ML20198D408

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Proposed Tech Specs,Modifying Neutron Flux Requirements to Allow Use of Alternate Detectors
ML20198D408
Person / Time
Site: Beaver Valley
Issue date: 12/19/1997
From:
DUQUESNE LIGHT CO.
To:
Shared Package
ML20198D397 List:
References
NUDOCS 9801080209
Download: ML20198D408 (41)


Text

_ _ _ .

l ATTACHMENT A-1 Beaver Valley Power Station, Unit No. 1 Proposed Technical Specification Change No. 218

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The following is a list of the affected pages:

Affected Pages: 3/4 3-2 3/4 3-6 3/4 3-11 3/4 3-13 B 3/4 3-lb l

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9801090209 971219 PDR ADOCK 05000334 P PDR

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TABLE 3.3-1 DPR-66 _

REACTOR TRIP SYSTDI INSTRUMENTATION -

MINIMUM TOTAL NO. CHANNELS CHANNELS APPLICABLE FUNCTIONAL UNIT OF CHANNELS TO TRIP. OPERABLE MODES ACTION 1.- Manual Reactor Trip 2 1 2 - l ', 2, . 3'38, 12 4(3) and 5U8

2. Power Range, Neutron Flux
a. High Setpoint 4 2 3 1, 2 2 b.. Low Setpoint 4 2 3 l'88, 2 2
3. Power Range, Neutron Flux 4 2 3 1, 2 2 High Positive Rate
4. Power Range, Neutron Flux 4 2 3 1, 2 2 l

liigh Negative Rate S. Intermediate Range, Neutron 2 1 2 1888, 2, 3'88, 3 Flux (g.3landpf-y)erAlft aft (Al-33 anul Al-34) 4 8,and 5'

6. . Source Rangd Neutron Flux 10'

'"cle.;

W.y I'a t k:stn et capaitay 2

a. C crr- 1 2 2:2> , 3c2> , 4 I dif Nil Rob Fib /ly ruserN
  • 4 8 and 5'"

a.kJ dd WHf dar~of Cop &ill 1 4, and 5 5

b. 4heedown- 2 0 3,
7. Overtemperature AT 3 2 2 1, 2 7-I
8. Overpower 6T 3 2 2 1, 2 7 l
9. Pressurizer Pressure-Low 3 2 2 1, 2 7 (Above P-7)

N.

BEAVER VALLEY - UNIT 1 3/4 3-2 .

Amendment No. M (frejVK$ 0lot ')

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TABLE 3 . 3 -1 (continued)

ACTION:3l With the number of channels OPERABLE one less than required by - the' Minimum- Caannels OPERABLE requirement-and with the THERMAL POWER lov 1:

"a.

Below P-6, restore the inoperable ' channel to OPERABLE status prior to . increasing. THERMAL POWER above the P-6 setpoint.-

b. Above P-6 but below 5 percent of RATED THERMAL POWER, restore the-inoperable channel.to OPERABLE status. prior to increasing THERMAL POWER above 5' percent of RATED TFERNAL POWER.
c. Above 5 percent of. RATED THERMAL POWER,-POWER OPERATICN

+ may continue.

ACTION 4 - With - the number of channels OPERABLE one less . than required by the Minimum Channels OPERABLE requirement i/ and with the THERMAL POWER level:

a. Below P-6, restore the inoperable channal to OPERABLE t status prior to increasing THERMAL POWER ' above the P-6 setpoint.
b. Above P-6,-operation may continue.

ACTION 5 - 'With the number of channels OPERABLE one less than required by the Minimum Channels OPERABLE requirement, verify compliance with.thw SHUTDOWN MARGIN requirements ,

of Specification 3.1.1.1 or specification 3.1.1.2, as applicable within 1 hour1.157407e-5 days <br />2.777778e-4 hours <br />1.653439e-6 weeks <br />3.805e-7 months <br />, and at least once per 12 hours1.388889e-4 days <br />0.00333 hours <br />1.984127e-5 weeks <br />4.566e-6 months <br /> thereafter, and verify valves (1CH-90) or-(1CH-91 and 1CH-93) are closed and- secured in - position within the next hour.

2 ACTION 6 - Not applicable.

ACTION 7 - With the number of OPERABLE channelsW one less than the - Total Number of Channels, STARTUP and/or POWER OPERATION may proceed provided the following conditions are satisfied:

l a. The inoperable channel is placed in the tripped condition within 6 hours6.944444e-5 days <br />0.00167 hours <br />9.920635e-6 weeks <br />2.283e-6 months <br />, and

b. The Minimum Channels OPERABLE requirement is met;

! -however,.the inoperable channel may be bypassed for up to 4 hours4.62963e-5 days <br />0.00111 hours <br />6.613757e-6 weeks <br />1.522e-6 months <br /> for surveillance testing of other channala l per specification 4.3.1.1.1.

(6)_An OPERABLE hot leg channel consists of
1) three RTDs per hot l ' leg,for 2) .- two RTDs per hot leg with the failed RTD disconnected and the: required bias applied.

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BEAVER VALLEY - UNIT 1 3/4 3-6 Amendment No.
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ACTION 4 - a. MODE 2 (Below P-6); with one source range neutron flux ,

channel inoperable, immediately suspend- operations I involving positive reactivity additions.

b. MODE 3, 4 and 5; with one source range neutron flux  ;

channel inoperable, restore the inoperable channel to ,

OPERABLE status within 48 hours5.555556e-4 days <br />0.0133 hours <br />7.936508e-5 weeks <br />1.8264e-5 months <br /> or open the reactor trip ' 'l breakers within the next hour.

c. MODE 2 (Below P-6), 3, 4 and 5; with two source range neutron flux channels inoperable, immediately open the i reactor trip breakers.

ACTION 5 - With the number of OPERABLE channels one less than the Minimum Channels OPERABLE requirement:

a. Suspend o erations involving positive reactivity additions,(p) and
b. Close unborated water source isolation valve (s) (1CH-90) or (1CH-91 and 1CH-93) within 1 hour1.157407e-5 days <br />2.777778e-4 hours <br />1.653439e-6 weeks <br />3.805e-7 months <br />, and
c. Perform Surveillance Requirement 4.1.1.1.1 or 4.1.1.2, as applicable, within the- next hour and at least once per 12 hours1.388889e-4 days <br />0.00333 hours <br />1.984127e-5 weeks <br />4.566e-6 months <br /> thereafter.

(7) Plant cooldown is allowable provided the temperature change is accounted for in the calculated shutdown margin.

BEAVER VALLEY - UNIT 1 Page 1 of 1 (Proposed Wording)

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F TABLE 4. 3-1 DPR-66 . . .

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! M CTOR TRIP SYSTEM INSTRUMENTATION SURVEILLANCE REOUIREMENTS Channel Modes in Which Channel Channel Ft.nctional Surveillance Functional Unit Check Calibrat19D Test Reauired

1. Manual Reactor Trip H.A. N.A. S/U'88, N.A.

R'888

2. Power Range, Neutron Flux
a. High Setpoint S Dc2 3, M 8 Q 1, 2 l and Q8
b. Low Setpoint S N.A. S/ U'
  • 8 2
3. Power Range, Neut'ron Flux, N.A. R Q 1, 2 High Positive Rate
4. Power Range, Neutron Flux, N.A. R Q 1, 2 liigh Negative Rate S. Intermediate Range, S N.A. S/U8 1 2, 3'8,

fAl. a 0{ hl-3 W Al$t!*tt AI~3I * $~3'I Source Rangei Neutron Flux 4 W s- -NvA,k S / "' " , 2, '& 4I# }

6.

m_, _ - - ..

  • ce>

3,N "d S XMKhl uR%aal tapeWis'ly i 4 "Overtemperature AT <--S R Q 1, 2

8. Overpower AT S R Q 1, 2
9. Pressurizer Pressure-Low S R Q 1, 2
10. Pressurizer Pressure-High S R Q 1, 2
11. Pressurizer Water S R Q 1, 2 Level-High T k 3, Y a f b iE.h All f)s fGlly est/?fYe '

S nki tal W. Ad eal(opL,ljy _

isEAV Lit VALLEY - UNIT 1 3/4 3-11 Amendment No. 4t++-

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.* s' DPR-66 TABLE 4.3-1 (Continue 11, NOTATION (1) -

If not performed in previous 31 days.

(2) -

Heat balance only, acove 15 percent of RATED THERMAL POWER.

(3) -

At least once every 31 Effective Full Power Days (ETPD) }

compare incere to excore axial imbalance above 15 percent of RATED THERMAL POWER. Recalibrate if absolute difference greater than or equal to 3 percent.

(4) -

(NotkJsed)

(5) -

Each train tested every other month.

(6) -

Neutron detectors may be excluded from CHANNEL CALIBRATION.

(7) -

Below P-10.

(8) -

Below Pj.

/(9) -

(Not Used)

(10) -

The CHANNEL FUNCTIONAL TEST shall independently verify,the OPERABILITY of the undervoltage and shunt trip circuits for the Manual Reactor Trip runction. The test shall also verify the OPERABILITY of the Bypass Breaker trip circuit (s).

(11) -

The CHANNEL Ft'HC.*FIONAL TEST shall independently verify the OPERABILITY of the undervoltage and shunt trip attachments of the Reactor Trip Breakers.

(12) -

Local manual shunt trip prior to placing breaker in service.

(13) -

Automatic undervoltage trip.

(14) -

With the reactor trip system breakers closed and the control rod drive system capable of rod withdrawal.

(i n - Su,willann de c/ehchts wdi$unred i.'e , re c}ed' a d qbt need' nd bel% CMMn /Nar-feawa/csa/h,

,not >4f vo M/ k be est}t/o'*y 00bf 3140D6 &pt&tm/

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J BEAVER VALLEY - UNIT 1 3/4 3-13 Amendment No.

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_ ____ m_ _ _ _ . _ _ _ _ _ - - _ ________ _ _____

. . DPR-66 INSTRUMENTATION BASES 3/4.3.1 and 3/4.3.2 PLOTECTIVE AND ENGINEERED SAFETY FEATURES (ESF)

INSTRUMENTATION (Continued)

Below the setpoint P-11 allows the manual-block of safety injection actuation on low pressurizer pressure, allows manual block of safety injection and steamline isolation on low steamline pressure (with Loop Stop Valves Open) and enabling steamline isolation on high steam pressure rate, automatically disables auto actuation of the pressurizer PORVs unless the Reactor Vessel Over Pressure Protection System is in service.

P-12 Above the setpoint P-12 automatically reinstates an arming signal to the steam dump system. Below the setpoint P-12 blocks steam dump and allows manual bypass of the steam dump block to cooldown condenser dump valves.

Table 3 3-1 Action 2 has been modified by two notes. Note ,(4) allows placing the inoperable channel in the bypass condition for up to 4 hours4.62963e-5 days <br />0.00111 hours <br />6.613757e-6 weeks <br />1.522e-6 months <br /> while performing: a) routine surveillance testing of f other channels, and b) setpoint adjustments of other channels when required to reduce the setpoint in accordance with other technical specifications. The 4 hour4.62963e-5 days <br />0.00111 hours <br />6.613757e-6 weeks <br />1.522e-6 months <br /> time limit is justified in accordance with WCAP-10271-P-A, Supplement 2, Revision 1, June 1990. Note (5) only requires SR 4.2.4 to be performed if a Power Range High Neutron Flux channel input to QPTR becomes inoperable. Failure of a component in the Power Range High Neutron Flux channel which renders the High Neutron Flux trip function inoperable may not affect the

c. pability to monitor QPTR. As such, determining QPTR using the movable incore detectors oncu per 12 hours1.388889e-4 days <br />0.00333 hours <br />1.984127e-5 weeks <br />4.566e-6 months <br /> may not be necessary.

t' I$E~kY -

3 BEAVER VALLEY - UNIT 1 B 3/4 3-lb Amendment No. 44+-

LUCsYb (Yo*Cf05ti l

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INSERT 2 Source Ranae Neutron Flux The limithg condition for operation ( ' '.')) requirement for the source range neut ron flux trip fun: tion ensures that protection is provided against an uncontrolled rod cluster control assembly (RCCA) bank rod withdrawal accident from a subcritical condition during startup with the reactor trip breakers (RTOs) closed. This trip function provides redundant protection to the Pover Range Neutron Flux-Low Setpoint and Intermediate Range Neutron Flux i. rip functions (See UFSAR Section 14.1.1 and Specification 2.2.1 Bases). In MODES 3, 4, and 5, with the RTBs closed, administrative controls also prevent the uncontrolled withdrawal of rods. The nuclear instrumentation system (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 reactor trip system (RTS) automatic protection function required in MODES 3, 4, and 5. Therefore, the functional capability at the specified trip setpoint is assumed to be available.

The LCO requires two channels of source range neutron flux to be OPERABLE when the RTBs are closed. Two OPERABLE channels are sufficient to ensure 1.o single random failure will disable this trip function. The LCO also requires one channel of the source range neutron flux to be OPERABLE in MODE 3, 4, or 5 with RTBs open. In this case, the source range function is to provide control room indication and the high flux at shutdown alarm. The outputs of the function to RTS logic are not required OPERABLE when the RTBs are open.

The source range neutron flux function provides protection for control rod withdrawal from subcritical, boron dilution and control rod ejection events. The function also provides visual neutron flux indication in the control room.

In MODE 2 when below the P-6 setpoint aaring a reactor startup, the source range neutron fha trip must be OPERABLE. Above the P-6 setpoint, the Intermediate Range Neutron Flux trip and Power Range Neutron Flux-Low Setpoint trip will provide core protection for reactivity accidents. Above the P-6 setpoint, the NIS source range detectors are de-energized and not functional.

In MODE 3, 4, or 5 with the reactor shut down and with the control rod drive (CRD) system capable of rod withdrawal, the source range neutron flux trip function must also be OPERABLE. If the CRD system is not capable of rod witndrawal, the source range 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 as a result of events like a boron dilution.

BEAVER VALLEY - UNIT 1 Page 1 of 5 (Proposed Wording)

INSERT 2 Suitable detectors (N-33 and N-34) used in place of primary source range 7 neutron flux monitors N-31 and N-32 are recognized as alternate detectors. Alternate detectors may be used in place of primary source range neutron flux monitors as long as the -required netttron flux indication, high flux at shutdown. alarm, and source range high neutron flux trip functions are provided.

ACTION 4 Item (a) applies to one inoperable source range neutron flux trip channel WMn in MODE 2, below the P-6 setpoint, and performing a i reactor. startup. With the unit in this condition, below P-6, the NIS source range performs the monitoring and protection functions. With one of the two channels inoperable, operations involving positive reactivity additions shall be suspended immediately.

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.

Item (b) applies to one inoperable source range neutron flux trip channel when in MODE 3, 4, or 5, with the RTBs closed and the CRD system capable of rod withdrawal. With the unit in this condition, the NIS source range performs the monitoring and protection functions. With one of the source range channels inoperable, 48 hours5.555556e-4 days <br />0.0133 hours <br />7.936508e-5 weeks <br />1.8264e-5 months <br /> is allowed to restore'it to OPERABLE status. If the channel cannot be returned to an OPERABLE status, 1 additional hour is allowed to open the RTBs. Once the RTBs are open, rod withdrawal is not possible and the uni' enters ACTION 5. The allowance of 48 hours5.555556e-4 days <br />0.0133 hours <br />7.936508e-5 weeks <br />1.8264e-5 months <br /> to restore the channel to OPERABLE status, and the additional hour to open the RTBs, are justified in WCAP-10271-P-A, Supplement 2, Rev. 1, June 1S90.

Item (c) 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 the RTBs closed and the CRD system capable of rod withdrawal. With the 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

. opened immediately. With the RTBs open, rod withdrawal is not possible and the unit enters ACTION 5.

BEAVER VALLEY - UNIT 1 Page 2 of 5 (Proposed Wording)

fNSERT 2 bCTION 5 This ACTION applies when the required number of OPERABLE source range neutron flux channels is not met in MODE 3, 4, or 5 with the RTBs open.

With the unit in this condition, the NIS source range performs the monitoring function. With less than the required number of source range channels OPERABLE, operations involving positive reactivity additions shall be suspended immediately. This will preclude any power escalation. However, a note applicable to this ACTION allows plant cooldown as long as the shutdown margin is adequate to account for the positive reactivity addition resulting from the temperature change.

This ensures the core is controlled and the shutdown margin requirements are satisfied for all applicable events. In addition to suspension of positive reactivity additions, the valve (s) that controls the addition of unborated water to the RCS must be closed within i hour. The isolation of unborated water sources will preclude a boron dilution accident.

Also, the shutdown margin (SDM) must be verified within 1 hour1.157407e-5 days <br />2.777778e-4 hours <br />1.653439e-6 weeks <br />3.805e-7 months <br /> and once every 12 hours1.388889e-4 days <br />0.00333 hours <br />1.984127e-5 weeks <br />4.566e-6 months <br /> thereafter as per SR 4.1.1.1.1 or 4.1.1.2, SDM verification. With no source range channels OPERABLE, core protection is severely reduced. Verifying the SDM within 1 hour1.157407e-5 days <br />2.777778e-4 hours <br />1.653439e-6 weeks <br />3.805e-7 months <br /> allows sufficient time to perform the calculations and determine that the SDM requirements are met. The SDM must also be verified once per 12 hours1.388889e-4 days <br />0.00333 hours <br />1.984127e-5 weeks <br />4.566e-6 months <br /> thereafter to ensure that the core reactivity has not changed. Item (a) precludes any positive reactivity additions; therefore, core reactivity should not be increasing, and a 12 hour1.388889e-4 days <br />0.00333 hours <br />1.984127e-5 weeks <br />4.566e-6 months <br /> frequency is adequate. This does not include xenon decay which is accounted for in the shutdown margin surveillance. The completion times of within 1 hour1.157407e-5 days <br />2.777778e-4 hours <br />1.653439e-6 weeks <br />3.805e-7 months <br /> and once per 12 hours1.388889e-4 days <br />0.00333 hours <br />1.984127e-5 weeks <br />4.566e-6 months <br /> are based on operating experience in performing the ACTIONS and the knowledge that unit conditions will change slowly.

SOURCE RANGF NEUTRON FLUX SURVEILLANCE REOUIREMENTS (SR)

IF sNEL CHECK The alternate source range detectors are modified by a note to indicate they are not subject to the source range detector surveillance requirements until they have been connected to the applicable circuits an: are required to be OPERABLE. This complies with the testing requirements for components that are required to be OPERABLE.

Performance of the CHANNEL CHECK once every 12 hours1.388889e-4 days <br />0.00333 hours <br />1.984127e-5 weeks <br />4.566e-6 months <br /> ensures that gross failure of instrumentation has not occurred. A CHANNEL CHECK is a comparison of the parameter indicated on one channel to a similar parameter on other channels. It is based on the assumption that BEAVER VALLEY - UNIT 1 Page 3 of 5 (Proposed Wording) l

,  ?. ' ,

INSERT 2 instrument. ' channels- monitoring the same_ parameter. should- read-approximately the _same : value._ significant deviations :between the two

instrument -' channels ' could : be an : indication: of excessive . . instrument drift in one of-the. channels or of - something even more serious. A

' CHANNEL CHECK for a single channel involves a qualitative assessment of the channel indication to verify the) channel is operating in the J appronimate ? range - for the - expected plant conditions.- A : CHANNEL CHECK will-detect gross channel failure; thus, it: is key to verifying that-sthe-instrumentation continues-to operate-properly;between.each CHANNEL CALIBRATION.

Agreement critaria- are -det.armined -by the unit staff- based on a combination of- the channel instrument uncertainties,- including indication and readability. If a channel- is outside the match

-criteria, it. may =be. an indication that - the. sensor ; or the . signal

_ processing. equipment aas drifted outside its limit.

._The- frequency- is based on operating experience that- demonstrates

-channel failure is _ rare. Thus, performance of - the CHANNEL CHECK ensures ^that undetected overt channel f ailure is -limited to 12 hours1.388889e-4 days <br />0.00333 hours <br />1.984127e-5 weeks <br />4.566e-6 months <br />.

-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.

When the control rods are fully inserted and are not capable of withdrawal, inadvertent control rod withdrawal is not a concern and one source range detector can adequately-monitor the core.

CHANNEL FUNCTIONAL TEST The alternate source range detectors are modified by a note _to indicate

-they are not subject- to the source range detector- ' surveillance requirements until they have been. connected to the applicable circuits and -are required to - be OPERABLE.- This complies with the testing requirements for components that are required to be OPERABLE.

A CHANNEL FUNCTIONAL TEST is performed on each required channel every 92- days _to ensure the entire _ channel will perform the intended function. Setpoints must be within the Allowable 7alues. The frequency of 92 days is justified in WCAP-10271-P-A, Supplement 2, Rev. 1,_ June 1990.

This- surveillance is modified by a Note that -_ specifies testing' when -

below P-6 and is clarified to address the transition from MODE 2 to MODE 3. . A transition into MOE 3-with the. reactor trip breakers closed

.is'often made for a short period of time during plant shutdown. _During a - normal shutdown, the - reactor trip breakers are opened. shortly af ter entering MODE 3. The transition time _in MODE 3 from when the. reactor d

trip breakers are closed to when_they are opened is less than the time required to perform the CHANNEL FUNCTIONAL TEST prior to entering MODE 3. Therefore, =an allowance to enter MODE 3 without first performing the source range-CHANNEL FUNCTIONAL TEST is warranted.

BEAVER VALLEY - UNIT 1 Page 4 of 5 (Proposed Wording)

+

INSERT 2 CHANNEL CALIBRATION The alternate source range detectors are modified by a note to indicate they are not subject to the source range detector surveillance requirements until they have been connected to the applicable circuits and are required to be OPERABLE. This complies with the testing requirements for components that are required to be OPERABLE.

A CHANNEL CALIBRATION is performed every 18 months, or approximately at every refueling. The CHANNEL CALIBRATION for the source range neutron detectors consists of obtaining the detector plateau and preamp discriminator curves, evaluating those curves, and establishing detector operating conditions as directed by the detector manufacturer.

The 18 month frequency is based on the need to perform this surveillance under the- conditions that apply during a - plant outage -

since performance at power is not possible. The protection and monitoring functions are also calibrated at an 18 month frequency as is normal for reactor protection instrument channels. Operating experience has shown these components usually pass the surveillance when performed on the 18 month frequency.

BEAVER VALLEY - UNIT 1 Page 5 of 5 (Proposed Wording)

l ATTACHMENT A-2 1

l Beaver Valley Power Station, Unit No. 2 Proposed Technical Specification Change No. 85 The following is a list of the affected pages:

Affected Pages: 3/4 3-2 3/4 3-6 3/4 3-10 3/4 3-13 B 3/4 3-3 1

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TABLE 3.3-1 NPF-73: .

REACTOR TRIP SYSTEM INSTRUMENTATION MIN 1 MUM TOTAL NO. CHANNELS CHANNELS APPLICABLE TO TRIP OPERABLE MODES ACTION OF CHANNELS FUNCTIONAL UNIT 1 2 1 2, 3'", 12 4 l'8 and 1; Manual Reactor Trip. 2 5

e

2. Power Range, Neutron Flux 2 3 1,'2 2
a. High Setpoint 4 3 l, 2 2 Low Setpcint 4 2.

b.

3 1, 2 2

Power Range, Neutron' Flux '4 2 '

3.

11igh ' Positive Rate 2 3 1, ' 2 2

4. l'ower Range, Neutron Flux 4 liigh.Hegative Rate +

1 2 l,.2, 3 '" , 3 5 ~. Intermediate. Range, Neutron 2 4' and 5

()ldl oYAI-3.2) o*' lll]&% ale (.d-E2t) oos) N- &~2 L G.. Source Rangei Neutron' Flux

'"'i 3 2JTa%,r,aat csy );,My 2 1 2 2gl,3>, ,,,

4

"'u'8if/M/s na r,seWo.</

ad [cyd.7,'h +0 1 3, 4, and 5 5'

b. a'e&.. k [ed 10.$s...

2 2 1, 2' 7 3 2

7. Overteunperature AT '

2 1, 2 7 3 2

8. Overpower AT 2 2 1, 2 _7 Pressurizer: Pressure-Low 3 l 9.

(Above P-7) 7-2 2 1, 2 Pressurizer Pressure-liigh 3 10.

y ) y4g,y,4g j jy jy g, pa ),, ,

( D, .afl..y

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Amendment 13EAVEli VALLEY - UNIT 2 3/4 3-2 (fkfi* irk s h N

..NPF-73 j ,' TABLE 3'.3-1 (Centinued)

ACTION 3= -

With the number of - channels OPERABLE one less than required . by the Miniaum Channels OPERABLE _ requirement and with the THERMAL POWER level a- Below' P-6,. restore the- inoperable- channel to

' OPERABLE. status prior to increasing THERMAL POWER above the P-6 setpoint.

b. Above P-6 but below'5 percent . of RATED THERMAL POWER, restore the inoper3ble channel to OPERABLE status prior to increasing. THERMAL POWER above 5 percent of RATED THERMAL' POWER.

7A'$6-ft T / 3 1

c. Above 5 percent of RATED . THERMAL POWER, OPERATION may-continue.

POWER ACTION 4 - .With the number of channels OPERABLE - one less than required by the Minimum Channels OPERABLE requirement and with the THERMAL POWER level:

a. Below -P-6, restore the inoperable channel to OPERABLE status-prior to increasing THERMAL POWER above the P-6 setpoint and suspend positive reactivity oparations.
b. Above P-6, operation may continue.

ACTION 5 - With the number of OPERABLE channels one less than the Minimum Channels OPERABLE requirement, restore the inoperable channel to OPERABLE status within 48 hours5.555556e-4 days <br />0.0133 hours <br />7.936508e-5 weeks <br />1.8264e-5 months <br /> or open the Reactor Trip System breakers, suspend all l operations involving positive reactivity changes and verify valves (2CHS-91, 2CHS-96 and 2CHS-138) l 37 and 2CHS-828) are closed and secured in position within the next hour.

or(2CHS-) -

ACTION 6 - This Action is not used..

ACTION 7 - With the number of OPERABLE channelsI 'I one less than the Total Number of Channels, STARTUP and/or POWER

OPERATION may proceed provided the following conditions i are satisfied

1 a.- The inoperable channel is placed in the tripped condition within 6 hours6.944444e-5 days <br />0.00167 hours <br />9.920635e-6 weeks <br />2.283e-6 months <br />, and l b. The Minimum Channels OPERABLE requirement is met; however, the inoperable channel may be bypassed for up to 4 hours4.62963e-5 days <br />0.00111 hours <br />6.613757e-6 weeks <br />1.522e-6 months <br /> for surveillance testing of other channels per Specification 4.3.1.1.1.

l-(6) An OPERABLE hot leg channel consists of:

1) three RTDs per hot j leg, or 2) two RTDs per hot leg with the failed RTD disconnected and the required bias applied.

l

' BEAVER VALLEY - UNIT 2 3/4 3-6 .

Amendment NO. ~

(ftofesnlLLhk!*t

  • ' l l'NBLRT 1 i

ACTION 4 - a. MODE 2 (Below P-6); with one source range neutron flux channel inoperable, immediately suspend operations t involving positive reactivity additions. >

b. MODE 3, 4 and 5; with one source range neutron flux channel inoperable, restore the inoperable channel to OPERABLE status within 48 hours5.555556e-4 days <br />0.0133 hours <br />7.936508e-5 weeks <br />1.8264e-5 months <br /> or open the reactor trip breakers within the next hour.
c. MODE 2 (Below P-6) , 3, 4 aind 5; with two source r3nge neutron flux channels inoperable, immediately open the ,

reactor trip breakers.

ACTION 5 - With the number of OPERABLE channels one less than the Minimum Channels OPERABLE requirement '

a. Suspend o involving positive reactivity additions,Igerations I and -
b. Close unborated water source isolation valves (2CHS-91, 2CHS-96 and 2CHC-138) or ( 2 CHS-3 *, and 2CHS-828) within i hour, and
c. Perform Surveillance Requirement 4.1.1.1.1 or 4.1.1.2, as applicable, within the next hour and at least once per 12 hours1.388889e-4 days <br />0.00333 hours <br />1.984127e-5 weeks <br />4.566e-6 months <br /> thereafter.

(7) Plant cooldown is allowable provided the tahrerature change is .

accounted for in the calculated shutdown margin.

BEAVF.R. VALLEY . UNIT 2 Page 1 of 1 (Proposed Wording)

TABLE 4.3-1 ypp_73 ,

REACTOR TRIP SYSTEM INSTRUMENTATION SURVEIT f>JfCE REQUIREMENTS Channel Modes in which Channel Channel Functional Surveillance Functiona1 Unit Check Ca1ibratio'n Test Recuired

1. PEanual Reactor' Trip N. A. . M.A. 1, 2, 3*8, S[3Usas, R 4 ", S''
2. Power Range, Neutron Flux
a. High Setpoint S D,M!'8 Q 1, 2 l ,

4 and Q

b. Low Setpoint S R S/ U' *
  • l"', 2
3. Power Range, Neutron Flux, N.A. R Q 1, 2 Iligh Positive Rate
4. Power Range, Neutron Flux, N.A. R Q 1, 2 liigh Negative Rate S. Intermediate Range, Neutron S R S/U'" 1 2, 3',

Flux g y l g_g ,,, pj}g,.j('SQ g;j m/ ,f.gM) I 4 , S "' '

G. Scurce Ranged, Meutron Flux S R Si.'"f, " , 2, 3 4

,,,,<~>

a'.5(NC).N!lmearI(stabs lY7 Overtemperatura AT S R Q 1, 2

0. Overpower AT S R Q 1, 2 l 9. Pressurizer Pressure-Low S R Q 1, 2.

(Above P-7)  :

10. Pressurizer Pressure-High S R Q 1, 2
11. Pressurizer Water Level-High S R 2 Q 1, s (Above P-7) .
l. $ik Al' Alch Qly E>c.Ya yl S $ 3, 9 <r- ) V

, 6 J &.I ; tL. /.i. ,1 f.y u h 1:1,  :

i i l

BEAVER VALLEY - UNIT 2 3/4 3-1 ' Amendment No. e (thy ~5til db t

  • NPT-73 TABLE 4.3-1 (Continued)

TADLE NOTATION (1) -

If not performed in previous 31 days.

(2) -

Heat balance only, above 15 percent of RATED THERMAL POWER.

(3) -

At least once every 31 Effective full Power Days (ETPD) l compare incore to excore axial imba100ce above 15 percent of RATED THERMAL POWER. Recalibrato if absolute difference i greater than or equal to 3 percent.

(4) -

(NotkJsed).

(5) -

Each train tested every other month on a STAGGERED TEST BASIS.

(6) -

Neutron detectors may be excluded free CHANNEL CALIBRATION.

(7) -

Below P-10.

(8) -

Below y (9) -

(dot Used)

(10) -

The CHANNEL FUNCTIONAL TEST shall independently verify the OPERABILITY of the undervoltage and shunt trip circuits for the Nanual Reactor Trip Function. The test shall also verify the OPC9Ah!LITY of the Bypass Breaker trip circuit (s).

(11) -

The CHAFNEL FUNCTIONAL TIST shall independently virify the OPERABILITY of the undervoltage and shunt trip attachments of the Reactor Trip Breakers.

(12) -

Local manual shunt trip prior to placing breaker in service.

(13) -

Automatic undervoltage trip.

(14) -

With the reactor trip sydten breakers closed and the control rod drive system capable of rod withdrawal.

(ts") - %eerillax e h u M A "cd nch *At od o!b.'A

b. he.hn anl4/ n asec Y a ncl t% dre t C/W6/t/ I"T r.

_- ---- o

,.to!~u us U ff be fehk he scuoct on Ja sktlvu merthbon get cr* lT p ,J t & }y o'te D & I [v o m 140lV k urh/ }.2 lfoues Oho er0%y, inh ITl s

BEAVER VALLEY - UNIT 2 3/4 /-13 Amendment No. "

(ftcpeseJ- W**'deh

  • NPF-73 3/4.3 IllSTRUME14TATI0ll BASES 3/4.3.1 and 3/4.3.2 REACTOR TRIP SYSTEM AlfD E11GIllEERED SAFETY FEATURES ACTUATIOli SYSTEM IllSTRUMEllTATIOli (Continued)

The Engineered safety Feature Actuation system interlocks perform the following functions:

P-4 Reactor tripped - Actuates turbine trip, closes main feedwater valvcs on Tm below setpoint, prevents the opening of the main feedwater valves which were closed by a safety injection or high steam generator water level signal, allows safety injection block so that components can be reset or tripped.

Reactor not tripped - prevents manual block of safety injection.

P-11 Above the setpoint, P-11 automatically reinstates safety injection actuation on low prensurizar prossure, automatically 'alocks steamline isolation on high steam pressure rate and enables safety injection und steamline isolation (with Loop stop Valve open) on low steamline pressure. Bolow the setpoint, P-11 allows the manual block of safety i'ajection actuation on low pressurizer pressure, allows manuti block of safety injection and steamline isolation (with Loop stop Valve open) on Low steamline pressure and enables steamline isolation on high steam prcasure rate.

P-12 Above the setpoint, P-12 automatically reinstates an arming signal to the steam dump system. Below the setpoint P-12 blocks steam dump and allows manual bypass of the steam dump block o cooldown condenser dump valves.

Table 3.3-1 Action 2 has been modified by two notes. Note (4) allows placing the inoperable channel in the bypass condition for up to i. hours while performing: a) routine surveillance testing of other channels, and b) setpoint ad;astments of other cha.1nels when required to reduce the setpoint in accordance with other technical specifications. The 4 hour4.62963e-5 days <br />0.00111 hours <br />6.613757e-6 weeks <br />1.522e-6 months <br /> time limit is justified in a:cordance with WCAP-10271-P-A, Supplement 2, Revision 1, June 1990. Note (5) only requires SR 4.2.4 to be performed if a Power Range High Neutron Flux channel input to QPTR becomes inoperable. Failure of a component in the Power Range High Neutron Flux channel which renders the High Neutron Flux trip function inoperable may not affect the capability to monitor QPTR. As such, determining QPTR using the movable incore detectors once per 12 hours1.388889e-4 days <br />0.00333 hours <br />1.984127e-5 weeks <br />4.566e-6 months <br /> may not be necessary.

=-~~;

XA/S M Y . ,2 BEAVER VALLEY - UNIT 2 B 3/4 3-3 Amendment No. D (f*tafesd (UcNt Ah

,. ,o INSERT 2 Eg1*yj.Rance Neutron Flux The limiting condition for o' eration (LCO) requirement for the source range neutron flux trip function ensures that protection is provided against an uncontrolled rod cluster control assembly (RCCA) bank rod withdrawal accident from a subcritical condition during s,artup e with the reactor trip breakers (RTBs) closed. This trip function provides redundant protection to the Power Range Neutron Flux-Low Setpoint and Intermediate Range Neutron Flux trip functions (see UFSAR Section 15.4.1 and Specification 2.2.1 Bases). In MODES 3, 4, and 5, with the RTBs closed, administrative ::ontrols also prevent the uncontrolled withdrawal of rods. The nuclear instrumentation systc9 (NIS) source range detectors are located external to the reactor ves al 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 reactor trip system (RTS) automatic protection function required in MODES 3, 4, and 5. Therefore, the functional capability at the specified trip setpoint is assuned to be available.

The LCO requires two channels of source range neutron flux to be OPERABLE when the RTBs are closed. Two OPERABLE channels are sufficient to ensure no single random failure will disable this trip function. The LCO also requires one channel of the source range neutron flux to be OPERABLE in MODE 3, 4, or 5 with RTBs open. In this case, the source range function is to provide control room indication and the high flux at shutdown alarm. The outputs of the function to RTS logic are not required OPERABLE when the RTBs are open.

The source range neutron flux function provides protection for control rod withdrawal from subcritical, boron dilution and control rod ejection events. The function also provides visual neutron flux indication in the control room. ,

In MODE 2 when below the P-6 setpoint during a reactor startup, the source range neutron flux trip must be OPERABLE. Above the P-6 setpoint, the Intermediate Range Neutron Flux trip and Power Range Neutron Flux-Low Setpoint trip will provide core protection for reactivity accidents. Above the P-6 setpoint, the NIS source range detectors are de-energized and not functional.

In MODE 3, 4, or 5 with the reactor shut down and with the control rod drive (CRD) system capable of rod withdrawal, the source range neutron flux trip function must also be OPERABLE. If the CRD system is not

- capable of rod withdrawal, the source range 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 as a result of events like a boron dilution.

BEAVER VALLEY - UNIT 2 Page 1 of 5 (Proposed Wording) 9

~ _ _ . - . . ~ _ _ - . - - ~

I'NSERT 1 Suitable detectors 'N-52A and H-52B) used in place of primary source range neutron flux monitors N-31 and N-32 are recogni::ed as alternate detectors. Alternate detectors may be used in place of primary source range neutron flux monitors as long as the required neutron flux indication, high flux at shutdown alarm, and source range high neutron flux trip functions are provided.

Note (8) limits the uso of alternate detectors (N-52 A and N-52B) to a monitoring function until a plant design change can provide the capability for directly connecting these detectors into the source range circuits so they can provide the required alarm al.d trip functions.

ACTION 4 Item (a) applies to one inoperable source range ne'atron flux trip channel when in MODE 2, below the P-6 setpoint, and performing a reactor startup. With the unit in this condition, below P-6, the NIS source range performs the monitoring and protection functions. With one of the two channels inoperable, operations involving positive react'.vity additions shall be suspended immediately.

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.

Item (b) applies to one inoperable source rango neutron flux trip channel when in MODE 3, 4, or 5, with the RTBs closed and the CRD system capable of rod withdrawal. With the unit in this condition, the NIS source range performs the monitoring and protection functions. With one of the sourco range channels inoperable, 48 hours5.555556e-4 days <br />0.0133 hours <br />7.936508e-5 weeks <br />1.8264e-5 months <br /> is allowed to restore it to OPERABLE status. If the channel canno?, be returned to an OPERABLE status, 1 additional hour is allowed to open the RTBs. Once the RTBs are open, rod withdrawal is not possible and the unit ontors ACTION 5. The allowanco of 48 hours5.555556e-4 days <br />0.0133 hours <br />7.936508e-5 weeks <br />1.8264e-5 months <br /> to restore the channel to OPERABLE status, and the additional hour to open the RTBs, are justified in WCAP-10271-P-A, Supplement 2, Rev. 1, June 1990.

Item (c) applies to two inoperablo sourco 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 the RTBs closed and the CRD system capablo of rod withdrawal. With the unit in this condition, below P-6, the NIS source rango performs the monitoring and protection functions. With both source range channels inoperable, the RTBs must be opened immediately. _ With the RTBs open, rod withdrawal is not possible and the unit enters ACTION 5.

BEAVER VALLEY + UNIT 2 Page 2 of 5 (Proposed Wording)

- o biSERT 2 ACTION 5 This ACTION applies when the required number of OPERAALE source range neutron flux channels is not met in MODE 3, 4, or 5 with the RTBs open.

With the unit in this condition, the NIS source range performs the monitoring function. With less than the required number of source range channels OPERABLE, operations involving positive reactivity additions shall be suspended immediately. This will preclude any power escalation. However, a note applicable to this ACTION allows plant cooldown as long as the shutdown margin is adequate to account for the positive reactivity addition resulting from the temperature change.

This ensures the core is controlled and the shutdown margin requirements are satisfied for all applicable events. In addition to suspension of positive reactivity additions, the valves that control the addition of unborated Nater to the RCS must be closed within 1 hour1.157407e-5 days <br />2.777778e-4 hours <br />1.653439e-6 weeks <br />3.805e-7 months <br />. The isolation of unborated water sources will proclude a boron dilution accident.

Also, tl'.e shutdown margin (SDM) must be verified within i hour and once every 12 hours1.388889e-4 days <br />0.00333 hours <br />1.984127e-5 weeks <br />4.566e-6 months <br /> thereafter as per SR 4.1.1.1.1 or 4.1.1.2, SDM verification. With nn sourca range channels OPERABLE, core protection is severely reduced. Verifying the SDM within 1 hour1.157407e-5 days <br />2.777778e-4 hours <br />1.653439e-6 weeks <br />3.805e-7 months <br /> allows sufficient time to perform the calculations and determine that the 'SDM requirements are met. The SDM must also be verified once per 12 hours1.388889e-4 days <br />0.00333 hours <br />1.984127e-5 weeks <br />4.566e-6 months <br /> thereafter to ensure that the core reactivity has not changed. Item (a) precludes any positive reactivity additions; therefore, core reactivity should not be increasing, and a 12 hour1.388889e-4 days <br />0.00333 hours <br />1.984127e-5 weeks <br />4.566e-6 months <br /> frequency is adequate. This does not include xenon decay which is accounted for in the shutdown margin surveillance. The completion times of within 1 hour1.157407e-5 days <br />2.777778e-4 hours <br />1.653439e-6 weeks <br />3.805e-7 months <br /> and once per 12 hours1.388889e-4 days <br />0.00333 hours <br />1.984127e-5 weeks <br />4.566e-6 months <br /> are based on operating experience in performing the ACTIONS and the knowledqe that unit conditions will change slowly.

SOURCE RANGE NEUTRON FLUX SURVEILLANCE REOUIREMEl4TS ( SR).

syANNEL CHECK The alternate source range detectors are modified by a note to indicate they are not subject to the source range detector surveillance requirements until they have been connected to the applicable circuits and are required to be OPERABLE. This complies with the testing requirements for components that are required to be OPERABLE.

Performance of the CHANNEL CHECK once every 12 hours1.388889e-4 days <br />0.00333 hours <br />1.984127e-5 weeks <br />4.566e-6 months <br /> ensures that gross failure c _: instrumentation has not occurred. A CHANNEL CHECK is a comparison of the parameter indicated on one channel to a similar parameter on other channels. It is based on the assumption that BEAVER VALLEY - UNIT 2 Page 3 of 5 (Proposed Wording)

INSERT 2 instrument channels monitoring the same parameter should read approximately the same value. Significant deviations between the two instrument channels could be an indication of excessive instrument drift in one of the channels or of something even more serious. A CHANNEL CHECK for a single channel involves a qualitative assessment of the channel indication to verify the channel is operating in the approximate range for the expected plant conditions. A CHANNEL CHECK will detect gross channel failure; thus, it is key to verifying that the instrumsntation continues to operate properly between each CHANNEL CALIBRATION.

Agreement criteria are determined by the unit staff based on a combination of the channel instrument uncertainties, including indication and readability. If a channel is outside the match criteria, it may be an indication that the sensor or the signal processing equipment has drifted outside its limit.

The frequency is based on operating experience that demonstrates channel failure is rare. Thus, performance of the CHANNEL CHECK ensures that undetected overt channel failure is limited to 12 hours1.388889e-4 days <br />0.00333 hours <br />1.984127e-5 weeks <br />4.566e-6 months <br />.

The CHANNEL CHECK supplements less tormal, but more frequent, checks of channels during normal operational use of the displays ansociated with the LCO required channels.

When the control rods are fully inserted and are not capable of withdrawal, inadvertent control rod withdrawal is not a concern and one source range detector can adequately monitor the core.

CHANNEL FUNCTIONAL TEST The alternate source range detectors are modified by a note to indicate they are not subject to the source range detector surveillance requirements unti) they have been connected to the applicable circuits and are required to be OPERABLE. This complies with the testing requirements for components that are required to be OPERABLE.

A CHANNEL FUNCTIONAL TEST is performed on each required channel every 92 days to ensure the entire channel will perform the intended function. Setpoints must be within the Allowable Values. The frequency of 92 days is justified in WCAP-10271-P-A, Supplement 2, Rev.

1, June 1990.

This surveillance is modified by a Note that specifies testing when below P-6 and is clarified to address the transition from MODE 2 to MODE 3. A transition into MODE 3 with the reactor trip breakers closed is often made for a short period of time during plant shutdown. During a normal shutdown, the reactor trip breakers are opened shortly after entering MODE 3. The transition time in MODE 3 from when the reactor .

trip breakers aro closed to when they are opened is less than the time required to parform the CHANNEL FUNCTIONAL TEST prior to entering MODE 3. Therefore, an allowance to enter MODE 3 without first performing the source range CHANNEL FUNCTIONAL TEST is warranted.

BEAVER VALLEY - UNIT 2 Page 4 of 5

' Proposed Wording)

INSERT 2 CilANNEL CALIBRATION The alternate sodrce range detectors ars modified by a note to indicate they are not subject to the source range detector surveillance requirements until they have been connected to the applicable circuits and are required to be OPERABLE. This complies with the testing requirements for components that are required to be OPERABLE.

A CHANNEL CALIBRATION is performed every 18 months, or approximately at 1 every refueling. The CHANNEL CALIBRATION for the source range neutron 1 detectors consists of obtaining the detector plateau and preamp discriminator curves, evaluating those curves, and establishing i detector operating conditions as directed by the detector manufacturer.  :

The 18 month frequency is based on the need to perform this surveillance under the conditions that apply during a plant outage since performance at power is - not possible. The protection and munitoring functions are also calibrated at an 18 month frequency as is 4 normal for reactor protection instrument channels. Operating experience has shown these components usually pass the surveillance when performed on the 18 month frequency.

BEAVER VALLEY - UNIT.2 Page 5 of 5 (Proposed Wording)

. e, . ..

ATTACHMENT B Beavor Valley Power Station, Unit Nos. 1 and 2 Proposed Technical Specification Change No. 218 and 85 REVISION OF SOURCE RANGE DETECTORS i- .

w l i

A. DESCRIPTION OF AMENDMENT REQUEST The proposed amendment would reviso the source range requirements in Mode 2 (Bolow P-6), 3, 4, and 5 to incorporate the guidance provided in NUREG-14 31 Improved Standard Technical Specificacions (ISTS), with some modifications to address plant specific design features. This change also incorporatos two important featuress (1) allows the use of alternate detectors as long as the required functions are provided, and (2) with inoperable detectors, the change allows plant cooldown as long as the shutdown margin accounts for the temperature change. In addition, for Unit 2 Table 3.3-1, the chango modifies the Channels To Trip and Minimum Channels Operable to 0 and 1, respectively, to be consistent with the Unit 1 and ISTS requirements. Table 4.3-1 has boon modified for both units to include items "a" and "b" as addressed in Table 3.3-1 and by including a note that exempts the alternate source range detectors from surveillance testing until they are required for operability.

B. BACKGROUND The proposed changos are requested to reduce the potential for enforcement discretions or emergency technical specification changes in the event source rango detectors become inoperable.

During the Unit 2 fourth refueling outage, Action 5 was ontored because source range detector N-31 was declared inoperable. The rnquirements of this action were complied with, then source ra . ige detector N-32 was testod to verify its operability. This detector was found operable, however, since two detectors were not operable as required by Table 3.3-1 Item 6.b, the potential existed for required entry into Specification 3.0.3 which requires a modo reduction with resulting plant cooldown. However, the required plant cooldown would involve a positive reactivity addition as a result of the RCS temperature reduction, which is contrary to the requirements of Action 5 that specifies no positive reactivity changes. Therefore, this change to the technical specification requirements was requested by the plant to eliminate the potential for a repeat of this event. In addition to correction of the atove problem, it was determined that this change should also include the ability to use alternate detectors since Unit 1 has installed spare detectors and Unit 2 has Gamma Metrics neutron detectors that only provido neutron indication to the Control Room and the alternate shutdown panel.

C. JUSTIFICATION Tablo 3.3-1, Reactor Trip System Instrumentation, Item 6 has been modified to include "or alternate" along with the unit specific source range and alternato detector mark numbers to allow the use of alternate detectors in place of the source range neutron flux B-1

ATTACHMENT B, crntinutd Proposed Technical Specification Change Nos. 218 and 85 Page 2 detectors. The alternate detectors will be required to provide sufficient sensitivity to adequately monitor reactivity changes in the core while providing the same functional requirements as the source range neutron flux detectors. The clarification "(Below P-10)" has been deleted since it could be read to require the source range detectors operable any time when Below P-10. In actuality, the source range detectors are not required operable between P-6 and P-10. This clarification has also been deleted from Table 4.3-1.

Item 6.a has been modified by replacing "Startup" with "With Rod Withdrawal Capability" and Item 6.b has been modified by replacing

" Shutdown" with "With All Rods Fully Inserted and Without Rod Withdcaval Capability." These changes eliminate confusion related to the meaning of "Startup" and " Shutdown" since the limitations associated with these requirements are based on whether or not the reacter trip breakers are open and the rods are capable of being withdrawn to add positive reactivity to the core. In addition, for Unit 2, the " Channels To Trip" has been changed from 1 to 0 and the number of " Minimum Channels operable" has been changed from 2 to 1.

This change is consistent with the Unit 1 and ISTS requirements and eliminates the potential for contradiction with the shutdown requirements of Specification 3.0.3.

Table 3.3-1 Action 4 has been modified by incorporating the ISTS requirements into the Beaver Valley format. This action applies with the reactor trip breakers closed and the rods capable of withdrawal. Item "a" incorporates the ISTS requirements of Condition I when the plant is in Mode 2 (Below P-6) with one inoperable detector. Item "b" incorporates the ISTS requirements of Condition K when the plant is in Modes 3, 4, and 5 with one inoperable detector. Item "c" incorporates the ISTS requirements of Condition J when the plant is in Modes 2 (Below P-6), 3, 4, and 5 with two inoperable detectors.

Table 3.3-1 Action 5 also has been modified by incorporating the ISTS requirements into the Beaver Valley format. This action applies with the Minimum Channels operable requirement not met when the reactor trip breakers are open, therefore, the rods are not capable of withdrawal. Items "a," "b," and "c" incorporate the ISTS requirements of Condition L when the plant is in Modes 3, 4, and 5. Note (7) is applied to Item "a" to allow the plant to cooldown with no operable detector as long as adequate shutdown margin is available to account for the positive reactivity addition resulting from the temperature change.

Table 4.3-1, Reactor Trip System Instrumentation Surveillance Requirements, Item 6, has been separated into Items "a" and "b" like Table 3.3-1 to specify surveillance requirements based on rod withdrawal capability. Item "a" applies when the rods are capable of withdrawal and provides for an "S" Channel Check frequency with an "R" Channel Calibration frequency. This is consistent with B-2

' ATTACHMENT B, continuOd Proposed Technical Specification Change Nos. 218 and 85 j Page 3 Table 3.3-1 for Channel Check since two channels are required operable. Item "b" applies when the rods are fully inserted and not capable of withdrawal and specifies an "S" for Channel Check since a qualitative evaluation of the channel can be performed to verify the channel is indicating in the approximate range for the expected plant conditions and an R" for Channel Calibration 1 consistent with the ISTS. Also on this table, the Channel I Functional Test frequencies have been changed to "Q" with Note (8).

Note (8) has been modified to address the note applicable to ISTS SR 3.3.1.7 to allow a transition from Mode 2 to Mode 3 without first performing a channel functional test on the source range detectors. The word " Alternated has been modified by Note (15) so )

that the alternate source range detectors are not required to be ,

surveillance tested until they are connacted to the appropriate i circuits and required to be operable.

Bases 3/4.3.1 and 3/4.3.2, Protective and Engineered Safety Features (ESF) Instrumentation, has been revised by adding the applicable portions of the ISTS Bases describing the source range '

i detectors along with additional discussion concerning the use of alternate detectors. i D. SAFETY ANALYSIS The proposed changes will reduce the potential for enforcecont discretions or emergency technical specification changes when source range detectors are required but are declared inoperable.

These changes will also eliminate the potential for contradiction between the source range action requirements and the shutdown requirements of Specification 3.0.3. Along with this, the capability to use alternate detectors in place of the source range neutron flux detectors has been added to allow the plant to take advantage of alternate detectors currently installed in the plant.

The use of alternate detectors was addressed by adding "o!

alternate" and the unit specific mark numbers to Item 6 of Table 3.3-1. This is similar to Amendments 175 and 55, for Units 1 and 2, respectively, which incorporated the use of alternate detectors into Specification 3.9.2 for Mode 6. When two detectors are required operable, either the source range detectors or the alternate detectors are adequate to meet the source range instrumentation requirements. This provides for channel separation to ensure redundant channels are available. The statement (Below P-10) can be interpreted to require the source range detectors to be operable when Below P-10. However, the operator is permitted to remove power from the source range detectors when above P-6, therefore, to reduce the potential for confusion (Below P-10) has been deleted. The alternate detectors must provide the accuracy and sensitivity required to adequately monitor changes in the core reactivity condition. The alternate detectors will be connected to the source range circuits to provide the required neutron flux indication, high flux at shutdown alarm, and source range high B-3

. __ __ _ _ . _ ~ . __._____ ______ _

  • , . e.

ATTACHMENT B, crntinu d Proposed Technical Specification Change Hos. 218 and 85 Page 4 neutron flux t "ip. The relative source range and alternate detector locati is are shown on Attachment D, Figure 1. Unit 1 has installed m detectors N-33 and N-34 that are equivalent to source range m.cctors N-31 and N-32 and can be easily connected to the source range circuits in place of an inoperable cource range detector. Unit 2 has installed post-accident neutron flux monitors (Gamma Metric detectors) N-52A and N-52B that at present cannot be directly connected to the source range circuits without a plant design change. Thucefore, Note (8) has been addad to the word

" alternate" that was added to Table 3.3-1 Item 6 so that the Gamma Metric detector, can only be used to provide additional verification of the core reactivity condition until such time as a plant design change is performed to provide the capability for directly connecting the Gamma Metric or other detectors into the source range circuits so they can provide the required alarm and trip functions. Incorporating this ability now will eliminate a future technical specnfication change thet would otherwise ' >)

required to implemer.t the plant design change to the detector circuits.

Note (15) has been added to the word " alternate" that was added to Table 4.3-1 Item 6 to indicate the alternate detectors are exempt from the surveillance requirements until such time as they are connected to the source range circuits and required to be operable.

This is appropriate for the testing of components when those components are not required to be operable but are subsequently demonstrated operable by surveillance testing prior to placing in service. The function of the source range detectors is to provide direct neutxon flux monitoring of the core to detect changes in reactivity which would result in a loss of the required shutdown margin. Plant cooldown and xenon decay are rclognized as positive reactivity additions, however, they are accounted for in the shutdown margin calculations. The shutdown margin remains essentially unchanged and will be available to preclude a criticality event during this evolution. The alternate detectors will provide neutron flux monitoring in place of the source range detectors thus assuring core monitoring at a level consistent with the current technical specification requirements. Therefore, there is no loss of function or need for additional compensatory actions and required plant evolutions can be performed while relying on the alternate detectors.

Table 3.3-1 Items 6.a and 6.b have been modified to eliminate confusion related to the mode and rod withdrawal limitations.

Items 6.a and 6b are currently titled "Startup" and " Shutdown,"

respectively, however, the mode limitations are concerned with the capability to add positive reactivity by withdrawing the control rods. Therefore, the titles have been changed to clarify this limitation to ensure the required number of " Channels To Trip" and

" Minimum Channels Operacle" are met for the applicable modes.

Along with this, the Unit 2 Table 3.3-1 Item 6.b required number of "C'tannels To Trip" and " Minimum Channels operable" has been reduced by 1 to 0 and 1, respectively, since the plant is shutdown and the B-4

ATTACHMENT B, c:ntinuCd Proposed Technical Specification Change Nos. 218 and R5 Page 5 rods are not capable of withdrawal. In this condition, the source range detectors do not provide a trip function and the control rods cannot be withdrawn to add positive reactivity. Therefore, the source range detectors only provide indication and the high flux at shutdown alarm so only one channel is required operable. This is consistent with the Unit 1 and ISTS requirements and eliminates a requirement to enter Specification 3.0.3 with two channels inoperable since now this condition is addressed in the action statement.

breakers closed Table 3.3-1 Action 4 applies with and the rods capable of withdrawal. the reactor trip ISTS Cond.t ion I has been addressed in Item "a" which applies in Mode 2 (Below P-6) with one inoperable detector. This action requires suspension of operations involving positive reactivity additions. ISTS Condition K has been addressed in Item "b" and applies in Modes 3, 4, and 5 with one inoperable detector. This action requires restoring the inoperable channel to operable status within 48 hours5.555556e-4 days <br />0.0133 hours <br />7.936508e-5 weeks <br />1.8264e-5 months <br /> or open the reactor trip breakers in the next hour. ISTS Condition J is addressed in Item "c" and applies in Modes 2 (Below P-6), 3, 4, and 5 with two inoperable detectors. In this condition, the action is to open the reactor trip breakers immediately. When the reactor trip breakers are open, then Action 5 applies since this action applies in Modes 3, 4, and 5 with the reactor trip breakers open and the rods not capable of withdrawal. This action incorporates ISTS Condition L with Item "a" requiring suspension of operations involving positive reactivity additions. Note (7) is applied to this item to allow the plant to cooldown as long as the positive reactivity addition resulting from the cooldown is accounted for in the shutdown margin. Item "b" requires closing the unborated water source isolation valves within i hour in accordance with Specification 3.1.2.9. This specification identifies the valves that must be isolated and allows for RCS makeup by allowing those valves to oe opened when performing planned boron dilution activities. Item "c" requires performing the shutdown margin requirements of Surveillance Requirement 4.1.1.1.1 or 4.1.1.2, as applicable, within the next hop; and every twelve hours thereafter. Completion of these action requirements addresses those criteria that must be satisfied to ensure that the core is maintained in a safe condition while also providing for plant cooldown which has been accounted for in the shutdown margin.

Table 4.3-1, Item 6, has been modified to include the use of alternate detectors and separated inta Items "a" and "b" similar to the changes to Table 3.3-1. When the rods are capable of withdrawal, Item "a" provides an "S" Channel Check and an "R" Channel Calibration frequency consistent with Table 3.3-1 requirements where two channals are required operable. The Channel Check ensures that gross failure of the instrumentation has not occurred and the Channel Calibration ensures the entire channel will perform the intended function. Also provided is a "Q" channel Functional Test frequency for Modes 2, 3, 4 and 5 consistent with current requirements and the ISTS. When the rods are fully B-5

n ATTACHMENT B, continu d Proposed Technical Specification Change Nos. 218 and 85 Page 6 i

inserted and are not capable of withdrawal, Item "b" requires a Channel check which involves a qualitative assessment to verify the channel is indicating in the proper range since only or.e channel is required operable in accordance with Table 3.3-1. Also provided is an "R" frequency for Channel Calibration and a "Q" Channel Functional Test frequency for Modes 3, 4 and 5 consistent with the ISTS. The Channel Functional Test frequency for the source range detectors has been changed to "Q" like the ISTS with Note (8).

Note (8) currently states "Below P-6" and has been modified by allowing a reasonable period of time following the transition from Mode 2 to Mode 3 to perform the source range channel functional test. The transition into Mode 3 with the reactor trip breakers closed involves a short period of time in Mode 3 before the reactor trip breakers are opened during a plant shutdown. The transition time in Mode 3 from when the reactor trip breakers are closed to ,

when they are opened is less than the time required to perform the channel functional test prior to entering Mode 3. Therefore, the ability to enter Mode 3 without first performing the source range channel functional test is v- snted. Following a plant trip, the operators are evaluating the ec..dition of the plant, complying with technical specifications and setting priorities. The selected time is reasonable, based on operating expenance, to perform a Channel Functional Test on the source range detectors in an orderly manner and without challenging the operators during plant trip as well as normal plant shutdown operations.

Applicable portions of the ISTS Bases describing the source range detectors have been added to our Bases 3/4.3.1 and 3/4.3.2, Protective and Engineered Safety Features (ESP) Instrumentation.

Additional discussion describing the use of alternate detectors has also been included to ensure the alternate detectors are suitable for use in place of the sourco range detectors.

Changes to the UFSAR system description are included in Attachment C. The operability requirements will continue to be met when using an alternate detector in place of a source range neutron flux dotector. No changes are being incorporated that would act to increase the probability of a positive reactivity addition event, therefore, the proposed change is considered to be safe and will not reduce the safety of the plant.

E. NO SIGNIFICANT HAZARDS EVALUATION The no significant hazard considerations involved with the proposed amendment have been evaluated, focusing on the three standards set forth in 10 CFR 50.92(c) as quoted below:

The Commission may make a final determination, pursuant to the procedures in paragraph 50.91, that a proposed amendment to an operating license for a facility licensed under paragraph

50. 21 ( b) or paragraph 50.22 or fcr a testing facility involves no significant hazards consideration, if operation of the facility in accordance with the proposed amendment would not:

B-6

ATTACHMENT B, c ntinued 1 sposed Technical Specification Change Nos. 218 and 85 Page 7 (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 followl."g evaluation is provided for the no significant hazards  !

consideration standards.

i in the

1. Does the change involve a significant increase probability or consequences of an accident previously j evaluated?

-The proposof. amendment would modify the reactor crip system instrumentation requirements to permit the use of alternate detectors in place of inoperable source range detectors. The alternate detectors will be connected to the source range circuits to provide the required indications and functions.

The alternate detectors are not required to be tested to satisfy the surveillance requirements until they are connected to the source range circuits and required to be operable. The alternate detectors must have the accuracy and sensitivity ,

required to adequately monitor changes in the core reactivity levels. The alternate detectors will provide neutron flux monitoring in place of the source range detectors thus assuring core monitoring at a level consistent with the current technical specification requirements. Therefore, there is no loss of function or need for additional compensatory actions and the operators can perform required plant evolutions while relying on the alternate detectors.

Two o'perable detectors are required when the control rods are capable of withdrawal. Rod withdrawal and boron dilution add positive reactivity which can significantly affect the reactivity condition of the core, therefore, two monitors are required operable during startup evolutions. Redundant detectors are required to ensure that two source range neutron flux detectors are available to detect changes in core reactivity. These changes provide those indications and '

functions censistent with the current technical specification requirements where at least two source range detectors are operating and capable of providing the required functions.

The function of the source range detectors is to provide direct neutron flux monitoring of the core to detect changes in reactivity which world result in a loss of the required shutdown margin.

One source range or alternate dete'ctor is required when the control rods are fully inserted and are not capable of withdrawal. Platt cooldown is recognized as a positive B-7

' ATTACHMENT B, c:ntinurd Proposed Technical Specification Change Nos. 218 and 85 Page 8 reactivity addition, however, this is accounted for in the

  • shutdown margin calculations. The shutdown margin remains essentially unchanged and will be available to preclude a criticality event durint this evolution. Inadvertent control rod withdravel is not a concern, therefore, one source range or alternate detector can adequately monitor the core neutron f.1m x . The action statements have been modified to address the HUREG-1431 Improved Standard Technical Specification (ISTS) requirements along with incorporating the ability to use alternate detectors in place of the source range detectors.

Bases 3/4.3.1 and 3/4.3.2, Protective and Engineered Safety Features (ESP) Instrumentation, has been revised to include the modifications to the source range detector requirements including the use of alternate source range detectors. The alternate detectors must provide sufficient accuracy and sensitivity to adeyoately monitor changes in core reactivity during Modes 2 (Below P-6), 3, 4, and 5.

The operability requirements of the source range neutron flux instrumentation will continue to be met when using an alternate detector in place of a source range neutron flux detector. No changes are being incorporated that would ect to increase the probability of a positive reactivity addition event, therefore, the proposed change will 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?

The function of the source range detectors is to provide direct neutron flux monitoring of the core to detect positive reactivity additions which would result in a loss of the required shutdown margin. The alternate detectors must provide the accuracy and sensitivity required to adequately monitor changen in the core reactivity levels during shutdown and startup activities. The alternate monitors will be connected to the scurce range cirettits to provide the required indications and functions. Therefore, there as no loss of function or need for additional compensatory actions and plant shutdown and startup activities can be continued while relying on the alternate detectors.

Control rod withdrawal 12 a method capable of providing rapid positive reactivity =ddition with boron dilution being a much slowcr positive reactivity addition method. With the control rods capable of withdrawel, a rod withdrawal event could rapidly initiate core criticality so redundant source range detectors are required operable. This ensures adequate monitoring capability is available to alert the operators of a rapid increase in the core reactivity condition. The maximum l

reactivity addition due to the boron dilution is slow enough B-8 i

  • ~

' ATTACHMENT B, CCntinued Proposed Technical Specification Change Nos. 218 and 85  ;

Page 9 to allow the operator to determine the cause and take  ;

corrective action before the shutdown margin is lost. These >

changes will not affect the operability or reliability of the  :

source range instrumentation to provide the required indications and functions. Therefore, the proposed change will not create the possibility of a new or different kind of accident from any accident previously evaluated.

3. Does the change involve a significant reduction jn a margin of safety?

The proposed change will continue to ensure the required source range instrumentation functions are available during s'hutdown and startup conditions.

. This change will not reduce  ;

the reliability of the source range detectors to monitor the core reactivity condition and provide the appropriate indications or affect the required shutdown margin. PJant operation will continue to be maintained within the shutdown ,

margin requirements of Specification 3.1.1.1 and 3.1.1.2. The '

required indications and functions are still maintained in accordance with current technical specification requirements and the shutdown margin is unaffected, therefore, the proposed change will not involve a significant reduction in a margin of safety.

F. NO SIGNIFICANT HAZARDS CONSIDERATION DETERMINATION Based on the considerations expressed above, it is concluded thLt the activities associated with this license amendment request satisfies the no significant hazards consideration standards of 10 CFR 50.92(c) and, accordingly, a no significant hazards' consideration finding-is justified.

G. ENVIRONMENTAL CONSIDERATION The proposed amendment changes a requirement with respect to the installation or use of a facility component located within the restricted area as defined in 10 CFR Part 20. It has been determinted that the proposed amendment involves no significant increase in the amounts, and no significant change in the types of any effluents that may be released offsite, and that there is no significant increase in individual or cumulative occupational radiation exposure. Accordingly, the prcposed amendment meets the eligibility criteria for categorical exclusion set forth in 10 CFR 51.22(c)(9). Pursuant to 10 CFR 51.22(b) no environmental impact statement or environmental assessment need be prepared in '

connection ~with the issuance of this proposed amendment.

H. UFSAR CHANGES See Attachments C-1 and C-2.

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l ATTACHMENT C-1 i

i Beaver Vsliey Power Station, Unit No. 1 Proposed Technical Specification Change No. 218  ;

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Applicable UFSAR Changes

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BVPS-1-UPDATED FSAR Rov. 8 (1/90)

The movable incore neutron detector system would be used for more detailed mapping if the thermocouple system were to indicate an abnormality. These two complementary systems are more useful when taken together than either system alone would be. The incore instrumentation system is described in more detail in Section 7.7.

The Incore Instrumentation is provided to obtain data from which fission power density distribution in the core, coolant enthalpy distribution in the core, and fuel burnup distribution may be determined.

3.4.5.2 overtemperatura and overpower A T Instrumentation The overtemperature A T trip protects the core against low DNBR. The ovcrpower A T trip protects against excessive power (fuel rod rating protection).

As discussed in Section 7.2, factors included in establishing the overtemperature AT and overpower AT trip setpoints include the reactor coolant temperature in each loop and the axial distribution of core power through the use of tho two section er. core neutron detectors.

3.4.5.3 Instrumentation to Limit Maximum Power Output The output of tha three ranges (source, intermediate, and power) of detectors, with the electronics of the nuclear instruments, are used to limit the maximum power output of the reactor within their respective ranges. tieuf,wt MWW There are #4Me8> radial locations containing a total of $1 '

..g..t neutron i

flux detectors installed around the reactor in the ,ri-- y shieldf'EanK two proportionalcountersforthesourcerangeinstalledonoppos/te

" flat" portions of the core containing the primary utartup souwes at an elevation approximately one quarter of the core height. "Two compensated ionization chambers for the intermediate range, located in the same instrument wells and detector assemblies as the source range detectors are positioned at an elevation corresponding to one half of the core height; four dual section uncompensated ionization chamber assemblies for the power range installed vertically at the four corr.ers of the core and located equidistant from the reactor vessel at all points and, to minimize neutron flux pattern distortions, within one foot of the reactor vessel. Each power range detector provides two signals corresponding to the neutron flux in the upper and in the lower sections of a core quadrant. The three ranges of detectors are used as inputs to monitor neutron flux from a completely shutdown condition to 120 percent of full power with the capability of recording overpower excursiens up to 200 percent of full power.

The difference in neutron flux between the upper and lower sections of the power range detectors are used to limit the overtemperature A T and overpower A T trip setpoints and to provide In the operator with an indication of the core power axial offset.

addition, the output of the power range channels are used for:

l 3.4-39

1

  • * )

, . ,- l INSEAT 1 Located 90 degress tros the 4,ource range detectors, on opposite flat .

portions of the core at approximately one quartur of the core height, are  !

olternate source range detectors. The alternate detectors are similar to the. source range detectors and can be connected to the source range circuits to provide equivalent functions in place of inoperable source range detectors. Curveillance testing of the alternate detectors is not required until they are connected to the source range circuits and required ,

to be operable.

4 E

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ATTACHMENT C-2 Beaver Valley Power Station, Unit No. 1 Proposed Technical Specification Change No. 85  ;

l l Applicable UFSAR Changes l

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. ,wn,m,.----r--.--a,- , + ...n-,. . . , , . . . - . . - , . . . - - - - . - - - - - , - - - . ~ ,

l o e' s BVPS-2 UFSAR Rev. a preselected position, and fission chamber detectors positioned its guide thimbles which run the length of selectad fuel assemblies to measure the neutron flux distribution. Figure 4.4-22 shows the l number and location of instrumented assemblies in the core.

The core-exit thermocouples provide a backup to the flux monitoring instrumentation for monitoring power distribution. The routine, systematic, collection of thermocouple readings by the operator provides a data base. From this data base, abnormally high or abnormally low readings, quadrant temperature tilts,' or systematic departures from a prior reference map can be deduced.

The moveable incore neutron detector system would be used for more detailed mapping if the thermocouple system were to indicate an abnormality. These two complementary systems are more useful when l takan together than either system alone would be. The incore I instrumentation system is further discussed in section 7.7.1.9.

The incore instrumentation is provided to obtain data from which fission power density distribution in the core, reactor coolant enthalpy distribution in the core, and fuel burnup distribution may be determined.

4.4.6.2 overtemperature and overpower AT Instrumentation The overtemperature AT trip protects the core against low DNBR. The overpower AT trip protects agsinst excessive power (fuel rod rating protection).

As discussed in section 7.2.1.1.2, factors included in establishing the overtemperature AT and overpower AT trip setpoints include the reactor coolant temperature in each reactor coolant loop and the axial distribution of core power through the use of the two section excore neut.>on detectors.

4.4.6.3 Instrumentation

  • Limit Maximum Power output The output of the three ranges (source, intermediate, and power) of detectors, with the electronics of the nuclear instruments, are used to 1 Lait the maximum power output of the reactor within their respective ranges.

There are eight radial locations containing a total of e.ert hv.. ..eutron l flux detectors installed around the reactor in the neutron shield tank, two preportional counters for the source range installed on opposite " flat" portions of the core containing the primary start up sources at an elevation approximately one quarter of the core height. Two compensated ionization chambers for the intermediate range, ocated in the same instrumer.t wells and detector assemblies as the source range detectors, are positioned at an elevation correep nding to 1/2 of the core height. Four dual section uncompeasated ionisation chamber assemblies for the power range are WIW )

4.4-33

_ ._ . .. . . ._ - - - . - - - . - ~ .

INSERT 1 I

Located 90 degrees from the source range detectors, on opposite flat portions of the core within the neutron shield tank, are the post-accident neutron flux monitors. A design change would be required to connect the post-accident neutron flux monitors as alternate detectors to the source i range circuits to provide equivalent functions in place of inoperable cource range detectors. The post-accident neutron flux monitors (as citernate detectors) may be used for monitoring purposes until detector ,

functions are modified to permit equivalent altra and trip functions.

Surveillance testing of the alternate detectors is not required until they cre connected to the source range circuits and required to be operable.

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-_...~----s, . . - , - - - - - - _ . . . _ - - - - - - .

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ATTACIU4ENT D Beaver Valley Power Station, Unit Hos. 1 and 2 Proposed Technical Specification Change Nos. 218 and 85 FIGURE 1 ,

Relstive' Source Range and Alternate Detector Locations

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l FIGURE 1 UNIT 1 N 32 UNIT 2 N42 e

UNIT 1 N43 g UNIT 1 N44 UN;T 2 N425 g

UNIT 2 N 52A e

UNIT 1 N41 UNIT 2 N41 RELATIVE SOURCE RANGE AND ALTERNATE DETECTOR LOCATIONS SOURCE RANGE ALTERNATE DETECTORS DETECTORS UNIT 1 N 31, N 32 N 33, N 34 UNIT 2 N 31, N 32 N 52B, N b2A

_ _ _ - - _ _ - . _