ML20202G908

Safety Evaluation Re Amend to License DPR-59 to Revise TS Tables 3.2-2 & 4.2-2

ML20202G908
Person / Time
Site:	FitzPatrick
Issue date:	02/06/1998
From:	POWER AUTHORITY OF THE STATE OF NEW YORK (NEW YORK
To:
Shared Package
ML20202G816	List: JAFP-98-0046, Forwards Revised Amend to DPR-59,revising TS Table 3.2-2 & 4.2-2, Core & Containment Cooling Sys Initiation & Control Instrumentation Operability Requirements. W/Revised TS Pages & Safety Evaluation ML20202G855 ML20202G884 ML20202G908
References
NUDOCS 9802200246
Download: ML20202G908 (39)

Text

__-_________-__ __

Attachment IV SAFETY EVALUATION

- CORE AND CONTAINMENT COOLING SYSTEM INITIATION AND CONTROL INSTRUMENTATION (JPTS-%002) 0 0

.~[

New York Power Authority JAMES A. FITZPATRICK NUCLEAR POWER PLANT Docket No. 50-333 DPR-59 9802200246 980206 PDR P

ADOCK 05000333 PDR

o- . .:,-

Attachment IV SAFETY EVALUATION Page 1 of 23

1. INTRODUCTION This application for an amendment to the James A. FitzPatrick Technical Specifications (TS) proposes changes to TS Table 3.2-2, " Core and Containment Cooling System Initiation and Control Instrumentation Operability Requirements." The proposed changes will revise allowed outage times (AOTs) for 4kV Emergency Bus Undervoltage Trip Functions. He AOTs for these trip functions were extended by Amendment 227; however, as described in Reference 2, the AOT extensions for these trip functions were not consistent with the requirements of Standard Technical Specifications (STS), NUREG 1433 (Reference 3), and differed from the recommendations in the associated Licensing Topical Report (Reference 5).

Additional changes are proposed to TS Table 3.2 2 and to TS Table 4.2 2, " Core and Containment Cooling System Instrumentation Test and Calibration Requirements." These changes will: (1) replace the generic actions for inoperable instrument channels with function-specific actions,(2) replace the generic test AOT with function-specific test AOTs, and (3) relocate selected trip functions from the TS to an Authority controlled document. This will ensure consistency with STS, simplify the use of TS, and facilitate STS conversion by minimizing the differences between current TS and STS. The changes will also enhance safety by ensuring that an inoperable instrument cl.arnel is not placed in the tripped condition when this c'ondition is not a safe state for the channel.

11. . DESCRIPTION, PURPOSE, AND SAFETY IMPLICATION OF THE PROPOSED CHANGES To simplify review of this application, the following subsections address the specific changes to each trip function. Each subsection includes a description, purpose, and safety implication of the proposed change. The exact wording of the changes to the TS are not provided. The changes aie described in sufficient detail so that, when reviewed in conjunction with the revised TS pages in Attachment I and the marked-up TS pages in Attachment 111, a clear understanding of the changes to each trip function is provided.

1. Table 3.2-2. all Trin Function Description Delete "(Notes 1 and 2)" from the column heading " Min. mum No. of Operable Instrument -

Channels Per Trip System" on pages 66,67,68,69, and 70. These notes refer to the generic actions and AOTs for all trip functions. Specific ac* ions and AOTs will be adopted as described in the following subsections.

T V

y . . .

, Attichment IV SAFETY EVALUATION Page 2 of 23 Purpose Deleting the note references from the column heading allows revised requirements to be adopted for each trip function. The existing TS refer to generic actions and AOTs that were adopted L mendment 227 (Reference 1) and were intended to optimize consistency in the text for the .arious instrumentation groups; however, they differ from the requirements of STS for some trip functions. The revised actions and AOTs will simplify the use of TS by providing trip function-specific requirements, and ensure consistency with STS.

Safety implication Deleting the notes from the column heading does not have any safety implication. The ,

changes to each trip function and safety implication are discussed in the following 4 subsections. t

2. Table 3.2-2. Reactor Low-tow Water Level (Item 1)

Description Add "(Notes 1,1I)" to the second column for table item 1 on page 66. . This trip function-initiates liigh Pressure Coolant injection (llPCI) and Reactor Core Isolation Cooling (RCIC). The Standby Gas Treatment System (SGTS) also starts to support 1-IPCI operation, upon receipt of a llPCI initiation signal, as described in Reference 4 (Sections 5.3.3.4 and 6.4.1).

• Add Note i to page 70. This note provides revised actions for one or more inoperable instrument channels. The revised actions delete ttu requirement to trip one trip system within 6 hours6.944444e-5 days <br />0.00167 hours <br />9.920635e-6 weeks <br />2.283e-6 months <br /> whenever multiple instrument channels are inoperable. The revised actions ,

are consistent with STS. Reference STS Table 3.3.5.1-1, Function 3a; and Table 3.3.5.2-1 Function 1.

Add Note 11 to 1 age 71b. This note provides the test AOT. The test AOT is consistent with existing TS and STS requirements for this trip function. Reference STS Surveillance Requirements 3.3.5.1 and 3.3.5.2, Note 2, _

Purpose

. The revised actions adopt the requirements of STS. STS provide a 24-hour repair AOT for this trip function, regardless of the number of inoperable instrument channels, provided ti'at system initiation capaoility is maintained. Current TS require one trip system be tripped within 6 hours6.944444e-5 days <br />0.00167 hours <br />9.920635e-6 weeks <br />2.283e-6 months <br /> whenever multiple instrument channels are inoperable, and are thus more restrictive than STS.

The test AOT is applicable to trip functions for which initiation capability is required to be maintained during testing, and does not alter the intent of the current TS.

l

g.-3 ,

-Attachment IV -

SAFETY EVALUATION Page 3 of 23 Safety Implication The revised actions are consistent with the STS requirements for this trip function. The intent of the test AOT is not altered by this change and remains the same as approved in

. Amendment 227 (Reference 1). Therefore, there is no safety implication with this change.

3. Table 3.2 2. Reactor Low-Low-Low Water Level (Itentl)

Description Add "(Notes 2,3,11)" to the second column for table item 2 on page 66. This trip function initiates Core Spray, Low Pressure Coolant injection (LPCI), and the Automatic Depressurization System (ADS). Emergency Diesel Generators (EDGs) also receive a start signal from Core Spray and 1 PCI logic.

Add Note 2 to page 70. This note provides revised actions for one or more inoperable instrument channels for Core Spray and/or LPCI. The revised actions delete the requirement to trip one trip system within 6 houes whenever multiple instrument channels are inoperable. The revised actions are consistem with STS, Reference STS Table 3.3.5.1-1, Functions la and 2a.

Add Note 3 to page 70. This note provides revised actions for one or more inoperable ,

instrument channels for' ADS. The revised actions delete the requirement to trip one trip system within 6 hours6.944444e-5 days <br />0.00167 hours <br />9.920635e-6 weeks <br />2.283e-6 months <br /> whenever multiple instrument caanuela are inoperable. The revised actions also extend the repair AOT from 24 hours2.777778e-4 days <br />0.00667 hours <br />3.968254e-5 weeks <br />9.132e-6 months <br /> to 96 hours0.00111 days <br />0.0267 hours <br />1.587302e-4 weeks <br />3.6528e-5 months <br /> with HPCI or RCIC inoperable, or otherwise up to 8 days. The revised retions are consistent with STS.

Reference STS Table 3.3.5.1-1, Functions 4a and 5s.

Note 11 provides the test AOT that is consistent with existing TS and STS requirements for this trip function. Reference STS Surveillance Requirements 3.3.5.1, Note 2.

Purpose The revised actions permit full use of the repair AOT when enultiple instrument channels are inoperable, provided that system initiation capability is maintained.

For ADS, the revised actions also extend the repair AOT to be consistent with STS.

Existing TS provide only a 24-hour repair AOT for ADS instrument channels. The 24-hour repair AOT. was added in Amendment 227, based on the recommendations of Licensing Topical Report (LTR) NEDC-30936-P-A, Part 2 (Reference 5) A review of the recommended changes to TS contained in the LTR, as clarified in Reference 6, reveals that the 24-hour repair AOT for ADS instrument channels was to be applied in addition to an existing 7-day or 72-hour AOT for an inoperabie ADS trip system. Thus the intent of the TS changes recommended by the LTR was to provide au 8-day /96-hour repair AOT for ADS trip functions. This intent is reflected in STS.

9

Attachment IV SAFETY EVALUATION Page 4 of 23 The test AOT is applicable to trip functions for which initiation capability is required to be maintained during testing, and does not alter the intent of the current TS.

Safety implication he revised actions are consistent with the STS requirements for this trip function. The repair AOT for ADS is consistent with the intent of the LTR and the STS. The intent of the test AOT is not altered by this change and remains the same as approved in Amendment 227. Therefore, there is no safety implication with this change.

4. Table 3.2-2. Reactor liich Water Level (Items 3 and 4)

Description Add "(Notes 4,12)" to the second column for table items 3 and 4 on page 66. These trip functions trip the llPCI turbine and close the RCIC steam supply isolation valve.

Change "(Note 8)" to "(Note 16)" in the fiflh column for table items 3 and 4 to reflect renumbered notes for Table 3.2-2. This change is editorial, has no impact on TS requirements, and thus further discussion of this change is not required.

Add Note 4 to page 71. This note provides revised actions for one or more inoperable instrument channels. The revised actions delete the requirement to trip one trip system within 6 hours6.944444e-5 days <br />0.00167 hours <br />9.920635e-6 weeks <br />2.283e-6 months <br /> whenever multiple instrument channels are inoperable. Also dele:ed, is the requirement to trip an inoperable instrument channel upon expiration of the repair AOT.16

, operability of the instrument channel is not restored within the repair AOT, the system is declared inoperable. In addition, the requirement to maintain capability of the function during the repair AOT is deleted. The revised actions are consistent with STS. Reference STS Table 3.3.5.1-1, Function 3c; and Table 3.3.5.2-1, Function 2.

Add Note 12 to page 71b. This note provides the revised test AOT. The revised test AOT deletes the requirement to maintain initiation capability of the trip function during testing.

The revised test AOT is consistent with STS. Reference STS Surveillance Requirements 3.3.5.1 ano 3.3.5.2, Note 2.  :

Purpose The revised actions permit full use of the repair AOT when multiple instrument channels are inoperable, and delete the requirement to trip an inoperable instrument channel, to be consistent with STS. The existing TS would require placing an inoperable instrument channel in the tripped condition. As described in the Bases for STS Sections 3.3.5.1 and 3.3.5.2 (Actions C.1 and C.2), placing the channel in trip would either cause the initiation or it would not necessarily result in a safe state for the channel in all events.

o .- o ,

Attachment IV SAFETY EVALUATION Page 5 of 23 The requirement to maintain capability of the function during testing is deleted to be consistent with STS. As described in Reference 4 (Section 7.4.3.2.4 and Figure 4.7-2), the ,

logic for these trip functions is arranged in a two-out-of-two-taken-once configuration.

Therefore, it is not possible to maintain initiation capability during testing or repair AOTs.

Safety implication The revised actions are consistent with the STS requirements for there trip functions.

Deleting . requirement to trip an inoperable instrument channel is appropriate since placing the channel in trip would not always result in a safe sc te for the channel. The revised test AOT is consistent with STS and retains the same c'uration (6 hours6.944444e-5 days <br />0.00167 hours <br />9.920635e-6 weeks <br />2.283e-6 months <br />) as approved in Amendment 227. Therefore, there is no safety implication with this change.

5. Tahic 3.2-2, Heactor low Level (Inside Shroud) (Item 5)

Description Add "(Notes 5,11)" to the second column for table item 5 on page 66. This trip function prevents diversion of LPCI flow when adequate core cooling is not assured.

Delete "(Note 9)" from the second column for table item 5. This note was used to identify single channel trip systems., and was necessary for interpretation of the generic test AOT.

Since the generic test AOT has been replaced with function specine test AOTs, this note is no longer required and is deleted as described in Subsection 11.18.

Add Note 5 to page 71. This note provides revised actions for one or more inoperable instrument channels. The revised actions delete th quirement to trip one trip system within 6 hours6.944444e-5 days <br />0.00167 hours <br />9.920635e-6 weeks <br />2.283e-6 months <br /> for multiple instrument channel failures. In addition, the requirement to maintain capability of the function during the repair AOT is deleted. The revised actions are consistent with STS. Reference STS Table 3.3.5.1-1, Function 2e.

Note 11 provides the revised test AOT. The revised test AOT adds a requirement that initiation capability be maintained for the reaundant trip function. This is consistent with STS. Reference STS Surveillance Requirements 3.3.5.1, Note 2.

Purpose The revised actions permit full use of the repair AOT when multiple instrument channels are inoperable, and delete the requirement to maintain capability of the trip function during repair, to be consistent with STS. As described in the Bases for STS Section 3.3.5.1 (Actions B.1, B.2, and B.3), this function provides backup to administrative controls that prevent diversion of LPCI flow. Thus, a loss of function capability is permitted for 24 '

hours.

l

, . . - s .-

Att::chment IV SAFETY EVALUATION Page 6 of 23 The revised test AOT requires initiation capability te maintained to be consistent with STS.

The existing TS do not place this restriction on use of the test AOT, As described in Reference 4 (Section 7.4.3.5.4), a single instrument channel b used to monitor water level b inside the core shroud for each LPCI loop. Based on this design, when one of the two instrument chuanels is under test, the other (or redundant) instrument channel is cape5 '

preventing diversion of flow in its respective LPCI subsystem. Therefore, trip capabilny can and should be maintained for the redundant trip function during testing.

Safety Implication The revised actions are consistent with the STS 'squirements for this trip function.

Deleting the requirement to maintain capability af the trip function du ing repair is appropriate since function capability is not reqmted to ensure operabi'ity of LPCI. Revising the test AOT to require initiation capability be maintained % epprouiate since this is provided for by design. In addition, the revised test AOT is conastent with STS and retains the same duration (6 hours6.944444e-5 days <br />0.00167 hours <br />9.920635e-6 weeks <br />2.283e-6 months <br />) as approved in Amendment 227. Therefore, there is no safety implication with this change.

6. Table 3.2-2. Containment Hinh Pressure Glem 6)

The original submittal requested that the Containment fligh Pressure trip function that prevents inadvertent operation of containment spray during accident conditions be moved from the technical specifications to a plant controlled procedure. The basis for the removal of the trip function was that it did not meet the criteria set forth in 10 CFR 50.36. As stated in the original submittal, failure of the containment high pressure trip function would not have a significant effect on the primary containment. It has been evaluated that operation of the containment spray is not requ! red during any design basis accident.

Therefore, it is not relied upon for detection or mitigation of any transient or accident, is not relied upon to detst degradation of the reactor coolant pressure boundary, and is not significant to public health or safety. However, the Authority determined that the trip function should be retained in technical specifications based on the informatien provided in NEDO-31466, Supplement I (reference 8). This document concluded that this function met criterion 3 of 10 CFR 50.36 and should be retained in the technical specifications.

The Containment liigh Pressure Function is provided as an isolation of the containment spray mode of kilR on decreasing containment pressure following manual actuation of the system. This isolation ensures excessive depressurization of the containment does not occur due to containment spray. This function also serves as an interlock pennissive to the RHR system to be manually aligned from the LPCI mode to the containment spray mode after containment pressure has exceeded the trip setting. The permissive ensures containment -

pressure is elevated before the manual transfer is allowed.

Purpose i

The revised actions permit full use of the repair AOT when multiple instrument channels are inoperable, and delete the requirement to maintain capability of the .;ip function during repair, to be consistent with STS. As described in the Bases for STS Section 3.3.5.1 (Actions B.1,0.2, and B.3), this function provides backup to administrative controls that prevent diversion of LPCI flow. Thus, a loss of function capability is permitted for 24 hours2.777778e-4 days <br />0.00667 hours <br />3.968254e-5 weeks <br />9.132e-6 months <br />.

L ' ' ' '

, .- a-,

Attichment IV SAFETY EVALUATION Page 7 of 23 The revised test AOT requires initiation capability be maintained to be consistent with STS.

The existing TS do not place this restriction on use of the test AOT. There are four channels of the Containment liigh Pressure functior.. Based on this design, when one of the two instrument channels is under test, the other (or redundant) instrument channel is capable of preventing diversion of flow in its respective LPCI subsystem. Therefore, trip capability can and should be maintained for the redundant trip function during testing.

Safety implication The revised actions are consistent with the STS requirements for this trip function.

Deleting the requirement to maintain capability of the trip function during repair is appropriate since function capability is not required to ensure operability of LPCI Revising  ;

the test AOT to require initiation capability be maintained is appropriate since this is i provided for by design.- In addition, the revised test AOT is consistent with STS and retains the same duration (6 hours6.944444e-5 days <br />0.00167 hours <br />9.920635e-6 weeks <br />2.283e-6 months <br />) as approved in Amendment 227. Therefore, there is no safety implication with this change.

7. Inble 0.4-2 Reactor Low Incl (item 1)

Description This trip function provides a confirmatory low water level signal for ADS. This change rellects deleted trip functions, is editorialin nature, and thus no further discussion is required.

Add "(Notes 3,1l)" to the second column for table item 7.

Delete "(Note 9)" from the second column for table item 6. Due to replacem,mt of the geneiic test AOT, this note a no longer required for interpretation of the TS.

Note 3 provides revised actions for one or more inoperable instrument channels. The revised actions delete the requirement to trip one trip system _within 6 hours6.944444e-5 days <br />0.00167 hours <br />9.920635e-6 weeks <br />2.283e-6 months <br /> whenever multiple instrument channels are inoperable. The revised actions also extend the repair AOT from 24 hours2.777778e-4 days <br />0.00667 hours <br />3.968254e-5 weeks <br />9.132e-6 months <br /> to 96 hours0.00111 days <br />0.0267 hours <br />1.587302e-4 weeks <br />3.6528e-5 months <br /> with IIPCI or RCIC inoperable, or otherwise up to 8 days.

The revised actions are consistent with STS. Reference STS Table 3.3.5.1-1, Functions 4d and 5d. -

Note iI provides the revised test AOT. The rNsed tes 30T adds a requirement that initiation capabi:ity be maintained for the redundant trip function. This is consistent with STS. Reference STS Surveillance Requirements 3.3.5.1, Note 2.

Purpose The revised actions permit full use of the repair AOT when multiple instrument channels are inoperable, provided that system initiation capability is maintained. The revised actions also extend the repair AOT to be consistem with STS.

Attichment IV SAFETY EVALUATION Page 8 of 23 The revised test AOT requires initiation capability be maintained to be consistent with STS.

The existing TS do not place this restriction on use of the test AOT. As described in Reference 4 (Section 7.4.3.3.2), the control scheme for ADS consists of a single actuation system containing two logics Either logic can initiate automatic depressurization.

Therefore, trip capability can and should be maintained for the redundant trip functi3n during testing.

Safety implication The revised actions and AOTs are consistent with the STS requirements for this trip function. The repair AOT is consistent with the intent of Reference 5 as implemented in the STS. Revising the test AOT to require initiation capability be maintained is appropriate since this is provided for by design. Therefore, there is no safety implication with this change.

8. Table 3.2-2. Drywell High Pressure (Item 8)

Description This trip function initiates Core Spray, LPCI, and ilPCI. EDGs also receive a start signal from Core Spray and LPCI logic, and SGTS also starts upon receipt of a llPCI initiation -

signal. This change reflects deleted trip functions, is editorialin nature, and thus no further discussion is required.

Add "(Notes 1,2,11)" to the second column for table item 8.

Note i provides revised actions for one or more inoperable instrument channels for 1IPCI.

The revised actions delete the requirement to trip one trip system within 6 hours6.944444e-5 days <br />0.00167 hours <br />9.920635e-6 weeks <br />2.283e-6 months <br /> for multiple instrument channel failures. The revised actions are consistent with STS.

F.eference STS Table 3.3.5.1-1, Function 3b.

s Note 2 provides revised actions for one or more inoperable instrument channels for Core Spray and LPCI. The revised actions delete the requirement t, trip one trip system within 6 hours6.944444e-5 days <br />0.00167 hours <br />9.920635e-6 weeks <br />2.283e-6 months <br /> for multiple instrument channel failures.- The revised avions are consistent with STS. Reference STS Table 3.3.5.1-1, Fur 'tions Ib and 2b.

Note li provides the test AOT that is consistent with existing TS and STS. Reference STS Surveillance Requirements 3.3.5.1, Note 2.

Purpose The revised actions permit full use of the repair AOT when multiple instrument channels are inoperable, provided that system initiation capability is maintained. ,

, The test AOT is applicable to trip functions for which initiation capability is required to be maintained during testing, and does not alter '.he intent of the current TS.

, *V.

Attachment IV SAFETY EVALUATION Page 9 of 23 Safety impliention The revised actions are consistent with the STS requirements for this trip function. The intent of the test AOT is not altered by this change and remains the same as approved in Amendment 227. Therefore, there is no safety implication with this change.

9. IRble 3.2 2. lienetor Low Pressure (Item 9) .

Description 4

This trip function provides a low-pressun, permissive signal for opening Core Spray and LPCI injection valves. This change reflects deleted trip functions, is editorialin nature, and thus no further discussion is required.

Add "(Notes 6, i1)" to the second column for table item 9.

Add Note 6 to page 71. This note provides revised actions for one or more inoperable -

instruruent channels. The revised actions delete the requirement to trip one trip system within 6 hours6.944444e-5 days <br />0.00167 hours <br />9.920635e-6 weeks <br />2.283e-6 months <br /> whenever multiple instrument channels are inoperable. Also deleted, is the ,

requirement to trip an inoperable instrument channel upon expiration of the repair AOT If I operability of the instrument channel is not restored within the repair AOT, the supported feature is declared inoperable. The revised actions are consistent with STS. Reference STS Table 3.3.5.1-1, Functions Ic and 2c.

Note 11 provides the test AOT that is consistent with existing TS and STS. Reference STS Surveillance Requirements 3.3.5.1,' Note 2.

- Purpose The revised actions permit full use of the repair AOT when multiple instrument channels are inoperable, provided that system initiation capability is maintained.

, The revised actions also delete the requirement to trip an inoperable instrument chani.el upon expiration of the repair AOT to be consistent with STS. The existing TS would require placing this instrument channel in the tripped condition. As described in the Bases for STS Section 3.3.5.1, Actions C.1 and C.2, placing the channel in trip would either cause the initiation or it would not necessarily result in a safe state for the channel in all events.

~

The test AOT is applicable to trip functions for which initiation capability is required to be maintained during testing, and does not alter the intent of the current TS.

Safety implication The revised actions are conristent with the STS requirements for this trip function.

Deleting the requirement to trip an inoperable instrument channel is appropriate since piccing the channel in trip would not always result in a safe state for the channel. The intent of the test AOT is not altered by this change and remains the same as approved in Amendment 227. Therefore, there is no safety implication with this change.

l l

,- f t. r.

' Att:chment IV SAFETY EVALUATION Page 10 of 23

10. Igl$tl&2. Resetor Ixw Pressure (Item 10) 0- Description This trip function permits closure of LPCI injection valves while in shutdown cooling, in conjunction with a shutdown cooling isolation signal. This change reDects deleted trip

- functions, is editorialin nature, and thus no further discussion is required.  !

Add "(Notes 2,12)" to the second column for table item 10.

Delete "(Note 9)" from the second column for table item-10. This note was used to identify -

single channel trip systems, and was necessary for interpretation of the generic test AOT. ~

Since the generic test AOT hat been replaced with function-specine test AOTs, this note is no longer required.

Note 2 provides actions for one or mere inoperable instrument channels that are consistent with the intent of existing TS requirements.

Note 12 provides the test AOT t~ s msistent with existing TS requirements for this trip -

- function.

Purpose a This change adopts function-speci0c actions and a function-specific test AOT for this trip _

function. The intent of the existing actions is not altered, and the requirements of the test AOT are not changed.-

The existing generic actions provide a 6 hour6.944444e-5 days <br />0.00167 hours <br />9.920635e-6 weeks <br />2.283e-6 months <br /> repair AOT for multiple inoperable instrument channels, provided function capability is maintained. Only two channels of reactor low -

pressure are provided for this trip function; therefore function capability is not maintained ,

when more than one channel is inoperable and thus, the 6-hour repair AOT is not _ i applicable to t% trip function. The function-specific actions require the supported feature -

be declared inoperable within one hour from discovery of loss of initirition capability for features in both divisions (i.e., both LPCI subsystems). This is consistent with STS-requirements for similar trip functions. This trip function is not included in the STS and will be evaluated for possible relocation during STS conversion.

Safety implication The requirements of the test AOT are not affected by this change and remain the same as approved in Amendment 227. The revised actions delete a 6-hour repair AOT that is'not applicable to this trip function. Therefore, there is no safety implication with this change.

h. .-

, ?* .

Attichment IV SAFETY EVALUATION page i1 of 23

11. Table 3.2-2. Core Sorav ;:nd RHR Pumn Start Timers (items 11 and 12)

Description These trip functions provide a time delay for pump start to prevent overloading the associated emergency bus. This change reflects deleted trip functions, is editorial in nature, and thus no further discussion is required.

Add "(Notes 7,11)" to the second column for table items 11 and 12 on page 67.

Delete "(Note 3 & 9)" from the second column for table items 11 and 12. Note 9 was used to identify single channel trip systems, and was necessary for interpretation of the generic test AOT. Since the generic test AOT has been replaced with function-specific test AOTs, this note is no longer required. Note 3 was used to iden:ify the fact that an inoperable start timer disables automatic initiation of the affected pump. As described below, Note 7 will provide revised actions for one or more inoperable start timers, including the effects on pump operability. Therefore, Note 3 is no longer required.

Change "(Note 8)" to "(Note 16)" in the fifth column for table items 11 and 12 to reflect

, renumbered notes for Table 3.2 2.

Add Note 7 to page 7la. This note provides the actions for one or more inoperable start tin.ers. The revised actions are consistent with the STS; reference Bases for Section 3.3.5.!, ftmetion 2.f. The actions consist of the following:

A. With one start timer inoperable, restore the timer to an operable status within 24 hours2.777778e-4 days <br />0.00667 hours <br />3.968254e-5 weeks <br />9.132e-6 months <br />.

B. With two or more start timers inoperable, within one hour declare the associated ECCS subsystem (s) inoperable.

C. If the required actions and associated completion times of A and B cannot be met declare the associated ECCS subsystem (s) inoperable.

Note 11 provides the revised test AOT. The revised test AOT adds a requirement that initiation capability be maintained for the redundant trip function. This is consistent with STS. Reference STS Surveillance Requirements 3.3.5.1, Note 2.

x

. / * ,

Attrchment IV SAFETY EVALUATION Page 12 of 23 Purpose The revised actions for one inoperable start timer preserve the 24 hour2.777778e-4 days <br />0.00667 hours <br />3.968254e-5 weeks <br />9.132e-6 months <br /> repair AOT as approved in Amendment 227, and as specified in the STS. If a single inoperable timer cannot be restored to an operab!c status within the repair AOT, the affected pump is declared inoperable. Declaring the pump inoperab'e ensures the appropriate LCO is entered. Under these conditions, plant operation could continue for up to 7 days, provided all other low pressure ECCS are operable. For inoperability of any one start timer beyond the repair AOT, the resulting conditions are bounded by LCO 3.5.A, " Core Spray System and Low Pressure Coolant injection (LPCI) Mode of the RilR System."

With two or more inoperable start timers, the associated ECCS subsystem (s) are declared inoperable within one hour. If only one ECCS subsystem is declared inoperable, due to two start timers being inoperable in the same subsystem, plant operation could continue for up to 7 days, provided all other low-pressure ECCS subsystems are operable. If two or more ECCS subsystems are declared inoperable, under these conditions, the reactor is placed in the cold condition within 24 hours2.777778e-4 days <br />0.00667 hours <br />3.968254e-5 weeks <br />9.132e-6 months <br /> per LCO 3.5.A. For two or more inoperable start timers the revised actions are consistent with STS Reference STS Section 3.3.5.1, function 2.f.

The effects on the associated emergency bus due to a failed timer were evaluated .

(Reference 7). The evaluation has shown that the failure of a single ECCS timer would not adversely affect another ECCS subsystem from performing its function. This is true for one '

timer failure per bus. For each emergency bus, the associated EDGs can start any two ECCS pumps simultaneously. This condition could occur with one, RilR or CS, inoperable timer per bus. Since any two of the three pumps per emergency bus can be started simultaneously, a basis is provided to remove the statement "... rack out circuit breakers..."

in Note 7 A and B of Table 3.2-2 in JPN-96-010.

If more than two timers have failed, then et least two of the four ECCS subsystems have been affected. In this case, the ECCS LCO action for two ECCS subsystems inoperable is more restrictive than the LCO action for an emergency bus inoperable. Therefore, protecting the emergency bus by racking om the affected creakers provides no added value.

The revised test AOT (Note 11) requires initiation capability be maintained to be consister.i with STS. The existing TS do not place this restriction on use of the test AOT. Each pump bas its own separate start timer, therefore capability of the redundant timer (i.e., the timer for the redundant pump) can and should be maintained during testing.

l l

Att chm:nt IV SAFETY EVALUATION Page 13 of 23 Safety Implication For a single inoperable start timer, the revised actions retain the previously evaluated 24-hour repair AOT, Upon expiration of the AOT, the resulting condition is bounded by the existing 7 day LCO for a single inoperable low pressure ECCS ibsystem. With two or more inoperable start timers, the associated ECCS subsystem (s) are declared inoperable within one hour; this is consistent with the STS. If both start timers for the same LPCI subsystem are inoperable, the condition is bounded by the 7 day LCO for an inoperable ECCS subsystem. The revised test AOT assures the capability of the redundant trip function. Therefore, there is no safety implication with the proposed change.

12. Ipble 3.2-2. Auto Illowdown Timer (Item 13)

Description This trip function provides a time delay for initiation of ADS. This change reflects deleted trip functions, is editorialin nature, and thus no further discussion is required.

Add "(Notes 8, i1)" to the second column foi table item 13.

Delete "(Note 9)" from the second column for table item 13. This note is no longer required for interpretation of the TS.

Add Note 8 to page 71a. This note provides revised actions for one or more inoperable instrumeu channels for ADS. The revised actions delete the requirement to trip one trip system within 6 hours6.944444e-5 days <br />0.00167 hours <br />9.920635e-6 weeks <br />2.283e-6 months <br /> for multiple instrument channels failures. Also deleted, is the requirement to trip an inoperable instrument channel upon expiration of the repair AOT.

The revised actions also extend the repair AOT from 2d tiours to 96 hours0.00111 days <br />0.0267 hours <br />1.587302e-4 weeks <br />3.6528e-5 months <br /> with IIPCI or RCIC inoperable, or otherwise up to 8 days. The revised actions are consistent with STS.

Reference STS Table 3.3.5.1-1, Functions 4c and Sc.

Note 11 provides the revised test AOT. The revised test AOT adds a requirement that initiation capability be maintained for the redundant trip function. This is consistent with STS. Reference STS Surveillance Requirements 3.3.5.1, Note 2.

Purpose The revised actions pennit full use of the repair AOT when multiple instrument channels are inoperable, provided that system initiation capability is maintained, and extend the repair AOT to be consistent with STS.

, / .- ,

Attachment IV SAFETY EVALUATION -

Page 14 of 23 The requirement to trip an inoperable instrument channel is deleted to be consistent with STS and to prevent override of the ADS time delay. Automatic depressurization is delayed

- to allow IIPCI time to -hQ water level and thus limit the occurrence of a severe depressurization transient on the reactor vessel. Therefore, tripping an inoperable ADS timer would defeat the time delay and thus, would not be appropriate.

l The revised test AOT requires initiation capability be maintained to be consistent with STS.

The existing TS do not place this restriction on use of the test AOT. Either of the two ADS logics can initiation automatic depressurization. Therefore, trip capability can and ,

should be maintained for the redundant trip function during testmg. 1 l

Safety implication The revised actions and AOTs are consistent with the STS requirements for this trip function. Deleting the requirement to trip an inoperable instrument channel is appropriate since tripping the channel would defeat the purpose of the ADS time delay. The extended repair AOT is consistent with STS. Adding the requirement to maintain function capability during testing is appropriate since it is provided for by design. Therefore, there is no safety implication with this change.

13. Table 3.2-2, RilR (LPCI) and Core Sprav Pumn Discharme Pressure Interlock (Items _L4 and 15)

Description These trip functions provide a permissive signal for ADS actuation. This change reflects deleted trip functions, is editorial in natare, and thus no further discussion is required.

Add "(Notes 8,11)" to the second column for table items 14 and 15.

Note 8 provides revised actions for one or more inoperable instrument channels. The revised actions delete the requirement to trip one trip system within 6 hours6.944444e-5 days <br />0.00167 hours <br />9.920635e-6 weeks <br />2.283e-6 months <br /> whenever multiple instrument channels are inoperable. Also deleted, is the requirement to trip an inoperable instrument channel upon expiration of the repair AOT. If operability of the instrument channel is not restored within the repair AOT, ADS is declared inoperable. The revised actions also extend the repair AOT from 24 hours2.777778e-4 days <br />0.00667 hours <br />3.968254e-5 weeks <br />9.132e-6 months <br /> to 96 hours0.00111 days <br />0.0267 hours <br />1.587302e-4 weeks <br />3.6528e-5 months <br /> with HPCI or RCIC inoperable, or otherwise up to 8 days. The revised actions are consistent with STS.

Reference STS Table 3.3.5.1-1, Functions 4e,4f, Se, and 5f.

Note 11 provides the test AOT that is consistent with existing TS and STS. Reference STS Surveillance Requirements 3.3.5.1, Note 2.

, [-*'.-

Attachment IV SAFETY EVALUATION Page 15 of 23 Purpese The revised actions permit full use of the repair AOT when multiple instrument channels are inoperable, provided that system initiation capability is maintained, and extend the repair AOT to be consistent with STS.

The requirement to trip an inoperable instrument channel is deleted to be consistent with STS and to prevent override of the discharge pressure icterlock. The discharge pressure interlock ensures the availability of an injection source prior to depressurizing the reactor vessel. Therefore, tripping an inoperable instrument chimnel could allow ADS to initiate without a source of injection and thus, would be inappropriate.

The test AOT is applicable to trip functions for which initiation capability is required to be maintained during testing, and does not alter the intent of the curren: TS.

Safety Implication The revised actions and AOTs are consistent with the STS requirements for this trip function. Deleting the requirement to trip an inoperable instrument channel is appropriate since tripping the channel would defeat the purpose of the discharge pressure interlock.

The e. tended repair AOT is consistent with STS. Therefore, there is no safety implication 1 with this change.

14 Table 3.2 2. RilR (I.PCI). Core Spray. ADS. HPCI. and RCIC Trin System Bus Power Monitors (items 16.17.18.19. and 20). Core Sorny Sparner to Reactor Vessel d/g (item 21). and 1.PCI Cross-Connect Valve Position (item 25)

Description Delete table items 16,17,18,19,20,21, and 25 from pages 68 and 69. The bus power monitors provide an alarm when they sense a loss of power on their respective logic bur.

The differential pressure function provides an alarm when a break is detected in the core

- spray sparger. The valve position function provides an alarm when a locked-closed valve is not fully closed.

Purpose

- These trip functions are deleted to be consistent with STS, and because they do not satisfy the 10 CFR 50.36 criteria for inclusion in the TS. These trip functions provide only control room annunciation upon detection of abnormal conditions for the associated ECCS. These functions are not relied upon for detection or mitigation of any transient or accident, are not relied upon to detect degradation of the reactor coolant pressure boundary, and are not significant to public health and safety.

1 m> - _ _ _ _ _ _ _ _ _ - - _ - - - _

Attachment IV SAFETY EVALUATION y Page 16 of 23 In addition, the aisting TS requirements for these trip functions specify that an inoperable channel be tripped upon expiration of the repair AOT. This action would serve no purpose other than to cause annunciation in the control room. ,

Upon approval of this amendment application, the operability requirements for these functions will be relocated to an Authority controlled document. In addition, the actions for an inoperable instrument channel will be revised to require that the associated parameter be monitored at least every 12 hours1.388889e-4 days <br />0.00333 hours <br />1.984127e-5 weeks <br />4.566e-6 months <br />. Any future change to the design, surveillance or operability requirements of these trip functions will be controlled under 10 CFR 50.59.

This commitment is listed in Attachment IV.

Safety implication Since these functions are not included in STS and do not satisfy the criteria for inclusion in the TS, relocation of the operability requirements to an Authority controlled document is appropriate. In addition, revising the relocated actions to require periodic monitoring of the associated parameter when an instrument channel is inoperable, rather than tripping the instrument channel, is appropriate since this preserves the purpose of the function. Any future changes to these trip functions will be controlled under 10 CFR 50.59. Thererore, there is no safety implication with this change.

15. Table 3.2-2, Condensate Storare Tank Low Level (items 22 and 23) and Sunnression Chamber Ilich Level (item 24)

Description Renumber as table items 16,17, and 18 on page 68. These trip functions transfer llPCI and RCIC suction to the suppression chamber. This change reflects deleted trip functions.

Add "(Notes 9, Il)" to the second column for the renumbered trip functions.

Change "(Note 8)" to "(Note 16)" in the fifth column for the renumbered trip functions to reflect renumbered notes for Table 3.2-2.

Add Note 9 to page 71a. This note provides revised actions for one or more inoperable instrument channels. The revised actions delete the requirement to trip one trip system within 6 hours6.944444e-5 days <br />0.00167 hours <br />9.920635e-6 weeks <br />2.283e-6 months <br /> for multiple instrument channel failures. The revised actions also provide the option to align suction for the affected system to the suppression pool, rather than tripping an inoperable instrument channel or declaring the affected system inoperable. The revised actions are consistent with STS. Reference STS Table 3.3.5.1-1, Functions 3d and 3e; and Tab:e 3.3.5.2-1, Function 3.

Note 11 provides the test AOT that is consistent with existing TS and STS. Reference STS Surveillance Requirements 3.3.5.1 and 3.3.5.2, Note 2.

.Y* ,

Attachm:nt IV SAFETY EVALUATION Page 17 of 23

Purpose The revised actions adopt the requirements of STS. STS provide a 24-hour repair AOT for this trip function, regardless of the number of inoperable instrument channels, provided that system initiation capability is maintained or suction is aligned to the suppression pool. The revised actions also allow the affected system to be aligned to the suppression pool in lieu of tripping instrument channels since this preserves the purpose of the function.

The test AOT is applicable to trip functions for which initiation capability is required to be maintained during testing, and does not alter the intent of the current TS.

Safety implication The revised actions are consistent with the STS requirements for this trip function.

Allowing the affected system to bc :.ligned to the suppression pool in lieu of tripping instrument channels is appropriate since, if aligned, the function is already performed. The intent of the test AOT is not altereu by this change and remains the same as approved in Amendment 227 (Reference 1). Therefore, there is no safety implication with this change.

16. Table 3.2-2. 4kV Fmereenev Hus Undervoltare Trin Functions (items 26. 27. 28,29.

and 30)

Description Renumber as table items 19,20,21,22, and 23 on page 69. These trip functions provide EIX) initiation and sequential restart of vital loads in the event of an undervoltage or loss of voltage condition on the associated 4160 volt emergency bus. This change reflects -

deleted trip ftmetions.

Delete "(Note 9)" from the second column for the renumbered trip functions. This note is no longer required for interpretation of the TS.

Add "(Note 10)" to the second column for the renumbered trip functions.

Change "(I pet 4kV bus)" to "(2 per 4kV bus)" in the second column, and change "2" to "4" in the fifth column for (renumbered) table items 19 and 22. This change reflects that there are two instrument channels (undervoltage relays) per trip system for a total of four inst., ment channels per trip function. Each trip system is arranged in a two-out-of-two logic arrangement,thus operability of both instrument channels is required. This change ensures consistency with De6nition 1.F.3, " Instrument Channel" and Definition 1.F.12 " Trip System." The intent of the TS is not altered by this change and thus, no further discussion is required.

, 3 * ,

Attachment IV SAFETY EVALUATION Page 18 of 23 Change "(Notes 4 and 6)" to "(Note 14)" in the sixth column for table item 19, Change

"(Notes 4 and 7)" to "(Note 15)" in the sixth column for table item 22. Change "(Note 5)"

to "(Note 13)" in the sixth column for table items 20,21,and 23. These changes reflect renumbered notes for Table 3.2-2 a..d the deletion of Note 4. The renumbered notes do not alter the intent of the TS and thus, no further discussion is required. Note 4 was used to indicate that operation could continue with an inoperable sensor, provided the inoperable sensor was placed in the tripped condition. This note is no longer required because its contents are addressed by the revised actions.

Add Note 10 to page 71b. This note provides revised actions for one or more inoperable instrument channels. The revised actions require an inoperable instrument channel be placed in trip within one hour, or the d:wted EDG System be declared inoperable. The revised actions are consistent with STS. Reference STS Section 3.3.8.1.

The deletion of "(Notes I and 2)" from the column heading " Minimum No. of Operable Instrument Channels Per Trip System," as described in Subsection 11.1, combined with the changes to renumbered table items 19,20,21,22 and 23 described above; deletes any allowance for a test AOT for the 4kV Emergency Bus Undervoltage Trip Functions. This differs from STS in that the STS allow a 2-hour test AOT for these functions, provided EDG initiation capability is maintained. The current surveillance requirements for the FitzPatrick undervoltage trip functions consist of a once-per-18-month functional test and

, calibration. These functional tests and calibrations typically require more than 2 hours2.314815e-5 days <br />5.555556e-4 hours <br />3.306878e-6 weeks <br />7.61e-7 months <br /> to complete. Therefore, based on the frequency and duration of surveillance, the 2-hour test AOT does not provide any significant operational benefit. During STS conversion, the surveillance requirements for these trip functions will be evaluated and thus, the 2-hour test AOT may be proposed at that time.

Purpose The actions are revised and the test AOT is deleted to correct an error that was introduced in Amendment 227. Existing TS would allow an unconditional (function capability not required) 6-hour test AOT and a 24-hour repair AOT for these trip functions. As discussed in Reference 2, these AOTs are not consistent with the requirements of STS and differ from the recommendations in the Licensing Topical Report (Reference 5) that formed the basis for Amendment 227.

Safety implication Since this change corrects an error in the TS. and adopts the applicable requirements from STS, there is no safety implication.

, a* .

Attachment IV SAFETY EVALUATION Page 19 of 23

17. Table 3.'.2. Heactor I..ow Prc<sure (Item 31)

Des. ription Renumber as table item 24 on page 69 to reflect deleted trip functions. This trip function ,

provides a low pressure permissive signal for closing recirculation pump discharge valves.

Add "(Notes 6,11)" to the second column for the renumbered table item.

Note 6 provides revised actions for one or more inoperable instrument channels. The revised actions delete the requirement to trip one trip system within 6 hours6.944444e-5 days <br />0.00167 hours <br />9.920635e-6 weeks <br />2.283e-6 months <br /> for multiple indrument channel failures. Also deleted, is the requirement to *. rip an inoperable instrument channel upon expiration of the repair AOT. The revised actions are consistent with STS. Reference STS Table 3.3.5.1-1, Function 2d.

Note 11 provides the test AOT that is consistent with existing TS and STS. Reference STS Surveillance Requirements 3.3.5.1, Note 2.

Purpose The revised actions permit full use of the repair AOT when multiple instrument channels are inoperable, provided that system initiation capability is maintained.

The revised actions also delete the requirement to trip an inoperable instrument upon expiration of the repair AOT to be consistent with STS. The existing TS would require placing this instrument channel in the tripped condition. As described in the Bases for STS Section 3.3.5.1, Actions C.1 and C.2, placing the channel in trip would either cause the initiation or it would not necessarily result in a safe state for the channel in all events.

The test AOT is applicable to trip functions for which initiation capability is required to be maintained during testing, and does not alter the intent of the current TS.

Safety implication The revised actions are consistent with the STS requirements for this trip function.

Deleting the requirement to trip an inoperable instrument channel is appropriate since placing the channel in trip would not always result in a safe state for the channel. The intent of the test AOT is not altered by this change and remains the same as approved in Amendment 227. Therefore, there is no safety implication with this change.

l

o ao ,

Attcchment IV SAFETY EVALUATION Page 20 of 23

18. Table 3.2-2. Notes Description Delete Notes I and 2 from page 71 and replaced with revised Notes I through 12. The revised notes appear on pages 70,71,71a, and 71b. He deleted notes provided generic actions and a generic test AOT for each trip function listed in Table 3.2-2. Revised Notes I through 12 provide function-specific actions and AOTs. This change also deletes the applicability statement that appeared in (deleted) Note 1. The applicability statement requ:res trip systems to be operable or tripped, whenever any ECCS subsystem is required to be operable. The applicability statement is not required because it duplicates LCO 3.2.B, "C(ne and Containment Cooling Systems - Initiation and Control," and the function specific k actions.

Delete Note 3 from page 71a. This note provided reference to LCO 3.5 for inoperable core spray and/or RilR pump start timers. As described in Subsection 11.11, revised Note 7 provides the actions, including affects on pump operability, for one or more inoperable start timers.

Delete Note 4 from page 71a. This note was used to indicate that operation could continue with an inoperable 4kV Emergency Bus Undervoltage Relay, provided the inoperable relay was placed in the tripped condition. As described in Subsection 11.16, thi note is no longer required because its contents are addressed by the revised actions.

Delete Note 9 from page 7ta. As described in Subsection 11.5, this note was used to identify single channel trip systems, and was necessary for interpretation of the generic test AOT. Since the generic test AOT has been replaced with function-specific test AOTs, this note is no longer required.

Renumbered Notes 5,6,7, and 8 to reflect addition of Notes 1 through 12. The revised note numbers are 13,14,15, and 16.

, Purpose The deleted, revised, and renumbered notes reflect function specific actions and AOTs that are added to the TS. The purpose of the revised actions and AOTs is discussed in the previous subsections.

Saf'ty implication The safety implications with the revised actions and AOTs are discussed in the previous subsections. The renumbered notes do not alter the intent of the TS and thus there is no safety implication with this change.

1

, &o .

Attrchment IV SAFr!Y EVALUATION Page 21 of 23

19. Table 4,2-2. Trin System ilus Power Monitors (item 6). Core Sprav Snarrer Fo (item 2h and LPCI Cross Conneet Valve Position (item 10) Surveillance Requirements Description Delete table items 6, 7, and 10 from page 80 and renumber the remaining table items.

These items specify the surveillance requirements for the bus power monitor, core spray sparger d/p, and LPCI cross connect valve position trip functions.

Purpose These surveillance requirements a c deleted to reflect removal of the associated trip functions from Table 3.2-2 (reference Subsection 11.14). Upon approval of this amendment application, the surveillance requirements will be relocated to an Authority controlled document. Any futuro changes to the design, surveillance or operability requirements for the associated trip functions will be comrolled under 10 CFR 50.59.

Safety implication Since the associated functions are not included in STS, and do not satisfy the criteria for inclusion in the TS, relocation of the surveillance requirements to an Authority controlled document is appropriate. Any future changes to the associated trip functions will be controlled under 10 CFR 50.59. Therefore, there is no safety implication with this change.

Ill. EVALUATION OF SIGNIFICANT llAZARDS CONSIDERATION Operation of the FitzPatrick plant in accordance with the proposed Amendment would not involve a significant hazards consideration as defined in 10 CFR 50.92, since it would not:

1, . involve a significant increase in the probability or consequences of an accident previously evaluated.

The proposed changes are limited to replacement of the generic actions and test AOT with function-specific actions and test AOTs, and relocation of selected trip functions from the TS to an Authority controlled document.. The changes do not introduce any new modes of plant operation, make any physical changes, or alter any operational setpoints. Therefore, the changes do not degrade the performance of any safety system assumed to function in the accident analysis. Consequently, there is no effect on the probability o. consequences of an accident.

t c

[a F*. . ,

Attachment IV SAFETY EVALUATION Page 22 of 23

2. create the possibility of a new or different kind of accident from those previously evaluated.

The proposed changes do not introduce any new accident initiators or failure mechanisms since the changes do not introduce any new modes of plant Operation, make any physical changes, or alter any operational setpoints. Therefore the changes do not create the possibility of a new or different kind of accident.

3. involve a significant reduction in the margin of safety.

The proposed changes do not alter the manner in which safety limits, limiting safety system settings, or limiting conditions for operation are determined. The relocated requirements do not satisfy the 10 CFR 50.36 criteria for inclusion in the Technical Speci6 cations.

Therefore, the changes do not involve a significant reduction in the margin of safety.

IV. IMPLEMENTATION OF THE PROPOSED CHANGES Implementation of the proposed changes will not adversely affect the ALARA or Fire Protection Programs at the FitzPatrick plant, nor will the changes impact the environment.

V. CONCLUSION Revising the Technical Specifications to adopt function specific actions and test AOTs, and relocate selected trip functions to an Authority controlled document, does not involve an unreviewed safety question or a significant hazards consideration and will not endanger the health 3 an_d safety of the public. The Plant Operating Review Committee (PORC) and Safety Review Committee (SRC) have reviewed this proposed change to the Technical Specifications and have agreed with this conclusion.

VI. REFERENCES

1. NRC letter, C. E. Carpenter, Jr., to W. J. Cahill, Jr., dated September 11,1995, issuing Amendment 227 to the James A. FitzPatrick Technical Specifications

2. NRC letter, C. E. Carpenter, Jr., to W. J. Cahill, Jr., dated December 11,1995, regarding

" Correction to Amendments 227 and 228 for the James A, FitzPatrick Nuclear Power Plant"

3. NUREG-1433, " Standard Technical Specifications for General Electric Boiling Water.

Reactors (BWR/4)," Revision 1, dated April 1995 l

I , & * ,

Attachment IV ,

SAFETY EVALUATION Page 23 of 23

4. James A. FitzPatrick Updated Fin'al Safety Analysis Report, Sections 5.3.3.4,6.4.1, 7,4.3.2.4, 7.4.3.3.2, 7.4.3.5.4,14.6.l .3.3; Figures 4.72,7.48; and Table 7.3 ! '

5 NElXS30936.P.A. Part 2, "IlWR Owners Group Technical Specification improvement Methodology (With Demonstration (4 for ilWR ECCS Actuation Instrumentation),"

December 1988

6. GE letter to NitC, dated March 22,1990, regarding "Clari0 cation of Technical Specification Changes Given in ECCS Actuation instrumentation Analysis"

7. JAF RPT EDO 02857,"New York Power Authority James A. FitzPatrick Nuclear Power Plant Analysis of Core Spray or RilR Pump Start Timer Failt.res"

8. NEDO 31466, Supplement I,

• Technical Speci0 cation Screening Criteria Application and Risk Assessment". February 1990.

8 k

._ __m_______.__. ___ _

0 h *e I

l sa Ii o l{,1,,,)P Ilgi l ill,

,l  ;

ap.< -

I k

I2 .

il t l) i,,

Ik kt br

\ * .

4 a

h t

M 93w

< 9 9

~ a g i O e .s ' *3 r-

d.

2a 1 3 um 3

z A

T ~

c 5 i

I y 1 J 4 .

1 kQ kQ kkpIO kk B -

1Q .

> h $ $

1 i" G 4 1ii

( ( (

I OI OI a O IC O E I

~

?

! i

!  ! 5 s a a 8 i ![! j iO OG i 0CI IO )O O O a E

i l .

!!i I . f

! I s  !!

til a  : g Illll! ;1*l jll sb{q'}  !!

[i I

Illllli i i

. 4 o ,

Attachment V MARKED UP TECliNICAL SPECIFICATION PAGES Inserts Insert At "1. With one or more channels inoperable for itPCI and/or RCIC:

A. Within one hour from discovery of loss of system initiation capability, declare the affected system inoperable, and H. Within 24 hours2.777778e-4 days <br />0.00667 hours <br />3.968254e-5 weeks <br />9.132e-6 months <br />, place channel in trip.

C. If required actions and associated completion times of actions A or B are not met, immediately declare the affected system inoperable.

2. With one or more channels inoperable for Core Spray and/or RilR:

A. Within one hour from discovery of loss of initiation capability for feature (s)in both divisions, declare the supported features inoperable, and B. W; thin 24 hours2.777778e-4 days <br />0.00667 hours <br />3.968254e-5 weeks <br />9.132e-6 months <br />, place channel in trip.

C. If required actions and associated completion times of actions A or B are not met, immediately declare associated supperted feature (s) inoperable.

3. With one or more channels inoperable for ADS:

A. Within one hour from discovery of loss of ADS initiation ca--t;lity in both trip systems, declare ADS inoperable, and

11. Within 96 hours0.00111 days <br />0.0267 hours <br />1.587302e-4 weeks <br />3.6528e-5 months <br /> from discovery of an inoperable channel concurrent with IIPCI or RCIC inoperable, place channel in trip, and C. Within 8 days, place channel in trip.

D. If required actions and associated comph; tion times of actions A, B, or C are not met, immediately declare ADS inoperable."

Inse111:

"4. With one or more channels inoperable for liPCI and/or RCIC:

A. Within 24 hours2.777778e-4 days <br />0.00667 hours <br />3.968254e-5 weeks <br />9.132e-6 months <br />, restore en nel to operable status.

B. If required action and associated completion time of action A is not met, immediately declare affected system inoperable.

Page 1 of 3 i

, 9o .

Att:chment V MARh'ED UP TECIINICAL SPECIFICATIJN PAGES Inserts

$. With one or more chanr:Is inoperable for containment spray:

A. Within 24 hours2.777778e-4 days <br />0.00667 hours <br />3.968254e-5 weeks <br />9.132e-6 months <br />, pce channel in trip.

B. If required action and associated compiction time of action A is not met, immediately declare associated supported feature (s) inoperable.

6. With one or more channels inoperable for injection permissive and/or recirculatina discharge valve permissive:

A. Within one hour from discovery of loss of initiation capability for feature (s)in both divisions, declare the supported features inoperable, and B. Within 24 hours2.777778e-4 days <br />0.00667 hours <br />3.968254e-5 weeks <br />9.132e-6 months <br />, restore channel to operable status.

, C. If required actions and associated completion times of actions A or B are not met, immediately declare associated supported feature (s) inoperable "

Insert Ct

" 7. A. With one start timer inoperable, restore the timer to an operable status within 24 hours2.777778e-4 days <br />0.00667 hours <br />3.968254e-5 weeks <br />9.132e-6 months <br />.

II. With two or more start timers inoperable, within one hour declare the associated ECCS subsystem (s) inoperable.

C. If the required actions and associated completion times of A and B cannot be met declare the associated ECCS subsystem (s) inoperable.

\

8. With one or more channels inoperable for ADS:

A. Within one hour from discovery of loss of ADS initiation capability in both trip systems, declare ADS inoperable, and B. Within 96 hours0.00111 days <br />0.0267 hours <br />1.587302e-4 weeks <br />3.6528e-5 months <br /> from discovery of an inoperable channel concurrent with IIPCI or RCIC inoperable, restore channel to operable status, and C. Within 8 days, restore channel to operable status.

D. If required actions and associated completion times of actions A, B, or C are not met, immediately declaic ADS inoperable.

Page 2 of 3

, *. t> .

Att: chm:nt V MARXED UP TECliNICAL SPECIFICATION PAGES Inserts

9. With one or more channels inoperable for lipCl and/or RCIC:

A. Within one hour from discovery of loss of system initiation capability while suction for the affected system is aligned to the CST, declare the affected system inoperable, and

11. Within 24 hours2.777778e-4 days <br />0.00667 hours <br />3.968254e-5 weeks <br />9.132e-6 months <br />, place channel in trip or align suction for the affected system to the suppression pool.

C. If required actions and associated completion times of actions A or 11 are not met, immediately declare the affected system inoperable."

Insert D:

" 10. With one or more channels inoperable for 4kV Emergency Ilus Undervoltage Trip Functions:

A. Within one hour, place channel in trip,

11. If required action and associated completion time of action A is not met, imraediately declare the alTected Emergency Diesel Generator System inoperable,

11. When a channel is placed in an inoperable status solely for performance of required surveillances, entry into associated Limiting Conditions For Operation and required actions may be delayed for up to 6 hours6.944444e-5 days <br />0.00167 hours <br />9.920635e-6 weeks <br />2.283e-6 months <br /> provided the associated Trip Function or the redundant Trip Function maintains ECCS initiation capability.

12. When a channel is placed in an inoperable status solely for performance of required surveillances, entry into associated Limitmg Conditions For Operation and required actions may be delayed for up to 6 hours6.944444e-5 days <br />0.00167 hours <br />9.920635e-6 weeks <br />2.283e-6 months <br />."

page 3 of 3

, * , t> .

Attachment VI 1,lST OF COMMITMENTS CORE ANI) CONTAINMENT COOLING SYSTEM INITIATION ANI) CONTROL INSTRUMENTATION (JPTS 96-002)

New York Power Authority JAMES A. FITZPATRICK NUCLEAR POWER PLANT Docket No. 50-333 DPR 59

a >=e s .

Attachment VI Ll8T OF COMMITMENTS CORE AND CONTAINMENT COOLING SYSTEM INITIATION AND CONTROL INSTRUMENTATION (JPTS 96 002)

' I Descris: tion Due Date Commitment No.

Relocate operability and surveillance Within 60 days of JAFP 98-0040-01 requirements for logic bus power monitors, Amendment issue date core spray sparger d/p, and LPCI cross-connect valve position instruments to an Authority controlled document. Revise actions for inoperable instrument channels ta require associated parameter be mon;tored at least every 12 hours1.388889e-4 days <br />0.00333 hours <br />1.984127e-5 weeks <br />4.566e-6 months <br />, rather than placing channelin trip. Ensure the Authority controlled document requires that any future changes to relocated requirements be controlled under the provisions of 10 CFR 50.59. ,

a i

- - --_-m_ _ _ _.m____ . _

, 6 - .

Attachmont V MARK UP OF REVISED TECHNICAL SPECIFICATION PAGES CORE AND CONTAINMENT COOLING SYSTEM INITIATION AND CONTROL INSTRUM:7dTATION (JPTS 96 OO2)

New York Power Authority JAMES A. FITZPATRICK NUCLEAP, POWER PLANT Docket No. 50-333 DPR 59

~ ~

4*

JAFMPP TARf F 3 2-2 CORE 'L@ CONTS--'^^"adT COm intG SYSTEM INITIATION AND Coeusss0t naastTPannaFMTATanas OPEP" ITY REmnasarnaFMTS Mmunum No. of Total Number of Operable Irstrument Insuument Channels Channels For -

• Provided by Design item Trio Svetam f Trio Furv*an Tno I_sval R ^h for beh Trio Svstams Remarks No. - {N'.:n 1 and 21i Initiates HPCI, RCIC, and Reactor Low-Low a 126.5 in. above TAF 4 (HPCI & RCIC) 1 2 SGTS.

(Mi,3 1, a ) Water Level 4 (Core Spray & RHR) Initiates Core Spray, RHR (LPCI),

2 2 Reactor Low-Low- a 18 in. above TAF and Emergency Diesei Low Waser Level Generain

[yd,3 g ,,)

Inisates ADS (if not inhstated by 4 (ADS) ADS override switches), in conpunchon with Confrmatory Low Level,120 second delay and RHR (LPCI) or Core Spray pump discharge pressore interlock.

JG I Trips HPCI turtzne.

Reactor High Water s 222.5 in. above TAF 2 (Noteftf 3 2 Laval

(%h3 3 (2) 2 ; Note Closes RCIC steam s y l 1

4 2 Reactor High Water s 222.5 in. abova TAF valve.

Level (Ndes 9,10 an DELETG 2 Prevents inadvertent 1 Reactor tow Level a o in. above TAF operahon of containment spay S 1(Note 9)) during accident corxhtion.

(insade shroud)

(&hs f,ii) Prevents inadvertent operation 1 < p < 2.7 psig 4 2 Contamment High of containment spray durity 6

Pressure accident cono, lion.

(Nelof11) j Amendment No. 6p,1,[.% h8,-22P 66

Y y

JAFf58P TAAf F 32-2 (Confdl CORE Afe CONTAME.NT COOLNdG SYSTEKlfETIATKNd M0 COfuirsOL BdSTpwafTATKlet Cm==== rTY REwwagTS Mwumum No. d. Total Number of Operable instrument instrument Channels ChanruG Per .Ddtg Provided by Desegn item Trio S for Rnth Trio Svetams Remarks Trio Ft tvi Trio L=d e ^' g tyt fp*w 1 and 21 2 Contwmatory low water 7 I g(Note 9 Low Level a 177 irt above TAF tw ADS actm (Ndo 3,II) Irutsales Cwe Spray, RHR s 2.7 psig 4 8 2 Drywe5 High (LPCI) HPCI and SGTS.

(N4 f,2,n) Pressure 4 Pemwts operung Core 2 Reactor Low P assure z 450 psig Spray and RHR (LPCI) 9 (Nd c r*/jf } insechon valves.

OJA 2 Pemuts closure of RHR Reactor Low Pressure 50 s p s 75 psig 10 1(Note 9) (LPCI) infection valves wtmle in shutdown coohng in s (Ndo 4I4) conjunction with PCIS segnal Irvtiales starting of l 11 1 Core Spray Pump 11 1 0.6 sec. 1 (Note [ core spray pump (Notesg(p) Start Tamer (ed loop) 7 j// (each soop) )

12 1 RHR (LPCI) Pump fg (Notes /g)) Start Timer 1 (Notep[l' Starts 1st Pump (A Loop) 1st Pump (A Loop) 1.0 + 0.5 (-) O sec. Starts 1st Pump (B Loop) 7/ // 1st Pump (B Loop) 1.0 + 0.5 (-) O sec. 1 (Note Starts 2nd Pur.y (A Loop) 1 (Note i4 2nd Pump (A Loop) 6.010.5 sec. Starts 2ru Pump (B Loop) 2nd Pump (B Loop) 6.01. 0.5 sec. 1 (Note if ,

Amendment No ). g. 9. 9 1p. m , 67

O JAFN8P ,

Tyu F 22-2 front d>

cn8ME ^4 enMT^-- asT enna mac- SYSTFM MemATKW AleD CONTIM3L NATEM (PsiL6 IEMMEAEasTS Muumum No. of Totd Number of Operable instrument- Insensnent Channels Channels Per Prmidad try Design item Trin Svstem Odd Trio 12:! c =- tar " *. Trio Se ^--a Ramarks k (ip^ - 1 ~ 21 Trin Fa *-,

-_ s 2 Irweiates ADS (if not inhdated 13 1 W Tener 120 sec. 5sec. W ADS menm satees).

(Ndes 5,n) Pamuts ADS actuabon.

125 psig 20 peig 8 14 4 RHR (i.PCI) Pump Discharge Pmesure Olo/cs8>/t) Inledock 100 psig i 10 psig 4 Pemuts ADS am.

15 2 Core Spray Pump 0L D'*Ch*'0* P'M*

(ydes 9 II) 1 Interlodt -

2 Mondors avadd*y RHR (LPCI) Trip Loss of Voltage 16 1 (Note 9)

System Bus Power of power to logic systems. }

uor. tor 2 IJondors avad=huy Care Spray Trip Loss of Voltage 17 1 (Note 9) of power to logic systems.

System Bus Power '

/

l l

l Amendment No. p. %, %, yl4, RT1 m

O f

JARrP .

I TABLE 12 2 dconfd cess amo ec+r- - =r c+m - sysi== mananon Amo camnon. mestnumsmunom aPenams.nr nemansumms Msumum No. of Totef Numberof l

OperaMa insensment insenenent Channels Channess Per Pansed by Demon nem T v r-- F eD k ft lar .r Tdo- -

h (f;"-- M-a *Y Tdo - - 1-- Tdo i " * ~ -- .

2 Monsors zweitetutey Laos of Vollege b8 1 (Note 9) ADS TQ System B= e=or Monsor or po -io =* symms. gag, 2 Monsors aweilahmey HPCI T.1p System Less of Votege 19 1 (Note 9) of parer to logic systems.

Bus Po or MEmitor RCIC Tsip System Laos of Voltage 2 Monsors W  !

20 1 (Note 9) of pcwor to logic systems. l Bus Pouer Montor s 0.5 paid 2 Aisnns to irwac=a.

21 1 (Note 9) Cose Spsey Sperger Core Spray sparger to Reassor Pneeum pipe book.

( Vesesi @ _

w /

n -( ,

p tank bosom sucson to suppression AW b f (*

9 Tardt Laur Level

(= 15,000 gui. sweig chamber. p g I

Transfers HPCI purap 2 Condensets Stamps a 59.5 in. above tank 2 (NotoffIf suction to suppseesson

'h 23 (yg, 9 y ) Tank Low Level bosom

(=15,000 gel aves) chamber.

1 2 (Notoff//, Transfers HPCI pump 2 Suppmosion Chamber s 6 fr'. above nonnel suchon to suppreemon JWf 3 ' Hipt l Laval level m'

(Nbs 9, II ) -

' A %x wt Alarms when vafwe l LPCI Cmes-Connect NA 1 (Note 8) ' Oclele f25 is not dosed.

1 (Note 9) telse Pomeon rmeadmma No. A p. e s .p. ny ,

% id

> c~? 7: -

\l i h

i 11 .

11 di li e = lW]i ir lj 1

a 1diiIllitir k ~ ~T ~ -

s j nl i. .

lf  ! i i  !

1 t .

~

~

F :: i i5 i  !

!li f  ! i i  !

f! i E

sg I i1 .

a s i.i.,....~

l}]k si @1 4 P i h Jl' l*l

l=l

i 2 ik.

E -

ja jr!f}

,!hljqI

!  ;}i11 1 Il 1 t h'I is

,1 1i13.l11.l,!j 1 ill ,

5 il Iil't.itjpp, I

lii11ill9ill1 i1 IILl gl il r '

~

d 1liitjja l i 1 il l li Il i 1

I!I

,n u Ih!!!lliI!!!lll'!r pi ni 1 illl !b !!i 4

nI l 11

}! i

> m 1p:

! :e