4) Neutron detectors may be excluded from CHANNEL CALIBRATION. (5) Fr Tr:-- "_ z;;____,__.m. __m ____m _ f - ^- , ' ^ .. _: 5':.: r;;; r : _ _______m__. _ . _ . - m,_._
. , r; 'r ' '_. _o____m____. 1-26.LG l '_ :~ - X '_'_ : L _ :..L' _ _ __ __:_:. ::::_: , ._ _
- L';; :_ : rX_ n: m" i.
For the intermedete Range and Power Range Neutron Flux channels the provisens of Specillcobon 4.0.4 are not applicable for entry into MODE 2 or 1 incore - Excore Calibraten. :: r;S^^-2n 72 hours after achievina oeuilibrium) (6) ~~
%21-A~ M O- ^^ - with Thermal PowerB75% of RATED THERMAL POWER.
W ;:: '-- ' T;: ~ - t ^ . ' = :-' _ ; ; " _ '_ ' - '- L" ; 2 " 2 ^~ *
"gg g
I (7)- Each train shall be tested at least every 62 days on a STAGGERED TEST BASIS. i (9) Quadedy Surveillanceba- : ouarterly and antar to ^.9- "'"? 2*, x: 5* . 7,26.LG. ~ j shall also include venficaten that perrmssives P-6 and P-10 are in their required state __ ;,1-28-A _,, for existing plant condsbons b; -M ;::; M ?; pn- _: z r - - _:7 21 ' *1'32-LG
- 7 ~"
w .J .a (10) Setpomt verslicaten is not required. l (11 AC ING CE OP T1 EST i yv the Q t-32. l - i Fup l of the u nd shu trip ' for the nual R or ["1-12-LG "*" , test I also the O RABIL ofthe ss Br er trip it(s . i ' j- (12) Deleted. i I
"C 1 , _ _ _ _
_ _ _ M O"" ^.*"_'" d 50 .n nr! : : ^ i _ _ - .__ . _. "; 2:" h ( 1-31.A "
*^ *"
'_.-- ;f ;n: 5 C; ' :.c ?: ".._: :h'": - t: '"::: 2 r-- "n; :^:- ^'T; ' - _
u " t-I i i 4 WOLF CAEEK- UNITI JN 3-12 Amendment No. :2, 25. 55,83,96 Mark-arp ofCTS3M. 3 S/lSM7
CsANGE NUPEER H2iG DESCRIPTION Neutron Flux-high Setpoint Function to the Overtemperature [4T] Function. This change clarifies the relationship of these surveillances to the f (aI) 3 penalty portion of the Overtemperature [4T] Function. The primary purpose of these surveillances is to verify correct f 3(41) input to Overtemperature [4T]. Although these surveillances affect all power range neutron flux channels, and appropriate action must be taken for any affected power range neutron flux channel, this change groups the surveillances with the most appropriate reactor trip function for operability concerns. [The frequencies of these surveillances are revised in accordance with CN 1-40 LS 41.] The applicable portions of current TS Table 4.31 Notes (3) and (6) are incorporated directly into ITS SR 3.3.1.3 and SR .zw l 3.3.1.6,asdiscussedinCN125frNote(4)hasbeen deleted from the daily, monthly, and quarterly surveillances associated with Notes (2), (3), and (6) of current TS Table 4.3 1 since these surveillances are not CHANNEL CALIBRATIONS, rather they are comparisons and adjustments as needed. These changes are consistent with NUREG 1431. Rev.1. 1-22 M Quarterly COTS have been added to current TS Table 4.3-1 for the Power Range Neutron Flux Low and Intermediate Range Neutron Flux trip functions in the event extended operation within their Applicability (i.e., MODE 1 below P 10 and MODE 2) takes place. The current ITS only require a COT prior to startup for these functions. New Note [(19)] has been added to require that the new quarterly COT be performed within 12 hours after reducing power below P-10 for the power range and intermediate range instrumentation (P-10 is the dividing point marking the Applicability for these trip functions), if not performed within the previous 92 days. [In addition, new Note (20) has been added] such that the P 6 and P 10 interlocks are verified to be in their required state during all COTS on the Power Range Neutron Flux Low and Intermediate Range Neutron Flux trip functions. These changes are consis n with NUREG - 1431, Rev.1 and traveler (OG 1 . sIM42. @ 3.3-49 } 1 23 A This change adds a new Note [21] to current TS Table 4.3-1 and new Note [4] to current TS Table 4.3 2 that explicitly requires the 18 month calibrations include verifications of affected time constants consistent ! with NUREG - 1431. Rev.1. WCGS-Description ofchanges to CTS 3M.3 8 S/158 7
CHANGE ' NUMBER HSiC DESCRfPTION 1-24 LS-9 This change reflects a relaxation in the performance of COTS prier to startup, consistent with NUREG-1431. Rev. 1. These COTS. for the Power Range Neutron Flux - Low. Intermediate Range Neutron Flux. and Source Range Neutron Flux trip functions, will not be required if performed within the previous 92 days. Note [(1)] of CTS Table 4.31 has been revised to extend this period i from 31 days to 92 days. Note [(la)] is added for use with the turbine trip function TAD 0Ts. for which no such change was provided. 1-25 # NUREG-1431 Rev.1 incorporates the current TS 4.0.4 ri ' exception for the surveillances covered by current TS Table 4.31 Notes (2), (3), and (6) into the ISTS SR Y 8-Z ) . 3.3.1.2. 3.3.1.3, and 3.3.1.6 surveillance frequencies. In the current TS. these surveillances have no time i requirements []. In general, the combined effect of l current TS 4.0.3 and current TS 4.0.4 would allow [24 ; hours] for the completion of a surveillance if it were ! not performed upon entry into the specified H0DE or l other condition for that surveillance. Current TS 4.0.3 allows [] for the completion of a surveillance ; once the appropriate MODE or plant condition is established. In the improved TS, the TS 4.0.4 exceptions are incorporated as a NOTE in each affected surveillance. In converting to the NUREG-1431 format. ITS SR 3.3.1.2. SR 3.3.1.3, and SR 3.3.1.6 require these surveillances to be performed within [24] hours after THERMAL POWER is greater than or equal to 15% RTP I (current TS Note (2) for the comparison of NIS power to calorimetric power), within [24] hours after 50% RTP (current TS Note (3) for the comparison of excore Axial Flux Difference (AFD) to incore AFD) and within [72 i hours after achieving equilibrium conditions with ' THERMAL POWER 2 75%] RTP (current TS Note (6) for the incore excore calibration), respectively. Since these surveillances are conditional on THERMAL POWER levels greater than the H0DE 2 to MODE 1 breakpoint. there is no need to retain the current TS 4.0.4 exception, as discussed in ITS Section 1.4. as long as the ITS Surveillance Notes allow the plant to reach conditions appropriate for the performance of the surveillances. The power level at which the monthly surveillance is performed to compare incore vs. excore AFD. and adjustment of the NIS as required by Note (3) of current TS Table 4.31. is changed from 215% RTP to 250% RTP. This change is also precipitated by the conversion to the ITS format which replaces the current TS 4.0.4 exception with a finite time interval after WCGS-Description of changes to CTS 3M.3 9 5/15/97
CHANGE NUMBER NSBC DESCRIPTION exceeding a specified power level. With the deletion 4 of the current TS 4.0.4 exception, the specified power level in ITS SR 3.3.1.3 should reflect the applicable safety analysis basis consistent with the [ Applicability and] Required Actions of ITS LCO 3.2.3 (AFD) and LCO 3.2.4 (QPTR). As with the changes discussed above, there is no need to retain the current TS 4.0.4 exception as long as the Its Surveillance Notes allow the plant to reach conditions appropriate l for the performance of_the surveillances. e e. m s n e.v.vs > smu. These changes are W adifilmstKO7 thin nat e Qngt,Jhey sijnpry repett tDe-inrArForaHonaD he ja v24 current 15 4.0.4 exc_eptions j e g_t % W e d 3 I
- w. ,,.+ i.w t C 1-26 LG This change moves the detail concerning NIS detector I calibration to the BASES for ITS SR 3.3.1.11.
consistent with NUREG - 1431. Rev.1. This information is more appropriately controlled outside of the TS while the calibration requirement itself and its Frequency are unchanged. 1-27 LS-10 Surveillances on the Source Range Neutron Flux trip ; function are reorganized to reflect plant status in accordance with NUREG 1431 Rev. 1. New Note [(19)] requires that the quarterly COT be performed within 4 hours after reducing power below the respective source range instrinnentation Applicabilities, if not att rods are full 3 performed within the previous [92] days. Since the COT gg g% gg is valid for [92] days, there is no need to repeat it 6, renaered,g% sacagR4 if one has been performed within the prior [92 days]. of rod W4hdrA aftm The 4 hour allowan:e pennits a normal shutdown to Yhe proceed without a delay for testing in H0DE 2 and for a f short time in MODE 3 untilEtbe-REFactommaseTO I_ 0 3-Ls-4E0 1 L #Wangpthis trip function no longer provides
" 3 3 -o ' l protection. Since the current TS has no Specification 4.0.4 exception, this 4 hour allowance is less restrictive.
1-28 A Note [9] is revised to require the P 6 and P 10 interlock verification to be performed during all source range COTS. These permissives are verified to be in their correct state prior to entry into MODES 3.
- 4. and 5 during shutdown and after leaving H0 DES 3. 4 l and 5 during startup. This change is consistent with NUREG 1431, Rev. 1.
1 29 LG Not applicable to Wolf Creek. See Conversion Comparison Table (Enclosure 3B). WCGS-Description ofchanges to CIS3M.3 10 S/15/97
CONVERSION COMPARISON TABLE - CURRENT TS 3/4.3 rage 7 of 30 TECH SPEC CIIANGE APPLICABILITY NUMBER DESCRII" TION DIABLO CANYON COMANCilE PEAK WOLF CREEK CALLAWAY 1 20 Callaway's current ACTION Statement 31 is reformatted per No No No Yes A NUREG-1431 Rev. I to require restoration of an inoperable channel within 6 hours or the plant must be taken to MODE 3 within 12 hours. This is an administrative change since the total time to exit the Applicability is unchanged. 1-21 This change reflects the reorganization of the Yes Yes Yes Yes A surveillances on the incore/excore axial flux difference. There is no change to the surveillances or how they are performed. (See also CN 1 25 A). 1 22 Quarterly COTS have been added for power range low and Yes Yes Yes Yes M intermediate range flux channels. [The requirement to verify the state of P 6 and P-10 has been added for these COTS). 1 23 This change adds notes to the RTS and ESFAS SR Tables 4.31 Yes Yes Yes Yes A and 4.3 2 that explicitly requires the 18 month calibrations to include verifications of affected time constants where applicable. 1 24 The COTS for the power range neutron flux - low setpoint. Yes Yes Yes Yes LS-9 the intermediate range neutron flux and the Source Range Neutron Flux trip functions will no longer be required if performed within the previous 92 days (extended from 31 days). Note [la] is added for use with the turbine trip functions, for which no such change was provided. NUREG-1431 Rev. 1 incorporates the current TS 4.0.4 Yes Yes Yes Yes A-25 Jf pt exception from Table 4.3-1 Notes (2), (3) and (6) into the ITS SR 3.3.1.2. SR 3.3.1.3. and SR 3.3.1.6 surveillance [Q t-ZSl frequencies. This change moves detail concerning NIS detector operation Yes Yes Yes Yes 1-26 LG and testing to the BASES for ITS SR 3.3.1.11. WCGS-CONVERSION TABLE- CTS 3M.3 5/15/97
ADDITIONAL INFORMATION COVER SHEET ADDITIONAL INFORMATION NO: Q 1-32 APPLICABILITY: WC REQUEST: [ Note [(7)] of current TS Table 4.3-1 is revised to move the independent UVTA and STA verification to the CASES for ITS SR 3.3.1.4.] [ Note (11) of current TS Table 4.3-1 is deleted since it is redundant; every TADOT requires independent UVTA and STA verification per ITS SR 3.3.1.4, not just those TADOTs following maintenance or adjustment.) Notes f(16) and (18)] of current TS Table 4.3-1 are moved to the BASES for ITS SR 3.3.1.14. Comment: Note 16 on the RTB bypass breaker TADOT is marked as deleted and the l deletion justified as a relocation of the requirement to the Bases. In actuality, there is no change from the CTS because the test required by note 16 is covered in ITS by the bypass breaker requirements which are combined there with general RTB requirements. In this format the UV trip test is called out by virtue of note (k) on function 20 in ITS table 3.3.1-1. The markup of the ITS is correct and the markup of the CTS is incorrect. Revise the CTS. FLOG RESPONSE: The comment to correct the CTS markups is only applicabb to Wolf Creek. The CTS has been revised to reflect that the details of Notes 16,11 and 18 have teen moved to the ITS SR 3.3.1.4 and SR 3.3.1.14 Bases. Also the . bracketed text of DOC 1-32-LG has been revised to correctly reflect ; moving the details of these notes. l ATTACHED PAGES: Encl. 2 3-11, 3-12, 3-12a Encl.3A 11 Encl. 3B 9
)
i
l TABLE 4.3-1 REACTOR TRIP SYSTEM INSTRUMENTATION SURVEILLANCE REQUIREMENTS TRIP ANALOG ACTUATING MODESFOR CHANNEL DEVICE WHICH CHANNEL CHANNEL OPERATIONAL OPERATIONAL ACTUATION SURVE4LLANCE FUNCTIONAL UNIT CHECK CALIBRATION TEST TEST LOGIC TEST SS-REQU4RE@-
- 18. Reactor Trip System Interlocks (Continued) 1 44.A l
- d. Power Range Neutron Flux, P-10 N.A. R(4) R N.A. N.A. 4r3
- e. Turbine impulse Chamber I-23-A Pressure, P-13 N.A. R 21) R NA. NA. ?
-32
- 19. Reactor Trip Breaker N.A. N.A. N.A. M(7 NA. 1,2,O','*,5 ,
- 20. Automatic Trip and '
Interlock Logic N.A. N.A. N.A. NA. M(7) 1, 2, 3*, ' *, 5* l-32-LG
- 2,3*,'*,5*
- 21. Reactor Trip Bypass Breaker N.A. N.A. N.A. M(17), N.A. ,
lQ t-32. ] WOLF CREEK- UNIT I 3/4311 Amendment No. 43-26 M:rA-up ofCTS 3/4. 3 5/15M7
f 1 TABLE 4.3-1 (Continued) l TABLE NOTATIONS
*Only if the Reactor Trip System breakers happen to be closed and the control rod drive system is capable of rod withdrawal.
) NBelow P-6 (Intermediate Range Neutron Flux Interlock) Setpoint. 1 1
#NBelow P-10 (Low Setpoint Power Ra Neutron Flux Interlock) Setpoint.
(1) if not performed in provous 34 2 days. (1a) if not performed in prevous 31 days. %" 24-LS-9_' l (2) Compenson of calorimetric to excore power indication above 15% of RATED THERMAL POWER. Adjust excore channel gains consistent with calorimetnc power if absolute difference is greater than 2%. S:;r- : ; M ?;::*:2::- i.0 '
= :-' ,_ , ' - 5 :..1 ; M : ^ ^"' 2 =
- l-25 d pt b (3) Single point comparison of incore to excore AXIAL DIFFERENCE within 24 hour aflerTHERMAL POWER is > :t :;; *" RATED THERMAL E N -- ,
l POWER. Recalibrate if the absolute inflorence is greater than or equal to 3%. T1-2M l 5 : n : ; d ?; r * - - - -- 10.i r r > :;;' : * ': 5 ;..' ; ' ' ^^' 2 r
- _ 1-40-L.5-41 or the purpose of this surveillance, the interval is defined as 31 effective full power]
l days (EFPD). l (4) Neutron detectors may be excluded from CHANNEL CALIBRATION.
' * - - " - - - " - ^ - - ^ - - - - ~ - - - - - - ' ^ ' " - - ' ' ^ "
(5) 1r_.---~~:1T; '_ _ ;_:c'_'/ r'" K.-'JJ_'J ';: i T ' J_im__.1'.o____ _m____,_
.126-LG
=~ '._:_:,.;_ :__;'t X .'. L,_,; ' . " ~ ~
'_~'_:' r :~;;-'__ : ..'; ' ._ ._ . . _ _ _ - - _ _ . _ _ ' . ' _ _:, _;;_T:
For the intermediale Range and Power Range Neutron Flux channels the provisions of_ . _ - l Specificebon 4.0.4 are not applicable for entry into MODE 2 or 1 Incore - Excore Calibrabon, Zi: d;^_^.:n 72 hours after achievina equilibrium) (6) l141.A " Q LEondition with Thermal PowerD5% of RATED THERMAL POWER. S: ;1 : : ; d "-- '- ^ - 10.1 = : ' :;;' _ _' ': 5 :nt ; M: ^^5 2 =
- gg i
'g l (7) Each train shall be tested at least every 62 days on a STAGGERED TEST BASIS. ;
(g) Questesty Surveillance 6erformed euarterty and nrior to e^.ed- ^_^^^S 2*, '* xf 5* II.M i shall also include venficaton that permissives P-6 and P 10 are in their required state ll-28-A__ i I for existing plant conditions 'y :t:: 2 : . M ^: ;;:-f:f;; _nnz - .:'n f:~ 41:52-LG; ~
- m. :.
(10) Setpoint venfication is not required. (11 A ING TIO TEST yv the Q1-31] I of the u . CE OP nd shu trip ci for the nual R or 'l-32-LGf test also the O RABil ofthe as B er trip it(s . Fu[on. "' ' (12) Deleted.
~c:r;':; . r : - . M ^aEa ^ ="_= e t: ::c ' n::--- e; ::. _ e ; :'.:m 4 31-A~'
. I ;:l: ' _^ ." ; ' : '.' '. _^ i'.I: -- ' "- f: 2 ^- -% ^:: ^. !' -
1 l l WOLF CREEK- UNIT 1 3M 3-12 Amendment No. 12, 25, !5, *?. 96 Mark-up ofCTS3M. 3 5IlSR7
TABLE 4 3-1 (Continued) TABLE NOTATIONS (13) DELETED. (14) DELETED. (15) The MODES specified for these channels in Table 4.3-2 are more restrictive and, therefore, applicable, p i-32 l (16) Thy, TRIP AC ING D CE OPE T shall epende vpW9 ' 1-32-LG ane OPE React LITY of rip Bre undervoWe%ONAL ands m-inp nts e (17) Local manual shunt trip prior to placing breaker in service. (18) MM%gep A# '_~ 3 2- I - T 1-32-LG ' [New(19) f The ANALOG CHANNEL OPERATIONAL TEST shall be performed within 12 hours after reducing power below P-10 for the power range and
~1 .22-M intermediate range instrumentation and within 4 hours after reducing power 1-27-LS-10 below P 4 for the source range instrumentation, if not performed within the previous 92 dayy New (20) Surveillance shall also include verification that permissives P-6 and P 10 1-22-M are in their required state for existing plant conditions. - - ~
New (21) includes verification of time constants, where applicable.
~']23-A ~ ,
i 9Mh ihe 44 Girol katem capable. *f rod JNlrwa er one, oc marv. et>ds not fd inseried, h. ACDT G rd g gg reqmdd prior tb e.rder'mg 3 -from tiobe.2 wid {4 hours after eMermg MODE.3. WOLF CREEK- UNIT 1 3M 3-12a Amendment No. !2,25,13,52 Mark-up of CTSJM. 3 5/1597
( CHANGE NUMBER N2iG DESCRIPTION l 1-30 M Not applicable to Wolf Creek. See Conversion Comparison Table (Enclosure 3B). j l ! 1-31 A One-time surveillance waivers are deleted. They are no longer ap icable. ] l 1-32 LG [ Note ] of current TS Table 4.3-1(is feyfsed'ED pi-32.] (b move.,the independent UVTA and STA verification to the BASES for ITS SR 3.3.1.4.] [floty'(llyof rrept Ty-l a e .3-1A @ rete #"sigeAt is f dant 40 Mbts-]f6) l . Notes [ and (18)] of current TS Table l UO 4.31 are mov the BASES for ITS SR 3.3.1.14. Inese changes are consistent with NUREG 1431, Rev. 1. 1-33 TR-1 Not applicable to Wolf Creet See Conversion j Comparison Table (Enclosure 3B). l 1-34 A Not applicable to Wolf Creek. See Conversion Comparison Table (Enclosure 3B). I 1-35 LG Not applicable to Wolf Creek. See Conversion Comparison Table (Enclosure 3B). 1-36 H Not applicable to Wolf Creek. See Conversion Comparison Table (Enclosure 38). 1-37 In the current TS, the "Minimte Channels OPERABLE" is one less than the " Total Number of Channels" for bb iTS c..,J ; h A, . , Functional Units [18.c] (P-8), [18.d](P-9), and e.nwa s os ,,. p. imee. [18.e](P 10) in Table 3.31 and Functional l ,ga #,guu , ww Untt [11.a](P 11) in Table [3.3 3]. For these Reactor , 4= c h*nnds Trip System and ESFAS interlocks, current ACTION
% c.r.sa,rep % uo m %,u g Statements [8 and 20] for an inoperable channel are rear.c.ha ch ye . based on the " Minimum Channels OPERABLE" columns in Tables 3.31 and [3.3 3]. In the improved TS. only the
" Total Number of Channels" information is retained in the LCO and that column is relabeled as the " Required Channels", as discussed in CN 104 LG and CN 143 A.
Required Actions in improved TS 3.3.1 Ccaditions S and T and improved TS 3.3.2 Condition L are tied to the R uired Channe The e, t ui 1 Q3 3 l rr Refer also to CN 1-51 LG for P 7. 1-38 R In MODES 3, 4, and 5 when all control rods are fully inserted and the Rod Control System is incapable of rod I withdrawal, the source range neutron flux function does not provide input to any reactor trip function nor is it credited for mitigation of any analyzed event. (At one time, the source range neutron flux signal was WCGS-Description ofchanges to CTS 3M.3 11 S/1587 l l
t CONVERSION COMPARISON TABLE - CURRENT TS 3/4.3 rage 9 or3e TECll SPEC CHANGE APPLICABILITY l NtatBER DESCRII" TION DIABLO CANYON COMANCHEPEAK WOLF CREEK CALLAWAY cf0*O Yes Yes Yes 1-32 [ Note [h] of current TS Table 4.31 (WsetQtd movesYes LG the independent UVTA_and STA verification to the BASES __for M) Not (Ji) and (18)] of current TS Table 4.3-1 are moved to the S for ITS SR 3.3.1.14. 1-33 The BONS actuation SR is changed to allow the use of an No not in current No not in current No not in current Yes TR 1 actual signal. if and when one occurs, to satisfy TS. TS. TS. ; surveillance requirements. The Callaw3y current ACTION Statement (5.b] requirements No No No Yes 1-34 A for two inoperable source range channels are divided between the reactor trip, indication and BONS functions served by the source range channels. New ACTION 4.1 added to CTS Table 3.3-1 retains the requirement to open the reactor trip breakers to serve the reactor trip function. The ACTION Statement 5.b requirements that are not related to reactor trip are moved to ITS 3.3.9. See also CN 1 '3-M. No already moved No already moved No-already moved to 135 LG DCPP will move response time limit tables to the updated Yes i FSAR per Generic Letter 93 08 and NUREG-1431. Rev. 1. to TRM. to FSAR Section FSAR Section 16.3. 16.3. i Yes No No No 1_-36 This DCPP specific change adds a requirement to perform a Channel Calibration on Function Unit 17 every ,W months. I oc.3.3.oo 2_ ( ()r LS-5Q
$/15M7 WCGS-CONVERSION TABLE- CTS 3M.3 <
_ _ _ _ _,r.~-- # . ,_,-----.
l ADDITIONAL INFORMATION COVER SHEET ADDITIONAL INFORMATION NO: Q 1-37 APPLICABILITY: DC, CP, WC, CA l REQUEST: In the current TS, the " Minimum Channels OPERABLE" is one less than the " Total Number of Channels" for Functional Units [18.c] (P-8), [18.d](P-9), and [18.e](P-10) in l Table 3.3-1 and Functional Unit (11.a](P-11) in Table [3.3-3). For these Reactor Trip System ' and ESFAS interlocks, current ACTION Statements [8 and 20] for an inoperable channel are based on the " Minimum Channels OPERABLE" columns in Tables 3.3-1 and [3.3-3]. In the improved TS, only the " Total Number of Channels" information is retained in the LCO and that ! column is relabeled as the " Required Channels", as discussed in CN 1-04-LG and CN 143-A. Required Actions in improved TS 3.3.1 Conditions S and T and improved TS 3.3.2 Condition L are tied to the Required Channels. Therefore, the required permissive channels for these Functional Units are revised in the current TS. Refer also to CN 1-51-LG for P-7. : Comment: [ DOC]- The CTS markup changes the total number of channels for the P7, P8, P9,and P10 interlocks (CTS functions 22b, c, d, and e) from 4 channels to 3 and the required number of channels in the ITS is 3 instead of 4. This is counter to the format of the improved TS. Allinstalled RTS channels should be required to be , OPERABLE and actions provided for any channel out of service. If the impact of a single l inoperable channel is very low, the Required Action may be minimal. Revise the ITS 1 Table to require 4 channels for P7, P8, P9,and P10 interlocks. [OOS issue] The CTS markup changes the total number of channels for the P-11 I interlock (CTS function 8a) from 3 channels to 2. The interlock enables on any two of three channels, thus proposed required channels do not account for single channel failures. This is counter to the format of the improved tech specs and this is a change to the CTS. Allinstalled channels are required to be operable and actions provided for any channel out of service. If the impact of a single inoperable channelis very low, the required action may be minimal. This change in conjunction with JFD 3.3-44 (multiple function entry for inoperable I interlock channels) are OOS issues. Single channel inoperabilities can be verified and operation is indefinite, but multiple inoperable channels as proposed could place the I plant in an unsafe condition if the applicable P-11 setpoint (AV)is disabled because power is lowered and then re-enabled because power is raised again. At the transition back into the power range when P-11 is required the ITS would not require subsequent reverification of setpoints per Required Action L.1. {not WC} The CTS markup changes the total number of channels for the P11 interlock (CTS function 8a) from 3 channels to 2. This is counter to the format of the improved tech specs. Allinstalled RTS channels should be required to be OPERABLE and actions provided for any channel out of service. If the impact of a single inoperable channelis very low, the Required Action may be minimal. FLOG RESPONSE: See the response to Comment Number O 3.3-44. All permissive channels will be required OPERABLE in the ITS and DOC 1-37-A was changed to 1-37-M. ATTACHED PAGES: l None l l I
. ADDITIONAL INFORMATION COVER SHEET ADDITIONAL INFORMATION NO: O 1-40 APPLICABILITY: WC, CA REQUEST: Surveillance intervals applied to Notes (3) and (6) of CTS Table 4.3-1 will be defined in terms of effective full power days (EFPD). However, EFPD may be longer than calendar days as specified in the CTS. Therefore, this change is considered less restrictive.
l Comment: The justification is inadequate for changing the CTS SR frequency to 92 EFPD and for proposing the CTS incore/excore calibration for Power Range Flux, High Setpoint be applied instead to Overtemperature DT in the ITS. Adequate justification would be the current requirements represent unsafe practices or may result in an operational hardship. l l l l FLOG RESPONSE: DOC 1-40-LS-41 and NSHC LS-41 have been revised, as per the l l attached. The second part of the comment is misplaced since that change l l is discussed under DOC 1-21-A. l l ATTACHED PAGES: 1 Encl. 3A 12 Encl. 3B 10 Encl. 4 64 l l l l l
~ . .
~ . - - - - - - . - - -.-~---.~ ---.-- - _-.---
CHANGE NUPEER HSHC DESCRIPTION credited in the analysis of the inadvertent boron ; dilution event: however, as described in a previous license amendment [ Wolf Creek Amendment 0%], this analysis was revised to credit other alarms.) Because the source range neutron flux function in these . conditions does not satisfy any of the four criteria of . 50.36 (C)(2)(ii), it.is being deleted from the Technical Specifications. However, the operation of this function will continue to be maintained trhough ! plant procedures as it does provide important alternate l indication to the reactor operators. i 1-39 A This change adds Note [5] to Functional Units [2.b and 3] in current TS Table 4.31. Note [5] is currently listed against Functional Unit [2.a]. Testing l methodology and the timing of that testing for the i power range channels apply to all power range functions, not just power range-high. As such, this is i an ahinistrative change only. ITS SR 3.3.1.11 applies l to all power range functions in a similar fashion. 1 40 LS 41 Surveillance intervals applied to Notes [(3) and (6)] of the current TS Table 4.31 will be defined in terms I of effective full power days (EFPD). EFPD is defined as the integrated energy output of the fuel at rated thermal power over 24 hours and is a measure of fuel depletion. This is more reflective of the changes occurring by basing the surveillances on core burnup. This is intended to correlate NIS detector peiformance
- o. M ll W Ajl"terv ha with core performance and represents a minor change for \@+D[
a base load plant. However?EFPD may be longer than@ w "on calendar days specified in the current TS. Therefore, d" **N this change is considered less restrictive. l l 1 41 A Not applicable to Wolf Creek. See Conversion l Comparison Table (Enclosure 38). 1 42 M Not applicable to Wolf Creek. See Conversion Comparison Table (Enclosure 38). 1-43 A The " Total Number of Channels" columns in current TS Tables 3.31 and [3.3 3] and the [" Minimum Channels Operable"] columns in current TS Table [3.3 6] are relabeled as the " Required Channels" consistent with
- NUREG 1431 Revision 1. Action Statements are also revised to use the ITS terminology, " Required l Channel s." Changing the column titles is purely j akinistrative. The numbers in the columns are adjusted, if necessary. Where the numbers are adjusted, those changes are described in different CNs.
WCGS-Description ofchanges to CTS 3M.3 12 S/lS/97 i u . - ._ ._ _
CONVERSION COMPARISON TABLE - CURRENT TS 3/4.3 rage io of 30 TECII SPEC CIIANGE APPI.ICABILITY NilMRER DESCRIPTION DIABI.O CANYON COMANCilE PEAK WOt,F CREEK CALLAWAY 5 1-37 # In the current TS, the " Minimum Channels OPERABLE" is one Yes Yes Yes Yes i M less than the " Total Number of Channels" for Functional Units [18.c] (P 8). [18.d](P 9), and [18.e](P-10) in Table 3.3-1 and Functional Unit [11.a](P-11) in Table [3.3-3]. For these Reactor Trip System and ESFAS interlocks, current ACTION Statements [8 and 20] for an inoperable channel are based on the " Minimum Channels OPERABLE" columns in Tables 3.3-1 and [3.3-3]. In the improved TS. only the " Total Nunter of Channels" information is retained in the LCO and that column is relabeled as the " Required Channels", as discussed in _ CN 1 04 LG and CN 1 43 A. Required Actions in improved fgg,, y m c,a, hon 4 mt fa, g4 .n. p,m b k cbnnel lQ3.3-44 ( TS 3.3.1 Conditions 5 and T and improved TS 3.3. , maa_ , % , 4 cr.s rys. % cMnnets i@eutd c.,
, Condition L are tied to the Required Channels. Therprej g g me,re.
restricM 69 - the r ired)(raiss cna s for th(se Fyffctiopal Uffitsj m- - revisgint vrr efer also to CN 1-bl-W for P-7. 1-38 The source range channel operability requirements in MODES No - see Yes relocated to Yes - Relocated to No - see Cns 1 3, 4. and 5 when incapable of rod withdrawal are relocated CN 1 09-M the TRM. Chapter 16.3 of the LS-32, R USAR. 1 30-ti, and l to a Licensee controlled document. 134 A k This change adds Note [(5)] to Functional units [2b and 3] Yes Yes Yes Yes 1-39 A in CTS Table 4.3-1. No already in 1-40 Surveillance intervals applied to Notes (3) and (6) of No-already in Yes Yes LS 41 current TS Table 4.3-1 will be defined in terms of current TS. current TS. effective full power days (EFPD). HoweverflFPQ7may be ]Nvstlanca. Mtem longer thangalendar days spectfied in the current TS. 42*aA en _- ~ I.4 '-* I Therefore.(this change is considered less restrictive. q ,dMQ Yes No No No ; 1 41 This DCPP specific change moves the first sentence of note A (1) of Table 3.3-2 to ITS SR 3.3.1.16. and moves the rest of note (1) to the Bases. i 5/15/97 WCGS-CONVERSION TABLE- CTS 3M.3 c
I IV. SPECIFIC N0 SIGNIFICANT HAZARDS CONSIDERATIONS NSHC LS-41 10 CFR 50.92 EVALUATION l FOR TECHNICAL CHANGES THAT IMPOSE LESS RESTRICTIVE REQUIREMENTS WITHIN THE TECHNICAL SPECIFICATIONS l l The surveillance intervals applied to Notes [(3) and (6)] of the current TS Table 4.3-I will be defined in terms of effective full power days (EFPD). EFPD is defined as j the integrated energy output of the fuel at rated thermal power over 24 hours and is a 1 measure of fuel depletion. This is more reflective of the changes occurring by basing the surveillances on core burnup. This is intended to correlate NIS detector [m.4o t ) pe_rformance with core performance and represents a minor change for a_ base load plant. gverysA longthangndar dgas spyprfied in,tNFcurrjat T} The proposed TS change has been evaluated and it has been determined that it involves ! no significant hazards consideration. This determination has been performed in j accordance with the criteria set forth in 10 CFR 50.92(c) as quoted below: l l
'The Ca7 mission may make a final determination. pursuant to the procedures in 50.91. that a proposed amendment to an operating license for a facility licensed under 50.21(b) or 50.22 or for a testing facility involves no significant hazards consideration. if operation of the facility in accordance l
with the proposed amendnent would not:
- 1. Involve a significant increase in the probability or consequences of an accident previously evaluated; or l 2. Create the possibility of a new or different kind of accident from any l accident previously evaluated: or j
- 3. Involve a significant reduction in a margin of safety."
! The following evaluation is provided for the three ca'egories of the significant hazards consideration standards: l l 1. Does the change involve a significant increase in the probability or ! consequences of an accident previously evaluated? Overall protection system performance will remain within the bounds of the previously performed accident analyses since no hardware changes are proposed. The frequency change of the surveillance requirements is intended to correlate NIS detector i performance with core performance and represents a minor change for a base load plant. . This is more reflective of the changes occurring by basing the surveillance on core
, burnup. The proposed change will not affect the probability of any event initiators i nor will the proposed change affect the ability of any safety-related equipment to perform its intended function. There will be no degradation in the performance of nor j an increase in the number of challenges imposed on safety-4 WCGS- NSHCs - CTS 3M.2 64 S/15/97
INSERT LS-41 0 1-40 A surveillance interval based on EFPD may be longer than one based on calendar days, as specified in the current TS: however, a review of operating experience has shown that instrument drift is sufficiently low that any surveillance 1 interval increase corresponding to this change would be accommodated without impacting nuclear instrumentation system performance. The capability to effectively monitor core performance is not affected since neutron flux shapes change relatively slowly during steady state operation. l
)
I l l
ADDITIONAL INFORMATION COVER SHEET ADDITIONAL INFORMATION NO: O 1-51 APPLICABILITY: DC, CP, WC, CA REQUEST: This change moves the description of the P-7 inputs, i.e., P-10 and P-13, to the Bases since they are duplicated by Functional Units [18.e and 18.f] and lists "1 per train" under the Required Channels column. [] Comment: The requirement for a channel operational test of the P-7 function should not be deleted. The P-7 function is a distinct function for which surveillance must be specified. Eliminating the channel calibration requirement is acceptable since P-7 has no setpoint of it own. The COT, however, should be retained because the P-7 function has elements which are not part of P-10 or P-13. FLOG RESPONSE: The P-7 logic function is tested under CTS Table 4.3-1 Functional Unit 20 (Functional Unit 22 for DCPP) and will be tested under the ITS as described in the response to Comment Number Q 3.3-54. This comment is directed to DCPP, which has surveillance requirements associated with P-7 in the CTS. As explained in the response to Comment Number Q 3.3-54, the testing requirements specified for P-7 are inappropriate for a logic circuit. DOC 1-59-LS-46 has been created to justify the deletion of the CHANNEL CAllBRATION, per the reviewer's suggestion. In addition, the new LS DOC justifies the deletion of the COT and the adoption of an ACTUATION LOGIC TEST on a refueling outage basis. As a result of this revision. DOC 1-51-LG is revised to delete the bracketed sentence at the end of the DOC (empty brackets for the other FLOG plants). ATTACHED PAGES: Encl. 3A 13 Encl. 3B 12 l l
CHANGE l M#REE R21C DESCRIPTION l l 1-44 A The " MODES For Which Surveillance Is Required" columns i in current TS Tables 4.3-1 and 4.3 2 [ ] are deleted l since this information is enveloped ~by current TS l Tables 3.31 and [3.3 3] and is redundant given the integrated operability / SR format in improved TS Tables 3.3.1 1 and 3.3.21. 1 45 H The Overtemperature [6T], Overpower [4T]. Pressurizer Pressure High, and Steam Generator Water level Low-Low trip functions, which currently reference ACTION Statement [6], are now referenced to new ACTION Statement [2.1], consistent with ITS Condition 3.3.1 Condition E. This change is more restrictive since one less hour is available under new ACTION Statement [2.1] than under the combination of current ACTION Statement l [6] and LCO 3.0.3. 1 46 A Not applicable to Wolf Creek. See Conversion Comparison Table (Enclosure 3B). 1 47 A Not applicable to Wolf Creek. See Conversion Comparison Table (Enclosure 3B). , 1-48 LS 4 Not applicable to Wolf Creek. See Conversion Comparison Table (Enclosure 3B). 1 49 LS 18 Not applicable to Wolf Creek. See Conversion ; Comparison Table (Enclosure 38).
]
1 50 A Not applicable to Wolf Creek. See Conversion Comparison Table (Enclosure 3B). 1-51 LG This change moves the description of the P 7 inputs, i.e.. P 10 and P 13 to the Bases since they are duplicated by Functional Units [18.e and 18.f], The Required Channels column for P 7 lists "I per train" since that is a more appropriate convention for a logic function. These changes are consistent with NUREG - 1431, Rev.1Q ja i-si ) 1 52 LG This change moves the specifics on _h__ow to _ verify usa.corj IteO rEble 4 3-t Me. Permissive functions of ACTIO$49FpmCH)to the l Bases, consistent with NUREG - 1931, Rev.1. This N bD MN information is more appropriately controlled outside of l the TS while the underlying requirement to verify
't2o3 for Est:As
~
proper permissive operation is unchanged. 1-53 h I durren re ed S 1 co
.3 st t ta S
n 2 ] s 3s IQ3.3-12D) [ se sed nC 4- -LS 2i the /4 p kape. _ N c+ LtseA . y l _ l WCGS-Description ofchanges to CTS 34.3 13 S/15/97
CONVERSION COMPARISON TABLE - CURRENT TS 3/4.3 Page i2 or30 TECll SPEC CIIANGE APPLICABII.ITY Nt!MBER DESCRIPTION DIABLO CANYON COMANCllE PEAK WOff CREEK CALIAWAY 1-48 For DCPP CTS ACTION 7 is revised to allow a reduction in Yes No No No LS 4 power below P 9 in lieu of tripping the inoperable channel. The action is also revised to allow bypassing a tripped channel for four hours for surveillance testing other channels. Note (j) is edded to Table 3.3-1. Applicable Modes for Functional Unit 17.a and b that states that the requirements are sly applicable above P 9, 1-49 For DCPP. CTS KTION 9 is deleted and revised ACTION 6 is Yes No No No LS-18 used which allows a power reduction below P 7 in lieu of tripping the inoperable channel. Note (g) is added that specifies that Functional Unit 19 of the CTS does not have to be applied until the power level associated with P-7 is reached. ACTION 6 also allows the tripped channel to be bypassed for up to 4 hours to perform surveillance testing on other channels. 1-50 ACTION [28] of the CTS duplicates CTS ACTION [6] and is Yes Yes No not in current No not in current A deleted. TS. TS. 1-51 This change moves the description of the P 7 input, i.e.. Yes Yes Yes Yes LG P-10 and P-13 to the Bases since they are duplicated by Functional Units [18.e and 18.f] a ists "1 per train" under the Required Channels col la -51 1 This change moves the_ specifics _ on how to verify permissive Yes Yes. Yes Yes 1 52 LG functions of ACTION %Mto the Bases. (tM. T. Leo f_\
'" * ~
is wit S . S-1 the_3 . <._ p _
- Io+ d582 -
ACTION Statement 5.b of Callaway's ckrent TS Table 3.3-1 No No No Yes 1-54 LS 37 is revised to change the 14 day recurfing verification of the closed status of the unborated wat source isolation valves to 31 days. NQe>3 hd.Tabk 4 S-5 dote.O3 WCGS-CONVERSION TABLE- CTS 3M.3 ' s- RTS a AGTton t2O3 % ESFAS ( .
1 I l l ADDITIONAL INFORMATION COVER SHEET ADDITIONAL INFORMATION NO: O 1-53 APPLICABILITY: DC, CP, WC, CA i ! REQUEST: Current TS Table 3.3-1 ACTION Statement [2.c] is revised to be consistent with i ITS SR 3.2.4.2, as discussed in CN 4-04-LS-12 in the 3/4.2 package. ) l I Comment: The note "* on CTS markup action 2.c is justified as changing the i completion time to be consistent with ITS SR 3.2.4.2. This change is categorized as an administrative change to the CTS. Approval of ITS SR 3.2.4.2 is pending staff approvel l l because it represents a less restrictive change to CTS 4.2.4.2. The staff concludes note "* is also less restrictive to CTS T3.3-1. Provide a revised DOC for this change. The note *" is also shown in the CTS markup to apply to Source Range shutdown modes. This note is not included in the BDPS LCO. Provide clarification of the intent of l the CTS markup. i FLOG RESPONSE: DOC 1-53-A has been withdrawn. See also the response to Comment Number O 3.3-120 and the attached pages for that response. For DCPP, the insertion of the *" note into CTS Table 3.3-1 was incorrect and has been deleted. The contents of the note were already included in revised ACTION 2. The second comment refers only to Callaway and was resolved during l meetings with NRC staff between September 15-18,1998, as discussed l in Reference 5. ATTACHED PAGES: l None ! l l l I l
ADDITIONAL INFORMATION COVER SHEET APPLICABILITY: WC, CA ADDITIONAL INFORMATION NO: O 2-02 (3.3) REQUEST: CTS ACTION b.1, Equation 2.2-1, and the values for Total Allowance (TA), Z, and Sensor Error (S) are deleted, consistent with NUREG-1431 Rev.1. Comment: This change was accepted at the 8/14/98 meeting. Explain the LG classification for deleting CTS requirements. The staff position is that this change is less restrictive because limits (required operator actions) contained in the CTS are deleted and now given elsewhere in licensee controlled documents. {CA, WC} The staff also notes this CN is a duplicate of CN 2-03 A for LSSS changes. Additional CN 2-03A comments are provided with that CN in this table. FLOG RESPONSE: New DOC 2-54-M has been written regarding elimination of ACTION b.1 in CTS 3.3.2. DOC 2-03-A in the 2.0 package has been revised to reference DOC 2-54-M in the 3.3 package. ATTACHED PAGES: Attachment 5, CTS 2.0 - ITS 2.0 Encl.3A 2 Attachment 9, CTS 3/4.3 - ITS 3.3 Encl. 2 3-13 Encl. 3A 22 Encl.3B 22 l
l l CHANGE NLABER HSHC DESCRIPTION the revision to 10CFR50.73, an LE" would no longer be required. Setpoint adjustments required by current ACTION b.1 for analog channels are perfomeo with the i affected_ channel removed from service. Equation 2.2 1 l effectively allows rack error to increase above its l nominal value by an amount dependent on the available setpoint margin: however, this margin is available for utilization at any time and is not restricted to whether the ACTION is entered. As such, current ACTION b.1 effectively provides no different recourse than current ACTION b.2. With a nonconservative as measured trip setpoint current practice is to enter ACTION b.2. Therefore, CTS ACTION b.1. Equation 2.2-1, and the values for TA, Z, and S can be deleted as they are no longer required. filu, Q:C. 2.-54-M {n. 3.s gg pz-ozes,j j 2 04 X Add on the ali signs, to K 1, .K,a K. ; si NUREG- 31 Rev . indi es the c rva e di for se K va p j
- s. {Also 1
/ ty si. ve added t ime cons
- nts (t values) th var le setti s to indi te the l l
k l - conserv ve dir ion for e blishi time s t j ! sett s. the i ality si to the ime ! Q tant va s is cons tent with G143.} ! 1 ! 2-05 A Not applicable to Wolf Creek. See Conversion Comparison l Table (Enclosure 38). l 2 06 LG The requirements stipulated in ACTIONS [a and b.2] are moved to ITS Table 3.3.1-1, with direction contained in i t the [ITS Background (Trip Setpoints and Allowable Values) ! Bases ACTIONS Bases, and SR 3.3.1.10 and SR 3.3.1.11 l l Bases). This change removes details more appropriately l controlled outside of the TS while retaining those aspects l necessary to assure the protection functions are performed if necessary.
- l. 2-07 A Not applicable to Wolf Creek. See Conversion Comparison Table (Enclosure 38).
-es A st applicaWla. 4 LWF Creek. Sam. (mar $4 (**Pm 3 % "TaMa. ( Endestvu. 3 S) . [cp n,oop .
. WCGS-Descripdon ofChanges to CTS 2.0 2 MM7 L _ , __ . . _ _ __ _ . -
INSTRUMENTATION I-@-A 3/4.3.2 ENGINEERED SAFETY FEATURES ACTUATION SYSTEM INSTRUMENTATION LIMITING CONDIT10N FOR OPERATION - QI4GEul
. 3.3.2 The Engineered Safety Features Actuation System (ESFAS) instrumentation ' 241-A l (ifor each _r_. function?--- .
*:t shown in Table 3.3-3 shall be OPERABLE W3-LG ..
_ e _ . _,. h'_ .t
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APPLICABILITY: .^: f.::7 h According to able 3.3-3. L ACTION:'
'I141-A
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_ J A _ _ _ _ , n.._n...._a______-.__>*.et...r.:_,_._.____-.___sr._.___m.....-r...L.._ _ - s. 7 _ _,_., . _ M _a _ J _ t _ _ , e - E ir 6: " .: -- :r:'" x!= 'h pr:r :;---) :fi: x== i -
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l c. With an ESFAS instrumentation channel or interlock inoperable, take the l I ACTION shown in Table 3.3-3. i 1-01-A (
- Separate Condition entry is allowed for each Functg
,1 WOLF CREEK- UNIT 1 3M 3-13 Amendment No. 34,93 Mark-up ofCTS3M. 3 S/lSM l' i
.-- - n .- , _-- . . - - - . . . , ..,
k CHANGE NthBER HSE DESCRIPTION Channels" column. With separate Condition entry per pump. ITS 3.3.2 Condition J would allow one inoperable . channel per pump as long as it is tfipped within 1 hour. This would allow a second channel on the other , pump to be inoperable for up to 1 hour prior to the l comencement of any additional action, i.e. either ; placing the second channel in trip which may or may not result in an auxiliary feedwater actuation signal (AFAS) for the motor driven auxiliary feedwater pumps j or reducing power. Placing the second channel on the other pump in trip will result in an AFAS only if the , second channel is in the same separation group as the I channel already in trip (as depicted in USAR Figure 1 7.3 1 sheet 2). If the two channels are in different separation groups, no AFAS will be initiated and continued operation will be permitted. 2 47 M Not applicable to Wolf Creek. See Conversion Comparison Table (Enclosure 3B). I 2-48 LS-28 Not applicable to Wolf Creek. See Conversion Comparison Table (Enclosure 3B). 3-01 A The requirements of this current TS [3.3.3. Table 3.3-6] are moved to separate specifications in the improved TS. The RCS Leakage Detection requirements are moved to improved TS 3.4.15. [The Fuel Building requirements are moved to improved 4TS 3.3.8.] The Control Room requirements are moved to improved TS 3.3.7. [The Containment Atmosphere requirements are moved to ITS 3.3.6.] o s-o2. ] 3 02 M h equir nts pulated ~ ACTION are mo dt ITS Ta [3. 1 and 3 . 1], wi explic' dir ion tained i he ITS IONS B
- s. / e4 ur A0T or set adjus nt is eli insted.
w WS 3A-3 03 LG The requirements associated with the criticality monitors are moved to a licensee controlled document. These monitors are required by 10CFR70.24: however. there is no requirement for [them] to be in the Technical Specifications [nor do they meet any of the four criteria for inclusion in the ITS). Since Part 70 is invoked in the Operating License, these monitors will be retained in the plant design. (osecr 3A QM] 3 04 M Not applicable to Wolf Creek. See Conversion Comparison Table (Enclosure 3B). WCGS-Description ofchanges to CTS 3M.3 22 S/15/97
i INSERT 3A-22a 0 3-02 CTS 3.3.3.1, Action [a] is revised to delete the 4 hour allowance to adjust the ; radiation monitoring channel Alarm / Trip Setpoint if the setpoint value has been exceeded. The CTS allowed a 4 hour window in which to adjust the Trip Setpoint to within limits before declaring the channel inoperable and taking the appropriate Action specified in the Table. NUREG-1431 requires declaring the channel inoperable immediately and entering the appropriate Condition if the Trip
' Setpoint is less conservative than the tolerance specified in calibration l procedures. The proposed change is considered a more restrictive change which l reduces plant operational flexibility.
i 1 l l l i i I s i
INSERT 3A-22b 2-49 A Not used. ' [ou43 } 2-50 LG The CTS [##] not to Table [3.3-3] is revised to move the descriptive material related to the automatic blocking of the interlock to the ITS 3.3.2 Bases. Moving these details does not affect the Applicability or the Operability of the Function which will continue to protect the health and safety of the public. loa 3 MJ 2-51 LG Not applicable to Wolf Creek. See Conversion Comparison Table (Enclosure 3B). , Not applicable to Wolf Creek. See Conversion Comparison Table lG33-6 \ 2-52 A (Enclosure 3B). Not applicable to Wolf Creek. See Conversion Comparison TabljQ33-261 I 2-53 LG (Enclosure 3B). lo2-o2.(s.d 2-54 M Although DOC 2-02-A characterizes the deletion of ACTION b.2 from LC0 ) 3.3.2 as administrative since the change is consistent with current j plant practice since the trip setpoint adjustment is done for a majority of analog channels with the channel in trip and therefore ] declared inoperable (i.e. no different in effect than entering i ACTION b.2), there could be scenarios where ACTION b.1 would present another alternative. For instance. since containment pressure High-3 l has an installed bypass design feature. ACTION b.1 could allow trip setpoint adjustments in bypass. This would eliminate logging requirements for equipment out of service. Since this change is eliminating ACTION b.1 as an allowed recourse, this is a n: ore restrictive change. {Q2.4160N 2-55 M Not applicable to Wolf Creek. See Conversion Comparison Table (Enclosure 3B). lc?2.-ce(3.3[ l 2-56 LS-48 Not applicable to Wolf Creek. See Conversion Comparison Table (Enclosure 3B). [os.w2. { 2-57 A Current TS Table 3.3-3 Functional Unit 3.c.2), Containment brge Isolation Automatic Actuation Logic and Actuation Relays (SSPS) and Functional Unit 9.b. Control Room Isolation - Automatic Actuation l Logic and Actuation Relays (SSPS). and associated surveillance requirements are deleted. The change is acceptable since the purpose of SSPS for the associated Functions 3.c.2) and 9.b is to generate a l Containment Phase A isolation signal which is redundant to CTS Table 3.3-3, Functional Unit 3.c.4) and 9.d. The BOP-ESFAS processes signals from the SSPS, signal processing equipment, to actuate ; certain ESF equipment. A Containment Phase A Isolation signal (CIS-A) is generated within the SSPS and provides an output signal to the BOP-ESFAS as an actuating input for initiating a Containment Purge ' Isolation Signal (CPIS) and Control Room Ventilation Isolation Signal . 1
l I ! INSERT 3A-22b (continued) [ois.nl . (CRVIS). Anv combination of f ailures which could degrade or prevent ! the CIS-A from reaching the BOP-ESFAS would require entry into CTS l Table 3.3-3, Functional Unit 3.a.2), Action Statement 14. Action j Statement 14, as revised by DOC 2.23-A, requires restoring an L inoperable channel to OPERABLE status within 6 hours or place the j plant in MODE 3 within 12 hours and MODE 5 in 42 hours. Action l Statement 14 is revised to require that with Function 3.a.2) inoperable, immediately take the ACTIONS of Specification 3.6.3. Taking the Actions in Specification 3.6.3 is consistent with CTS Action Statement 17, as revised by DOC 2-05-M, to maintain the , containment purge supply and exhaust valves closed. Action Statement 26 for Functional Unit 9.b requires restoring the inoperable channel l to OPERABLE status within 7 days (as revised from 48 hours per DOC 2- r 16-LS-12) or initiate and maintain operation of the CREVS. Deletion of Function 9.b and associated Action Statement is acceptable due to l the shorter re:toration time of Action Statement 14. The proposed change is considered administrative since the change only clarifies / reformats an existing requirement and does not affect any operating limits or how the plant is operated. -
%ss m\ .
2-58-A Amendment No. 117 dated May 28, 1998, added a new Action Statement to l CTS 3/4.3.2, Table 3.3-3, Functional Unit 7.b., Refueling Water ! ! Storage Tank Level (RWST) - Low Low Coincident with Safety Injection.
- New Action Statement 30 replaces Action IS, and would be entered for ,
an inoperable RWST analog channel, allows for 6 hours to place an inoperable RWST analog channel in a bypassed condition and allows for surveillance testing of an additional channel of Functional Unit 7.b. ; ! by placing the channel in a tri' pped condition for up to 4 hours. ; This change is considered administrative since it adds a new Action , Statement previously approved by the NRC. ; \ l 1 , 3 i l' l I l i
+
i i ! i
L ! h p - i INSERT 3A-22c- 0 3-03 :
- t
[For WCGS and Callaway. Section 9.1 of the USAR/FSAR indicates that' the' design of L the spent. fuel storage racks, new fuel storage racks, the fuel handling ! l- equipment, and the administrative controls are such that subtriticality will be , l maintained under normal and accident conditions.) As such, the requirements ; j associated with the criticality functional unit is not required to. be in the TS l to provide adequate protection of the public health and safety. The licensee l 1 controlled documents containing the moved requirements will be maintained using i the provisions of 10 CFR 50.59. Therefore. the descriptive information that has been moved continues to be maintained in an appropriately controlled manner." i i ! I l + l : t I ! i i i h i h 1 I (' l-l , i. 1 i i l-t i 3 - l
- i b
t _ CONVERSION COMPARISON TABLE - CURRENT TS 3/4.3 rege 22 or30 TECil SPEC CllANGE AFFLICAOILITY NUMRFR DESCRII"ilON DIABLO CANYON COMANCllE FEAK WOLF CREEK CALLAWAY 2 48 LS-28
/b .2 a tion.615 .6 t 7
a and allow he af cted E gent ied t ti Uni s iesel yek @ fNoye IN T-32 M @ Jkf - @ 2 8 18.21
- M/A L&O1
) -
2ener or be . ared i rab and r res try nto
--- I l S ifi ion .1.1 n more han elay r p -
ble, urrent . tion of DCP di not $ffess
- ( t_ above ituatio_ and r ires en y intosCO .0.3. M M-3 01 The requirements of this specification [ CTS 3.3.3. Table Yes Yes Yes Yes A 3.3 6] are moved to separate specifications in the improved TS. The RCS Leakage Detection requirements are moved to i groved TS 3.4.15. [The Fuel Building requirements are moved to i groved TS 3.3.8]. The Control Room requirements are moved to improved TS 3.3.7. [The Containment Atmosphere requirements are moved to ITS 3.?.6].
3 02 The requirements stipulated in ACTION [a] are moved to ITS fes Yes Yes Yes M Table'[3.3.7-1 and 3.3.8-1]. with explicit direction , e contained in the ITS ACTIONS Bases. The 4 hour A0T for setpoint adjustment is eliminated. 3 03 The requirements associated with the criticality monitors Yes - moved to No - not in current Yes - moved to USAR Yes moved to FSAR LG are moved to a licensee controlled document. These F3AR. TS. Section 16.3. Section 16.3. monitors are required by 10CFR70.24: however, there is no requirement for [them] to be in the Technical Specifications. [nor do they meet arly of the four criteria for inclusion in the ITS). 3-04 This change adds the Applicability for movement of Yes Yes No - see Yes M irradiated fuel assemblies. The current TS Applicability CN 3-12 A of "All" MODES does not cover movement of irradiated fuel assemblies when the core is off-loaded. 3-05 ACTION Statement [27] for the [ Control Room Air Intake) Yes Yes Yes Yes LS-14 [and ACTION Statement (30] for the [ Fuel Building Exhaust] radiation monitors have extended completion times, from [72 hours] to 7 days for one required channel inoperable. WCGS-CONl'ERSION TABLE- CTS 3H.3 5/15/97
( y i INSERT 3B-22 TECH SPEC CHANGE APPLICABILITY r WOLF CREEK CALLAWAY ! DIABLO CANYON COMMANCHE PEAK NUMBER DESCRIPTION N/A N/A N/A N/A 2-49 Not Used Yes Yes Yes Yes 2-50 The CTS [##] not to Table [3.3*3] is LG revised to move the descriptive material lypjt3 63 ) related to the automatic blocking of the interlock to the ITS 3.3.2 Bases. Yes No No No gg g3,79 g 2-51 The channel identifiers RM-44A and B are LG moved to the ITS Bases for ITS 3.3.6 No Note (e) to CPSES CTS Table 3.3-2, applied No Yes No , 2-52 to the Turbine Trip and Feedwater Isolation (h?3.3 -65F] ; A Functional Unit 5.b, is reflected in ITS Tabl 3.3.2-1 Functional Unit 5.b., footnote l (p). Yes No 2-53 In this Callaway-specific change, the tie No No {qJL3.:ts j ; LG breaker closure discussion in ACTION 19 of CTS Table 3.3-3 is moved to the Bases for e
~
ITS 3.5.5 Condition B as one example of -- multiple channels inoperable on one bus. t No - not in No - not in Yes Yes 2-54 Deletion of ACTION b.1 eliminates one ' M possible recourse for an Allowable Value CTS. CTS. [GP2 o2.C33)) not met. Yes No No i 2-55 Note (c) to current TS Table 3.3-2 for the No M Steam Line Isolation Functional Units l42-o7(310} 4.a.2. 4.b. 4.c. 4.d. and 4.e is revised to state that the LCO requirements are not ( applicable in MODES 2 and 3 when the MSIVs , are closed and deactivated. No Yes No No 2-56 DCPP CTS ACTION Statement 35 is revised to LS-48 require MODE 2 entry and to delete the \q2.-ceb(13)} requirement to enter LCO 3.0.3 which requires the unit to be placed in MODE 3 as a minimum. d n _ - - . - _ . _ _ _ . . . . _ . _ _ - - . _ _ - . _ _ _ _ - _ - - - _ - - - _ - _ . _ _ _ _ _ - -_ . _ _ - - . _ _ - - - - - . - . . . - - - - - - . _ _ . ---....-,-.-,-----,c.-.,-_...,n~,---.n . .,n.
,-n _.- . . . - . _ . , __ __
i INSERT 3B-22b (continued) No - not in No - not in Yes Yes-2-57 Current TS Table 3.3-3 Functional Unit A 3.c.2), Containment Purge Isolation CTS CTS g3,4 , Automatic Actuation Logic and Actuation
'lt Relays (SSPS) and Functional Unit 9.b.
Control Room Isolation - Automatic Actuation Logic and Actuation Relays t (SSPS), and associated surveillance requirements are deleted. Yes WCGS Amendment No. 117 dated May 28, 1998 No No Yes .} 2-58 [sel3-ato j f A added a new Action Statement to CTS 3/4.3.2. Table 3.3-3, Functional Unit 7.b., Refueling Water Storage Tank Level (RWST) - Low-Low Coincident with Safety Injection. t t
\
* . I f
i t 1
?
~\
i
?
P i t r
. _ . _ _ _ _ _ _ _ _ _ _ _ _ _ _ _ _ . _ _ _ _ _ _ _ _ _ _ _ _ _ _ _ _ _ _ _ _ . _ _ _ _ _ _ _ _ . _ _ _ _ _ _ _ _ _ _ _ _ _ _ _ _ _ _ ~ _ _ _ _ _ _ _ , ~ . . , _ _ _ _ , - . . . _ _ . _ _ . . . _ . . . _ , . _ - _ . . _ _ _ _ _ _ _ , . , _ . _ _ _ _ _ _ , . . _ . . . _ - _ . _ _ . _ .
ADDITIONAL INFORMATION COVER SHEET ADDITIONAL INFORMATION NO: O 2-09 APPLICABILITY: WC REQUEST: Separate ESFAS entries for the motor-driven and turbine-driven auxiliary feedwater pumps are no longer necessary. The only difference in the requirements (an SR 4.0.4 exception for response time testing of the turbine-driven auxiliary feedwater pump) has been addressed in the ITS by a Note in Surveillance Requirement 3.3.2.10. [lTS Table 3.3.2-1 , has eliminated the unnecessary repetition in CTS Tables 3.3-3 and 3.3-4.] l Comment: {WC} This CN is not shown in all applicable changes to CTS Table 3.3-4 f markup for AFW. Correct the submittal. l FLOG RESPONSE: CTS Table 3.3-4, Functional Unit 6, has been modified to correctly identify the use of DOC 2-09-LG. , i ATTACHED PAGES: Encl. 2 3-25, 3-26 l l I l l t t
TABLE 3.3-4 (Continued) ENGINEERED SAFETY FEATURES ACTUATION SYSTEM INSTRUMENTATION TRIP SETPOINTS TOTAL SENSOR Trip ALLOWABLE 01-A FUNCTIONAL UNIT ALLOWANCEyTA) [ ERROR-46) SETPOINT VALUE 2MA
- 5. Turbine Trip and 2-03-LO Feedwater Isolation ,
- a. Automatic Actuation Logic and Actuation Relays (SSPS) N-A. N-A NA NA- N.A.
- b. Steam Generator Water Level-High-High 6-0 3r48 3-64 ;?9% M < 79.7% of nemwnenge narrow range inetnament instrument open span
- c. Safety injection See item 1. above for all Safety injechon Trip Setpomis and Allowable Values.
- 6. Auxiliary Feedwater , N"**
( c _"." ..y ' : " g NA Sub[ N A, N-A. N-A, 14 ~2.-31 ]
- b. Automatic Actuation Logic and Actuation Relays (SSPS) NA N-A. NA N-Ae N.A.
- c. Automatic Actuation Logic and Actuation Relays (BOP ESFAS) N-A, N-A. NA NA N.A.
- d. S!eam Generator Water Level-Low-Low
'~
D 236 34,48 3-64 2 23.5% d 222.3% of _ penew4enge nanow range metnament instrument open span H OLF CREEK- UNIT I 3/4 3-25 Amendment No. MarA-up ofCTS3/4. 3 5/l5/97
TABLE 3.3-4 (Continued) ENGINEERED SAFETY FEATURES ACTUATION SYSTEM INSTRUMENTATION TRIP SETPOINTS 01-A TOTAL SENSOR TR4R ALLOWABLE 2-02-A 3 FUNCTIONAL UNIT AL40WANGE-fTA) E ERROR 46) ESWT VALUE 2-03-LG
- 6. Aux eedwater (Continaed)
?_ @ -LG-i 23-6 24,48 2-64 6 > 22.3% of _-.
nosvow+enge narrow range @ 2-01\ inskwnent instrument open span
- e. Safety injection -
Start Motor- ; Driven Pumps See item 1. above for all Safety Injection Trip Setpoints and Allowable Values.
- f. Loss-of-Offsite Power-Start Turbine-Driven Pump N-A. NA. N-A. N A. N.A.
- g. Trip of All Main Feed-water Pumps - Start Motor-Driven Pumps NA NA MA. N-A. N.A.
- h. Auxiliary Feedwater Pump Suction Pressure.
Low (Transfer to ESW) NA N-A. N-A. 12t"^ p';; 3 20.53 psig
- 7. Automatic Switchover to Containment Sump
- a. Automatic Actuation Logic and Actuation Relays (SSPS) N-A- N-A. NA N-A. N.A.
- b. RWST Level-Low-Low 34 4-24 4-86 , 6, 3 35.1% of ,
inetmanent instrument open span Coincident with Safety injection See item 1. above for Safety injection Trip Setpoints and Allowable Values. N OLF CREEK- UNITI JM 3-26 Amendment No. MarA-up of CTS 3M. 3 5/lSM7
ADDITIONAL INFORMATION COVER SHEET ADDITIONAL INFORMATION NO: O 2-11 APPLICABILITY: CP, WC REQUEST: The Functional Unit for Loss of Power [ CTS 8.a,8.b) is moved to improved TS 3.3.5. Comment: {CP} The CTS LOP instrument titles were dropped in the iTS and this ! change was neither identified nor evaluated. Show that CTS requirements are not ! i changed as a result of using new LOP Function terminology in ITS SR 3.3.5.3 : {WC} T3.3-4 (F8.a,8.b) trip setpoints are incorrectly deleted in the CTS markup and the inequalitiies are deleted in the ITS. The CTS applicability is expanded to adopt the iSTS. i This change is neither markedup or evaluated in the CTS. Provide revised CTS and ITS. FLOG RESPONSE: For CPSES, DOC 2-11-A remains correct. The function titles have been corrected in the ITS (see the response to Comment Number Q 3.3-131). For WCGS, Functional Units 8.a. and 8.b., trip setpoints were incorrectly deleted in the CTS markup. The CTS markup has been modified to show the setpoints as retained. ITS SR 3.3.5.3 has been modified to reflect the , inequalities. (Note that this paragraph was revised subsequent to the l CPSES Section 3.3 response to the Request for Additional Information being submitted to the NRC and the changes only affect Wolf Creek.) l l ATTACHED PAGES: l Encl. 2 3-27 Encl.5A 3.3-56 Encl. 5B B 3.3-166 l l 4
TABLE 3 3-4 (Continued) ENGINEERED SAFETY FEATURES ACTUATION SYSTEM INSTRUMENTATION TRIP SETPOINTS 2-01-A TOTAL SENSOR Trip ALLOWABLE 2-02-A FUNCTIONAL UNIT ."LLOV'^NCE iTA) 3 EP9T iS! SETPOINT VALUE 2 03-LG
- 8. Loss of Power {Q 2-Il }
een strikdop
- a. 4 kV Undervoltage
-Loss of Voltage NA N-A. NA j 2 S3V (120V > 74.7V (120V Bus) 2-1 l-A j Buo).wA4e w/1 + 0.2, -0.5s delay .
f delay
- b. 4 kV Undetvoitage
-Grid Degraded i Voltage NA NA NA - 159V > 104.3V (120V Bus)
(1"! Sr) w/119 + 11.6s delay M115 fl_,, -
- 9. Control Room isolation
- c. ManualInitiation NA NA NA NA N.A
~
- b. oma ' Actu N- m og dA ation lh 3,3 32,}
t
- c. Automatic Actuation Logic and Actuation Relays (BOP ESFAS) NA NA N-A- NA N.A. L
- d. Phase "A" Isolation See item 3.a. above for all Phase "A" Isolation Trip Setpoints and Allowable Values.
- 10. Solid-State Load Sequencer NA NA NA NA N.A. 2-13-A-
- 11. Engineered Safety Features Actuation System Interlocks
- a. Pressurizer Pressure, t P-11 NA NA NA ; 1970 M < 1979 psig
- b. Reactor Trip, P-4 N-A- NA NA N-A N.A. ,
WOLF CREEK- UNIT I 3M 3-27 Amendment No. M:rA-up of CTS 3M. 3 $/15/97 ________-___m __. _ _ - . _ _ - _ - _ _ _ _ _ _ _____ _ - - _ - _ _4+_ _ - _ a ___1 :sr _ i -*J ^ _- +m +=e= =*w
- T*- '
t , LOP DG Start Instrumentation j 3.3.5 SURVEILLANCE REQUIREMENTS (continued) SURVEILLANCE FREQUENCY SR 3.3.5.3 Perform CHANNEL CALIBRATION with ;ctpcint 18 months LB PSC Allowdic " slue Trip Setpoint and Allowable Value as follows:
- a. Loss of voltage Allowable Value 274.7V, 120V bus with a time delay of 1.0 + 0.2, 0.5 sec.
2 [Q 2-u j Loss of. voltage Trip Setpoint 83V,120V bus with a time delay of 1.0 sec. .
- b. Degraded voltage Allowable Value 2 104.3V,120V bus with a time delay of 119 t 11.6 gec.
.. ~
IQ 2-Il \ Degraded voltage Trip Setpoint 106.9V. 120VbuswithAtime_ delay.of 119.sec. __, ~ l x 3.3. 3.4 ve4 toe os s+,a ese easeouss vir4es m a i,ww. .gue m um. is _% .- stm a c e w t I M 6tb
~ -
[Q 3.3-5G } l l l l l WCGS-Mark-up ofNUREG-1431 - ITS 3.3 3.3-56 S/15/97 l
LOP DG Start Instrumentation B 3.3.5 l l BASES SURVEILLANCE SR 3.3.5.3 (continued) REQUIREMENTS reA u e. 6 m M % 3 3 G M The Frequency of 8 months is based on operating experience and consistency with t typical industr refueling cycle and is justified by the asstaption of an nth calibration interval in the determination of the magnit of equipment drift in the setpoint analysis. qA\me. (dmMcA)lg3,3,q.gl REFERENCES 1. RISAR, Section 8.3.
- 2. RISAR, Chapter 15. O-iq 2-tt 1 3
- 3. Unit Sp,;;ific RTS/ESTET ~~
- Ana t ogy _ f. [ ~ _
l
&k 0 2.s.ss
,sR 3.s.s.4 i;; he ph-mme.a. 4 he regaded. repenw
+iec vaikchen eveg 16 months on a ser4 ease.a.o rmwr i B Asis . Res gom' Time. VeriC ca6n acqmu cri+cri> are:
t>4 tTe ATnh3(r SL(.r14AL Ap4D 8:uucTnoy R@uMTa% l Lossof Puce l o. 4ky Bus undervolby - At4 sa.canas W ef Vattge- I
- b. 4kg Eas. tindervelby-- (,IM sceends GrtA DagsacA hthy l l
Eachverifiohen 561l Madc. al lent encirAn 4ach 4kt be& fras'ns are veriEed At least ont per % menb.
~ _
l l l l WCGS-Mark-up ofNUREG-H31-Bases 3.3 B 3.3-166 5/15/97 l l
ADDITIONAL INFORMATION COVER SHEET ADDITIONAL INFORMATION NO: O 2-12 APPLICABILITY: CP, WC, CA REQUEST: This Functional Unit [ CTS 9.a-9.d) is moved to improved TS 3.3.7. The Applicable MODES have been expanded to include movement of irradiated fuel assemblies to cover fuel handling accidents. Comment: Previous CTS changes resulting in requirements moved to other specs in the ITS format the change is noted as administrative. What is different about this change that it is more restrictive? FLOG RESPONSE: As stated in DOC 2-12-M, the APPLICABLE MODES are extended from MODES 1-6 to MODES 1-6 and during the movement of irradiated fuel. , in accordance with the CTS applicability, movement of irradiated fuel when the core was off-loaded (i.e, not in any define MODE), would not be covered by this specification. Because the additional applicability, beyond that required by CTS, is being adopted, this change is considered to be more restrictive. ATTACHED PAGES: , l Encl.3A 17 i i
l CHANGE NUMBER 82iG DESCRfPTION 2 12 H This Functional Unit [ current TS 9] is moved to improved TS 3.3.7. Consistent with NUREG 1431 Rev.1. the Applicable MODES have been expanded to include movement of irradiated fuel assemblies to cover fuel handling accidents. Quse8.T 3A-g-[w 2.-i?-] 2 13 A This Functional Unit [ CTS 10] is moved to ITS 3.8.1 consistent with NUREG 1431 Rev.1. 2 14 H This change modifies ACTION Statement [20] for permissive P 11 [] to provide specific shutdown requirements to exit Applicability in lieu of applying l LC0 3.0.3. This change is more restrictive by one hour, consistent with NUREG 1431 Rev.1. 2 15 H Cd20 Action Statement [16] has been expanded to specify lWc.1Lo103 additional actions and options if an inoperable channel cannot be placed in bypass within the specified time period. In the current TS, this would have required an entry into LCO 3.0.3, which would necessitate that the plant initiate a shutdown within 1 hour and be in the MODE 3 in the next 6 hours. In the ITS. the requirements to place the inoperable channel in bypass within a time constraint and the reduction, by 1 hour. in the time to exit the Applicability are more __ restrictive than the current TS. L 3 QT Q 1-IN 2-16 LS 12 ACTION Statement [26] for a channel inoperable in the i I current TS Table [3.3 3], Function [9] is modified to be consistent with NUREG 1431 Rev. 1 (i.e., a 7 day A0T in ITS 3.3.7). 2 17 LS 13 Not applicable to Wolf Creek. See Conversion Comparison Table (Enclosure 3B). l 2 18 LS 31 Current TS Table 3.3 3 ACTION Statement 19 is revised to reflect ITS 3.3.5 for the Loss of Power Functional GacssteA loaa skcMu-I j NL emenjeg lona sapee Relaxation is obtained for multiple inoperable channels
,(LsELS) be immedOte.L3 decked on one bus in MODES 14. This situation currently j iheperable . % Regd requires entry into LCO 3.0.3 since it is beyond the scope of ACTION Statement 19.
Adia A LT5 3 eb \ h*5 a 12. s,,s cnq2xHk'The % nsk F r multiple inoperable channels on one bus, the new [ 6 -16 3 k t.sa s, % cmmat.E *Am.) i ~ ACTION Statement would direct thaj /a'5JA$utj ne cyann
! (perJufictiopflosfsv)o (agp4nd/oVdegraded voltag ),
2 4 De'restop(d in K hogPf.fFor multiple inoperable channels on two buses, the new ACTION Statement would require restoration of all but one channel per Function i WCGS-Description ofchanges to CTS 3H.3 17 S/15 M 7
INSERT 3A-17a 0 2-15 i In practice, because a time for completion of an action is not specified, no rigorous completion time is applied; the action is completed in an unspecified, " reasonable" time frame. For the functions where a completion time is not specified, the operability of the channel has no safety significance. The required number of channels remain sufficient to initiate the required protective action. even if a single failure is considered, regardless of the state of the one inoperable channel . Because a specific time would be required by the ITS, this change is considered to be more restrictive. 1 1 INSERT 3A-17b 0 2-12 Because the additional applicability, beyond that required by CTS is being l adopted this change is considered to be more restrictive. j i I 1 4
. - _ - - __- - . - ~ _. _ _ _ _ _ _ _ _ _ _ . _ _ _ _ _ . .. __
ADDITIONAL INFORMATION COVER SHEET ADDITIONAL INFORMATION NO: Q 2-15 APPLICABILITY: DC, CP, WC, CA REQUEST: Action Statement (16) has been expanded to specify additional actions and options if an inoperable channel is not placed in bypass within the specified time period. In the ITS, the requirements to place the inoperable channelin bypass within a time constraint and the reduction, by 1 hour, in the time to exit Applicability are more restrictive than the current TS. [] Comment: The completion time for bypass of an inoperable containment high-high pressure signal (Functions 2.c and 3.b.3 - Action 17 and Function 4.c - Action 17.1) is changes from unspecified (immediate) to within 6 hours. Justification is not provided for the new completion time. This also appears to be a less restrictive, not a more restrictive change. The completion time for bypass of an inoperable channel in action 16 is changed from i unspecified (immediate?) to 6 hours. Justification is not provided for the new time. This also appears to be a less restrictive, not a more restrictive change. : FLOG RESPONSE: Items 1 and 2. In practice, because a time for completion of an action is not specified, no rigorous completion time is applied; the action is completed in an unspecified, " reasonable" time frame. For the functions where a completion time is not specified, the operability of the channel has i no safety significance. The required number of channels remain sufficient to initiate the required protective action, even if a single failure is considered, regardless of the state of the one inoperable channel. Because a specific time would be required by the ITS, this change is considered to be more restrictive. DOC 2-15-M will be enhanced to reflect this discussion. ATTACHED PAGES: Encl. 3A 17 l l l
' CHANGE
!MBf3 82iG DESCRIPTTON 2 12 H This Tuactional Unit [ current TS 9] is moved to improved TS 3.3.7. Consistent with NUREG 1431 Rev. 1.
the Applicable MODES have been expanded to include movement of irradiated fuel assemblies to cover fuel handling accidents. QMAT 3A - t lb)--[w z-i2-] 2 13 A This Functional Unit [ CTS 10] is moved to ITS 3.8.1 consistent with NUREG 1431 Rev.1. l 2 14 H This change modifies ACTION Statement [20] for permissive P 11 [] to provide specific shutdown requirements to exit Applicability in lieu of applying LCO 3.0.3. This change is more restrictive by one hour, consistent with NUREG - 1431. Rev.1. 2 15 H CTD Action Statement [16] has been expandeo to specify Nc1 Lot 63 additional actions and options if an inoperable channel cannot be placed in bypass within the specified time period. In the current TS, this would have required an entry into LC0 3.0.3, which would necessitate that the plant initiate a shutdown within 1 hour and be in the MODE 3 in the next 6 hours. In the ITS the requirements to place the inoperable channel in bypass within a time constraint and the reduction, by 1 hour, in the time to exit the Applicability are more __ restrictive than the current TS. L 3 {sRT 3A-rj14.c 2.-tE l l 2 16 LS 12 ACTION Statement [26] for a channel inoperable in the current TS Table [3.3 3) Function [9] is modified to l be consistent with NUREG 1431 Rev.1 (i.e., a 7 day A0T in ITS 3.3.7). 2 17 LS 13 Not applicable to Wolf Creek. See Conversion Comparison Table (Enclosure 3B). 2 18 LS 31 Current TS Table 3.3 3 ACTION Statement 19 is revised to reflect ITS 3.3.5 for the Loss of Power Functional Gecssted th: header j.wL emen$e-3 load sapee Relaxation is obtained for multiple inoperable channels
, (t.5El 5) be immedMeg dahed on one bus in MODES 14. This situation currently i dnoperalAe-. % % d requires entry into LC0 3.0.3 since it is beyond the scope of ACTION Statement 19.
4dik A tTs .3.e.1 ha a 12. ' w wgtuuk'T4c % res%c g ggg g) For multiple inoperable channels on one bus, the new_ [GE-lol g ~ ACTION Statement would direct tha J /ai) A5utj ne cpann (per vo agp 1ind/oydegraded voftag ) 4 ,D e'Jufictio osfs c 4 rest d in X ho .fTor multiple inoperable Channels on two buses, the new ACTION Statement would l require restoration of all but one channel per Function WCGS-Description ofchanges to CTS 3M.3 17 S/15/97
INSERT 3A-17a 0 2-15 In practice, because a time for completion of an action is not specified, no rigorous completion time is applied; the action is completed in an unspecified,
" reasonable" time frame. For the functions where a completion time is not specified, the operability of the channel has no safety significance. The ]
required number of channels remain sufficient to initiate the required protective action, even if a single f ailure is considered, regardless of the state of the one inoperable channel. Because a specific time would be required by the ITS, this change is considered to be more restrictive. INSERT 3A-17b 0 2-12 Because the additional applicability, beyond that required by CTS, is being l adopted, this change is considered to be more restrictive. I l l
ADDITIONAL INFORMATION COVER SHEET ADDITIONAL INFORMATION NO: O 2-16 APPLICABILITY: CP, WC, CA REQUEST: ACTION Statement [26] for an inoperable channel in the current TS Table [3.3-3] Functional Unit [9.a-9.c] is modified to be consistent with NUREG-1431, Rev.1 (7 day AOT in ITS 3.3.7). Comment: Insufficient information is provided to justify extending the allowed outage time for one CRVS channel inoperable from [1 hour) [48 hours] to 7 days. If the system arrangement is such that each instrument channel is dedicated to a single CRVS train (one-out-of-one starts one train), then the effect of a single inoperable instrument channel is similar to that of an inoperable mechanical train and the extended AOT may be acceptable. If, however, the two channels are used in a one-out-of-two logic start both CRVS channels, a single inoperable instrumentation channel degrades the operability of bM. .Techanical trains and the justification provided for the 7 day AOT is not germane. {WC} CTS Action 26 provisions of 3.0.4 not applicable are deleted without evaluation. Provide a jusfication for this change. FLOG RESPONSE: The premise behind the NRC comment is that the 7-day AOT is acceptable for a design where the cross-train feed aspect is not present. The FLOG plants disagree since this design feature increases isolation function availability. Given one inoperable radiation monitor channel for a design without a cross-train feed, the associated isolation logic train is inoperable. Given one inoperable radiation monitor channel for the FLOG design with a cross-train feed, both isolation logic trains remain functional since the OPERABLE radiation monitor channel will provide inputs to both isolation logic trains. However, the isolation logic train powered by the same train as the inoperable radiation monitor channel will be declared inoperahie. The isolation logic train powered by the same train as the l OPERABLE radiation monitor channel will remain OPERABLE, meeting l the same safety system status as provided by a design without a cross-l train feed. Since the FLOG design is superior to a design without a cross-train feed, the 7-day AOT is justified. PLANT-SPECIFIC DISCUSSION The Control Room Ventilation isolation design is depicted on USAR Figure 7.3-1 sheet 2. Radiation monitor GKRE0004 is powered from separation group 4. It provides an input to that separation group's isolation logic train, as well as providing an isolated input to the opposite train's (separation group 1) isolation logic. The same cross-train logic input design applies to radiation monitor GKRE0005, which is powered from separation group 1. 4 For the Wolf Creek specific comment regarding CTS Action 26, an
- equivalent comment was made in comment number Q 2-26 LS-21. The comment was resolved in the September 15-18,1998 meeting as documented in Reference 5.
I
1 ATTACHED PAGES: None i i I l l 1 l 4 J i l
ADDITIONAL INFORMATION COVER SHEET ADDITIONAL INFORMATION NO: Q 2-18 APPLICABILITY: WC, CA REQUEST: Current TS Table 3.3-3 ACTION Statement 19 is revised to reflect ITS 3.3.5 for the Loss of Power Functional Unit. Comment: [OOS)- Reject. Proposed change extends CTS AOTs for inoperable channels. AOT extensions not consistent with ISTS are OOS. Adopt ISTS for loss of redundancy and loss of function for inoperable LOP actuation channels or translate CTS requirements into ITS format. ! [OOS]- Reject. Proposed change extends CTS AOTs for 2,3, and 4 inoperable ' channels to 12 hours. The CTS AOT changes are not evaluated. AOT extensions not l consistent with ISTS loss of redundancy and loss of function actions and CTS are OOS. i Adopt ISTS for loss of redundancy and loss of function for inoperable LOP actuation channels or translate CTS requirements into ITS format. The NSHC discussion on entry into LCO 3.0.3 specifies this change "does involve any relaxation in the allowed outage time currently required by LCO 3.0.3." Please clarify this statement. The staff notes that the NUREG gives a one hour repair AOT for loss of i function conditions which is allowed based on the one hour in LCO 3.0.3 given that the ; LCO includes a LCO 3.0.3 equivalent shutdown requirement. FLOG RESPONSE: The last comment under Comment Number O 1-18 is also applicable to I this DOC. As discussed during meetings with NRC staff on September 15 and 16, 1998, ITS 3.3.5 Required Action B.1 has been revised in response to Comment Number Q 3.3-99 to immediately declare the associated load shedder and emergency load sequencer (LSELS) inoperable. The extended AOT for multiple inoperable channels on one bus in MODES 1-4 is evaluated in DOC 2-18-LS-31 and is consistent with Vogtle's approved ITS. We agree that this is an out of scope change, as identified in Attachment 3 of the original ITS submittal. However, we feel that this change is justified and the attached pages include revisions to DOC 2 LS-31 and to LS-31 to further support this change. The NSHC LS-31 discussion referenced in the second paragraph above is based on a comparison of shutdown time requirements in CTS LCO 3.0.3 vs. ITS LCO 3.3.5. Since ACTION 19 of current TS Table 3.3-3 for Functional Units 8.a and 8.b does not address the inoperability of more than one channel the failure of multiple channels would result in entering current LCO 3.0.3 which requires that the plant be brought to MODE 3 in 7 hours and MODE 5 in 37 hours. ITS 3.3.5 Conditions C and D also require that the plant be brought to MODE 3 in 7 hours and MODE 5 in 37 hours. While ITS 3.3.5 Condition C explicitly allows one hour for restoration, ITS 3.3.5 Required Action D.1 (i.e., be in MODE 3 in 6 hours) effectively eliminates the one hour for action initiation present in CTS LCO 3.0.3. Under the current TS, if LCO 3.3.2 were restored in the first hour the plant would exit LCO 3.0.3. Therefore, this is not seen as a relaxation; however, DOC 2-18-LS-31 and NSHC LS-31 have been revised to more
I i correctly characterize this sentence to say that this Condition has the j same shutdown track time in both the CTS and ITS. j ATTACHED PAGES: -l i 1 Encl. 3A 17,18 i ! Encl. 4 54 l l l 1 1 1 l i e l l (. l l i I i i i j- ! i < 1 l l
CHANGE NUMBER H2iG DESCRIPTf0N 2 12 H This Functional Unit [ current TS 9) is moved to improved TS 3.3.7. Consistent with NUREG 1431 Rev. 1. the Applicable MODES have been expanded to include movement of irradiated fuel assemblie_s to cover fuel handling accidents. QuSEAT 34-nb)-[a z-i2.-] 2 13 A This Functional Unit [ CTS 10] is moved to ITS 3.8.1 consistent with NUREG 1431 Rev.1. 2 14 H This change modifies ACTION Statement [20] for permissive P 11 [] to provide specific shutdown requirements to exit Applicability in lieu of applying LCO 3.0.3. This change is more restrictive by one hour, consistent with NUREG 1431. Rev.1. 2 15 H D Action Statement [1d] has been expanded to specify hac.1LolO_1 additional actions and options if an inoperable channel cannot be placed in bypass within the specified time period. In the current TS this would have required an entry into LC0 3.0.3. which would necessitate that the plant initiate a shutdown within 1 hour and be in the H0DE 3 in the next 6 hours. In the ITS the requirements to place the inoperable channel in bypass within a time constraint and the reduction, by 1 hour, in the time to exit the Applicability are more __ _ restrictive than the current TS. C. J {ERT' 3A _l$Q2.-15') 2 16 LS 12 ACTION Statement [26] for a channel inoperable in the current TS Table [3.3 3] Function [9] is modified to be consistent with NUREG 1431 Rev. 1 (i.e., a 7 day A0T in ITS 3.3.7). 2 17 LS-13 Not applicable to Wolf Creek. See Conversion Comparison Table (Enclosure 3B). 2 18 LS 31 Current TS Table 3.3 3 ACTION Statement 19 is revised to reflect ITS 3.3.5 for the Loss of Power Functional
- Unit.
I+he assee.iated load shedder-l Relaxation is obtained for multiple inoperable channels j M emerge.$ oad ssPencer This situation currently l(t.sa 5) be imme.diateg deckred on one bus in MODES 1 4. i Aoperable . % Regd requires entry into LCO 3.0.3 since it is beyond the scope of ACTION Statement 19. 4c.+ik A tTs .3.e'.1 has a 12- l w cogh.+idw ' tac. in msbc. i For multiple inoperable channels on one bus. the new __ GE#3 the t.s,a.s. % dWASt.E %s.) _ - - _ ~ ACTION Statement would direct thal./a'5) A5ut y cpann perJunctio oss f vo agp4nd/oVdegraded voftag ) d in K ho .J7or multiple inoperable t De' rest channels on two buses, the new ACTION Statement would require restoration of all but one channel per Function WCGS-Description ofchanges to CTS 3M.3 17 S/158 7
l l INSERT 3A-17a 0 2-15 In practice, because a time for completion of an action is not specified, no rigorous completion time is applied; the action is completed in an unspecified, j
" reasonable" time frame. For the functions where a completion time is not specified, the operability of the channel has no safety significance. The required number of channels remain sufficient to initiate the required protective action, even if a single failure is considered, regardless of the state of the one inoperable channel. Because a specific time would be required by the ITS, this change is considered to be more restrictive.
INSERT 3A-17b 0 2-12 Because the additional applicability, beyond that required by CTS, is being i adopted. this change is considered to be more restrictive. J l l l l l 1 I
CHANGE NUMBER H$ llc DESCRIPTION , ( 4 in mom 3 5 h (loss of voltage __ and/or degraded voltage) on one bus in y r,, bra , I hour, which[sMsJet ipvdlveAy rAxpfork4nAt)e) {Q2-te> \ put. age time currently required by entry into l f6, 4 w sa m e A b " LCO3.Q}. If the Completion Time for multiple channels Q+uk -- -
=
on one bus inoperable were not met in MODES 14, the plant must be shut down to MODE 3 in 6 hours and MODE 5 h.=c.,N"' in 36 hours. If the Completion Time were not met at l Q REDES)- other times in the Applicability, the associated DG and offsite circuit would be immediately declared inoperable and corresponding ACTIONS would be taken. k Since LC0 3.0.3 applies only in MODES 14, a relaxation oT@ hours would be involved for multiple inoperable channels on one_ bus as compared tg, A91 rte-tuM56 M\
@ . [] Qhe. cts Wch his nd AeT forts mi.t*Q ctions p ided y a S fety D
~
2-19 LG [Thischan moves fInjec n signa nd the pump s rt ries ** I not for Fu ional Un s [6.e. .f. 6. n I rrent T 'able [3. ] to t ITS .3.2 B ses. l gnsist t with N G - 14 . Re 1. NsEST 3A-lek] 2 20 A Not applicable to Wolf Creek. See Conversion Comparison Table (Enclosure 3B). 2 21 LS 22 Not applicable to Wolf Creek. See Conversion Comparison Table (Enclosure 3B). 2-22 tt a;d. lG 3.3-4 ST 2-23 A This change revises ACTION Statements [14 and 27] in current TS Table 3.3 3 to clarify that the 12 hour A0T to get to MODE 3 includes 6 hours for restoration followed by a 6 hours shutdown to MODE 3. consistent with WCAP - 10271 and NUREG 1431. Rev.1. 2 24 LS 19 Not applicable to Wolf Creek. See Conversion Comparison Table (Enclosure 3B).
-_- m- --
%2-27' 2-25 .# CTJX.3 u lon .a.1 quirym(ntf manuaJ
.att o a ngl iain am i ation 10ve is t ES un on is afet unctio or SG r ur nd been ved cur t TS Ta [3. ] in cord e wit EG - 1 . Rev. .
E func nr es is tion of inta steam y
- s. ndiv' al 11 . OPE TY o ndiv' al I line 's ass ed un ITS LC0 .2B s wi h6 i
l C letio ime as 1scussed i the 3 .7 p age. l (u ua. - l WCGS-Description ofchanges to CTS 3M.3 18 S/1S/97 L
l l l INSERT 3A-18a 0 3.3-63 ) 02-22 A The CTS [#] note of Table [3.3-3] is technically equivalent to ITS Note (b). Table 3.3.2-1. l l t 1 j INSERT 3A-18b 0 2-19 ' The text in Functional Units [1, 6.e. 6.f. and 6.g] of current TS Table [3.3-3), describing the ESFAS functions provided by a Safety Injection signal and the AFW pump start entries [, and the ** note for Functional Unit 6.9 ], are moved to the APPLICABLE SAFETY ANALYSES, LCO, AND APPLICABILITY Section of the ITS 3.3.2 Bases. The list of functions initiated by a Safety Injection signal and the particular AFW pump (s) started involve clarifying information for the retained Functional Units: the limitations and restrictions of the current TS are unchanged. The Functional units are retained in the ITS while the descriptive material is moved to the Bases. l l l
)
l l l l l I
} Q 2-lfb IV. SPECIFIC NO SIGNIFICANT HAZARDS CONSIDERATIONS NSHC LS 31 M 5*' 5 n 10 CFR 50.92 EVALUATION h'Mc FOR TECHNICAL CHANGES THAT IMPOSE LESS RESTRICTIVE c ;,, , 7 8,,, g REQUIREMENTS WITHIN THE TECHNICAL SPECIFICATIONS be.:, time 3). 3 or ka in MODE.3 &
m e n uk c;, he ws, Current TS Table 3.3-3 ACTION Statement 19 is re ised to reflect ITS 3.3.5 for the Loss of Power Functional Unit. Relaxation is obt ined for multiple inoperable channels on one bus in H0 DES 1 4. This situation urrently requires entry i_n_to ~ LCO 3.0.3 since it is beyond the scope of ACTION S tement 19. ([usEq LS-3IM lusERT ts-at For multiple _ inoperable channels on one bus, the n ACTION S_tatement would ge@ R Test tion al ut ne thinnektferJufict4on Do1% of yoMage andfor degraded)
< ta __
n1 u For multiple inoperable chann is on two buses, the new ACTION Statement would require restoration of all but one c nnel per Function (loss of voltage and/or degraded voltage) on one bus in 1 hour which @pse-ftvene-any~ prrat.ierC.frThe4 Dew 6is-catag0timelcurrently required by entry into LCO 3.0.3. If tTe Completion Time for multiple channels on one bus inoperable were not met in H0 DES 14, the plant must be shutdown to MODE 3 in 6 hours and N0DE 5 in 36 hours. If the Completion Time were not met at other times in the Applicability, the associated DG and offsite circuit would be immediately declared inoperable and corresponding ACTIONS would be taken. Since LCO 3.0.3 applies only in H0 DES 1-4, a relaxation of hours would be involved for multiple inoperable channels on one bus as compared to i2 Ommeaiate AE0'.34,3-totrydhe cts which hu no Acrr En. thh cona;fieh kh t e u Wh The proposed TS change has been evaluated and it has been determined that it involves no significant hazards consideration. This determination has been perfon..ad in accordance with the criteria set forth in 10 CFR 50.92(c) as quoted below:
"The Connission may make a final determination. pursuant to the procedures in 50.91. that a proposed amendnent to an operating license for a faci 1ity licensed under 50.21(b) or 50.22 or for a testing facility involves no significant hazards consideration. if operation of the facility in accordance with the proposed amendnent would not:
1
- 1. Involve a significant increase in the probability or consequences of an accident previously evaluated; or
- 2. Create the possibility of a new or different kind of accident from any accident previously evaluated; or
- 3. Involve a significant reduction in a margin of safety."
WCGS- NSHCs - CTS 3M.2 S4 SM587 I
.. .. . -- - - - . . - . - - . , ~ . - - - . . . - - . . . . . - .~.-
E INSERT LS-31a- 0 2-18 i Required Action B.1-of ITS 3.3.5 would direct immediate entry into ITS 3.8.1 i Condition F which has a 12 hour Completion Time for equipment restoration. Loss of two or more channels (loss of voltage and/or degraded voltage) on one bus is no worse from an overall safety system perspective than the loss of that train's load shedder and emergency load sequencer (LSELS). The associated LSELS will be declared inoperable even though Condition B of ITS 3.3.5 may be entered with two channels remaining OPERABLE and capable of satisfying the necessary two-out-of- i four logic. The 12 hour equipment restoration time allowed by ITS 3.8.1 Condition ! F is a reasonable allowed outage time for these instruments that is consistent ! with the LSELS allowed outage time and that takes into account the low probability of an event occurring during this interval that would require the LOP ; DG start instrumentation. ) i INSERT LS-31b 0 2-18 l l the associated LSELS'be immediately declared inoperable. This Required Action in ITS 3.8.1 has a 12 hour Completion Time to restore the LSELS to OPERABLE status. , 1 l 1 l-l i I l i i I i
. = . . - .. . . ~. . .. . . - . - . - - - . . - _ . . _ . . - . - -
ADDITIONAL INFORMATION COVER SHEET i ADDITIONAL INFORMATION NO: O 2-19 APPLICABILITY: DC, CP, WC, CA REQUEST: This change moves functions provided by a safety injection signal and the AFW pump start entries [and ** note] for Functional Units [6.e, 6.f, and 6.g] in current TS Table [3.3-3] [ to the ITS 3.3.2 Bases. 1 ) Comment: Clarify the intent of this change is to state that descriptive text regarding l ESFAS functions is moved to the Bases with the limitation and restrictions of the CTS l unchanged. Provide a citation giving the location of the text in the Bases. FLOG RESPONSE: The DOC 2-19-LG will be enhanced to provide the requested information. I ATTACHED PAGES: i Enct2 3-20 Encl. 3A 18 l
@th th'e, noseber8f CP RAQ.G channMb one. ,4 Q 3,3,, Q I
lc.cc, Man We, Qtdred Channd for Iwndtbn 3.o.2.) M cWi % +3 % A N l q redd b3 Spu. C2h m 3.fa.3[ TABLE 3 3-3 (Continued) ] TABLE NOTATIONS
# Trip function may be blocked in this MODE below the P-11 (Pressurizer 2-22-4 lO M d Pressure Intertock) Set;)oint. _ __
g,g l
##(ndjertetwr30trinmicMociscrsbovePM'G@may be blocked below -
P-11 wnen Safety injection on low steam hne pressure is not blocked. '
'The p=t! = cf Sp :{=$2n ? S ' := not app'! :b't. ] remon
- Neb";$ I* @,A hC33404I
**One !- Sep:=Sc^ 0 Oup 1 end One in Scp =Sen C=up ' 2 ***The de en- ;!:: ten of en:!=in Of SOP ESF#.S ede:S:n !:;!: cnd edu: g2.-69 \
2-31-A S n =!:y: =nde::: Of'h: feur ch:nne!:!nepe=b!:. ^.:t!:n Eid: ment 21 app'! : to beh Fund! nc! L'nt S C end S.;i'N ==. T ACTION STATEMENTS ACTION 14 - ' / the number of OPERABLE channels one less than the f r "u- 1-04-LG Require hannels OPrPf.SLE =;u!= nsat.[r3 store train to OPERABLE) 1-43-A , within 6 hours orlbe in at least HOT STANDBY within]!2 hounbrand in 2-23-A I COLD SHUTDOWN within the following 30 hours; however. one channel _ Q3.3j { may be bypassed for up to 4 hours for surveillance testing @sr Sppempeop - Q5.L5-4G AJ6' provided the other channelis OPERABLE. -- ACTION 15 - With the number of OPERABLE channels one less than the htal Nume: OdtequiddjChannels, operation may proceed until performance of 1-43-A the next required ANALOG CHANNEL OPERATIONAL TEST provided the inoperable channel is placed in the tripped condition within 1 hour. ACTION 16- With the number of OPERABLE channels one less than the T ! ! Number of (Require @ Channels, operation may proceed provided the inoperable channel 1-43-A is placed in the byoassed conditionjwithin 6 hours or be in HOT STANDBY] [ within the next 6 hours and in HOT SHUTDOWN within the following 6f
-M hours. On: th: 5' mem chan^ !: OPEPf.SLE : qu=me-* = met. One _
additional channel may be bypassed for up to 4 hours for surveillance Q'Z ,3 , g 4 s.sj } testing bees'edeemmMFD l o I en d the h 3* ACTION 17 - Withbmber of OPERABLE channeis)less than the !': T2T- 1-04-LG Channels OPEP^.BLE =qu= men *, operation may continue provided thef 1-43-A cc- L hj%nment pur; :u- 'y :-d :M udfhet. v 've := m:!nte!ned :!:;;( A DY M~M osble'cperdit4nesflI8"JMe 7(.s%ctterb Pumcwm requWu.3 we-twe ACTION 18 - Wit the number of OPERABLE channels one Require 1-43-A less than the hannels CPEPf.SLE =;u= men', restore the inoperable channel to OPERABLE status within 48 hours or be in at least HOT STANDBY within the next 6 hours and in COLD SHUTDOWN within the following 30 hours. ACTION 19 - With the number of OPERABLE channels one less than the 4tal 1-04-LG Numb:: c'.Q' uirehannels, STARTUP and/or POWER OPERATION 2-34 LS-34 may proceed provioed the following conditions are satisfied:
- a. The inoperable channel is placed in the inpped condition within 4 6 ours, ard insert 19.1 ^ N 2-10-M insert 19 (cont.) 2-18-LS-31
- a. Not applicable when all MSIVs are closed.
- b. Not applicable when all MIFVs, main feed isolation valves are closed. 2-07-LS-Il l
l WOI.F CREEK- UNIT 1 3M 3-20 Amendment No. 43 MarA-up of CTS 3M. 3 S/lSR7
l CHANGE IMBER !LSliC DESCRIPTION orbdn koD5 35'bc (lcss of voltage _ and/or degraded voltage) on one bus in n g c, w.a r, , I hour, which(dWspet ipvdlveAy rpaxpfork4n tbe) [Q2-te> \ _- wee pur.ae time currently required by entry into (6,ibe wme. hb" LCO3.Q}. If the Completion Time for multiple channels Q+uk. -
=- ^-
on one bus inoperable were not met in H0 DES 14, the plant must be shut down to H0DE 3 in E hours and H0DE 5 U e , 'lh** in 36 hours. If the Completion Time were not met at m NDM- other times in the Applicability, the associated DG and offsite circuit would be immediately declared inoperable and corresponding ACTIONS would be taken. k Since LCO 3.0.3 applies only in H0 DES 1-4, a relaxation of @ hours would be involved for multiple inoperable channels on one_ bus _a_s compared to,GTedrate-tuM5#3 M\
@ [] Qhe cts Atch his no AcT for@ mLhG 2 19 LG This chan moves
~
ctions p idedpyaSfety
- Inject ~ n signa nd the pump s frt ries 4* I not for Fu ional Un s [6.e. .f. 6.g n rrent T able [3.- ] to t ITS .3.2 B ses, )
gnsist t with N G - 14 . Re 1. lusERT 3A-6/ 2 20 A Not applicable to Wolf Creek. See Conversion Comparison Table (Enclosure 3B). 2 21 LS 22 Not applicable to Wolf Creek. See Conversion Comparison Table (Enclosure 3B). 2-22 Ot urai iRi 'sA lo3.3-4,31 2 23 A This change revises ACTION Statements [14 and 27] in current TS Table 3.3 3 to clarify that the 12 hour A0T to get to H0DE 3 includes 6 hours for restoration followed by a 6 hours shutdown to H0DE 3 consistent with WCAP - 10271 and NUREG 1431. Rev.1. 2 24 LS 19 Not applicable to Wolf Creek. See Conversion Comparison Table (Enclosure 3B). g h 2-2 C 2-25 .# CT .3 fu lon .a.1 uir nt f manua t o a ngl ain am i ation ve is ot ES un on is afet unctio or SG r ur nd been ved cur t TS I Ta [3. ] in corda. .e wit EG - 1 , Rev. . ie E func nr (es is tion of inta steam s, ndi l li . OPE TY o ndiv al linej 's a und ITS LC0 .2 B s wi Cpmpletio ime as dscussed i the 3/ .7 p age. ym. WCGS-Description ofchanges to CTS JM.3 18 S/15/97
1 INSERT 3A-18a 0 3.3-63 l 02-22 A The CTS [#] r. cts of Table [3.3-3] is technically equivalent to ITS Note (b), Table 3.3.2-1. ) INSERT 3A-18b 0 2-19 The text in Functional Units [1, 6.e 6.f and 6.g] of current TS Table [3.3-3], l describing the ESFAS functions provided by a Safety Injection signal and the AFW j pump start entries [, and the ** note for Functional Unit 6.g ], are moved to the APPLICABLE SAFETY ANALYSES, LCO, AND APPLICABILITY Section of the ITS 3.3.2 l Bases. The list of functions initiated by a Safety Injection signal and the ' particular AFW pump (s) started involve clarifying information for the retained 1 Functional Units; the limitations and restrictions of the current TS are l unchanged. The Functional units are retained in the ITS while the descriptive material is moved to the Bases. l l l l l l l l l i (
i ADDITIONAL INFORMATION COVER SHEET ADDITIONAL INFORMATION NO: Q 2-25 APPLICABILITY: CP, WC REQUEST: The requirement for manual actuation of a single main steam isolation valve has ; been moved from current TS Table [3.3-3]. OPERABILITY of individual lines is assessed under t ITS LCO 3.7.2. Comment: ITS 3.7 2 addresses valve operability and as such the CTS changes i proposed in Table 3.3.2 are deleted in the ITS. Provide an less restrictive justification for l the CTS changes which result from eliminating these main steam line isolation ; instrumentation requirements. CN 2-06-LS-33 is an appropriate application of changes [ to CTS. {CP) Note that CTS Action 21 is deleted as part of this change and the DOC reference is : 2-06A (CTS markup 3/4 3-28) which is 2-06LS in Section 3A. 2-06LS does not apply to I the proposed changes in general and to CP specifically. I i FLOG RESPONSE: DOC 2-25-A will not be used. DOC 2-06-LS-33 will be adopted to justify the changes. Slight modifications are required to DOC 2-06 and to LS-33 to extend the applicability to other FLOG plants. ATTACHED PAGES: Encl. 2 3-16, 3-21 Encl.3A 16,18 Encl. 3B 14,17 Encl. 4 2, new LS-33 l l l l l l i
TABLE 3.3-3 (Continued) ENGINEERED SAFETY FEATURES ACTUATION SYSTEM INSTRUMENTATION [ REQUIRED) M4NIMUM TOT.^.L ". CHANNELS GHANNELS APPLICABLE ; g,1-43-A _ , ' FUNCTIONAL UNIT OF CHANNELS TO-Taip OPERABLE MODES ACTION kli!44-LOhi
- 4. Steam Line Isolation
- a. Manuallnitiation 1 p2-25 l 1): .d:;:fd 1/elea m b e 4Meemime i f, _ . ._ . . ; 47 43 33 g:, .-
m .
- 2) System 2 4 3 1,hh 22 [:07-g113}-
C2-07-LS-Il
- b. Automatic Actuation 2 4 3 1, h h 29 ie
' 'A" Logic and Actuation Relays (SSPS)
- c. Containment Pressure-High-2 3 3 3 1,hh [ '
- d. Steam line 3/ steam line {g:]{'-- 3Meenline 1 2-07-LS-ll l Pressure-Low . . , _ . _ _ .
line
~
- e. Steam Line Pressure- 3/ steam line 3Meem4me 3 Mosm 4me '; 3,
-;_r Negative Rate-High i!"2-07-LS-11'.t ii ,
- 5. Turbine Trip & Feedwater Isolation 07-LS-Il
- a. Automatic Actuation Logic 2 4 3 1, b) 27 and Actuation Relay (SSPS)
[ ^'2-2 k i J
- b. Steam Generator Water 4/stm. Gen. 3delm-Gen 3detm-Gen- 1,h 28f.2 jgy1245Ayj 08-M; j -
Level-High-High M : ; ;-- '. nr. :;x - etn;;:P : .; :'-- , 2.'07.Ls.1l J - Gen. p
- c. Safety injection See item 1. above for all Safety injection initiating functions and requirements.
1 i WOLF CREEK- UNIT I 3M 3-16 Amendment No. 43 Mark-up ofCTS3/4. 3 5/lSM7 ;
1 TABLE 3 3-3 (Continued) l ACTION STATEMENTS (Continued) i
- b. The "" mum Channc!: OPEP ^.SLE requiremen* :: met; he';; ;;r, the 1-04-LG inoperable channel may be bypassed for up to ours for surveillance testing of other channels (p35@pafrCatper4 ., [4 L_S- 4 5.,)-@2-34-LS-34 j ACTION 20 - With less than the ?"" mum hannels OPERABLE within 1 hour d# 3#l M0!Or- ;n by Ob 012tien O!'he :=cc!:ted p;rm!=P;; nnune: ter 1-04-LO "nde';;':) that the interlock is in its required state for the existino plant 1-43-A condition, or cep!y Spec!S=tien 2 A2.fbe in MODE 3 within 7 hours and) 2-14-M (MODE 4 within 13 hours.
ACTION 21 - With the number of OPERABLE Channels one less than the ?'" mum 1-04-LG I (Requir3ehannels OPEP.^SLE requiremen'. be in at least HOT STANDBY l-43-A within 6 hours and in at least HOT SHUTDOWN within the following 6 hours; however. one channel may be bypassed for up to 2 hours for surveillance q 3.3j j i testingppdhcpecn p52.1)provided the other channelis OPERABLE. 1-66_ -u, I ACTION 22 - With the number of OPERABLE channels one less than the w 1-43-A Number efRequired; Channels, restore the inoperable channel to OPERABLE status within 48 hours or be in at least HOT STANDBY within 6 hours and in at least HOT SHUTDOWN within the following 6 hours. ( 2 -c6 -l.5- ^CT'ON 22
. "'""'he number of OPEP^SLE chen c!: enc !c= th:n 'hc Tet !
Number Of Channc!:, rettere the ineperab!c channe! te OPER.^9LE
!!ut'1"*"" 48 heur Or dec!:re the =ce! !cd ';;!';; :noperable end !:he the 2cticn requ: red by Spec:5 cation 2.71.5. ,
4T!ON 24 im" Ahc number cf O?EP ^.0LE che =!: en: !c= th:n 'h:""""/ :) Channe!:CLNE.". LMf M det!: c the Meded cu"'!2 y
%) ~'
I feedeleter pump incper:b!c :nd inc the ^.CT!ON required by Sze!5=tien 2.71 ? - 8~ M #
"'""'hc number cf OPER^.BLE " nne!: One !c= than 'hc ?'"me, 2-13-A
^CT!ON 25 Channe!: OPEP ^. ELE requ! :m:n', de '::: th: "c:*cd dic=!
;cner ter end c":!!c pc;;;r rur:0 incper b!: Ond t:k the
^ CT!CN :qd:d by Op.b.:.a. 0 0.t ACTION 26 - With the number of OPERABLE channels one less than the ?'" um 1-04-LG (Required) Channels OPEP^.B' E requiremen' restore the inoperable channel 1-43-A to OPERABLE status withi days 'S heur; or initiate and maintain 2-12-M operation of the Control Room mergency Ventilation System. -Dumg
__,a : i n nne e ~u e .u -,~ a, a , ,,, c u ,m., , n e - -. bhh cbbhWithno channels OPERABl E,immediateiy deciaEone 2MS-12 CREVS train inoperable and initiate and maintain operation of the other CREVS train in the CREVS mode and restore the inoperable CREVS train to OPERABLE status within 7 days, or immediately place both CREVS trains in the CREVS mode of operation. With the Required Actions and associated Completion Times not met : 2-26-LS-21
- a. When in MODE 1,2,3, or 4, be in MODE 3 in 6 hours and in MODE 5 in 36 hours.
- b. When in MODE 5 or 6, or during movement of irradiated fuel assemblies,immediately suspend CORE ALTERATIONS and movement of irradiated fuel assemblies.
WOLF CREEK- UNIT I 3M 3-21 Amendment No. M. 43 Mark-up of CTS 3M. 3 S/1S M
CHANGE NUMBER 82iG DESCRIPTION irradiated fuel assemblies within containment [and Core Alterations.,] %ecr 3A-iWp s.s n ) e )dIfJ 2 2 06 LS 33 fNoAt licn Tabhf ek. oov6rsforr ima 3A tk 2-26 l (26mpar (EnWosure . 2-07 LS 11 [ Note (a) is added to current TS Table 3.3 3 Function 4.a.2. 4.b. 4.c. 4.d. and 4.e for the Steam Line Isolation Function to state that the LCO requirements are not applicable in MODES 2 and 3 when the MSIVs are closed.] Note (b) is added to current TS Table [3.3 3] for the Feedwater Isolation and Turbine Trip Function. [ Functional Units 5.a. and 5.b] to state that the LC0 requirements are not applicable when the [MFIVs], are closed []. When these valves are closed [] they are already performing their safety function. These changes are consistent with NUREG 1431. Rev. 1. 2 08 h [New ACTION Statements 28.1 and 28.2 replace ACTION Statement 28 in current TS Table 3.3 3 for CTS 3.3.2 Functions 1.c.1.d.1.e. 4.c. 4.d. 4.e. 5.b. 6.d.1. and 6.d.2]. These ACTION Statements, written to reflect the Applicability of the affected channels and , consistency with ITS 3.3.2 [ Condition D and I]. are l more restrictive, by one hour, than the current TS ACTION Statement [28) which invoke [s] LCO 3.0.3 if the ! inoperable channel is not placed in trip within 6 hours. 2 09 LG Separate ESFAS entries for the motor-driven and turbine driven auxiliary feedwater pumps are no longer necessary, consistent with NUREG - 1431. Rev.1. The only difference in the requirements (an SR 4.0.4 exception for response time testing of the turbine driven auxiliary feedwater pump) has been addressed in the ITS by a Note in Surveillance Requirernent 3.3.2.10. [ITS Table 3.3.2.1 has eliminated the unnecessary repetition in current TS Tables 3.3 3 and 3.3-4). 2 10 M New ACTION Statement [19.1] is added to current TS Table [3.3 3] for one inoperable Main Feedwater Pump trip AFW start channel. This is a more restrictive change. consistent with NUREG 1431. Rev.1. since it l reduces by 1 hour the Completion Time to reach MODE 3 as compared with entry into LCO 3.0.3. 2 11 A The Functional Unit for Loss of Power [ CTS 8] is moved to improved TS 3.3.5. I WCGS-Description of changes to CTS 3H.3 16 5/15/97
INSERT 3A-16b 0 3.3-32 The revisions to ACTION Statement 17 to CTS Table 3.3-3 are more restrictive in nature in that no time limits for the completion of these actions are specified in the CTS. l l
CHANGE
!MBE8 H2iG DESCRIPTION kcD5 3bA (loss of voltage and/or degraded voltage) on one bus in g yc,k.un, I hour, which[d#sJet 1pvdiveAy rJ4xptfork4n,.tt)e3 {Q2-te \
w __ _ _ _- put. age time currently required by entry into (6,ibe wmc **b" LC03.Q}. If the Completion Time for multiple channels V*uk -- on one bus inoperable were not met in H0 DES 14, the
= - - ^- plant must be shut down to MODE 3 in 6 hours and H0DE 5 l c . , %** in 36 hours. If the Completion Time were not met at l Q NDM- other times in the Applicability, the associated DG and offsite circuit would be imediately declared I
inoperable and corresponding ACTIONS would be taken. k Since LCO 3.0.3 applies only in MODES 14. a relaxation or@ hours would be involved for multiple inoperable channels on one_ bus as compared tg A41 rte-TUP 3X3 M\
@ . [] Qhefc.Ts Acb hit go Act for6. cm,fitoC)
~
2 19 LG fThischan moves ctions p ided a S fety ] I Injec n signa nd the A pump s rt ries ** l for Fu ional Un s [6.e. .f. not 6.9 n rrent T able [3. ] to t ITS .3.2 B ses, ) gnsist t with N G - 14 . Re 1. tusegT' 3A-16b/ 2-20 A Not applicable to Wolf Creek. See Conversion l Comparison Table (Enclosure 3B). i i l 2 21 LS-22 Not applicable to Wolf Creek. See Conversion Comparison Table (Enclosure 3B). 2 22 it used. }Q3.3-(.ST 2 23 A This change revises ACTION Statements [14 and 27] in current TS Table 3.3 3 to clarify that the 12 hour A0T to get to H0DE 3 includes 6 hours for restoration followed by a 6 hours shutdown to MODE 3, consistent with WCAP - 10271 and NUREG 1431. Rev.1. 2 24 LS 19 Not applicable to Wolf Creek. See Conversion Comparison Table (Enclosure 38). _m --
@ 2-271 2 25 .# CTjE.3 u ion .a.1 uir nt f manual Xt o a ngl ain am i ation ve is t ES un on is afet unctio or SG r ur nd been ved cur t TS Ta [3. ] in cord e wit EG - 1 , Rev. .
E func nr es is tion of inta steam y s, ndiv' al li . OPE TY o ndivJdual I line 's ass ed un ITS LC0 .2 B s wi the C letio ime as scussed i the 3 .7 p age. _I _ _ _ WCGS-Description ofchanges to CTS 3M.3 18 S/1S/97
i INSERT 3A-18a 0 3.3-63 02-22 A The CTS [#] note of Table [3.3-3] is technically equivalent to ITS Note (b), Table 3.3.2-1. INSERT 3A-18b 0 2-19 The text in Functional Units [1, 6.e. 6.f. and 6.g] of current TS Table [3.3-3], describing the ESFAS functions provided by a Safety Injection signal and the AFW pump start entries [, and the ** note for Functional Unit 6.g ], are moved to the APPLICABLE SAFETY ANALYSES, LCO. AND APPLICABILITY Section of the ITS 3.3.2 Bases. The list of functions initiated by a Safety Injection signal and the particular AFW pump (s) started involve clarifying information for the retained Functional Units: the limitations and restrictions of the current TS are unchanged. The Functional units are retained in the ITS while the descriptive material is moved to the Bases.
insenT 3B-14 CONVERSION COMPARISON TABLE - CURRENT TS 3/4.3 rage u or30 , TECll SPEC CilANGE AFFLICABit.ITY NilMHER DESCRIPTION DIABLO CANYON COMANCllE FEAK WOt.F CREEK CAI.I.AWAY 1 61 If the requirements of current CPSES ACTION Statement 6 are No see Yes No - see No - see M not met. LCO 3.0.3 would be entered. In accordance with CNf 1-19 LS 8. CNf 1-19-LS-8. CNf 1-19 LS-8. the IST4, this ACTION Statement is revised to state that, if th! ACTION requirements are not met, the plant must be taken below the P-7 Interlock setpoint within the next 6 hours. 2 01 The Ergineered Safety Features Actuation System Yes Yes Yes Yes A Instrurtitation [] Allowable Values are moved to ITS Table 3.3.2 1. 2 02 CTS ACTION b.1. Equation 2.2-1, and the values for Total No - not in current No - not in current Yes Yes A Allowance (TA). Z, and Sensor Error (S) are deleted. TS. TS. consistent with NUREG-1431 Rev. 1. 2-03 The Engir.eered Safety Features Actuation System No - retain in ITS. Yes - moved to Yes - Hoved to ITS Yes - Noved to ITS LG Instrumentation Trip Setpoints are moved to a licensee Bases. 3.3.2 Bases. 3.3.2 Bases controlled document. 2 04 The requirements stipulated in ACTIONS a and b are moved to Yes Yes Yes Yes LG ITS Table 3.3.2 1 with explicit direction contained in the ITS ACTIONS Bases. 2 05 The Functional Unit for Containment [ Purge 3 Isolation. CTS No - see ( M .see~CN-2,,2tt-A) Yes Yes H 3.c. is moved to improved TS 3.3.6. Improved TS 3.3.6 adds CN 02-20 A [qz.ogj requirements on the OPERABILITY of the containment { purge C5 radiation] monitors and extends the Applicability for the [ Manual Initiation and BOP ESFASlactuation logic to include during movement of irradiated fuel assenblies within containment {andCoreAlterations} 06 nal Unit 4.a.1 of current TS Tabl s been No - retain CTS Yes atMIE~e-2'PA Yes
% 2.-25']
Il' CGS-CONVERSION TABLE- CTS 3N.3 MW
1 i INSERT 3B-14 TECH SPEC CHANGE APPLICABILITY NUMBER DESCRIPTION DIABLO CANYON COMMANCHE PEAK WOLF CREEK CALLAWAY 1-62 In a Callaway-specific change, ACTION 7 in No No. No Yes ; A CTS Table 3.3-1 is moved fron Functional lGgasres4) Units 13.a and 13.b to Functional Unit 13.c i 1-63 All reformatting, renumbering, and Yes Yes Yes Yes A editorial wording is in accordance with the Westinghouse Standard Technical- {d? t-A GE63 } Specifications. NUREG-1431. , 1-64 Notes are added to Tables 4.3-1 and 4.3-2 Yes Yes Yes Yes A to exclude ~setpoint verifications during i TADOTs on Functional Units that do not have qi,g,73 \ 1 setpoints associated with them. 1-65 Explanation of ITS treatment of seven slave No No Yes Yes . A relays with extended surveillance frequency. 4>2-4E} 1-66 This change would delete the reference to Yes Yes Yes Yes LS-45 Specification 4.3.1.1 and 4.3.2.1 in the ,3 allowed bypass notes contained in certain 4 2L S,3 .
~
CTS ACTION statements, thus permitting any testing needed for restoration of the , inoperable function. 1-67 This change revises DCPP CTS ACTIONS 13 and Yes No No No ,. M 29 to provide specific shutdown l requirements to exit Applicability, in lieu \d?3/I-+b \ of applying CTS. [ l 4 _ _ _ _ _ .__.___.__.____.__..-_m _ _ . . _ . _ _ _ _ _ . _ _ _ _ _ . _ _ _ _ _ . _ . _ _ _ _ _ _ _ _ _ _ . _ _ _ _ _ _ _ . _ _ _ _ _ _ _ _ _ _ _ . _ _ . _ . _ . _ _ . _ _ _ _ _ . _
CONVERSION COMPARISON TABLE - CURRENT TS 3/4.3 rage 17 ar30 TECil SPEC Cil ANGE APPLICABILITY NUMBER DESCRIPTION DIABLO CANYON COMANCllE PEAK WOLF CREEK CALIAWAY 2-20 The Functional Unit for Containment Vent Isolation is moved Yes Yes No see CN No - see CN 2-05-M A to ITS 3.3.6. There are no technical differences 2 05 M introduced by this process. 2-21 In CPSES current TS Table 3.3-2, Action 17.1 replaces No Yes No No LS-22 Action 17 for R$'ST Level Low Low and Action 17.2 replaces Action 17 for !G Water Level High High. 2-22 Jiekosed. The CTS E*] Meof Tabet D.533isWM Je h nyg. ves, gem. gs, aggg g O equdalewt tu ITS d4 ate. M . Tah 3.~12.-l. IQa3-b3) 2-23 This change revises ACTION Statements [14.27, and 34] in No - already in No - already in Yes Yes A CTS Table 3.3-3 to clarify that the 12 hour A0T to get to current TS current TS H0DE 3 includes 6 hours for restoration followed by a 6 hour shutdown to MODE 3. 2 24 At CPSES, the required Action for an inoperable SI No Yes No No LS 19 sequencer is revised per ITS 3.8.1 Condition F to extend the time available for restoration of an inoperable SI sequencer from 6 hours to 12 hours. 2-25 /The ir nt (o nu act ion as le s No e d No - u . tXnJ
- Jee " ^ J6 d4 T
lat -W'I3 @ valv as no ILI of fr curr TS 1 11 s is ss sed ~f -- " Tab [3.3- OP- ivi g r ITS C0 3. . Aled 11xd- / 2-26 The Required Action for an inoperable Control Room No - not in current Yes Yes Yes LS 21 [ Isolation] [ Manual Initiation, SSPS or 80P-ESFAS] channel TS. is modified to provide appropriate actions with the number of 0PERABLE channels [two] less than the number of Required Channels. S/1S/97 WCGS-CONVERSION TABLE - CTS 3M.3
l ? NO SIGNIFICANT HAZARDS CONSIDERATION (NSHC) t CONTENTS i (Continued) . u sel - LS 28. . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . Not @rrnciSHD D:c s.2 e= ' 1 _ LS 29. . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . Not appl i cabl e LS 3 0. . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . Not a ppl i c abl e LS 31................................................................... 54 LS 32....................................... .. . . . . .Not appl _icable @z2d LS.33.....-.................................. ine.te . . . . et-sperr,ae LS-34................................................................... 57 LS 3S............................................... . . . . .Not _ applicable LS 36............................................... ....Not h ".m.__
. z- icAs sW -
LS 37............................................... ...Not applicable LS.38................................................ ....Not y-- .- y a icA 3.s m 21 i LS 39................................................................... 60 LS 40................................................................... 62 LS 41................................................................... 64 : LS 42................................................................... 66 i LS 43......_............_................................................. 69 I O.s.44 i on er 4- oy o ,-n T V. Recurring No Significant Hazards Considerations **TR" TR - 1. . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . Not a ppl i c abl e TR 2 . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . Not appl i c abl e Ls.46 @seeer 4 dim s.si ( . Ls.4 c, r4.t.ppb calA lO t-50 t.5-41 rJot aglicalh. lQ 1-EQ LS- 46 j gy ,pp ;c3ga. lqz<e(s3j L'a-49 kioi- APPld (Q 2-3(= 3 y kbt' aff \ s5>A (Q 3-t5 ] LS- $1 lu.WRT 4-b dD 3.3-19 3 LS 51 5l'd'2iPM '***'I #'3 3'# \ LS- 5'S 4 t a P P hc.a A { D c. 3.3-00~11 l l l WCGS- NSHCs - CTS 3M.2 2 S/150 7 i l l
l i INSERT 4-c 0 2-25 I ! IV. SPECIFIC N0 SIGNIFICANT HAZARDS CONSIDERATIONS NSHC LS-33 10 CFR 50.92 EVALUATION FOR TECHNICAL CHANGES THAT IMPOSE LESS RESTRICTIVE REQUIREMENTS WITHIN THE TECHNICAL SPECIFICATIONS i Functional Unit 4.a.1) of current TS Table [3.3-3], manual initiation of individual steam line isolation, is not an ESF function and it is therefore deleted along with its ACTION Statement [23] from the ESFAS TS. The ESF function requires isolation of all intact steam lines, not individual lines. The safety I analyses do not model the individual isolation function for the MSIVs [nor is l that function performed with safety-related equipment]. Functional Unit 4.a.2), manual initiation of system level steam line isolation, is retained in the ESFAS TS and serves as a backup for the automatic isolation function. [The MSIVs have two redundant actuation trains. One train is designed to be active and the other is stand-by. Fast closure via both trains occurs automatically after a steam line isolation signal or if the system level manual i initiation switches ABHS0079 or ABHS0080 are actuated. A valve stroke time of I 5 seconds is ensured by redundant, high pressure hydraulic accumulators.] i [ Individual steam line isolation can be attained using manual switches ABHIS0011, ABHIS0014, ABHIS0017, and ABHIS0020: however, this closure is relatively slow (several minutes) and is attained only through the active actuator train (not i redundant). This slow closure function isolates the high pressure accumulators j and closes the MSIV using a non-safety air-driven hydraulic pump with its air l supply from the non-safety instrument air system.] The proposed TS changes has been evaluated and it has been determined that it involves no significant hazards consideration. This determination has been performed in accordance with the criteria set forth in 10 CFR 50.92(c) as quoted below:
"The Commission may make a final determination, pursuant to the procedures in 50.91, that a proposed amendment to an operating license for a facility licensed under 50.21(b) or 50.22 or for a testing f acility involves no significant hazards consideration, if operation of the facility in accordance with the proposed amendment would not:
- 1. Involve a significant increase in the probability or consequences of an accident previously evaluated; or
- 2. Create the possibility of a new or different kind of accident l from any accident previously evaluated; or i 3. Involve a significant reduction in a margin of safety."
i
IV. SPECIFIC N0 SIGNIFICANT HAZARDS CONSIDERATIONS LSHC LS-33
/.conti nued )
The following evaluation is provided for the three categories of the significant hazards consideration standards:
- 1. Does the change involve a significant increase in the probability or consequences of an accident previously evaluated?
Overall protection system performance will remain within the bounds of the previously performed accident analyses since no hardware changes are proposed. The only accident which credits manual steam line isolation is the steam generator tube rupture (SGTR). The SGTR analysis presented in the FSAR assumes that all four steam lines are isolated simultaneously when offsite power is lost in order to maximize the offsite radiological consequences. This analysis assumption is fulfilled by the system level closure function discussed above. The proposed changes will not affect the probability of any event initiators. The proposed changes will not affect the ability of any safety-related equipment to perform its intended function. [The equipment used to perform the individual isolation function is non-safety.] There will be no degradation in rne performance of nor an increase in the number of challenges imposed en equipment assumed to function during an accident situation. Therefore, the proposed changes do not involve a significant increase in the probability or consequences of an accident previously evaluated.
- 2. Does the change create the possibility of a new or different kind of accident previously evaluated?
There are no hardware changes nor are there any changes in the method by which any safety-related plant system performs its safety function. The change will not affect the normal method of plant operation. No new accident scenarios, transient precursors, failure mechanisms, or limiting single failures are introduced as a result of this change. Therefore, the proposed change does not create the possibility of a new or different kind of accident from any previously evaluated.
- 3. Does this change involve a significant reduction in a margin of safety?
The proposed change does not affect the acceptance criteria for any analyzed event. There will be no effect on the manner in which safety limits or limiting safety system settings are determined nor will there be any effect on those plant systems necessary to assure the accomplishment of protection functions. There will be no impact on any margin of safety.
h l IV. SPECIFIC NO SIGNIFICANT HAZARDS CONSIDERATIONS ( NSHC LS-33 (continued) N0 SIGNIFICANT HAZARDS CONSIDERATION DETERMINATION l Based on the above evaluation, it is concluded that the activities associated with NSHC "LS-33" resulting from the conversion to the improved TS format satisfy 3 the no significant hazards consideration standards of 10 CFR 50.92(c); and i accordingly, a no significant hazards consideration finding is justified. ! l l l l l
ADDITIONAL INFORMATION COVER SHEET ADDITIONAL INFORMATION NO: O 2-26 APPLICABILITY: CP, WC, CA REQUEST: The Required Action for an inoperable control room [ isolation] [ manual initiation, SSPS, or BOP-ESFAS) channel is modified to provide appropriate actions with the number of OPERABLE channels [two]less than the number of required channels. Comment: Provide a safety basis discussion for the proposed changes. {WC) CTS markup shows deletion of 3.0.4 exceptions in Modes 5 & 6. Provide an evaluation of this change. Neither the DOC nor the NSHC provide specific justification for providing a no channels OPERABLE condition or for the actions required in that condition. I FLOG RESPONSE: DOC 2-26 and NSHC LS-21 have been revised to provide additional ' justification. I ATTACHED PAGES: Encl.3A 19 Encl. 4 52 1 l f j
_ -. - - .=- - -. . -. - . - - - -- 1 i l CHANGE l NUMBER R$BC DESCRfPTION __ [
%2 2(* \
l 2 26 LS 21 The Required Action for an inoperable Control Room [ Isolation] [ Manual Initiation. SSPS. or BOP ESFAS] M channel is modified toJrov' e pr ia _ jt r acponyajt Fthe r OP c n s ] Mss ,inanM t r R r ha 1.f consistent with NUREG - g,p'.- 1431. Rev.1., Depending on the initial mode of operation, the modified action requires either:
- 1) [CREVS] to be placed in its [CRVIS mode]. or a plant shutdown to be initiated or.
- 2) immediate suspension of movement of irradiated fuel assemblies and Core Alterations.
2-27 A Not applicable to Wolf Creek. See Conversion Comparison Table (Enclosure 3B). 2-28 LG Not applicable to Wolf Creek. See Conversion Comparison Table (Enclosure 3B). 2-29 M Not applicable to Wolf Creek. See Conversion Comparison Table (Enclosure 3B). 2 30 A This change deletes Note (3) from Functional Unit 2.b of current TS Table 4.3 2. The slave relays listed in Note (3) were never associated with containment spray. This is an administrative change since the required quarterly surveillances have always been performed and the NOTE (3) never was used to extend the test interval. 2 31 A The *** Note for Functional Unit 6.g of current TS Table 3.3 3 is deleted. This note is no longer needed given that the ITS provides separate condition entr on a per pump basis as evaluated under CN 2-46 LS 42 3 1 n i [r 2 32 LS 23 Not applicable to Wolf Creek. See Conversion QsERT 3A-23 Comparison Table (Enclosure 3B). 2 33 A Not applicable to Wolf Creek. See Conversion Comparison Table (Enclosure 3B). 2-34 LS 34 ACTION Statement 19 of current TS Table 3.3-3 Functional Units 8a and 8b is revised to require an inoperable loss of power channel to be placed in trip within 6 hours and an allowance to be bypassed for l surveillance testing for up to 4 hours is added rather than the current 1 bour and-2 hours, respectively. This is consistent with ITS 3.3.5 Condition A. l WCGS-Description ofchanges to CTS 3N.3 19 S/15197
_ . . . - . - - - _ _ _ _ _ _ _ - - - ..~ ... --.-.... -.-. l ! INSERT 3A-21 0 2-31 ACTION Statement 21 for Functional Unit 6.c in CTS Table 3.3-3, " Automatic i Actuation Logic and *.;iuation Relays (BOP ESFAS)," directs that with one B0P ESFAS logic train inoperable, the plant is to be shutdown to MODE 3 in 6 hours l and to MODE 4 in 12 hours. The BOP ESFAS logic trains are powered by separation group 1 and separation group 4. Each turbine driven main feedwater pump has two pressure switches, one in separation group 1 and one in separation group 4, used l for indication of main feedwater pump trip and AFW start per Functional Unit 6.g i ! in CTS Table 3.3-3. If one B0P ESFAS logic train were de-energized, and ACTION Statement 21 entered, one pressure switch on main feedwater pump A and one pressure switch on main feedwater pump B would be rendered inoperable. Since ACTION Statement 19 for Functional Unit 6.g covers only one inoperable pressure switch, i.e., the ACTION covers "one less than the Total Number" which is listed as "4 (2/ pump)" in Table 3.3-3, de-energizing one BOP ESFAS logic train would i result (absent the *** footnote) in an LCO 3.0.3 entry for functional Unit 6.g. The only reason the *** footnote was added in OL Amendment No. 64 dated October 9, 1991 for Callaway and Amendment No. 43 dated March 29, 1991 for WCGS was to avoid the reporting requirements associated with an LC0 3.0.3 entry. DOC 2-46-LS-42 describes how the ITS format, listing "2 per pump" as the Required Channels for Function 6 g of ITS Table 3.3.2-1, would allow separate Condition entry per pump such that the de-energization of one BOP ESFAS logic train would result in ITS 3.3.2 Condition J being entered separately for each main feedwater pump. This would not involve an LC0 3.0.3 entry under the ITS: however, since the affected pressure switch channels must be tripped in 1 hour per Required Action J.1 and the channels are in the same separation group, the motor-driven auxiliary feedwater pumps would be started since the start logic would be satisfied. In this scenario ITS 3.3.2 Condition R would also be entered with a 6 hour shutdown in MODE 3. Therefore, the *** footnote serves no purpose in the ITS and it has bv.i deleted. INSERT 3A-21a 0 2-26 , The proposed change would provide appropriate actions to be taken, in lieu of shutting down the plant per LC0 3.0.3 if [two] channels of Control Room [ Isolation] [ Manual Initiation, SSPS or BOP-SSPS) are inoperable. l-
i 1 IV. SPECIFIC NO SIGNIFICANT HAZARDS CONSIDERATIONS NSHC LS-21 10 CFR 50.92 EVALUATION FOR I TECHNICAL CHANGES THAT IMPOSE LESS RESTRICTIVE REQUIREMENTS WITHIN THE TECHNICAL SPECIFICATIONS I h[ IQ 2-2( ] In accordance with the current Technical Specifications. the Required Action if both required channels of Control Room [ Isolation] [ Manual Initiation. SSPS or B0P ESFAS] are inoperable is to enter LC0 3.0.3 and take the plant to Mode 5. The proposed ; change would prevent unnecessary plant transients by requiring that specified compensatory steps be taken to assure control room habitability would be maintained if an accident were to occur. Thus, depending on the initial mode of operation, the proposed actions [] would require either: I
- 1) the [ Control Room Emergency Ventilation System (CREVS)] to be placed in its
[ Control Room Ventilation Isolation Signal (CRVIS) mode] or a plant shutdown to ! be initiated or.
- 2) immediate suspension of movement of irradiated fuel assemblies and Core Alterations.
The proposed TS change has been evaluated and it has been determined that it involves no significant hazards consideration. This determination has been perfonned in accordance with the criteria set forth in 10 CFR 50.92(c) as quoted below:
"The Comission may make a final determination, pursuant to the procedures in 50.91. that a proposed amenoment to an operating license for a facility licensed under 50.21(b) or 50.22 or for a testing facility involves a no significant hazards consideration. if operation of the facility in accordance with the proposed amendnent kould not:
- 1. Involve a significant increase in the probability or consequences of an accident previously evaluated; or
- 2. Create the possibility of a new or different kind of accident from any accident previously evaluated: or
- 3. Involve a significant reduction in a margin of safety."
The following evaluation is provided for the three categories of the significant hazards consideration standards:
- 1. Does the change involve a significant increase in the probability or consequences of an accident previously evaluated?
Overall protection system performance will remain within the bounds of the previously performed accident analyses since no hardware changes are proposed. The proposed WCGS- NSHCs - CTS 3M.2 52 S/158 7
INSERT LS-21 0 2-26 The proposed change would provide appropriate actions to be taken. in lieu of shutting down the plant per LC0 3.0.3 if [two] channels of Control Room [ Isolation] [ Manual Initiation. SSPS or BOP-SSPS] are inoperable. These actions which include the actuation of one train of [CREVS] and initiation of the appropriate compensatory measures for one inoperable train of [CREVS), are sufficient to maintain the habitability of the control room. l
ADDITIONAL INFORMATION COVER SHEET ADDITIONAL INFORMATION NO: O 2-31 APPLICABILITY: WC, CA REQUEST: The *** Note for Functional Unit 6.g of current TS Table 3.3-3 is deleted. This note is no longer needed given that the ITS provides separate Condition entry on a per pump basis, as evaluated under CN 2-46-LS-42, and given the adoption of ITS LCO 3.0.6 and the l Safety Function Determination Program. ! Comment: Explain in more detail why the ITS testing does not result in changes to the CTS required testing with the deletion of the proposed note. FLOG RESPONSE: This DOC does not reflect just a testing issue. In the attached pages this ; DOC has been clarified. Taken together, DOCS 2-31-A and 2-46-LS-42 describe the intended change; however, additional detail has been added to DOC 2-31-A. ATTACHED PAGES: Encl. 3A 19 s Encl. 3B 18 l l l l . , _ _ __
I CHANGE l NUMBER H51fC DESCRIPTION l 2 26 LS-21
@2.4Q The Required Action for an inoperable Control Room
[ Isolation] [ Manual Initiation. SSPS or B0P-ESFAS] $ channel is modified tofrov' e pr r1atp ac n t ithegamber OP c nn s o] _Mss an h u pufnber Re re ha el .f consistent with NUREG - g,g> 1431. Rev.1., Depending on the initial mode of operation, the modified action requires either:
- 1) [CREVS] to be placed in its [CRVIS Mde), or a plant shutdown to be initiated or.
- 2) immediate suspension of movement of irradiated fuel assemblies and Core Alterations.
2-27 A Not applicable to Wolf Creek. See Conversion Comparison Table (Enclosure 3B). 2 28 LG Not applicable to Wolf Creek. See Conversion Comparison Table (Enclosure 3B). 2-29 M Not applicable to Wolf Creek. See Conversion Comparison Table (Enclosure 3B). 2-30 A This change deletes Note (3) from Functional Unit 2.b of current TS Table 4.3 2. The slave relays listed in Note (3) were never associated with containment spray. This is an administrative change since the required quarterly surveillances have always been performed and the NOTE (3) never was used to extend the test interval. 2 31 A The *** Note for Functional Unit 6.g of current TS Table 3.3 3 is deleted. This note is no longer needed given that the ITS provides separate condition entr on a per Sump basis as evaluated under CN 2 46 LS 42 3 1 n i [n 2-32 LS 23 Not applicable to Wolf Creek. See Conversion egm Comparison Table (Enclosure 3B). 2 33 A Not applicable to Wolf Creek. See Conversion Comparison Table (Enclosure 3B). 2 34 LS 34 ACTION Statement 19 of current TS Table 3.3-3 Functional Units 8a and 8b is revised to require an inoperable loss of power channel to be placed in trip within 6 hours and an allowance to be bypassed for i surveillance testing for up to 4 hours is added rather than the current I hour and 2 hours, respectively. This is consistent with ITS 3.3.5 Condition A. WCGS-Description ofchanges to CTS 3H.3 19 S/15/97
)
i l INSERT 3A-21 0 2-31 ACTION Statement 21 for Functional Unit 6.c in CTS Table 3.3-3, " Automatic Actuation Logic and Actuation Relays (B0P ESFAS)." directs that with one BOP ESFAS logic train inoperable, the plant is to be shutdown to MODE 3 in 6 hours ! and to MODE 4 in 12 hours. The B0P ESFAS logic trains are powered by separation I group 1 and separation group 4. Each turbine driven main feedwater pump has two pressure switches, one in separation group 1 and one in separation group 4, used for indication of main feedwater pump trip and AFW start per Functional Unit 6 9 in CTS Table 3.3-3. If one B0P ESFAS logic train were de-energized, and ACTION j Statement 21 entered, one pressure switch on main feedwater pump A and one ! pressure switch on main feedwater pump B would be rendered inoperable. Since ACTION Statement 19 for Functional Unit 6.g covers only one inoperable pressure , switch, i.e., the ACTION covers "one less than the Total Number" which is listed ' as "4 (2/ pump)" in Table 3.3-3, de-energizing one B0P ESFAS logic train would result (absent the *** footnote) in an LC0 3.0.3 entry for Functional Unit 6.g. The only reason the *** footnote was added in OL Amendment No. 64 dated October j 9, 1991 for Callaway and Amendment No. 43 dated March 29, 1991 for WCGS was to avoid the reporting requirements associated with an LCO 3.0.3 entry. DOC 2-46-LS-42 describes how the ITS format, listing ~2 per pump" as the Required Channels for Function 6.g of ITS Table 3.3.2-1, would allow separate Condition i entry per pump such that the de-energization of one B0P ESFAS logic train would l result in ITS 3.3.2 Condition J being entered separately for each main feedwater ! pump. This would not involve an LC0 3.0.3 entry under the ITS: however, since the ) affected pressure switch channels must be tripped in 1 hour per Required Action J J.1 and the channels are in the same separation group, the motor-driven auxiliary feedwater pumps would be started since the start logic would be satisfied. In this scenario ITS 3.3.2 Condition R would also be entered with a 6 hour shutdown to MODE 3. Therefore, the *** footnote serves no purpose in the ITS and it has been deleted. INSERT 3A-21a 0 2-26 The proposed change would provide appropriate actions to be taken, in lieu of shutting down the plant per LC0 3.0.3 if [two] channels of Control Room [ Isolation] [ Manual Initiation SSPS or B0P-SSPS] are inoperable. i I
CONVERSION COMPARISON TABLE - CURRENT TS 3/4.3 rage is or30 TECil SPEC CHANGE APPLICABILITY NUMBER DESCRIPTION DIABLO CANYON COMANCllE PEAK WOLF CREEK CALLAWAY 2 27 The CPSES Action Statement for the loss of offsite power - No Yes No No A start motor driven auxiliary feedwater pumps is modified to require that if the Action Statements are not satisfied, the plant be taken to MODE 4 to exit the LCO Applicability. The CTS requires that MODE 5 be entered; however, because the function is only applicable in MODES 1. 2. and 3. the LCO mvid be exited prior to MODE 5, and MODE 5 entry is not a requirement. 2-28 This change moves information inserted by LA 114/115 on Yes No No No LG containment spray and safety injection coincidence to the Bases. 2 29 A new functional unit 9 is added to the DCPP CTS. per a Yes No No No M License Amendment Request, that incorporates ACTION 20.1 (new) and the appropriate Surveillances for the Residual Heat Removal (RtR) pump trip from low Refueling Water Storage Tank (RWST) level. 2-30 This change deletes Note (3) from Functional Unit 2.b. The No - not in current No - not in current Yes Yes A slave relays listed in Note (3) were never associated with TS. TS. containment spray. 2-31 The *** Note for Functional Unit 6.g of current TS Table No - not in current No - not in current Yes Yes A 3.3-3 is deleted. This note is no longer needed given that TS. TS. the ITS provides separate condition entry on a per pump
~
basts _asevaluatedunderCN2-46-LS-42.fand }Q2 31 1 WCGS-CONVERSION TABLE- CTS 3/4.3 5/15/97
ADDITIONAL INFORMATION COVER SHEET ADDITIONAL INFORMATION NO: O 2-34 APPLICABILITY: WC, CA REQUEST: ACTION Statement 19 of current TS Table 3.3-3 Functional Units 8a and 86 is revised to require an inoperable loss of power channel to be placed in trip within 6 hours and an allowance to be bypassed for surveillance testing for up to 4 hours is added rather than the current 1 hour and 2 hours, respectively. This is consistent with ISTS 3.3.5 Condition A. Comment: Extended test AOTs for bypass and surveillance are based on approved topical report WCAP-10271. Revise the DOC to document a safety basis for similar changes to LOP instrumentation for staff review. FLOG RESPONSE: As discussed during meetings with NRC staff on September 15 and 16, 1998, NSHC LS-34 has been modified to provide additional justification for the proposed change. ATTACHED PAGES: Encl. 4 57 l l 1 t V
IV. SPECIFIC NO SIGNIFICANT HAZARDS CONSIDERATIONS NSHC LS 34 i 10 CFR 50.92 EVALUATION l FOR l TECHNICAL CHANGES THAT IMPOSE LESS RESTRICTIVE l ' REQUIREMENTS WITHIN THE TECHNICAL SPECIFICATIONS l CTS 3.3.2. " Engineered Safety Features Actuation System Instrumentation." Functional Unit 8 for Loss of Power is moved to ITS 3.3.5. The CTS Completion Tima of placing the inoperable channel in the tripped condition is being revised to 6 hours and the allowance for bypassing the inoperable channel while_ per in surveillance testing , l of other channels is being revised to 4 hours. graT ts-34 g o z_w. } , 1 l The proposed TS change has been evaluated and it has been determined that it involves ' l no significant hazards consideration. This determination has been performed in I accordance with the criteria set forth in 10 CFR 50.92(c) as quoted below: ) l l "The Connission may make a final determination. pursuant to the procedures in l 50.91. that a proposed amendrnent to an operating license for a facility 1 l licensed under 50.21(b) or 50.22 or for a testing facility involves no significant hazards consideration. if operation of the facility in accordance with the proposed amendnent would not: 1
- 1. Involve a significant increase in the probability or consequences of an accident previously evaluated; or
- 2. Create the possibility of a new or different kind of accident fran any accident previously evaluated; or
- 3. Involve a significant reduction in a margin of safety."
The following evaluation is provided for the three categories of the significant hazards consideration standards:
- 1. Does the change involve a significant increase in the probability or consequences of an accident previously evaluated?
l
- Overall protection system performance will remain within the bounds of the previously i performed accident analyses since no hardware changes are proposed. The proposed change adds a relaxation to the Completion Time and the allowed time to be in a bypass condition while performing surveillance testing associated with an inoperable channel ;
in the toss of Power 4 kV Undervoltage-Loss of Voltage and Grid Degraded Voltage functions. The Completion Time generically approved by the NRC based on 4 J WCGS- NSHCs - CTS 3M.2 S7 S/lSMI
r INSERT LS-34 0 2-34 Revising the Completion Time to 6 hours to place the inoperable channel in trip and revising the time allowance for bypassing the inoperable channel for surveillance testing from 2 hours to 4 hours are acceptable considering the Function remains fully OPERABLE on every bus and the low probability of an event occurring during these intervals. l l i l l l l l l l 1 i i i i l I l P 1
ADDITIONAL INFORMATION COVER SHEET ; ADDITIONAL INFORMATION NO: O 2-37 APPLICABILITY: WC REQUEST: CTS 3.3.2 Functional Unit 6.a requirement for manualinitiation of an auxiliary feedwater pump is being deleted. The CTS Action Statement 24 with one channelir. operable requires declaring the applicable feedwater pump inoperable and entering the ACTIONS required by CTS 3.7.1.2. Therefore, this is consistent with the NUREG-1431 (TS 3.3.2 which does not have this Function identified and ITS 3.7.5 which has the ACTIONS consistent with those in the CTS ACTION 24. I Comment: {WC} [ SCOPE ISSUE] CTS requirements (limits, actions and SRs) for ' AFW manual initiation are eliminated in the instrumentation section. Revise ITS 3.3.2 to I include CTS requirements so that all actuation instrumentation is included in Section 3.3. FLOG RESPONSE: ITS 3.3.2 has been revised to include the CTS requirement Functional ) Unit 6.a for manualinitiation of an auxiliary feedwater pump. The , associated markups result in WCGS adopting JFD 3.3-58 consistent with j Callaway and DCPP. ! ATTACHED PAGES: Encl. 2 3-17,3-21,3-25,3-36 , Encl. 3A 20 Encl. 3B 20 , Encl. 5A 3.3-31,3.3-41,3.3-42,3.3-43 ; l Encl. 58 8 3.3-104, B 3.3-105, B 3.3-106, B 3.3-125 l Encl.6A 8 Encl. 6B 10 l , l 1 4 l
TABLE 3.3-3 (Contmued) ENGINEERED SAFETY FEATURES ACTUATION SYSTEM INSTRUMENTATION MINIMlJM T OT ^.L "^. CHANNEb6 CHANNELS APPLICABLE I . OF CHANNELS TO-Trip OPERAHLE ' MODES ACTION 2 FUNCTIONAL UNIT ['s.y3Aqg]
-((-04-LO~'r 4
- 6. Auxiliary Feedwater rwm Mk%k k= '" ^ -_ -
3(*.7^_- .;) 4/pwmp 4dpump (4r3-3_ 2)4 [ l'3' f
- b. Automatic Actuation Logic 2 4 3 1, 2, 3 29 and Actuat.% Relays (SSPS)
- c. Automatic Actuation Logic 2 4 3 -1, 2, 3 21 and Actuation Relays (BOP ESFAS)
- d. Stm. Gen. Water Level-4/stm. Gen. 1,2,3 28.1 Low-Low ( 248-M
- n. , e._..._._-w..-..n.._...,- _
- n. ......n_._.. m._ n ..
_ n_._.. < ,n_ n_ng ULQS-A 2 M *-- _,__L., g-- 9. ;,=
- 2) St- ' Ttf_...; Cf;= Pum; M'- . C= 2.t'- . C = ?!... . C=
- 2, 3 2"* 2
%: y2 5 0- [V~J i-05-A .7 M x - l
;;;. _::. .; y _L ., f.? 2 0910 g
' ~
W. G-- 9 .;-- i
- e. Safety injection - S4ad "i....- D i = " r p-See item 1. above for all Safety injection initiating functions 2-19-LG and requirements.
- f. Loss-of-Offsite Power - [
St- ' Tu ' ,; M;= " - ; 2 4 2 1,2,3 22 )
. 2 19-LG i WOLF CREEK- UNITI 3M 3-17 Amendment No. 43 l Mark-up ofCTSJH. 3 5/15M7
i TABLE 3 3-3 (Continued) ACTION STATEMENTS (Continued)
- b. The ?' -Hum Channe! OPE"* "LE m ;urm:n' :: --'; h:::r:r, the 104.LG inoperable channel may be bypassed for up to ours for surveillance 7 testing of other channels (ppr-8Fgerficatper* - O y L) 42.)- % ,34,gg,34 ACTION 20 - With less than the ""mu hannels OPERABLE, within 1 hour d # 3*3# l Md:- n: by dr ;frn !'he enr!d:d p '-!r :: 2^.nunc!ger 1-04-L0 "ndr (:) that the interlock is in its required state for the existino olant 1-43-A '
condition. or pr'; 5;rd'rfen 2 0.2.fbe in MODE 3 within 7 hours and) 2-14-M , (MODE 4 within 13 hours. J l ACTION 21 - With the number of OPERABLE Channels one less than the f': tm2T
- l-04-LG (Reautre3) Channels OPE"^ SLE re;u =r:n', be in at least HOT STANDBY 1-43-A within 6 hours and in at least HOT SHUTDOWN within the following 6 hours, however. one channel may be bypassed for up to 2 hours for surveillance testingypemcppon F5I.Bprovided the other channel is OPERABLE.
3,3j j _u 3,4g w__ _ _ ACTION 22 - With the number of OPERABLE channels one less than the Tota 1-43-A Numb:: c Require 4 Channels, restore the inoperable channel to OPERABLE status within 48 hours or be in at least HOT STANDBY within 6 hours and in at least HOT SHUTDOWN within the following 6 hours. 2-c6-IS- ^ CT!ON 23 "J^ *he number cf OPEP^ OLE 2:ne!: ene 're then *he Tete!
' 2%
Number Of Ch:nne!:, retere the inep rd'r 2:n=!! OPEP^.9LE
- Mr ;"':- 49 h~": er dnc'2 e the enetded ; ';r inep~'"'^ i
- nd !9:!" rMen requ! red by SprfrMrn 2.71.5. ,,
l 4T!6N 24 i"^ A hnumber f OPE"f.9LE d:nn :n: !:n then 'h:'""3 ) Chann6"" .L;fC- $ de&re the 2":-'ed 2r:'c /
~
'crtrder pump beperd! Ond idt- 'he .^.CT!OM tr';u!'ed b;' 8
? " rfr-2.712 - I- M +
^CT!ON 25
. '"t"'he number of OoEP^"LE denn& ent !rr then *he f'" mum 2-13-A )
Ch:nnd OPEP^.BLE re;ub:=:n*, dr' : the :":td fe:! l
;:ncrder :nd " :!te pr;;:: ru = ineperd'r end 4 air,e4he j
^ CT!ON :; ,_::;d by Cp;M.w. 0.0.t !
ACTION 26 - With the number of OPERABLE channels one less than the !'"mu- 1-04-LG ; (Required) Channels GEEP1.E' " q rwerA, restore the inoperable channel 1-43-A i 2-12-M to OPERABLE status withihis 5: = or initiate and maintain operation of the Control Room cmergency Ventilation System. -Deg operat!:n b "005 5 2nd S, *he : =r:ent of Secr45:n 2 0 ' cre not
= !!:d'elWith no channels OPERABLE,immediately deciare one 21 12 CREVS train inoperable and initiate and maintain operation of the other CREVS train in the CREVS mode and restore the inoperable CREVS train to OPERABLE status within 7 days, or immediately place both CREVS trains in the CREVS mode of operation.
With the Required Actions and associated Completion Times not met : 2-26-LS-21
- a. When in MODE 1,2,3, or 4, be in MODE 3 in 6 hours and in MODE 5 In 36 hours,
- b. When in MODE 5 or 6, or during movement of irradiated fuel assemblies,immediately suspend CORE ALTERATIONS and movement of irradiated fuel assemblies.
WOLF CREEK- UNIT 1 3M 3-21 Amendment No. M,43 Mark-up ofCTS3M. 3 S/1S/97
TABLE 3.3-4 (Continued) ENGINEERED SAFETY FEATURES ACTUATION SYSTEM INSTRUMENTATION TRIP SETPOINTS TOTAL SENSOR TR4R ALLOWABLE 2-01-A FUNCTIONAL UNIT N E ERROR 46) SETRQiNT VALUE 2-02-A
- 5. Turbme Trip and M-LG -
Feedwater Isolation
- a. Automatic Actuation Logicand Actuation '
Relays (SSPS) KA. N-A N-A. NA N.A.
- b. Steam Generator Water Level-High-High 6-0 248 3-61 ; 79*6 d 5 79.7% of newsw4enge narrow range insternent instrument open span
- c. Safety injection See item 1. above for all Safety Irgection Trip Setpomts and Allowable Values.
"" ~
- 6. Auxiliary Feedwater renam *Wb p N-A. NA N-A. NA s
( . "gd '-Lg
~14 ~2 -31 ) ,
- b. Automatic Actuation Logic and Actuation Relays (SSPS) N.A. N-A. NA N-A- N.A.
- c. Automatic Actuation Logic and Actuation Relays (BOP ESFAS) NA N-A. N-A. N-A- N.A.
- d. Sleam Generator Water Level-Low-Low
~
D 244 2448 2-61 ;23.5% M 222.3% of nonew+enge narrow range inskwnent instrument span span it'OLF CREEK- UNIT 1 3M 3-25 Amendment No. MarA-up ofCTS3M. 3 SHSM7
_. _,...m . . . . __- -_- - - - - - - -- - --- _ - - ------------ ---. . 1 TABLE 4.3-2
?
ENGINEERED SAFETY FEATURES ACTUATION SYSTEM INSTRUMENTATION SURVEILIANCE REQUIREMENTS _1-44-A? TRIP ! ANALOG ACTUATING MODIES , CHANNEL DEVICE -MASTER SLAVE FQ5HNMICH CHANNEL CHANNEL OPERATIONAL OPERATIONAL ACTUATION RELAY RELAY SUfWEILLANCE FUNCTIONAL UNIT CHECK CALIBRATION TEST TEST LOGIC TEST TEST TEST !S NC'"JECD e
- 4. Steam Line Isolation
~
'~ !
- e. ManuelInshation NA NA NA R NA N.A. NA 4r44 [
- b. Automatic Actuation .N.A. N.A. N.A. NA M(1) . M(1) Q 4r44 Logic and Actuahon Relays (SSPS)
- c. Containment Pressure- S Ri 4) Q NA NA N.A. N.A. 4r43 1-23-A . -l High-2 i
- d. Steam Line Pressure. S Ri4) Q NA NA NA NA 4r43 1-23-A I LOW l.23.A -
- e. Steam Line Pressure- S RI 4) Q N.A N.A. NA N.A. 3 ;
Negative Rate-High .i
- 5. Turbine Trip and Feedwater Isolatit.n 3
a Automatic Actuation NA N.A. NA NA M(1) M(l) O(3) 4r3 Logic and Actuation i Relay (SSPS) i
- b. Steam Generator Water S R4 Q NA N.A. N.A. N.A. 4r3 - I-23-A - l Level-High-High j
- c. Safety friection See item 1. above for all Safety legection Surveillance Requerements g 8-M 4 -lGI-13] f =w w sM b. b j v
h M ^. u .' M ^. ne ua 97 3, 3, 3 4rb3 o.nutomanc actuation N.A. M.A. NA M(1) up) Q Logic and Actuation N.A. M 2-W t ' Relays (SSPS) f 1 i i i WOLF CREEK- UNITI 3M 3-36 Amendment No. 43 -l M:rA-up ofCTS3M. 3 $/1597 t
.I . _ . . _ _ . . _ _ _ . _ . . _ _ _ _ _ _ _ _ _ _ . _ _ _ _ _ _ _ _ _ _ _ _ _ _ _ _ _ . _ _ _ _ . _ _ _ _ . . _ _ . _ _ _ _ . . _ _ _ _ _ _ _ . _ _ _ _ . _ _ _ . . _ . _ _ _ _ _ . . _ _ _ _ _ _ _ _ _ _ _ _ _ _ __ _ _ _ _ _ _ . _ . _ _ _ _ _ _ __________i
CHANGE NUMBER N2iG DESCRIPTIM 2 35 A Not applicable to Wolf Creek. See Conversion Comparison Table (Enclosure 38). 2 36 Not applicable to Wolf Creek. See Conversion 1Q2-3'1 Comparison Table (Enclosure 38). 2 37 CTS 3. . Funct nal Uni 6.a r rement or ual (,L4 - in ation an Auxi 'ary F ater p is ing eleted. he CTS tion S ement wit ne ch nel ino le r es dec ring t ppli le f ater p inope e and ering t ACTI S reg ' red by S 3.7 .2. ITS .7.5 whic has t ACTI con tent wit hose in CTS TION will used! l 4 the corr nding C requi nt. is is f i l
' consiste with the EG 1 ITS 3 .2 w 'ch does not j l (havet_ s Functi identif ed. Not used.
j 2 38 LS-35 Not applicable to Wolf Creek. See Conversion Comparison Table (Enclosure 3B). 1 2 39 LG Not applicable to Wolf Creek. See Conversion Comparison Table (Enclosure 38). 2 40 .NgFysed. IuurT SA-Q lQ 2-40 1 2-41 LS 36 Not applicable to Wolf Creek. See Conversion Comparison Table (Enclosure 38). 2-42 LS 38 Not applicable to Wolf Creek. See Conversion l Comparison Table (Enclosure 3B). 2 43 LG Not applicable to Wolf Creek. See Conversion Comparison Table (Enclosure 38). 2 44 A Not applicable to Wolf Creek. See Conversion Comparison Table (Enclosure 3B). 2 45 LG Consistent with NUREG - 1431. Rev.1. current TS Table 4.3-2 Note [3] is revised to move the "during refueling" clarification of the 18 month surveillance interval for the seven slave relays to the Bases for ITS SR 3.3.2.6. SR 3.3.6.5. and SR 3.3.7.5. 2-46 LS 42 In ITS 3.3.1 and ITS 3.3.2 separate Condition entry is allowed for each Function. Where the Required Channels are specified on a per bus or per pump basis, the applicable Condition may be entered separately for each bus or pump. If the current TS contains different formats under the " Total Number of Channels" and
" Minimum Channels OPERABLE" columns i.e. if a per bus WCGS-Description ofchanges to CTS 3M.3 20 5/158 7
1 1 INSERT 3A-20a 0 2-40
)
This administrative change affects the manner in which the current TS 4.0.4 i exception for testing the TDAFW pump is presented. This exception allows entry into MODE 3 to perform the turbine driven auxiliary feedwater pump response time testing. In NUREG-1431. Rev. 1. the current TS 4.0.4 exception [SR 4.3.2.2 and 4.71.2.la.2)) is reflected in the ITS SR 3.3.2.10 notes, l i 4 l l l l l l l l l l
CONVERSION COMPARISON TABLE - CURRENT TS 3/4.3 rage 20er30 TECil SPEC CIIANGE APPLICABILITY NUMBER DESCRirTION DIABLO CANYON COMANCllE PEAK WOLF CREEK CALI.AWAY 2-36 This change revises the APPLICABILITY of Functional Unit 7 Yes No - see No - see No - see f LS-M to require operability when the associated DG is required CN 2-32-LS-23 CN 2-18-LS 31 CN 2 18-LS-31 to be OPERABLE by LCO 3.8.2 of the ITS. _j_p 2 36. j att fa 111 F s be delet t 24 w nnel rab SJA 6J A .a a, g f CTS tion at one NA requ es de ring appl able f ate i rab e - - a enter the TIONS ir y CTS .7.1.2 heref , thi is c stent th G- 1I 2 whi does have is Fu ion tifi and .5 ch has con stent th tho e in 5 ACTION _ 64o4- liseA. _ ____ for DCPP, delete MODE 4 Applicability from the Manual Yes No No No 2-38 LS 35 Initiation f MSIVs since the valves are not required to be t CPERABLE in MODE 4 per CTS 3.7.1.5 or ITS 3.7.2 2 39 Move valve numbers in CTS ACTION 18 dealing with Yes No not in current No - not in current No not in current TS. TS. TS. LG containment ventilation isolation to the Bases.
~
ikEC1 SB-20p Jtpr Nde NMr- ug [Q - 2.-30_3 2 40 { _ No - not in current l 2-41 Callaway's ACTION Statements 27a and 34a of current TS No - not in current No - not in current Yes Table 3.3-3 for the Automatic Actuation Logic and Actuation TS. TS. TS. LS-36 Relays (MSFIS). Functional Units 4.b.2 and 5.a.2 are revised to specify action "with the nunber of channels less than the required channels" Those ACTION Statements currently require action "w?th the number of OPERABLE channels pag less than the minimum nunber of channels", but no action exists if none of the required channels per train are OPERABLE. WCGS-CONVERSION TABLE- CTS 3M.3 S/IS/97
INSERT 3B-20a 0 7 TECH SPEC CHANGE APPLICABILITY-NUMBER DESCRIPTION DIABLO CANYON COMMANCHE PEAK WOLF CREEK CALLAWAY 2-40 This administrative change affects the Yes Yes Yes No - Already A manner in which the current TS 4.0.4 in current TS exception for testing the TDAFW pump is presented.- This exception allows entry into MODE 3 to perform the turbine driven auxiliary feedwater pump response time testing. In NUREG-1431. Rev. 1, the current TS 4.0.4 exception [SR 4.3.2-.2 and 4.7.1.2.la.2)] is reflected in the ITS SR 3.3.2.10 notes.
ESFAS Instrumentation 3.3.2 ACTIONS (continued) CONDITION REQUIRED ACTION COMPLETION TIME E"H?fi?isi41otei;23dE[iEi= l M: OneiduLnne]. LC0J3~0~4jisf not7 applicable I hour gjjg$ng inoperable = =?r== =5-m -E====ri M3 Place channerinitrip; nil MkB perarmancer M.2 Restore _ nektTcoE _. [q2.3-ih channeLV st.. a_tu.s. a. _ W .= N; One. train'inoperab]e P rr- r :~--Z~-7-ISTE19 h-M y - One, train,may K bypassed;for up to~ 2: hours ~for._. sur.v.eil..l..ance. te g l W y oVided;.W _otheri.tfain is 10PSURE. isEQQ.jjnu ..;;.==.p.~.g.32 N.1 . Be..~in MODE. 3. 6 hours 18. 23i.59s> N.;2 . Be. in .MO.DE'4. .
- 12. hours
=-
O. one or more channels O.t Enter gicalAt CenAih6n(s) lmme4; as-se> thopenbic. . amd. Required ActiovQd LCD 3 ~7.E fer ihe. " a.gociated awdhirr3 Mdu- _ pq(A wude thopedea., i i l l 1 1 1 l I WCGS-Mark-up ofNUREG-1431 -ITS 3.3 3.3 31 S/1587
3 ESFAS Instrumentation 3.3.2 Table 3.3.21 (page 7 of II) Engineered Safety Feature Actuation System Instrumentation APPLICABLE N00ES OR OTER SPECIFIED REQUIRED SLRVEILLANCE ALLOWABLE M}P FUNCTION COWITIONS CHANNELS COWITIONS REQUIREENTS VALUE" SiMNNW" , I-31 l
- 6. Auxiliary Feedwater _ -
[ b S-S E313:483! s (g..~ Manut lentsb.h 1,2,3 lper p m p O KR 3.3.2.2> wA *
~ p. Automatic Actuation 1.2.3 2 trains G SR 3.3.2.2 NA M Logic and Actuation SR 3.3.2.4 Relays (Solid State SR 3.3.2.6 Protection System)
W z-yr) Automatic Actuation 1.2.3 2 trains GN SR 3.3.2.3 NA M l Logic and Actuation 3:3.iS9:ga Relays (Balance of Plant ESFAS) j _ I4 2-Bil d # SENitaET8sel 12.277 4'per SG D SR J A Z,1 i]!2;3r;of Low-law SRJ.3.45 MartuwiRange y.mN.S
$fMa $d SR 3:3~2.9 I 4839 !
M (N) 943.3 55l (continued) (a) n;;;; ;r '; ::;. =; ;r ,. .'1; r,'-.;;;=; sy ..;; . =1; l;.-_;l; V;ln r. 4. ; = ; n- ; 0;;di x M ';;y n;d by th; ur.' The A11msable Value defines the Limiting Safety 3ystem Setting..See 053;3g
; * ;w7 the. Bases _ for m the Tttp,Setpoints.
WCGS-Mark-up ofNUREG-1431 -ITS 3.3 3.3 41 S/lSB7
l l ESFAS Instrtmentation 3.3.2 Table 3.3.21 (page B of 11) ) Engineered Safety Feature Actuation System Instrumentation APPLICABLE MODES OR OTER SPECIFIED REQUIRED SLREILLANCE ALL(MABLE Mie FUNCTION COWITIONS OMNNELS COWITIONS PIQUIREOff5 VALUEW SEDOWP*
- 6. Auxiliary Feedwater (cont 1 W ) pst?3)Wi*
_ k>2 37) afetyInjection Refer to Function 1 (Safety Injection) for all initiation functions and requirements. QZ-37) fs. Loss of Offsite Power 1.2.3 2 trains F SR 3.3.2.7 i (2^12 " ; ;2^7;] " SR 3.3.2.9 .;i;t, . 0.0 /, ' a a .0 m -- e-we m.y a eee+ m ym s.3-se 9 a.s-ss ] (continued) (a) ^;.i ;r';
. L*.. '; /; e.;ifi; ig' ,_....;ti; ;; ny _,,;;i , ; ,1y ;"- --ti; ";;,;; f ,;;7,; ; , e4=
CMi -.Ld.1;;y .nd by tr.; . ;it lhe3UcumbleJalue defines.lthe'Liertting. Safety System SettinfSeefhe Beams.:ftr_the3rfP1Setpoints. i WCGS-Mark-up ofNUREG-1431 -ITS 3.3 3.3 42 S/15/97
f a ESFAS Instrumentation 3.3.2 4 Table 3.3.21 (page 10 of 11) >
- Engineered Safety Feature Actuation System Instrumentation i
t i APPLICALI 1 ! BCDES OR ODER SPECIFIED REQUIRED SLRVEILLANCE ALLGMBLE MEP i j IUICTICE COICITIONS CHAISELS C010!TIONS REQUIREENTS VALUE'8 SEWeillP" J i
- 6. Auxiliary Feeenter y *pg (continued) 4 =*u
$ hi;.it.: ": ^ z.n he fal-per i ElH H -G-7 - [003 i ; e-f7034 Gee %nH%sup hue SlH H -a-9 vehege tuo j " 2.2.2.;0 vehege 1o13rl 3'3-'80
- g. Trip of all Main l
Feeduster Puups 1h 2 per pump J SR 3.3.2.8 m-6-6-4-9
. ; ; ;;t, - . ; p; m 49 slH H H H e B
- h. Auxiliary Feeenter 1.2.3 fe} 3 FM SR 3.3.2.1 sh B E Puup Suction Transfer i s t. 9 m ia 5 ev7 EIH 4-4-7 w-f8D-6ai on Suction Pressure - SR 3.3.2.9 fpe4e} '
Law SR 3.3.2.12 fre4ei g.3
- 7. Automatic Switchover to Contairunent Snap
- a. Automatic Actuation 1.2.3.4 2 trains C SR 3.3.2.2 NA M Logic and Actuation Relays SR 3.3.2.4A SR 3.3.2.51:p
@R 3.3.2.10 b4d 3 ~b
- b. Refueling Water 1.2.3.4 4 d;M 46 Storage Tank (INST)
K SR 3.3.2.1 SR 3.3.2.5 ;.t . ; lt w-3D wf-l g Level . Low Law SR 3.3.2.9 and _-
@dM-{G3.3 55 \ ir-f-i (3.3-S Coinci: lent with Refer to Function 1 (Safety Injection) for all initiation g g*p SafetyInjection functions and requirements. , 43.34 &Ek)
I WC 3 MM - he, bb 6e he.%'pSs. (continued) (a) t/ - * ; 1^_ . "-O ; -;i-r
'. _.._..;c =3 _.._:~. =13 "" t'. ; '!;i.; ' , 2::; = L^ '".
lQs.3-M e-am ma i., l psari WCGS-Mark-sqp ofNUREG-1431 - l153.3 3.3 43 S/2SR7
-.- - - -.. . -. . - = . _ . - .-. . . - . _ _ - _
4 ESFAS Instrtmentation B 3.3.2 , BASES ~ APPLICABLE 6. Auxiliary Feessater (continued) SAFETY ANALYSES. LCO, and r;ht;d;. A b; in;l ir, the CC AJRg gr gg;tig APPLICABILITY pl3Ellyt will automatically realign the pump suctions to the safety.ralated Essential Service Water (ESW) System. (ni;;y r;ht;d). The AFW System is aligned so that upon a ptmp start, flow is initiated to the respective SGs immediately. (a.. iusamr a s.3-104 }-1 o 2-M l
- a. Auxiliary Faathater - Autnmatic Actuation Loaic and Actuation Relavs (SSPS) l W 3.5-ED {
--- as; w y- - mv _ a -- J "I T ; k ;;;; ti n usi; er.d ;;t t'.=
;.;y; ce.. ut Of tk :~ _ fGturs ;r.d ;4;rs.t; ir.
N 4 tk : n ..ar n i nri k t fr,r CSI Z I;sti = 1.b. h Auxiliary Feedsater - Aut-tic Actuation Lonic and Actuation Relavs (B0P ESFAS) 1 A t m tk st att a k ;;; r.: ut ati m r; u y; cer.sht of tr.c :n f;;turcs er.d si,erete ir, tr.e :r
..2. n i nrikt fert:Tr I;xti= 1.b. me at_tuati m Jogic and~actuatign. M )W O onsig m same faatutas. and marate in_thuana.monet.a dKctitKd ~f8CBOP~E5FAUTETMQlBW"55cf9fME5R i 3:3.2.'
j
~
lon-31 1 A&, Auxiliary Feedwater Steam Generator Water level - , Low Low SG Water Level-Low Low provides protection against l a loss of heat sink. A feed line break, inside or
- outside of containment, or a loss of MFW, would j result in a loss of SG water level. SG Water
. Level-Low Low provides input to the SG Level j Control System. Therefore, the actuation logic must be able to withstand both an input failure to the control system which may then require a protection function actuation and a single failure in the other channels providing the protection function actuation. Thus, four OPERABLE channels are required to satisfy the requirements with (continued)
WCGS-Mark-up ofNUREG-1431-Bases 3.3 8 3.3-104 5115/97
l INSERT B 3.3-104 0 2-37
- a. Auxiliary feedwater - Manual Initiation Manual initiation of Auxiliary Feedwater can be accomplished from the control rooin. Each of the three AFW pumps has a pushbutton for manual AFAS initiation.
The LCO requires three channels to be OPERABLE.
i ESFAS Instrumentaticn i B 3.3.2 { 1 BASES o Z-1M APPLICABLE Ar Auxiliary Feedwater - Steam Generator Water Level - SAFETY ANALYSES, low Low (continued) i LCO. and I 1 APPLICABILITY two out of four logic. rer unit; that Pav; 1 id'.st;d pr;tection :.r.d antr;l ;ter.rel;. ;,1y it.r a preta tien ;tenrel; er; ra n ;;;ry te ;;ti;fy tra protectiv; re vir a nt;. Ter ett.cr unit; : Pet rev; aly thr;; chenial;. ; .edi;n ;i; al ;;l;;ter is previid er j;;tifistien i; previid in
";fercrae 7.
With the transmitters (d/p cells) located inside containment and thus possibly experiencing adverse environmental conditions (feed line break). the Trip Setpoint reflects the inclusion of both steady state and adverse environmentet instrument uncertainties. Thet.TriplSetpointLfo LtheJtartiNotoriDriven .P.ilu!ps gtheTStartlurbine-Driven ~ Pimps _is523ISEo] ' [g23d 1 M Auxiliary Fee &#ater - Safety Iniection e An SI signal starts the motor driven _AFW pumps v ~ia h IDCA Yogdincer. 1 ' 1at~ n t ns re grac3,3.goj Ft s a he u sf r or , t reo r ts re t ir tr a f i_p t uT e . 2 .fA6stnaddfunction 1. SI, @ CroM!>e6Eitbfor all initihting functions and g requirements. Amelg,Famd failmasW of a si sirsHaiaitet<- %M h m ,
.sfy.
Auxiliary Feedwater - Loss of Offsite Power _ fg A loss of offsite power to the safegua_rdjservtee buses will be accompanied by a loss of reactor coolant pumping power and the subsequent need for some method of decay heat removal. The L%ss of Deffsite Ppower (LDP)]is detected by a voltage drop on each safeguard 3ervtee bus. The LOPfis strised and prw=M@yltheTcitdif tryJoODPiDG~stalt LLnad_wTmergencimdleguencerruidzitidito thelBOPLESFASiby.ithe; relay' actuation;2 Loss of power to either safeguard 3 ervtee bus will start the turbine driven AFW pump to ensure that at least one SG contains enough water to serve as the heat sink (continued) WCGS-Mark-up ofNUREG-1431-Bases 3.3 B 3.3105 5/15/97
ESFAS Instrumentation B 3.3.2 BASES , Q t.-vi APPLICABLE f E. Auxiliary Feedwater - Loss of Offsite Power SAFETY ANALYSES, (continued) LCO, and APPLICABILITY for reactor decay heat and sensible heat removal following the reactor trip. In~skfittorCol:elthe d%eselisenerators 'are _ started;and:tp_to; speed;' the mR6fPdrWM)GupyWJg_'W._1,.aT1yloaded
~
ontLo_theldtese1Mator%ses.
- 6. Auxiliary Feedwater '
(continued) [ hqh 6.f [o z-3M Functions 6.a through(Ebe5 Mfd 3?B)must be OPERABLE in MODES 1, 2 and 3 to ensure that the SGs remain the heat sink for the reactor. SG Water Level-Low Low in any operating SG will cause the motor driven AFW pumps to start. The system is aligned so that upon a start of the ptmp, water imediately begins to flow to the SGs. SG l Water Level-Low Low in any two operating SGs will cause the turbine driven ptmps to start. These Functions do not have to be OPERABLE in MODES 5 and 6 because there is not enough heat being generated in the reactor to require the SGs as a heat sink. In MODE 4. AFW actuation does not need to be OPERABLE because either AFW or residual heat removal (RfR) will already be in operation to remove decay heat or sufficient time is available to manually place either system in operation,
- f. h ilicrv rccd.acter Ur.&rvoltcoc necctor coolant Etsm Not_psedi A 1;;; Of p;w;r er. the bu;;; th;t provid; p;.;;r t; tra RC"; previt:; indic; tion ;f ; padin; 1;;; cf '
RC." for;;d ficw in th; ROS. Th; 'Jadcrvcit;;; RCP Iuration ';;n;;'; th; volt;;; d;w atr;;;. Of ;;;h RCP br;;k;r. A 1;;; cf pc.;;r. cr en e g a RCP br;;ker. On twe 07 .;r; RCP;. will ;t;rt th; turbira driven A"' pa;;p t; crour; thet et 1;;;t era 50 ;;ntein; l eneagh watcr t :;;rs; ;; th; taat sink for r;;;ter d;;;y h;;t and ;;n;ibi; h;;t r;;avel fcils.;ing th; I r;;; tor trip.
- g. Auxiliary Feedwater - Trio of All Main Feedwater Ptaps (continued) l WCGS-Mark-up ofNUREG-1431-Bases 3.3 B 3.3 106 5/15197 i
1 i ESFAS Instrumentation B 3.3.2 i BASES ACTIONS L 1. L 2.1 and L 2.2 (continued) by LCO 3.0.3 to initiate shutdown actions in the event of a i complete loss of ESFAS function. If the interlock is not in the 4 required state (or placed in the required state) for the existing unit condition, the unit must be placed in H0DE 3 within the next ! 6 hours and MODE 4 within the following 6 hours. The allowed l L Completion Times are reasonable, based on operating experience. l to reach the required unit conditions from full power conditions ' in an orderly manner and without challenging unit systems. Placing the unit in MODE 4 removes all requirements for l OPERABILITY of these this~1nterlocks. f N.T"and%2 Cped[tMMTagiggjes Mjhe' Aux 111aryJeedwater_EtapiSect.jon Tfiggsfer vnwwetio_nfressureTuncticriahe:candensate SturageTank'Tsittuthfghlfteliableland1 referred; suction _ source IRClauFAprmatWTI;31sJAmetTMhes"a"Egig30G;BrdpIMettC EnntIDNt M.A ierstien'T M i e iEI3ll W M 3 R ighr E E MARE 3MmbatyaAge3ias!,Jegtwm timEat!!srigsg!!!ss;3snens;as3heJ!uptrutgitjagglR1303333lH trDisrettenanourtconditionris andLfted_w11 gee 3ssung 13tDMIGWag!plicable; Mon [ngd[sT_aWyermittati i wwa_nminiurabwaranner N21 and~N2 ! Copdttfon NiagpliesitoAMliaryfeedwate_r Bal_ance of Riant ESSS~automit1Cait:tuatiohlogicland:actuatichTreltysc utth ione j taminmmpersbregttielurift;must:be3trought~te: === wmin ! RourCandM.MthinithelfoT1ci_tingTMJheiRequired MicrE.areinod1 Qed by_a; Note.thatialloiws~one3 rain to.be I toi!as[sedMEtoThours3orTsurvei))arme1 test [ngJrovidedithe a othEr~tr~ in~71s7WERABLE~.' (~o.I w _ iusser e 3 3-i2A s 42-sy - SURVEILLANCE The SRs for each ESFAS Function are identified by the SRs column REQUIREMENTS of Table 3.3.2 1. (continued) WCGS-Mark-up ofNUREG-H31-Bases 3.3 B 3.3 125 5/15/97
I 1 INSERT B 3.3-125 0 2-37 L1 Condition 0 applies to the Auxiliary Feedwater Manual Initiation Function. With one or more channel (s) inoperable, enter the applicable Condition (s) and Required i Action (s) of LCO 3.7.5 for the associated auxiliary feedwater pump (s) rendered inoperable. l l 1 l l l I i
= -_
i l As suh, hAcehm reference-> b %ese sRe i {q 2.3.M] l "TcWs .3.3.t. t wa. s.3. 2. - t can be. de.ta+cA . % c. ; c:urved TS ,i6 notiden%fy wW ch 6me.+iJn3. h>vs. o <quiveA vesponse tike . I Nt#EER JUSTIFICATION i 3.3 55 This change revises ITS SR 3.3.1.16 and SR 3.3.2.10 to verify ; g., Oce fired response timej, accomodating those channels that hav no response time requirements per the current licensing basis. l l 4.,g , g - The response time limits and the identification of those gg functions that have required response times are currently listed in a licensee controlled document, not in the current TS. This change makes t_he ITS consistent with this as_pect of the current t TS. ] A simnar revi.ibn 6 4he. iTs s.s. c sA note. han, >%.been' -- i
,n,ae reg. nag sa s.s.r .ta._ 4 5*84 3.3 56 This change revises ITS 3.3.2 Condition J [] to reflect current TS Table 3.3 3 Action [19] for Functional Unit [6.g]. [The I
required ACTION is to place the channel in trip within 1 hour ' rather than to restore operability within 48 hours]. 1 3.3 57 Not Used l 3.3 58 No lica f CJeeli. SpefonverJecf1 Comparisondable Closu I NSE KT d. A -8,o s i 3.3 59 This change adds new ITS 3.3.2 Condition [N] to reflect current TS Table 3.3 3 ACTION [21] on B0P ESFAS portion of AFW initiation. i 3.3 60 Not Applicable to Wolf Creek. See Conversion Comparison Table l (Enclosure 6B). 3.3 61 Tnis change revises the ITS SR 3.3.2.11 Frequency to 18 months per current TS Table 4.3 2 Functional Unit [11.b], which is the ESFAS P 4 permissive. The 18 month frequency for the , surveillance of the bas 4.; switch logic associated with the l opening of the reactor trip breakers is the value specified in the current TS. [] l l 3.3 62 Not Applicable to Wolf Creek. See Conversion Comparison Table l (Enclosure 6B). l 3.3 63 This change revises ITS Table 3.3.21 [ Note (g)] per current TS l Table [3.3 3] Note [#]. This revision is b clarification to the operator that describes the circumstances under which the [Steamline Pressure Negative Rate - High function may be blocked when below the] P 11 permissive. 3.3-64 This change revises ITS Table 3.3.21 Note (j) to exclude the HFRVs, consistent with current TS [3.7.1.6] []. WCGS-Differencesfrom NUREG-1431-ITS 3.3 8 5/15/97
i INSERT 6A-8a 0 2-37 This change adds new ITS 3.3.2 Condition [0] to reflect current TS Table 3.3-3 ACTION Statement [24] on manual AFW [ ] initiation. l l i I J l I
CONVERSION COMPARISON TABLE FOR DIFFERENCES FROM NUREG-1431 Page 10 of 23 SECTION 3.3 TECH SPEC CHANGE APPLICABILITY NUMBER DESCRIPTION DIABLO CANYON COMANCHE PEAK WOLF CREEK CALLAWAY 3.3 53 The REQUIRED CHANNELS description for Functions 2.a and Yes No No No 3.b.(1). of ITS Table 3.3.2-1, are revised per the DCPP CTS to note that only two switches (one per train) exist and that both must be moved coincident for manual _ initiation. fha _dA[s;R 3.s.t.51 and delefe. SR33- I.it anA sgM 3.3 54 Function 18.b (P-7) of ITS Table 3.3.11 is clarifieh b Yes e[75TS Yes {Q 3.3-M l COTS and Channel Ca11brations apply to the F-10 and P 13 I .--Tes inputs, not to the P.7 logic function, y,ijg;g,g,h gg aghy 3.3 55 Revise ITS SR 3.3.1.16 and 3.3.2.10 to v hify No - SR will be Yes Y ' wi be Yes lQ3 3-SF3 C&3 response times, acconnodating these channels retained in ITS a ITS that have no response time require _ments per the current Tables for required es rr ged i licensing basis. [J. Marcs-lop Functions. qunc or Q 3.3 56 Revise ITS 3.3.2 Condition J to reflect current TS Table No - See CN 3.3-116 Yes Yes Yes [3.3 3] ACTION Statement [19] for Functional Unit [6.g]. ; 3.3 57 Not used. N/A N/A N/A N/A 3.3 58 Adds new ITS 3.3.2 Condition [@ to reflect current TSh Yes No not in current y eN Yes Table 3.3-3 ACTION Statement [24] on manual AFW [] TS f ye3 (o 2.-y _l initiation. 3.3-59 Adds new ITS 3.3.2 Condition [N] to reflect current TS No - not in current No - not in current Yes Yes Table 3.3 3 ACTION Statement [21] on BOP ESFAS portion of TS. TS. AFW initiation. 3.3 60 Consistent with the design and current TS. Surveillance Yes Yes No used for BOP- No - used for 80P. Requirement [s 3.3.2.3 and 3.3.2.7 are] is not used by any ESTAS. ESFAS. function listed in Table 3.3.2-1. 3.3 61 Change ITS SR 3.3.2.11 Frequency to 18 months per current Yes Yes Yes Yes TS Table 4.3-2 Functional Unit [11.b]. which is the ESFAS PA permissive. [] WCGS-Conversion Comparison Table-ITS3.3 5/1587
i I INSERT 6B-10a 0 3.3-55 t As such, line-item references to these $Rs in Tables 3.3.1-1 and 3.3.2-1 can be ' deleted. A similar revision to the ITS 3.3.6 SR Note has also been made regarding SR 3.3.6.6. 1 l l l l
)
l l I i 4 k
i ADDITIONAL INFORMATION COVER SHEET ADDITIONAL INFORMATION NO: O 2-40 APPLICABILITY: DC, CP, WC REQUEST: This administrative change affects the manner in which the current TS 4.0.4 i exception for testing the TDAFW pump is presented. This exception allows entry into MODE 3 , to perform the turbine driven auxiliary feedwater pump response time testing. In NUREG-1431, ' Rev.1, the current TS 4.0.4 exception from [ Table 3.3-2, Notation d and Section 4.7.1.2.b.2)) is reflected in the ITS SR 3.3.2.10 notes. Comment: The CN states that a note is added to the turbine driven auxiliary feed pump response time testing based on the existing 4.0.4 exception. It does not appear that CTS 4.3.2.2 includes a 4.0.4 exception for this function. Therefore the justification is unacceptable and the classification should be LS rather than A. Provide justification for the explicit 24 hour interval and SG pressure allowances given in the note to SR 3.3.2.10. FLOG RESPONSE: ESF response time testing requires verification that each auxiliary feedwater pump starts as designed automatically upon receipt of an Auxiliary Feedwater Actuation test signal. However, for the turbine-driven auxiliary feedwater pump (TDAFP), an exception to Specification 4.0.4 is provided for entry into MODE 3. This exception is provided because in MODE 4, there is insufficient steam pressure to drive the TDAFP. The exception is converted into the ITS format via the NOTE to ITS SR 3.7.5.2 by specifying the appropriate conditions (e.g., minimum steam pressure and reasonable time for completion of SR). For WCGS, the CTS 4.0.4 exception is applied to the TDAFP start instrumentation; however, the explicit allowance for the minimum steam pressure and maximum time allowed to complete the surveillance is not explicitly stated. Because it is necessary to start the TDAFP to determine its response time, this same note is applied to the required RESPONSE TIME TESTING surveillance for the ESF instrumentation that starts the TDAFP. All other surveillances associated with the TDAFP start instrumentation are required to be current. , 1 ATTACHED PAGES: Encl. 2 3-13a ; Encl. 3A 20 Encl.3B 20 , i
SURVEILLANCE REQUIREMENTS 4.3.2.1 Each ESFAS instrumentation channel and interlock and the automatic actuation logic and relays shall be demonstrated OPERABLE by the performance of the ESFAS Instrumentation Surveillance Re nts specified in Table 4.3-2. 4.3.2.2 Tt_ % N LK SAFETY F T ES NSPONSE TIME' of each ESFAS function }Q3.~ shah t :_^_.22d2- rn 'reid to be hin the limit at least once per 18 monthsD (STAGGERED TEST basM E: '#
..__-______m. ._ _ _ - - - __ Y_2:!! _.m '-
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*The provisions of Specification 4.0.4 are not applicable for response time testing of the steam turbine-driven auxiliary feedwater pump for entry into MODE 3. { qpo }
MotvegmreA. to be performed for &c. 4uxbiht drinw AFtd pep 2 A l Luntil 2A hours >fh Str ps5wu. C2 pa% %% or apA tb 900 pii3, 4 WOLFCREEK- UNIT 1 3M 3-13a Amendment No. 84 Mark-up ofCTS3M. 3 5/IS/97 4
CHANGE NUMBER RSBC DESCRIPTION 2-35 A Not applicable to Wolf Creek. See Conversion Comparison Table (Enclosure 3B). I 2-36 Not applicable to Wolf Creek. See Conversion IQZ-3tj Comparison Table (Enclosure 38). A 2-31 2 37 CTS 3. . Funct nal Uni 6.a r rement or ual 3 (Adi in ation an Auxi 'ary F ater p is ing eleted. he CTS tion S ement wit ne ch nel ino le r es dec ring t ppli le f ater p inoper e and ering t ACTI S reg ' red by CTS 3.7 .2. ITS .7.5 whic has t ACTI con ' tent wit hose in CTS TION will used' g the corr nding C requi nt. is is f , L consiste with the EG-1 ITS 3 .2w'chdoesnot} ! (havethTsFuncti identif ed. et usei. j l l 2 38 LS 35 Not applicable to Wolf Creek. See Conversion Comparison Table (Enclosure 3B). 2-39 LG Not applicable to Wolf Creek. See Conversion Comparison Table (Enclosure 3B). 2 40 )4Filsed, t usuT SA Q [o 2-40 1 2-41 LS 36 Not applicable to Wolf Creek. See Conversion ) Comparison Table (Enclosure 3B). 2-42 LS-38 Not applicable to Wolf Creek. See Conversion ! Comparison Table (Enclosure 3B). l 2 43 LG Not applicable to Wolf Creek. See Conversion ' Comparison Table (Enclosure 3B). I 2 44 A Not applicable to Wolf Creek. See Conversion Comparison Table (Enclosure 3B). ! 2-45 LG Consistent with NUREG 1431. Rev. 1. current TS Table 4.3 2 Note [3] is revised to move the "during refueling" clarification of the 18 month surveillance interval for the seven slave relays to the Bases for ITS SR 3.3.2.6. SR 3.3.6.5, and SR 3.3.7.5. 2 46 LS 42 In ITS 3.3.1 and ITS 3.3.2 separate Condition entry is allowed for each Function. Where the Required Channels are specified on a per bus or per pump basis, the applicable Condition may be entered separately for each bus or pump. If the current TS contains different formats under the " Total Number of Channels" and
" Minimum Channels OPERABLE" columns, i.e. if a per bus WCGS-Description ofcitanges to CTS 3M.3 20 S/15/97
INSERT 3A-20a 0 2-40 This administrative change affects the manner in which the current TS 4.0.4 exception for testing the TDAFW pump is presented. This exception allows entry into H0DE 3 to perform the turbine driven auxiliary feedwater pump response time testing. In NUREG-1431. Rev. 1, the current TS 4.0.4 exception [SR 4.3.2.2 and 4.7.1.2.la.2)] is reflected in the ITS SR 3.3.2.10 notes.
CONVERSION COMPARISON TABLE - CURRENT TS 3/4.3 rage 20 er30 TECH SPEC CHANGE APPLICABII,ITY NUMBER DESCRIPTION DIABLO CANYON COMANCIIE PEAK WOt.F CREEK cat,t.AWAY
; 2-36 This change revises the APPLICABILITY of Functional Unit 7 Yes No - see No - see No see i t_5-e to require operability when the associated DG is required CN 2 32 LS 23 CN 2-18 LS-31 CN 2-18-LS 31 to be OPERABLE by LCO 3.8.2 of the ITS. Idiz-36 j ati fa 111 F er s be delet CTS ction at t 24 w one nnel rab MA % 6J A %
f ' requ es de ring appl able f ate i rab e - - a enter heref , thi is cor stent the TIONS tr th t y CTS .7.1.2 EG- 1 IT 2 / [ whi does have is F ion ntift and - .5 ch has AC con stent with tho e in S ACTION _ Qot tWA. __ For DCPP delete H00E 4 Applicability from the Manual Yes No No No 2-38 LS-35 Initiation f MSIVs since the valves are not recuired to be OPERABLE in HODE 4 per CTS 3.7.1.5 or ITS 3.7.2 2-39 Nove valve nunbers in CTS ACTION 18 dealing with Yes No not in current No - not in current No - not in current LG containment ventiletion isolation to the Bases. TS. TS. TS. 2 40 [ IkEC.'1"3B~20 Jt#r _ b WL) ICf -2 30] 2-41 Callaway's ACTION Statements 27a and 34a of current TS No - not in current No - not in current No - not in current Yes LS-36 Table 3.3-3 for the Automatic Actuation Logic and Actuation TS. TS. TS. Relays (HSFIS). Functional Units 4.b.2 and 5.a.2. are revised to specify action "with the number of channels less than the required channels". Those ACTION Statements currently require action "with the number of OPERABLE ' channels ong less than the minimum number of channels", but no action exists if none of the required channels per train are OPERABLE. WCGS-CONVERSION TABLE- CTS 3H.3 5/15/97
INSERT 38-20a 0 7-11 TECH SPEC CHANGE APPLICABILITY NUMBER DESCRIPTION DIABLO CANYON COMMANCHE PEAK WOLF CREEK CALLAWAY This administrative change affects the Yes Yes Yes No - Already 2-40 A manner in which the current TS 4.0.4 in current TS exception for testing the TDAFW pump is presented. This exception allows entry into MODE 3 to perform the turbine driven auxiliary feedwater pump response time testing. In NUREG-1431. Rev. 1, the current TS 4.0.4 exception [SR 4.3.2.2 and 4.7.1.2.la.2)] is reflected in the ITS SR 3.3.2.10 notes. __..__m_ _______.-___ . . _ _ _ _ . _ - _ . _ _ _ . _ _ . - _ _ _ _ _ _ . _ _ _ _ ____ _____._______________________.______._m__._ - _ __ _____________-________.__m__m _ _ __ _ ____m __ _ _ _ _ __ . _ _ _ _ - _ _ - . _ _ _ _ _ _ _ _ _ _ _ _ _ _ _ _ . _ _ . _ _
ADDITIONAL INFORMATION COVER SHEET ADDITIONAL INFORMATION NO: Q 2-45 APPLICABILITY: WC, CA REQUEST: Current TS Table 4.3-2 Note (3) is revised to move the "during refueling" clarification of the 18 month surveillance interval for the seven slave relays to the Bases for ITS SR 3.3.2.6, SR 3.3.6.5, and SR 3.3.7.5. Comment: {WC, CW) This change is identified in T4.3-2 to table notation for thte slave results in a less restrictive change because additional test flexibility results in optional testing during refueling. Provide less restrictive documentation. Removal of the requirement to conduct certain slave relay tests only during refueling has not been specifically justMed. The justification should explain why it is acceptable to perform testing at other times. Provide a DOC explaining why note 3 to SSPS slave relay test is not copied in ITS SR 3.3.6.6. FLOG RESPONSE: These comments were discussed during a meeting with NRC staff on September 18,1998. The outcome of that discussion was a commitment for Callaway and WCGS to generate a new "A" DOC to explain how footnote (3) to CTS Table 4.3-2 was translated into ITS requirements. New DOC 1-65-A is included in the attached pages. ATTACHED PAGES: 1 Encl. 2 3-38 l Encl. 3A 14 I Encl. 38 14 l l l
TABLE 4 3-2 ENGINEERED SAFETY FEATURES ACTUATIOP SYSTEM INSTRUMENTATION SURVEILLANCE REQUIREMENTS TRIP ANALOG ACTUATING MODES CHANNEL DEVICE MASTER- SLAVE FQIMNNIGH CHANNEL CHANNEL OPERATIONAL OPERATIONAL ACiUATION RELAY RELAY SURVEILLANGE
* * ~ ~ " " ^ '
FUNCTIONAL UNIT CHECK CALIBRATION TEST TEST LOGIC TEST TEST TEST
- 9. Control Room isolation kD'*La 5 flf N
- a. Manual Indiation N.A. N.A N A. R N A. NA_ M A. All IdiP13-321 I and s - _
2.j23 ", elays PS NA NA NA NA All
- c. Automahc Actuation Logic and Actuahon N.A. M(1)(3) N.A.
{2-STQ - Relays (BOP ESFAS)
- d. Phase *A* Isolabon See item 3.a. above for all Phase "A" Isolshon Sunreillance Requwoments
'a S:M St-^r trM S:7- .__. N^ M..^ N .^ M^ "(*)(2; M^ M^
- 2, ? , '
g-g
- 11. Engineered Safety Features Actuahon System Interlocks sa 23-A
- oe n _u
- a. Pressurizer Pressure, N.A. 4) Q NA NA NA NA 4-3r3 P- 11 g g,
- b. Reactor Trip, P-4 NA N.A. NA (5) N.A; .NA NA 4r raa TABLE NOTATIONS (1) Each traen shall be tested at least every 62 days on a STAGGERED TEST BASIS (2) Continuity check may be excluded from the ACTUATION LOGIC TEST.
(3) Except Relays K602, K620, K622. K624, K630. K740, and K741, which shall be tested at least once per 18 months g y dunng each COLD SHUTDOWN exceeding 24 hours unless they have been tested within the
^_.:.7- _ ,_ g' ..end
= ._
h2 46 l g4 (4) includes verification of time constants,where applicable. (5) Vm&,4;un of setpomt not requwed 4p 2 m { Q t-2.3 l ! I WOLFCREEK- UNITI M4 3-38 Amendment No. 43 ' l MarA-up of CTS 3M. 3 MI597
CHANGE NUMBER !MC DESCRIPTION ( 1 54 LS 37 Not applicable to Wolf Creek. See Conversion Comparison Table (Enclosure 3B). 1 55 LS 39 Applicability Note [*] and ACTION Statements [5.a and 10] for Functional Units [1. 6.b.19. and 20] of l current TS Table 3.31 are modified to provide an alternative to opening the reactor trip breakers (RTBs) while still assuring that the function and intent of opening the RTBs is met. As currently worded, these ( ACTION Statements result in a feedwater isolation signal (FWIS) when in MODE 3 with a T , less than [564*F. USAR Table 7.3 14 and USAR Figure 7.2-1 (sht.13) detail the FWIS generation on the coincidence requh M of P 4 and low T,,.] A more generic action. which eh5" k 'E assure @he rods are fully inserted and cannot be {
* - withdrawn. replaces the specific method of precluding f
Qa.ts-set rod withdrawal. The revised Applicability and ACTION FR s3M Statements still assure rod withdrawal is precluded. This change does not involve any safety impact and is consistent with traveler. ) I 1-56 Not applicable to Wolf Creek. See Conversion W i-s4 Comparison Table (Enclosure 3B). 1 57 LG Current TS Table 3.31 Functional Units [12.a and 12.b] are combined per traveler TSTF - 169. The Required Channels. ACTION Statement, and Surveillance Requirements are the same for both Functional Units. The only difference between the two is the Applicability which could lead to entry into ACTION Statement 6 for Functional Unit [12.a]. followed by a power reduction below P 8 exiting the Applicability and required actions for that Functional Unit, and ) subsequent re entry in ACTION Statement 6 for l Functional Unit [12.b]. This would involve an improper l ctmiulative A0T of 12 hours before tripping an inoperable channel, beyond that evlauated in WCAP 10271 and its Supplements. The relaticuships between these Functional Units ..
- permissives P 7 and P-8 are moved to the ITS 3.3.1 Bases.
4 1 58 A Not applicable to Wolf Creek. See Conversion Comparison Table (Enclosure 3B). 1 59 n
@c._ s.te=pe eq
,.. - b ch m LMf
% . _Crer.k.
s e Su.G- A..sg 1 60 Not used. 1-61 M Not applicable to Wolf Creek. See Conversion Comparison Table (Enclosure 3B). WCGS-Description ofchanges to CTS 3M.3 H S/2S/97
INSERT 3A-14 1-62 A Not applicable to Wolf Creek. See Conversion Comparison Table (Enclosure 3B). 1-63 A All reformatting, renumbering, and editorial rewording is in ' Ql'A Gf.4J) -_ accordance with the Westinghouse Standard Technical Specifications, NUREG-1431. During the development certain wording preferences or English language conventions were adopted. As a result, the Technical Specifications (TS) should be more readily readable, and therefore understandable, by plant operators and other users. During the reformatting, renumbering, and rewording process, no technical changes (either actual or interpretational) to the TS were made unless they were identified and justified.
} GI-23 J 1-64 A The refueling interval TADOTs for Functional Units [1 and 17] in CTS Table 4.3-1 have been revised to include existing Note [10. "Setpoint verification is not required."] Likewise, refueling interval TADOTs for Functional Units [1.a. 2.a. 3.a.1), 3.b.1), 3.c.1), 4.a. 6.a. 9.a and 11.b] in CTS Table 4.3-2 have been revised to add a new Ncte [5],
" Verification of setpoint not required." This change is administrative in nature since the subject Functional Units have no setpoints associated with them. This change does not affect the operating limits or manner in which the plant is operated. There are no changes to current plant practices for the performance of these TADOTs since there are no setpoints to verify for these Functional Units. This change is strictly an acknowledgement that the corresponding ITS SRs 3.3.1.14, 3.3.2.8, and 3.3.2.11 have an explicit Note to this effect.
1-65 A Seven slave relays are listed in Note (3) to CTS Table 4.3-2 for an exception to the quarterly SLAVE RELAY TEST. These slave relays are associated with the following ESF actuation signals: K602 (SIS): K620 (turbine trip and main feedwater pump trip): K622 (CIS-A): K624 (CIS-A): K630 (CIS-A and the CIS-A input to containment purge isolation and control room ventilation isolation): K740 (SIS, RWST low-low): and K741 (SIS, RWST low-low). ITS SR 3.3.2.6 has been revised with a Note per JFD 3.3-19 that excludes these seven slave relays from the quarterly surveillance. Based on the differing Functional Unit MODE Applicabilities, new ITS SRs 3.3.2.13 and 3.3.2.14 have been added under JFD 3.3-19 to cover the surveillance frequency applicable to these slave relays. The only slave relay associated with containment purge isolation and control room ventilation isolation, K630, has the extended surveillance frequency under new ITS SR 3.3.2.13. Based on feedback received from the NRC reviewer at a meeting on September 16, 1998, the 90 days cited in Note (3) has been changed to 92 days to follow standard convention for an exception to a quarterly surveillance frequency. l l
INSERT 3A-14 (continued) Q 3.Q\ 1-66 LS-45 The CTS allows certain inoperable channels, or for some plants one other channel, to be bypassed for testing per Specification 4.3.1.1 or 4.3.2.1. The intent of the bypass is to allow testing that will verify that the channel has been restored to an OPERABLE condition and can be returned to service. The allowed bypass time for testing has been evaluated for its impact on the safety analyses. It has l been determined that the impact of the allowed bypasses is minimal. l Whether the bypass is for setpoint verification or response time verification has no impact on the safety analysis. This change would delete the reference to Specification 4.3.1.1 and 4.3.2.1 in the allowed bypass notes contained in certain CTS ACTION statements, thus i permitting any testing needed for restoration of the inoperable I function. t l l I l I l l l 1
pJSGRT 3B-14 CONVERSION COM PARISON TABLE - CURRENT TS 3/4.3 rage I.s of 30 TECil SPEC CllANGE APPLICABII,ITY NIIMHl:M DESCRIPTION DIABLO CANYON COMANCllE PEAK WOIE CREEK cal.I.AWAY 1-61 If the requirements of current CPSES ACTION Statement 6 are No see Yes No - see No - see H not met. LCO 3.0.3 would be entered. In accordance with CNf 1 19 LS 8. CN# 1-19 LS 8. CN# 1-19 LS 8. the ISTS this ACTION Statement is revised to state that, if the ACTION requirements are not met, the plant must be taken below the P 7 interlock setpoint within the next 6 y hours. 2-01 The Engineered Safety Features Actuation System Yes Yes Yes Yes A Instrumentation [] Allowable Values are moved to ITS Table 3.3.2-1. 2 02 CTS ACTION b.1, Equation 2.2-1, and the values for Total No not in current No - not in current Yes Yes A Allowance (TA), Z. and Sensor Error (S) are deleted. TS. TS. consistent with NUREG-1431 Rev. 1. 2 03 The Engineered Safety Features Actuation System No retain in ITS. Yes moved to Yes - Hoved to ITS Yes - Hoved to ITS LG Instrumentation Trip Setpoints are moved to a licensee Bases. 3.3.2 Bases. 3.3.2 Bases controlled document. The requirements stipulated in ACTIONS a and b are moved to Yes Yes Yes Yes 2-04 LG ITS Table 3.3.2-1, with explicit direction contained in the ITS ACTIONS Bases. Yes 2-05 The Functional Unit for Containment @ urge 3 Isolation. CTS No - see (M.se(C3HL2K) Yes M 3.c. is moved to improved TS 3.3.6. Improved TS 3.3.6 adds CN 02-20 A pg.og} requirements on the OPERABILITY of the containment { purge es radiation]monitorsandextendstheApplicabilityforthe p [ Manual Initiation and B0P ESFASlactuation logic to include during movement of irradiated fuel assemblies within containment {andCoreAlterations} al Unit 4.a.1 of current TS Tabl s been No - retain CTS es EPA Yes 2 06 F c -25"] S/1S/97 Il' CGS-CONVERSION TABLE- CTS 3/4.3
_ _ _ _ _ _ _ _ _ _ ~ - . - - - _ _ - - _ _ _ _ _ _ __ _. _ _ _ _ - - _ _ - _ _ _ _ _ _ _ __ __ _ _ _ _ _ _ _ _ - - _ _ INSERT 38-14 TECH SPEC CHANGE APPLICABILITY NUMBER DESCRIPTION DIABLO CANYON COMMANCHE PEAK WOLF CREEK CALLAWAY 1-62 In a Callaway-specific change. ACTION 7 in No No No Yes A CTS Table 3.3-1 is moved from Functional ]Gla3rcs& } Units 13.a and 13.b to Functional Unit 13.c 1-63 All reformatting, renumbering, and Yes Yes Yes Yes A editorial wording is in accordance with the Westinghouse Standard Technical {G? t-A GE o1 1 Specifications. NUREG-1431. 1-64 Notes are added to Tables 4.3-1 and 4.3-2 Yes Yes Yes Yes A to exclude setpoint verifications during TADOTs on Functional Units that do not have q gggg setpoints associated with them. 1-65 Explanation of ITS treatment of seven slave No No Yes Yes A relays with extended surveillance
@ 2-4E l frequency. _
1-66 This change would delete the reference to Yes Yes Yes Yes LS-45 Specification 4.3.1.1 and 4.3.2.1 in the 1 allowed bypass notes contained in certain CE 2L 33 ~ CTS ACTION statements, thus permitting any testing needed for restoration of the inoperable function. 1-67 This change revises DCPP CTS ACTIONS 13 and Yes No No No . 29 to provide specific shutdown M requirements to exit Applicability. in lieu \433-4'"\ of applying CTS.
ADDITIONAL INFORMATION COVER SHEET ADDITIONAL INFORMATION NO: Q 3-01 APPLICABILITY: DC, CP, WC, CA REQUEST: The requirements of this specification [ CTS 3.3.3) are moved to separate specifications in the improved TS. The RCS leakage detection requirements are moved to improved TS 3.4.15. [The fuel building requirements are moved to improved TS 3.3.8.] The ; Control Room requirements are moved to improved TS 3.3.7. [] l Comment: {WC} CTS T3.3-6 (F1.a) ### alarm /setpoint is moved to ODCM. CTS Also, Action 26 modified to include ITS Action A 4 hour repair allowance. These changes are neither identified nor evaluated. Provide a less restrictive justification and a revised CTS markup. {WC, CW} Several CTS Action 30 changes are not evaluated. The CTS requires , operation of the Emergency Exhaust System within 72 hours. The ITS uses FBVIS l mode. The CTS requries maintaining Fuel Building at a negative pressure. This requirement is deleted without discussion. {CW} Several CTS Action 38 changes are not evaluated. The use of CRVIS mode to replace the CTS recirculation mode. The shutdown to Modes 3 & 5 or the addition of the requirement to suspend CORE ALTERATIONS when in Modes 5 & 6 when this is not included in the iTS applicabiltiy. Provide justificaitons for all changes to the CTS. . 1 i The DOC does not provide specific justification for providing a no channels OPERABLE conditions or for the actions required in that condition. Furthermore, this is not an administrative change. FLOG RESPONSE: The first portion of first comment concerning the ### notation in Table 3.3-6 is addressed in the response to Comment Number O 3.3-32. The second portion of the first comment is addressed by revising CTS Action 26 utilizing DOC 3-11-M which was used by CPSES to make an equivalent change. Reference 5 in the WCGS cover letter indicated that DOC 3-11-M was acceptable. The second comment and the portion of the third comment dealing with system lineup nomenclature were discussed during meetings with NRC staff between September 15 and September 18,1998. These are the same comments resolved under Comment Number O 3.3-80 in those meetings. In response to the third comment, new DOC 3-18-M has been generated to discuss more restrictive requirements added to CTS ACTIONS 30 and 38 for Callaway and ACTIONS 27 and 30 for WCGS. The last comment is incorrect in stating the DOC should address a provision for no channels OPERABLE. Current ACTIONS 30 and 38 for Callaway and Actions 27 and 30 for WCGS already have a 1 hour HVAC system lineup action for no channels OPERABLE and the mark-up retains that Completion Time. For CPSES and DCPP, the last comment does not apply (see DOCS 3-13-M and 3-15-M, respectively).
ATTACHED PAGES: Encl. 2 3-41 Encl.3A 23,24 Encl. 3B 23,25 s I l I
l 1 1 TABLE 3 3-6 (Continued) TABLE NOTATIONS
*'"'" fue! - *he re:p=tN: fue! eter:g p=!. p 3.g' .
.t a wq
" f " red tied 'u:!la 'h: fuO! c'^r:g: Or02: Or fue! by:!d!ng. ;ggp
+ ~ ._ y a ;
# Trip Setpoint concentration value (pCi/cma ) is to be established such that the actual submersion l dose rate would not exceed 2 mR/h in the control room.
## Trip Setpoint concentration value (pCi/cm3 ) is to be established such that the actual submersion l dose rate would not exceed 4 mR/h in the fuel building.
### Trip Setpoint concentration value (pCi/cm3 ) is to be established such that the actual submersion dose rate would not exceed 9 mR/h in the containment bgdjng ,,/f etpoint v e may be g .g. gjf.
l me equiv nt limits of on 3.1 o eODC ccorda with the m dology d i paramet in the OD during co inment pur or vent p ided the point valu oes not e of twie e maximu concentrati activity in t containm determi by the sa e analysi rfofmed gq 3_,, g or to each ease in acco ance with T le 3-1 of ODCMf --m--__--_ - restore. the cbn nel to of'EIVtBLE ACTION STATEMENTS Ala dka A bQ* ' 3 st-M ACTION 26 - With less than the Minimum Channels OPERABLE requirement, peration may continue provided the containment purge valves are maintained closed. ACTION 27 - number of OPERABLE channels one less than the ?'"mu-- (E; P =.uire hannels OPER^.9LE rr;u!':m:n', isolate the Control Room 3-d aj Emergency Ventilation System and initiate operation of the Control Room 14h Emergen Ventilati System in the recirculation mode within 72 'cu - days r with no OPEF3ABLE cpsnnels within 1 ho d res in rabl to RABt,Estatup4anthin[ days, orface bo n l G 3,$l] , : peradon .. medi ly.
. f f __ ,
^CT!ON 2B
. = !rre the- *he ! : mum Channe!: OPER^.9LE requ!remen*,0^^'a- - j-4-ri l I
!!On m y cen' nue for up te 30 dry: previd^ :n r-- 0;ricte g'-v3-LU
"'M Q
?^"*f': rn' rr^r: men!!:: 0
"h = =:?t - S:O ! *::
pree!ded ia 'he fut! 0 00. 0 '^"e the in^p^rebie rnca.itors to OPEo^9LE etetut v^5 20 d y: er turpend !! Operation:induing fue! mavemen* :- 'he fue! be!! ding. ACTION 29 - Must satisfy the ACTION requirements to pecf=t!:n 2.tS.* ACTION 30 - With the number of OPERABLE channels one less than the f'"mu-- (RequireWhannels OPER^.SLE requ=m:n', isolate the Fuel Building Ventilation g9 System and initiate operation of the Emergen haust System to maintain the fuel _ gg] building at a negative pressure within 72 5:ur,7 days, wit (no OPER,ABLE chpnnel.s , g;gg -
^
vptffinfhosgfand re ore the inope train 1 PERpdLE statywithinfdayg oJ45Iacefoth t s in opp /ation
/
media
' 7 7 / g.gg.(
-_ ] / / - l W,tri 3/4 3-41', g 3,eg \
l l l WOLF CREEK- UNIT 1 3M 3-41 Amendment No. %,56 Mark-up ofCTS 3M. 3 $/15/97
l [ I INSERT 3/4 3-41a 0 3-01 f With no channels OPERABLE: 3-lB-N ; ! '(a) Immediately declare one CREVS train inoperable and take appropriate ; ( ACTIONS and within 1 hour place on CREVS train in the CRVIS mode, or j i (b) Within 1. hour place both CREVS trains in the CRVIS mode. ! t With the Required ACTIONS and associate Completion Times not met: (a) When in MODE 1, 2, 3, or 4, be in MODE 3 in 6 hours and in MODE 5 in I 36 hours. I V i (b) When in MODE 5 or 6. or during movement of irradiate fuel assemblies. : immediately suspend CORE ALTERATIONS and movement of irradiated fuel ' l assemblies. l l 1 l l INSERT 3/4 3-41b 0 3-01 , With no channels OPERABLE: 3~ 2* M-l (a) Immediately declare one EES train inoperable and take appropriate ! ACTIONS and within 1 hour place one EES train in the FBVIS mode, or l (b) Within 1. hour place both EES trains in the FBVIS mode.
- With the Required ACTIONS and associated Completion Times not met, immediately l suspend movement of irradiated fuel assemblies in the fuel building.
1 I i 1 a I i l
CHANGE NUMBER NStlC DESCRIPTION I 3 05 LS 14 CTS ACTION Statement [27] for the [ Control Room Air Intake) and ACTION Statement [30] for the [ Fuel Building Exhaust] radiation monitors have extended completion times in NUREG 1431 Rev.1 ITS 3.3.8. from [72 hours] to 7 days for one required channel inoperable, consistent with NUREG 1431 Rev. 1. lq a.os ) 3 06 A ACTION [c] of current TS LCO 3.3.3.1 is revised to state the Specification 3.0.3 exception is [ retained only for the Fuel Building Exhaust Gaseous Radioactivity Instrumentation and to note that the Specification 3.0.4 exception is only needed for the RCS Leakage Detection System instrumentation. The LC0 3.0.3 exception is not needed in ITS 3.3.7 or ITS 3.4.15 since Required ACTIONS are provided with the appropriate remedial measures for all combinations of channel failures, including shutdown actions, or reference is made to the associated plant system ITS for the systems affected by the inoperability of the radiation monitors. [The LCO 3.0.4 exception is
.. retained for the RCS Leakage Detection radiation monitors, as discussed in ITS 3.4.15: however, that exception is not needed for the Fuel Building Exhaust or Control Room Air Intake radiation monitors since their ACTION Statements allow continued operation for an unlimited period of time.]
3 07 LS 16 The Applicability for the Fuel Building Exhaust radiation monitors has been revised to read. "during 1 movement of irradiated fuel assemblies in the fuel [] l building" consistent with NUREG 1431. Rev. 1. [] 3 08 M Not applicable to Wolf Creek. See Conversion Comparison Table (Enclosure 38). 3 09 LS-24 Not applicable to Wolf Creek. See Conversion Comparison Table (Enclosure 3B). l 3 10 LG Not applicable to Wolf Creek. See Conversion I Comparison Table (Enclosure 38). fjeML] u 13 3 12 A Wolf Creek's use of the Applicability "All" includes MODES 1. 2. 3. 4. 5. 6. and movement of irradiated fuel ; assemblies. Therefore, this is considered as an I administrative change that is more specific. l l i WCGS-Description of changes to CTS 3H.3 23 S/ISR 7 l I I
i i l INSERT 3A-23a 0 3-01 The ACTION STATEMENT for an inoperable gaseous radioactivity monitor is modified to require that the inoperable channel be restored within 4 hours. If not restored continued operation is permitted (similar to the current TS allowance) provided the containment [ purge] valves are closed. The change is more restrictive or administrative in nature in that no time limits for the completion of any actions are specified in the current TS. l l l l l l l l l l l l l
CHANGE NUMBER HSlE DESCRIPTION ! 3 13 H Not applicable to Wolf Creek. See Conversion Comparison Table (Enclosure 38). l 3 14 LS-29 Not applicable to Wolf Creek. See Conversion Comparison Table (Enclosure 38). l 3 15 M Not applicable to Wolf Creek. See Conversion Comparison Table (Enclosure 38). 3-16 A Not applicable to Wolf Creek. See Conversion Comparison Table (Enclosure 3B). 3 17 A Not applicable to Wolf Creek. See Conversion _w -- Comparison Table (Enclosure 38). E 3A-2D i 4 01 R Not applicable to Wolf Creek. See Conversion ! Comparison Table (Enclosure 3B). 5 01 R Not applicable to Wolf Creek. See Conversion , Comparison Table (Enclosure 38). 6 01 R Not applicable to Wolf Creek. See Conversion _ Comparison Table (Enclosure 3B). NctiQ C.Fh er 5 % 3 , % W s @ 7 01 A The requirements f current TS Table [3.3 9] are
~
r fined on a f nctional basis, with Required
%"miuMuM CHAWELS OPEDRE] . rathe than on a per channel basis.
c,w bcader &mt 6, revded.b \
..guiggo ogwune cmshha consistent with NUREG - 1431. Rev. 1. The point at um ohrsedtoh 3.3tMe.5.y which the ACTION Statements are entered is unchanged.
7 02 M Not applicable to Wolf Creek. See Conversion Comparison Table (Enclosure 3B). 7-03 Not used. 7-04 LS-15 This change increases the number of days the Function (s) in current TS Table [3.3 9] and the [ ASP] controls may remain inoperable before imposing mode change requirements from 7 days to 30 days. This is based on operating experience and the low probability of an event that would require evacuation of the control room. This is consistent with NUREG-1431 Rev. 1 (ITS 3.3.4. Condition A). t 7 05 A Not applicable to Wolf Creek. See Conversion Comparison Table (Enclosure 3B). 7-06 LG The Readout Location and Total No. of Channels columns in current TS [ Table 3.3 9 and the wording addressing the Auxiliary Shutdown Panel controls in the LC0] have WCGS-Description ofchanges to CTS 3M.3 24 SAS/97
. _ . - . - - . . _ - - _ _ _ - - ~. - . _ - . - - - - .._ - - - .
f INSERT 3A-24 ! C23-01 \ l l 3-18 M Current TS LC0 3.3.3.1 contains an LC0 3.0.3 exception and Table 3.3- ! 6 ACTIONS [27 and 30] for the Fuel Building Exhaust Radiation l Monitors and the Control Room Air Intake Radiation Monitors do not contain any default actions if they aren't met. Therefore, the addition of a default action to immediately suspend movement of 1 irradiated fuel assemblies in the fuel building if ACTION [30] were not met for inoperable Fuel Building Exhaust Radiation Monitor (s) is a more restrictive requirement. Similarly, the addition of def ault l actions to bring the plant to MODE 5, when originally in MODES 1-4, I or to immediately suspend CORE ALTERATIONS and movement of irradiated fuel assemblies when in MODE 5 or 6 or during movement of irradiated 1 fuel assemblies if ACTION [27] were not met for inoperable Control Room Air Intake Radiation Monitor (s) is a more restrictive l requirement. These additions impose new and more stringent l limitations on the manner in which the plant must be operated. f (Q3-8S \ 3-19 LS-50 Not applicable to Wolf Creek. See Conversion Comparison Table (Enclosure 3B). l@3.5-19 } 3-20 LS-51 WCGS CTS Table 3.3-6, Functional Unit 1.a. Containment Atmosphere - Gaseous Radioactivity High (GT-RE-31&32). requires operability in "All" modes. ITS Table 3.3.6-1 (as modified by TSTF-161) requires this Function in Modes 1, 2, 3, 4, During CORE ALTERATIONS (footnote (a)) and During movement of irradiated fuel assemblies within containment (footnote (b)). The CTS has been revised to specify the l applicable modes for this function consistent with ITS Table 3.3.6-1,
- LC0 3.6.3 and LC0 3.9.4 This is acceptable since these are the only L conditions for a significant release of fission product radioactivity in containment. In Modes 5 and 6 without fuel handling in progress or when the purge valves are closed, the potential for a j radioactivity release is minimized and operator action is sufficient to ensure post accident offsite dosas are maintained within limits.
\ Q3.3-S2 l 3-21 LS-52 Not applicable to Wolf Creek. See Conversion Comparison' Table (Enclosure 38).
l 4 i
l CONVERSION COMPARISON TABLE - CURRENT TS 3/4.3 rage 23 or30 TECII SPEC CilANGE APPLICABILITY NUMBER DESCRIPTION DIABLO CANYON COMANCHE PEAK WOLF CREEK cal.LAWAY Yes Yes Yes Yes 3-06 ACTION [c] of current TS LCO 3.3.3.1 is revised to state A the Specification 3.0.3 exception is [ retained only for the Fuel Building Exhaust Gaseous Radioectivity Instrumentation and tn note that the Specification 3.0.4 exception is only needed for the RCS Leakage Detection System instrumentation]. 3-07 The Applicability for the Fuel Building Exhaust radiation Yes No-not in current Yes Yes LS-16 monitors has been revised to read. "during movement of TS. irradiated fuel assen611es in the fuel [] building ~ [ ]. Yes No No No 3 08 The DCPP CTS have been revised to include manual initiation M of the fuel handling building and automatic initiation of the control room pressurization System. These systems are not classified as ESF functions in the CTS. This revision incorporates the Actuation Logic. Master Relay and Slave Relay Tests included in NUREG - 1431. Rev. I for the CRVS and TADOT for the manual actuation of both systems. The CPSES Surveillance frequency for the performance of a No Yes No No 3 09 ' LS-24 CHANNEL OPERABILITY TEST for the radiation monitoring instrumentation channels would be extended from once per 31 days to once per 92 days. This change is consistent with the ITS. Yes No No No 3 10 The DCPP descriptive information related to the Required - LG Channels per normal intake is moved to the Bases. 3-11 The M ACTION STATEMENT for an inoperable gaseous No Yes k Ws No M radioactivity monitor is modified to require that the inoperable channel be restored within 4 hours. If not restored, continued operation is permitted (similar to the CTS allowance) provided the containment @ent-iecia6en] [Q 3-OI ) valves.are closed. The change is more restrictive or adninistrative in nature in that no time limits for the completion of any actions are specified in the CTS. SMS/97 WCGS-CONVERSION TABLE- CTS 3M.3
g lusERT 3@ 'AS CONVERSION COMPARISON TABLE - CURRENT TS 3/4.3 rage 25 or30 TECll SPEC CIIANGE APPLICABILITY NtJMBI'.R DESCRIITION DIABLO CANYON COMANCllE PEAK WOLF CREEK CALLAWAY 3 17 The CPSES restrictions on opening of the centainment No Yes rio No A pressure relief valves is moved from the Radia.'-- Monitoring Instrumentation Specification in the CTS to ITS 3.6.3 and the ITS Administrative Controls Section 5.5.1 for
%y the 00CM.
4-01 DCPP LCO 3.3.3.2, Movable Incore Detectors is relocated to Yes - see No No - already No R a licensee controlled document. attachment 21, page relocated per
- 11. Amenchent 89 5 01 DCPP LCO 3.3.3.3 Seismic Instrumentation is relocated to Yes - see LAR 95- No No - already No R a licensee controlled document. 07. relocated per Amendment 89 6-01 DCPP LCO 3.3.3.4. Meteorological Instrumentation, is Yes - see No No - already No R relocated to a licensee controlled document. attachment 21 page relocated per
- 13. Amendment 89 7-01 The requirements of current TS Table 3.3 9] are redefined No - already in _
Yes Yes _ Yes A on a functional basis with Requir The current rhe" M emnM c3*+MEL5 ORME!"cclum heano) which ACTION Statements are entered is uncha@ point at I C di I
.IQ ,org{C5gigAg"REggeg g g f*j 7-02 Shutdown requirement for inoperable Remote Shutdown No - already in Y b already No - already in M controls is changed from HOT STANDBY to HOT SHUTDOWN. current TS. current TS. current TS.
7-03 Not Used N/A N/A N/A N/A 7-04 This change extends Remote Shutdown A0T from 7 days to No - already in Yes Yes Yes LS 15 30 days. current TS. If' CGS-CONVERSION TABLE- CTS 3M.3 5/15/97
INSERT 3B-25 i TECH SPEC CHANGE APPLICABILITY , DIABLO CANYON COMMANCHE PEAK WOLF CREEK CALLAWAY [
- NUMBER DESCRIPTION 3-18 Addition of default actions if current TS No No Yes Yes M Table 3.3-6 ACTIONS [27 and 30] are not gq,,,y met.
This change replaces the DCPP CTS action Yes No No No j 3-19 LS-50 requirement to place the CRVS in the ; recirculation mode for an inoperable pgs-t!{} ! monitor with a rquirement to place the CRVS l in the presurization mode. 3-20 WCGS CTS Table 3.3-6, Functional Unit 1.a. No No Yes No ! LS-51 Containment Atmosphere - Gaseous {q3.311) Radioactivity High (GT-RE-31832), requires ; operability in "All" modes. ITS Table ; i 3.3.6-1 (as modified by TSTF-161) requires this Function in Modes 1, 2, 3, 4, During CORE ALTERATIONS (footnote (a)) and During movement of irradiated fuel assemblies within containment (footnote (b)). The CTS has been revised to specify the applicable modes for this function' consistent with ITS Table 3.3.6-1. LCO 3.6.3 and LCO 3.9.4. Yes No No No [ 3-21 Notes (a) and (b) in DCPP CTS Table 3.3-6 LS-52 are deleted since RM-45A and 45B are not {g13 61 { i installed and there is not intent to install them. t f e I t i e i
_ _ _ __ . _ _ = _ . _ _ . . _ _ _ _ _ _ ._ __ ADDITIONAL INFORMATION COVER SHEET ADDITIONAL INFORMATION NO: O 3-02 APPLICABILITY: DC, CP, WC, CA REQUEST: The requirements stipulated in ACTION [a] are moved to ITS Tables [3.3.7-1 and 3.3.8-1), with explicit direction contained in the ITS ACTIONS Bases. The 4 hour AOT for [ setpoint adjustment is eliminated. Comment: Evaluate how the CTS requirement changes for each use in the ITS. The 4-hour AOT for setpoint adjustment appears to be extended. How can it be that a TS is deleted (moved to the Bases) and the justification is more restrictive. This change should be documented based on how the iTS treats a channel with the setpoint not met. FLOG RESPONSE: DOC 3-02 M it revised to indicate that the CTS action that permitted adjusting the setpoint to within the limit within 4 hours is deleted. As discussed in the ITS B 3.3.7 Actions Bases, if the Trip Setpoint is less conservative than the tolerance specified by the calibration procedure, the channel must be declared inoperable immediately and the appropriate condition entered. DOC 3-02-M is revised to state:
" CTS 3.3.3.1, Action [a] is revised to delete the delete the 4 hour allowance to adjust the radiation monitoring channel Alarm / Trip Setpoint if the setpoint value has been exceeded. The CTS allowed a 4 hour window in which to adjust the Trip Setpoint to within limits before declaring the channel inoperable and taking the appropriate Action specified in the Table. NUREG-1431 requires declaring the channelinoperable immediately and entering the appropriate Condition if the Trip Setpoint is less conservative than the tolerance specified in calibration procedures.
The proposed change is considered a more restrictive change which reduces plant operational flexibility." ATTACHED PAGES: Encl.3A 22
CHANGE NUMBER NSlE DESCRIPTION Channels" column. With separate Condition entry per pump. ITS 3.3.2 Condition J would allow one inoperable channel per pump as long as it is tFipped within I hour. This would allow a second channel on the other pump to be inoperable for up to 1 hour prior to the l commencement of any additional action. i.e. either placing the second channel in trip which may or may not result in an auxiliary feedwater actuation signal (AFAS) for the motor-driven auxiliary feedwater pumps l or reducing power. Placing the second channel on the other pump in trip.will result in an AFAS only if the second channel is in the same separation group as the channel already in trip (as depicted in USAR Figure 7.3 1 sheet 2). If the two channels are in different , separation groups, no AFAS will be initiated and continued operation will be permitted. 2-47 M Not applicable to Wolf Creek. See Conversion Comparisca Table (Enclosure 38). 2 48 LS 28 Not applicable to Wolf Creek. See Conversion Comparison Table (Enclosure 3B). 3 01 A The requirements of this current TS [3.3.3. Table 3.3-6] are moved to separate specifications in the improved TS. The RCS Leakage Detection requirements are moved to improved TS 3.4.15. [The Fuel Building requirements are moved to improved;TS 3.3.8.] The Control Room i requirements are moved to improved TS 3.3.7. [The l Containment Atmosphere requirements are moved to ITS ! 3.3.6.] o s.o2. 1 < 3-02 M h equir nts pulated ACTION are mo t ITS Ta [3. 1 and 3 . 1], wi explic
. dir ion tained i he ITS IONS B s. 4 ,
ur A0T or set adjus nt is eli inated. w WS 3A-3-03 LG The requirements associated with the criticality monitors are moved to a licensee controlled document. These monitors are required by 10CFR70.24: however. there is no requirement for [them] to be in the Technical Specifications [nor do they meet any of the four criteria for inclusion in the ITS]. Since Part 70 is invoked in the Operating License, these monitors will be retained in the plant design. om] 3 04 M Not applicable to Wolf Creek. See Conversion Comparison Table (Enclosure 3B). l WCGS-Description ofchanges to CTS 3M.3 22 S/15/97
I l I INSERT 3A-22a 0 3-02 l l CTS 3.3.3.1. Action [a] is revised to delete the 4 hour allowance to adjust the radiation monitoring channel Alarm / Trip Setpoint if the setpoint value has been exceeded. The CTS allowed a 4 hour window in which to adjust the Trip Setpoint to within limits before declaring the channel inoperable and taking the appropriate Action specified in the Table. NUREG-1431 requires declaring the ' channel inoperable immediately and entering the appropriate Condition if the Trip l Setpoint is less conservative than the tolerance specified in calibration procedures. The proposed change is considered a more restrictive change which reduces plant operational flexibility. I
I INSERT 3A-22b j 2-49 A Not used. -
}os.541 } [
2-50 LG The CTS [##] not to Table [3.3-3] is revised to move the descriptive material related to the automatic blocking of the interlock to the , ITS 3.3.2 Bases. Moving these details does not affect the i Applicability or the Operability of the Function which will continue i to protect the health and safety of the public. l 2-51 LG Not applicable to Wolf Creek. See Conversion Comparison Tabl I (Enclosure 3B). ! IQ3.5-K\ ! 2-52 A Not applicable to Wolf Creek. See Conversion Comparison Table ; (Enclosure 38). 2-53 LG Not applicable to Wolf Creek. See Conversion Comparison labljQ15-2e} + (Enclosure 3B). le 2-o2.(s.103 2-54 M Although 00C 2-02-A characterizes the deletion of ACTION b.2 from LC0 l 3.3.2 as administrative since the change is consistent with current plant practice, since the trip setpoint adjustment is done for a ! majority of analog _ channels with_ the channel in trip and therefore : declared inoperable (i.e., no different in effect than entering ACTION b.2). there could be scenarios where ACTION b.1 would present l another alternative. For instance, since containment pressure High-3 has an installed bypass design feature, ACTION b.1 could allow trip I setpoint adjustments in bypass. This would eliminate logging ! requirements for equipment out of service. Since this change is ! eliminating ACTION b.1 as an allowed recourse, this is a more restrictive change. {Q2.41M i 2-55 H Not applicable to Wolf Creek. See Conversion Comparison Table , (Enclosure 3B). ! Q2.-ce(13M 2-56 LS-48 Not applicable to Wolf Creek. See Conversion Comparison Table (Enclosure 3B). l os.s-s2- l ; 2-57 A Current TS Table 3.3-3 Functional Unit 3.c.2), Containment Purge Isolation Automatic Actuation Logic and Actuation Relays (SSPS) and Functional Unit 9.b. Control Room Isolation - Automatic Actuation Logic and Actuation Relays (SSPS), and associated surveillance requirements are deleted. The change is acceptable since the purpose of SSPS for the associated Functions 3.c.2) and 9.b is to generate a Containment Phase A isolation signal which is redundant to CTS Table 3.3-3, Functional Unit 3.c.4) and 9.d. The B0P-ESFAS processes signals from the SSPS, signal processing equipment, to actuate certain ESF equipment. A Containment Phase A Isolation signal (CIS-A) is generated within the SSPS and provides an output signal to the B0P-ESFAS as an actuating input for initiating a Containment Purge Isolation Signal (CPIS) and Control Room Ventilation Isolation Signal
~
W INSERT 3A-22b (continued) lois Etl (CRVIS). Any combination of fai]ures which could degrade or prevent the CIS- A f rom reaching the BOP-ESFAS would require entry into CTS Table 3.3-3, Functional Unit 3.a.2), Action Statement 14. Action l Statement 14, as revised by DOC 2.23-A, requires restoring an ! inoperable channel to OPERABLE status within 6 hours or place the plant in MODE 3 within 12 hours and MODE 5 in 42 hours. Action Statement 14 is revised to require that with function 3.a.2) inoperable, immediately take the ACTIONS of Specification 3.6.3.
' Taking the Actions in Specification 3.6.3 is consistent with CTS l Action Statement 17, as revised by DOC 2-05-M, to maintain the containment purge supply and exhaust valves closed. Action Statement 26 for Functional Unit 9.b requires restoring the inoperable channel to OPERABLE status.within 7 days (as revised from 48 hours per DOC 2-16-LS-12) or initiate and maintain operation of the CREVS. Deletion of Function 9.b and associated Action Statement is acceptable due to 1 the shorter restoration time of Action Statement 14. The proposed change is considered administrative since the change only clarifies / reformats an existing requirement and does not affect any operating limits or how the plant is operated.
k5.302} 2-58-A Amendment No. 117 dated May 28, 1998, added a new Action Statement to CTS 3/4.3.2. Table 3.3-3. Functional Unit 7.b. , Refueling Water Storage Tank Level (RWST) - Low-Low Coincident with Safety Injection.
- New Action Statement 30 replaces Action 16, and would be entered for an inoperable RWST analog channel, allows for 6 tours to. place an inoperable RWST analog channel in a bypassed condition and allows for surveillance testing of an additional channel of Functional Unit 7.b.
by placing the channel in a tripped condition for up to 4 hours. This change is considered administrative since it adds a new Action Statement previously approved by the NRC. 1
INSERT 3A-22c 0 3-03 . [For WCGS and Callaway, Section 9.1 of the bSAR/FSAR indicates that the design of the spent fuel storage racks, new fuel storage racks, the fuel handling equipment, and the administrative controls are such that subtriticality will be maintained under normal and accident conditions.] As such, the requirements associated with the criticality functional unit is not required to be in the TS to provide adequate protection of the public health and safety. The licensee i controlled documents containing the moved requirements will be maintained using the provisions of 10 CFR 50.59. Therefore, the descriptive information that has been moved continues to be maintained in an appropriately controlled manner." i t I
~
l 1 e 4 i i l
ADDITIONAL INFORMATION COVER SHEET ADDITIONAL INFORMATION NO: O 3-03 APPLICABILITY: DC, WC, CA l REQUEST: The requirements associated with the criticality monitors are moved to a licensee controlled document. These monitors are required by 10 CFR 70.24; however, there is no requirement for [them] to be in the technical specifications [nor do they meet any of the four criteria for inclusion in the ITS). l l Comment: It is not clear that DOC 03-03-LG is referring to a change to the CTS. This DOC appears to relate to notes *a_ and *b) which appear to be already in the CTS. How does DOC 03-03-LG related to the tech spec conversion? If notes (a) and (b) are ! changes to the CTS, they need to be identified as such and more fully justified. If changes are moved outside of TS to a licensee controlled document then provide a
" relocated" evaluation for changes not meating 10 CFR 50.36.
FLOG RESPONSE: For WCGS and Callaway, DOC 03-03-LG is specifically related to CTS Table 3.3-6, Functional Unit 2.b., Criticality High Radiation Level, and associated Table notation "*" The change (DOC 03-03-LG) to move the criticality monitoring functional unit and associated requirements to the USAR/FSAR. DOC 03-03-LG is revised to add the following information:
"[For WCGS and Callaway, Section 9.1 of the USAR/FSAR indicates that the design of the spent fuel storage racks, new fuel storage racks, the fuel handling equipment, and the administrative controls are such that subcriticality will be maintained under normal and accident conditions.]
l As such, the requirements associated with the criticality functional unit is not required to be in the TS to provide adequate protection of the public health and safety. The licensee controlled documents containing the moved requirements will be maintained using the provisions of 10 CFR 50.59. Therefore, the descriptive information that has been moved continues to be maintained in an appropriately controlled manner." For DCPP, the requirements of notes [* and **] of CTS 3.3.3.1 are directly related to their function as " criticality monitors" as required by 10 CFR 70.24. The criticality monitor requirement is removed, but the monitors are retained in the TS since these monitors also function to transfer the Fuel Handling Building Ventilation system to the lodine Removal mode of operation. Note [**] is revised to incorporate the applicability requirements associated with the movement of irradiated fuel in the fuel handling building that have always existed, but were enveloped by the criticality monitor requirement. ATTACHED PAGES: l l Encl. 3A 22 1 7 l
CHANGE Nt#EER !GC DESCRIPTION . Channels" column. With separate Condition entry per pump. ITS 3.3.2 Condition J would allow one inoperable channel per pump as long as it is tFipped within 1 hour. This would allow a second channel on the other pump to be inoperable for up to 1 hour prior to the commencement of any additional action. i.e. either placing the second channel in trip which may or may not result in an auxiliary feedwater actuation signal (AFAS) for the motor driven auxiliary feedwater pumps or reducing power. Placing the second channel on the other pump in trip will result in an AFAS only if the second channel is in the same separation group as the channel already in trip (as depicted in USAR Figure 7.3-1 sheet 2). 'r 'he two channels are in different separation groups, .% AFAS will be initiated and continued operation will be permitted. 2 47 H Not applicable to Wolf Creek. See Conversion Comparison Table (Enclosure 38). 2-48 LS 28 Not applicable to Wolf Creek. See Conversion Comparison Table (Enclosure 3B). 3-01 A The requirements of this current TS [3.3.3, Table 3.3-6] are moved to separate specifications in the improved TS. The RCS Leakage Detection requirements are moved to improved TS 3.4.15. [The Fuel Building requirements are movedtoimproved.TS3.3.8.] The Control Room requirements are moved to improved TS 3.3.7. [The Containment Atmosphere requirements are moved to ITS 3.3.6.] m o 3 o2.1 h equir 3 02 H nts pulated ACTION are mo t ITS Ta [3. -1 and 3 . -1], wi explic' dir ion tained i he ITS IONS B s. 4 ur A0T or set nt is eli inated. adjus w 145 3A 2-3-O'; LG The requirements associated with the criticality monitors are moved to a licensee controlled document. These monitors are required by 10CFR70.24: however. _ there is no requirement for [them] to be in the Technical Specifications [..or do they meet any of the four criteria for inclusion in the ITS). Since Part 70 is invoked in the Operating License, these monitors will be retaincd in the plant design. (st 34 2 ]2 sos.ca l 3 04 H Not applicable to Wolf Creek. See Conversion Comparison Table (Enclosure 3B). WCGS-Description ofchanges to CTS 3N.3 22 S/1SJ97
INSERT 3A-22a 0302 CTS 3.3.3.1, Action [a] is revised to delete.the 4 hour allowance to adjust the radiation monitoring channel Alarm / Trip Setpoint if the setpoint value has been exceeded. The CTS allowed a 4 hour window in which to adjust the Trip Setpoint to within limits before declaring the channel inoperable and taking the appropriate Action specified in the Table. NUREG-1431 requires declaring the channel inoperable immediately and entering the appropriate Condition if the Trip Setpoint is less conservative than the tolerance specified in calibration procedures. The prcposed change is considered a more restrictive change which reduces plant operational flexibility. I l l i 1 ! l l I l i i
)
l i INSERT 3A-22b f 4 2-49 A Not used. - I l o u 4 3. } l 2-50 LG The CTS [##] not to Table [3.3-3] is revised to move the descriptive material related to the automatic blocking of the interlock to the l ITS 3.3.2 Bases. Moving these details does not affect the ' Applicability or the Operability of the Function which will continue to protect the health and safety of the public. 2-51 LG Not applicable to Wolf Creek. See Conversion Comparison Tabl eGa.3 M J (Enclosure 3B). Not applicable to Wolf Creek. See Conversion Comparison Table IQts-WI 2-52 A l- (Enclosure 3B). , 2-53 LG Not applicable to Wolf Creek. See Conversion Comparison TablMN $ ! l (Enclosure 3B). I i lo2 o2.(s.sM ! 2-54 M Although DOC 2-02-A characterizes the deletion of ACTION b.2 f rom LC0 3.3.2 as administrative since the change is consistent with current plant practice, since the trip setpoint adjustment is done for a l majority of analog channels with the channel in trip and therefore i declared inoperable (i.e., no different in effect than entering ! ACTION D.2). there could be scenarios where ACTION b.1 would present i ! another alternative. For instance, since containment pressure High-3 l has an installed bypass design feature, ACTION b.1 could allow trip ! setpoint. adjustments in bypass. This would eliminate logging l requirements for equipment out of service. Since this change is eliminating ACTION b.1 as an allowed recourse, this is a more restrictive change. lQ 2.41(EM l 2-55 M Not applicable to Wolf Creek. See Conversion Comparison Table ! (Enclosure 3B). (Q2.-ce(53)_ 2-56 LS-48 Not applicable to Wolf Creek. See Conversion Comparison Table (Enclosure 3B). los.s.32. [ 2-57 A Current TS Table 3.3-3 Functional Unit 3.c.2), Containment Purge Isolation Automatic Actuation Logic and Actuation Relays (SSPS) and Functional Unit 9.b, Control Room Isolation - Automatic Actuation i logic and Actuation Relays (SSPS), and associated surveillance requirements are deleted. The change is acceptable since the purpose of SSPS for the associated Functions 3.c.2) and 9.b is to generate a Containment Phase A isolation signal which is redundant to CTS Table 3.3-3, Functional Unit 3.c.4) and 9.d. The B0P-ESFAS processes l signals from the SSPS, signal processing equipment, to actuate l } certain ESF equipment. A Containment Phase A Isolation signal (CIS-A) ! is generated within the SSPS and provides an output signal to the j 4 BOP-ESFAS as an actuating input for initiating a Containment Purge i Isolation Signal (CPIS) and Control Room Ventilation Isolation Signal ]- 1 { ! l
__ _ _ _. _ .. _ . _ __ _ . . _ . . _ _ . _ . _ . _ _ _ _ _ _ = i i i INSERT 3A-22b (continued) (cuLs 511
.(CRVIS). Any combination of failures which could degrade or prevent j the CIS-A from reaching the BOP-ESFAS would require entry into CTS 1 Table 3.3-3 Functional Unit 3.a.2) Action Statement 14. Action ,
Statement 14. as revised by DOC 2.23-A. requires restoring an
- inoperable channel to OPERABLE status within 6 hours or place the plant in MODE 3 within 12 hours and MODE 5 in 42 hours. Action Statement 14.is revised to require that with Function 3.a.2) i inoperable, immediately take the ACTIONS of Specification 3.6.3. .
Taking the Actions in Specification 3.6.3 is consistent with CTS ) Action Statement 17. as revised by DOC 2-05-M. to maintain the containment purge supply and exhaust valves closed. Action Stateraent 26 for Functional Unit 9.b requires restoring the inoperable channel to OPERABLE status within 7 days (as revised from 48 hours per DOC 2-16-LS-12) or initiate and maintain operation of the CREVS. Deletion of Function 9.b and associated Action Statement is acceptable due to the shorter restoration time of Action Statement 14. The proposed change is considered administrative since the change only clarifies / reformats an existing requirement and does not affect any operating limits or how the plant is operated.
%we> \
2-58-A Amendment No. 117 dated May 28, 1998, added a new Action Statement to CTS 3/4.3.2. Table 3.3-3. Functional Unit 7.b., Refueling Water Storage Tank Level (RWST) - Low-Low Coincident with Safety Injection.
. New Action Statement 30 replaces Action 16. and would be entered for an inoperable' RWST analog channel, allows for 6 hours to place an inoperable RWST analog channel in a bypassed condition and allows for surveillance testing of an additional channel of Functional Unit 7.b.
by placing the channel in a tripped condition for up to 4 hours. This change is considered administrative since it adds a new Action Statement previously approved by the NRC. l l l i i
4 INSERT 3A-22c 0 3-03 [For WCGS and Callaway, Section 9.1 of the USAR/FSAR indicates that the design of the spent fuel storage racks, new fuel storage racks, the fuel handling equipment, and the administrative controls are such that subtriticality will be maintained under normal and accident conditions.] As such, the requirements associated with the criticality functional unit is not required to be in the TS to provide adequate protection of the public health and safety. The licensee controlled documents containing the moved requirements will be maintained using the provisions of 10 CFR 50.59. Therefore, the descriptive information that has been moved continues to be maintained in an appropriately controlled manner." k l
l I ADDITIONAL INFORMATION COVER SHEET ADDITIONAL INFORMATION NO: O 3-05 APPLICABILITY: DC, CP, WC, CA REQUEST: ACTION Statement [38) for the [ Control Room Air intake) [and ACTION Statement [30) for the [ Fuel Building Exhaust)) radiation monitors have extended Completion Times, from [72 hours) to 7 days for one required channel inoperable. Comment: Insufficient information is provided to justify extending the allowed outage time for one CRVS channelinoperable from [1][48)[72] hours to 7 days. If the system arrangement is such that each instrument channel is dedicated to a single CRVS train (one-out-of-one starts one train), then the effect of a single inoperable instrument channel is similar to that of an inoperable mechanical train and the extended AOT may be acceptable. If, however, the two channels are used in a one-out-of-two logic start both CRVS channels, a single inoperable instrumentation channel degrades the operability of both mechanical trains and the justification provided for the 7 day AOT is not germane. FLOG RESPONSE: The response to this comment is addressed under Comment Number Q 2-16 for Callaway, CPSES and WCGS. The DCPP control room is common to both units. The normal air intakes are separate, but are in close proximity to each other. There is one train of control room ventilation for each unit. The pressurization air intakes are at opposite ends of the turbine building. There are two radiation monitors at each normal air intake either of which will initiate the opposite Units pressurization system. The system is designed so that d n#Ma is detected at one units normal air intake due to a LOCA or other cesign basis event, the system starts the opposite units pressurization fans which take suction from the end of the opposite units turbine building. With this arrangement, a single monitor can be out of service without effecting the operability of the ventilation train. Loss of the second required monitor renders that train of control room pressurization inoperable. The loss of l the radiation monitors for a single train only effects that train, thus it would ) be similar to a mechanical failure rendering a single train inoperable. l Since the loss of the required radiation monitor would be equivalent to a mechanical failure, the allowed outage time of 7 days permitted by CTS 3.7.5.1 and LCO 3.7.10 of NUREG-1431for inoperability of a single train of ventilauon is appropriate for loss of one trains required radiation monitor. LS14 has been revised to include this system description and justification for'ne 7 day A0T.
!;i addition to the above, DCPP submitted a version of NSHC LS14 authored by one of the other FLOG members. The corrected copy is attached.
ATTACHED PAGES: None 4
ADDITIONAL INFORMATION COVER SHEET ADDITIONAL INFORMATION NO: O 7-01 APPLICABILITY: CP, CA, WC, DC REQUEST: The requirements of current TS Table [3.3-9] are redefined on a functional basis with Required Channels. The point at which ACTION Statements are entered is unchanged. Comment: { [CP] Revise ITS T3.3.9-1 column to " REQUIRED NO. OF FUNCTIONS" FLOG RESPONSE: 1) The generic NSHC "A" (administrative changes) has been revised to better define administrative changes.
- 2) The CTS table markup has been revised as necessary to provide the correct column titles.
4 DOC 7-01 A is revised to read as follows: The requirements of current TS Table [3.3-9] are redefined on a functional basis, with Required Functions, rather than on a per channel basis, consistent with other Section 3.3 tables in NUREG-1431 Rev.1. The point at which the ACTION Statements are entered is unchanged. [The
- MINIMUM CHANNELS OPERABLE" column header format is revised to
- REQUIRED CHANNELS" censistent with other ITS Section 3.3 tables.]
The conversion comparison table (Enclosure 3B) is revised as follows to be consistent with DOC 7-01 A: The requirements of current TS Table [3.3-9] are redefined on a functional basis with Required Functions. The point at which ACTION Statements are entered is unchanged. [The
" MINIMUM CHANNELS OPERABLE" column header format is revised to " REQUIRED CHANNELS" consistent with other ITS Section 3.3 tables.]
See also the response to Comment Number O 3.3-24 for CPSES, WCGS ard Callaway and O 3.3-128 for DCPP. ATTACHED PAGES: Encl. 2 3-44 Encl.3A 24 Encl. 38 25 Encl. 4 6
TABLE 3 3-9 Fiundiim 7-os-A_ REMOTE SHUTDOWN AO*"TO !C b R i -v__ _ _ _ M7-oi1 [@Mr= l L l-ok-it 7-06-LG 7-01-A E.EQUIRED l RSADQUT Gh CHANkELS @ / l (lpmg) Q '7-b I } LOC.^'!OM C" ^ *!SL S 0"S"^.BL .JalCPJ0$66 7-ol-A
- 1. RCS Pressure-Wide Range AGRt 2 1 -- _
- 2. Reactor Coolant Temperature-Cold Leg pg.3.s ED] ASP ( 1
- 3. Source Range. Neutron Flur ASAK 2 1
- 4. Reactor Trip Breaker indication M " rip 5 :cher 1/ trip breaker
- 5. Reactor Coolant-Temperature ASPX 2 1 Hot Leg
- 6. Reactor Coolant Pump Breakers W 4Jpump 1/ pump
- 7. Pressurizer Pressure ASPX 4 1
- 8. Pressurizer Level ASRK 2 1
- 9. Steam Generator Pressure ASRK l':t- C r. 1/stm. gen.
- 10. Steam Generator Level ASidC l':t- C:r. 1/stm. gen.
- 11. Auxiliary Feedwater Flow Rate ASP)( 1
- 12. Auxiliary Feedwater Suction ASO( 2 1 Pressure l
" ::!!:r; Shutt: ":r.:!.
"" r r7:!p S;!!:h; r . 7-06-LG l
~*?2 S "/ S::!!:h;:: .
I #Not required OPERABLE in MODE 1 or in MODE 2 above P-6 Setpoint. l l l l 4 WOLF CREEK- UNIT 1 3M 3-44 Amendment No. 89 Mark-up ofCTS 3M. 3 S/l$37 l
CHANGE filt!Bf3 liSiC DESCRIPTION 3-13 N Not applicable to Wolf Creek. See Conversion Comparison Table (Enclosure 38). 3 14 LS 29 Not applicable to Wolf Creek. See Conversion Comparison Table (Enclosure 3B). 3 15 M Not applicable to Wolf Creek. See Conversion Comparison Table (Enclosure 3B). 3-16 A Not applicable to Wolf Creek. See Conversion Comparison Table (Enclosure 3B). 3 17 A Not applicable to Wolf Creek. See Conversion Comparison Table (Enclosure 38). AT 3A-_2D 4 01 -R Not applicable to Wolf Creek. See Conversion Comparison Table (Enclosure 3B). 5 01 R Not applicable to Wolf Creek. See Conversion Comparison Table (Enclosure 3B). 6 01 R Not applicable to Wolf Creek. See Conversion Comparison Table (Enclosure 3B). (WritiQ Cether SecMn 5.3)Ws @ 4g 7 01 A _ The requirements f current TS Table [3.3 9] are gMghAwas oPERAN.E" fined on a f DCtional basis, with Required 1 aw header formt G, revddLb . panfef). rathe than on a per channel basis, , ggg CHAWML " CMSMed Consistent with NUREG - 1431, Rev. 1. The point at 1 g% other set. hob 3.'ataMes.Q whichvthe ACTION Statements are entered is unchanged. 7 02 M Not applicable to Wolf Creek. See Conversion Comparison Table (Enclosure 3B). 7-03 Not used. 7-04 LS 15 This change increases the number of days the Function (s) in current TS Table [3.3 9] and the [ ASP] controls may remain inoperable before imposing mode change requirements from 7 days to 30 days. This is based on operating experience and the low probability of an event that would require evacuation of the control room This is consistent with NUREG-1431 Rev. 1 (TT5 a 3 '. Condition A). 7-05 A Not .401' Alt; to Wolf Creek. See Conversion Coner wo Table (Enclosure 3B). 7-06 LG Pw Resuout Location and. Total No. of Channels columns ir merent TS [ Table 3.3-9 and the wording addressing the Auxiliary Shutdown Panel controls in the LC0] have WCGS-Description ofchanges to CTS 3M.3 N S/1587 l
1 INSERT 3A-24 43+ol k 3-18 M Current TS LC0 3.3.3.1 contains an LC0 3.0.3 exception and Table 3.3- ; 6, ACTIONS [27 and 30] for the Fuel Building Exhaust Radiation ' Monitors and the Control Room Air Intake Radiation Monitors do not contain any default actions if they aren't met. Therefore, the addition of a default action to immediately suspend movement of
- irradiated fuel assemblies in the fuel building if ACTION [30] were not met for inoperable Fuel Building Exhaust Radiation Monitor (s) is a more restrictive requirement. Similarly, the addition of default l
actions to bring the plant to MODE 5, when originally in MODES 1-4, or to immediately suspend CORE ALTERATIONS and movement of irradiated fuel assemblies when in MODE 5 or 6 or during movement of irradiated fuel assemblies if ACTION [27] were not met for inoperable Control Room Air Intake Ra'diation Monitor (s) is a more restrictive requirement. These additions impose new and more stringent , limitations on the manner in which the plant must be operated. I i i l (Q3-IS \ 3-19 LS-50 Not applicable to Wolf Creek. See Conversion Comparison Table (Enclosure 38). lG3.3-79} ! 3-20 LS-51 WCGS CTS Table 3.3-6, Functional Unit 1.a. Containment Atmosphere - Gaseous Radioactivity High (GT-RE-31&32), requires operability in "All" modes. ITS Table 3.3.6-1 (as modified by TSTF-161) requires this Function in Modes 1, 2, 3, 4, During CORE ALTERATIONS (footnote (a)) and During movement of irradiated fuel assemblies within containment (footnote (b)). The CTS has been rev' sed to specify the applicable modes for this function consistent with ITS Table 3.3.6-1. LCO 3.6.3 and LCO 3.9.4. This is acceptable since these are the only conditions for a significant release of fission product radioactivity in containment. In Modes 5 and 6 without fuel handling in progress or when the purge valves are closed, the potential for a radioactivity release is minimized and operator action is sufficient to ensure post accident offsite doses are maintained within limits.
\ Q 3.3-8 2. l 3-21 LS-52 Not applicable to Wolf Creek. See Conversion Cocparison' Table (Enclosure 38).
i 4 I I i i
g luSERT 30 25 CONVERSION COMPARISON TABLE - CURRENT TS 3/4.3 P.ge25or30 TECII SPEC CHANGE APPLICABILITY yNUMBER DESCRIPTION DIABLO CANYON COMANCllE FEAK WOLF CREEK CALLAWAY 3-17 The CPSES restrictions on opening of the containment No Yes No No A pressure relief valves is moved from the Radiation Monitoring Instrumentation Specification in the CTS to ITS 3.6.3 and the ITS Administrative Controls Section 5.5.1 for
%,y the 00CM.
4 01 DCPP LCO 3.3.3.2. Movable Incore Detectors. is relocated to Yes - see No No - already No R a licensee controlled document. attar %ent 21. page relocated per
- 11. Amendnent 89 5 01 DCPP LCO 3.3.3.3. Seismic Instrumentation, is relocated to Yes - see LAR 95- No No - already No R a licensee controlled document. 07. relocated per Amendment 89 6 01 DCPP LCO 3.3.3.4. Meteorological Instrumentation. is Yes - see No No - already No R relocated to a licensee controlled document. ettachment 21 page relocated per
- 13. Amendment 89 7 01 The requirements of current TS Table 3.3 9] are redefined No already in _
Yes Yes _ Yes A on a functional basis with Requir . The point at current "The*M ; wuesc3%MuS oeuh6W"cclumn heada) I"#I I gd,C5di[1"gMQ",iTffM,"*f No - already in which ACTION Statements are entered is trThange ., %dL) -
~ - + _
~ --
7 02 Shutdown requirement for inoperable Remote Shutdown No - already in _ Yes No already in M controls is changed from HOT STANDBY to HOT SHUTDOWN current TS. current TS. current TS. 7-03 Not Used N/A N/A N/A N/A . 7-04 This change extends Remote Shutdown A0T from 7 days to No - already in Yes Yes Yes LS 15 30 days. current TS. t WCGS-CONYERSION TABLE- CTS 3M.3 5/l5A7 _ _ _ . _ _ _ _ _ ___ ___..___.. _______. _ _._._.__ _ _ _____.___________ _ _.-_ _ __ _ _ _ _ _ _ ___ _ _ _ _ __ ____m__
INSERT 3B-25 TECH SPEC CHANGE APPLICABILITY NUMBER DESCRIPTION DIABLO CANYON COMMANCHE PEAK WOLF CREEK CALLAWAY 3-18 Addition of default actions if current TS No No Yes Yes l M Table 3.3-6 ACTIONS [27 and 30] are not }qs-6(j t met. 3-19 This~ change replaces the DCPP CTS action Yes No No No LS-50 requirement to place the CRVS in the , recirculation mode for an inoperable p[s-isrj l monitor with a rquirement to place the CRVS :! in the presurization mode. t 3-20 WCGS CTS Table 3.3-6, Functional Unit 1.a. No No Yes No l LS-51 Containment Atmosphere - Gaseous 193.3-71) Radioactivity High (GT-RE-31&32), requires . operability in "All" medes. ITS Table l 3.3.6-1 (as modified by TSTF-161) requires : this Function in Modes 1, 2, 3, 4. During l CORE ALTERATIONS (footnote (a)) and During f movement of irradiated fuel assemblies ]; within containment (footnote (b)). The CTS has been revised to specify the applicable modes for this function consistent with ITS ; Table 3.3.6-1. LCO 3.6.3 and LCO 3.9.4. i 3-21 Notes (a) and (b) in DCPP CTS Table 3.3-6 Yes No No No l LS-52 are deleted since RM-45A and 45B are not (gas-a1 { j installed and there is not intent to install them. j r i I
III. GENERIC NO SIGNIFICANT HAZARDS CONSIDERATIONS "A" 10 CFR 50.92 EVALUATION FOR , ADMINISTRATIVE REFORMATTING AND REWORDING i M
\ Q 1-oh roposed TS revision includes reformatting and rewording the(Egdinp%) @
requirements in accordance with the NtWARC Technical Specification Writei's Guide and the improved Standard Technical Specifications in NUREG 1431. This is intended to make the TS more readily understandable to plant operators and other users. Application of the Writer's Guide will also assure consistency between specifications. During this reformatting and rewording process, no technical changes (either actual or l interpretational) were made to the TS unless they were identified and justified. This proposed TS change has been evaluated and it has been determined that it involves no significant hazards consideration. This determination has been performed in accordance with the criteria set forth in 10 CFR 50.92(c) as quoted below:
"The Comission may make a final determination, pursuant to the procedures in 50.91. that a proposed amendnent to an operating license for a facility licensed under 50.21(b) or 50.22 or for a testing facility involves no significant hazards consideration, if operation of the facility in accordance with the proposed amendnent would not:
1 Involve a significant increase in the probability or consequences of an l accident previously evaluated: or l
- 2. Create the possibility of a new or different kind of accident from ays i accident previously evaluated; or
- 3. Involve a significant reduction in a margin of safety."
The following evaluation is provided for the three categories of the significant hazards consideration standards:
- 1. Does the change involve a significant increase in the probability cr consequences of an accident previously evaluated?
l The proposed change involves reformatting and rewording of the current Technical l Specifications. The reformatting and rewording process involves no technical changes to the current Technical Specifications. As such, this Aamm.%hh ck~gu, m. TS c%s %.ua mA affed opaQ \'. ~~% or w e a wkick <w.yL M &> opw>te A. Le .g., ss-p.n. re- a ram 4 %.
-rs , cw.tia 4 # Ts www app 1Lc4 L&
Ms.~ vasm&s., e,%wo<A ekw ;tooracaqoek los expimA. 4A M
- kgqaa3g J.yor W .apac;4- w m b-> Q J C Ts.
WCGS- NSHCs - CTS 3M.2 6 5/158 7
i ADDITIONAL INFORMATION COVER SHEET ! ADDITIONAL INFORMATION NO: O 7-04 APPLICABILITY: WC, CA REQUEST: This change extends the Remote Shutdown AOT from 7 days to 30 days. . Comment: {WC, CA} Revise 7-04 to include a synopsis of the safety analysis , discussion from IPEEE Report, ULNRC-3232, dated June 30,1995 which justify l extension of the function repair times to 30 days. r i ( . FLOG RESPONSE. ULNRC-3232 is the Callaway-specific IPEEE report that demonstrated no impor'ance to remote shutdown equipment irrespective of their allowed outa'Je times. Since this reference is not generic and not needed to support the DOC, it has been deleted. ATTACHED PAGES: i Encl. 4 46 l I ' I ll I 1 I
l IV. SPECIFIC NO SIGNIFICANT HAZARDS CONSIDERATIONS NSHC LS-15 10 CFR 50.92 EVALUATION FOR TECHNICAL CHANGES THAT IMPOSE LESS RESTRICTIVE REQUIREMENTS WITHIN THE TECHNICAL SPECIFICATIONS The allowed outage time (A0T) for ACTIONS a and b of current TS LC0 3.3.3.5 is increased from 7 days to 30 days. As discussed in NUREG 1431 Rev.1. this is based on 4 operating experience and the low probability of an event that would require evacuation of the control room during the conditions covered by the A0T. The extended A0T will not increase the core damage frequencies reported.QJMicperr4)K5pf ttgAPEEE g gj Rep rf.JLNRC Mdated-700s-30.A] The proposed TS change has been. evaluated and it has been determined that it involves no significant hazards consideration. This determination has been performed in accordance with the criteria set forth in 10 CFR 50.92(c) as quoted below:
*The Corwnission may make a final determination. pursuant to the procedures in 50.91, that a proposed amendbent to an operating license for a facility licensed under 50.21(b) or 50.22 or for a testing facility involves no significant hazards consideration, if operation of the fac11ity in accordance with the proposed amendnent would not:
- 1. Involve a significant increase in the probability or consequences of an accident previously evaluated: or
- 2. Create the possibility of a new or different kind of accident frorn any accident previously evaluated; or
- 3. Involve a significant reduction in a margin of safety. "
The following evaluation is provided for the three categories of the significant , 1 hazards consideration standards:
- 1. Does the change involve a significant increase in the probability or consequences of an accident previously evaluated?
Overall protection system performance will remain within the bounds of the previously performed evaluations since no hardware changes are proposed. The proposed change adds a relaxation to the A0T associated with remote shutdown functions. The proposed change in the A0T will not affect any of the analysis assumptions for any of the scenarios previously evaluated. The proposed change will not affect the probability of any event initiators nor will the proposed change affect the ability of any safety-related equipment to perform its intended function. There will be no degradation in the performance of nor an increase in the number of challenges imposed on safety-related equipment assumed to function during an accident situation or control room evacuation. Therefore, the proposed change does not involve a significant increase in the probability or consequences of an accident previously evaluated. WCGS- NSHCs - CTS 3M.2 46 53 S/97
ADDITIONAL INFORMATION COVER SHEET ADDITIONAL INFORMATION NO: Q 7-06 APPLICABILITY: DC, CP, WC, CA : REQUEST: The Readout Location and Total No. of Channels columns in current TS > [ Table 3.3-9] have been moved to the Bases of improved TS 3.3.4. [] Comment: {WC & CA } 7-06 LG is applied to Action b, but this change is not evaluated. Revise DOC 7-06 LG or change CTS markup. {WC, CW} CTS changes to T3.3-9 Note " as applied to Reactor Trip Switch Gear are not evaluated. Provide a revised DOC. {CW} Apply 7-06 LG to the CTS LCO statement. FLOG RESPONSE: The CTS markups have been revised to correctly reflect the information i that is being moved. Additionally, DOC 7-06-LG has been revised to reflect the changes to the CTS markups. For Callaway, the CTS mark-up has been revised to apply DOC 7-06-LG to LCO 3.3.3.5. l ATTACHED PAGES: Encl. 2 3-43, 3-44 Encl. 3A 24,25 l Encl. 3B 26 ) I I I l f f 1 l l 1
- -- - - _ . - - . - . ~ . . - . - - - . _ , ~ . . . . _ . - . . - -
i INSTRUMENTATION l-63-A REMOTE SHUTDOWN INSTRUMENTATION " lQ l-A GEN \
. LIMITING CONDITION FOR OPERATION I
l 3 3 33 The Remote Shut S stem . xP.:d ;instem:. _ :- ~.7-01-A ~ (each Functio 3n iven in Table 3. : d the r ' y & " -- . ;x:: '^.SP)} umetalete- " 7-06-LG l , eenweis shall be OPERABLE x'^r. ::f:a "- ':y:d r : ::! t: th: n.. _: re-( usJalets. p 3.g g APPLICABILITY: MODES 1,2, and 3. ! l ACTIONh 141-i~
- a. With the number of OPERABLE Remote Shutdown zn?.:. ..m -E ehennels less than the Required number of Functions ??' . 2 . cxx._
^"'-"^* 5 as required by Table 3.3-9, re
- - e the inoperable ehannel(s)
""M 7-04-LS-15 (FunctionEMo OPERABLE status within 30 ys; otherwise. " "
be in at least HOT STANDBY within the next 6 hours and in HOT SHUTDOWN ! within the following 6 hours. t
- b. With the ASP controls i , restore the inoperable ASP controls l to OPERABLE status within ys; otherwise, be in at least HOT 7 04-l&l5 STANDBY within the next 6 rs and in HOT SHUTDOWN within the --
following 6 hours. l c. The provisions of Speofication 3.0.4 are not applicable. l l l I l i l l l SURVEILLANCE REQUIREMENTS l i 4.3.3.5.1 Each remote shutdown monitoring instrumentation channel s ll be demonstrated OPERABLE by performance of the CHANNEL CHEC " nd CHANNEL T7 09-LS-43 CALIBRATION at the frequencies given in Table 4.3-6. " g,q 4.3.3.5.2 The ASP controisk/npidsMhall be demonstrated OPERABLE at least once per 18 months (Dygpfratpch a@egAdmponenLJrompe asp) "I- 13
- D 4
,,,,,.ru__m___,e___m_._ . n , _ _m ___..__<._ ,_,__._
1555 5'E hblE5:EE 3E::E' : ,1:5 .((;EE[E 5EE.E:'h'.:j: dr. :: ::. 60*d,r@reLASPee.dvols) Lf4"i""iq
~
i
- Separate Condition entry is allowed for each Functiod
[_g 3,3.q 4 l M1-A I _.... m . l !. " For each required instrumentation channel that is normally energized. 7-09-LS-43 - l J 4 f WOLF CREEK- UNIT 1 3M 3-43 Amendmeut No. 89 ; Mark-up ofCIS3/4. 3 S/1SM7
TABLE 3 3-9 FwdA REMOTE SHUTDOWN, !O'"TOo!GbR _ _ _ -_- 14 7-o11 l-oL-W 7-06-LG 7-01-A 171-06I vnv a i un m m... .. iu 4 EQUIRED i FUNCTION / RSADQUT QE CHANNELS @ / l {LuwiMAAENT) Q *7-01 } LOC?T!O" CP ^ m!ELS CoEn^oL_. m w, m, ,_,_, I
- 1. RCS Pressure-Wide Range ASM 2 1 1-
- 2. Reactor Coolant Temperature. _=h 1 1
Cold Leg ASP){ 4- 1 ut. 3.3-ED]
- 3. Source Range, Neutron Flur ASM 2 1 I l
- 4. Reactor Trip Breaker Indication M " rip 5::: Err 1/ trip breaker
- 5. Reactor Coolant-Temperature ASPX 2 1 Hot Leg
- 6. Reactor Coolant Pump Breakers W 4/ pump 1/ pump l 7. Pressurizer Pressure ASPj( 4 1 l 8. Pressurizer Level ASRK 2 1 l
l 9. Steam Generator Pressure ASRK 2':t . C n 1/stm. gen. i
- 10. Steam Generator Level ASPk 1':t . Gen 1/stm. gen.
- 11. Auxiliary Feedwater Flow Rate ASP)( 1 l 12. Auxiliary Feedwater Suction ASIK 3 1 i Pressure i i
l t
*^=:!!:; Shut 22: orn:l.
I i "o. ::::: T ip r S;; itch; r . 7-06-LG l l ***12.8 5" S ::tch; r.
#Not required OPERABLE in MODE 1 or in MODE 2 above P-6 Setpoint.
l 4 WOLF CREEK- UNIT I 3/4 3-44 Amendment No. 89 MarA-up ofCTS 3M. 3 S/lSR7
CHANGE NUMBER M2iG DESCRIPTION i l 3 13 M Not applicable to Wolf Creek. See Conversion Comparison Table (Enclosure 38). 3 14 LS 29 Not applicable to Wolf Creek. See Conversion Comparison Table (Enclosure 3B). 3 15 M Not applicable to Wolf Creek. See Conversion Comparison Table (Enclosure 3B). ! 3 16 A Not applicable to Wolf Creek. See Conversion Comparison Table (Enclosure 3B). 3 17 A Not applicable to Wolf Creek. See Conversion _ , Comparison Table (Enclosure 38). M 5AT2-4 01 ~~R Not applicable to Wolf Creek. See Conversion Comparison Table (Enclosure 3B). 5 01 R Not applicable to Wolf Creek. See Conversion Comparison Table (Enclosure 3B). 6 01 R Not applicable to Wolf Creek. See Conversion _ Comparison Table (Enclosure 3B). l ( N it Q Cetber Sec.& 3,%W. i@ 4 ig 7 01 A _ ___ The requirements f current TS Table [3.3 9] are fedefined on a f nCtional basis, with Required [g hMicWas OPEMBuiestumn Ctg def). be* &"*t rathe than 3onmim a per channel basis. gEaumED Cpg catsMcM- Consistent with NUREG - 1431. Rev.1. The point at WM oker See tto'n 3.'ataMes.G whichr the ACTION Statements are entered is unchanged. 7 02 M Not applicable to Wolf Creek. See Conversion Comparison Table (Enclosure 3B). l 7 03 Not used. l
\
7 04 LS-15 This change increases the number of days the I Function (s) in current TS Table [3.3 9] and the [ ASP] l controls may remain inoperable before imposing mode i change requirements from 7 days to 30 days. This is based on operating experience and the low probability of an event that would require evacuation of the l control room. This is consistent with NUREG-1431 , Rev. 1 (ITS 3.3.4. Condition A). 7-05 A Not applicable to Wolf Creek. See Conversion ; Comparison Table (Enclosure 3B). i 7 06 LG The Readout Location and Total No. of Channels columns in current TS [ Table 3.3 9 and the wording addressing the Auxiliary Shutdown Panel controls in the LC0] have WCGS-Description ofchanges to CTS 3M.3 24 SAS/97 i
_ _ . _ _ _ _ _ _ . - _ _ _ . _ _ _ _ _ _ . _ _ _ _ _ _ _ _ _ . ~ . INSERT 3A-24 43+Di k 3-18 M Current TS LC0 3.3.3.1 contains an LCO 3.0.3 exception and Table 3.3-
- 6. ACTIONS [27 and 30] for the Fuel Building Exhaust Radiation Monitors and the Control Room Air Intake Radiation Monitors do not contain any default actions if they aren't met. Therefore, the addition of a default action to immediately suspend movement o.'
irradiated fuel assemblies in the fuel building if ACTION [30] were not met for inoperable Fuel Building Exhaust Radiation Monitor (s) is a more restrictive requirement. Similarly, the addition of def ault actions to bring the plant to MODE 5, when originally in MODES 1-4, or to immediately suspend CORE ALTERATIONS and movement of irradiated fuel assemblies when in MODE 5 or 6 or during movement of irradiated fuel assemblies if ACTION [27] were not met for inoperable Control Room Air Intake Radiation Monitor (s) is a more restrictive requirement. These additions impose new and more stringent limitations on the manner in which the plant must be operated.
\Q3-IS \
3-19 LS-50 Not applicable to Wolf Creek. See Conversion Comparison Table (Enclosure 3B). IQS.5-M \ 3-20 %-51 WCGS CTS Table 3.3-6, Functional Unit 1.a. Containment Atmosphere - Gaseous Radioactivity High (GT-RE-31&32), requires operability in i "All" modes. ITS Table 3.3.6-1 (as modified by TSTF-161) requires i this Function in Modes 1, 2, 3, 4. During CORE ALTERATIONS (footnote (a)) and During movement of irradiated fuel assemblies within containment (footnote (b)). The CTS has been revised to specify the applicable modes for this function consistent with ITS Table 3.3.6-1, LCO 3.6.3 and LCO 3.9.4. This is acceptable since these are the only conditions for a significant release of fission product radioactivity in containment. In Modes 5 and 6 without fuel handling in progress or when the purge valves are closed, the potential for a radioactivity release is minimized and operator action is sufficient to ensure post accident offsite doses are maintained within limits. l
\ Q 3.3-82. l 3-21 LS 52 Not applicable to Wolf Creek. See Conversion Comparison' Table (Enclosure 3B).
I ai 4 )
- _- . . - - . ~ -- - - . _ - --. .
l l CHANGE NUMBER NStiC DESCRIPTION been moved to the Bases of improved TS _3.3.4. consistent with NUREG - 1431. Rev. 1.f[ scri ve M-*'" l t at the'cgols als vedj ,,t(I 7 07 (M NetATAe$ RT 3A - 2LL-A GJ.3-22-} 7 08 TR 2 Not applicable to Wolf Creek. See Conversion Comparison Table (Enclosure 3B). 7 09 LS 43 The current TS require that CHANNEL CALIBRATIONS are performed for instrumentation used in the Post cident N M Honi gring [and Remote Shutdown] Systems on a month bas s) Some of these instruments are then de- rgized and remain in this state until re energized for use in the management of plant events or for the performance of the CHANNEL CHECKS, CHANNEL CHECKS are performed more frequently than CHANNEL CALIBRATIONS for the purpose of detecting gross channel failures or excessive drift of one channel relative to other channels monitoring the same process variable. During l the period that the channel is de energized, it is not subject to the failure mechanisms or conditions that i typically lead to instrument failure or excessive drift. Recognizing that de energized ciiannels are not subjected to the same failure mechanisms as energized channels, the current TS was revised to exempt instrumentation that is not normally energized from the I performance of the periodic CHANNEL CHECKS consistent with NUREG 1431. Rev. 1. 7-10 Mfr No 1 ers go ,_ q 7 11 SS .3.3.5 is be' delet . 'siy N C-HI l d icat
.7.5 f n curr AFW S em o TS 3 .1.2 a bility cover uir in4TS \
nts, tuSEC 3A-?Sa.) 7 12 A New Note excludes neutron detectors from CHANNEL CALIBRATION consistent with current TS Table 4.3-1. Functional 3.3.4.3. @a# unit 3A- 6. Note 2sgl o 4 and1-.2. Jwith improved TS S 8 01 A This change, consistent with NUREG 1431 Rev.1. revises
" Channel and Instrument" to " Function."
( 8 02 Not Used 8 03 A This change revises current TS Table [3.310] to clarify the number of channels required to be operable. j WCGS-Description of changes to CTS 3M.3 25 SMS/97 i LS - 44 oJsenT 3 A-2EQ-l Q ~1-13 ] l
INSERT 3A-25a 0 7-11 CTS SR 4.3.3.5.3 which provides a 4.0.4 exception for entry into MODE 3 for the [TDAFW pump and] ASDs (Callaway)/ARVs (Wolf Creek) is deleted. [This exception . is not necessary for the TDAFW pump since the ASP controls can be tested without running the TDAFW pump. ITS SR 3.7.5.2 verifies TDAFW pump performance has not i l degraded during the cycle.] This exception is not necessary for the ASDs/ARVs l since the ASP controls can be tested in MODE 4 ITS SR 3.7.4.1 ensures that the [ ASDs/ARVs are tested through a full cycle at least once per fuel cycle. This i change is considered a more restrictive change since it eliminates the flexibility to perform the surveillance in MODE 3. INSERT 3A-25b 0 7-12 l , l l Since neutron flux is one of the required channels and the detectors are normally i excluded from CHANNEL CALIBRATIONS in other specifications, this Note applies to the SR Frequency in CTS Table 4.3-6. Neutron detectors are one type of sensor
- that can not be adjusted per the definition of CHANNEL CALIBRATION. As discussed
! in the ITS SR 3.3.1.11 Bases, the CHANNEL CAllRRATION for the source range l detectors consists of obtaining integral bias curves, evaluating those curves, i and comparing the curves to the manufacturer's data. This Note in ITS SR 3.3.4.3 is consistent with other CTS requirements for calibrating channels containing neutron detectors. This change is considered an administrative clarification of existing requirements. 1 INSERT 3A-25c 0 7-13 7-13 LS-44 CTS SR 4.3.3.5.2 requires the auxiliary shutdown panel (ASP) controls be demonstrated OPERABLE at least once per 18 months by operating each actuated component from the ASP. The proposed change revises CTS SR 4.3.3.5.2 to delete the phrase "by operating each actuated component from the ASP." The OPERABILITY of the ASP controls ensures there is sufficient information available on selected unit parameters to place and maintain the unit in MODE 3 should the control room become inaccessible. CTS SR 4.3.3.5.2 verifies that the ASF controls perform the intended function. The CTS requirement to operate each actuated component is overly restrictive since the specific components associated with the ASP are verified OPERABLE by other specifications. For example. USAR Section 7.4.3.1.1 identifies the automatic / manual control for each power operated atmospheric dump valve as an ASP control. ITS SR 3.7.4.1 verifies that the atmospheric dump valve is OPERABLE by performance of one complete cycle of each valve. Operation of the equipment from the ASP is not necessary. The surveillance can be satisfied by performance of a continuity l
INSERT 3A-25c (continued) 0 7-13 check. Performance of this surveillance in conjunction with the performance of other required surveillances on equipment associated with the ASP will ensure that if the control room becomes inaccessible. the plant can be placed and maintained in MODE 3. INSERT 3A-25d 0 3.3-22 A monthly CHANNEL CHECK is added to CTS Table 4.3-6 for Instrument 6. Reactor Coolant Pump Breakers. Since this imposes a new surveillance not currently required, this is a more restrictive requirement. l l l
CONVERSION COMPARISON TABLE - CURRENT TS 3/4.3 rage 26 orso TEGI SPEC Of ANGE APPLICABILITY NtlMMEM DESOtf ri H)N DIABt O CANYON COMANOIE PEAK WOt.F CREEK CAI.I.AWAY 7-05 Consistent with the ITS. the modifications would clarify Yes Yes No already in No already in A the requirement to be in HDT SHUTDOIM in 12 hours by current TS. current TS. replacing the requirement with a new requirement to be in HOT STANDBY in 6 hours and in HOT SHUTlyNN in the next 6 hours. 7 06 The Readout Location and Total No. of Channels columns in Yes Yes Yes Yes LG currentTSTable[3.39]f he . ing p si g tN O Mary,5M0tdgsFPane ont_ in LGBTwive been lQ 1.og, j moved to the Bases of 1sproved 15 3.3.4J _ 1,oqueipas Io3DMDnt,rple-1s a,
~
A eon 4hly CHANtJEL.dilRKisadded for m klo g Qo BM 1es 7brAyes, 7 07 __ CTS Deble. 4. 3 -< , s2.u -beakem. gep3.3 @ 7 08 The CPSES requirement to submit a special report if the No Yes No No TR 2 nunter of remote shutdown monitoring instruments is less than the required number would be deleted from the CTS. This requirement is covered by other regulatory requirements. . 7 09 Clarification is provided that Channel Checks are only No - retained Yes Yes Yes LS 43 required for normally energized instrumentation channels by current TS. adding "for each required instrumentation channel that is normally energized" per ITS [SR 3.3.3.1 and SR 3.3.4.1] to CTS [4.3.3.5.1 and 4.3.3.6]. ._
.g jFr a In t CTS.
labl dete nation r dec heat r al. tt ste ng i trumen rat sa ion Ny W4 yer dA
. uA
)<fcuretnt No-MA grent vail at t remote s down anel, s bas on s as -
ge ator le add a tary edwat flow t tp b"8b rator. In the I . It i rec red th either of - ( these i cations suffi ent. e4ot t.tsed. WCGS-CONVERSION TABLE- CTS 3M.3 SRSM7 __ _ . _ . _ . _ _ _ _ _ _ _ _ _ _ _ _ . _ _ _ _ _ . _ _ _._ _ _ _ _ _ _ _ __ __ _ __ _ _ m _m___-_ _ . _
ADDITIONAL INFORMATION COVER SHEET ADDITIONAL INFORMATION NO: O 7-09 APPLICABILITY: CP, WC, CA, DC REQUEST: Clarification is provided that Channel Checks are only required for normally
. energized instrumentation channels by adding "for each required instrumentation channel that is normally energized", per ITS [SR 3.3.3.1 and SR 3.3.4.1) to CTS (4.3.3.5.1 and 4.3.3.6].
Comment: FLOG RESPONSE: The applicability of DOC 7-09-LS-43 has been revised to include DCPP. Per the agreement at the 8/14/98 meeting, a list of the de-energized instruments will be included in LS-43. ATTACHED PAGES: 1 Encl. 4 69 Encl. 5B B 3.3-158 l l l 1 )
l l IV. SPECIFIC NO SIGNIFICANT HAZARDS CONSIDERATIONS NSHC LS-43 10 CFR 50.92 EVALUATION FOR i TECHNICAL CHANGES THAT IMPOSE LESS RESTRICTIVE l REQUIREMENTS WITHIN THE TECHNICAL SPECIFICATIONS 44 R4sete Sh440 {otot } The current TS require that CHANNEL cal.IBRATIONS are formed for ' trumentation used in the Post Accident Monitoring ["] System on a month bas Many of these i instruments are then de energized and remain in this ate until r nergized for use in the management of plant events or for the performance of the CHANNEL CHECKS. j CHANNEL CHECKS are performed more frequently than CHANNEL CALIBRATIONS for the purpose i of detecting gross channel failures or excessive drift of one channel relative to ; other channels monitoring the same process variable. During the period that the l channel is de energized. it is not subject to the failure mechanisms or conditions l that typically lead to instrument failure or excessive drift. Recognizing that de- ) energized channels are not subjected to the same failure mechanisms as energized channels. the current TS was revised to exempt instrumentation that is not normally energized from the performance of the periodic CHANNEL CHECKS, i Gutect 6-eh o, o1\ This proposed TS change has been evaluated and it has been determined that it involves j no significant hazards consideration. This determination has been performed in accordance with the criteria set forth in 10 CFR 50.92(c) as quoted below:
"The Cortmission may make a final determination, pursuant to the procedures in 50.91, that a proposed amendrnent to an operating license for a facility licensed under 50.21(b) or 50.22 or for a testing facility involves no i significant hazards consideration. If operation of the facility in accordance with the proposed amendrnent would not:
- 1. Involve a significant increase in the probability or consequences of an accident previously evaluated; or l
l 2. Create the possibility of a new or different kind of accident frorn any accident previously evaluated; or
- 3. Involve a significant reduction in a margin of safety."
The following evaluation is provided for the three categories of the significant hazards consideration standards: i 1. Does the change involve a significant increase in the probability or l consequences of an accident previously evaluated? The instrumentation affected by the proposed change does not provide any automatic reactor protection or ESFAS functions. The instrumentation is used to provide indication to the reactor operators following a plant event. This indication may be used by the plant staff to manage an event, but serves no l WCGS- NSHCs - CTS 3M.2 69 5/1S M l
( INSERT LS-43 0 7-09 The following are those instruments that are normally de-energized: , fSource Range - normally de-energized in MODE 1 or in MODE 2 above I the P-6 setpoint] l I i l l 1 1 l 1 i l l I i J
Remote Shutdown System ! B 3.3.4 - i BASES (continued) F.c m RTb P. sib' o a F-ch , we, wveM433'n-l : requic ment 6, me+ N vesi% %.e. ac+x.o pes'.hin WCT85 A dic3W m . SR 3.3.4.1 Q4 %e. RT6 ss.te%cw 4= h4. i SURVEILLANCE l REQUIREENTS ' Performance of the CHAlelEL CHECK once every 31 days ensures that a gross failure of instrumentation has not occurred. A CHANNEL CHECK is nonnally a comparison of the parameter indicated on one i channel to a similar parameter on other channels. It is based on the assumption that instnment channels monitoring the same parameter should read approximately the same value. Significant ! deviations between the two instriment channels could be an indication of excessive instrument drift in one of the channels ! or of something even more serious. CHANNEL CHECK will detect t gross channel failure: thus, it is key to verifying that the instrumentation continues to operate properly between each CHANNEL CALIBRATION. p ,,,. d [ s w .3 Agreement criteria are determined by the unit staff, based on a py h (g g%, g gg sursb. indication and readability. If the channels are within the combination ofthethe channel instrtament (a'; a a channel is outside the criteria, it may be an indication that If criteria, it is an indication that channels are OPERABLE. g
, % ou t ,
the sensor or the signal processing equipment has drifted outs re m d e. its limit.
- h. "
Qarca+b<c*w As specified in the Surveillance, a CHANNEL CHECK is only WS~M required for those channels which are nonnally energized. The Frequency of 31 days is based upon operating experience which demonstrates that channel failure is rare. The CHANNEL CHECK supplements less formal, but more frequent, checks of channels during normal operational use of the displays associated with t LCO required channels. d 4 3.3 22.] ad }4-7-Cfl }
.5.uEr.,s. ks McEtmn diaA is de-eneg sed., A Moc6 I w A mod 5M anu,. me.f a, setpnt. _ >
SR 3.3.4.2 ' SF lQ 3.3-94) l SR 3.3.4.2 verifies each required Remote Shutdown System and control circuit and transfer switch perfonas the intended function. This verification _ performed from t_he remote jq sf3.qqj aartfTiary shutdown panel oostlyr as 4 4 -4 G k O oftheequipmentfromtheremetegiliarygdownhperation nel 1 (continued) WCGS-Mark-agp ofNUREG-1431-Bases 3.3 8 3.3158 5/15197
l ADDITIONAL INFORMATION COVER SHEET i ADDITIONAL INFORMATION NO: O 7-11 APPLICABILITY: WC, CA 1 REQUEST: CTS SR 4.3.3.5.3 is deleted. This is duplicated in CTS 3.7.1.2 and covered in ITS 3.7.5 for AFW System operability requirements. i Comment: This change is to delete the provisions of Specification 4.0.4 as applied to RSS turbine AFW pump and ADVs. Because the 4.0.4 provision is eliminated for RSS an L-DOC is needed for this change. The existence of a similar provision in Plant System TS is irrelevant to the assessment of the RSS change. Alternatively, revise ITS to delete proposed note to SR 3.3.4.2 and move it as a Note to the LCO ACTIONS. Provide a DOC for changing the SR to an Actions note. In either case, explain why the ! ISTS cannot be adopted without this proposed exception. l FLOG RESPONSE: DOC 7-11-A was applicable only to Wolf Creek. Wolf Creek subsequently determined that a similar Note should have been placed in the Wolf Creek ITS as proposed in JFD 3.3-92. JFD 3.3-92 added a Note to ITS SR 3.3.4.2 that the ASP controls for the TDAFW pump and SG Atmospheric I Steam Dump (ASD) valves for Callaway and Atmospheric Relief Valves (ARVs) for Wolf Creek are not required to be verified prior to entry into , MODE 3, consistent with CTS SR 4.3.3.5.3. This JFD applicability was identified as applicable to Callaway only. Therefore, this Comment Number is applicable to both Callaway and Wolf Creek. A more restrictive DOC has been initiated to delete CTS SR 4.3.3.5.3 for WCGS since deleting the SR would prevent going into MODE 3 to perform this surveillance on the TDAFW purap and the ARVs. Current WCGS plant procedures perform this surveillanu in MODE 4. Fcr Callaway, CTS SR 4.3.3.5.3 is revised to maintain the 4.0.4 exception for the TDAFW pump and delete the exception for the ASDs. The note to Callaway ITS SR 3.3.4.2 is revised to apply only to the TDAFW pump. DOC 7-11-A is revised to 7-11-M and states:
" CTS SR 4.3.3.5.3 which provides a 4.0.4 exception for entry into MODE 3 for the [TDAFW pump and] ASDs (Calla'uay)/ARVs (Wolf Creek) is deleted. [This exception is not necessary for the TDAFW pump since the ASP controls can be tested without running the TDAFW pump. ITS SR 3.7.5.2 verifies TDAFW pump performance has not degraded during the cycle.] This exception is not necessary for the ASDs/ARVs since the ASP controls can be tested in MODE 4. ITS SR 3.7.4.1 ensures that the ASDs/ARVs are tested through a full cycle at ieast once per fuel cycle.
This change it considered a more restrictive change since it eliminates the flexibility to perform the surveillance in MODE 3."
- ATTACHED PAGES
Encl. 2 3-43 Encl. 3A 25 Encl. 3B 27 Encl. 6B 15 I l
__ _. m. __ . . - . _ _ _ _ _ .- _ _ . _ _ . . _ . . . _ . _ . . . _ _ _ . _ _ _ . _ _ _ _ __ INSTRUMENTATION , I-(p3-A I REMOTE SHUTDOWN INSTRUMENTATION lQ l-A GElJJ LIMITING CONDITION FOR OPERATION r
- 3.3 33 The Remote Sh S stem ..r:::..x,, :n;;;;zn' " . d;n---!- for 7-01 A feech Functio]n iven in Table 3. crd 5: :n 't ; c _
e n :(.^S" 3 * *A*I* t *- ' 7-06-LG
, eentseis shall be OPERABLE . '^' r _re '- ':y:d M- n:! t: S: xc.. 're-(. unstaista. .
@ 1-06 l APPLICABILITY: MODES 1,2, and 3.
ACTIONC )) 41-A
- a. With the number of OPERABLE Remote Shutdown xx: - .ng 7-61-A ~
- j. ehennels less than the Required nurnber of Functions ?" ..;z C:nn= J~" ~ M as required by Table 3.3-9, r the inoperable ehennel(s) 7-04-LS-15 Functions OPERABLE status within 30 ys; othenvise, ~ " ~ #.
be in at least HOT STANDBY within the next 6 hours and in HOT SHUTDOWN within the following 6 hcurs.
- b. With the ASP controls inop , restore the inoperable ASP controls
!- to OPERABLE status within ys; otherwise, be in at least HOT 7 04.LS.15 STANDBY within the next 6 rs and in HOT SHUTDOWN within the - i following 6 hours. __ l
- c. The provisions of Specification 3.0.4 are not applicable.
I i l I l SURVEILLANCE REQUIREVENTS i ! I 4.3.3.5.1 Each remote shutdown monitoring instrumentation channel s 11 be demonstrated OPERABLE by performance of the CHANNEL CHEC " nd CHANNEL 7-09-LS-43 CAllBRATION at the frequencies given in Table 4.3-6. l g,q
' 4.3.3.5.2 The ASP controlskknsf6sMhall be demonstrated OPERABLE at least once per 18 rviai,{vpiptratp acysetNJhe asPJ
~7-II-l W
,,,,,ru.___=_,____,,___m .--,n,____.___.. m.. ,_ _
wAeI5iT EE b td:.IE $E5: rr . 'Y,55;I.$[-Eh h 5:I.EE[;4; ' 7 ll-gM IG '22b2- Lfg5 Tq 60 6 r@ral AsPehols}
- Separate Condition entry is allowed for each Functiod [op 3,3.% l 1
,,-01-A
" For each required instrumentation channel that is normally energized. 7-09-LS-43 l
I' t WOLF CREEK- UNITI 3M 3-43 Amendment No. 89 ; Mark-up ofCTS3/4. 3 5/15/97
,._ . m , _ . _ _ _ _ _ _ - . . .. _ _. _ _. _ ._ . _ _ _ _ . . _ _ . - . _ _ _ _ _ . i CHANGE NLABER HSHC DESCRIPT10N been moved to the Bases of improved TS _3.3.4 N '*" I ! consistent with NUREG 1431. Rev. 1.f[ scri ve the cpls
~
t at al ve j '7 07 h Net. tTse@, NSERT 3A , G 3. 3 - 2.2.] i 7 08 TR 2 Not applicable to Wolf Creek. See Conversion ! Comparison Table (Enclosure 38). 7 09 LS 43 The current TS require that CHANNEL CALIBRATIONS are performed for instrtmentation used in the Pos cident b Moni (ring [and Remote Shutdown] Systems on a month zed l bas s) Some of these instruments are then de l ard remain in this state until re energized for use in the management of plant events or for the performance of the CHANNEL CHECKS. CHANNEL CHECKS are performed l more frequently than CHANNEL CALIBRATIONS for the l purpose of detecting gross channel failures or i excessive drift of one channel relative to other I channels monitoring the same process variable. During the period that the channel is de energized, it is not subject to tre failure mechanisms or conditions that typically lead to instrtment failure or excessive drift. Recognizing that de energized channels are not subjerted to the same failure mechanisms as energized l channels, the current TS was revised to exempt l instrumentation that is not normally energized from the performance of the periodic CHANNEL CHECKS consistent , with NUREG 1431. Rev. 1. ! ud ( 7 11 S .3.3.5 is be delet . s N#-U I I d
.7.5 f icat AFW S n curr em o TS 3 .1.2 a ility cover uir __ ts. LusERT SA-254.)
in N l I 7 12 A New Note excludes neutron detectors from CHANNEL CALIBRATION consistent with current TS Table 4.31, l l l Functional u it 6, Note 4_and with improved TS SR l 3.3.4.3. NSES.T .M- 25QI o 7-8 2 J j
- ' This change, consistent with NUREG 1431 Rev.1, revises 8 01 A i " Channel and Instrument" to " Function."
8 02 Not Used ) 8 03 A This change revises current TS Table [3.310] to clarify the number of channels required to be operable. WCGS-Description ofchanges to CTS 3M.3 25 5/158 7 k- 8 _ LS - 44 94 seat 3 A-25Q-l Q 1 13 J
1 1 INSERT 3A-25a 0 7-11 ) CTS SR 4.3.3.5.3 which provides a 4.0.4 exception for entry into MODE 3 for the i [TDAFW pump and] ASDs (Callaway)/ARVs (Wolf Creek) is deleted. [This exception is not necessary for the TDAFW pump since the ASP controls can be tested without i
- running the TDAFW pump. ITS SR 3.7.5.2 verifies TDAFW pump performance has not l degraded during the cycle.] This exception is not necessary for the ASDs/ARVs since the ASP controls can be tested in MODE 4. ITS SR 3.7.4.1 ensures that the l ASDs/ARVs are tested through a full cycle at least once per fuel cycle. This j change is considered a more restrictive change since it eliminates the l flexibility to perform the surveillance in MODE 3.
INSERT 3A-25b 0 7-12 1 Since neutron flux is one of the required channels and the detectors are normally excluded from CHANNEL CALIBRATIONS in other specifications, this Note applies to the SR Frequency in CTS TaL*.e 4.3-6. Neutron detectors are one type of sensor that can not be adjusted per the definition of CHANNEL CALIBRATION. As discussed l in the ITS SR 3.3.1.11 Bases, the CHANNEL CALIBRATION for the source range L detectors consists of obtaining integral bias curves, evaluating those curves, and comparing the curves to the manufacturer's data. This Note in ITS SR 3.3.4.3 is consistent with other CTS requirements for calibrating channels containing neutron detectors. This change is considered an administrative clarification of existing requirements. i INSERT 3A-25c 0 7-13 7-13 LS-44 CTS SR 4.3.3.5.2 requires the auxiliary shutdown panel (ASP) controls be demonstrated OPERABLE at least once per 18 months by operating each actuated component from the ASP. The proposed change revises CTS SR 4.3.3.5.2 to delete the phrase l "by operating each actuated component from the ASP." The OPERABILITY of the ASP controls ensures there is sufficient information available on selected unit parameters to place and I maintain the unit in MODE 3 should the control room become inaccessible. CTS SR 4.3.3.5.2 verifies that the ASP controls perform the intended function. The CTS requirement to operate each actuated component is overly restrictive since the specific components associated with the ASP are verified OPERABLE by other specifications. For example, USAR Section 7,4.3.1.1 identifies the automatic / manual control for each power operated atmospheric dump valve as an ASP control. ITS SR 3.7.4.1 verifies that the atmospheric dump valve is OPERABLE by performance of one complete cycle of each valve. Operation of the equipment from the A5P is not necessary. The surveillance can be satisfied by performance of a continuity i f i
I l l INSERT 3A 25c (continued) 0 7-13 check. Performance of this surveillance in conjunction with I the performance of other required surveillances on equipment i associated with the ASP will ensure that if the control room becomes inaccessible, the plant can be placed and maintained in H0DE 3. INSERT 3A-25d 0 3.3-22 A monthly CHANNEL CHECK is added to CTS Table 4.3-6 for Instrument 6. Reactor l Coolant Pump Breakers. Since this imposes a new surveillance not currently j recuired, this is a more restrictive requirement. l i l I l l l 1 l l
,_ n CONVERSION COMPARISON TABLE - CURRENT TS 3/4.3 rage 27 or30 q% insect se.-2,D te ,_o 1 TECII SPEC CllANGE AP/LICABILITY NUMBER DESCRIPTION DIABLO CANYON L COMANCilE PEAK WOLF CREEK CALLAWAY
-11 b .3.5. s bei. le Th duplic3t.e6 n No - not in current No - not in current Yes Nhpe11es!AffRS.
ts CTS .1.2 is cov ed in S 3.7.c or AFW Sist TS. TS. Nes rabili_ req _ ts. _s uE Ee.T 3 6 -2. la. [4 7-s e ( 7 12 New NOTE excludes neutron detectors from CHANNEL No - not in current No already in Yes Yes A CAllBRATION consistent with current TS Table 4.31 TS. current TS. Functional Unit 6. Note 4 and with improved TS SR 3.3.4.3. 8 01 This change, consistent with NUREG-1431 Rev. 1 revises Yes Yes Yes Yes A " Channel and Instrument" to " Function." 8 02 Not used. N/A N/A N/A N/A 8-03 This change revises current TS Table 3.310 to clarify the Yes Yes Yes Yes A number of channels required to be operable. This is an administrative change which deletes the " Minimum Channels Operable" column [and revises the "[ Total] No. of Channels" column to be the " Required Channels" column]. The required actions are now based on one channel inoperable or two channels inoperable, rather than "less than the Total Number" or "less than Minimum Number." Consistent with NUREG 1431 Rev. 1. (ITS 3.3.3 Required Yes Yes Yes Yes 8 04 LS-17 Actions C.1. E.1 and G) this change de:etes the requirement to initiate alternate method of monitoring within 72 hours when two channels of Containment Radiation Level or [RVLIS) are inoperable as specified in CTS [3.3.3.6 Action c]. 8 05 in conjunction with CN 8 03 A. this change rearranges the No - see CN No - not in current Yes Yes A ACTION Statements for the single channel Functions (i.e.. 8 11 LS TS SG Water Level - Wide Range end AFW Flow Rate). No change in A0T is requested, therefore this ia an administrative change. 5/15/97 WCGS-CONVERSION TABLE- CTS 3/4.3 i
f 1 i
- - INSERT 3B-27a 0 7-11 TECH SPEC CHANGE APPLICABILITY NUMBER DESCRIPTION DIABLO CANYON COMMANCHE PEAK WOLF CREEK CALLAWAY 7-11 CTS SR 4.3.3.5.3 which provides a 4.0.4
, M exception for entry into MODE 3 for the ; [TDAFW pump and] ASD (Callaway)/ARVs (Wolf .; . Creek) is deleted. I ! i INSERT 3B-27b 0 7-13 ! TECH SPEC CHANGE APPLICABILITY j' NUMBER DESCRIPTION DIABLO CANYON COMMANCHE PEAK ' WOLF CREEK CALLAWAY' 7-13 CTS SR 4.3.3.5.2 requires the auxiliary No - not in No - not in Yes Yes ! LS-44 shutdown panel (ASP) controls be CTS CTS , demonstrated OPERABLE by performance at ' least once per 18 months by operating each l actuated component from the ASP. The proposed change revises CTS SR 4.3.3.5.2 to ! delete the phrase "by operating each actuated component from the ASP." t A Y
.s., _, - . , - . . . . . . , .
CONVERSION COMPARISON TABLE FOR DIFFERENCES FROM NUREG-1431 Page 15 of 23 SECTION 3.3 i TECH SPEC CHANGE APPLICABILITY ; NUMBER DESCRIPTION DIABLO CANYON COMANCHE PEAK WOLF CREEK CALLAWAY 3.3 88 Revise ITS 3.3.9 to apply in MODE 2 only below P 6 and to No - not in current No not in current No - not in current Yes reflect ACTION Statement 5.b per current TS Table 3.3-1. TS. TS. TS. 3.3-89 Revise COT in ITS $R 3.3.9.3 to add the 4 hour allowance No - not in current No - not in current No - not in current Yes from ITS SR 3.3.1.7. TS. TS. TS. 3.3-90 Exclude neutron detectors from CHANNEL CALIBRATION ITS No not in current No - not in current No - not in current Yes l SR 3.3.9.4 TS. TS. TS. I Qa-Ls-e,au { Note 4 p @per TsTG-current t %Q)TS Table 4.3-1. Functional Unit 6. [T8L3 3M J 3.3-91 Add CHANNEL CHECK and response time surveillances (ITS No - not in current No - not in current No - not in current Yes per current TS Table 4.3 1. TS. TS. TS, Ct 3-15-4E4i TM-3.3 ooc. SR 3.3.9.1 Functional Unit 6. and Note 12 SR 3.3.9.5)MT5TF- IO 3.3 92 No - adopted ISTS No - not in current No adopted ISTS Yes Adds SR 3.3.4.2_ Note that the ASP controls for the TDAFW pump (nd;5Er$5D_jare not required to be verified prior to format. TS. format. p g_gg l entry into MODE 3 consistent with current TS SR 4.3.3.5.3. Yes Yes Yes 3.3-93 ITS 3.3.1 Condition V is deleted. It is not entered from Yes Table 3.3.1-1 nor do the Bases clarify when it would be needed, raising the concern of misinterpretation. Condition V does not replace LCO 3.0.3 requirements to assess when the plant is outside the licensing basis. r - ( Ng . Yes 3.3 94 ITS 3.1.4 is revised per current 15 [3.3.3.5] with regard (Ygs t4o) Yes Yes to [ ASP] controls. (fo f S/15197 WCGS-Conversion Comparison Table-ITS3.3
ADDITIONAL INFORMATION COVER SHEET ADDITIONAL INFORMATION NO: O 7-12 APPLICABILITY: WC, CA REQUEST: New Note excludes neutron detectors from CHANNEL CAllBRATION consistent l with current TS Table 4.3-1, Functional Unit 6, Note 4 and with improved TS SR 3.3.4.3. Comment: Insufficient discussion to make a determination that the change is administrative. The RSS CTS does not contain an allowance to exclude neutron detectors from CHANNEL CALIBRATIONS. Delete the proposed Note to ITS SR 3.3.4.3 or provide a DOC to justify the relaxation to CTS. FLOG RESPONSE: Wolf Creek and Callaway believe that the proposed change is an i administrative change. NRC accepted the same change at Vogtle as an ! administrative change, as discussed in Section 3.1.3.3 item (21) of the ; Vogtle SER wherein it was stated that this change "is essentially an ; administrative clarification of existing requirements and is therefore acceptable." ' DOC 7-12-A is revised to include: "Since neutron flux is one of the requirea channels and the detectors are normally excluded from
- CHANNEL CALIBRATIONS in other tpecifications, this Note applies to l the SR Frequency in CTS Table 4.3-6. Neutron detectors are one type of l sensor that can not be adjusted per the definition of CHANNEL !
CAllBRATION. As discussed in the ITS SR 3.3.1.11 Bases, the ' i CHANNEL CALIBRATION for the source range detectors consists of obtaining integral bias curves, evaluating those curves, and comparing the curves to the manufacturer's data. This Note in ITS SR 3.3.4.3 is l conr.istent with other CTS requirements for calibrating channels containing neutron detectors. This change is considered an l administrative clarification of existing requirements." , l l ATTACHED PAGES: 1 Encl.3A 25 l I
CHANGE NUPBER NSilC DESCRIPTION been moved to the Bases of improved TS 3.3.4 _ consistent with NUREG 1431. Rev. 1.((-- scri ve '* I
~
at thecgols als veyd tfI l 7 07 @ NetAfseth IMSF.R.T 3A -2%L- '3" -l i 7 08 1R 2 Not applicable to Wolf. Creek. See Conversion i Comparison Table (Enclosure 3B). 7 09 LS 43 The current TS require that CHANNEL CALIBRATIONS are l performed for instrumentation used in the Post cident d , l Moni (ring [and Remote Shutdown] Systems on a month ! bas s ) Some of these instruments are then de rgized ; and remain in this state until re-energized for use in ! the management of plant events or for the performance
- of the CHANNEL CHECKS. CHANNEL CHECKS are perfonned l
more frequently than CHANNEL CALIBRATIONS for the purpose of detecting gross channel failures or l excessive drift of one channel relative to other channels monitoring the same process variable. During the period that the channel is de energized, it is not subject to the failure mechanisms or conditions that , typically lead to instrument failure or excessive ! drift. Recognizing that de energized channels are not subjected to the same failure mechanisms as energized i channels, the current TS was revised to exempt instrumentation that is not nonna11y energized from the . performance of the periodic CHANNEL CHECKS consistent I with NUREG 1431. Rev. 1. l
-10 h No 1 e go ,_,q 7 11 S .3.3.5 is be delet . 's iyN C-4 - I d icat
.7.5 f n curr AFW S em o TS 3 .1.2 a ility cover uir in 4TS nts. tusdT SA-254.)
\
7-12 A New Note excludes neutron detectors from CHANNEL i CALIBRATION consistent with current TS Table 4.31. !- Functional unit 6. Note 4 and with improved TS SR 3.3.4.3. 3A- 2sgl o 7-s 2. J 8 01 A This change, consistent with NUREG 1431 Rev. 1. re:iises
" Channel and Instrument" to " Function."
8 02 Not Used 8 03 A This change revises current TS Table [3.310] to clarify the number of channels required to be operable. WCGS-Description ofchanges to CTS 3M.3 25 S/1587
-8 L5 - 44 i4 saa.T s A-2.5{-] o 1.n3 ]
l l INSERT 3A-25a 0 7-11 CTS SR 4.3.3.5.3 which provides a 4.0.4 exception for entry into MODE 3 for the [TDAFW pump and] ASDs (Callaway)/ARVs (Wolf Creek)'is deleted. [This exception is not necessary for the TDAFW. pump since the ASP controls can be tested without running the TDAFW pump. ITS SR 3.7.5.2 verifies TDAFW pump performcnce has not degraded during the cycle.] This exception is not necessary for the ASDs/ARVs since the ASP controls can be tested in MODE 4. ITS SR 3.7.4.1 ensures that the ASDs/ARVs are tested through a full cycle at least once per fuel' cycle. This change is considered a more restrictive change since it eliminates the flexibility to perform the surveillance in MODE 3. INSERT 3A-25b 0 7-12 Since neutron flux is one of the required channels and the detectors are normally excluded from CHANNEL CALIBRATIONS in other specifications, this Note applies to the SR Frequency in CTS Table 4.3-6. Neutron detectors are one type of sensor that can not be adjusted per the definition of CHANNEL CALIBRATION. As discussed in the ITS SR 3.3.1.11 Bases, the CHANNEL CALIBRATION for the source range detectors consists of obtaining integral bias curves, evaluating those curves, and comparing the curves to the manufacturer's data. This Note in ITS SR 3.3.4.3 is consistent with other CTS requirements for calibrating channels containing neutron detectors. This change is considered an administrative clarification of existing requirements. 1 INSERT 3A-25c Q 7-13 7-13 LS 44 CTS SR 4.3.3.5.2 requires the auxiliary shutdown panel ( ASP) I controls be demonstrated OPERABLE at least once per 18 months by operating each actuated component from the ASP. The proposed change revises CTS SR 4.3.3.5.2 to delete the phrase "by operating each actuated component from the ASP." The OPERABILITY of the ASP controls ensures there is sufficient information available on selected unit parameters to place and maintain the unit in MODE 3 should the control room become inaccessible. CTS SR 4.3.3.5.2 verifies that the ASP controls perform the intended function. The CTS requirement to operate each actuated component is overly restrictive since the specific components associated with the ASP are verified OPERABLE by other specifications. For example. USAR Section 7.4.3.1.1 identifies the automatic / manual control for each power operated atmospheric dump valve as an ASP control. ITS SR 3.7.4.1 verifies that the atmospheric dump valve is OPERABLE by performance of one complete cycle of each valve. Operation 4 of the equipment from the ASP is not necessary. The surveillance can be satisfied by performance of a continuity ? r
. _ . . - . ~ ~ . - .
l' INSERT 3A-25c (continued) 0 7-13 check. Performance of this surveillance in conjunction with ' the performance of other required surveillances on equipment associated with the ASP will ensure that if the control room becomes inaccessible, the plant can be placed and maintained in MODE 3. INSERT 3A-25d 0 3.3-22 A monthly CHANNEL CHECK is added to CTS Table 4.3-6 for Instrument 6 Reactor Coolant Pump Breakers. Since this imposes a new surveillance not currently required, this is a more restrictive requirement. l j i 1
\
1 i i l I l
- - ._, _ . - - - . . . __ _ - - - - - =_ _ _ . _ - -
ADDITIONAL INFORMATION COVER SHEET ADDITIONAL INFORMATION NO: O 7-13 APPLICABILITY: WC, CA REQUEST: This item was identified during the licensee /NRC meeting on August 11,1998. The NRC requested a DOC be initiated to identify either moving portions of CTS SR 4.3.3.5.2 concerning operating each actuated component from the ASP or deletion of the requirement. FLOG RESPONSE: DOC 7-13 LS-44 was initiated. The DOC states:
" CTS SR 4.3.3.5.2 requires the auxiliary shutdown panel (ASP) controls be demonstrated OPERABLE at least once per 18 months by operating each actuated component from the ASP. The proposed change revises ,
CTS SR 4.3.3.5.2 to delete the phrase "by operating each actuated l component from the ASP." The OPERABILITY of the ASP controls I ensures there is sufficient information available on selected unit l parameters to place and maintain the unit in MODE 3 should the control l room become inaccessible. CTS SR 4.3.3.5.2 verifies that the ASP controls perform the intended function. The CTS requirement to operate each actuated component is overly restrictive since the specific components associated with the ASP are verified OPERABLE by other specifications. For example, USAR Section 7.4.3.1.1 identifies the automatic / manual control for each power operated atmospheric dump valve as an ASP control. ITS SR 3.7.4.1 verifies that the atmospheric dump valve is OPERABLE by performance of one complete cycle of each valve. Operation of the equipment from the ASP is not necessary. The surveillance can be satisfied by performance of a continuity check. Performance of this surveillance in conjunction with the performance of other required surveillances on equipment associated with the ASP will l ensure that if the control room becomes inaccessible, the plant can be placed and maintained in MODE 3." ATTACHED PAGES: Encl. 2 3-43 Encl. 3A 25 Encl. 3B 27 Encl. 4 2, new LS-44 l l l t
. .. . _ _ _ ._ _ _ _ _ _ . _ - . . _ _ _ _ _ _ _ _ _ _ . _ _ _. . . ...m_ . __
l INSTRUMENTATION l-63-A REMOTE SHUTDQWN INSTRUMENTATION lQ l-A GEkl } LIMITING CONDITION FOR OPERATION 3.3 3 5 The Remote Shut S stem .; ..".:.in , hm =:ntaben for ~ 7-01-A 7 feech Functio 3n iven in Table 3. eneHhoeumhesy th " m ;:::: (^SP3 M*I*f*- ' 7-06-LG ' eenkele shall be OPERABLE . ::it ':;' ; d :": n:: te th: :20! ' r [unstsista. p 3.og g APPLICABILITY: MODES 1,2, and 3. ACTIONh ]I41-ATe
..r._ a .u.:
- a. With the number of OPERABLE Remote Shutdown =:n!"._.... ]7-01'-k]
ehennels less than the Required number of Fundions !'"cr. 2:nn::: QDERABbli as required by Table 3.3-g, re e the inoperable f;nn:!;:) 7"7-04-LS45 < 7 [Functione)to OPERABLE status within 30 ays;otherwise, A l be in at least HOT STANDBY within the next 6 hours and in HOT SHUTDOWN ! within the following 6 hours. I i b. With the ASP controls in , restore the inoperable ASP controls to OPERABLE status within ys; otherwise, be in at least HOT 744-LS-15 ' STANDBY within the next 6 urs and in HOT SHUTDOWN within the - following 6 hours. _
- c. The provisions of Specification 3.0.4 are not applicable.
SURVEILLANCE REQUIREMENTS 4.3.3.5.1 Each remote shutdown monitoring instrumentation channel s 11 be demonstrated OPERABLE by performance of the CHANNEL CHEC " nd CHANNEL [749-LS-43 ' CAllBRATION at the frequencies given in Table 4.3-6. ]Qp 4.3.3.5.2 The ASP controlsk ref6sMhall be demonstrated OPERABLE at least once per 18 months (Dpipfratpch acJudtejpxTmponenpJh6 AmS 'I - l'A - N l
, , , , , n .,- -. = _ .,e -_.-- , n , . . a --_.. ~ . a.. ._.
SE Ed h E:I b:t:5 5E EEEY.: f E,b':5:5.E d b; M E'b 5 [;5:je E7-11-gN fr- 2b22-6 % r k u'reL ASPa4=lQ L[5"i" iT] l
- Separate Condition entry is allowed for each Functiod 141-A
@ 3.3 -94 l ,
" For each required instrumentation channel that is normally energized. 7-09-LS43 I
l-WOLF CREEK- UNIT 1 3M 3-43 Amendment No. 89 Mark-up ofCTS3M. 3 !/1587
CHANGE NUISER !GtE DESCRIPTION been moved to the Bases of improved TS _3.3.4 pM* I consistentwithNUREG-1431.Rev.1.f[ scri ve t at the 'copWels ' als ve 7-07 NotAfsed. NSERT 3A, O S. 3 -2M (M 7-08 TR 2 Not applicable to Wolf Creek. See Conversion Comparison Table (Enclosure 38). 7 09 LS 43 The current TS require that CHANNEL CALIBRATIONS are performed for instrumentation used in the Pos cident b Monit(ring [and Remote Shutdown] Systems on a month rgized bas s) Some of these instruments are then de and remain in this state until re energized for use in the management of plant events or for the performance of the CHANNEL CHECKS. CHANNEL CHECKS are performed more frequently than CHANNEL CALIBRATIONS for the purpose of detecting gross channel failures or excessive drift of one channel relative to other channels monitoring the same process variable. During the period that the channel is de energized, it is not subject to the failure mechanisms or conditions that typically lead to instrument failure or excessive drift. Recognizing that de-energized channels ai7 not subjected to the same failure mechanisms as energized channels, the current TS was revised to exempt instrumentation that is not normally energized from the performance of the periodic CHANNEL CHECKS consistent with NUREG - 1431. Rev. 1. 7-10 ers h __ _ 1 gg,4 7-11 S .3.3.5 is be' delet . s NM-U l i d icat
.7.5 f n curr AFW 5 em o TS 3 .1.2 a ility cover uir in N ts. IOSEf,T SA-254.)
7 12 A New Note excludes neutron detectors from CHANNEL CALIBRATION consistent with current TS Table 4.31. Functional unit 6. Note 4 and with improved TS SR 3.3.4.3. aA-2sgl o -it ] 8 01 A This change, consistent with NUREG 1431 Rev. 1. revises
" Channel and Instrument" to " Function." !
f 8 02 Not Used 8 03 A This change revises current TS Table [3.3-10] to clarify the number of channels required to be operable. WCGS-Description ofchanges to CTS 3M.3 25 $/15M7 h . LS - 44 HJ5ERT S A-25 -l @ ~l L3 j
INSERT 3A-25a 0 7-11 l CTS SR 4.3.3.5.3 which provides a 4.0.4 exception for entry into MODE 3 for the [TDAFW pump and) ASDs (Callaway)/ARVs (Wolf Creek) is deleted. [This exception l is not necessary for the TDAFW pump since the ASP controls can be tested without l running the TDAFW pump. ITS SR 3.7.5.2 verifies TDAFW pump performance has not l degraded during the cycle.] This exception is not necessary for the ASDs/ARVs since the ASP controls can be tested in MODE 4. ITS SR 3.7.4.1 ensures that the L ASDs/ARVs are' tested through a full cycle at least once per fuel cycle. This 1 change is considered a more restrictive change since it eliminates the flexibility to perform the surveillance in MODE 3. INSERT 3A-25b 0 7-12 i Since neutron flux is one of the required channels and the detectors are normally excluded from CHANNEL CALIBRATIONS in other specifications, this Note applies to i the SR Frequency in CTS Table 4.3-6. Neutron detectors are one type of sensor that can not be adjusted per the definition of CHANNEL CALIBRATION. As discussed in the ITS SR 3.3.1.11 Bases, the CHANNEL CALIBRATION for the source range detectors consists of obtaining integral bias curves, evaluating those curves, and comparing the curves to the manufacturer's data. This Note in ITS SR 3.3.4.3 is consistent with other CTS requirements for calibrating channels containing neutron detectors. This change is considered an administrative clarification of existing requirements. l INSERT 3A-25c 0 7-13 7-13 LS-44 CTS SR 4.3.3.5.2 requires the auxiliary shutdown panel (ASP) , controls be demonstrated OPERABLE at least once per 18 months l by operating each actuated component from the ASP. The proposed change revises CTS SR 4.3.3.5.2 to delete the phrase "by operating each actuated component from the ASP." The j OPERABILITY of the ASP controls ensures there is sufficient information available on selected unit parameters to place and l maintain the unit in MODE 3 should the control room become j inaccessible. CTS SR 4.3.3.5.2 verifies that the ASP controls i perform the intended function. The CTS requirement to operate each actuated component is overly restrictive since the specific components associated with the ASP are verified l OPERABLE by other specifications. For example, USAR Section 7.4.3.1.1 identifies the automatic / manual control for each ! power cperated atmospheric dump valve as an ASP control. ITS ' SR 3.7.4.1 verifies that the atmospheric dump valve is OPERABLE by performance of one complete cycle of each valve. Operation of the equipment from the ASP is not necessary. The surveillance can be satisfied by performance of a continuity (
i INSERT 3A-25c (continued) 0 7-13 check. Performance of this surveillance in conjunction with the performance of other required surveillances on equipment associated with the ASP will ensure that if the control room becomes inaccessible, the plant can be placed and maintained in MODE 3. INSERT 3A-25d 0 3.3-22 A monthly CHANNEL CHECK is added to CTS Table 4.3-6 for Instrument 6. Reactor Coolant Pump Breakers. Since this imposes a new surveillance not currently required, this is a more restrictive requirement. I 1 l
INSERT 3B-27a 0 7-11' i , TECH SPEC CHANGE APPLICABILITY 'I NUMBER DESCRIPTION DIABLO CANYON COMMANCHE PEAK- WOLF CREEK CALLAWAY 7 CTS SR 4.3.3.5.3 which provides a _4.0.4 l M exception for entry into MODE 3 for the ; [TDAFW pump and] ASD (Callaway)/ARVs (Wolf Creek) is deleted. i INSERT 38-27b 0 7-13 ! TECH SPEC CHANGE APPLICABILITY [ NUMBER DESCRIPTION DIABLO CANYON COMMANCHE PEAK WOLF CREEK CALLAWAY 7-13 CTS SR 4.3.3.5.2 requires the auxiliary No - not in No - not in Yes Yes , LS-44 shutdown panel (ASP) controls be CTS CTS i demonstrated OPERABLE by performance at , least once per 18 months by operating'each actuated component from the ASP. The ! proposed change revises CTS SR 4.3.3.5.2 to ; delete the phrase "by operating each ! actuated component from the ASP." i i t 1 4 . t t f I 1
. - - _ . . . - _ _ _ . _ _ . . . _ _ .__-.-._.-_..._.___._.-___.__.____-.___.___________________._.___._____m-_. _ _ _ _ _ _ _ _ _ _ _ _ _ - - _ _ _ _ _ _ . _ _ -
I [ _, _3 CONVERSION COMPARISON TABLE - CURRENT TS 3/4.3 r.8 27 or3e : t,s _g tussstT M-271. [op p _ o _] [ t TECH SPEC CHANGE APPLICABILITY [ i NUMBER DESCRIPTION DEABLO CANYON COMANCHE PEAK WOI.F CREEK CAR.LAWAY Nyt}atfle#4ffRS.
~
1 b SR .3.5. s bei 1 This 11 n No - not in current No - not in current Yes- ' CTS . 1.2 is co in 3.7. AFW TS. TS. Nes abili_ i _ s. __l us se.T 36 -2l7a_ [4 7-se ( No - already in 7-12 New NOTE excludes neutron detectors from CHANNEL No - not in current Yes Yes A CALIBRATION consistent with current TS Table 4.3-1. TS. current TS. Functional Unit 6. Nute 4 and with improved TS SR 3.3.4.3. l ' Yes Yes a 8-01 This change, consistent with NLREG-1431 Rev.1. revises Yes Yes A " Channel and Instrument" to " Function." 8 02 Not used. N/A N/A N/A N/A 8-03 This change revises current TS Table 3.3-10 to clarify the Yes Yes Yes Yes A number of channels required to be operable. This is an ! administrative change which deletes the " Minimum Channels Operable" column [and revises the "[ Total] No. of Channels" f column to be the " Required Channels" column]. The required actions are now based on one channel inoperable or two j channels inoperable, rather than "less than the Total i Number" or "less than Minimum Number." Consistent with NLREG-1431 Rev.1. (ITS 3.3.3 Required Yes Yes Yes Yes ! 8 04 LS-17 Actions C.1. E.1, and G) this change deletes the l I
- i. requirement to initiate alternate method of monitoring within 72 hours when two channels of Containment Radiation Level or [RVLIS] are inoperable as specified in CTS
[3.3.3.6 Action c]. > 8 05 In conjunction with CN 8 03-A. this change rearranges the No - see CN No - not in currcnt Yes Yes , A ACTION Statements for the single channel Functions (i.e., 8 11 LS TS ' SG Water Level - Wide Range and AFW Flow Rate). No change T i in A0T is requested, therefore this is an administrative change. , a WCGS-CONVERSION TABLE- CTS 3/4.3 $/ISn7 ! t 1 h
NO SIGNIFICANT 1%ZARDS CONSIDERATION (NSHC) CONTENTS (Continued) ued. LS 28 . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . Not @rrDc8SBb lm 8 2 " O LS 29. . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . Not a ppl i cabl e LS 30. . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . Not appl i cabl e LS 31................................................................... 54 LS 32........................................ ... . . . . .Not _ applicable @. Z- id LS 33....................................... M5=1.te....Lotipplfcabl]e LS-34................................................................... 57 LS-35............................................... . . . . .Not _ applicable LS 36............................................... ....Not N '- - icAs %
. m--
LS 37. ............... ............................. ...Not applicable s -- - LS.38.. . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . ...Not . . . = 4:3g. . __ a\cA 2.1.an_\ LS 39 .................................................................. 60 t LS 40................................................................... 62 LS 41................................................................... 64 LS 42................................................................... 66 LS-43................................................................... 69
~Tuseer 4- ay cp :-13 )
~
( ts.~. 44 V. Recurring Po Significant Hazards Considerations "TR" TR 1. . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . Not a ppl i c abl e TR 2. . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . Not a ppl i c abl e Ls-4s @see.r 4W f lo a.si \. Ls.4c, rM,gboA lo l-50 Lb 4'l g4ot ag\icaldt [Q t-EGd L5- 46 ,g,y ,pp};c,j4, lq g<g(n j L*.>- 4 9 Klot appl d ($ 2-3C.] LS- SO
'U I' M 3-'O L5- 51 Nse.er 4-b } c 3.3-H J _
ts. 52. 6,t 9pnca lG3.se2.1 LS. 5 ~.5 Rot apphc.2ds {Dc. 3.3-co2.\ i l WCGS- NSHCs - CTS 3M.2 2 S/2S/97 _ _ _ _ _ _ _ _ _ _ _ _ _ _ _ . _ i
f INSERT 4-a 0 7-13 IV. SPECIFIC NO SIGNIFICANT HAZARDS CONSIDERATIONS NSHC LS-44 10 CFR 50.92 EVALUATION i FOR TECHNICAL CHANGES THAT IMPOSE LESS RESTRICTIVE REQUIREMENTS WITHIN THE TECHNICAL SPECIFICATIONS CTS SR 4.3.3.5.2 requires the auxiliary shutdown panel ( ASP) controls be demonstrated OPERABLE at least once per 18 months by operating each actuated , component from the ASP. The proposed change revises CTS SR 4.3.3.5.2 to delete the phrase "by operating each actuated component from the ASP." If temporary evacuation of the control room is required because of some abnormal condition. l the operators can establish and maintain the plant in a hot standby condition I from outside the control room. The OPERABILITY of the ASP controls ensures there i is sufficient information available on selected unit parameters to place and maintain the unit in MODE 3 should the control room become inaccessible. CTS SR 4.3.3.5.2 verifies that the ASP controls perform the intended function. The CTS requirement to operate each actuated component is overly restrictive since the specific components associated with the ASP are verified OPERABLE by other specifications. For example. USAR Section 7.4.3.1.1 identifies the i automatic / manual control for each power operated atmospheric dump valve as an ASP l control. ITS SR 3.7.4.1 verifies that the atmospheric dump valve is OPERABLE by 1 performance of one complete cycle of each valve. Operation of the equipment from l the ASP is not necessary. The surveillance can be satisfied by performance of a l continuity check. Performance of this surveillance in conjunction with the performance of other required surveillances on equipment associated with the ASP will ensure that if the control room becomes inaccessible. the plant can be placed and maintained in MODE 3. l This proposed TS change has been evaluated and it has been determined that it involves no significant hazards consideration. This determination has been performed in accordance with the criteria set forth in 10 CFR 50.92(c) as quoted l below:
"The Commission may make a final determination. pursuant to the procedures in 50.91. that a proposed amendment to an operating license for a facility licensed under 50.21 (b) or 50.22 or for a testing facility involves no significant hazards consideration, if operation of the facility in accordance with the proposed amendment would not:
- 1. Involve a significant increase in the probability or consequences of l an accident previously evaluated; or l
- 2. Create the possibility of a new or different kind of accident from
! any accident previously evaluated; or 4 1 l l l
- - . _ . . _ - _ - - - = _ _ = . _ -
IV. SPECIFIC NO SIGNIFICANT HAZARDS CONSIDERATION NSHC LS-44 l (continued)
- 3. Involve a significant reduction in a margin of safety. "
- The following evaluation is provided for the three categories of the significant hazards consideration standards
- 1. Does the change involve a significant increase in the probability or consequences of an accident previously evaluated?
The proposed change involves surveillance requirements for ASP controls that are used to place and maintain the plant in MODE 3 from a location other than the
- control room. This type of change would have no effect on the probability of
- occurrence of previously evaluated accidents. The equipment required to be
! operated and monitored from the ASP are not modified by the proposed change and [- will be maintained OPERABLE in accordance the equipment-specific surveillance requirements. ITS SR 3.3.4.2 will ensure that the ASP controls are OPERABLE such that, if the control room become inaccessible, the plant can be placed and maintained'in MODE 3 from outside the control room. No changes in the ASP controls would result.from the proposed change, and the consequences of postulated accidents would not be adversely affected. Therefore, the proposed change would not result in a significant increase in the probability or consequences of a previously evaluated accident. i 2, Does the change create the possibility of a new or different kind of accident from any accident previously evaluated? The assumptions of the accident analyses are unaffected by the proposed change. The surveillance requirements that remain in Technical Specifications provide i assurance that unit can be placed and maintained in MODE 3 from outside the I control room. Also, no new permutations or event initiators are introduced by i the deletion of the requirement to operate each actuated component from the ASP. j- Therefore, this proposed change would not create the possibility of a new or different kind of accident.
- 3. .Does this change involve a significant reduction in a margin of safety?
l The proposed change has an insignificant effect on OPERABILITY requirements of the ASP controls necessary to place and maintain the unit in MODE 3 from a location other than the control room. The remaining surveillance of controls and equipment-specific surveillance requirements assure proper mitigation of assumed events. 'In addition, the accident analyses are assumed to be initiated from conditions which are consistent with the Technical Specifications Limiting Condition for Operation. The proposed change would not have a significant effect on ASP controls OPERABILITY. Therefore, there is no change in the accident ! analyses and all relevant event acceptance criteria remain valid. Further, the proposed change has no effect on any actual or regulated failure point which is
I IV. SPECIFIC NO SIGNIFICANT HAZARDS CONSIDERATION ' l NSHC LS-44
- (continued) protected by an event acceptance criterion. Because there is no change in any failure point nor in any event acceptance criteria, there is no reduction in a l
margin of safety. NO SIGNIFICANT HAZARDS CONSIDERATION DETERMINATION Based on the above evaluation, it is concluded that the activities associated with NSHC "LS-44" resulting from the conversion to the improved TS format satisfy the no significant hazards consideration standards of 10 CFR 50.92(c). and accordingly, a no significant hazards consideration finding is justified. l l l I l l l
ADDITIONAL INFORMATION COVER SHEET I ADDITIONAL INFORMATION NO: O 8-01 APPLICABILITY: DC, CP, WC, CA , i REQUEST: This change, consistent with NUREG-1431 Rev.1, revises " Channel" and
" Instrument" to " Function."
1 Comment: Insufficient discussion to make a determination that the change is administrative. Revise DOC. All occurrences of this change in CTS 3.3.6 are not j identified and discussed. Insufficient discussion to make a determination that the change is administrative. Revise DOC. All occurrences of this change in CTS 3.3.6 are neither identified nor evaluated. FLOG RESPONSE: See response to Comment Number Q 1-A GEN and new DOC 1-63-A. ATTACHED PAGES: l See attached pages for Comment Number Q 1-A GEN. I l t
l l ADDITIONAL INFORMATION COVER SHEET ADDITIONAL INFORMATION NO: O 8-04 APPLICABILITY: DC, CP, WC, CA REQUEST: Consistent with NUREG-1431, Rev.1 (ITS 3.3.3 Required Actions C.1, E.1, and
- G.1), this change deletes the requirement to initiate an alternate means of monitoring within 72 hours when two channels of containment radiation level [or .
RVLIS) are inoperable as specified in current TS [3.3.3.6 ACTION c]. Comment: What is the basis for deleting the requirement to initiate the alternate
- method of monitoring in the case of containment high range radiation monitoring? The NSHC indicates that this automatically happens in the case of RVLIS, but implies that l PASS monitoring of the containment is not initiated under condition G.
1 FLOG RESPONSE: NSHC LS-17 has been revised as per the attached. ATTACHED PAGES: Encl. 4 50
)
l i l l I-i l l
j IV. SPECIFIC NO SIGNIFICANT HAZARDS CONSIDERATIONS , 1 NSHC LS-17 J 10 CFR 50.92 EVALUATION l FOR ! TECHNICAL CHANGES THAT IMPOSE LESS RESTRICTIVE REQUIREMENTS WITHIN THE TECHNICAL SPECIFICATIONS l This change deletes the requirement to initiate the preplanned alternate method of l monitoring containment radiation or reactor vessel water level within 72 hours when l two channels are inoperable. This makes ACTION c of current TS LCO 3.3.3.6 the same i as ACTION b, except that a plant shutdown is not needed if the 7 day A0T is not met for these functions with preplanned alternates. Containment radiation indication is
- used to assess whether the fuel cladding and reactor coolant pressure boundaries have l been breached such that a significant portion of the core activity inventory is available for release to the environs. The preplanned alternate for this variable uses the PASS system which is administrative 1y controlled outside the TS. [The preplanned alternates for RVLIS include a combination of the core exit thermoc uples, RCS wide range hot and cold leg temperature, wide range RCS pressure, press izer level, and RCS subcooling monitor indications to verify adequate core cooling . These variables
- are already continuously monitored under the LC0 and do not requi an action l directing that they be initiated.
The proposed TS change has been evaluated and it has been determined that it involves i no significant hazards consideration. This determination has been performed in l l accordance with the criteria set forth in 10 CFR 50.92(c) as quoted below: 1 "The Corimission may make a final determination. pursuant to the procedures in 50.91. that a proposed amendnent to an operating license for a facility i licensed under 50.21(b) or 50.22 or for a testing facility involves no l significant hazards consideration, if operation of the facility in accordance with the proposed amendrnent would not:
- 1. Involve a significant increase in the probability or consequences of an accident previously evaluated; or
- 2. Create the possibility of a new or different kind of accident frorn any accident previously evaluated; or
- 3. Involve a significant reduction in a margin of safety."
l l The following evaluation is provided for the three categories of the significant j hazards consideration standards:
- 1. Does the change involve a significant increase in the probability or consequences of an accident previously evaluated?
WCGS- NSHCs - CTS 3N.2 50 5/158 7
INSERT LS-17 0 8-04 Implementation of containment air sampling via the PASS will be initiated as required'by ITS 3.3.3 Condition G. There is no safety benefit to activating the PASS earlier than required by Condition G considering the other indications available to detect inadequate core cooling. i l I j l l
ADDITIONAL INFORMATION COVER SHEET ADDITIONAL INFORMATION NO: O 8-05 APPLICABILITY: WC, CA REQUEST: In conjunction with CN 8-03-A, this change rearranges the ACTION Statements for the single channel Functions (i.e., SG Water Level- Wide Range and AFW Flow Rate). No change in AOT is requested, therefore this is an administrative change. Comment: Insufficient discussion to make a determination that the change is administrative. Revise DOC. FLOG RESPONSE: See the response to Comment Number Q 3.3-21 concerning the required number of channels for wide range steam generator water level and AFW flow rate. Based on maintaining the CTS for these functions, DOC 8-05-A provides the administrative changes to reflect single channel actions. ATTACHED PAGES: None l l [ 9
ADDITIONAL INFORMATION COVER SHEET ADDITICNAL INFORMATlON NO: Q 8-07f APPLICABILITY: DC, WC, CA REQUEST: ITS proposes steam generator wate ievel (Wide Range) and auxiliary feec' water flow functions as diverse variables because the ITS includes only one required instrument channel for each function per steam generator. Comment: The staff does not credit Steam Generator Water Level (Wide Range) and Auxiliary Feedwater Flow functions as diverse PAM variables. However, the staff does credit Steam Generator Water Level (Wide Range) instrumentation in redundant loops in three and four loop Westinghouse plant designs. The staff also credits Auxiliary Feedwater Flow instrumentation in redundant loops in three and four loop Westinghouse plants. Therefore, credit for redundant loop design is given for specified PAM functions. If credit is taken for the redundancy provided by the instrumentation in the other loops, the STS LCO wording applies and the reauired number of channels is "2." Provide a design basis justification for deviating from the STS required number of channels for steam generator water level (Wide Range) and auxiliary feedwater flow. FLOG RESPONSE: See the response to Comment Number Q 3.3-21 (4) for WCGS and Callaway and Comment Number O 3.3-71 for DCPP. ATTACHED PAGES: None ) l l
?
ADDITIONAL INFORMATION COVER SHEET ADDITIONAL INFORMATION NO: O 2-03 (2.0) APPLICABILITY: CA, WC REQUEST: CTS ACTION b.1, Equation 2.2-1, and the values for Total Allowance (TA), Z, and Sensor Error (S) are deleted, consistent with NUREG-1431 Rev.1, as they are no longer required. Comment: Explain the justification that administrat ' TS changes include moving CTS requirements that permit adjustment of trip setpoints to a licensee controlled document (TS Bases or FSAR). Additionally, the 12 hour limit to adjust the trip setpoint in ACTION b.1 is deleted. The staff position is that this change is less restrictive. FLOG RESPONSE: See the response to Comment Number Q 2-02 (3.3). ATTACHED PAGES: None i I l l l l 1 I l
i ADDITIONAL INFORMATION COVER SHEET l l ADDITIONAL INFORMATION NO: Q 2-04 (2.0) APPLICABILITY: CA, DC, WC 1 REQUEST: Addition of the inequalb/ signs to K i, K , K ,3 and Ka, consistent with NUREG-1431 Rev.1, indicates the conservative direction for these K values. Comment: Potential OOS - Provide a source document to justify this change, preferably l a document that has staff review and approval. FLOG RESPONSE: This DOC is dented and the CTS is retained. JFD 3.3-10 is revised for Callaway and W CGS and new JFD 3.3-108 is added for DCPP to justify the revision of the ITS to be consistent with the CTS. ATTACHED PAGES: Attachment No. 5 CTS 2.0 - ITS 2.0 Encl. 2 2-7,2-8,2-9,2-10 Encl.3A 2 Encl. 3B 1 Attachment No. 9 CTS 3/4.3 - ITS 3.3 Encl.5A 3.3-23, 3.3-24 Encl.6A 2 Encl. OB 2 I i l i l
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. I
= = = = = = =- = = = =
u T K, C ( A ( T i
- O T, g
2 N A 2 E T S 8 S A $ S E L L B E )
*' t 2
2 t 3 *
- t s
5 A - B R + + t o + + T A I U S, T , + -
' 1 3 TA K K g 2
- 4 6 I T T t A t I t I I 1 T t A '
+
R E I I P ( T I M E
)
S N0 U25 T
- R t K- I E + +
V : e EL - O '( ( 1 r e E Ro f 1: T h Cp E A W Fu - T LA r O Dei N Nh
TABLE 2.2-1 (Condnued) TABLE NOTATIONS (Continued) NOTE 1: (Continued) T' s 586.5'F (Nominal Tavg at RATED THERMAL POWER); 0.00067 h { p2-04-l P = Pressurizer pressure, psig; P' = 2235 psig (Nominal RCS operating pressure); S = Laplace transform operator, s'1; and fg(Al) is a iunction of the indicated difference between top and bottom detectors of the power-range neutron ion chambers: with gains to be selected based on measured instrument response during plant STARTUP tests such that: b (i) for qg - qb etween -23% and + 5%, fq(AI) = 0, where qg and qb are percent RATED THERMAL POWER in the top and bottom halves of the core sei,pecieet,, and qt + 9bi s total THERMAL POWER in percent of RATED THERMAL POWER; (ii) for each percent that the magnitude of qt - Ab exceeds -23%, the AT Trip Setpoint shall be automatically reduced by 2.27% of its value at RATED THERMAL POWER; and (iii) for each percent that the magnitude of eq - ab exceeds +5%, the AT Trip Setpoint shall be automatically reduced by 1.84% of its value at RATED THERMAL POVER. NOTE 2: 5 9:nner: -- : J .2- mp S:";;!-: ed d e-::: u :_.. :: f T@ S :";;:--: 'y -- .:. t'- ETMl])jij
? jet g 37 - - kuunwar4 WOLF CREEK-UNITI 2-8 SIL5/97 Mark-up of CTS 2.0
TABLE 2.2-1 (Continued) IABLE NOTATIONS (Continued) NOTE 12: OVERPOWER AT IThe OVERPOWER AT Function Allowable Value shall not exceed {~W**2.gg;LGFJi iiis following setpoint by more than 2.6% of AT span: F*** AT (t * *' S) ( i ) 5; AT, (K. - (1 + t, S) (1 + t, S) K, (I + t, S) (I + t.S) T - K. [T (I + t.S) - T"] - f;(AI)) Where: AT = Measured AT;
= Lead-lag compensator on measured AT; g t j , t2 me stants utilized in lead 4ag compensator for AT s,
((
' = Lag compensator on measured AT; I+t 3S Af-
= Time constant utilized in the lag compensator for AT, t3
% 2 s; h2 04l t3 { jg ATo = Indicated AT at RATED THERMAL POWER; K4 --e 1.10; . pyg
.02rF for increasing average temperature and 0 for decreasing average "
K5 mperature;
*7
= The fur.ction generated by the rate-lag compensator for Tavgdynamic I + t, S compensation; g
= Time constants utilized in the rate-lag compensator for Tavg 7 10 s; 17 { .
I
= Lag compensator on measured Tavg; I+t 6S t6 = Time constant utilized in the measured Tavg, lag compensator T6 = 0 s; ilDLF CREEK-UNIT 1 2-9 5115/97 MarA-up of CTS 2.0
TABLE 2.2-1 (Continued) IAB.LE NOTATIONS (Continued)
]
NOTE-3:2: (Continued) K6 g 100128/*F for T > T* and K6 for T sT"; { lR2-o4} T = Average temperature. *F; 'M T" = Indicated T, a instrumentd,t5RATED 586.5'F); THERMAL POWER (Calibration temperature for AT S = Laplace transform operator, s-1; and f2(AI) = 0 for all Al '
"JTE ' % 22-1*% M AT p
": r ' ..r T @ T:;i: 22" d _. . _ _ : f _ _. . ; _ ': f T@ T :O::-". h :._ . S r. h h e
l l WOLF CREEK-UNIT 1 2-10 $115/97 Mark-up ofCTS 2.0
y l l CamGE NulBER EiHC DESCRIPTION the revision to 10CFR50.73, an LER would no longer be required. Setpoint adjustments required by current ACTION b.1 for analog channels are performed with the affected channel removed from service. Equation 2.2 1 ; effectively allows rack error to increase above its ) nominal value by an amount dependent on the available ! setpoint margin; however, this margin is available for utilization at any time and is not restricted to whether the ACTION is entered. As such, current ACTION b.1 effectively provides no different recourse than current ACTION b.2. With a nonconservative as measured trip 1 setpoint, current practice is to enter ACTION b.2. Therefore CTS ACTION b.1, Equation 2.21, and the values for TA, Z, and S can be deleted as they are no longer required. ((tg tec.1-54-M 4 %. 3.s g % 2-ozM)] K the ali TsTgns, to K , K 2-04_ Add e si on tw NUREG- 31 Rev 2
, Ks. a es the Kh co rva e dir n for
, indi se K va y
- s. {Also
/ ty si ve added t ime cons nts (r values) th var le setti s to indi te the !
conserv ve dir ion for e blishi time st3nt I sett s. the i ality si to thes ime/ Q tant va s is cons tent with EG143.) - l 2 05 A Not applicable to Wolf Creek. See Conversion Comparison Table (Enclosure 38). ! 2 06 LG The requirements stipulated in ACTIONS [a and b.2] are moved to ITS Table 3.3.11, with direction contained in ! the [ITS Background (Trip Setpoints and Allowable Values) Bases ACTIONS Bases, and SR 3.3.1.10 and SR 3.3.1.11 ' Bases]. This change removes details more appropriately controlled outside of the TS while retaining those aspects I necessary to assure the protection functions are performed if necessary. l 2 07 A Not applicable to Wolf Creek. See Conversion Comparison Table (Enclosure 38).
-QS A & applicaW. k LadFCreek, Saa. (cme m ImpM
~~ TaMa. (Endos,uu. 3S) , .
p g,g WCGS-Desenprion of Changes to CTS 2.0 2 S/158 7
I _ ~
.c e T% c.Pses opdik.c.hge. veydoTa%21-1, dde 1, In +do g,3 m g, cp3,gcog A reflech nea overtempeAuw. d-Spwometers, appmed.or urnu 2. tk Ame4M 55/41, uA amitcA fh- urdi G t Fla.M-co2.
- M VERSION COMPARIS0N TABLE - CURRENT TS 2.0 page 1 or 1 TECH SPEC CHANGE APPLICABILITY NUMBER DESCRIPTION DIABLO CAh.M COMANCHE PEAK WOLF CREEK CALLAWAY 1-01 The specific restrictions on nuder of loops and licensed No - not in current No - not in current Yes Yes A reactor power for power operation would be removed from the TS. TS.
SLs. Ti.2se restrictions are stated in other requirements of the license. 1-02 The requirement es odied in separate administrative controls Yes Yes Yes Yes A dealing with SL violations is deleted. 2-01 The requirements of this LCO are moved to ITS 3.3.1. Yes __ Yes Yes Yes A
@ ca2ola) gug 2-02 The Reactor Trip System Instrumentation Trip Setpoints are No - retained Yes - moved to ITS Yes - moved to ITS Yes moved to ITS LG moved to a licensee controlled document. current TS 3.3.1 Bases 3.3.1 Bases. 3.3.1 Bases.
2 03 CTS ACTION b.1. Equation 2.2 1, and the values for Total No - not in current No - not in current Yes Yes A Allawance (TA), Z. and Sensor Error (S) are deleted. TS. TS j consistent with i4UREG-1431 Rev.1. as they are no longer required. 2-04 of inequ he t ons s Jer h R- f [to K .K..K,. K, y si si nt wi G- 1/ .V[ (ur4__ _ Yee- [O. 04 l l Rev. ndicat the ser .tve di ection r th(se g - P4atLAScM / AQ ues {a val. _ 2 05-A This change corrects the OT6T dequation in the DCPP Yes No No No CTS by relocating the bracket to the correct position, as . __ described in CN 3.3-10 of thehackagedCTs 3/4.3) IIC ALL-0031 2-06 The requirements stipulated in ACTIONS [a and b] are moved Yes Yes Yes Yes LG to ITS Table 3.3.1-1, with explicit direction contained in the ITS Bases. 2-07 A This change incorporates the values for T* (Nomir.a1mT at Yes No No No RATED THERMAL POWER), that were inadvertantly deleted during a previous License Amendnent for DCPP. W""S-Conversion Comparison Table - CTS 2.0 5/15M7
I RTS Instrumentation 3.3.1 1 \ Table 3.3.1 1 (page 7 of 8) l j Reactor Trip System Instrumentation I l l
- Ngtg 1- Overtemoerature AT '
The Ov:rtemperature aT Function Allowable Value shall not exceed the following Trip Setpoint by more than 3-64 1.3% of AT span. WBtPS$ - l (1+T 3s) 1 i (1+ t,s) 1 3 j
$f $ ar, < K3 - K, T - T, + K3 (P - P,) - f (AI) 3 l
- (1 + t,s) ,1 + T3 s, (1+ T3 s) (1+ T,s) ,
I i i l l Wher0: AT is measured RCS AT. 'F. AT, is the indicated AT at RTP. *F. s is the Laplace transform operator, sec'2 l T is the measured RCS average temperature. 'F. lGWP T' 1F the W @T at RTP
- f. *f=+ -
m s 500*f 586.5'F. };gg.pgj; f j i ! P is the measured pressurizer pressure, psig. , P' is the nominal RCS operating pressure r t 2235 psig. 02-o+ , peg pst l i-09 1.10 0-0138 0.0137/*F K3 0.000671/psig l W 6 see h 3 see 13 [2] xc @ sec O . jg.psy 33 16 sec g is y see
- t. . [2] x ; = 0 sec
*3;34103-5 f (AI) = Mi-26 {35 23* + (q, i q )} when qs - q, < 354 23% RTP IG33 yI ,
i g- -, o n g of RTP when 23% 354 RTP s q, - q, s M St RTP 1 1-05 {(q, q,) - 5% 7} when q, - q, > M 5% RTP g g;pg; ,
~
l where qi and q, are percent RTP in the upper and lower halves of the core. j respectivel. ~.nd q, + q, is the total THERMAL POWER in percent RTP. , I i. I i d k i WCGS-Mark-up ofNUREG-1431 -ITS 3.3 3.3 23 S/1587 l l
1 RTS Instrumentation 3.3.1 Table 3.3.11 (page 8 of 8) . Reactor Trip System Instrumentation Note 2- Overoower AT l i The Overpower AT Function Allowable Value shall not exceed the following Trip Setpoint by more than -34 2.6% of AT span. Mig.75gl (1+ T3 s) i (T,s) i 1 or :s or, < r,- r r - r, r -r y - r,(ar) - (1+ T2 8) 1+ T 8 3 (1 + T3 8) 1+ Ts 8, (1 + Ts *) t 33 i l l Where: AT is measured RCS AT, *F. , l AT is the indicated AT at RTP, *F. s is the Laplace transform operator, sec 2 T is the measured RCS average temperature, 'F. T' is the indicated M T,,, at RTP (Calibration temperature for aT instrumentation). O ;pgggg s 58PF- 586.5'F.
)
1.10 K. 0.02/*F for increasing T , N 0.00128/*F when T > T- Q2M(2.0)}
, g 0/*F for decreasing T,,, 0/*F when T s T" l ti 6 see TE3see t 3@f23sec gggpsg i l
l Ts s DJ m
= 0 sec t,g10sec g '
l l ! fr(AI) = Of RTP for all al. i f l l l f WCGS-Mark-up ofNUREG-H31-ITS 3.3 3.3 24 S/2SM7
CHANGE NUMBER JUSTIFICATION found in the BASES. The note replaces the exception to LCO 3.0.4 in the current TS. I 3.3 08 This change deletes the Reviewer's Note in ITS Tables 3.3.1-1 and l 3.3.21 and adds a Note reflecting the Allowable Value as the ! LSSS. Trip Set points are listed in the Bases as one of the allowed formats approved by the NRC. These changes are acceptable as administrative change to match an approved format. os.1A&Sl\ 3.3 09 o See41diveca6n Comfa'riserfiabM 3.3 10 [].; In addition, the f (aI) t penalty function was corrected toiz-odod reflect correct decimal point placement and to ensure a reduction a m w2b in the set point if (q, - q ) is outside the deadband. The f t (al) value must be positive such that it lowers the set point when subtracted. The inequality signs around the deadband were corrected to reflect a zero penalty when (qt - q ) is within the deadband. Decimal point placement corrections have been made to recognize that the penalty function gains have units of (% aT an/* RTP). e (e GA-2c. Y l 3.3 11 Not applicable to Wolf Creek. See Conversion Comparison Table (Enclosure 6B). 3.3 12 This change corrects a typo in the inequality sign of ITS Table 3.3.2 1 Note (h). The time constant should be ~2" the specified value. I 3.3 13 Not applicable to Wolf Creek. See Conversion Comparison Table ! (Enclosure 68). 3.3 14 This change retains the monthly COT for Function 6.h of ITS Table 3.3.21, per current TS Table 4.3 2 Functional Unit 6.h. No TAD 0T is performed. l 3.3-15 The CHANNEL CHECK surveillance (SR 3.3.2.1) is deleted from the i P-11 [ ] interlock because CHANNEL CHECKS are not applicable for l_ permissive functions. This change is consistent with the current ! TS.
- 3.3 16 This change [ adds Note (p) and] deletes SR 3.3.2.9 from Function 69 in ITS Table 3.3.21. [ Note [(p)] is added to avoid auxiliary feedwater actuations during normal plant startups and shutdowns].
J WCGS-Differencesfrom NUREG-1431-ITS 3.3 2 S/1S/97 1 i
INSERT 6A-2a 0 3.3dGEN The addition of footnote [(m)] to ITS Table 3.3.1-1 'or Function 10 clarifies the low flow setpoint relationship to the quantity identified as [ loop design flow], consistent with current TS. INSERT 6A-2b 0 2-04 (2.0) Inequality signs on K i, Kr, K , Ks, and K are changed to equal signs to be 4 consistent with the CTS. INSERT 6A-2c 0 2-04 (2.0) [ Inequality signs on t , tz , 1 , 3 3 2, 4 ts, te, and trare changed to equal signs to be consistent with the CTS.] 1
Page 2 of 23 CONVERSION COMPARISON TABLE FOR DIFFERENCES FROM NUREG-1431 SECTION 3.3 TECH SPEC CHANGE APPLICABILITY DIABLO CANYON COMANCHE PEAK WOLF CREEK CALLAWAY NUMBER DESCRIPTION Yes Yes Yes Yes 3.3 07 Note 3 is added to ITS SR 3.3.1.11 to be consistent with the current T5 Table 4.3-1 Note [5]. This ensures that this exception, for power and intermediate range detector plateau voltage verification as discussed in the ITS BASES for SR 3.3.1.11, is included in the Technical Specifications rather than being only found in the BASES. . No-retained current Yes Yes Yes 3.3 08 Deletes the Reviewer's Note in ITS Tables 3.3.1-1 and 3.3.21 and adds a Note reflecting the Allowable Value as TS format. the LSSS. Trip Setpoints are listed in the Bases. Yes No not in current 6 ,AdAsprfd-- Yes (current TS per 3.3 09 The addition of footnote [(m)] to ITS Table 3.3.11 for T OL Amendment No. 15 xtpotnt relationship TS Ves. Function 10 clarifies the low dated 4 8-86) _ to the quantity identifled a MinimumMeasuredFlowD consistent with the current T g43,4 fgg {Q 3,3g,g No-See CN 3.3 38 Yes Yes (current TS per 3.3-10 []. In addition. the f (61) cenalth function was i Mr r4o-See] OL Amendmert correctep(afed fhe Ke, K2, Kg ,KG, aud Kl. 3.3 -to8/ N 2 dated
%e.qualiti s'igns were.changeA. to eget si,3ns. ,,g g msutTca-2a ,- . -
Yes No - See CN 3.3-41 No-see CN 3.3 41 No - see CN 3.3 41. 3.3-11 Added "or Rod Control System incapable of rod withdrawal." which makes Note (f) the complete antithesis of Note (b). Yes Yes Yes Corrects typo in the inequality sign of ITS Table 3.3.2-1 No - see CN 3.3-12 Note (h). 3.3-105. No No No The equations for Overteeperature 4T are revised to be Yes 3.3-13 consistent with the DCPP CTS. The value of the time constant t, nas always been 0 seconds and the factors utilizing these time constants have not been shown as part of these equations in licensing doctments since the factor value has been unity. Thus, the factors utilizing these time constants have been deleted. S!!SN7 WCGS-Conversion Compariwn Table-ITS3.3
INSERT 6B-2a 0 2-04 (2.0) [ Inequality signs on t ,i tz , t 3, t., ts, t,and ti are changed to equal signs to be consistent witht the CTS.]
\
t i t t 0 _ - - - - - _ _ ~ - - _ - - - . . . - - - . _ _-._---.._____...._.._.1.--.. - _ ._ _ --___-.-- -- _ . --._____-.
. . ., - - - . _ . . ~ - . . . -- - - -
ADDITIONAL INFORMATION COVER SHEET ADDITIONAL INFORMATION NO: O 3.3 d GEN APPLICABILITY: DC, CP, WC REQUEST: Generic JFD Comment Section 3.3.1 Comment: The allowable value and trip setpoint of the reactor coolant low flow function (function 10) should be explicitly stated as a percentage of minimum measured flow per loop. FLOG RESPONSE: ITS Tables 3.3.1-1 and 3.3.2-1 have been revised as required to include j the appropriate units of indication. ATTACHED PAGES: Encl. SA 3.3-19,3.3-43 Encl. 5B B 3.5-22 Encl.6A 2 Encl. 6B 2 l l j l l e i
. RTS Instrtmentation 3.3.1 ) Tebte 3.3.1 1 (page 3 of 8) Reactor Trip System Instrumentation i ,' APPLICABLE MODES SURVEILLANC f, OR OTHER ' E SPECIFIED REQUIRED FUNCTION REQUIREMENT ALLOWABLE 99f9 + g l CONDITIONS CHANNELS CONDITIONS S VALUE " SEffet#fM
- 8. Pressurfter Pressure
- a. Low 1* 4 M SR 3.3.1.1 4806 4906 M;If51psig SR 3.3.1.7 SR 3.3.1.10 33 35 po43 (%$d (ar3<sy.so- la3.3 55' j
[_.s.3-sj
- b. High 1,2 4 E SR 3.3.1.1 2596 SR 3.3.1.7 si2400psig e-EBOS SR 3.3.1 10 pett gy g g F W @ -}Q3.3-5F}
- 9. Pressurizer Weter 1* 3 M SR 3.3.1.1 s.95". W of s-9EN Level High SR 3.3.1.7 instrument iit mR M g -MB m
SR 3.3.1.10 spian isu..itHeiin. e. 3.3-09
- 10. Reactor Cootent 3M stXKf."I Flow - Leae les L(op M
RfM;.7 a)._(m) [#SMEbl"
-lQ33-55l 3.3 -5
= :.
.. ;!.,;. i 4* % kM .1." 8 Pre M foop = ".!.1.7 W lW.448 L. : i4- 4* % M = :. .;.; 89:e e;905" e --
toop = :. .1.7 s-4Dr9M N
. ,. "...^^
= :.:. " . ;t, i
(continued) (c) :. . . ._. . . ;.a . . ; . ; . _ ._ _ . I ! . . v. _ c..; . . _ , .. . . . ; . . . ; , ;d ;
= _ , - . . - . , ;,, .. _ ;..Z]hii'AlleiiiitdEval_ue defines ~the; timitingiW,tideoi. Setting'.lhe gggg this. W K M M ,_6ts]
(g) Above the P-7 (Low Power Reactor Trips Block) interlock.
.:.; ;...;... 0;r_..:_. ._.. . ;_, ......i. ;;; ;; .t. r ;; r. .. __. : ;, ;; ; ; . .... ; ; :: .: r : ;r._.. : . _ ... . r ;._;
ggg (mb7e of loop desdn flea - So,324 ym r
;5.3ct. GEu ] 3.3-49 C
WCGS-Mark-up ofNUREG-H31 'ITS3.3 3.3 19 5/1587 1
ESFAS Instrumentation 3.3.2 Table 3.3.21 (page 10 of 11) Engineered Safety Feature Actuation System Instrumentation APPLICABLE M DES OR ODER SPECIFIED REQUIRED SLRVEILLANCE ALLOWABLE 1 REP FLNCTION COWITIONS CH4BIELS COEITIONS REQUIREENTS VALUE58 EEWeisW*
- 6. Auxiliary Feedeter (continued)
"r
- 2
' --Ma#P k_ se .; '; Q{ez,n)he dent-hmy h 4 0 .2.2.7 i ; O:0 i ; t-f7034 two = :.:.2.0 Z . .2.!:
ve m ge tue vehege W-' C Ioise1 33-1o0
- g. Trip of all Main Feedseter Pumps ih 2 per pump J SR 3.3.2.8 2 2.2.2.0 m
. ; 2 p:
4e
= :.:.:.:: 3 -
- h. Auxiliary Feedseter P.sup Suction Transfer 1.2.3 fi!) 3 FM SR 3.3.2.1 S$3 p.sia _ M P "T 7"*P on Suction Pressure -
ER-}4 e 7 .:.: M '~
~?
SR 3.3.2.9 fre+ei e-t-i Low SR 3.3.2.12 fre4ei
- 7. Autoestic Switchover to Contairement Simp
- a. Automatic Actuation 1.2.3.4 2 trains C SR 3.3.2.2 NA E Logic and Actuation Relays SR 3.3.2.4A SR 3.3.2.St37
@ R 3.3.2.83) $13 N
- b. Refueling Water 1.2.3.4 4 Storage Tank U NST)
K SR 3.3.2.1 @iH H e-GS gg SR 3.3.2.5 W.; :: 3-f--3 Level Low Low SR 3.3.2.9 and _m
@H MI- {G 3 5 55 l 1rf--i ~3.3-Sh-Coincident with Refer to Function 1 (Safety Injection) for all initiation SafetyInjection functions and requirements. 4 4*p g 43.34 (r&d
}LdC3*EM - Sc. bb h he.%ipSe, (contifad)
(a) " /.; c ': = . = s'i: i;;__12: 2, _ c i . at "" < t : Y:: , 2:a x W ir
^_.2 x; _d i; t'; .it M'~-^~ ..
_ C'_1 , shrines WN= - ._._ - h' .
]qs.3-vg .
M ~.~ E m-aL-**t: m m era r i A 44 W susf( I ps.sr-) WCGS-Mark-ap ofNUJtEG-1431 - ITS 3.3 3.3 43 5/1587
RTS Instrumentation B 3.3.1 BASES APPLICABLE 9. Pressurizer Water Level Hiah (continued) SAFETY ANALYSES, LCO, and on increasing power by the P 7 interlock. On decreasing APPLICABILITY power, this trip Function is automatically blocked below P 7. Below the P 7 setpoint, transients that could raise the pressurizer water level will be slow and the operator will have sufficient time to evaluate unit conditions and ; take corrective actions. !
- 10. Reactor Coolant Flow Low
,,_m,
, _ _ _ _ _m....
_ _ , _ _ . , - ,m, . . ,..,n_~_,,m_ mm m , i___s, mm m The Reactor Coolant Flow-Low MM trip Function ensures that protection is provided against violating the DNBR limit due to low flow in one or more RCS loops, while avoiding reactor trips due to normal variations in loop flow. Above the P 8 setpoint, which is approximately 48% ] RTP, a loss of flow in any RCS loop will actuate a reactor trip. ( M low the P 8 setpoint and above the.Pi7 l 63-ED l setpoint, a loss of flow in two or more loops is required toactuateareactortripjF ctio I e g apPt rent mar t CEach RCS loop has three flow detectors to monitor flow. The flow signals are not used for any control j system inpt.t.
~
, bsq.97.of teepeqn The LC0 requires three Reactor Coolant Flo+ Low 7 G33 # i . channels per loop to be OPERABLE in MODE 1 above -8. The l o [, pip Setpoint iski$0CDPTgli1M1iigmMeitsur(4Kow 0$V
-9p;250gpnoj. In MODE 1, above the P-8 setpoint, a loss of j flow in one RCS loop could result in DNB conditions in the l
core. @ IS 323-22]- l b. Reactor Cociant flow Low 'Two Loco:0 Thc C;;; tor Cociant ricw-L;w 'Two Loops; trip Functi;n n;urt; th;t p ;;;^ tion is pr;;ided ; ; inst j viciatin- th: 0"SC limit due to icw flow in two or 1 (continued) WCGS-Mark-up ofNUREG-1431-Bases 3.3 B 3.3-22 5/15l97 4
INSERT B 3.3-22 WC 3.3-ED Below the P-8 setpoint a loss of flow in two or more loops is required to actuate a reactor trip because of the lower power level and the greater margin to the design limit DNBR. Below the P-7 setpoint all reactor trips on low flow are automatically blocked since there is insufficient heat production to be concerned about DNB. (
CHANGE NUMBER JUSTIFICATION found in the BASES. The note replaces the exception to LCO 3.0.4 in the current TS. 3.3 08 This change deletes the Reviewer's Note in ITS Tables 3.3.11 and 3.3.21 and adds a Note reflecting the Allowable Value as the LSSS. Trip Set points are listed in the Bases as one of the allowed formats approved by the NRC. These changes are acceptable as administrative change to match an approved format.-os.sd&&L\ 3.3-09 See4oiivece6n Compa'riserfiabM 3.3 10 [].2 In addition, the f (aI) penalty function was corrected toprMoM 3 reflect correct decimal point placement and to ensure a reduction m 6A-2b in the set point if (q, q,) is outside the deadband. The f3 (aI) value must be positive such that it lowers the set point when subtracted. The inequality signs around the deadband were corrected to reflect a zero penalty when (qt q,) is within the deadband. Decimal point placement corrections have been made to recognize that the penalty function gains have units of (* AT n/%RTP)7 3.3 11 -- Not applicable to Wolf Creek. See Conversion Comparison Table (Enclosure 6B). 3.3-12 This change corrects a typo in the inequality sign of ITS able 3.3.2 1 Note (h). The time constant should be ~2" the specified value. j .3.3 13 Not applicable to Wolf Creek. See Conversion Comparison Table l (Enclosure 68). 3.3-14 This change retains the monthly COT for Function 6.h of ITS Table l 3.3.21, per current TS Table 4.3 2 Functional Unit 6.h. No l TAD 0T is performed. I i 3.3 15 The CHANNEL CHECK surveillance (SR 3.3.2.1) is deleted from the l P-11 [ ] interlock because CHANNEL CHECKS are not applicable for i permissive functions. This change is consistent with the current
- ' TS.
3.3 16 This change [ adds Note (p) and] deletes SR 3.3.2.9 from Function 6g in ITS Table 3.3.2-1. [ Note [(p)] is added to avoid auxiliary feedwater actuations during normal plant startups and shutdowns). WCGS-Differencesfrom NUREG-H31-ITS 3.3 2 S/1S/97
~
l i INSERT 6A-2a 0 3.3dGEN l The addition of footnote [(m)] to ITS Table 3.3.1-1 for Function 10 clarifies the I low flow setpoint relationship to the quantity identified as [ loop design flow), l consistent with current TS. INSERT 6A-2b 0 2-04 (2.0) ! I 1 Inequality signs on K i, K,, K4 Ks. and K, are changed to equal signs to be j consistent with the CTS, l INSERT 6A-2c 0 2-04 (2.0) l [ Inequality signs on t i, tz , T , 3 t,, ts, ts, and T are changed to equal signs to be i consistent with the CTS.] t I l l 1 4-
Page 2 of 23 CONVERSION COMPARISON TABLE FOR DIFFERENCES FROM NUREG-1431 SECTION 3.3 APPLICABILITY TECH SPEC CHANGE , COMANCHE PEAK WOLF CREEK CALLAWAY DESCRIPTION DIABLO CANYON NUMBER Yes Yes Yes Yes 3.3 07 Note 3 is added to ITS SR 3.3.1.11 to be consistent with the current TS Table 4.3-1 Note [5]. This ensures that this exception. for power and intermediate range detector plateau voltage verification as discussed in the ITS BASES for SR 3.3.1.11. is included in the Technical Specifications rather than being only found in the BASES. Yes Yes Yes Deletes the Reviewer's Note in ITS Tables 3.3.1-1 and No-retained current 3.3 08 3.3.21 and adds a Note reflecting the Allowable Value as TS format. the LSSS. Trip Setpoints are listed in the Bases. No-not in current I ,Iflet Prt Yes (current TS per i Yes 3.3 09 The addition of footnote [(m)] to ITS Table 3.3.1 1 for TS vez, OL Amendment No. 15 Function 10 clarifies the low flow xtpoint_ relationship dated 4-8-86) _ , to the quantity identified a [ Minimum Measured Flo]w [G 3.3ME4] < consistent with the current T gg,g,,,,, gg),_ -
~_
No See CN 3.3-38 Yes Yes (current TS per i []. In addition, the f, (al) penalty function was e4o-See 3.3-10 *J 3 3 -m8]. OL Amendment correctepfamd. +he. Ki, th , K4 , Kg, aud.Kr. /
%equalit3 sighs wesc chqed to e.cyl spa.. 42-c4(2M{ g tussutTca. h , - --
No - See CN 3.3-41 No-see CN 3.3-41 No - see CN 3.3-41. Added "or Rod Control System incapable of rod Yes 3.3 11 withdrawal " which makes Note (f) the complete antithesis of Note (b). Yes Yes Yes Corrects typo in the inequality sign of ITS Table 3.3.21 No - see CN 3.3-12 3.3-105. Note (h). No No Yes No 3.3 13 The equations for Overtemperature 4T are revised to be consistent with the DCPP CTS. The value of the time
- constant t, has always been 0 seconds and the factors utilizing these time constants have not been shown as part of these equations in licensing documents since the factor value has been unity. Thus, the factors utilizing these time constants have been deleted.
S/1587 , Il' CGS-Conversion Comparison Table-ITS3.3
____-s - - - --- eem--um . - - 4 e N U W
.c 9
9
.C w
C W 9
'4 M
C O T U
^ W O.
m N O w & U T M C C s e gp N *s= M O m 3 - t7 O o F. - V W CD C m
.C
- u g W L. m 5 $ m- v 2; C m M M M e M M C O' M C CD w M M N h e 4 CD w
@ m m
W 3 GC CT kJ W N C 2: =
= w
. . - , ._ _ _ _ _ _ _ _ _ _ _ = _ _ - . - -
1 ADDITIONAL INFORMATION COVER SHEET l ADDITIONAL INFORMATION NO: O 3.3 e APPLICABILITY: WC REQUEST: Transcription error. More restrictive. Section 3.3.1 l l Comment: CTS shows Action 5 (Action K in ITS markup), ITS markup requires Actions J and K (4.1 and 5 in CTS) when operating in mode 3,4, or 5. Revise CTS markup for Modes 3,4,5. FLOG RESPONSE: CTS Functional Unit 6b., ACTION has been modified to reflect Action 4.1 (DOC 1-08-M) consistent with Action K in the ITS. Additionally, it was i identified that the **" footnote was inadvertently left off the Applicable ' Modes as discussed in DOC 1-38-R. ATTACHED PAGES: Encl. 2 3-2 i l l l.
TABLE 3.3-1 REACTO81 TRIP SYSTEM INSTRUMENTATION 1-43-A T0!.^L "L. GMANNEb8 CHANNELS APPLICABLE iMLG i FUNCTIONAL UNIT OFCHANNEt$ TO"" OPERABLE- MODES ACTION
- 1. Manual Reactor Trip 2 4 3 1, 2 1 l-55-LS-39 2 4 2 3*,4*,5* 10 1-05-A
- 2. Power Range, Neutron Flux l-17-A I'II'b8-7
- a. High Selpoint 4 2 3 1, 2 4
- b. Low Setpoint 4 3 3 12,2 2.1 1-05-A !
- 3. Power Range, Neutron Flux High Positive Rate 4 2 3 1, 2 h IOLS-2
- 4. Power Range, Neutron Flux, High Negative Rats 4 2 3 1,2 hg u.opy l I-17-A S. Intermediate Range, Neutron Flux 2 4 2 1M,2 3h i Source Range, Neutron Flux l-08-M .
6.
- a. Startup 2 4 2 2N 4, l.43.A 2 4 2 3 5 1-38-R
- b. Shutdown 3
- 7. Overtemperature a T ,
Four Looo Operation 4 2 3 1, 2 h
- I-05-A l-45-M i
1 17-A 8 Overpower aT Four Loop Operation 4 2 3 1,2 1-05-A 4 3 3 .- 6 -# g,g9gg
- 9. Pressurizer Pressure-Low 4 2 3 1, 2 1-45-M
- 10. Pressurizer Pressure-High l-05-A N OLFCREEK- UNIT I 3M 3-2 Amendment No. %
MarA-up ofCTSJM. 3 5/15M7
ADDITIONAL INFORMATION COVER SHEET ADDITIONAL INFORMATION NO: O 3.3 f APPLICABILITY: WC i REQUEST: Transcription error, minor. Section 3.3.1 Comment: Undervoltage RCPs. ITS requires 2/ bus. Should requile 4-2/ bus. l
\
FLOG RESPONSE: The CTS markup was in error. DOC 2-46-LS-42 justifies deleting the "4" i from the CTS table for Functional Units 14 and 15. The CTS markup has ! been modified to reflect deleting the "4". No changes are required to ITS l Table 3.3.1-1. J ATTACHED PAGES: Encl. 2 3-3 l l i i
TABLE 3 3-1 (Continued) REACTOR TRIP SYSTEM INSTRUMENTATION REQUIRED MINIMUM TOT.^.L "J. CHANNEOS CHANNE4& APPLICABLE I'43-^ FUNCTIONAL UNIT OMHANNELS TO-TR4R OPERABLE MODES ACTION 1-04-LG
- 11. Pressurizer Water Level-High 3 3 3 6 -# 1-05-A
- 12. Reactor Cociant Flow- Low 3/ loop 6 -#
- . S:7.;!: L- ; (.^. 5 : P S) 3Aeep 2Aeepe 3Aeep-in 4 6-# l-05-A _,
. . . , _ , - ._ _. . oper- . l-19-LS-8 la-^p la^^^ b la
- 6-# l-57-LO
- 5. M L::;; (^.t:;; P ' --d iJ_. S) W p- :::". ---
d~J D NW I-05-A
- 13. Steam Generator Water Level-Low-Low 4/stm. Gen. 2/skn-Gon
" c ; _, _.
l'_...._..*- ed :;;. 1, 2 6#(th 1-45-M
- .; c'- a#ng+1m-Gen. p
- 14. Undervoltage-Reactor Coolant Pumps us 244ms 3 Q
1W 6 -# 1-05-A 1 19-LS-g 2-46-LS-42
- 15. Underfrequency-Reactor Coolant N la 3.3f -- }
1-05-A Pumps / bus 3449s 3 6 -# g,g9,gg,g
- 16. Turbine Trip
- a. Low Fluid Oil Pressure 3 3 3 1(a) 3 1-15-A
- b. Turbine Stop Valve Closure 4 4-- 4 ila) 1-05-A g-IS*'
)q s 3-o1l ' ~ I-1l-LS-S
- 17. Safety injection input from ESF 2 4-- 2 1, 2 7 WOLF CREEK - UNIT I 3M 3-3 Amendment No. 43,43 MarA-up ofCTS3M. 3 5/15/97
l i ADDITIONAL INFORMATION COVER SHEET l [ ADDITIONAL INFORMATION NO: Q 3.3 g APPLICABILITY: WC i REQUEST: Transcription error, minor. Section 3.3.1 Comment: Underfrequency RCPs. ITS requires 2/ bus. Should require 4-2/ bus. l l FLOG RESPONSE: See the response to Comment Number Q 3.3 f. { ATTACHED PAGES: See the attached pages in the response to Comment Number O 3.3 f. l t l l i l l ! t i ! l l l l l 1 i l l l l 1 c l
ADDITIONAL INFORMATION COVER SHEET ADolTIONAL INFORMATION NO: O 3.3 h APPLICABILITY: WC REQUEST: CTS Markup Section 3.3.1 l Comment: Reactor trip breaker undervoltage and Shunt Trip. CTS markup shows l Actions 12 and 9 (ITS Actions U and R). ITS only requires Action U (CTS Action 12) and l this is consistent with STS. The staff also notes that Action 12 in the CTS markup has
- an incomplete first sentence. Explain the discrepancy between CTS and ITS actions.
Provide the missing text in CTS Action 12. Identify other instances of missing text from l the CTS markup. FLOG RESPONSE: The CTS markup has been modified to delete Action 9. This Action was originally identified because Action 12 referred to Action 9. In response to Comment Number Q 3.3-117 it was identified that DOC 1-14-A should l have been applied to change Action 12. In response to Comment Number Q 3.3-117 the missing text has been identified and corrected. Additional instances of any missing text or identified in responses to the Comment Number or in licensee identified items. ATTACHED PAGES: l Encl. 2 3-4 i l I l I I l i
_ - _ _ _ _ - ~ . . .- . _ _ - - _ _ _ . _ - - . _ . _ _ _ _ _ TABLE 3.3-1 (Continued) REACTOR TRIP SYSTEM INSTRUMENTATION MNMUM TOT ^1 ="J. CHANNELS GHANNELS APPLICABLE l-43-A FUNCTIONAL UNIT OFCHANNELS TO - OMiRASbE MODES ACTION ' l-04-LG ,
- 18. Reactor Trip System interlocks
- a. Intermediate Range Neutron Flux, P-6 2 4 3 2N 8
- b. Low Power Reactor 1 1 12-M -
Trips Block, P-7 g373 a 1e :-d -4 3 a 4 s
, I-51-LG-
?? ! ;d 3 4 3 4 8
- c. Power Range Neutron N33#I 1-12 4 45.3 44]
Flux, P-8 4 X 3 3 1 8.1
- d. Pcwer Range Neutron
( I ~I~ 21-37[. Flux, P-9 4/ 4 3 3 1 .
- c. Power Range Neutron Flux, P-10 f 3 3 1, 2 8 l-370 M
-4y
- f. Turbine impulse Chamber Pressure, P-13 2 4 3 1 h I-12-M 1-13-LS-6
- 19. Reactor Trip Breakers (b) 2 4 3 1, 2 9,43 2 4 3 3*,4*,5* 10 1-14-A
- 20. Automatic Trip and Interlock 2 4 3 1, 2 7 logic 2 4 3 3*,4*,5* 10 lo s.sh .)
(NIw) Reactor Trip Breaker I each per RTB I,2 12 1-14-A U1derveltage sad Shunt Trip
- I each per RTB 3*,4 ,5' 19 (Mechanisnes WOLF CREEK- UNITI 3/43-4 Amendment No. -26,43 M:rn-up ofCTS3/4. 3 5/158 7
ADDITIONAL INFORMATION COVER Si!EET ADDITIONAL INFORMATION NO: O 3.3 i APPLICABILITY: CA, CP, DC, WC REQUEST: CTS Markup Section 3.3.1 , Comment: Interlock Action [8] requirements to " apply Specification 3.0.3" are deleted in the ITS. Provide a justification for this CTS change. Based on 8/14/98 meeting this comment will be responded to as part of DOC 1-52-LG comment response. e FLOG RESPONSE: As discussed in the Reference 3 meeting minutes, NRC accepted DOC 1-52-LG with no comments. Therefore, this question should be closed as well. ; ATTACHED PAGES: None l e
i ADDITIOUAL INFORMATION COVER SHEET ' ! ADDITIONAL INFORMATION NO: Q 3.3 J APPLICABILITY: DC, CP, WC, CA l i REQUEST: ITS Section 3.3.2, Notes to Required Actions G.1 and H.1. ' Comment: The note allowing surveillance testing in Actions G and H allow bypass of l a train for any surveillance test. The existing condition [23) only allows bypass of a train ! specifically for testing per specification 4.3.2.1. This excludes bypass for CTS 4.3.2.2, ; response time testing. This relaxation is neither noted norjustified in the CTS markup. FLOG RESPONSE: DOC 1-66-LS-45 has been developed to justify the inclusion of response l time testing during the bypass of an inoperable channel or one other l !. channel for DCPP and CPSES. i ATTACHED PAGES: Encl. 2 3-5 and insert 3/4 3-5A,3-6,3-6a,3-20,3-21,3-21a and insert page l Encl. 3A 14 i l Encl. 3B 14 ' l Encl. 4 2, new LS-45 l l ( i l l i l i I _ _
i l l l TABLE 3.3-1 (ContinueU) l TABLE NOTATIONS
*Only if the Re:::= rT ip Sy::= br=L= h:pp= :: b: i.: S: :!:=d p=: den =d S: 1-55-LS-39 ods are not fully inserted.
Control
#The.prc=!:= Rod Drive System cf Spri5eanen 10M = ne:is pp!!=bk.
capable of rod withdrawal o@Mone OMS 6Edl or_1-05-A moiM .
##Below the P-6 (Intermediate Range Neutron Flux Interlock) Setpoint.
l" "~" I
###Below the P-10 (Low Setpoint Power Range Neutron Flux Interlock) Setpoint. l (1) The applicable MODES for these channels noted in Table 3.3-3 are more restrictive and therefore applicable.
ACTION STATEMENTS ACTION 1 - Wi he number of OPERABLE enannels one less than the *"! !mem {l-04-LG ~ Required hanneb OPEP>. ELE nquirement, restore the inoperable channel :1 4' 3-A to OPERABLE status within 48 hours or be in HOT STANDBY within the next 6 ) hours. ACTION 2 - With the num f OPERABLE channels one less than the Tesal ~T-04-LG ' ' Mumbr c.u equir hannels, STAR 1UP and/or POWER OPERATION may
'~' l-43-A proceed provided the following conditions are satisfied: ;q3,3g }
- a. The inoperable channel is placed in the tripped condition within 6 hours;
- b. 7.:! 1.u Ch=nd OPERAELE aq=:m= :: m::, h = =, I-M
- Li -4 5' Note:the ' o rable channel may be bypassed for up to 4 hours for surs_eillance 1-04-LG testing nd setpoint adjustmenDof other channels @rsty.ceftfa3pr4-)d and 1-17-A b e. Either, THERMAL POWER is restricted to less than or equal to /w. ot RATED THERMAL POWER =d $: Pern R=g: ?kuren r!= T rip S::pcir - 1-18-LS-7
=d =d :: ';;_i= = :q=! :: !!"' cf P>.5D ~ '
ER ^.L PO".TR within 12 hours; o the power range neutron flux input to), the QUADRANT POWTR TILT RATI is inoperable, the OPTRJis monitored at least once per 1 (e) 1 N~I } pui ts per Specification 414.2.
^
- c. (Otherwise, be in HOT STANDBY within 12 hours )
dNSERT 3/4 3-5AJ 71-04-LG ~ ACTION 3 - With th_e number of channels OPERABLE one less than the '"umur ' I-43-A (Requir@ Channels OPEP>.BLE =q===: and with the THERMAL POWER level:
- 2. 9:!re d: P 5 (! ::m:di::: R=g: Meur : r!= ' ::r!=L) S::pcir r=:ere i: in p=bk :h==! :: OPER.^. ELE ==: pr!= :: in==ig EP3" ^.L
~
;l-07.LS-3 PO"'ER :b v: 6: P 5 S: p !- ; = - -
a4. Above the P-6 (Intermediate Range Neutron Flux Interlock) Setpoint but below 10% of RATED THERMAL POWER,6ithin 24 houEj=:=: 6:i=p=bk . _.
- h==! !: OPEP). ELE : :*= pri= : 0 ine :=in m"'" ^ L PO".TR aber:
1-07-LS-3 10"'. ? P ^.5D ER ^ L PO".TPCse;iHERMAL POWER to d P6 or) ~ ~ ~~
/6 crease to > PIO. )
3-51]) ACTION 4 - W' the number of OPERABLE channels one less than the .imum equire hannels OPEP).BLE : qui ==Qmmsdiatelpsuspend all J 1-43-A operations involving positive reactivity changes. ]-08-M hSERT 3/4 3-D _ (a) Above the P-9 (Power Range Neutron Flux Interlock) Setpoint ' 1-15-A (b) neluding any reactor trip bypass breakers that are racked in and closed o bypassing an RTB. g Above the P-7 (Low Power Reactor Trip Block) interlock. en Aa. - - (c) (el hM required to be performed @ peri >trone1rafrebmu-trmee Power Range J Erd __.VNeutron Flux EQE56 to QPTR is inoperableJDwrvttwrrA1,.cttw Ett 25. -giwic_4_D (F.is.d -T)-f cP 3.3- 12o
@d.) ~ Above. Ms. P-I, (In6me.diate. R>ny. deatron % ) seitegr Q-o7-LS htac.2.3.o WOLF CREEK- UNIT 1 3M 3-5 Amendment No. -%-9 96 Mark-up ofCTS3M. 3 S/lSM7 l
7 - INSERT.1/4 3-5 A ACTION 2.1 - With the number of OPERABLE channels one less than I the Required Channels, STARTUP and/or 14I3-2? POWER OPERATION may proceed provided the [l_-45-M .il following conditions are satisfied (Note: The inoperable - - l channel may be bypassed for up to 4 hours for surveillance testing 6pdipdiqHmbritputBof other Q j.'17.A ' channelsgg;&pEcjgcencyApg:
~
' f IT M-La-4E 1 3h' '
@ 2 3f }
- a. The inoperable channel is placed in the tripped condition within 6 hours, or
- b. Be in HOT STANDBY within 12 hours.
f
\
INSERT 3/4 3-5 B ACTION 3.1 - With the number of channels OPERABLE two less than the Required Charanels and with the THERMAL POWER level: INd(
- a. Above the P-6 Setpoint but below 10% of RATED THERMAL POWER, immediately suspend operations involving positive reactivity addition.= and, within 2 73M.13 3~
hours, reduce THERMAL POWER to less than the P6 A"- Setpoint. INSERT 3/4 3-4 ACTION 4.1 - With no source range neutron Dux channels OPERABLE, ': 1" 08-M
~ ^ "
immediately open the reactor trip breakers l F i l
g ( ,; g ., & - w v \ O' "55 " '3'*O\ s
. =
.a.+.-, m TABLE 3 3-1 (Continued)
ACTION STATEMENTS (Continued) ACTION 5 deth.A 48 h*=M fM j 5g*f,j, [ c,r W th the number of f PERABLE channels one less than the P n== l-43-A 5# i,Gite, Require hannelspFEPf.BLE aquinm= , restore the inoperable channel i ,,73 g
*N *** to OPERABLIlsattirr*1tW48 trourberyrthrAollqwemd Aotl@ully insert (all rods, and place the Rod Control System in a condition incapable of rod 1-55-LS-39
( (withdrawa@ pen 2: R=== Trip Br= hen, =d :=p=d :." spr=:= - - ~ " r=Mr.; p=" = ==:i 'i y :h=;= . SM- h: re" h = ~ 1-38-R
~'
b.. With no channels OPERABLE, (open the Reactor Trip Breakers), JNh ,:=p=d :!! :p:=:!:= i =!"ng p = = :=::i >i*y ried her. ch=gn =d =rify = mph == Sh 1: S"" 3 " '" ' ' ^." C " 71-38-R~
=quimm=:: cf SpriE=:!= 3.' ' ' idi ' h=r =d := y !2 h=rs 3
er=f::- ACTION 6 - With the number of OPERABLE channels one less than the -Tetal ' M:nbr ef(RequirHDChannels, STARTUP and/or POWER OPERATION 1-43-AT may proceed provided the following conditions are satisfied: l1-15-A
- a. The inoperable channel is placed in the tripped condition If11-LS-5._
within 6 hours; and
- b. S: 5'" .:= Ch=rd OPEPf.BLE =qu!=== ==; however, ~g gLa the inoperable channel may be bypassed for up to 4 hours for surveillance testing of other channels @
SpecMes1 Ion <Lrfjor
-{Q3Sd (c._ Reduce Thermal Power to < P-7 within 12 hours 3 1-19-LS-8 ACTION 7 - With the number of OPERABLE Channels one less than theM
!-!::= Channels OPEP>.BLE = quin = , restore the inoperable channel to J
an a. {i OPERABLE status within 6 hours or be in at least HOT STANDBY within _ the next 6 hours; however, one channel may be bypassed for up to 4 hours for /'t-u,-ts-%p' g - surveillance testing @fr 619Ecificantnf 4htiprovided the other channel is operable? ACTION 8 - With less than the !Hm:- M =tr c'fRequire f) Channels '1 ~ 43-A OPERABLE, within I hour determincFioyserva,Iptr orjM aspciatpd J 1-12-M
@perrssive,,affnuricedfor veintfowls(mat the interlock is in as required state for the existing plant condition, or :pp!y SpriEntie- 333. be in at least htt3<
CHot Standby within 7 hourD - ACTION 8.1 With less than the Required Channels OPERABLE, within I hour 12-M determineAyptiseryatiperoItht,atsoostetettattsyrt amflupcfktor? ;gy,3,3,co;j
@6f4that the interlock is in its required state for the existing plant condition, or be in at least MODE 2 within 7 hours.
ACTION 9 - With the number of UPERABLE Reactor Trip Breakers one less than - theM" := Channels OPEP3.BLE :';;i===:,[estore the) e y (inoperable
' STANDBY within breaker to OPERABLE dif7) hours; status however, one breaker mayin beIbypassed hour olbefor _ in at least 6_ HOT l_=6-t s-&$
up to 2 hours forfmaintenance or foBsurveillance testing [persfesifrGetf}d 1 provided the other breaker is OPERABLE. nh4&ha@ "*d"d'~437 With the number of OPERABLE channels on less than the g W ' l-43-A~ ~ ACTION 10 - (RequiredjChannelsj??EPf.BLE =;;ir==., restore the i' sop _ ble channel 1-55-LS-39 l to OPERABLE statuspuf4 T cp= he R=== a4p]lully insert all j [ rods and place the Rod Control System in a condition incapable of rod ( withdrawalbreakers withm the next hour. ACTION 11 - With the number of OPERABLE channels less than the Total Number Not Used of Channels, operation may continue provided the inoperable - channels are placed in the tripped condition within 6 hours. WOLF CREEK- UNIT I JN 3-6 Amendment No. !2,25, 9, S2,96 Mark-up of C153M. 3 5/15/97
)
l
)
ACTION 12 - With one of the diverse trip feitures (undervoltage or shunt trip attachment) inoperable, reston it to OPERABLE status wnhm t The breaker shall not be bypassed while one of the diverse trip features is inoperable except for the time required for performing maintenance to restore the breaker to OPERABLE status. CTION 13 - With less than th umber of Required Channels, operation may 1-15-A continue provided the following conditions are satisfied (Note: An i 1-11-LS-5 l inoperable low fluid oil pressure channel may be bypassed for up to 4 ! hours for surveillance testing of other channelsgtjpar3):t.J: I f*L54
- s. jg3.3jj ,
The inoperable channels are placed in the tripped condition within 6 hours, or {
- b. Reduce THERMAL POWER to less than P-9 within 10 hours.
- l ACTio*J 13.1- Ldith the. numbu of CPERAe.LE. chamuh less, t . ig.g,$ . c; {
hr he. R q w d c. h a.n M .6, o y * +i i n con + = provide.A hs. foliowm3 ccmdi*tm kO 13-DN l
- ,w,us .
- h. .
- o. . The. ihopuM.s ch>nruh ww- piacui vhhipp ccmdbb cdithih (o hours ,or l b . RAu 'THERMAt PoWE.Y2. -lo less bn P-9 t,siMih lO bevi. i
- 1 l
_ - - ^ ___,.o. _ ; f. h,di.3, i.i4 4 QS.3-t t1 } 4 S kows or p. ._g ._._. u. _~_vt . __ i. _ p3
.~7----
( _ -
@CA- _- lea *+ hot STAh1DBY (4b'n b ned 6 l
WOLFCREEK- UNIT 1 3M S-6a Amendment No. 43 Mark-up ofCTS3M. 3 5/15/97
1 g*gth tNe naher#f CPCRACLG ctwnnMb eme, pg4 g73g
~
lc.3 O um We, Qu' ired Cha.nrn\ for i~wrdtbn ) 3.ct.,4 i wcri ncg +2W.Wa M. Tid qudcA b3 pu thCML SYS 3M[ TABLE 3 3-3 (Continued) TABLE NOTATIONS
# Trip function may be blocked in this MODE below the P-11 (Pressunzer Pressure interlock) Setpoint.
2-22-4 @M M
#(naturtetar.wrsutomatjcaktHocid raMMG)may be blocked below ()-sy gf.g P-11 when Safety injection on low steam kne pressure is not blocked.
*E:p 05 n Of Sper:S:t= 2 ^ ' cre no! Opp!!~t! . ]re move S N e b M PA MC 33'004I
**On h S peraten Creep 12.d one h Seper t! n Cr:Up ' 2 '90 d: :ncr;!::S:n of nsenin of SOP ESF^.S cduat! n !:;i Ond Ode: [Q2.-i9\
2-31-A ' S n -!:';; render: MO f th four ch:nn !:inoper:b!:. ^. t!:n S!:t
'n=t 21 app!!::i te? Fund!:nc! Und S Ond S g ! 'h!: =se-ACTION STATEMENTS ACTION 14 -} d the number of OPERABLE channels one less than the ? r-Hu.- 1-04-LG Require hannels OPEPf.SLE : ;uirement.(restore train to OPERABLF) 1-43-A within 6 hours oBbe in at least HOT STANDBY within]I2 hourgfand in 2-23-A COLD SHUTDOWN within the following 30 hours; however, one channel Q3.3j{
may be bypassed for up to 4 hours for surveillance testing @er Sapemg.atrop - h,j,..Ls-4G AJS' provided the other channelis OPERABLE. ACTION 15 - With the nu r f OPERABLE channels one less than the Telat
'! umber 0.Sequire hannels, operation may proceed until performance of 1 43.A the next required ANALOG CHANNEL OPERATIONAL TEST provided the inoperable channelis placed in the tripped condition within 1 hour.
ACTION 16 - With the number of OPERABLE channels one less than the Tete! Number of (Require @hannels, operation may proceed provided the inoperable channe_I y,43,g j is placed in the bypassed condstionjwitnin 6 hours or be in HOT STANDBY 2-15-M [_within the next 6 hours and in HOT SHUTDOWN within the following 6 7ours. nd :he !a mum Cha =d OPEP ^.BLE : ;=cm:n* = met. One l addrtional channel may be bypassed for up to 4 hours foi surveillance testing bee %endemonadrFD Q',3,4g-Q s.sj } - e en d the w h rs. 32 ACTION 17 - Withbriber of OPERABLE channeisjless than the ?"'^h"" 1-04-LG Channels OPEP.^.BLE requwement, operation may continue provided thef 1-43-A n'" bment pur;c =;;! ; rd rheud "P; :::::=htemed ! 04 L-(3p logbjVcpridip;:fn%T&3.>6'apir fi3 p]t. esp eac2Wew (Q.ctichs :!us.3 metaen requid bM d'#b' [oa3-32.] l ACTION 18 - With the number of OPERABLE channels one less than the !" mu-V CRguirgehannels OPEPf.SLE requiremen'. restore the inoperable channel 1-43-A l to OPEHABLE status within 48 hours or be in at least HOT STANDBY l within the next 6 hours and in COLD SHUTDOWN within the following ! 30 houm. I ACTION 19 - With the number of OPERABLE channels one less than the Tetal 1-04-LG l
" ember c'Q" uirehannels. STARTUP and/or POWER OPERATION 2-34-LS-34 l may proceed previoed the following conditions are satisfied:
! a. The inoperable channel is placed in the tnpped condition within 4 ours. end Insort 19.I N 2-10-M insert 19 (cont.) -- 2 18-LS-31
- a. Not applicable when all MSIVs are closed.
- b. Not applicable when all MIFVs, main feed isolation valves are closed. 2-07-LS-11 WOLF CREEK- UNITI 3M 3-20 Amendraent No. 43 MarA-up of CTS 3M . 3 S/1S m
TABLE 3 3-3 (Continuod) ACTION STATEMENTS (Continued)
- b. The !'i" mum Chenn:!: OPE"^ SLE : ;2 m:n* :: met,50;; ;;r, the l-M LG inoperable channel may be bypassed for up to iours for surveillance 2 testing of other channels (ppu3Feafrcatarra . , . (te Lp.4_F,,)-g -3RS-34 ACTION 20- With less than the !? mum hannels OPERABLE, within i hour N 3'I# l M:!:--:n: by Ob=.1:SenOf'nMed ted per"^!; z;t ennunc: ! 1-04-LO wwsew(s) that the interiock is in its required state for the existino olant 1-43-A condition, or cpp!y Sped 5 :S n 222 jbe in MODE 3 within 7 hours and] 2-14-M_
(MODE 4 within 13 hours. ACTION 21 - With the number of OPERABLE Channels one less than the ?':-Num 1-04-LG (Required) Channels OPER*"LE re; dement, be in at least HOT STANDBY vothin 6 hours and in at least HOT SHUTDOWN within the following 6 hours; - l-43-A - however, one channel may be bypassed for up to 2 hours for surveillance 3,3j g testingy,pemcpteon p5z.3provided the other channel is OPERABLE. . g.a.4g ACTION 22 - With the number of OPERABLE channels one less than the Tetal ~ 1-43-A~
^
Number O'RequiredjChannels, restore the inoperable channel to
^
OPERABLE status within 48 hours or be in at least HOT STANDBY within 6 hours and in at least HOT SHUTDOWN within the following 6 hours. 2 -c4. -LS-
~
^ CT!ON 22
'*T$ the number c' OPEP'.9LE channe!: ene ! = th:n the Tete!
Number Of Ch nne! , 0 terc the incperab!e 2:nne! te OPEP.^.BLE
.. .. . ...:.w: e a um .w ded- e the - rd ':d d inep ^
end tche the 29 reqsed by Sped 5c Sen 2.71.5. 4T!ON ia *d he nu-tnr_of ^"EP_^. ELE :". nne!: n:u_.-a ! n then 'h:S".- - ru e--a r- - n . . m a_u._ .w m .a m,,
< m . ... ~ _ i - J i ! X L'.7,"I'r'r M .7,'. L a w.,~ ' i w 'd.~12rT .:f 7 ,7'- I ~ ~ ~ ~ ' ~ ' ' ' " -"- r i.4g,,
^CT!Oh 25
. '"*" the number of OPEP^.SLE chenne!: One !:= then 'he !* ^%u, 2-13-AT
) Channd: O"EP.^SLE re;f:m:n'. de:!::: th: :":ded di:=!
;enerater end c" de pc'cc:r Scurce !-^per b!: Ond td: the
^ CT!OF' r:q ir:d b, Opcic/.e. 0 0.1 ;
ACTION 26 - With the number of OPERABLE channels one less than the ?"-%um 1-04-lG (Required) Channels OPEP_^ SLE re';demen*, restore the inoperable channel 1-43-A to OPERABLE status withi day '" heur: or initiate and maintain 2-12-M operation of the Control Room mergency Ventilation System. -Deg _-. .:- : u nn e r _ a e .w- -.m .a :_ < e __.r ,.,. ., e n 2 - . - - - .
' ' -)hith no channels OPERABLE,inimediateiy declare one 2-16-LS-12 CREVS train inoperable and initiate and maintain operation of the other CREVS train in the CREVS mode and restore the inoperable CREVS train to OPERABLE status within 7 days, or immediately place both CREVS trains in the CREVS mode of operation.
With the Required Actions and associated Completion Times not met : 2 26-LS-21
- a. When in MODE 1,2,3, or 4, be in MODE 3 in 6 hours and in -
MODE 5 in 36 hours.
- b. When in MODE 5 or 6, or during movement of irradiated fuel assemblies,immediately suspend CORE ALTERATIONS and movement of irradiated fuel assemblies.
WOLF CREEK- UNIT 1 3M 3-21 Amendment No. 9,43 Mark-up of CTS 3M. 3 S/15/97
. . __ ._ __ . . _ . .- _ . - . . . ~ _ . . - _ _ ~ - _ . . . . . - _ - - . _ . . _ . . . . _ . . - . - _ .
d i l TABLE 3 3-3 (Continued) ACTION STATEMENTS (Continued) I 1
' ACTION 27- With the number of OPERABLE channels one less than the Mwwswm 1-43-A ~
j deauirehhannels OPEP ^ 9'_E rr;;rr._n:frostore the inoperable] 2-23-A l ( channel to OPERABLE atatus within 5 hours ofbe in at least HOT
- l. STANDBY within 12 hours;-beweves m one channel may be bypassed for up to 4 hurs for surveillance testing @N.Dprovided the othr r channelis OPERABLE. @b6-Lb%.{Q3.Sp
[nsert 28.1 and 28.5 D l l AFTE M t830 l AfiaL Akm ...L-. .g MBf'*B A B I E" ' - - - l= ===l---&L-= ska T a f Ll. - ' - - -#
' ~
Ch nd'5,V'^A5h$5do655o 55EUIS'EEd:':E:55;EEIbe 2-08-M I
! :;::-i'_ d xx:: b p'-- ' " te t';;:f xnd5:n "'S S Seur.
- 5. h- M ' mum d:nn:: OPEP_^"' E : : _ rxx' !: mrt; 5:nn:,'he
':;: -.i d:nn : y '- ty- : rd '^r up te ' 'run ' r tewilanee
'- .;; -' : ;: d:xxt: ;-- E;::!'.x tb . ' ?.2M l ACTION 29 - With the number of OPERABLE channels one less than the Mwwswm 1-04-LG '
l GgggrgpChannels CPE"^?' '~ ::: cm:n", restore the inoperable channel 1-43-A ; j to OPERABLE status within 6 hours or be in at least HOT STANDBY within the l next 6 hours and in at least HOT SHUTDOWN within the following 6 hours; j bewever, one channel may be bypassed for up to 4 hours for surveillance l testing pg - provided the other channelis operable. g g .L5
, 4 3 ?>h_
l l M
- F5 c. 3/4 .3 -21 u, AM t 6. H T - [i d 5-A M 33
- B.)
1 i i 1 t I i i i i i i I ), i
^
WOLF CREEK- UNIT 1 3M 3-21a Amendment No. 43 , Mark-up ofCTS3M. 3 $/13R7 i f
. l
.. __- __.m- _ . _ _ __ _._.__m_ _ _ . _ _ - . _ _ _ . _ - _ _ . _ _ _ _ _ _ - . _ . . . _ _ _ _ . _ _ _ _
INSERTS ACTION 19.1 - 2-10-M - With the number of OPERABLE channels Required Channels, STARTUP and/or POWER OPERATION may proceed provided the following condit s are satisfied O E3-% one less l (Note: The inoperable channel may be bypassed for up t f ours for _ surveillance testing of other channelstighgIEcilianem_= m 3): p3.3j }
- a. The inoperable channelis placed in the tripped condition within 1 hour, or i
- b. Be in at least HOT STANDBY within the next 6 hours.
ACTION 19 (cont.) With the number of OPERABLE channels two or . 2-18.Ip1 more less than _the_ Required Channels on one bus, res a th,affecteghts to QPERAjlLtstatus afilto ~ han his M bo %23 981] 4 % ,j, y g, y,, ymug paa (nrhedder N _emwyk t.4 g mu.m ME EMapeold.. ) With the Required ACTIONS and associated Completion Times not met; (a) When in MODE 1,2,3, or 4, be MODE 3 in 6 hours and in MODE 5 in 36 houn. (b) When the associated DG is required OPERABLE by LCO 3.8.1.2, enter applicable Condition (s) and Required Action (s) for the associated DG and offsite circuit made inoperable. l ACTION 28.1 - With the number of OPERABLE channels one less than the Total Number of Channels, STARTUP and/or POWER MM l l OPERATION may proceed provided the following conditions l are satisfied (Note: The inoperable channel may be bypassed _ for up_to 4 hours for surveillance testing of other channelsg ,,--(Qs.3j} Q y j.3$.p: l a. The inoperable channel is placed in the tripped condition within j 6 hours, or ! 1 I l b. Be in HOT STANDBY within 12 hours and in HOT SHUTDOWN j ! within 18 houn. ACTION 28.2 - With the number of OPERABLE channels one less than the 24M Total Number of Channels, STARTUP and/or POWER OPERATION may proceed provided the following conditions are satisfied (Note: The inoperable channel may be bypassed : for up to 4 houn surveillance testing of other channels @ g5 SpecffjsseniliAS"L4):
- s. The inoperable channelis placed in the tripped condition within 6 hours or
- b. Be in HOT STANDBY within 12 hours.
i a WOLF CREEK- UNITI 3M 3 Amendment No. Mark-up ofCTS3M. 3 5/15M7 i
CHANGE NUMBER N2iG DESCR1PTION 1 54 LS 37 Not applicable to Wolf Creek. See Conversion Comparison Table (Enclosure 3B). 1 55 LS 39 Applicability Note [*] and ACTION Statements [5.a and 10] for Functional Units [1. 6.b. 19, and 20] of current TS Table 3.31 are modified to provide an alternative to opening the reactor trip breakers (RTBs) while still assuring that the function and intent of l opening the RTBs is met. As currently worded, these ACTION Statements result in a feedwater isolation signal (FWIS) when in H0DE 3 with a T , less than [564*F. USAR Table 7.314 and USAR Figure 7.21 (sht.13) detail the FWIS generation on the coincidence re lm- of P 4 and low T.,.] A more generic action, which I anon oc ** assure @he rods are fully inserted and cannot be
- withdrawn, replaces the specific method of precluding
} Q,31,5-4E0 t rod withdrawal. The revised Applicability and ACTION P R s.3 M I Statements still assure rod withdrawal is precluded.
This change does not involve any safety impact and is consistent with traveler. 1-56 h Not applicable to Wolf Creek. Comparison Table (Enclosure 3B). See Conversion p n-SM 1 57 LG Current TS Table 3.31 Functional Units [12.a and 12.b] are combined per traveler TSTF 169. The Required Channels, ACTION Statement, and Surveillance Requirements are the same for both Functional Units. The only difference between the two is the Applicability which could lead to entry into ACTION Statement 6 for Functional Unit [12.a], followed by a power reduction below P 8 exiting the Applicability and required actions for that Functional Unit, and subsequent re entry in ACTION Statement 6 for Functional Unit [12.b]. This would involve an improper cumulative A0T of 12 hcurs before tripping an inoperable channel beyond that evlauated in WCAP-10271 and its Supplements. The relationships between these l Functional Units and permissives P 7 and P 8 are moved to the ITS 3.3.1 Bases. 1 58 A Not applicable to Wolf Creek. See Conversion Comparison Table (Enclosure 3B). f 1 59 h Not oppu c2A b (Mf.Cnd.. % G-mA
- c. - es .. eu.-y ..s o
- 1 60 Not used.
1 61 M Not applicable to Wolf Creek. See Conversion ; Comparison Table (Enclosure 3B). l l hs_sRT 3A - 4 WCGS-Description ofchanges to CTS 3H.3 14 5/15/97 l
- - . . ~ . _ . - _ . . - . - - . - ~ . - - . . . - - - . ~ . . . - -
INSERT 3A-14 1 62 A Not applicable to Wolf Creek. See Conversion Comparison Table (Enclosure 3B). 1-63 A All reformatting, renumbering, and editorial rewording is in QWA QW " accordance with the Westinghouse Standard Technical Specifications, ! NUREG-1431. During the development certain wording preferences or j English language conventions were adopted. As a result, the ' Technical Specifications (TS) should be more readily readable, and therefore understandable, by plant operators and other users. During the reformatting, renumbering, and rewording process, no technical changes (either actual or interpretational) to the TS were made unless they were identified and justified.
} GI 23 J 1-64 A The refueling interval TADOTs for Functional Units [1 and 17] in CTS Table 4.3-1 have been revised to include existing Note [10, **Setpoint verification is not required."] Likewise, refueling interval TADOTs :
for Functional Units [1.a. 2.a. 3.a.1), 3.b.1), 3.c.1), 4.a. 6.a 9.a i and 11.b] in CTS Table 4.3-2 have been revised to add a new Note (5), l
" Verification of setpoint not required." This change is l administrative in nature since the subject Functional Units have no j setpoints associated with them. This change does not affect the ;
operating limits or manner in which the plant is operated. There are j no changes to current plant practices for the performance of these ; TADOTs since there are no setpoints to verify for these Functional ; Units. This change is strictly an acknowledgement that the corresponding ITS SRs 3.3.1.14, 3.3.2.8, and 3.3.2.11 have an ] i explicit Note to this effect. ' I Q245 1 1-65 A Seven slave relays are listed in Note (3) to CTS Table 4.3-2 for an exception to the quarterly SLAVE RELAY TEST. These slave relays are associated with the following ESF actuation signals: K602 (SIS): K620 (turbine trip and main feedwater pump trip): K622 (CIS-A): K624.(CIS-A): K630 (CIS-A and the CIS-A input to containment purge isolation and control room ventilation isolation); K740 (SIS, RWST low-low): and K741 (SIS, RWST low-low). ITS SR 3.3.2.6 has been revised with a Note per JFD 3.3-19 that excludes these seven slave relays from the i quarterly surveil'ance. Based on the differing Functional Unit MODE Applicabilities, new ITS SRs 3.3.2.13 and 3.3.2.14 have been added under JFD 3.3-19 to cover the surveillance frequency applicable to these slave relays. The only slave relay associated with containment purge isolation and control room ventilation isolation K630, has the extended surveillance frequency under new ITS SR 3.3.2.13. Based on feedback received from the NRC reviewer at a meeting on September 16, 1998, the 90 days cited in Note (3) has been changed to 92 days to follow standard convention for an exception to a quarterly surveillance frequency. l
i 1 i INSERT 3A-14 (continued) l Q 3.~5j} 1-66 LS-45 The CTS allons certain inoperable channels, or for some plants one other channel, to be bypassed for testing per Specification 4.3.1.1 or 4.3.2.1. The intent of the bypass is to allow testing that will verify that the channel has been restored to an OPERABLE condition and can be returned to service. The allowed bypass time for testing has been evaluated for its impact on the safety analyses. It has been determined that the impact of the allowed bypasses is minimal. Whether the bypass is for setpoint verification or response time
- verification has no impact on the safety analysis. This change would l
delete the reference to Specification 4.3.1.1 and 4.3.P.1 in the allowed bypass notes contained in certain CTS ACTION statements, thus permitting any testing needed for restoration of the inoperable function. i l l i i l l l l l l t
ig3cgT se-is CONVERSION COM PARISON TABLE - CURRENT TS 3/4.3 ragei4orso TECII SPEC CilANGE AFFt.lCARil3TY NtIMRER DESCRIPTION DIARLO CANYON COMANClfE PEAK WOt.F CREEK CAIJ.AWAY 1-61 If the requirements of current CPSES ACTION Statement 6 are No - see Yes No see No - see M not met. LCO 3.0.3 would be entered. In accordance with CNf 1 19 LS 8. CNf 1-19 15 8. CNf 1 19 LS 8. the I$TS. this ACTION Statement is revised to state that, if the ACTION requirements are not met, the plant must be taken below the P 7 interlock setpoint within the next 6 y hours. , 2 01 The Engineered Safety Features Actuation System Yes Yes Yes Yes A Instrumentation [] Allowable Values are moved to ITS ; Table 3.3.2 1. 2-02 CTS ACTION b.1, Equation 2.21. and the values for Total No not in current No - not in current Yes Ye- f A Allowance (TA), Z, and Sensor Error (S) are deleted. TS. TS. t consistent with NUREG-1431 Rev.1. j 2 03 The Engineered Safety Features Actuation System No retain in ITS. Yes moved to Yes - Moved to ITS Yes - Hoved to ITS
- LG Instrumentation Trip Setpoints are moved to a licensee Bases. 3.3.2 Bases. 3.3.2 Bases controlled document.
2-04 The requirements stipulated in ACTIONS a and b are moved to Yes Yes Yes Yes ; LG ITS Table 3.3.2 1 with explicit direction contained in the I ITS ACTIONS Bases. 2 05 ThefunctionalUnitforContainment@ urge] Isolation. CTS No - see MMC 3HL.JibA) Yes Yes t H 3.c. is moved to inproved TS 3.3.6. Iaproved TS 3.3.6 adds CN 02-20 A p g.og } requirements on the OPERABILITY of the containment [ purge es radiation] monitors and extends the Applicability for the , [, Manual Initiation and B0P ESFASlactuation logic to include during movement of irradiated fuel assesblies within containmentQndCoreAlterations} No - r6tain CTS , EWE C(fd!PA Yes 06 F al Unit 4.a.1 of current TS Tabl s been JV ars W5'] l l l ll* CGS-CONVERSION TABLE- CTS JM.3 S/15197
INSERT 3B-14 TECH SPEC CHANGE APPLICABILITY NUMBER DESCRIPTION DIABLO CANYON COMMANCHE PEAK WOLF CREEK CALLAWAY 1-62 In a Callaway-specific change, ACTION 7 in No No No Yes A CTS Table 3.3-1 is moved from Functional jdgasrest) Units 13.a and 13.b to Functional Unit 13.c 1-63 All reformatting, renumbering, and Yes Yes Yes Yes A editorial wording is in accordance with the Westinghouse Standard Technical lG? t-A ssEo1 } Specifications NUREG-1431. 1-64 Notes are added to Tables 4.3-1 and 4.3-2 Yes Yes Yes Yes A to exclude setpoint verifications during TA00Ts on Functional Units that do not have g q,,g,3 \ setpoints associated with them. 1-65 Explanation of ITS treatment of seven slave No No Yes Yes A relays with extended surveillance C> 2 1 frequency. 1-66 This change would delete the reference to Yes Yes Yes Yes LS-45 Specification 4,3.1.1 and 4.3.2.1 in the ,, allowed bypass notes contained in certain Ct JL33 CTS ACTION statements, thus permitting any testing needed for restoration of the inoperable function. 1-67 This change revises DCPP CT; ACTIONS 13 and Yes No No No M 29 to provide specific shutdown requirements to exit Applicability, in lieu kd>3J3-+C k of applying CTS.
l NO SIGNIFICANT HAZARDS CONSIDERATION (NSHC) ! CONTENTS (Continued) l i me 1 LS '28. . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . Not GapTEaSRb lW 5 2 -" ' l LS 29. . . . . . . . . . .. . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . Not a ppl i c abl e LS 30. . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . Not a ppl i cabl e LS 31................................................................... 54 LS 32....................................... .. . . . . .Not applicable @_l-IN
- LS 33....................................... I.n.wt.4-c .... N '
LS-34................................................................... 57 LS 35............................................... - . ....Not_ applicable LS 36............................................... ....Not *, . _" _
. icas %
LS 37................................................ ...Not applicable - - i LS . 38. . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . ."" . . . . . No t =^ . ^e' aIc4 3. s co2_A' LS 39................................................................... 60 LS 40................................................................... 62 i LS 41................................................................... 64 LS 42................................................................... 66 LS 43................................................................... 69 ([s_44 iuseer 4 iy. o 7-r3 ) V. Recurring No Significant Hazards Considerations "TR" TR 1. . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . Not appl i c abl e !
~
TR - 2. . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . Not a ppl i ca bl e ! ls.46 @ sse.r 4 D fo s.s i \; . ts.4 c, r4.t.ppbc>A 1 O l-5 0 l LS-4'l rJot aplicalda. (Q I-EQ LS- 46 ,3,y ,pp};c,g,_ (cgt<e(3,3 g L5-49 wt applia [e2-3c.] g,g kbt arrbE>A k s.es_] LS-Si NietT 4-b c 3.3-1 0 i LS 52. UahrPAlc>&.(a.3187.1 LS- 5'.5 et apphc.atJ.s {Dc. 3.3-cD').\ WCGS- NSHCs - CIS3M.2 2 5/15/97 l
1 INSERT 4-c 0 3.3j I IV. SPECIFIC N0 SIGNIFICANT HAZARDS CONSIDERATIONS i NSHC LS-45 10 CFR 50.92 EVALUATION i FOR TECHNICAL CHANGES THAT IMPOSE LESS RESTRICTIVE REQUIREMENTS WITHIN THE TECHNICAL SPECIFICATIONS This proposed change would delete the reference to Spec'fication 4.3.1.1 and 4.3.2.1 in the allowed bypass notes contained in certain CTS ACTION statements, thus permitting any testing needed for restoration of the inoperable channel. The CTS allows certain inoperable channels, or for some plants one other channel, to be bypassed for testing per Specification 4.3.1.1 or 4.3.2.1. The intent of the bypass is to allow testing that will verify that the channel has been restored to an OPERABLE condition and can be returned to service. The allowed bypass time for testing has been evaluated for its impact on the safety analyses. It has been determined that the impact of the allowed bypasses is minimal. Whether the bypass is for setpoint verification or response time verification has no impact on the safety analysis. The proposed TS change has been evaluated and it has been determined that it ; involves no significant hazards consideration. This determination has been performed in accordance with the criteria set forth in 10 CFR 50.92(c) as quoted below:
"The Commission may make a final determination, pursuant to the procedures in 50.91, that a proposed amendment to an operating license for a facility licensed under 50.21(b) or 50.22 or for a testing facility involves no significant hazards consideration, if operation of the facility in accordance with the proposed amendment would not:
- 1. Involve a significant increase in the probability or consequences of an accident previously evaluated; or I
I
- 2. Create the possibility of a new or different kind of l accident from any accident previously evaluated; or
- 3. Involve a significant reduction in a margin of safety." \
The following evaluation is provided fo.r the three categories of the significant hazards consideration standards:
- 1. Does the change involve a significant increase in the probability or consequences of an accident previously evaluated?
Overall protection system performance will remain within the bounds of the previously performed accident analyses since no hardware changes are proposed. The proposed change allows surveillance testing as required to return a function to an OPERABLE condition. The proposed change in the allowed testing will not affect any of the analysis assumptions for any of the accidents
IV. SPECIFIC NO SIGNIFICANT HAZARDS CONSIDERATION NSHC LS-45 (continued) previously evaluated. The proposed change will not affect the probability of I any event initiators nor will the proposed change affect the ability of any ; safety-related equipment to perform its intended function. There will be ! neither degradation.in the performance of nor an' increase in the number of challenges imposed on safety-related equipment assumed to function during an l accident situation. Therefore, the proposed change does not involve a i significant increase in the probability or consequences of an accident previously evaluated.
- 2. Does the change create the possibility of a new or.different kind of accident from any accident'previously evaluated?
There are no hardware changes nor are there any changes in the method by which any safety-related plant system performs its safety function. The change in- , the surveillance requirements will not affect the normal method of plant l operation. No new accident scenarios, transient precursors, failure mechanisms, or limiting single failures are introduced as a result of this change. Therefore, the proposed change does not create the possibility of a new or different kind of accident from any previously evaluated. 3.- Does this change involve a significant reduction in a margin of safety? ! The proposed change does not affect the acceptance criteria for any analyzed . event. There will be no effect on the manner in which safety limits or limiting safety system settings are determined nor will there be any effect on i those plant systems necessary to assure the accomplishment of protection. functions. There will be no impact on any margin of safety. I NO SIGNIFICANT HAZARDS CONSIDERATION DETERMINATION Based on the above evaluation, it is concluded that the activities associated with NSHC "LS45" resulting from the conversion to the improved TS format satisfy the NSHC standards of 10 CFR 50.92(c); and accordingly, a NSHC finding is justified. l ?
- - - - - - - - =
ADDITIONAL INFORMATION COVER SHEET ADDITIONAL INFORMATION NO: O 3.3 p APPLICABILITY: WC REQUEST: CTS Table 4.3-2 Function 7.b, automatic switchover to containment sump Comment: No reference is provided for the change to the channel calibration. FLOG RESPONSE: The CTS markup for Function 7.b has been modified to reflect that DOC 1-23-A is associated with the change. Additionally, Function 8 is modified to reflect that Table Notation (4), which had been added, does not apply to this Function. ATTACHED PAGES: Encl. 2 3-37
i i TABLE 4 3-2
- ENC" CERED SAFETY FEATURES ACTUATKn SYSTEM INSTRUMENTATION ;
_ SURVEILLANCE REQUS HMENTS TRIP . ANALOG ACTUATING MODES i CHANNEL DEVICE MASTER SLAVE FOINNMiGN CHANNEL CHANNEL OPERATIONAL OPERATIONAL ACTUATION RELAY RELAY SURVEILLANCE FUNCTIONAL UNIT CHECK Call 8 RATION TEST TEST LOGIC TEST TEST TEST 4841EQUIRED
- 6. Auxiliary Feedwater (Continued) !
- c. Automahc Actuahon N.A. NA NA N.A. M(1)(2) NA NA 4rk3 y J ggy . !
' Logic and Actuahon N S> w
- H i '
Reisys (BOP ESFAS)
- d. Steam Generator Water S 4) Q. NA NA NA NA 4r43 ** if fI-23.N t,y,q.to,_to, w e d;7 il
- e. Safety injechon See item 1 above for all Survemance Requirements !
- f. Loss-Offsite Pwa NA NA M NA NA NA 47 43 Q #1 " g' f
- g. Trip of All Main NA N.A R NA NA NA 4 -
Feedwater Pumps
- h. Auxiliary Feedwater S 4) M NA NA NA NA 4r M i Pump Suchon Pressure- i Low i
- 7. Automatic Switchover to i Contamment Sump :
- a. Automatic Actuation NA N.A. NA NA M(1) M(1) Q(3)
- 2, 3, '
Logic and Actuohon ' Relays (SSPS)
- b. RWST Level- Low-Low S 4) Q NA NA NA NA * , 2, 3, '
I~M~A . Coinodent With Safety injechon See item 1. above for all Safety IrW Survedance Requirements [4 3.SP .)- P
- 8. Loss of Power
- a. 4 kV Undervoltage - NA 4 NA M NA NA N.A.
- 2,3 '
jfh % ;I Loss of Voltage i
- b. 4 kV Undervoltage - N.A. Rl4) N.A. M NA N.A. N.A.
- 2, 2, '
Grid Degraded Voltage ( Q 3 '5 P [ l t i t f WOLFCREEK- UNITI 3/43-37 Amendment No.-39,43 Merk-up ofCTS3M.3 M597 ! I _ _ . _ _ _ . . _ _ _ _ _ _ . _ _ _ _ _ _ _ _ _ _ _ _ . _ _ _ _ _ _ _ _ _ _ _ _ _ _ _ _ _ _ _ . _ _ _ _ _ _ _ _ _ . _ _ _ _ _ _ _ _ _ _ _ _ _ _ _ _ _ _ _ _ _ _ _ _ ~ ____.___ _ __________ _ _ _ _ _. _ _____]
ADDITIONAL INFORMATION COVER SHEET ADDITIONAL INFORMATION NO: O 3.3 q APPLICABILITY: WC REQUEST: ITS Table 3.3.2-1, Function 6(c) Auxiliary Feedwater - Automatic Actuation Relays - BOP ESFAS Comment: The CTS markup shows footnote (k) applies to the Allowable Value Column. Footnote (k) is not provided in the rnarkup. Revise the CTS to show the applicable footnote. FLOG RESPONSE: The ITS markup showed footnote (k) applies to Function 6(c). The footnote was a transcription error. Footnote (k) only applied to Callaway and is therefore being deleted from the ITS markup. No changes are needed to the CTS to show the footnote. ATTACHED PAGES: Encl. SA 3.3-41
\
l
{ ESFAS Instrumentation 3.3.2 Table 3.3.21 (page 7 of II) Engineered Safety Feature Actuation System Instrumentation APPLICABLE M00ES OR OTER SPECIFIED REQUIRED FUNCTION SLRVEILLANCE ALLOWABLE Mie COWITIONS CHAMIELS COWITIONS REQUIREENTS VALUE" SENGWW" ,gl
- 6. Auxiliary Feocheater__ - - -- ^
l % -Sb
);$$@$9]
- Mang36 initsbe*w
. 8. 2,3
~{perpwp O ER 3.3.2.6 WA, -
- b. A. Anomatic Actuation 1 2 trains G SR 3.3.2.2 NA M Logic and Actuatiou SR 3.3.2.4 Relays (Solid State SR 3.3.2.6 Protection System) z-SM Automatic Actuation 1 2.3 2 trains GW Logic and Actuation SR 3.3.2.3 NA E Relays (Balance of E313Mi$
Plant ESFAS) _M SG18ItetiMe] IE2D QerSG D SR Z 3;2;1 O22;3r_q[ lawftoW SR3 3;2J Nergw3asse os.3g l YqENN NN 943.3-55] (continued) (a) en e.r On . U-
;p; . 't ; al .-. ..;;=r.; =, ...;; ; = y '. s,.M : ';;'. x :.r. .:, r; = Rtw, = -
St.dj 0 :';;, . ; by tt .,' The. A110mable Yalue defines the Limiting Safety System Setting.'See 6 h~g the.BaA,fbr_theJtip;Setpoints, t WCGS-Mark-up ofNUREG-1431 -ITS 3.3 3.3 41 S/1S/97
l l ADDITIONAL INFORMATION COVER SHEET ADDITIONAL INFORMATION NO: Q3.3r APPLICABILITY: WC REQUEST: ITS Table 3.3.2-1, Function 6(g) Auxiliary Feedwater - Trip of All Main Feed Pumps l l Comment: The CTS markup shows footnote (p) applies to the Applicablity. Footnote (p) changes are not identified or evaluated in the CTS. Provide justificaiton for proposed changes. FLOG RESPONSE: Footnote (p) was inappropriately added to ITS Table 3.3.2-1, Function 6.g., Trip of All Main Feed Pumps. The CTS does not have a corresponding footnote. However, the CTS Mode of Applicability for Function 6.g is MODE 1 whereas the Mode of Applicability in NUREG- , 1431 is MODES 1 and 2. A new JFD 3.3-100 was initiated for adopting - the CTS Mode of Applicability. ATTACHED PAGES: Encl.5A 3.3-43 . Encl. 5B B 3.3-107 l Encl.6A 13 Encl.6B 17 I l l l l l l l l I l l
)
ESFAS Instrumentation 3.3.2 Table 3.3.21 (page 10 of 11) Engineered Safety Feature Actuation System Instr: mentation APPLICABLE MIES Gt (mER SPECIFIED REQUIRED StRVEILIANCE ALI.0WBLE Mip FLMCTIGl (XIEITIONS OWSELS COWITIONS IEQUIRDENTS VALUE'8 SE350&lW*
- 6. Auxiliary Feeenter
~r *1g (continued) >A*ub h1. w f .- Mz n\M fattee i EIL4 4 4 4 C'": b; t-fM35 ,.m . . .
w 6" "i.,i.i?.. **** 6" , ; y _ ..... . wMen l o 3.3 rj 3 3-1ao
- g. Trip of all Main Feessater Pumps ih 2 per pump J SR 3.3.2.8 Z .2.2."
E t-f-tpe 43 2 2.2.2.M M
- h. Auxiliary Feeenter Pump Suction Transfer 1.2.3 E233 FM Sit 3.3.2.1 i_'41,O!!1a EEE '
cl " on Suction Pressurt - _ ElhM44 - CO.C: M SR 3.3.2.9 fre4ei a-t-i Low Sit 3.3.2.12 fre4e}
- 7. Automatic Switchover to Contairment Simp
- a. AJtomatic Actuation 1.2.3.4 2 trains C SR 3.3.2.2 NA E Logic and Actuation Relays Sit 3.3.2.4A SR 3.3.2.12P QR 3.3.7.13) N 3~b
- b. Refueling Water 1.2.3.4 Storage Tark (INST) 4 K Sit 3.3.2.1 sX._12 % e4D Sit 3.3.2.5 .t. .; t e-i-i Level - tm Low SR 3.3.2.9 end _-
W M -{os.3 55l M (3.3-5 ! Coincident with Refer to Function 1 (Safety Injection) for all initiation SafetyInjection functions and regrirements. g 4*p
, 43.34(rEA) ,
j u 3 SEM - he. 6 & k Tripse%. _ (contin"d) (a) ,$ w I' . . w-... , A. - . . ..
-[ - . . . . w.. w h .h w h wh bh.. y P' *
,....s lQ4.3-6 en---~~~mam~ war me l p3.5 r-)
l WCGS-Mark-up ofNUREG-1431-ITS3.3 3.3 43 S/2SM7
i ESFAS Znstrumentation i B 3.3.2 BASES l APPLICABLE g. Auxiliary Faa< hater . Trio of All Main Feedwater
- SAFETY ANALYSES, EMEdi (continued) 3 LCO, and APPLICABILITY A Trip of all HFW plaps is an indication of a loss of MFW and the subsequent need for some method of l decay heat and sensible heat removal to bring the
- reactor back to no load temperature and pressure. A 1
Elicli turbine driven MFW pump is equipped with two pressure switches (tiheW9Faffit"Itih]FaigM 3 infTsWaMtTdirgNWB) on the ;;;;r:1 ;1r/;11 line for the speed control system. A low pressure signal l from either of these pressure switches indicates a trip of that ptmp. "eter dciven "".! i.;;;; s.r; j ; qui;-;ed .;ith ; t ;;k;r ;;siti;n xxia; d;;in. f.r. i c-;-:a ;g-;-ly Lc;;k;r indist;; trat tha ;;;;; i; net rg.c.ing. Two OPERABLE channels per pimp satisfy i redundancy requirements. .;ith ea ;;t ;f tw t;ica { t in legic. A trip of all MFW ptmps starts the motor driven ;r.d turbin; driven AFW pumps to ensure that at least one SG is available with water to act lmos2.,[rW m Q as the heat sink for the reactor. 4 hI bW4 c ag Functior;; 5.f i.ad 6.g must be OPERABLE in This ensures that at least one SG is provided with water N 3d I to serve as the heat sink to remove reactor decay heat and sensible heat in the event of an accident.
- In MODES 3. 4 i
! and 5, the and thus RGPs-end nefther ptmp tripMFW is nigplups mayofbe indicative a_nonnally _ shut down condition iri initi ion. ! ermibL 18llEElrislstmgisengermerasist 3stratique fMMiBNDECL7tX~JIMs3RinttME85lBlaliBit _ _ _ ---caru ac'tERTdlBREET8fRREe6 t siWCimin5! r
- h. Auxiliary Feedwater . Pimm Suction Transfer on L etion Pressure . Low A low pressure signal in the AFW pump suction line
- protects the AFW ptmps against a loss of the nonnal supply of water for the ptmps, the CST. Thjfee Two pressure switches are located on the AFW pump 1
- (continued)
WCGS-Mark-sp ofNUREG-1431-Bases 3.3 8 3.3107 5115197
l l l CHANGE NUMBER JUSTIFICATION 12 hours provides a reasonable and consistent allowed outage -- time, based on time allowed for an inoperable sequencer for these instrument _s when Condition B becomes applicable. A w Gewu% C w am.s crs 3.s.s % eme m& ! g iAoperab;littg er. h.m EsF wees.. me. E.-psaem.T.G\< 4 i Mreunet.
.4 rw i cLa 4 4o resta re_ hfiunchemQ capaH r.tg .f Cah3 (b.
g A new Conditiong] ir also added to the Actions of ITS LC0 3.3.5. The new Condition provides the appropriate shutdown h actions if Conditions { Bi are not satisfied when in Modes 1-4. Condition is consistent with the actions required by the AC Sources ITS .8.1 for Modes 1 4. qs.2et9T Condition C of NUREG-1431 Rev.1 is revised to be Condition 00]. b l Condition * @ provides the appropriate default Condition for g g I failure to satisfy Condition [A Bi when the loss of power instnmentation is required opera le to support the diesel generator r_e quired operable in ITS LCO 3.8.2. The new (Conddiwipbrefers to the requirements for an inoperable diesel generator and offsite circuit in LCO 3.8.2. It is appropriate @ [ the spoppP6 tion wht# LCM 4.8.2 tequires.6 dieSBD - l ( neratof operabhEfto simply refer to the AC Sources Shutdown TS i (LCO 3.8.2). since in these Modes (5 & 6)ft oss ! (frlstrtfientsfinn-en1v cunecrts dresel4wr or o i the list of required actions is long.(concube i A va remed G dw9 l l 3.3-100
@. s [o 3 3r l l
l 3.3 101 Not Applicable to Wolf Creek. See Conversion Comparison Table (Enclosure 6B). i 3.3-102 Not Applicable to Wolf Creek. See Conversion Comparison Table j (Enclosure 6B). 3.3 103 Not Applicable to Wolf Creek. See Conversion Comparison Table , (Enclosure 6B). 3.3 104 Not Applicable to Wolf Creek. See Conversion Comparison Table (Enclosure 6B). l 3.3 105 Not Applicable to Wolf Creek. See Conversion Comparison Table ! (Enclosure 6B). l l l l l WCGS-Differencesfrom NUREG-1431-ITS 3.3 13 S/15/97 l i
_ . . .___ _ m._ . . . _ . _ _ _ _. .. ___ __ ._ _ _ _ _ _ . _ - _ _ . _ . _ ___ _ _ __ ._. l INSERT 6A-13b 0 3.3r ' 3.3-100 ITS Table 3.3.2-1. Function 6.g. Trip of all Main Feedwater Pumps, is revised to delete MODE 2 from the Applicable Modes or other Specified conditions column consistent with CTS Table i 3.3-3. Function 6.g. During a normal shutdown of the main i feedwater pumps, and also during the startup trip test of the i main feedwater pumps, the automatic initiation signal for.the auxiliary feedwater system is blocked. This allows for greater j operational flexibility during normal shutdowns and startup of the plant when automatic initiation of auxiliary feedwater flow. upon the trip of both main feedwater pumps is not ' needed. This is consistent with the NRC SER for Wolf Creek j (NUREG-0881) Section 7.3.2.7 which states: " Blocking will be i permitted just before shutdown of the last operating main feedwater pump and removed just after the first main feedwater ; pump is out of service. The staff concludes that the applicant's design and operating procedures will provide adequate assurance that the auxiliary feedwater start signal on loss of both main feedwater pumps will not be blocked during operating modes when the diversity of this signal is desired. Maintaining the CTS Mode of Applicability as MODE 1 will continue to allow the blocking of the auxiliary feedwater system. i ? 4
CONVERSION COMPARISON TABLE FOR DIFFERENCES FROM NUREG-1431 Page 17 of 23 repi;c %. awe,ci.ha tsEts W iAmeLht.t SECTION 3.3 cicc M inoperstda .. TECH SPEC CHANGE h APPLICABILITY NUMBER DESCRIPTION DIABLO CANYON COMANCHE PEAK WOLF CREEK CALLAWAY l 3.3 99 ITS3.3.5ConditionB_isrevisedt2/110w1 T s to No - see CN 3.3- No see CN 3.3- Yes Yes 6estore . Instrupent funct erfto the 111ty 104. 131, conti ed oper on in C tion A. 12 allowp e fg 774 1 i 1 i ased o ITS 3 .F allow e for a noperatne seque - 4 6-a;Ww C h 4McA.4 lb 3.3.5 W' "$M5Ib SM g .ptd Uh on hub Esf baus..~The. Co-pRah'in *B.ef Ihas d [mb A
+ resbe. % Whd c patMig -l Mih -
A new ConditiortGeDis also added to the Actions of ITS LCO 3.3.5. The new Condition provides the appropriate shutdown actions if Conditions [A,@Bi are not sattsried h, when in Hodes 1-4. Condition is consistent with the actions required by the AC ces ITS 3.8.1 for Modes 1-4. D Condition NUREG-14 . 1 is revised to be Condition [.W). Condition [ provides the appropriate
" ^"It Condition for failure to satisfy condition [A ,
Co-C @ld when the loss of power instrumentation is required operable to support the diesel generator required operable in ITS LCO 3.8.2. 3.3 100 % ~ _ s q s en.T G e -l'I Q W W 8/A - N/.A3 b? 13'~ I The note for ITS SR 3.3.1.12 is deleted since the plant Yes No - see CN 3.3-50. No - see CN 3.3 50. No - see CN 3.3 50. 3.3-101 design no longer includes the RTD bypass. The SR is retained and is applied to the required seismic trip instrumentation per the current licensing basis. Where cited in Table 3.3.2 1, a change to SR 3.3.1.10 has been tude, The control room (CR) does not have CR Atmosphere monitors Yes No - see CN 3.3-78. No see CN 3.3 33. No - see CN 3.3-33. 3.3-102 as part of its current design. There are redundant CR intake monitors for each intake. S/ ISM 7 WCGS-Conversion Comparison Tame-ITS3.3
INSERT 6B-17a 0 3.3r
. TECH SPEC CHANGE APPLICABILITY NUndER DESCRIPTION DIABLO CANYON COMMANCHE PEAK WOLF CREEK CALLAWAY 3.3- ITS Table 3.3.2-1, Function 6.g. Trip of No No Yes No 100 all Main Feedwater Pumps, is revised to delete MODE 2 from the Applicable Modes or other Specified conditions column consistent with Wolf Creek CTS Table 3.3-3, Function 6.g.
+
k [ ____________.__m_.______.___.__.____..______m____.____.___.___.__._____.___._m__ - _ _ _ _ _ _ _ _ . _ _ _ _ _ _ _ . . _ _ _ ____1. . _ _ _ _ _ _ _ _ _ _ _ _ _ .<-m_ __m.m_ _ _ ____.__ _ _ _ _ _ _ _ _ _ _ . _ _ - _ _ . _ __ _ _ . _ . .-
- i. _ . _ _
ADDITIONAL INFORMATION COVER SHEET l ADDITIONAL INFORMATION NO: O 3.3-02 APPLICABILITY: DC, CP, WC, CA REQUEST: It is acceptable to have more than one Turbine Stop Valve Closure - reactor trip function channels inoperable and placed in trip per current TS Table 3.3-1, Functional Unit (16.b], ACTION Statement [10]. In addition, the 4 hour bypass note applies only to the [ Low Fluid Oil Pressure] channels. ITS 3.3.1 Condition P has been revised. l Comment: CTS actions for turbine trip on oil pressure and valve closure require a i separate !TS Conditions based on the different CTS allowances for tripping and testing channels in each of these functions. Provide a revised ITS with justifications that use j ITS Action P for oil pressure channels and a separate valve closure ITS Action that is i equivalent to Action P without the Note to Action P.1. Based on 8/14/98 meeting this comment will be responded to as part of DOC 1-11 LS 5 I , comment response. Use Vogtle actions for models. {DC} Use 1-48 LS4 to adopt split l actions, for the others the change is CTS. FLOG RESPONSE: Based on the Reference 5 meeting minutes, the response to this question will be tracked under this Comment Number, O 3.3-02. The response to l Comment Number Q 1-11 will direct the reviewer here. l The FLOG will adopt Conditions O and P approved for Vogtle, as indicated in the attached pages. DOCS 1-11-LS-5,1-15-A,1-48-LS-4; l NSHCs LS-4, LS-5; and JFD 3.3-02 have been revised, as applicable. ATTACHED PAGES: l l Encl. 2 3-3, 3-6a l Encl. 3A 4,5,6 i l Encl. 3B 4, 6 l l Encl. 4 26,27 l Encl. 5A 3.3-7, 3.3-8, 3.3-21 Encl. 5B B 3.3-51, B 3.3-52 ! Encl. 6A 1 Encl. 6B 1 l l l l
TABLE 3.3-1 (Continued) REACTOR TRIP SYSTEM INSTRUMENTATION REQUIRED M6N4MWM TOT ^.L N'^. GMANNE48 GMANNEOS APPLICABLE I'43-^ GE-CHANNELS TO"" OPERASbE MODES ACTION 1-04-LO FUNCTIONAL UNIT
- 11. Pressurizer Water Level-High 3 3 3 64 1-05-A
. 1-19-LS-8 g
- 12. Reactor Coolant Flow- Low 3/ loop K7 6 -#
- . 5 -j; L q (.^t:c; P 9) 3Aeep 2AeegHe 34eep-M 4 6-# ' l-05-A
- yeper- e-A ~;- . I-19-LS-8
- % " ~; ="~a '"~;
1^-~; 2."^~; 5 2 "- M 1 6-# l-57-LG -
- b. % L::;: (.^t:;; P '
i_._ " S) W ;r - ^ ;-
; : ; :;;, ; ... . '~;
I-05-A
- 13. Steam Generator Water 4/stm. Gen. 2!:t- . 0 0 . S ' *- . , a '- 1, 2 6#{1h
'- - ; :;:- ~ 1-45-M Level-Low-Low eh simg44m ;;:c.; ; r Gen. gen-
- 14. Undervoltage-Reactor Coolant 1-05-A Pumps us 3-*A m a 1 6 -# l-19-LS-8 N la 3,3f }
2-46-LS-42
- 15. Underfrequency-ReactorCoolant Pumps / bus 3-44us 3 C
17 6 -# 1-05-A g.g 9,L3.g
- 16. Turbine Trip
- a. Low Fluid Oil Pressure 3 3 3 a 3 1-15-A
- b. Turbine Stop Valve Closure 4 4- 4 a
. 1-05-A
- 17. Safety injection input 33*3 p s .3-o 2. ) ' l-l l-LS-5 from ESF 2 4- 3 1, 2 7 WOLF CREEK- UNIT I JH 3-3 Amendment No.43,43 MarA-up ofCTS3M. 3 5/1SM7
.. - - - . . _ ~ ~ -- -. . . = ~ = - . .~ . -. . - . , _
ACTION 12 - With one cf the diverse trip features (undervoltag2 or shunt trip attachment) inoperable, restore it to OPERABLE status within t The breaker shall not be bypassed while one of the diverse trip features is inoperable except for the time required for performing maintenance to restore the breaker to OPERABLE status. CTION 13 - With less than the number of Required Channels, operation may 1-15-A continue provided the following conditions are satisfied (Note: An 1-i l-LS-5 inoperable low fluid oil pressure channel may be bypassed for up to 4 hours for surveillance testing of other channels @tjpr4f : ' **L 54 a.
,43.33]
The inoperable channels are placed in the tripped condition within 6 hours, or
- b. Reduce THERMAL POWER to less than P-9 within 10 hours.
_- -- n - - Ac to*J 13.1 - LJiW be. numnosof cPeRAe,LE. chmvuh less, t .11-t.$ - 5 br he. Rqad c.h>nda, oy*h6, cents provided 4s. 61odm3 ccmdl.-hm {Q 3.3-62.} I
><e. s&s&JA *. h.
- o. . The, thopuab4.A. ch>nd s ww- placAd Adip %
cowenibcm dthin 6 houn. , ov-
- b. hu ~TRERMAt PoWEy2. in le*5 Mm P-9 .
wikia 1O bosg A f 46 hears er .'.- h a L _- i . 4{c';'/ - -Q
' O I. 1 -14 *3 }33 3'IID
[A least 140[STAh!DBY tJbb kc. nexk (. b
. WOLF CREEK- UNIT 1 3M 3-6a Amendment No. 43 Mark-up ofCTS3M. 3 SMSM7
CHANGE NUMBER NS!iC DESCRIPTION l protection afforded by the intermediate range neutron l flux trip. These actions actually provide a more i timely and appropriate redress to the condition than entering LCO 3.0.3. These changes are consistent with NUREG 1431. Rev.1. 1-08 H Current ACTION Statement [4] for one source range I channel inoperable in H00E 2 below P 6 is revised to require the immediate suspension of operations involving positive reactivity changes. The CTS does not specify the timing for this ACTION. A new ACTION Statement [4.1] is added to address the condition where I both source range channels are inoperable in H00E 2 ! below P 6 []. The new ACTION Statement [4.1] requires l the the RTB's be opened immediately. This action I essentially accomplishes the reactor trip function. In such a condition with the current TS LCO 3.0.3 would have been entered. This is more conservative since I imediate rod insertion will take the plant to MODE 3 l [] much more quickly than [the 7 hours] allowed by LC0 l 3.0.3. These changes are consistent with NUREG 1431. Rev. 1. : 1 09 H Not applicable to Wolf Creek. See Conversion Comparison Table (Enclosure 3B). 1 10 LS 32 Not applicable to Wolf Creek. See Conversion Comparison Table (Enclosure 38). 1 11 LS 5 Current ACTION Statement [6] applies to the Low Fluid Oil Pressure trip function and allows continued operation with one inoperable channel as long as it is placed in trip within 6 hours (with a 4 hour bypass allowance for surveillance testing). There is no associate:t action if an inoperable channel is not placed in trip within 6 hour iythefe pf.adtMh3 , (loVmyki DY1.peperpeXha6n s G herefore. LC0 3.0.3 would be invoked. [New] ACTION Statement [13] allows p" continued operation with one @ inoperable channel @as long asbrB placed in trip within 6 hours (with a 4 hour bypass allowance for j surveillance testing) or THERHAL POWER is reduced below i j P-9 within 10 hours. [See also CN 115 A] Current ACTION [11] applies to the Turbine Stop Valve Closure trip function and allows continued operation with multiple inoperable channels as long as they are placed in trip within 6 hours. There is no need for the 4 hour bypass allowance for surveillance testing ! l WCGS-Description ofchanges to CTS 3M.3 4 S/15/97 I l
CHANGE HUEER MStfC DESCRIPTION since all 4 channels are required to trip the reactor: the bypass allowance is needed when 2 channels satisfy the trip logic. There is no associEted action if the inoperable channel (s) are not placed in trip within g- 6 hours: therefore. LC0 3.0.3 would be invoked. [New]p3.S.02.\
) allows continued operation with ACTION one or more Statement inoperab @le channels as long as they ar!i placed in trip within 6 hours or THERHAL POWER is j reduced below P-9 within 10 hours. [See also CN 1-15 A] '
These changes are consistent with NUREG - 1431. Rev. 1. 1 1 12 H New ACTION Statement [8.1] is created to differentiate between those RTS interlocks required to be operable in 1 MODE 1 only, and those interlocks required to be operable in MODE 1 AND 2. If the interlock function is required to be operable in MCDE 1 only and the LCO and ACTION requirements are not met, then new ACTION Statement [8.1] requires that the unit be taken to MODE 2 within 7 hours. In addition, current ACTION Statement [8] is revised for those interlocks required to be OPERABLE in HDDE 1 and 2. If one channel is inoperable, the interlock must be determined to be in its required state or the plant must be in at least HOT STANDBY within 7 hours. The changes to current ACTION Statement [8] and the addition of new ACTION Statement [8.1] are more restrictive, consistent with NUREG - 1431. Rev. 1. Current ACTION Statement [8] will continue to apply to Functional Units [18.a and 18.e.] Revised ACTION Statement [8] and new ACTION Statement [8.1] provide one less hour to exit Applicability, i.e. 7 hours, than the current ACTION Statement [8] which has the 1 hour interlock state verification or entry into LC0 3.0.3 which allows an additional 1 hour plus 6 hours to exit Applicability, for a total of 8 hours. I 1 13 LS 6 [ ACTION Statement [9] is revised to note that the 2 hour [] reactor trip breaker bypass allowance for [ ] breaker surveillance testing can also be used for l maintenance. This change does not impact the conclusions of WCAP 10271 P A Supplement 2. Rev.1 since there is no change to the bypass time. This change is consistent with traveler TSTF-168.] ACTION Statement [9] is [also] revised to require restoration of an inoperable RTB within I hour or the plant must be in HOT STANDBY within the next 6 hours, consistent with NUREG - 1431. Rev. 1. This is less restrictive since WCGS-Description ofchanges to CTS 3M.3 S SAS/97
l CHANGE l NUMBER E2iG DESCRIPTION l l a:1 additional hour is provided for the transition to MODE 3. , 1 14 A In the ISTS. Table 3.3.1-1 Fur,ction 20. the Reactor Trip Breaker (RTB) Undervoltage and Shunt Trip , Mechanisms are separate from the RTB Functional Unit. The current TS have been revised to reflect these requirements. new [ footnote (b)] has been added to the RTB Functional Unit to note that the sama OPERABILITY requirements and ACTIONS apply to a bypast, breaker if it is racked in and closed for bypassing an RTB. The bypass breakers were already handles in this fashion. Action Statement [12] in current T 7e 3.3 1 has been revised accordingly. u.%cr J j g req. l 1-15 A The Applicability for the Reactor Trip on Turbine Trip function is modified by a new footnote [(a)] such that this function is only required to be OPERABLE above the P 9 interlock setpoint (50% RTP). This is acceptable D since the trio funQion locked below P 9. [New] \03.3421 ACTION Statement [13'] ied to the Low Fluid Oil Pressure and Turbine Stop Valve Closure trip functions. These are consistent with NUREG 1431. Rev.1. 1 16 LS 40 The requirement to verify the setpoint during the ! quarterly TADOT for RCP Underfrequency [and RCP l Undervoltage] is deleted, consistent with NUREG - 1431. l Rev. 1. I 1 17 A Consistent with NUREG 1431 Rev. 1. 3.3.1 Requi-Action D and E Note, the current TS Table 3.3- L ACTION Statement 2(lifWheHLp0RJtitamentE.1AfMf:een [qs.34D modified by a NOTE that allows the bypass to be used for surveillance testing or setpoint adjustment. Setpoint adjustment can be performed at power and may be required by other Technical Specifications. The ' reason for placing the channel in bypass does not effect the impact of having the channel in bypass. 1-18 LS 7 The current TS requirement to reduce the Power Range Neutron Flux Trip setpoint in the event a power range flux channel is inoperable, is deleted. This deletion is consistent with NUREG 1431. Rev.1 and is justified by: l l 1) The loss of one chonnel does not impact the l reliability of the Reactor Trip System because the affected channel is placed in trip. It may. M' CGS-Description ofchanges to CTS 3H.3 6 5/15/97
INSERT 3A-6a 0 1-14 l This change is administrative in nature since the current TS already specifies operability and surveillance requirements on the diverse trip attachments and the l bypass breakers (when racked in and closed), as evidenced by CTS Table 3.3-1 ACTIONS [9 and 12] for Functional Unit [19], [ Table 3.3-1 ACTION 7 for Functional , Unit 20], Table 4.3-1 Note [(11)] for Functional Unit 1. Table 4.3-1 Notes [(7) ; ! and (16)] for Functional Unit [19), and Table 4.3-1 Notes [(17) and (18)] for I l Functional Unit [21). l l l l l i l l I l l I
CONVERSION COMPARISON TABLE - CURRENT TS 3/4.3 P.ge 4 orso TECII SPEC CllANGE APFLICABfLITY NiiMllER DESCRIPTION DIABLO CANYON CCMANCllE PEAK Wolf CREEK CALIAWAY 1-10 This Callaway specific change redefines Actions for the No No ' No Yes LS 32 source renge neutron flux channels in MODES 3, 4 and 5. The source range peutron flux channels are required to provide input to the Reactor Trip System to mitigate potential uncontrolled rod withdrawal events only when the Rod Control System is capable of rod withdrawal or s r are not fully inserted (see CN 155 LS-39). gney g-_-w'e If one source range neutron flux channel is inoperable in 9* MODES 3, 4. and 5 when rod motion is possible. ACTION LIR 3 3 -00'* Statement 5.a is entered. If the channel is not res ed -g within 48 hours, the Applicability is exited by . Idihk* Adlem b all rods and precluding rod withdrawal. If both source L Q i wt range channels are inoperable when rod motion is possible, b__ new ACTION Statement 4.1 is entered and the reactor trip breakers are issuediately opened. The current Action Statement 5.a requirements regarding the suspension of positive reactivity changes and closure of dilution source valves are deleted since they are not.
~_
related to the reactor trip function. fr.13and.T3.Q ore]._ applied to the Low Fluid Oil No-see Yes Yes Yes [Q 3.M1 } 1-11 [New] ACTION Statement LS-5 Pressure and Turbine Stop a ve Closure trip functions. CN 1 48 LS-4. Rather than entry into LCO 3.0.3 if current ACTI0tt S__tatements [6 and 11] are not metMTuff14dTeAdGWid oiberassace4bennekace1naperele)the new ACTION requires inoperable channels to be tripped within 6 hours, or power reduced below P 9 within 10 hours. S/15/97 WCGS-CONVERSION TABLE- CTS 3M.3
CONVERSION COMPARISON TABLE - CURRENT TS 3/4.3 rage 6of3e TECII SrEC CifANGE APPLICABILITY NUMBER DESCRIFTION DIABLO CANYON COMANCIIE PEAK WOLF CREEK Call.AWAY 1-15 The Applicability for Reactor Trip on Turbine Trip function No - see No - already Yes Yes A is modified by new footnote [(a)] such that this function CN 1 48-LS in current TS. is only required to be OPERABLE above the P 9 interlock setpoint (50t IETP). This is acceptable since the trip (gj3adt3.Q on] jos.3.o2.] function is blocked below P-9. [New) ACTION Statements - - - . _ -
@appliedtotheLowFluidOilPressureandTurbineStop Valve Closure trip functions.
1-16 The requirement to verify the setpoint during the quarterly Yes Yes Yes Yes LS 40 TADOT for RCP Underfrequency [and RCP Und:rvoltage] is deleted. 1 17 The bypass allowance can be used for surveillance testing Yes Yes Yes Yes A or setpoint adjustment. Setpoint adjustment can be performed at power and may be required by other Technical Specifications. 1 18 The current T5 requirement to reduce the Power Range Yes Yes Yes Yes LS-7 Neutron Flux Trip satpoints in the event a power range flux channel is inoperable is deleted. The time to reduce , power below 75% RTP is increased
- rom 4 hours to 12 hours and if actions are not completed as__ required. t_he unit must be in MODE 3 within 12 hours.(( y pp_ {q s,s.g2O } _
If the requirements of current ACTION Statement [6] are not Yes No see Yes Yes 1-19 ' LS-8 met. LCO 3.0.3 would be entered. In accordance with the CN 1 61 M ISTS. this ACTION Statement is revised to state that. if the ACTION requirements are not met, the plant must be I taken below the P-7 interlock setpoint within the next 6 hours. [The Applicability for Functional Units 9. 11. 12,
- 14. and 15 in current TS Table 3.3-1 is also revised to add new footnote (c)].
WCGS-CONVERSION TABLE- CTS 3/4.3 5/15/97
IV. SPECIFIC NO SIGNIFICANT HAZARDS CONSIDERATIONS NSHC LS-5 10 CFR 50.92 EVALUATION FOR TECHNICAL CHANGES THAT IMPOSE LESS RESTRICTIVE REQUIREMENTS WITHIN THE TECHNICAL SPECIFICATIONS Current ACTION Statement 6 applies to the Low Fluid Oil Pressure trip function and allows continued operation with one inoperable channel as long as it is placed in trip within 6 hours (with a 4 hour bypass allowance for surveillance testing). There is no associated action if an inoperable channel is not placed in trip within 6 hoursdiiiFJh ther.e a3 acturfoc.m6Itiple' inoperable.-etmaneQ: therefore LC0 3.0.3 would be invoked. New ACTION Statement ] allows continued operation with one 6Piii5t$ l48~3N inoperable channel @as long (UilOm> placed in trip within 6 hours (with a 4 hour bypass allowance for surve~ 1ance te ing) or THERMAL POWER is reduced below P 9 within 10 hours. e ;t 4 Current ACTION Statement 11 applies to the Turbine Stop Valve Closure trip function and allows continued operation with multiple inoperable channels as long as they are placed in trip within 6 hours. There is no need for the 4 hour bypass allowance for surveillance testing since all 4 channels are required to trip the turbine: the bypass allowance is needed when 2 channels satisfy the trip logic. There is no associated action if the inoperable channel (s) are not placed in trip within 6 hours; therefore, LCO 3.0.3 would be invoked. New ACTION Statement [ ] allows continued operation with multiple inoperable channels as long as they are pl ced in trip within 6 hours or puoq THERNAL POWER is reduced below P 9 within 10 hours. g Entry into LC0 3.0.3 is overly conservative in the above situations since this trip g function provides an anticipatory reactor trip function only above P 9. [New] ACTION V Statement @ consistent with the ISTS philosophy of reducing power to enter a 163 c't.) condition wWre a function is not required to be OPERABLE. This is less restrictive 5 than the current TS which would require [ entry into a MODE where the function is not required to be OPERABLE.] The proposed TS change has been evaluated and it has been determined that it involves no significant hazards consideration. This determination has been performed in accordance with the criteria set forth in 10 CFR 50.92(c) as quoted below:
"The Comission may make a final determination. pursuant to the procedures in 50.91. that a proposed amendnent to an operating license for a facility licensed under 50.21(b) or 50.22 or for a testing facility involves no significant hazards consideration. if Operation of the facility in accordance with the proposed amendment would not:
- 1. Involve a significant increase in the probability or consequences of an accident previously evaluated; or l 2. Create the passibility of a new or different kind of accident from any accident preyiously evaluated; or WCGS- NSHCs - CTS 3M.2 26 5/1SM7
IV. SPECIFIC N0 SIGNIFICANT HAZARDS CONSIDERATIONS NSHC LS-5 (continued)
- 3. Involve a significant reduction in a margin of safety."
The following evaluation is provided for the three categories of the significant hazards consideration standards:
- 1. Does the change involve a significant increase in the probability or consequences of an accident previously evaluated?
Overall protection system performance will remain within the bounds of the previously performed accident analyses since no hardware changes are proposed. The proposed change adds a relaxation to the ACTIONS associated with inoperable channel (s) in the Reactor Trip on Turbine Trip function by keeping the end point of the shutdown action above the CTS requirement if inoperable channel (s) are not placed in trip within ldt13-02 ) 6 hours Fyrf upKip]AVCowE01d)RI PJessur,S-cflangsM are-TnopeMib. The new ACTION _ Statement would reduce power to less than P-9 (50% RTP) within 10 hours in these situations as compared to entry into LC0 3.0.3 [(power s 5% RTP)] in the current TS. The proposed change in the ACTION statements will not affect any of the analysis assumptions for any of the accidents previously evaluated. This trip function is anticipatory only and is not credited in any USAR Chapter 15 accident analyses. The proposed change will not affect the probability of any event initiators nor will the proposed change affect the ability of any safety related equipment to perform its intended function. There will be no degradation in the performance of nor an increase in the number of challenges imposed on safety related equipment assumed to function during an accident situation. Therefore, the proposed change does not involve a significant increase in the probability or consequences of an accident previously evaluated.
- 2. Does the change create the possibility of a new or different kind of accident from any accident previously evaluated?
There are no hardware changes nor are there any changes in the method by which any safety related plant system performs its safety function. The change in ACTIONS will not affect the normal method of plant operation. No new accident scenarios, transient precursors, failure mechanisms, or limiting single failures are introduced as a result of this change. Therefore, the proposed change does not create the possibility of a new or different kind of accident from any previously evaluated.
- 3. Does this change involve a significant reduction in a margin of safety?
The proposed change does not affect the acceptance criteria for any analyzed event. There will be no effect on the manner in which safety limits or limiting safety system settings are determined nor will there by any effect on those plant systems necessary to assure the accomplishment of protection functions. There will be no impact on any margin of safety. WCGS-NSHCs - CTS 3M.2 27 5/1587
RTS Instrumentaticn 3.3.1 ACTIONS (continued) CONDITION REQUIRED ACTION COMPLETION TIME N. MITUSED m_. n___ __ ,. _,__. ,<_
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~c- _ (continued)
#c. one. Low Flu *id Oil Press,ure. - -
-- rioTE - - - - ---
g Tht. ihoPcabic channet mD b e. TurbtneTriP channel bypassed fw upie 4 hours m
'" P* M S - saraittmu.te hA ef
.- -- -. -. 3 4herchannas.
(43 M c.t Pt xa. channel iA Wip. 6. hours OR C . "2. Redaca. %E12 MAL POWER. to bean in 4 P-9. WCGS-Mark-up ofNUREG-1431 -ITS 3.3 3.3 7 S/1587
1 RTS Instrumentation 3.3.1 ACTIONS (continued) C0WITION REQUIRED ACTION COMPLETION TIME l P. [43.1-o1} One of~more Turbine - oil]
~
Trip Eh'anneI(s) l Be ino abl owjju NI23 N.;,.,9 inoperable. I . cha may be ypas J for to 4 urs for
%vbhe. SepV*\W. ve111 e testi of Ctm f s.
r Nchan _--- --- x --- _--- --- l P.1 Place channel (s) in trip. 6 hcurs E i P.2 Reduce TliERMAL POWER to 10 hours ,
< pzg, M 984! %!
Q. One train inoperable. -- ---
-- NOTE - -- ----
One train may be bypassed for up . to 4 hours for surve111ance E485~ E testing provided the other train is OPERABLE. Q.1 Restore train to OPERABLE 6 hours status. i E Q.2 Be in H0DE 3. 12 hours i (continued) i h WCGS-Mark-up ofNUREG-1431 -ITS 3.3 3.3 8 S/158 7 l
l RTS Instrumentation 3.3.1 l l l Table 3.3.1 1 (page 5 of 8) t Reactor Trip System Instrumentation " l APPLICABLE MODES OR OTHER SPECIFIED REQUIRED SURVEILLANC ALLOWABLE 4*te agg;g-. < FUNCTION CONDITIONS CHANNELS CONDITIONS E * " VALUE
- GE# 0 M *'
REQUIREMENT S
- 15. Not used. 497 : n. = E = . : . ". . ' a ';;.0;; i ' .;;; I 90-tfoter = 3. . . 7 .g;gg.3;01*
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- '- i'"' _.
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- - l
#tematch = !.',.'.
- 16. Turbine Trip 3 3,,.g, p
- o. Low Fluid Oil 15 3 #0 SR 3.3.1.10 956 ese b' Pressure SR 3.3.1.15 2 534.20 e-596:ee ggg.;j psig pefs -
- b. Turbine Stop 14 4 P SR 3.3.1.10 Valve closure SR 3.3.1.15 a 11 open .';,_. ggggp g
- 17. Safety 1,2 2 trains o SR 3.3.1.14 NA h4 Injection (SI)
Input from Engineered Safety Feature Actuation System (ESFAS)
- 18. Reactor Trip System Interlocks
- a. Intermediate 2* 2 S SR 3.3.1.11 2 6Ei11 amp a 1E-10 Range Neutron by4gi g g" Flux, P 6 gg SR 3.3.1.13 amp US 54
- b. Low Power Reactor Trips 1 1 train T h NA
.5.3-5Q
. . 13] NA Block, P-7 f j
- c. Power Range SR 3.3.1.11 o Neutron Flux, 4 SR 3.3.1.13 Sibe P-8 1 T 5diO@kis s 51'31 RTP
~
s 6BE RTP _ m l{Q 3.3-4t } {y (continued) l I (a) :....... . :e;.. 0.-, a.a , .' ; . . __..;.;;... - , ...;.;. ..;, ;.;;. _.. ;.;- - ,
.a. 4 . ;.. . '
;.,, _. .f L, .:.. .: .. ,,The.. Allowable yelue ' defines the Limiting Safety System Setting. See 4323408"4 e
, tWBones;foF_the {dp_SutpoTnts;
- (
- :) Below the P-6 (Intermediate Range Neutron Flux) Interlocks.
(j) Above the P-9 (Power Range Neutron Flux) interlock. I WCGS-Mark-up ofNUREG-1431 -ITS3.3 3.3 21 5/1587
RTS Instrumentation B 3.3.1 BASES l n__..,__; Im.e L#R 7 m.1 m .wgu . . wg. r w k..i.d
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l P.1 and P.2 l Condition P applies to Turbine Trip onCLow-ffu14-efOrelfsurror' ps.s-o2.] l ~@ Turbine Stop Valve Closure. With one or_nore channel (s) l inoperable the inoperable channel (s) must be placed in the trip l condition within 6 hoursE 'ed in n1ey1ppetumuivwo - (thie-ffsults'1T1 a.seffial o condit(on f For_the Turbine Trip g (on Turbine Stop Valve Closure function, four of four channels are 1 r i required to initiate a reactor trip: hence, more than one channel ' i (may be placed _in trip. ~rt r5fne on F A1T3
@rJestireJdfictM i one nnel i acad tr .r#q;m.i ri r,- l
, (continued) WCGS-Mark-up ofNUREG-1431-Bases 3.3 B 3.3 51 5/15l97 i I i
INSERT B 3.3-54 0 3.3-02 0.1 and 0.2 l Condition 0 applies to Turbine Trip on Low Fluid Oil Pressure. With one channel inoperable, the inoperable channel must be placed in the trip condition within 6 J hours. If placed in the tripped condition, this results in a partial trip condition requiring only one additional channel to initiate a reactor trip. If l the channel cannot be restored to OPERABLE status or placed in the trip condition, then power must be reduced below the P-9 setpoint within the next 4 hours. The 6 hours allowed to place.the inoperable channel in the tripped condition and the 4 hours allowed for reducing power are ' justified in Reference 6. The Required Actions have been modified by a Note that allows placing an inoperable channel in the bypassed condition for up to 4 hours while performing routine surveillance testing of the other channels. The 4 hour time limit is justified in Reference 6. l l h ? i n _ , . - - . . - , - , , , .- , - , _
L i l RTS Instrimentation l B 3.3.1 l
)
BEES , ACTIONS P.1 and P.2 (continued) on1
#itionat chann61 ishrstLto1nitiate1i~ r-fd [Q 3.3-62.]
If the channetcannot be restceM to OPERABLE status or placed in the trip condition, then power must be reduced below GS) the P 9 setpoint within the next 4 hours. The 6 hours allowed to place the inoperable channeLin the tripped condition and the[W.u-ED] 4 hours allowed for reducing power are justified in Referencetzt IThe Yred ns been mo yd by a y that al ows % 3/5-o2 l ing _1 ble liliChm7_1 cha in the
- bypass condit for up hours e perfo I sypv6illanc esting other nnels. 4 hou ime Q1miti ustified Referenc 7. f -
l l l 0.1 and 0.2 . l l Condition Q applies to the SI Input from ESFAS reactor trip and ' the RTS Automatic Trip Logic in MODES 1 and 2. These actions address the train orientation of the RTS for these Functions. l With one train inoperable, 6 hours are allowed to restore the train to OPERABLE status (Required Action Q.1) or the unit must be placed in MODE 3 within the next 6 hours. The Completion Time l of 6 hours (Required Action Q.1) is reasonable considering that l in this Condition, the remaining OPERABLE train is adequate to perform the safety funttion and given the low probability of an event during this interval. The Completion Time of 6 hours (Required Action Q.2) is reasonable, based on operating experience to reach MODE 3 from full power in an orderly manner and without challenging unit systems. The Required Actions have been modified by a Note that allows bypassing one train up toff) hours for surveillance testing, provided the other train is OPERABLE. i w nhh (bmk ted.) [Q 3.3 fr-1 1 ! R.1 and R.2 Condition R applies to the RTBs in MODES 1 and 2. These actions address the train orientation of the RTS for the RTBs. With one l train inoperable. I hour is allowed to restore the train to OPERABLE status or the unit must be placed in MODE 3 within the next 6 hours. The Completion Time of 6 hours is reasonable, 1 I l- _ (continued) WCGS-Mark-pp ofNUREG-1431-Baus 3.3 B 3.3 52 5l15l97 l
l l l JUSTIFICATION FOR DIFFERENCES FROM NUREG-1431 NUREG-1431 Section 3.3 This enclosure contains a brief description / justification for each marked up ; technical change to NUREG 1431 Revision 1 to make them plant specific or to ; incorporate generic changes resulting from the Industry /NRC generic change process. The change numbers are referenced directly from the NUREG 1431 mark ups. For enclosures 3A. 3B, 4, 6A. and 6B, text in brackets "[]" indicates the information is plant specific and is not common to all the Joint Licensing Subcomittee (JLS) plants. Empty brackets indicate that other JLS plants may have plant specific information in that bracket. CHANGE NUPBER DESCRIPTION 3.3 01 This trip function or design feature is not included in the plant design or it is not credited and has no safety function. 3.3 02- For the Reactor Trip on Turbine Trip function based on turbine stop valve position, 4 of 4 channels are required to close to gja less than 1% open in order to generate the reactor trip signal. 8 g# Thus, it is acceptable to have more than one Turbine Stop Valve l *"'# "N Closure reactor trip function channel inoperable and placed in i Y'" trip per current TS Table 3.3-1. Functional Unit [16.b]. ACTION ! Statement [11]. In addition, the 4 hour bypass note applies only to the [ Low Fluid Oil Pressure] channels. ITS 3.3.1 Condition P 1 & W \ l t hasbeenreviseg. gg,gf 3.3 03 Not applicable to Wolf Creek. See Conversion Comparison Table (Enclosure 6B). 3.3 04 Not applicable to Wo',f Creek. See Conversion Comparison Table (Enclosure 68). 3.3 05 Not applicable to Wolf Creek. See Conversion Comparison Table (Enclosure 6B). ! 3.3 06 Not applicable to Wolf Creek. See Conversion Comparison Table l (Enclosure 6B). 3.3 07 Note 3 is added to ITS SR 3.3.1.11 to be consistent with the current TS Table 4.31 Note [5]. This ensures that this exception for power and intermediate range detector plateau voltage
- verification, as discussed in ITS BASES for SR 3.3.1.11, is included in the Technical Specifications rather than being only i
WCGS-Dufferencesfrom NUREG-1431-ITS 3.3 1 S/158 7 l l r
CONVERSION COMPARISON TABLE FOR DIFFERENCES FROM NUREG-1431 Page 1 cf 23 SECTION 3.3 TECH SPEC CHANGE APPLICABILITY NUMBER DESCRIPTION DIABLO CANYON COMANCHE PEAK WOLF CREEK CALLAWAY 3.3-01 This trip function or design feature is not included in Yes Yes Yes Yes the plant design or it is not credited and has no safety function. 3.3 02 It is acceptable to have more than one Turbine Stop Valve Yes Yes Yes Yes Closure - reactor trip function channels inoperable and placed in trip per current TS Table 3.31. Functional Unit [16.b]. ACTION Statement [11]. In addition the 4 hour bypass note applies only to the [ Low Fluid Oil Pressure] channel _s. ITS 3.3.1, Condition P has been [o s. 3- o2.] revised. (cona;t 4n o % Wen o4Aed M] 3.3-03 This change to ITS 3.3.1 Condition R is consistent with Yes No - not in current No not in current Yes (current TS per the current licensing basis. A 4 hour A0T for SSPS logic TS. TS. OL Amendment No. 64 surveillance testing has little usefulness if the RTBs dated 10-9-91) cannot be bypassed for the duration of that testing. RTB surveillance testing retains the current 2-hour A0T. 3.3-04 This change represents the Callaway plant design as it No - see No not in current No - not in current Yes (current TS per relates to the SG Water Level Low Low Environmental CN 3.3-46 TS. TS. OL Amendment N(.. 43 Allowance Modifier (EAM) and Trip Time Delay (TTD) dated 4-14 89) circuitry. ITS Table 3.3.11 and Table 3.3.2-1 entries and the associated Required Actions have been enhanced to remove the redundancy in the current TS and add shutdown actions when inoperable channels aren't tripped per their + Completion Time. 3.3 05 This change to ITS SR 3.3.1.3 Note I represents the No - not in current No - not in current No - not in current Yes (current TS per current TS as it relates to the Overtemperature aT AFD fi TS. TS. TS. OL Amendment No. 84 (al) penalty function. dated 11-8-93) 3.3 06 Retains current TS power requirement of 75% RTP in the ITS Yes No - see No - See No - see SR 3.3.1.6 Note concerning when the incore/excore CN 3.3 97 CN 3.3-97 CN 3.3 97 calibration is performed. The ISTS proposal would require unnecessary delays in the post refuel power ascension. WCGS-Conversion Comparison Table-ITS3.3 S/1587
ADDITIONAL INFORMATION COVER SHEET ADDITIONAL INFORMATION NO: O 3.3-10 APPLICABILITY: DC, WC REQUEST: [The Overtemperature AT setpoint equation had a bracket in the wrong place and was corrected.) In addition, the f i(AI) penalty function was correctad and the K2 inequality sign was changed to an equal sign. Comment: Reject for [DC). The ITS proposes generic changes to the iTS that are not included in current TS. In Note 2 of ITS Table 3.3.1-1 the inequalities for t4 and t5 are reversed from the CTS markup in Note 3 of Table 2.2-1. [WC] - Revise T' be ' nominal"; Revise 2-04M to include t. Show that the F(Al) terms in ITS are equivalent to CTS values. Provide justification for text deleted from F(AI) Overtemperature AT Note 1. FLOG RESPONSE: For DCPP, the change to the ITS OTAT equation to relocate the bracket has been deleted and the CTS OTAT equation has been restored to the original version which has ben verified to be consistent with the Eagle 21 WCAP-11082 Rev.2. JFD 3.0-010 is no longer applicable to DCPP. For WCGS, T' has been revised to
- nominal. The F(Al) terms in the ITS have been revised to reflect correct decimal point placement instead of a percentage as in the CTS. No justification is required since the CTG text is equivalent to the ITS equations. The CTS discussed F(AI) in a text type format while the ITS uses an equation format.
Also, refer to the response to Comment Number Q 2-04 (2.0). ATTACHED PAGES: Encl. 5A 3.3-23 I r
I RTS Instrumentation 3.3.1 Table 3.3.11 (page 7 of 8) Reactor Trip System Instrumentation 1 Note 1- Overta=narature AT The Overtemperature aT Function Allowable Value shall not exceed the followfng Trip Setpoint by more than 3;e41.3% of AT span. 484EA:
' f '
(1+ Ti s) i 1 (1+ t,s) 1 i or 5 or, < 7 - r# + K (F - F ,) g 4 (1+ T s) (1 + T3 s) ,1+ T3s, (1+ t,s) 3 4 (AT) 3 , , Where: AT is measured RCS AT 'F. AT, is the indicated AT at RTP, 'F. s is the Laplace transform operator, sec 3 T is the measured RCS average temperature. *F. T' is the nonWt @T , at RTP, s 588af 586.5'F. IG N O3 gg.p339 f s,hs+ P is the measured pressurizer pressure, psig. P' is the nominal RCS operating pressure r 12235 psig. 02M gg.ps% i.49 1.10 - 9-9138 0.0137/*F K3 0.000671/psig W 6 sec 33 16 sec M 3 see T3 [2] eec y z sec O 4 gg.ps y g ts p see - T. . [2] x-; = 0 sec
;i4J40!";
f (AI) = Mh06 {36 23* + (q g)} when q, q, < 364 23% RTP
~
gofon 7] f RTP h05 {(qs q.) when 23t 354 RTP s q, q, s 74 5t RTP I43 3-# I St 7} when qs q, > 74 5t RTP ggg;psy;a where qi and q, are percent RTP in the upper and lower halves of the core, respectively, and q, + q, is the total THERMAL POWER in percent RTP. WCGS-Mark-up ofNUREG-1431 -1153.3 3.3 23 S/ ISM 7
ADDITIONAL INFORMATION COVER SHEET ADDITIONAL INFORMATION NO: O 3.3-17 APPLICABILITY: WC, CA REQUEST: New CONDITION [P] is added for Function 6.h of ITS Table 3.3.2-1, consistent with current TS Table 3.3-3 ACTION Statement [15]. Comment: {WC} Action M.2; {CW} Action P.2. Revise the proposed ITS Completion Time format to include a logical "OR" requirement: "31 days"_OR *During performance of the next required COT" FLOG RESPONSE: Based on meetings with the NRC held between September 15 and September 18,1998, Callaway will revise ITS 3.3.2 Required Action P.2 to delete the word " inoperable." Wolf Creek will make the same change to their ITS 3.3.2 Required Action M.2. Wolf Creek will also revise the Completion Time for their Required Action M.2 to match Callaway's, i.e.,
*During performance of the next required COT".
ATTACHED PAGES: Encl. 5A 3.3-31 l l
i i ESFAS Instrumentation 3.3.2 ACTIONS (continued) I l I CONDITION RE0'JIRED ACTION COMPLETION TIME
!=5E-i=?=Nate : 55ih :. j M .~ e One~~ channel MJ3][isJxLt; applicable l' hour j3y3;173 ;
i=f= =:-E:555:9----- = t_noperable : l l M.1 P1 ace ~channeriri trip ~.' l l E M[ ring l _ _ perf_onnancelof --
)
M.2 Restore M next~00]yTi~ / {433-l'l} channel to;0PERABLE flecterMr . status. 1 N. One train.' inoperable ;;--- 3 .~r-2? E = NOTE-t-I n i- = l One_,trainmay;1belbypas_ sed;forup to33mrs for1 surveillance , tesgngyovidedithe other. train 1s]PERABLE.
==:= .:. = - . . . - . . :==:= . -;. . .
N_ 1.. . Be_in.. MODE. 3. 6 hours 93.3-59T M , N;2 Be in ~ MODE'4'. 12 hours O. one or mere channels O.1 Enter gic>la Canaih6n(s) (mme41 33-se> ihopen'oic. . arnd. Repired Actio(s)4 LCD 3.~7.F for ihe. Q Z.-51 a.gociated., mihir3 eedtde_r f _ _ y(2h made ihope.r4bEa., l l l l l l WCGS-Mark-up ofNUREG-1431 -ITS 3.3 3.3 31 S/15/97
ADDITIONAL INFORMATION COVER SHEET ADDITIONAL INFORMATION NO: Q 3.3-19 APPLICABILITY: WC, CA REQUEST: 18-month test interval previously approved by NRC for selected slave relays t which, if tested at power, could result in plant trips or upsets. I Comment: (WC, CW} ITS SR 3.3.6.5 and 3.3.7.5 replace CTS quarterly slave relay - testing (SSPS relays ) with 18 month test. Also, CTS T4.3-2 Note (3) provides a , modified quarterly SR for specified logic relays. In the ITS these CTS requirements are changed and are neither identified nor evaluated. Provide a revised CTS and ITS markup with appropriate justifications. : {WC} CTS Table 4.3-2, Containment Spray (Function 2.b) Table Note (3) is deleted in l ITS SR 3.3.2.6 without justification. Provide appropriate justification. {WC, CW} The STS does not provide SR frequency changes as footnotes to SRs listed in Table 3.3.2-1. Move footnotes (c) and (p) to the SR Table as modified frequencies. FLOG RESPONSE: Based on a meeting held with NRC staff on September 15,1998, the second comment above was resolved (see DOC 2-30-A). In addition, the i first and third comments are addressed by the attached ITS and ITS l Bases changes; no changes to any DOC or JFD are required. ; l ATTACHED PAGES. i Encl. 5A 3.3-32,3.3-34,3,3-35,3.3-37,3.3-40,3.3-43 Encl. SB B 3.3-128, B 3.3-129, B 3.3-132, B 3.3-133 t l
)
l l l 1 f 4 4 1 1 I
i ESFAS Instrumentation 3.3.2 3 oth.c thm EsF REsW SURVEILLANCE REQUIREMENTS nn
~ - y verif i cati oh _
@ s.s.5C }
. . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . N0TE ~ --- " ~ ~ ~ ~ ~ ~ ----~ ---
Refer to Table 3.3.2-1 to determine which SRs" apply for.each ESFAS Function. s.s.ss kgb iMNENcaEo JA ApeAiNESR. 3.3.2.k" SURVEILLANCE FREQUENCY i 1 1 SR 3.3.2.1 Perform CHANNEL CHECK. 12 tours i l l l i SR 3.3.2.2 Perform ACTUATION LOGIC TEST. 31 days on a STAGGERED TEST BASIS L i SR.3.3.2.3 ~ ~ ~ --~ ~ ~ -- -- - NOTE --- ~ ~ ~ - --~ ~ ~ The continuity check may be excluded. i ............................................... t Perform ACTUATION LOGIC TEST. 31 days on a l STAGGERED TEST BASIS i ,- i SR 3.3.2.4 Perform MASTER RELAY TEST. 31 days on a STAGGERED TEST BASIS M -- ~ wars - - - - - -. SR 3.3.2.5 Perform COT. f.m,
. . azo, war agricalda.b alaw.nha-mu., aza., ocuo, 92 days
/ G. c r.e o , w M 4 i.
9 A -_
- ___ - - - -d- - los.s.a1 SR 3.3.2.6 (.3.3 -14 Perform SLAVE RELAY TEST. 92 days gqqmy SR 3.3.2.7 ---- ~ ~ ~---- -- -NOTE- - - - -- - -~-~ ~
VeHf4;;ti;r, of ral.y ;;; pir.t; r.;; r;quir;d. 4pg e j Perfarm TADOT. 92 31 days gg.ps y i (continued) i WCGS-Mark.ay ofNUREG-14.11 -1TS:J 3.3 32 $/1SR7 1 , , i
, 5 i
l ESFAS Instrtmentation ! 3.3.2 i i SURVEILLANCE REQUIREMENTS (continued) SURVEILLANCE FREQUENCY I i W23;E12 N form;CD E 317plygg gg g g g ! Q u -ss \ , SR 3.3.2.13 --
- - - NerrE. - - - - - - - I on applicable. 4e slave retags K4cz, 3***'i W. 2, K62.4 K630, K ~740,MK74).
3 I
+
P@m 6 LAVE RELAY ~~IEST. 18 monb , w Wk to enterin3 MODE 4 when'm j ,
; eveE Sor6ftw 724 ( !
hows. ifnet r performc.4 dihm, ,
> ihe.previ= 9% i I SR 3.3.2.114- - - - - - N cRE - - - - -- .-
% gelicable. b . slave re.laj K620.
1 - I Morm St. AVE RELA 7 TEST. ig,m,A 1 AeJD l Theslo anter[n3 l P100E 3 when M MODE S erg b >24
\
hows, ;$ mok
\ I pe<{ormeA. JW .
~
i the prevw 97.%s WCGS-Mark-sp ofNUREG-1431 -ITS3.3 3.3 34 S/158 7
)
ESFAS Instrumentation 3.3.2 Table 3.3.21 (page 1 of 11) Engineered Safety Feature Actuation System Instrumentation APPLICABLE NN)ES OR OTER SPECIFIEI) REQUIRED SURVEILLANCE ALLOW 4BLI Mie FLMCTION COWITIONS CHANELS COWITIONS REQUIREENTS VALUE" EEDOWP*
- 1. Safety Injection ggg
- a. Manual Initiation 1.2.3.4 2 B SR 3.3.2.8 NA --44A
- b. Automatic Actuation 1.2.3.4 2 trains C SR 3.3.2.2 NA NA Logic and Actuation SR3.3.2.4g Relays SR 3.3.2.
cons.s.z.n>3 gq3,3.gj 5374 DJ
- c. Containment 1.2.3 3 D sR 3.3.z.1 s _4.5 psig e &G Pressure-High 1 SR 3.3.2.5 B-86 potg g" g "gg SR 3.3.2.9 B-6 M - lQ 3.3-SF l 3'3-5
- o. Pcessurizer 1.2.3" 34 D SR33.2.1 a 1815 psig Pressure - Low 3-4049 p -a SR 3.3.2.5 SR 3.3.2.9 4609 pelg 4869
_ g; ppg QiiKUtG463 - lo 3.3-55 ] my
- e. Steam Line Pressure fit Low 1.2. 3 per QMMj D SR 3.3.2.1 a: 571 psig" s-fBE steam SR 3.3.2.5 606 psef" 3" line SR 3.3.2.9 676 3 'S '
(SadM- [as.3 ss_) feHHsh hM B-pee B : 2.2.2.1; - : 00: pi; s-f973 Oi".. ....ul steen SlH H he-6 pe4s
?,3;3;gg~1
' ~
Pressure Mne " 2.2.2. Between-56een " 2.2.2. 2 L4mes "ig'. 02 ; Pl; '- Mro '* T;;; St. . Lix; G-pee B " 3.2.2.1 fet 44+ gpgg stesh 5" 2.2.2.0 f; Not Usad. Hee Z .2.2.:
- e. ,,,,
Ci x '.... d t' 4r4,3'* 4-pee B 0" 2. .:.; a 32.C'" r-{55 Bit T ,-how-tew 4eep = :.2.2.5 F
..,,,, 1.323 90M.
5" 2.2.2.1" (continued) (a) .,su ;r ' ;; =; . LW: .r... ^t r,1-....;;n. ny _. ; xly "1; 11; .';1.;
- r. 4.re = 2;p; t M.dj =ti t;j .;d Ljt'.; =" The' Allowable. Value defines the Limiting Safety System Setting. See the~ Bases 1for:the.TripWints: _
q+r3,g 3"' (b) Above the P-11 (Pressurizer Pressure) interlockd [omd. belma P-il wnlen bloc.kM]Q3.'3 G}.3.3 c ) (c) Time constants used in the lead / lag controller are t a 5(Fseconds and t, s 5 seconds. id ft: . ; W " '_' 'T,,, - L= L;.: ' Oc Sc. ggg~g a: L;;; .. .. ;r ;,..: = ; f. _;.x d. ;. d n er r.erc. , . :r.; e 3::: f.1' ;u s = k b.: :20: i nd. "gyg~g
=d er 1.~ ...;r., ' x., ij Ce:: f. ' n w ; n (20: i nd = :::::: f.' ;= x u = O'C: -
123. ad cf _. . . .c r., = ".: : ?. ' ;t u _L. = = i nd. _ uni for . hour's not n WCGS-Mark-up ofNUREG-1431 -ITS3.3 3.3-35 S/lSR7
l ESFAS Instrumentation 3.3.2 7 l Table 3.3.21 (page 3 of 11) Engineered Safety Feature Actuation System Instrumentation APPLICABLE l MODES OR OTER SPECIFIED REQUIRED SURVEILLANCE ALLOWABLE Mie FUNCTION C0K)lTIONS CHANELS COM)ITIONS VAWE" REQUIREENTS SEDOWP"
- 3. Containment Isolation g3g
- a. Phase A Isolation (1) Hanual 1.2.3.4 2 B SR 3.3.2.8 NA E Initiation (2) Automatic 1.2.3.4 2 trains C SR 3.3.2.2 NA E Actuation Logic SR 3.3.2.4 w j and Actuation SR 3.3.2.6 U* i Relays I
{sg3,3, ,igI G3 55 T4 i (3) Safety Refer to Function 1 (Safety Injection) for all initiation ; Injection functions and requirements. '
- b. Phase B Isolation (1) Hanes) 1.2.3.4 2 per B SR 3.3.2.8 NA M Initiation train. 2 trains (2) Automatic 1.2.3.4 2 trains C SR 3.3.2.2 NA M Actuation Logic SR 3.3.2.4 l and Actuation SR 3.3.2.6
- Relays (3) Containment Pressure High - 3 1.2.3 4 E SR 3.3.2.1 s.28.3 psig e-6-4 ' ;g,pg7 g
'"ip."ip.; SR 3.3.2 H-in poet SR 3.3.; 9 H-05 '
MJ@-lQ3.3 55 l .5356
- 4. Steam Line Isnlation I l
- a. Manual Initiation 1. 2") . 3"> 2 F SR 3.3.2.8 M M ;
(continued) ! (a) .t . ua: ; On . Oc; .r...' n ; gl ..^.n u m m y .....:.;. =1; f'1;;;' ;;1 x 2, . .: . r; = 5 ;,~ ; ".
;;. / x:22.t;, .x ty th: m': The: Allowable _Value defines tte Limiting Safety System Setting. See Q3:3.gg p the.Sasqsfor thelTripWitits.'
(1) Except when all MSIVs are closed. r 2 the 7"4 d' - (M;19h Jos.3-t9] - - WCGS-kcrk-up ofNUREG-1431 -ITS 3.3 3.3 37 5/1587
4 a ESFAS Instrumentation 3.3.2 Table 3.3.21 (page 6 of 11) Engineered Safety Feature Actuation System Instrumentation APPLICABLE N0 DES OR OTER SPECIFIED FUNCTION REQUIRED SURVEILLANCE ALLOWABLE Mie COWITIONS CHANNELS COWITIONS PIQUIREENTS VALUE" SE3003#P*
, e ___ .2__ ,__,_m__
Nf3d3-08Pi h.TNot3eell
':if. ':if. ;;;n Fh; 4,7*,-3** 2-pee 9 Z .2.2.1 ; C00): ;f s-{-}-ef steem 0" 2.2.2.0 El' ;ts; -fwM aM0lb; Mne C" 2.0.0.0 ;.; ;t '.l' steen 0" 2.2.0.10 ind ;;;n Mee.et Pree w e +wM
' ud ;t..;
PPe*S8Pe
;IA 'I "
h.;.,...N- f'N. b. 5'32. 5..[N.. . I,i!. .f . _ . . .$. . C'
.. h53:3io14
- 5. Turbine Trip and Feedvater Isolation
- a. Automatic Actuation 1.2(8 2 trains H fG} SR 3.3.2.2 NA NA Logic and Actuation E3}"
Relays SR 3.3.2.4# id 8-PS 6 SR .3.2.fP.!9 s sa, .>.2.a 163 6l 3.3- H
- b. SG Water 1.2(8 3 4 per I fB} SR 3.3.2.1 s 79.7% of e-906 Level-High High E3}*" SG SR 3.3.2.5 Marrow Range (P 14) of AB PSIA 3R 3.3.2.9_ Instrument NeeeeW L(Q3.3-55l ~iipen ~
se-45
- c. SafetyInjection Refer to Function 1 (Safety Injection) for all initiation functions and requirements.
(continued) (a) ";.';.;c '; t t . %'t ;r..i; i-f.-...;ti; .; my _...;in :nly l;.;;th '.';h; d;e...dt;; ;7 0;te;i". St.di xt t .h ;, . xd by th; ='t The._ Allowable Value defires _the_ Limiting Safety System Setting.,See the.BasesJ gtitheJ tip_' W ints. F3?3E0Bi$ (9 Ext:ept when all MFIVs.are closed. ._ r . - w or f ( t lQs.3-6 WCGS-hfark-up ofNUREG-1431 - ITS 3.3 3.3 40 5/15/97
1 L 1 I ESFAS Instrumentation 3.3.2 ; i k Table 3.3.21 (page 10 of 11) i Engineered Safety Feature Actuation System Instnmentation , i APPLICABLE MODES OR ODER SPECIFIED REQUIRED SL8tVEILLANCE ALIGMBLE ilEP FUNCTICBI COICITIONS OW9ELS CX80!TIONS REQUIRDOfTS VALUE" EEN10Df?' )
- 6. /eaxiliary Fenester 'jy '
(continued) < rw-
- h i.d.";" M Z,n\he {+)-Per i O .2.2.9 i l003t i ; t-f9958 l j Geolent-Pep hoe O .2.2.0 vehege tue
= :.:.2.: vowooe c~ '
loa.sel 5 3 -880-
- g. Trip of all Main 1 2 per J SR 3.3.2.8 i ; 3 p;; - . ;p i Feedleter Pumps pup 2 2.2.2.0 5 43 __ _
Z .2.2.;; E j {
- h. Auxiliary Feedwater 1.2.3 fe} 3 FM SR 3.3.2.1 x' R E Jgia iIrWE Pump Suction Transfer L TW'"'g8 l
- ER-4+44 w-(GS 4&} ~ ~
on Suction Pressure .
~ SR 3.3.2.9 fre4ei . .
)
- Law SR 3.3.2.12 {pete} .. . ,3
- 7. Automatic Switchover '
to Contairuemt Sep l
- a. Automatic Actuation 1.2.3.4 2 trains C SR 3.3.2.2 NA E
- Logic and Actuation SR 3.3.2.4
- Relays SR 3.3.2. ,.^
f ' @R 3.3.1.13) [433*b ' _ N.J v
- b. Refueling Water 1.2.3.4 4 K SR 3.3.2.1 sN.J{ E t@ gg i Storage Tart (IndST) SR 3.3.2.5 ;d . ; 3t e-t-}
Level . Law Lev SR 3.3.2.9 and _- gia sm-los.3.ss I s-t-} [s.3-sp i Coincident with Refer to Function 1 (Safety Injection) for all initiation SafetyInjection functions and requirements. g 4*p
, $3.34 &E(
}WC3SEM - h N fr the. Tripse%. ("'"ti"W'd)
- ~ __ __ -
k vu , , h s , wh . h A 'h'"b
--~~.. -= '
~ a " himT-
'F'
- r' s'' ' ' ' ' -
~ ^4 ' t; ". sit M ^^
_ _ _ i t _- ~2----
-:^7 IQ3.3-89 l ps. sri WCGS-Mark-aqp ofNUJtEG-H31 -ITS 3.3 3.3 43 5fl537
i l ,i ' ESFAS Instrumentation B 3.3.2 i BASES i SURVEILLANCE SR 3.3.2.5 REQUIREMENTS (continued) Sr 3.3.2.5 is the performance of a COT. l i A COT is performed on each required channel to ensure the ent+ce i channel will perform the intended Function. Setpoints must be i found within the Allowable Values specified in Table 0.0.11. 332T1 l l TM differe..;; kt~::;n th ;;rrent "n f;;nd" vs.in; ;nd tt.; } F;;is; t;;t 'n 1;ft" ;;in; =;t k nrai;t;nt witt, tk drift
- ;11
- xra; a:--:d in tk ntpint nical;tien. The setpoint shall j be left set consistent with the assumptions of the current unit specific setpoint methodology.
TM *n f;;nd" 7.nd "n 1;ft" vel; n = ;t ;1;; k r;; erd;d ;..d r;;i:nd fer cerai;t;re3 .;itt, tk n:-- ;-tiene of tk nr;;ill;a;; int:r ni st;raien :nly;i; 0;f. 0 0; kn ;,,,,li ntic. The Frequency of 92 days is justified in Reference 6 7. SR 3.3.2.6 SR 3.3.2.6 is the performance of a SLAVE RELAY TEST. The SLAVE , RELAY TEST is the energizing of the slave relays. Contact I operation is verified in one of two ways. Actuation equipment that may be operated in the design mitigation MODE is either allowed to function, or is placed in a condition where the relay contact operation can be verified without operation of the j equipment. Actuation equipment that may not be operated in the ! design mitigation MODE is prevented from operation by the SLAVE ' RELAY M]ESF circuit. For this latter case, contact operation is verified by a continuity check of the circuit g aining the slave relay. This test is performed every _ $33-N Y N-
\Q M D*'\ -
2M : M . .M -.Th
- . _ _ _._ Alessi .?taisel____
_ ' Mi'i_ _ _ _ _ _ E _.25 ../ l ele JDesi a El _2thei , _tn 1
/
tassociaeW9fthe n' 1 - ? _
- trial .ano1E ince~that (continued)
WCGS-Mark-}}