ML20211N966

Requests Addl Info Re 961030 Ies Utilities Inc Submittal, Requesting Amend to Convert DAEC TS to Improved TS

ML20211N966
Person / Time
Site:	Duane Arnold
Issue date:	10/03/1997
From:	Kelly G NRC (Affiliation Not Assigned)
To:	Leslie Liu IES UTILITIES INC., (FORMERLY IOWA ELECTRIC LIGHT
References
TAC-M97197, NUDOCS 9710170181
Download: ML20211N966 (78)

Text

.

Octobere3,1997 Mr. Lee Liu Chairman of the Board and Chief Executive Officer IES Utilities Inc.

200 First Street, SE.

P.O. Box 351 Cedar Rapids,IA 52406-0351

SUBJECT:

DUANE ARNOLD ENERGY CENTER (DAEC)- REQUEST FOR ADDITIONAL INFORMATION ON Tile DAEC IMPROVED TECliNICAL SPECIFICATIONS (ITS)(TAC NO. M97197)

Dear Mr. Liu:

On October 30,1996, IFS Utilities Inc. submitted a request for a license amendment to convert the DAEC Technical Specifications to ITS. The staff requires additional information in order to comple:e its review. This request was inadvertently deleted from an earlier request for additional information (RAI). The enclosed questions cover Sections 3.10.2 to 3.10.8.

Sincerely, Ghenn elIf, ONiorhrojeft tIfa*n#"ge a

Project Directorate 1113 Division of Reactor Projects III/IV Office of Nuclear Reactor Regulation Docket No. 50-331 1

Enclosure:

RAI 1

_IO$,l cc w/o encl: See next page Distribution w/ encl:

w/o encl: EAdensam (EGA1)

Docket File GMarcus PDill-3 R/F GGrant, Rill PUBLIC i t t,' d 4 ACRS OGC (015 B-18)

G:\\DUANEARN\\97197RAK.WPD OFFICE PM:PDill-3 E LA:PDill-3 l E NAME GKelly (})2FCBoyle M L:,c"

.i O (~; j y E-3 h

• 3 DATE 10/ J/97/ f*'

10/4 /97 0 OFFICIAL RECORD COPY hl h l l ll 9710170181 971003 PDR ADOCK 03000331 P

PDR

Mr. Iee Liu

. October 2, 1997 l

Chairman of the Board and Chief Executive Officer

)

IES Utilities Inc.

200 First Street, SE.

j P.O. Box 351 Cedar Rapids, IA 52406-0351

SUBJECT:

DUANE ARNOLD ENERGY CENTER (DAEC)- REQUEST FOR ADDITIONAL INFORMATION (RAI) ON THE DAEC IMPROVED TECHNICAL SPECIFICATIONS (ITS) (TAC NO. M97197)

Dear Mr. Liu:

On October 30,1996, IES Utilities Inc. submitted a request for a license amendment to convert the DAEC Technical Specifications to ITS. The staff requires additional information i

in order to complete its review. The staff requests that you provide a response to the enclosed questions within 30 days to meet the staff's review schedule. The enclosed questions cover Section 3.3.

Sincerely, Original signed by:

Glenn B. Kelly, Senior Project Manager Project Directorate III-3 Division of Reactor Projects III/IV Office of Nuclear Reactor Regulation Docket No. 50-331

Enclosure:

As stated cc w/o encl: See next page Distribution w/ encl:

Docket File-PUBLIC PDIII-3 R/F

- w/o encl:

EAdensam (EGA1)

GGrant, RIII ACRS OGC,015B18 GMarcus G:\\DUANEARN\\97197 RAT.WPD OFFICE PM:PDIII;3,,j E LA:PDIII-3,l E NAME GKelly //JM CBoyle 6%

DATE 0/>/97

/0/'h97 OFFICIAL RECORD COPY

PCEcoq p

t UNITE') OTATES g

j NUCLEAR REGULATORY COMMISSION WASHINC f 0N 0.0. 30e86-4001 o

s., ***/

f.ctober 2, 1997 Mr. Lee Liu Chairman of the Board l

and Chief Executive Officer IES Utilities Inc.

200 First Street, SE.

P.O. Box 351 Cedar Rapids, IA 52406-0351

SUBJECT:

DUANE ARNOLD ENERGY CENTER (DAEC) - REQUEST FOR ADDITIONAL INFORMATION (RAI) ON THE DAEC IMPROVED TECHNICAL SPECIFICATIONS (ITS) (TAC NO. M97197)

Dear Mr. Liu:

On October 30,1996, IES Utilities Inc. submitted a request for a license amendment to convert the DAEC Technical Specifications to ITS. The staff requires additional information in order to complete its review. The staff requests that you provide a response to the enclosed questions within 30 days to meet the staff's review schedule. The enclosed 4

questions cover Section 3.3.

j Sincerely,

/

/

n

/

Glenn B.

lly, Se or Pr et Manager Project Directorate III-3 Division of Reactor Projects III/IV Office of Nuclear Reactor Regulation Docket No. 50-331

Enclosure:

As stated 4

cc w/o encl: See next page

e Lee Liu Duane Arnold Energy Center IES Utilities Inc.

9 cc:

Jack Newman, Esquire Kathleen H. Shea, Esquire Morgan, Lewis, & Bockius 1800 M Street, NW.

J Washington, DC 20036 5869 Chairman, Linn County Board of Supervisors 4

Cedar Rapids, IA 52406 IES Utilities Inc.

ATTN: Gary Van Middlesworth Plant Superintendent, Nuclear 3277 DAEC Road Palo, lA 52324 John F. Franz, Jr.

Vice President, Nuclear Duane Arnold Energy Center 3277 DAEC Road

' Palo, lA 52324 Ken Peveler Manager of Regulatory Performance Duane Arnold Energy Center 3277 DAEC Road Palo, IA 52324 U.S. Nuclear Regulatory Commission Resident inspector's Office Rura! Route #1 Palo, IA 52324~

Regional Administrator, Rlli U.S. Nuclear Regulatory Commission 801 Warrenville Road Lisle, IL 60532 4531 Parween Baig

' Utilities Division lowa Department of Commerce Lucas Office Building, 5th floor Des Moines, IA 50319

DAEC ITS 3.3.1.1 REACTOR PROTECTION SYSTEM (RPS) INSTRUMENTATION September 18,1997 3.3.1.1 DOC.

LJFD LCHANGE/ DIFFERENCE:

COlWMENT.

STATUS.

1 LAV CTS 2.1.A.1, CTS Table 3.1.1, ITS Table 3.3.1.1-1, Acceptance of these changes for ITS OOS and ITS Table 3.3.1.1-1, Footnote (b), all define Trip outside the :: cope of TSB review and are Level Settings that represent Limiting Safety Systems contingent upon Staff approval of NEDC-Settings. The change is the use of Allowab!e Values in 31336 and its applicability to DAEC the ITS instead of the Trip Level Setting in the CTS.

Instrument Setpoint Methodology The CTS defined the Trip Level Setting as a fixed value program.

or, in the case of APRMs, a linear formula that is presented as a table of solutions in the ITS. Each CTS Table 3.1.1 setpoint is increased by a small allowance for the Allowable Values in ITS Table 3.3.1.1-1. The allowances are established by DAEC Instrument Setpoint Methodology which is based on the General Electric (GE) inst; ment Setpoint Methodology; NEDC-31336.

2 R12 This change moves the CTS Umiting Safety System 50.36 requires LSSS to be included in OOS Setting along with Trip setpoints in CTS Table 3.1-1 are TS. CTS LSSS are replaced with moved to a licensee controlled document.

Allowable Values. Both LSSS and Allowable values are specified in the staff approved setpoint methodology.

Provide documentation of staff approval to replace trip setpoint LSSS with ellowable values for ITS RPS functions.

The acceptance of these changes is outside the scope of TSB review.

1

DAEC ITS 3.3.1.1 REACTOR PROTECTION SYSTEM (RPS) INSTRUMENTATION September 18,1997 3.3.1.1--

DOC JFD JCHANGE/ DIFFERENCE COMMENT STATUS 3

R2 The terms and definitions (S and W) for the setting of Provide documentation of staff approval OOS the APRM Flow Biased High Scram equation in CTS that the proposed ITS A8!cwable Values 2.1.A.1 are moved to a licensee controlled document.

limits are equivalent to CTS equation limits over the entire range of the S and W variables. Verify that the safety analysis assumptions are preserved by the proposed AVs over the entire range of S and W. Acceptance of these changes are outside the scope of TSB review.

4 None CTS 3.1.A.1 is changed from "With one channel Provide discussion and justification for required by Table 3.1-1 inoperable" to "One or more the revised CTS actions.

required channels inoperable," in ITS 3.3.1.1 CONDITION A. This change to CTS requirements is not discussed orjustified.

5 None CTS 3.1.A.2 is changed from "With two or more Provide discussion and justification for channels required by Table 3.1-1 inoperable" to "One the revised CTS actions.

or more Functions with one or more required channels inoperable in both trip systems,"in ITS 3.3.1.1 CONDITION B. This is a significant change of meaning to CTS that is not discussed orjustified.

2

DAEC ITS 3.3.1.1 REACTOR PROTECTION SYSTEM (RPS) INSTRUMENTATION September 18,1997 JJFD-

CHANGE / DIFFERENCE TCOMMENTlL STATUS 3.3.1;1

DOC?

6 R8 CTS 4.1.A.2 contains details of the Staggered Test Provide aidetional discussion and Basis Frequency of testing for the RPS Functions of justification for changes to frequency for Reactor Vessel Water Level-Low and Reactor Vessel testing RPS Functions that result from Steam Dome Pressure - High. This detail states that changing the fuel cycle to 24 months the reactor trip system response time test shall include from 1S months r.nd from the revised at least one logic train such that both logic trains are Staggered Test Basis definition.

tested at least once per 36 months. This detail is not in the ITS and is moved to plant procedures.

7 Lcy2 PS CTS 4.1.A.2 requires RPS Response Time testing This extension of the Surveillance Test OOS every 18 months on a staggered basis. ITS SR Intervalis outside the TSB scope of 3.3.1.1.18 and ITS SR 3.3.1.1.19 extend tSis review. Combine SR 3.3.1.1.18 and 19 surveillance interval to 24 months. The extension of into a single SR for consistency with the the Surveillance Test intervalis based on a ten year RPS RT TS definition.

review of surveillance test failures and review of the database for 10CFR50.65 (Maintenance Rule).

8 None CTS Table 3.3-1, Function 2.b, is changed from APRM Provide discussion and justification for Neutron Flux - Upscale to APRM Flow Biased - High in proposed changes.

ITS Table 3.3.1.1-1, Function 2.b. This deletion of CTS requirements is not discussed orjustified.

3

l i

1 DAEC ITS 3.3.1.1 REACTOR PROTECTION SYSTEM (RPS) INSTRUMENTATION September 18,1S' 7 9

1 i

.i I

3.3.1.1' DOC..JFD CHANGE / DIFFERENCE COMMENT STATUS 9

L3 CTS Table 3.1-1 Action 6 requires initiation of a Provide discussion and justification for i

reduction in Thermal Power within 15 minutes and to the deichon of the requirement for

[

reduce Thermal Power to less than 30% RTF, within 2 trwtiation of a reduction in Thermal Power hours for the RPS Trip Functions of Turbine Stop Valve within 15 mmutes. The proposed Bases

[

Closure and Turbine Control Valve Fast Closure. ITS cite

• cpm.iicnal expenence* as a reason i

3.3.1.1 Action E allows 4 hevrs to reduce Thermal for the coinpiebon time. Provide p; ant

}

Power to less than 30% RTP with no restriction on data that supports the Bases reason for initiation of a reduction in Thermal Power wrthin 15 the CT.

l minutes.

i i

10 A13 CTS Table 4.1-1, Footncte (f), requires t.Se LPRMs Provide calculations that support

[

calibrated at least once per 1000 ef'ective full power proposed changes.

l hours (EFPH). ITS SR 3.3.1.1.8 requires this LPRM i

calibration every 1000 MWDTT average core exposure.

i While the CTS and ITS Frequencies are similar, they j

are not exactly the same. The CTS Frequency of 1000

)

EFPH is approximately 958 MWDfr.

L 11 P54 STS 3.3.1.1 derened the Allowable Vr. lues in the case Provide documentabon of the staff of APRMs as a finear formula that is presented as a acceptance of allowable values at j

table of solut on? in ITS 3.3.1.1. This process deletes discrete flow poets.

the aQJe values on all intermediate values.

l L

l 4

l t

DAEC ITS 3.3.1.1 REACTOR PROTECTION SYSTEM (RPS) INSTRUMENTATION September 18,1997 3.3.1.1 DOC JFD CHANGE / DIFFERENCE COMMENT STATUS

/

12 L4 CTS Table 4.1-1, Function 1, requres a Channel Acceptance of this change is outsede *.he OOS Calibration of the IRMs on every controlled shutdown.

scope of TSB review and is contingent ITS SR 3.3.1.1.14 only requires performng this SR upon NRC approval of NEDC-30651-P-A every 24 months. This change is justified by NEDC-for DAEC.

30851-P-A, Technical Specification Improvement Analyses for BWR Reactor Protection System, March 1988, as applied to thilplant.

I 13 UC The Frequency of performng the Channel Calibration Acceptance of this charige is outside the OOS surveillance of CTS 4.1.A.1 and CTS Table 4.1-1 is scope of TSB reviewand cvidugad extended to facilitate a change to the plant operating upon NRC approvd of NEDC-31336 and cycle from 18 months to 24 months in ITS SRs its oppik it.ny ta DAEC Instrument 3.3.1.1.14 and 3.3.1.1.16. The proposed change Setpoint Me6odology pirrgi u.

extends the Surveillaw. Frequency from the current 3 month Surveillance Frequency for Table 4.1-1 Functions 4, and 6, and from the current 6 month Surveillance Frequency for Table 4.1-1, Function 10, to a 24 month Surveillance Frequency. Historical as-found and as-left data was utilized in die that assumptions of values for vendor-specified drift were conservative. Where these assump*Jons were not validated, historical drift was utilized directly using the y

second moment about zero (SMAZ) method described l

in NEDC-31336-A.

5

DAEC ITS 3.3.1.1 REACTOR PROTECTION SYSTEM (RPS) INSTRUML MTATION September 18,1997 3.3.1.1 :

DOC JFD CHANGE /DlFFERENCE COMMENT STATUS 14 LCY The Frequency of performing the Channel Calibration Acceptance of this change is outside the OOS surveillance of current Surveillance 4.1.A.1 and Table scope of TSB review and c.cidowd 4.1-1 is extended in ITS SRs 3.3.1.1.14 and 3.3.1.1.17 upon NRC approval of NEDC-31336 and from 18 months to 24 months. Historical as-found and its applicability to DAEC Instrument as-left data was utilized to validate that assumptions of Setpoint Methodology piegr.ca values for vendor-specified drift were conservative.

Where these assumptions were not validated, historical ddft was utilized directly using the second moment about zero (SMAZ) method described in NEDC-31336-A.

15 A3 ITS SR 3.3.1.1.15 adds a LOGIC SYSTEM Acceptance of this change is outside the OOS NTIONAL TEST to CTS 4.1.A.1 and sets the scope of TSB review and is contingent interval to 24 months. Ne discussion orjustification for upon staff acceptance of the proposed 24 24 mordhs is provided. This is an extension of the CTS month fuel cycle.

operating cycle surveillance interval froin 18 rnonths to 24 months.

16 M5 ITS SR 3.3.1.1.3 is added to the CTS Table 4.1-1 NRC approval of NEDE-30851P-A requiring that the automatic scram contactors be accepts a channel functional test.

" functionally tested

• weekly whereas the STS require a Evaluate the CTS changes and provide weekly "CFT*

staff acceptance of the proposal to replace the NEDO CFT with a functional test.

6

4 l

l DAEC ITS 3.3.1.1 REACTOR PROTECTION SYSTEM (RPS) INSTRUMENTATION September 18,1997

[

3.3.1.1 DOC JFD CHANGE / DIFFERENCE COMMENT STATUS 17 L5 CTS Tables 3.1-1 and 4.1-1 require Operabainty of the Acceptance of this change is outside the OOS APRM RPS Trip Funchons of Neutron Flux-Upscale, scope of TSB review and is cm--a-@d

+

in Startup and inoperative in Mode 5. In addition, CTS upon NRC approval of the Wty of i

2.1.A.2 requires Operability of the APRM RPS trip Limenck Units 1 and 2 (NPF-39 and j

function of Neutron Flux-Upscale, in Startup for Mode NPF-85) amendments 41 and 7 to l

l S. Proposed ITS 3.3.1.1 do not require APRM DAEC.

Functions in Mode 5. Justification is based on I

f Amendments 41 and 7 to I.unenck Generating Station q

Units 1 and 2 (NPF-39 and NPF-85), issued July 30,

]

1990, and its SER.

l t

18 L9 P63 ITS 3.3.1.1 Actions are modified by a Note Delete this proposed change. RPS delaying entry into the Conditions and SR Notes are based on approved i

Required Actions for two hours, iciieding the topical reports. Provide a revised

[

DAEC operating practice of not entering topical report for staff review and l

i Required Actions for Conditions caused by approval.

t performing Surveillance Requirements. The addition of a time limit on the allowance is l

based on DAEC GL-89-10 Motor Operated t

Valve (MOV) Program (J. Franz (lES) to W.

l Russell (NRC), " Generic Letter 89-10 l

Program," NG-94-4017, November 30,1994).

The same justification is used for the added J

allowance to STS 3.3.1.1. CTS and STS Completion Time is extended 2 hours2.314815e-5 days <br />5.555556e-4 hours <br />3.306878e-6 weeks <br />7.61e-7 months <br /> by this i

change.

i 7

f l

?

i DAEC ITS 3.3.1.1 REACTOR PROTECTION SYSTEM (RPS) INSTRUMENTATION September 18,1997 3.3.1.1 DOC' JFD

CHANGE / DIFFERENCE COMMENT STATUS l

19 LAV This change revises CTS Table 3.1.1 Trip Acceptance of this change is l

OOS Level Settings in ITS Table 3.3.1.1-1 outside the scope of TSB review instrumentation to reflect Allowable Values and is contingent upon NRC i

rather than setpoints found in the plant approval of NEDC-31336 and its procedures. These Allowable Values are applicability to DAEC Instrument established by DAEC Instrument Setpoint Setpoint Methodology program.

Methodology which is based on the General i

Electric (GE) Instrument Setpoint Methodology; l

NEDC-31336, General Electric Instrumentation

[

Setpoint Methodology. The Allowable Value forThe CTS Limiting Safety System Setting 2.1.A.2, APRM Scram,2.1.A.3, IRM Scram, l

2.1.B Reactor Vessel Low Water Level and 2.2.A, Reactor Vessel High Pressure Scram, l

are the same as the CTS Table 3.1.1 i

setpoints. The iTS Allowable Value is in the non-conservative direction, thus extending the CTS Limiting Safety System Setting beyond the plant licensed value. This appears to be a j

misapplication of NEDC-31336.

l l

8 i

e

O DAEC ITS 3.3.1.1 REACTOR PROTECTION SYSTEM (RPS) INSTRUMEhTATION September 18,15i97 3.3.1.1' DOC JFD CHANGE / DIFFERENCE COMMENT STATUS 20 A4 P7 ITS Table 3.3.1.1-1, Note (b). Setpoint gain Reject. The option to establish ITS adjustnants are used to establish interim flow limits that are underthe biased scram and rod block setpoints when administrative control of the single loop operations are entered. Current licensee is a generic change and practice is to use a procedural time limit of 72 has not been accepted by the staff hours. The proposal is to provide the option to for STS.

reset ITS Allowable Values when entering SLO, or the licensee can calibrate the APRMs.

21 A9 Trip level setting scram fast closure scram time Revise DOC and resubmit as a is moved to Bases. This "A" DOC is used to relocated change.

remove CTS requirements to the Bases.

22 A10 Channel Function Testing to be performed Revise DOC arid resubmit as a "L" prior to Star n is deleted through DOC.

m implementr;

. of ITS SR 3.0.4, which specified a.: R are to be met priorto entry into appficable conditions.

9

y DAEC ITS 3.3.1.1 REACTOR PROTECTION SYSTEM (RPS) INSTRUMENTATION September 18,1997 3.7.1.1 DOC

'JFD CHANGE / DIFFERENCE COMMENT STATUS 23 L1 RPS instrument function requirements for The DOC does not provide enough Modes 3 and 4 are deleted and requirements of a safety basis justification for the in ITS 3.10.3 and 3.10.4 are added for Modes proposed changes.

3 and 4.

24 L4 The DOCjustifies eliminating a CTS Provide NEDO-30851 citatiorm to OOS requirement to perform IRM Channel support the deletion. Acceptuce Calibrations every controIIed shutdown. The of the changes is beyond the proposed ITS SR extension is based on a plant scope of TSB review. Provide specific evaluation for NEDO-30851.

reference to staff SE that accepted plant specific reference.

25 M2 Time limits are proposed to delay performance Provide discussion that explains of CFT and Channel Calibration SRs once why the proposed enhancements Mode 2 is entered from Mode 1. The CTS do not present a safety issue in the does not currently impose time limits for operation of the plant.

performing these SRs once Mode 2 is entered from Mode 1.

26 P6 The ITS proposes changes to sensor The STS definitions permit testing Response Time Test from the channel which is equivalent to the proposed (function) RTT.

ITS SRs 3.3.1.1.18 and 3.3.1.1.19.

Revise the ITS to adopt the STS format.

10

-=

I I

DAEC ITS 3.3.1.1 REACTOR PROTECTION SYSTEM (RPS) INSTRUMENTATION September 18,1997 j

3.3.1.1 DOC JFD CHANGE / DIFFERENCE COMMENT STATUS 27 P63 The ITS proposed to insert a note to Actions Rejected.This proposed ITS i

that permits a 2 hour2.314815e-5 days <br />5.555556e-4 hours <br />3.306878e-6 weeks <br />7.61e-7 months <br /> delay in declaring an change is rejected because it is i

instrument channel inoperable during generic and the STS provide performance of SR 3.6.1.3.7 (EFCV) testing at appropriate remedial actions for the specified 18 month frequency.

performing TS required testing.

[

l 28 R2 P7 The proposed ITS includes Single Loop reset The acceptance of the proposed OOS P54 Allowable Values which specify AVin change is beyond the scope of i

increments of 25% of recirculation flow. The TSB review.

CTS uses a loop flow equation (variables W and delta W) which is consistent with STS

(

format.

l i

29 P9 The ITS proposes a new Setpoint methodology Acceptance of the proposed OOS and Allowable Value limits.

changc is beyond the scope of TSB review.

I l

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f i

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11

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t i

i DAEC ITS 3.3.1.1 REACTOR PROTECTION SYSTEM (RPS) INSTRUMENTATION September 18,1s97 l

I 3.3.1.1 DOC JFD CHANGE / DIFFERENCE COMMENT STATUS l

30 L8 P64 The CTS Manual Scram functional test Acceptance of this change is OOS frequency is increased to quarterly from beyond the scope of TSB review.

weekly. The discussion refers to a desig.

This change to the CTS requires difference and test configuration of the DAEC HICB staff review and approval.

i 2-push-button design and the NEDO-308514-f push-bottom design. Automatic scram contactors are exercised weekly using RPS i

Test Switches instead of the Manual Scram l

Push-buttons.

l i

1 31 LCY Generic Letter 91-04 changes in TS Acceptance of changes forITS is OOS 2

surveillance interval to acconiniodate a 24-beyond the TSB scope of review i

i month fuel cycle.

and is contingent of staff review and approval of Generic Letter 91-04 for DAEC.

i 32 L7 P58 Proposed deletion of RPS trip on high pressure Revise L7 and P58 to provido a is based on relay logic design at DAEC.

design-based discussion for the change to the CTS and the STS.

l

(

i 2

l

{

I

DAEC ITS 3.3.1.2 SOURCE RANGE MONITOR (SRM) INSTRUMENTATION August 21,1997 3.3.1.2 DOC JFD CHANGE / DIFFERENCE COMMENT STATUS 1

all M-DOCS explain proposed changes to the CTS. No M's justification is provided for including the resulting enhancement in the ITS.

2 none ITS adds SR 3.3.1.2.7 which requires a Channel Provide justification for the 24 morrJi Calibration in Modes 2 and 5 every 24 months. No Channel Calibration frequency.

justification is provided for the 24 month frequency. The STS contains a frequency of 18 months.

3 none DOC is not provided for CTS changes that result from Submit a DOC for these CTS changes.

adopting the Note to SR 3.3.1.2.4.

4 R.2 CTS descriptions are moved to unspecified licensee Provide additional discussion including controlled documents.

which specificlicensee contro!'ed documents include the CTS requirements CTS 3.9.B.3 requires that prior to spiral reloading, two to for " prior to spiral reloading" and Mich four fuel assemblies which have previously accumulated have previously accumulated exposure in exposure in the reactor brs loaded next to each of the four the reactor.*.

SRMs to obtain the requi.W 3 cps. The Note to ITS SR 3.3.1.2.4 does not require meeting the 3 cps with 5 4 fuel assemblies adjacent to the SRM and no other fuel assemblies in the associated core quadrant. The iTS does not specrfy " prior to spiral reloading" and "which have previously accumulated exposure in the reactor.*

5 M6 Added SR mode applicability requirements are incomplete Rev se DOC M6 for SR 3.3.1.2.6 and SR 3.3.1.2.7.

1

DAEC ITS 3.3.1.2 SOURCE RANGE MONITOR (SRM) INSTRUMENTATION August 21,1997 3.3.1.2 DOC JFD CHANGEDFFERENCE COMMENT STATUS 6

L1 The L DOC does not idenbfy the CTS changes that result Revise DOC L1 from @g the ITS. The L DOC does not justify that one SRM is sufficent dunng spiral offload or reload.

7 L2 The DOC does not jushfy deiebng CTS regthements for Revise DOC L2 the SRMs to be operable in Mode 2 with the IRMs on Range 3 or above.

2

O DAEC ITS 3.3.2.1 CONTROL ROD BLOCK INSTRUMENTATION August 25,1997 3.3.2.1 DOC JFD CHANGEMNFFERENCE CORWENT STATUS 1

R.2 Pivpcxd changes include moving requirements to Provide arMiharel hm and autornabcaNy bypass the RBM when penpheral control jushficahon idenbfyng why the design rods are selected to the Bases.

feature for automshc RBM bypass is not required in theITS to ensure RBM operability and as such can be appropnately contro5ed by the Bases.

i.

.2 R.3 R3-Prowde addibonalhm and R.4 Daily channel checks of the RBM upscale and doomscale jushficebon for why the surveitance (R.3) funcbons are moved to plant procedures. Jushficahon is and the clanficahon (R.4) are not requred based on the STS not including the surveillance.

to be in ITS to ensure RBM operability.

fL4 -

Docuss why it is appropnote to include The clanficahon that the RBM CFT includes the reactor these CTS requrementsin the Raama, manual control mulbpiexing system input is relocated to the Bases. Jushficahon is based on the STS not including the surveillance.

l

?

3 DAEC iTS 3.3.2.1 CONTROL ROD BLOCK INSTRUMENTATION August 25.1997 i

3.3.2.1 DOC JFD CHANGE / DIFFERENCE COMMENT STATUS 3

R.5 This change moves the trip settogs in the Trip Level This addsbon of Allowable Values to the k

OOS Se g column in CTS Table 3.2-C and replace them with Acceptance of this. wge for the ITS is tt Iowable Value in ITS Table 3.3.2.1-1. The added beyond the scope of TSB scope of review.

l A-able Values for the RBM trips are taken from NEDC-a 308 J-P. Average Power Range Monitor, Rod Block Acc.ept.nce of this change is cvui-@si Monitor and Teclu ac.i SWTwGen improvement (ARTS) upon staN approval of NEDC-30813-P.

3 j

Program for the Duane Arnold Energy Center, December 4

1984. In addition, the Trip Level Settogs in CTS Table Prowde addibonaldiscusskriand

)

32-C are moved to licensee cunh vried documents.

MTwGen showog why t.;p level settings These documents are not idenbfied.

are not required in the ITS to ensure RBM operab3ity. Discuss why the TS Bases are an oppivyii.ie document for these items.

l i

sion d jwhiwiun idenbfyng the licensee coubv".cd documents centicare the i

moved trip setpomts.

I i

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2 c

DAEC ITS 3.3.2.1 CONTROL ROD BLOCK ?NSTRUMENTATION August 25.1997 3.3.2.1 DOC JFD CHANGE / DIFFERENCE COMMENT STATUS 4

L2 CTS 3.3.A.2.e and 3.3A2.f for inoperable control rods Accept.cc of this ctwg is beyond the OOS requwe that when the reactor is less than 20% power, a scope of TSB review and is croangi t veiifn tkai be made that all inoperable control rods not in upon staff approval of NEDE-24011-P-A.

compliance with BPWS are sc-p n ted by 2 or more Operable control rods in any (m ecGcni, meluding the diagonal. CTS 3.3.C.1 for tne Rod Worth Minimizer (RWM) requwes RWM Operabihty whenever the reactor is Opc,.ing at less than 20% power. ITS 3.3.2.1 contains the analybcallimit of < 10% RTP instead of the nominal trip setpont of < 20% RTP. For the control rod drop G-d, the BPWS and RWM are not requ; red to limit control rod worth when Opci inig at > 10% RTP, as desenbed in NEDE-24011-P-A, General Electnc Standard Appik Goti for Reactor Fuel, Revision 8. Amendment 17.

5 M.1 LCO requwements are proposed for the bypass time Prim $ed addibonaldiscussion and delays. Currently, these requwements are incir.1ed in jtmGin,.Grai ?xplaming the use of plant fxucedures.

opgA baty notes (d) & (e) for the DAEC plant design.

6 L5 A one hour a810wance is provided in Notes to ITS SRs Provide diset.* and juurdno. for 3.3.2.1.2 and 3.32.1.3 to permit the plant to enter the these proposed ciw.vec to CTS.

A condibon before performmg requwed surveillances. The addebon of the Notes makes the pivpcr,cd regtprerment for a Channel Ft,.ct;cn I Test less restrictive because De Surveillance Test is ch.igc-d to until 1 hour1.157407e-5 days <br />2.777778e-4 hours <br />1.653439e-6 weeks <br />3.805e-7 months <br /> after the RWM is requwed operable from prior to operability requwements.

3

O DAEC ITS 3.3.2.1 CONTROL ROD BLOCK INSTRUMENTATION August 25,19D7 3.3.2.1 DOC JFD CHANGE / DIFFERENCE COMMENT STATUS t--

i 7

L3 The instrument functivnal test of the RBM is proposed to Provide add.4ional discussion and be deleted.

justification identifying why those testing requirements that remain in the ITS provide an adequate basrs for demonstrating operability based on the DAEC plant desgrt 8

L7 ITS 3.3.2.1 contains Note 2 to tne Surveillances that Acceptance of this dage is beyond the OOS allows an RBM channel inoperable for up to 6 hours6.944444e-5 days <br />0.00167 hours <br />9.920635e-6 weeks <br />2.283e-6 months <br /> for TSB scope of review and is ccnau gent the performance of required Surveillances before upon staff approval of the use of GENE-requiring entry into associated Conditions and Required 770-06-1 as it is applicable to DAEC.

Actions. This a!!owance is not in the CTS. Justification is based on GENE-770-06-1, Bases for Changes to Survei!!ance Test Intervals and A!! owed Out-of-Service Times for Selected Instrumentation Technical Specifications, February 1991.

9 LAV P10 This change revrses the Ted nical Specification setpoints This change to CTS Setpoin*JArmbie OOS for ITS 3.3.2.1 instrumentation to reflect A!!owable Values Values is outsde t!m TSB scope of review.

rather than setpoints found in the plant procedures.

Provide additional discussion and These A!!awable Values are established by DAEC justification for the dwge.

Instrument Setpoint Methodology which is based on the General Electnc (GE) Instrument Setpoint Methodology, Acceptance of this change is ccnL event NEDC-31336, General Electric Instrumentation Setpotnt upon staff approval of NEDC-31336 Methodology.

applicability to DAEC instrument Se point Methodology p vwiani.

4

DAEC ITC 3.3.2.1 CONTROL ROD BLOCK INSTRUMENTATION August 25,1997 3.3.2.1 DOC JFD CHANGE / DIFFERENCE COMMENT STATUS 10 none CTS Table 4.2-C requaes a CHANNEL FUNUTIONAL Acceptance of this dw.ve to the CTS OOS TEST of the Reactor niode Switch - Shutdown Posibon on Surveillance Test interval is outsde the a refueling interval (18 months). ITS SR 3.3.2.1.6 TSB scope of review and is conbnoent dw.wes this interval to 24 months. No <5=rs== ion or upon staff @>c= of the 24 aoniMest

)4A2:en is provided.

and fuel cyde interval 11 none CTS 3.3.C.t.a is noted to be ITS Achon D. Achon D Provide discussion and just:fication appises to RWM inoperable in shutdown, whereas, CTS clanfying translabon of CTS requwements 3.3.C.1.a applies to RWM inope able after 12 rods are to ITS Achon D.

I fury withdrawn.

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DAEC ITS 3.3.2.2 FEEDWATER MAIN TURBINE TRIP INSTRUMENTATION August 25,1997 3.3.2I DOC JFD CHANGE / DIFFERENCE COMMENT STATUS 1

P38 Staff review dated May 24,1994 indicates D/EC TS do Sutet plant-WsTS forFeedwater not contain the aW.Me TS goveming the availability Mari Turtune Trip instrumentabon based of the overfill r vin. Gun system instrumentation.

on STS.

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DAEC ITS 3.3.3.1 POST m1risasy gopWTOtW8G (PAN) WISTRUM3fTATION September 2,1997 l

4 l

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j

-3.3.3.1 DOC XD' CHANGFJDIFFERENCE tviaanspasT STATUS l

l 1

R.1 The NRC poseson on applicatum of te determeushc instruments of CTS 3M1F are forplant l

screerung cnteria to PAM instrumentation is that me channels to post arridarit morutonng j-PAM Table in The CTS should contam, on a plant sunmitances whose ranges are tecia, specdic boom, a5 Regulatory Guide 1.97 Type A instrumen!ahon.

L l

vanables and af Category 1 instruments. Those l

l instruments meetne this creena remen in the ITS. The Provide addhonaldiscusson and

)

instrums.its in CTS 3M1F and CTS 3M1H not evaluston explaming Wie season for mesteg tiis cribena, and their mean W CTS dIIerent function Estsigs in Wiese tuvo

[

3 j

re%. e (induding Actons Surveiennces and tables.

footnotes) are moved to liconose controRed documents.

l l

2 R.1 The NRC poolton on applicaton of tie determanske instruments of CTS 3M1Fand H screenwg cntena to PAM instrumentahon is met 9:e evaluated as retamed for ITS irw*=i==

PAM Table in The CTS should contam. on a plant RCSPressurewtuchis rudincluded in i

specdic bass, at Regulatory Gunte 1.97 Type A T3.3.3.1-1.

variables and a5 Category 1 instruments. Those i

instruments meetng this cntene remain in the ITS. The l

i instruments in CTS 3M1F and CTS 3M1H not

[

meeting this cntena, and their associated CTS l

requirements (including Achons. surveinances and t

footnotes) are monH to licensee controsed documents.

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i DAEC ITS 3.3.3.1 POST ACCIDENT WONITOftpsG PAIS 50STItuREENTATION deptember2, r47 L

l 3.3.3.1 DOC

.JFD'

' CHANGFJDIFFERENCE CORERRENT STATUS i'

{

3 R.1 The NRC poesten on applica; ion of the detemumste Summary W vpatrix does not screerung cntene to PAM instrumentaten is that the irwea= Wuose items spec 5ed to be PAM Table in The CTS should contam, on a plant r=anesaswi from CTS 3M 2.F and 3M2.H.

}

ll spec 5c bases, a5 Regulatory Guide 1.97 Type A Provide tie staKacceptance of DAEC i

. vanables and at Category 1 instruments Those LetterNG-92-2629,datedJuly3,1985 for f

j metruments meetng Wiis oiteria remain in the ITS. The conformance to RG 1.97.

j instruments in CTS 3M2F and CTS 3M.2.H not i

i meetag this cntens, and their asso: mated CTS Explam Wie refensnoe to" plant HakW j:

requirements [mciuding Adens, Surveitances and found on page 7 of 21 in the vennemnnri i

footnotes) are reoved to licensee controged documents.

matrix.

4 4

LIC The Frequency of performing the Channel Calbraten TL:s change to CTS Surveigence Test OOS surveigence of CTS 4.2.H.1 and CTS Table 42-H is intervalis outside tie TSB scope of extended to fadlitate a change to the DAEC operatng revieur. Provide =rereharialnears==== and l.

cycle from 18 months to 24 montis in ITS SR 3.3.3.1.2.

jusedicaten for Wie cfiange.

]

Helorical data was utdized to validate that vendor-speafied drift was conserwahve or utdesd direc9y usii.g Arraye= rice of Weis change is contmgent the second moment about zero (SMAZ) method upon stsK apprawal of NEDC-31336 and its i

described in NEDC-31336-A. ITS extends the applicability to DAEC instrument Setpost i

Surveillance Frequency from the cummt Annual Mottodology pmgram.

Surveigana Frequency forTable 4.2-H DryweE Pressure (Wide and Namw range) Funcson and from I

the cummt 6 month Surveigence Frequency far Table f'

4.2-H, Contamment Hydrogenf0xygen in-Line Morutor Functon, to a 24 monti Surminance Frequency.

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t DAEC ITS 3.3.3.1 POST ACCIDENT MONITORING (PAM) INSTRUMENTATION September 2,1997 3.3.3.1 DOC JFD CHANGE / DIFFERENCE COMMENT STATUS 5

LCY The Frequency for performing the Channel Calibration This extension of Surveillance Test Interval i'

OOS required by CTS 4.2.H.1 arrd Table 4.2-H is extended in is outside the TSB scope of review.

ITS SR 3.3.3.1.2 to facilitate a change to the plant opc,stig cycle from 18 months to 24 months. Historical Acceptance of this change is centingent data was utilized to validate that vendor-specified dnft upon staff approval of NEDC-31336 and its was conservative or utilized directly using the second applicability to DAEC Instrument Setpoint moment about zero (SMAZ) method described in NEDC-Methodology pvy n.

31336-A.

6 L5 P63 STS 5.3.3.1 Actions are modified in ITS 3.3.3.1 Actions Delete this chor@. RPS SR Notes are by a Note delaying entry into the Conditions and based on approved topical reports.

Required Actions for two hours, reflecting plant operating practice of not entenng Required Actions for Conditions caused by performing Survei!!ance Requirements. This position was communicated to the NRC staff in correspondence regarding the DAEC GL 89-10 Motor-Operated Valve (MOV) Program (J. Franz (IES) to W. Russell (NRC), " Generic Letter 89-10 Program," NG-94-4017, November 30,1994). Because the CTS does not a!!ow delaying entry into Conditions and Required Actions for two hours, the CTS Completion Time is extended 2 hours2.314815e-5 days <br />5.555556e-4 hours <br />3.306878e-6 weeks <br />7.61e-7 months <br /> by this change.

7 P36 CTS AOTs for inoperable Hydrogen & Oxygen monitor Delete this cW and adopt the STS channels are proposed. For one channel; restore in 30 based on the hke desegn and operation of days or provide attemate method within 30 days and PAM instrumentation. The STS aliows l

once per 7 days thereafter and repair in 60 days. For indefinite opasticnmth one chanr.el two inoperable channels, restore in 7 days, otherwise inoperable provided attemate meratviig is provide attemate method within 7 days and once per 48 available. The STS limit for the second hours thereafter and restore in 14 days.

ir.cpa sbie channel is 72 hours8.333333e-4 days <br />0.02 hours <br />1.190476e-4 weeks <br />2.7396e-5 months <br /> vice the I

CTS 14 days.

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l DAEC ITS 3.3.3.1 POST ACCIDENT MONITORING (PAN) INSTRUMNTATMNI

" 6 2,1997 i

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3.3.3.1 fE.

'JFD CHANGE 9 DIFFERENCE COMMENT STATUS 7

8 P49 Proposed Note to Achons would alkw W Delete ens change. Genenc STS changes j

condton entry for each containment penetrabon flow require an approved TSTF traveler.

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9 P39 Fwd Note to SR 3.3.3.1.1 elmnetes channel check Delete this change. Genenc STS changes

[

j for PCIV posshon irwEr= hart.

requwe an approved TETF traveler.

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10 M1 PiW ITS 'M a 24 rnonth channel calibration Acaptance of this change is thyond the i-OOS a.d 31 day channel check for the following added TS scope of TSB review and is conhngent funchons: Reactor Pressure, Reactor Vessel Level, and upon the staff accephng analysis to shour j

PCN posto;irwhc=hrvi.

that the propoJed ITS surveiRance teshng is appropnsee.

i 11 none none CTS Footnote (a) to Table 4.2.H is shown in the rnerkup This note appEas to SRVposshon as SR 3.3.6.3.1.

indbhon which is relocated. Explom why

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l the footnote is also not relocated.

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3 DAEC ITS 3.3.3.2 RERBOTE SHUTDOWN SYSTEM September 3,1997 I

3.3.3.2 DOC JFD CHANGE / DIFFERENCE COMMENT STATUS I

1 LCY The Frequency of performmg the Funcimal Test of This extensson of Sunreillance Test interval OOS Surveiltamce CTS 3.10.B.2 is extended in SR 3.3.3.2.1 to is outsxle the TSB scope of rev'ew.

facili'L a change to the plant operating cycle from 18 Provide addshonal discussion and

[

nvanFE a 24 months. Histonca! data was uti5ized to jud T. cation for the change.

validate that vendor-specified drift was conservatrve or utilized drectly usmg the second irgi.wid about zero A@ ice of this change is cui.L..gera (SMAZ) method descnbed in NEDC-31336-A.

upon staff approval of NEDC-31336-A and

[

sts My te OAEC Instrument Setport Methudology prograrn.

f.

2 R.1 CTS 3/4.10.2 requres that the Remote Shutdown Panels Provide addshonal discusseon and are locked when not in use or bemg maintaened. These jueiT.c. Gun of the a afety bases for this requirements are moved to ur.specified plant p.h.

ihion iricludeg the locahon in plant procedures of the moved requirement 3

M.2 ITS SR 3.3.3.2.2 adds a Channel Calibrabon of each Verify the Lcr 00C meludes ju ^& Gun requred funcbon to CTS 3/4.10.B and sets the interval to for the 24 rr.onth frequency of this new SR.

24 trwdt6. No discussion orju=LTn G06 for 24 rrw G6 is provided.

I DAEC ITS 3.3.4.1 END OF CYCLE RECIRCULATMNG TRIP (EOC4tPT) INSTRUMENTATIDN j

September 4,1997

-1 3.3.4.1.

DOC JFD CHANGE / DIFFERENCE COMMENT STATIF :

1 L1 CTS 4.2.G.3 requires performing a time response test.

Prowde emn-ian and,L M-. for of the RPT breakers at least once per operahng cycle extendmg the SR frequency.

(18 months). ITS SR 3.3.4.1.5 for EOC-RPT System Response Twne, requres performmg this test performed every 24 months on a Staggered Test Bases (STB) This extension to the CTS SurveiNance Test intervsl is beskM on remowng redundant teshng performed each operahng cyde.

2 LAV This change renses the Technical Specsficahon This change to CTS Setpoet/ANowable OOS setpoets for ITS 3.3.4.1 instrumentahon to reflect Values is <=*=rta the TSB scope of renew.

Aiiowable values rather than setpoets found in the plant procedures. These ANowable Values are Acceptance of this change is conhngent ed=Ninhed by DAEC Instrument Setpoint Methodology upon Staff approvalof NEDC-31336 which is based on the General Electnc (GE) instrument applicabihty to DAEC Instrument Setpont S,.Wi MeMedology; NEDC-31336, " General Electnc Methodology program.

Instrumentshon Setpont Methodology.*

3 LCY-The Frequency of performmg the Channel Calibrabon Acaptance of this change is outsede the OOS requred by CTS 4.1.A.1 and Table 4.1-1 is extended in scope of TSB renew and is conhngent ITS SR 3.3.4.1.2 to facMitate a change to the DAEC upon Staff W of NEDC-31336 and operahng cycle from 18 months to 24 months.

its apphcabitty to DAEC instrument Hestoncal data was utNued to vaEdste that vendor-Setpoet Methodology program.

Wu drift was conservative or uhlized directly uomg the second moment about zero (SMAZ) method described in NEDC-31336-A 1

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DAEC ITS 3.3.4.1 END OF CYCLE RECIRCULATION TRIP (EOC-RPT) INSTRUMENTATION 1

September 4,1997 l

'3.3.4.1-DOC

,JFD CHANGE / DIFFERENCE COMMENT STATUS t

i i

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LCY-2 The Frequency for performmg the Response Twne Test This extensson of Survegiance Test interval j

OOS and Channel Funcbonal Test including the RPT breaker is outssde the TSB scope of review.

,[

requwed by CTS 4.1.G.3 and Table 4.2-G is extended in ITS SR 3.3.4.1.3 and ITS SR 3.3.4.1.5 to facilitate a l

change to the DAEC operahng cycle frorn 18 months to 24 months. The extensson of the Surveillance Test interval is based on a ten year review of surveillance lest failures and review of the datah==a for 10CFR50.65

'i (Maintenance Rule).

I l

r!

5 None None STS SR 3.3.4.1.5 requires venficanon of the TSV-Provide jushficabon for the STS deviahon l

Closure and TSV - Fast Closure trip is not bypassed based on current licensing bases, system i

above 30% RPT on a 18 month frequency. ITS SR design, or operahonal constramts.

j 3.3.4.1.4 adds this requwement to the CTS and l

1 changes this interval to 24 months. No discussion or gl justificahon is provided.

[

i 6

A.9 CTS 3.12.C.3 requwes if the MCPR limit is not restored, Provide mMihnggl hminn and that Thermal Power be reduced to s 25% RTP, or to K% for extending the CTS such a power level that the limits are again beig. met, requwement from 25% RTP to 30% RTP.

l within the next 4 hours4.62963e-5 days <br />0.00111 hours <br />6.613757e-6 weeks <br />1.522e-6 months <br />. ITS 3.3.4.1 Requwed Achon

+l C.2 with EOC-RPT trip rap =hitty not restored or the MCPR limii not applied requwes a reduchon to s 30%

l' i

RTP withm 4 hours4.62963e-5 days <br />0.00111 hours <br />6.613757e-6 weeks <br />1.522e-6 months <br />. The CTS limit is extended from l

25% RTP to 30% RTP in the ITS.

i!.

7 A6 DOC A6 refers to CTS Table 4.2-G. The i;'..=rs to a Revise this DOC to reference the correct

{

monthly channel funcbonal test is ireim.t.

SR frequency applied to note ~

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f DAEC ITS 3.3.4.1 END OF CYOLE RECIRCUt.ATION TRIP (EOCAtPT) INSTRURIENTATION September 4,1997 i

3.3.4.1 DOC JFD CHANGE / DIFFERENCE-COMMENT STATUS

.ii 8

A7 Pressure switch response time of 30 msec is moved to Provide addsbonal discussion and the Bases be ed on the juur,4vn that the time is irfvinh to support this rJege as an l

intnnsic to the pressure switch TS M4 value.

admirustrative chango.

9 A8 AS suggests that CTS Table 3.2-G Achon 81 provides Provide addsbonaldiscussion and t[

equitalent requirements to ITS Condsbon A ar.d to justificahon for the equivalence between Condsbon B( if the 2 hour2.314815e-5 days <br />5.555556e-4 hours <br />3.306878e-6 weeks <br />7.61e-7 months <br /> allowance to restore MCPR the CTS and the p.upcxJ ITS.

4 8

limits is included). The changes to Achon 81 are not fully desenbed. Achon 81 addresses two condsbons; 3

one tilp syster.: inoperable for more than 72 hours8.333333e-4 days <br />0.02 hours <br />1.190476e-4 weeks <br />2.7396e-5 months <br /> and ll t

the condebon of both trip systems inoperable. In CTS 1

Achon 81 if a channel is tnpped the trip system is still

'i operable per note (c) because the channelis operable.

[

lt appears that opwations are allowed to conhnue

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without entenng Action 81 if any inoperable channelis I

^

inpped. ITS Condebon A requirer an inoperable j

I cie n e to be inpped in 72 hours8.333333e-4 days <br />0.02 hours <br />1.190476e-4 weeks <br />2.7396e-5 months <br />. Thus, basM on trip system logic, the CTS allows more channel failures l[

before an acbon is taken.

ITS Condsbon B addresses one or more furdurs I{

inoperable or the MCPR limit not operable. Again, l

because the EOC-RPT has 2 out-of 2 logic for each funcbon in each trip system and either trip system will i!

trip both pumps there is no equivalence to the CTS and

{

ITS Achons l

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DAEC ITS 3.3.4.1 END OF CYCLE RECIRCULATION TRIP (EOC-RPT) INSTRUMENTATION September 4,1997 3.3.4.1 DOC JFD CHANGE / DIFFERENCE COMMENT STATUS 10 M1 The ad& bon of the LSFT and pump breaker actuabon is Pnmde docussion and jushficebon for the OOS jushfied. The Frequency of performng the teshng 24 month test interval.

requred by ITS SR 3.3.4.1.3 to facilitate a change to I

the DAEC operahng cycle from 18 months to 24 months is not jushfied.

11 A4 The DOC states that restorabon of trip Wy (i.e.,

Revise the DOC. The 3TS do not wh-Operability) in the ITS can include placmg the channel a inoperabb andinpped channelto be P

in trip, tnus the ITS requirements are equnr4ent to CTS operable.

Table 3.2.G. Note (c).

4

DAEC ITS 3.3.4.2 ANTICIPATED TRAN5IENTWITHOUT SCRAM RECIRCULATION PUMP TRIP (ATWS-RPT) INSTRUMENTATION September 4,1997 3.3.4.2' DOC.

~JFD-CHANGE /DiFFERFNCE COMMENT STATUS 1

M.4 P.4 The CTS markup adds a Note to the CTS Table 4.2-G Provide additenal discussion verifying Surveillance Requirements for ATWS-RPTwhich aliows the intended status of the Surveillance delaying entry into associated Conddions and Required Requirements note in the ITS. The STS Actions for 6 hours6.944444e-5 days <br />0.00167 hours <br />9.920635e-6 weeks <br />2.283e-6 months <br /> when a channel is inoperabia for note is based on topacal report NEDE-performance of required Surveillances provided the 770-06-01. If appivpdide. Include an associated Functiore maintains ATWS-RPT trip evaluation of the E,yyrn blty of this capability (M4). This same note is deleted in the ITS topcal to DAEC.

markup. It is not clear whether the note should be deleted or retained in the ITS.

I 2

M.3 P.50 CTS Table 3.2-G Action 80 addresses inoperable (ATWS)

Provide further discussion and RPT channels. According to Footnote (a), Action 80 is justification for errminating the entered after the one required trip system for the function requirements of CTS Table 3.2-G Action is incperab'e. Action 80 - a. provides requirements for an 80 - a., including detail on channel inoperable single instrument channel. STS 3.3A2, function test equivalence.

l Required Actions A.1 or A.2 that provide requirements for an inoperable single instrument channel are deleted in the ITS 3.3.4.2 and only the Conditions of inoperable Functions are addressed. the discussion and justifcations that equate channelinoperability with Function inoperability are insuffrient I

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DAEC ITS 3.3.4.2 ANTICIPATED TRANSIENT WITHOUT SCRAM RECIRCULATION PUMP TRIP (ATWS-RPT) INSTRUMENTATION September 4,1997 3.3.4.2 DOC

.-JFD CHANGE / DIFFERENCE COMMENT STATUS 3

LAV This change revises the Technica! Specirn iica setpoints This change to CTS Setpoint/ Allowable OOS ror ITS 3.3.42 instrumentation to ref>ect Allowable Values Values is outside the TSB scope of rather than setpoir.s found in the plant procedures. These review.

Allowable Values are established by DAEC instrument Setpoint Methodology which is based on the General Acceptance of this change is c.cidigerd Electric (GE) instrument Setpoent Methodology; NEDC-upon Staff approvalof NEDC-31336 31336, " General Electric instrumentation Setpoint appricability to DAEC instrument Methodology."

Setpoint Methodology prog.am.

4 LCY-2 The Frequency for performing the LOGIC SYSTE~J This change to Surveillance Test OOS FUNCTIONAL TEST including the RPT breaker required intervat is outside the TSB scope of by CTS 4.1.G.2 is extended in ITS SR 3.3.42.4 to review faciirtate a change to the DAEC operating cycle from 18 months to 24 months. The extension of the Surveills.1ce Test interval is based on a ten year review of surveillance test failures and review of the database for 10CFR50.65 (Maintenance Rule).

5 none Based on the logic diagram, it appears that relay 404C1 Provide a response to this concem, actuates on high pressure and starts a time delay for level, include suppeiting documentation.

therefore, a single failure could disable one trip system which would require a more restncirve ~s 3 than STS.

6 A4 The DOC states that restoration of trip capability (i.e.,

Revise the DOC. The STS do not Operability) in the ITS can include placing the channel in consider a inoperable and tripped trip, thus the ITS requirements are equrvaient to CTS channel to be operable.

Tabie 3.2.G. Note (c).

2 L - _ _- --- ___

__ _... _.. _.... _.. _ _ _. _ _. _.. _. _ _..... _ _. ~. _.. _ _....... _ _ _. _. _ _. _ _. _.

A t

,.t DAEC ITS 3.3.4.2 ANTICIPATED TRANSIENT VATHOUT SCRAM RECIRCUL.ATION PUMP TRIP (A1WS-RPT) INSTRIFbE WON f

~

ar..;& c.x4,1997 i

bHANGE/DiFFERLM Y

STATUS

{3.3A2 i iDOCr

fJFD

^

as COhWIENT 7

M2 M2 discusses changes to CTS Action 80. Mc ;;st, CTS Provide addshonal discussion and Action 80 is modified by Table Note (a). Explam why M2 justdicahon.

j does not account for table note (a) in the DOC.

8 PS1 ITS proposes a genenc change to elmnate the channel Revise SR 3.3.4.2.1 to include the I

check of all pressure switches.

pressure sulches.

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DAEC ITS 3.3.5.1 EMERGENCY CORE COOUNG SYSTEM (ECCS) INSTRUMENTATION September 9,1997 1

3.3.5.11

-DOC-

JFD

. CHANGE / DIFFERENCE COMMENT _

. STATUS 1

A.4 P18 CTS Table 3.2-B, footnote (a) specifies thet a : cannel of This extension to CTS Completion Time is HPCI and RCIC Condensate Storage Tar + ! evd - Low rejected because it is not consistent with can be inoperable for up to 6 hours6.944444e-5 days <br />0.00167 hours <br />9.920635e-6 weeks <br />2.283e-6 months <br /> for th pe vmance of the topical report which was implemenied u

required SRs. Due to the need to override 5 q c to correctly in the CTS. Revise the ITS to prevent initiation of the HPCI Suction Transfer when provide a note to SRs that is consistent testing, ITS Table 3.3.5.1-1, Function 3.d, proposes 12 with the CTS.

hours to complete testing instead of the 6 hour6.944444e-5 days <br />0.00167 hours <br />9.920635e-6 weeks <br />2.283e-6 months <br /> allowance provided in CTS and in STS 3.3.5.1.

~

2 M.1 The ITS changes CTS Table 3.2-B by adding Pump Provide additional discussion and Discharge Flow-Lov.1 ypass) Functions to the ECCS justification for these surveillance OOS 8

instrumentation requirements. An LSFT(ITS SR frequencies.

3.3.5.1.9) with a 24 month frequency and a Channel i

Functional Test (SR 3.3.5.1.3) are assigned. No justification is provided for the surveillances or frequencies.

i 3

M1 The ITS changes CTS Table 3.2-8 by adding Pump Provide additional discussion and Discharge Flow-Low (Bypass) Functions to the ECCS justification for these differences.

Instrumentation requirements. The required channels per i

function requirement does not comport with the propcsed ITS Bases.

4 P15 Proposed changes to NUREG Action E.1 Completion Provide additional discussion and Times customize the CT to the low flow bypass valves justification for these changes.

that protect ECCS pumps; however, the terminology chosen is not consistent with function of these valves "one hour from the loss of initiation capability for minimum flow valves......" because these valves do not initiate ECCS.

l

I DAEC ITS 3.3.5.1 EMERGENCY CORE COOUNG SYSTEM (ECCS) INSTRUMENTATION September 9,1997

)3.3.5.1 DOC JFD

CHANGE /DIFFERENCEl COMMENT STATUS 4

8 5

L1 CTS Table 3.2-8 Actions 30,31,32 and 34 requires Acceptance of this enange is beyond the OOS declaring the associated system inoperable when more scope of TSB review and is continw.t than one affected ECCS initiation channel is inoperable.

upon Staff approval of NEDC~31336-P-A The completion times for Actions 30 and 34 are applicability to DAEC and Staff SER issued immediate and the completion times for Actions 31 and 32 for CTS Amendment 193.

are 1 hour1.157407e-5 days <br />2.777778e-4 hours <br />1.653439e-6 weeks <br />3.805e-7 months <br />. The ITS 3.3.5.1 Required Actions redefine a i

multichannel inoperability in terms of loss of function.

Thus, the ITS cnn allow up to two channels of a trip function (depending on the logic configuration and which two are inoperable) to be inoperable for up to 24 hours2.777778e-4 days <br />0.00667 hours <br />3.968254e-5 weeks <br />9.132e-6 months <br /> or, in the case of ADS,8 days before requiring further action.

l The extensions of these Completion Times are based on a previously conducted reliability analyses (NEDC-30936-P-A, December 1988). These extensions were evaluated for use at DAEC (NRC SER issued for CTS Amendnent 193, dated April 14,1993) based on the diversity of sensors available to provide initiation signals and the redundancy of the ECCS design. This extends the CTS Completion Time from immediate or 1 hour1.157407e-5 days <br />2.777778e-4 hours <br />1.653439e-6 weeks <br />3.805e-7 months <br /> to 24 hours2.777778e-4 days <br />0.00667 hours <br />3.968254e-5 weeks <br />9.132e-6 months <br /> or 8 days.

t l

J DAEC ITS 3.3.5.1 EMERGENCY CORE COOLING SYSTEM (ECCS) INSTRUMENTATION September 9,1997 33.5.1 !

DOC lJFD (CHANGE / DIFFERENCE

, :COMMENTj STATUS 6

L3 CTS Table 3.2-B Actions 30 and 34 with more than one Provide additional discussion and channel inoperable, require declaring the associated justification for the change that is system inoperable immediately. ITS 3.3.5.1 Required consistent with the ITS Bases.

Action B.1 allows 1 hour1.157407e-5 days <br />2.777778e-4 hours <br />1.653439e-6 weeks <br />3.805e-7 months <br /> from discovery of loss of initiation capability for features in more than one of the three low pressure ECCS subsystems, to declare the supported feature (s) inoperable. Justification is based on consistency with other CTS Actions for ECCS instrumentation that allow 1 hour1.157407e-5 days <br />2.777778e-4 hours <br />1.653439e-6 weeks <br />3.805e-7 months <br /> to declare associated systems inoperable with multiple channels inoperable.

CTS Completion Time is extended from immediate to 1 hour1.157407e-5 days <br />2.777778e-4 hours <br />1.653439e-6 weeks <br />3.805e-7 months <br />.

7 L4 PG3 STS 3.3.5.1 Actions are modified in ITS 3.3.5.1 Actions by Delete this proposed change. RPS SR a Note delaying entry into the Conditions and Required Notes are based on approved topical Actions for two hours, reflecting plant operating practice of reports. Provide a revised topical report not entering Required Actions for Conditions caused by for staff review and approval.

performing Surveillance Requirements. This position was communicated to the NRC staff in correspondence regarding the DAEC GL 89-10 Motor-Operated Valve (MOV) Program (J. Franz (lES) to W. Russell (NRC),

" Generic Letter 89-10 Program," NG-94-4017, November i

30,1994). CTS Completion Time is extended 2 hours2.314815e-5 days <br />5.555556e-4 hours <br />3.306878e-6 weeks <br />7.61e-7 months <br /> by this change.

r

DAEC ITS 3.3.5.1 EMERGENCY CORE COOLING SYSTEM (ECCS) INSTRUMENTATION September 9,1997 13.3.5.Y DOC JFD

CHANGE / DIFFERENCE COMMENT;;

' STATUS'-

8 LAV This change revises the Technical Specification setpoints Acceptance of the proposed change is OOS for all ITS Table 3.3.5.1-1 instrumentation to reflect beyond the scope of TSB review and is Allowable Values rather than setpoints found in the plant contingent upon staff acceptance of procedures. These Allowable Values are establisned by NEDC-31336.

DAEC Instrument Setpoint Methodology which is based on the General Electric (GE) Instrument Setpoint Methodology; NEDC-31336, General Electric j

instrumeiltation Setpoint Methodology.

The Allowable Value for Reactor Vessel Water Level-Low-Low CTS Umiting Safety System Setting 2.1.G, Reactor Vessel Water Level - Low-Low-Low and 2.1.H is the same as the CTS Table 3.2-B setpoints. The ITS l

Allowable Value appears to be in the non-conservative direction, sir.h that the proposed TS result in extending the CTS Lim. ting Safety System Setting beyond the plant licensed value.

i s

i

-. - - - - -. -.... - - - - --.. - -. - - - -. ~. -.. ~ -..

i t

j DAEC ITS 3.3.5.1 EMERGENCY CORE COOUNG SYSTEM (ECCS) INSTRUMENTAT90N Septerr.ber 9,1997

{

3.3.53:

DOC JFD?

m ECHANGE/OlFFERENCE,

COMMENT

STATUS I

9 LIC The Frequency of performng the Channel Calibration Acceptance of this change is beyond the j

OOS surveillance of CTS 4.2.0.1 and CTS Table 4.2-B is scope of TSB review and is contagent extended in ITS SRs 3.3.5.1.6 and 3.3.5.1.8 to facilitate a upon Staff approval of NEDC-31336 and

}

change to the plant operating cycle from 18 rnonths to 24 its applicabelsty to DAEC instrument j

months. Historical data was utilized to validate that Setpoint Methodology program.

z vendor-specified drift was conservative or utilized derectly j

1 using the second moment about zero (SMAZ) method l

{

desenbed in NEDC-31336-A. ITS extends the j

Surveillance Frequency for ITS Table 3.3.5.1-1 Functions v

i 1.a.1.b.1.c, 2.a. 2.b. 2.c, 2.1, 3.b, 3.d, 3.e, 4/5.a. 4/5.b,

[

4/5.d, and 4/5.e from the current 3 month Surveillance

(

Frequency to a 24 month Surveillance Frequency; and, l

for ITS Table 3.3.5.1-1. Functions 1.e and 2.e from the

{

current 12 month Surveillance Frequency to a 24 month j

Surveillance Frequency. In addition, the current 3 month Surveillance Frequency for ITS Table 3.3.5.1-1 Functions f

2.g 3.a and 3.c, is extended to a 12 month Survestlance Frequency.

[

i 10 LCY-2 The Frequency for performng the Logic System Acceptance of this change is beyond the i

OOS Functional Test required by CTS 4.2.B.2 is extended in scope of TSB review and is contingent f

ITS SR 3.3.5.1.9 to facilitate a change to the plant upon staff approval of the SR frequencies

(

operating cycle from 18 months to 24 months. The for the extended fuel cycle.

]

extension of the Surveellance Test interval is based on a ten year review of surveellance test failures and review of the database for 10CFR50.65 (Mamtenance Rule).

i i

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

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DAEC ITS 3.3.5.1 EMERGENCY CORE COOLING SYSTEM (ECCS)INSTRUMENTATIC 4 September 9,1997

[

l i

C3.1ST iDOC?

JFD

^

LCHANGE/DIFFERENCEi y.COMMENTi STATUS i

11 P15 STS 3.3.5.1 Requwed Actions B.1, C.1 and E.1 requwe Provide justificahon for the STS deviahon

[

declaring supported features inoperable when its based on current heensing basis, system redundant feature ECCS initiation capabdity is inoperable.

design, and opershonal constramts.

j The DAEC Loop selection logic cen ;;cetes the v

redundant relationship wwthin LPCI and its redundant j

relationship with CS. The ITS terrrunology is "two or more i

j low pressure ECCS subsystems"instead of the STS j

termmology "both divisions."

This change may be more

[

restrictive than intended because it ' cludes multiple m

l failures within the same division.

1 l

12 A.6 CTS Table 3.2-B for ADS lists the mwnmum Operable Provide additional discussion and channels requwed for each trip function in its entrety justificahon meludmg the basis for reducmg

(

(combmed logic). ITS 3.3.5.1 evenly divides ADS into the requwed number of channels.

[

Trip Logic A and Trip Logic B, mamts* ing the same total.

i m

This change requwes one half of the number of Cha mels j

listed in the CTS, listed as Trip Logic A and the other half i

i as Trip Logic B. This redefirwhon of the ADS system into two subsystems changes the requirements for f

inoperability of the ADS. The loss of one or more requwed channels makes all of ADS inoperable in the CTS but only makes a single trip logic inoperable in the ITS. The Requwed Action is different wi.h the same l

inoperability.

j i

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i DAEC ITS 3.3.5.1 EMERGDICY CORE COOLING SYSTEM (ECCS) INSTRUMENTATION September 9,1967 f3.3.5.15 DM JFD ECHANGEIDIFFERENCE1 -

COMMENT

. STATUS

.13 M4 CTS Table 3.2-8 contains Action 36 for the 4.16 kV Provide additional discussion and Emergency Bus Sequential Loadog Relay Function,

justification includeg the basis for deleting requiring inppmg the inoperab:3 channel withm one hour the channel trip.

l with the number of Operable channels one less than j

required. Operation is ther. allowed to contmue until t

performance of the next reqaired Channel Funchonal Test. Under the same conditions ITS 3.3.5.1 Requwed Action F.1 requwes restoring the channel to Operable status withm one hour. Instead of allowng continued i

operation with a tripped channal until the next channel Functional Test, ITS 3.3.5.1 Required Action 1.1 requwes the associated Core Spray subsystem and Low Pressure l

Coolant injection System / subsystem declared inoperable immediately if not restored within one hour. This changes i

a trip requirement to a requwement to declare a system i

inoperable.

14 R.1 CTS 4.2.B.2.f contains a requament to perform a Logic Provide additional discussion and System Functional Test once per operating cycle on Area justification includeg the basis for movmg i

Coolmg for Safeguards Systems. This testing the requwements for Area Coolmg for requirement in the CTS is moved to plant procedures Safeguards Systems and the identity of the j

along with CTS 3/4.5.1 for Er.girs.ed Safeguards plant procedure that contain this Compa 1ments Coolmg and Ventilation requwements. No survesilance.

j justification is presented for the removing of these j

requirements from the CTS.

[

i i

15 M4 P14 The ITS proposes to add the Emergency Bus Sequential Provide additional discussion and

.A7 Loading Relay Function to Table 3.3.5.1-1 for the Core justification to show that, based on DAEC Spray system. It appears this pump protechon relay is design, this component is not tested with unique to the Core Spray system because other otherload sequence relays requwed by components do not have similar requwements.

proposed ITS SR 3.8.1.13.

I i

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- - - - - - - - - -... ~..

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i O

DAEC ITS 3.3.5.1 EMERGENCY CORP COOLING SYSTEM (ECCS) INSTRUMENTAT10fd September 9,1997 v

L3.15.1[

DOC JFDj (CHANGE / DIFFERENCE COMMENTJ

STATUS I

i i

16 A8 ITS Actions F.1 & l.1, require an inoperable channel to be Provide additional discussion and restored in one hour or the supported system is declared justification for the delehons to CTS l

inoperable. This set of requirements is stated to be requirements.

j equivalent to CTS requirements to trip the channelin one hour because placing the channel in trip causes the associated functions to be inoperable. Explicit requirements to place s trip system in trip are replaced with administrative requirements. These are not equivalent..

l i

17 P13 The ITS proposes to delete NUREG Table 3.3.5.1-1 Provide specific discussion and justification manual initiation functions for CS, LPCI, HPCI and ADS.

that manual initiation capability for these functions do not exist in the DAEC design.

l

' v 18 L1 DOC L1 discusses CTS T3.2-B Actions 30 and 31. The Provide specific discussions to clanfy last sentences in the first paiorp aph provides unspeofied these justifications.

i evaluations of changes to the CTS for the" LPCI Loop Select Logic" and for"other functions" that are said to be evaluated and " determinatior.s made on design or other

}

i considerations" 19 L1 DOC L1 discusses mode of apphcability for ITS 3.3.5.1.

Provide speofic discussions to clanfy Actions B.1, C.1 and C.2 at the bottom of page 6. The these justifications.

last sentence of the paragraph provides a conclusion "this I

change is acceptable" without stating what changed and without furtherjustification of the safety basis for the proposed TS.

?

20 L1 DOC L1 discusses CTS T3.2-B changes for ADS Trip Provide spedric discussions to clanfy the Functions inoperable in one or both trip logics without DOC.

[

providing a safety analysis for the proposed change.

i i

i

DAEC ITS 3.3.5.1 EMERGENCY CORE COOLING SYSTEM (ECCS) INSTRUMENTATION September 9,1997 3.3.5.1 :

DOC' JFD CHANGE / DIFFERENCE ~

COMMENT.

STATUS 21 L1 DOC L1 discusses CTS T3.2-8 changes for ADS Trip Provide additional discussion to explain the Functions related to ADS valve operability (ITS Action H)

" CTS to ITS match."

and states that the "lTS matches CTS Action 31 for this Trip Function."

22 L1 DOC L1 discusses CTS T3.2-B changes for ADS Trip Provide spe5.c discussions to clarify the Functions related to ADS valve operability (ITS Action H)

DOC without providing a safety basis justification for the changes to TS repair times.

23 L1 DOC L1 discusses CTS T3.2-B changes for ADS Trip Provide specific discussions to clarify the Functions related to ADS valve operability. References DOC in the DOC are to ITS Action H whereas the CTS markup shows Action G. Provide a CTS markup consistent with the DOC discussion.

24 none ITS 3.3.5.1 includes a 18 month channel calibration for Provide specific discussions to clarify this the ADS Timer. The CTS requirement is once per change.

refueling interval. The changes are not discussed.

25 R2 This change moves the CTS 2.1.G. Reactor Vessel Water This change to CTS Setpoint/ Allowable OOS Level-Low-Low-Low and 2.1.H Reactor Vessel Water value is outside the TSB scope of review Level-Low-Low that are Umiting Safety System Settings and is contingent upon acceptance of the along with the Trip Level Setting column in CTS Table setpoint methodology. Including the 3.2-B and replaces it with Allowable Values in ITS Table equivalence of the CTS Limiting Safety 3.3.5.2-1. The CTS Trip setpoints are moved to an System Setting to the Allowable Values.

unspecified licensee controlled document. The reference level for the Reactor Vessel in CTS 2.1.G and CTS 2.1.H are deleted without discussion. The equivalence of the CTS Limiting Safety System Setting and the Trip Level Settings to the Allowable Values is not shown.

i

DAEC ITS 3.3.5.1 EMERGENCY CORE COOLING SYSTEM (ECCS) INSTRUMENTATION September 9,1997 3.3.51 LDOC*

JFD-

~. CHANGE / DIFFERENCE..

ICOMMENT

~ STATUS 26 M2 CTS Table 3.2-8 Action 35 for the HPCI Functions of Provide additional discussion and Condensate Storage Tank Level-Low and Suppression justification including the safety basis for Pool Water Level-High requires placing at least one proposing an option to line up to the.

inoperable channel in trip within 24 hours2.777778e-4 days <br />0.00667 hours <br />3.968254e-5 weeks <br />9.132e-6 months <br /> or declare the suppression pool.

associated system inoperable with the number of Operable channels less than required. ITS 3.3.5.1 l

Required Action D.1 requires HPCI to be declared inoperable within one hour from discovery of loss of suction transfer capability unless it is aligned to the suppression pool. Going from 24 hours2.777778e-4 days <br />0.00667 hours <br />3.968254e-5 weeks <br />9.132e-6 months <br /> to 1 hour1.157407e-5 days <br />2.777778e-4 hours <br />1.653439e-6 weeks <br />3.805e-7 months <br /> is more restrictive but the Note adding the option to line up to the suppression cool is less restrictive and is not discussed or justified.

I DAEC ITS 3.3.5.2 REACTOR CORE ISOLATION COOUNG (RCIC) SYSTEM INSTRUMENTATION September 10,1997 l

[3.3.51i

. DOC.

QFD

~CHANGEIDIFFERENCE COMMENT-STATUS'

[

1 A.4 P18 CTS Table 3.2-B, footnote (a) allows the two channels of This extension to CTS Completion Time is i

HPCI and RCIC Condensate Storage Tank Level-Low, rejected because it is not consistent with inoperable for up to G hours each for the performance of the topical report which was implemented required SRs. Due to the need to override the logic to correctly in the CTS. Revise the ITS to prevent initiation of the RCIC Suction Transfer when provide a note to SRs that is consistent testing, ITS Table 3.3.5.2-1, Function 3., allows 12 hours1.388889e-4 days <br />0.00333 hours <br />1.984127e-5 weeks <br />4.566e-6 months <br /> with the CTS.

to complete testing of both instruments instead of separate 6 hour6.944444e-5 days <br />0.00167 hours <br />9.920635e-6 weeks <br />2.283e-6 months <br /> allowances for each of the two instruments provided by the CTS. Assigning the 6 hours6.944444e-5 days <br />0.00167 hours <br />9.920635e-6 weeks <br />2.283e-6 months <br /> allotted to RCIC to HPCI in ITS 3.3.5.1 and then assigning the 6 hours6.944444e-5 days <br />0.00167 hours <br />9.920635e-6 weeks <br />2.283e-6 months <br /> allotted to HPOl to RCIC in ITS 3.3.5.2 doubles the STS Corapletion Time for both functions. The wording of the 12 hour1.388889e-4 days <br />0.00333 hours <br />1.984127e-5 weeks <br />4.566e-6 months <br /> HPCI allowance in ITS 3.3.5.2 i

does not reference HPCI testing and likewise the 12 hour1.388889e-4 days <br />0.00333 hours <br />1.984127e-5 weeks <br />4.566e-6 months <br /> HPCI allowance in ITS 3.3.5.1 does not reference RCIC testing. As a result, HPCI gets 12 hours1.388889e-4 days <br />0.00333 hours <br />1.984127e-5 weeks <br />4.566e-6 months <br /> and RCIC gets 12 hours1.388889e-4 days <br />0.00333 hours <br />1.984127e-5 weeks <br />4.566e-6 months <br /> versus 6 hours6.944444e-5 days <br />0.00167 hours <br />9.920635e-6 weeks <br />2.283e-6 months <br /> each in the CTS. Further justification is needed.

s 2

M.1 This change to CTS 3.2.B.2 adds a Logic System This change is outside the TSB scope of OOS Functional Test for each function of the RCIC System.

review and is contingent upon acceptance ITS SR 3.3.5.2.5 with a 24 month Surveillance Test of the STI interval extension justification.

Interval is assigned to these Functions. The CTS refueling cycle is 18 months and 24 months is a extension of that tirne.

DAEC ITS 3.3.5.2 REACTOR CORE ISOLATION COOL!NG (RCIC) SYSTEM INSTRUMENTAVON September 10,1997 3.3.5.2-DOC LJFD

CHANGiE/ DIFFERENCE LCOMMENT STATUS 3

M.2 CTS Table 3.2-8 Action 35 for the RCIC Functions of Provide additional discussion and Condensate Storage Tank Level-Low and Suppression justification including the basis for allowing Pool Water Level-High requires placing at least one the option to fine up to the suppression inoperable channel in trip within 24 hours2.777778e-4 days <br />0.00667 hours <br />3.968254e-5 weeks <br />9.132e-6 months <br /> or declaring the pool.

associated system inoperable with the number of Operable channels less than required. ITS 3.3.5.2 Required Action D.1 requires declaring RCIC Inoperable within one hour from discovery ofloss of suction transfer capability unless it is aligned to the suppression pool.

Reducing the CTS Completion Time from 24 hours2.777778e-4 days <br />0.00667 hours <br />3.968254e-5 weeks <br />9.132e-6 months <br /> to 1 hour1.157407e-5 days <br />2.777778e-4 hours <br />1.653439e-6 weeks <br />3.805e-7 months <br /> is more restrictive but the Note adding the option to line up to the suppression pool is less restrictive and is not discussed orjustified.

4 R.2 This change moves the CTS 2.1.H, Reactor Vessel Water This change to CTS Setpoint/ Allowable OOS Level-Low-Low that is a Umiting Safety System Setting value is outside the TSB scope of review and the Trip Level Setting column in CTS Table 3.2-B and and is contingent upon acceptance of the replaces it with Allowable Values in ITS Table 3.3.5.2-1.

justification of the equivalence of the CTS The CTS Trip setpoints are moved to an unspecified Limiting Safety System Setting to the licensee controlled document. The reference level for the Allowable Values.

Reactor Vessel in CTS 2.1.H is deleted without discussion. The equivalence of the CTS Limiting Safety System Setting and the Trip Level Settings to the Allowable Values is not shown.

L

^

DAEC ITS 3.3.5.2 REACTOR CORE ISOLATION COOLING (RCIC) SYSTEM INSTRUMENTATION September 10,1997 L3.3.5.2:

DOC LJFD-

~ CHANGE / DIFFERENCE ~

~ COMMENT STATUS 5

L1 CTS Table 3.2-B, Actions 30 and 31, requires declaring Acceptance of this change is beyond the OOS the associated system inoperable when more than one scope of TSB review and is contingent affected ECCS initiation channelis inoperable. The upon NRC approval of NEDC-31336-P-A completion time for Action 30 is immediate and the applicability to DAEC and NRC SER completion time for Actions 31 is 1 hour1.157407e-5 days <br />2.777778e-4 hours <br />1.653439e-6 weeks <br />3.805e-7 months <br />. The ITS 3.3.5.2 issued for CTS Amendment 193.

Required Actions redefine a multichannelinoperability in terms of loss of function. Thus, the ITS can allow up to two channels of a trip function to be inoperable for up to 24 hours2.777778e-4 days <br />0.00667 hours <br />3.968254e-5 weeks <br />9.132e-6 months <br /> before requiring further action. The extensions of these CTS Completion Times are based on a previously condocted reliability analyses (NEDC-30936-P-A December 1988). These extensions were evaluated for use at DAEC (HRC SER issued for CTS Amendment 193, dated April 14,1993) based on the diversity of sensors available to provide initiation signals and the redundancy of the ECCS design. This extends the CTS Completion Time from 1 hour1.157407e-5 days <br />2.777778e-4 hours <br />1.653439e-6 weeks <br />3.805e-7 months <br /> to 24 hours2.777778e-4 days <br />0.00667 hours <br />3.968254e-5 weeks <br />9.132e-6 months <br />.

6 L2 P63 ITS 3.3.5.2 Actions are modified by a Note delaying entry Delete this proposed change. RPS SR into the Conditions and Required Actions for two hours, Notes are based on approved topical reflecting plant operating practice of not entering Required reports. Provide a revised topecal report Actions for Conditions caused by performing Surveillance for staff review and approval.

Requirements. This position was communicated to the NRC staff in correspondence regarding the DAEC GL 89-10 Motor-Operated Valve (MOV) Program (J. Franz (lES) to W. Russell (NRC),

• Generic Letter 89-10 Program,"

NG-94-4017. November 30,1994). CTS Completion Time is extended 2 hours2.314815e-5 days <br />5.555556e-4 hours <br />3.306878e-6 weeks <br />7.61e-7 months <br /> by this change.

. = = _.

.p

l DAEC ITS 3.3.5.2 REACTOR CORE ISOLATION COOLING (RCIC) SYSTEM INSTRUMENTATION September 10,1997 3.3.5.2 '

DOC' LJFD LCHANGE/ DIFFERENCE

' COMMENT STATUS 8

L3 CTS Table 3.2-B, Action 30, requires declaring the Revise the DOC to be consistent with the associated system inoperable immediately when more ITS Bases.

than one channelis inoperable. ITS 3.3.5.2 Required Action B.1 allows 1 hour1.157407e-5 days <br />2.777778e-4 hours <br />1.653439e-6 weeks <br />3.805e-7 months <br /> from discovery of loss of RCIC initiation capability to declare the RCIC System inoperable. This extends the CTS Completion Time from immediate to 1 hour1.157407e-5 days <br />2.777778e-4 hours <br />1.653439e-6 weeks <br />3.805e-7 months <br />.

9 LAV The setpoints in CTS Table 3.2-B are moved to plant Acceptance of this change it beyond the OOS procedures and ITS Table 3.3.5.2-1 replaces the TSB scope of review and is contingent setpoints with Allowable Values. These Allowable Values acceptance of the justification of the are established by DAEC Instrument Setpoint equivalence of the CTS Umiting Safety Methodology which is based on the General Electric (GE)

System Setting to the Allowable Values.

Instrument Setpoint Methodology; NEDC-31336, General Electric Instrumentation Setpoint Methodology. The Allowable Value for Reactor Vessel Water Level-Low-Low CTS Limiting Safety System Setting 2.1.H is the same as the CTS Table 3.2-8 setpoint. The ITS Allowable Value is in the non-conservative direction from both tha setpoint and the CTS Limiting Safety System Setting, thus extending the CTS Limiting Safety System Setting beyond the piant licensed value: This is a misapplication of NECC-31336.

DAEC ITS 3.3.5.2 REACTOR CORE ISOLATION COOLING (RCIC) SYSTEM INSTRUMENTATION September 10,1997 3.3.5.2

DOC LJFD-

CHANGE / DIFFERENCE '

COMMENT STATUS 10 llc The Frequency of performing the Channel Calibration Acceptance of this change is beyond the OOS surveillance of CTS 4.2.B.1 and CTS Table 4.2-B is TSB scope of review and is contingent extended in ITS SRs 3.3.5.2.3 and 3.3.5.2.4 to facilitate a upon NRC approval of NEDC-31336 and change to the p! ant operating cycle from 18 months to 24 its applicability to DAEC Instrument months. Historical data was utilized to validate that Setpoint Methodology program.

vendor-specified drift was conservative or utilized directly using the second moment about zero (SMAZ) method described in NEDC-31336-A. The CTS 4.2.B.1 and CTS Table 4.2-B,3 month Surveillance Frequency is extended in ITS Table 3.3.5.'c-1 Functions 1. and 2., to a 24 month Surveillance Frequency and the CTS 3 month Surveillance Frequency is extended in ITS Table 3.3.5.2-1 Function 3., to n 12 month Surveillance Frequency.

11 L1 CTS Table 3.2-B Actions 31 for the RCIC Trip Function of Acceptance of this change is beyond the OOS Reactor Vessel Water Level-High requires RCIC to be TSB scope of reviewand is contingent declared inoperable with;n 24 hours2.777778e-4 days <br />0.00667 hours <br />3.968254e-5 weeks <br />9.132e-6 months <br /> with one channel upon NRC approval of NEDC-31336-P-A inoperable and within one hour when more than one applicability to DAEC and NRC SER initiation channelis inoperable. The ITS 3.3.5.1 Required issued for CTS Amendment 193.

Actions permit a 24 haur repair time for each inoperable channel. Thus, the ITS can allow up to two channels of to be inoperzble for up to 24 hours2.777778e-4 days <br />0.00667 hours <br />3.968254e-5 weeks <br />9.132e-6 months <br />. The extensions of these Completion Times are based on a previously conducted reliability analyses (NEDC-30936-P-A, December 1988).

These extensions were evaluated for use at DAEC (NRC SER issued for CTS Amendment 193, dated April 14, 1993) based on the diversity of sensors available to provide initiation signals and the redundancy of the ECCS design.

DAEC ITS 3.3.6.1 PRIMARY CorJTAINMENT ISOLATION INSTRUMENTATION September 15,1997 3.3.6.11

.DOCL JFDl

' CHANGE / DIFFERENCE :

-COMMENT STATUS l

1 MS P44 Footnote (d) is added to ITS Table 3.3.6.1-1 and Change the ITS Table 3.3.6.1-1 to list each applies to Function 5.b for RWCU Area Temperature-area as a separate TS function consistent High and to Function 5.c for RWCU Area Ventilation with STS format.

Differential Temperature - High. Footnote (d) proposes to require each RWCU area to an operab's 5.b or 5.c channel. The proposed Table has four rooms identified with each TS Function 5.b and 5.c.

e 2

P26 STS 3.3.6.1 contains only a 12 hour1.388889e-4 days <br />0.00333 hours <br />1.984127e-5 weeks <br />4.566e-6 months <br /> Channel Check Provide justification for STS deviation.

(SR 3.3.6.1.1); a 92 day and 184 day Channel include discussion based on current Functional Test (SR 3.3.6.1.2 and 3.3.6.1.5, licensing basis, system desin, and/or i

respectively); and a 92 day and 18 month Channel operational constraints.

Calibration (SR 3.3.6.1.4 and 3.3.6.1.6, respectively).

ITS SR 3.3.6.1.8, which requires a Channel Calibration every 24 months, is added to the STS 3.3.6.1 SRs

.vithout justification. In addition, surveillances for ITS Table 3.3.6.1-1, Functions 4.c 5.b,5.c, and 5.f are based on an unreferenced setpoint analysis for PCIS Functions. This analysis should be identified.

3 R10 HPCI and RCIC initiation signals which isolate Reject the relocation of these CTS containment are proposed to be relocated because its requirements. These manualisolation an uncommon practice to TS these isolation functions.

functions should be retained for overall redundancy and diversity of the isolation function as required by the plant licensing basis.

_n

^

DAEC ITS 3.3.6.1 PRIMARY CONTAINMENT ISOLATION INSTRUMENTATION September 15,1997 i

!3.3.6.1.:

DOC.

JFDI 1 CHANGE / DIFFERENCE

• COMMENT.

STATUS t

4 L3 CTS Table 3.2-A applies Action 23 to the Reactor Provide additional discussion and Water Level-Low isolation signal for the RHR justification including the protection Shutdown Cooling System. Action 23 requires closing provided by manual actions. Revise the the affected system isolation valves within one hour DOC to be consistent with the proposed and declaring the affected system inoperable. ITS TS Bases.

3.3.6.1, Required Actions J.1 and J.2, require i

Immediately initiating action to restore the channels to Operable status or immediately isolating the RHR-SDC System. The DOC states RHR-SDC System isolation is not required if Action is proceeding on a continuing basis to restore the inoperable channel (s) to Operable status. The Bases state that actions must continue until the channel is restored or the system is isolated.

Justification is based on the available manual isolation of the RHR-SDC. Bisjustification forchange of Required Action does not discuss manualisolation with loss of vessellevelindication and provides a basis that is different from proposed Action J Bases.

[

5 L6 The ITS proposes to delete the reactor low, low, low Provide addi ional discussion and level Group 7 isolation function. This function isolates justification showing that valves required to the RBCCW which is a closed system. Other reactor be operable by TS are not required by the low, low,lowwater levelisolation functions are safety analysis assumptions to have their retained. The justification for the proposed changes automatic isolation fonctions operab!e.

replace a TS requirement with a commitment that has no regulatory consequences. GDC-57 isolation valves are included in TS 3.6.1.3.

I

DAEC ITS 3.3.6.1 PRIMARY CONTAINMENTiSOLATION INSTRUMENTATION September 15,1997

'3.3.6.1-DOC:

!JFD

~ CHANGE / DIFFERENCE '

COMMENT STATUS 6

M6 P25 Changes are proposed to add Actions A.2 and Provide additional discussion and Conditon K to protect the primary containment from justification for the proposed changes to inadvertent spraying and to ensure the availability of explain the plant unique design which suppression pool cooling when required. These requires the addition of Condition K.

changes are new to the CTS and to the iTS. therefore, Evaluate the generic applicability of the the changes require approval by technical staff. In proposed changes.

addition, the proposed actions allow indefiriite operation in the inhibit mode if a single channelis Note: DOC L11 is based, in part, on the inoperable. The DOC does not just;fy indefinite acceptance of DOC M6 justification.

operation with the SPC inhibited.

7 L10 CTS Table 3.2-A Note (a) contains a 6 t our Allowed Provide additional discussion and Outage Time (AOT) for testing for the isolation justification presiding summary information Function of RWCU Differential Flow-High. The AOT of historical test times for completing the is extended to 12 he.ars in ITS 3.3.6.1. just.fication is stated SR and indicate the degeee to which based on availability of temperature monitoring to testing resulted in adverse impacts on isolate the RWCU System during the testing interval reactor operations.

and the 6 hour6.944444e-5 days <br />0.00167 hours <br />9.920635e-6 weeks <br />2.283e-6 months <br /> AOT is not adequate to allow for a Channel Carbration of this Function without requiring extra resources and persor. net. This change extends the CTS 6 hour6.944444e-5 days <br />0.00167 hours <br />9.920635e-6 weeks <br />2.283e-6 months <br /> Allowed Outage Time (AOT) to 12 hours1.388889e-4 days <br />0.00333 hours <br />1.984127e-5 weeks <br />4.566e-6 months <br />.

8 L11 CTS Table 3.2-B, Action 30, with more than one Provide additional discussion and affected Containment Cooling System isolation justification to support the application of Channel of Containment Pressure - High inoperable, Topical Report 24 hour2.777778e-4 days <br />0.00667 hours <br />3.968254e-5 weeks <br />9.132e-6 months <br /> AOT for the requires declaring the associated system inoperable containment cooling function.

immediately. ITS 3.3.6.1, Required Action A.2, allows 24 hours2.777778e-4 days <br />0.00667 hours <br />3.968254e-5 weeks <br />9.132e-6 months <br /> before any action is seguired. The STS 24 hour2.777778e-4 days <br />0.00667 hours <br />3.968254e-5 weeks <br />9.132e-6 months <br /> AOT is based on a staff approved topical report.

DAEC ITS 3.3.6.1 PRIMARY CONTAINMENTISOLATION INSTRUMENTATION September 15,1997 i

3.3.6.1l

DOC

JFD-CHANGE / DIFFERENCE COMMENT-STATUS 9

L14 CTS Table 3.2-A epplies Action 22 to the Main Steam Correct DOC L14 to correct the request for Line Pressure - Low Isolation Function. Action 22 a 12 hour1.388889e-4 days <br />0.00333 hours <br />1.984127e-5 weeks <br />4.566e-6 months <br /> SR extension.

requires the plant in at least Startup within 6 hours6.944444e-5 days <br />0.00167 hours <br />9.920635e-6 weeks <br />2.283e-6 months <br />.

ITS 3.3.6.1, Required Action E.1, allows 8 hours9.259259e-5 days <br />0.00222 hours <br />1.322751e-5 weeks <br />3.044e-6 months <br /> for.

achieving Mode 2 under the same circumstances. The Completion Time to reach Mode 2 allows for a controlled plant shutdown. The DAEC determined, l

based on reviews of recent plant controlled shutdowns, i

that 6 hours6.944444e-5 days <br />0.00167 hours <br />9.920635e-6 weeks <br />2.283e-6 months <br /> is not sufficient to reach Mode 2 from 100% RTP. This change extends the Completion' Time from 6 hours6.944444e-5 days <br />0.00167 hours <br />9.920635e-6 weeks <br />2.283e-6 months <br /> to 8 hours9.259259e-5 days <br />0.00222 hours <br />1.322751e-5 weeks <br />3.044e-6 months <br />.

j 10 L15 P63 STS 3.3.6.1 Actions are modified in ITS 3.3.6.1 Actions Delete this proposed change. RPS SR by a Note delaying entry into the Conditions and Notes are based on approved topical Required Actions for two hours, reflecting plant reports. Provide a revised topical report operating practice of not entering Required Actions for for staff review and approval.

Conditions caused by perfonning Surveillance Requirements. This operating practice is not pa.t of CTS 3/4.2. This position was communicated to the NRC staff in correspondence regarding the DAEC GL 89-10 Motor-Operated Valve (MOV) Program (J. Franz (lES) to W. Russell (NRC), " Generic Letter 89-10 Program," NG-94-4017, November 30,1994). L%

Completion Time is extended 2 hours2.314815e-5 days <br />5.555556e-4 hours <br />3.306878e-6 weeks <br />7.61e-7 months <br /> by this change.

e i

DAEC ITS 3.3.6.1 PrJMARY CONTAINMENT ISOLATION INSTRUMENTATION September 15,1997

3.3.6.1-DOC?

LJFD'

CHANGE / DIFFERENCE -

COMMENT:

STATUS 11 L.AV This change revises CTS Table 3.2-A Trip Level Acceptance of these changes forITS OOS Settings in ITS Table 3.3.6.1-1 instrumentation to outside the scope of TSB review and are reflect Allowable Vrtes rather than setpoints found in contingent upon NRC approval of NEDC-i the plant procedures. These Allomie Values are 31336 and its applicability to DAEC established by DAEC Instrument Setpoint Methodolocy instrument Setpoint Methodology program.

which is based on the General Electric (GE) Instrument S:,:W nt Methodology; NEDC-31336, General Electric i

f instrumentation Setpoint Methodology. The CTo Limiting Safety System Settings Allowable Value for Reactor Vessel Low Water Level, C TS 2.1.B. Nuclear System Low Pressure, CTS 2.1.F. Reactor Low Water Level, CTS 2...., Loss of Main Condenser Vacuum, CTS 2.1.J and Reactor Vessel Dome Pressure, CTS 2.2.E, are the same as the CTS Table 3.2-A setpoints.

The ITS Allowable Value are changed in the non-conservative direction, thus extending the CTS Limitirig Safety System Setting beyond the plant licensed value.

This is a misapplicatian of NEDC-31336.

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DAEC ITS 3.3.6.1 PRIMARY CONTAINMENT ISOLATION INSTRUMENTATION September 15,1997 3.3.6.1-

. DOC

JFD

. CHANGE / DIFFERENCE

_' COMMENT.

STATUS 12 LIC The Frequency of performing the Channel Calibration This extension of Surveillance Test interval OOS surveillance of CTS 4.2.A.1 and 4.2.8.1 and CTS is outside the TSB scope of review.

Tables 4.2-A and 4.2-8 is extended in ITS SRs 3.3.6.1.7 and 3.3.6.1.8 to facilitate a change to the Acceptance of this change is contingent plant operating cycle from 18 months to 24 months.

t pon NRC approval of NEDC-31336 and Historical data was utilized to vatdate that vendor-its applicability to DAEC Instrument specified drift was conservative or utilized directly using Getpoint Methodology program.

the second moment about zero (SMAZ) method described in NEDC-31336-A. ITS Table 3.3.6.1-1, extends the Surveillance Frequency for Functions 1.a.

2.a. 2.b, 3.a. 3.b. 3.d, 4.a 4.b, 4.d, 5.a, 6.b 6.c, and 7.a from the current 3 month Surveillance Frequency to 1

a 24 month Surveillance Frequency; and, for ITS Table 3.3.6.1-1, Functions 1.d 3.e,3.f. 3.g. 3.h,3.1,4.e,4.f, 4.g,4.h,4.1,5.b,5.c, and 5.f from the current 12 month Surveillance Frequency to a 24 month Surveillance Frequency. In addition, the current 3 month Surveillance Frequency for ITS Table 3.3.6.1-1 Function 5.e is extended to a 12 month Surveillance Frequency.

i

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f DAEC ITS 3.3.6.1 PRIMARY CONTAINMENTISOLATION INSTRUMENTA110N September 15,1997 -

i 3.3.6.1 IDOCL 9FD2 CHANGE / DIFFERENCE:

COMMENT

. STATUS 13-

!.CY The Frequency of perfornng the Channel Cahbration This extension of Survedlance Test interval f

OOS surveillance of CTS 4.2.A.1,4.2.D.1, Table 4.2-A and is.outside the TSB scope of review.

Table 4.2-D,4.1.A.1, and Table 4.2-A is extended in j

ITS SRs 3.3.6.1.8 from 18 months to 24 months.

Acceptance of this change is contingent Historical as-fot.nd and as-left data was utilized to upon NRC approval of NEDC-31336 and

}

validate that assumptxms of values for vendor-its apphcabihty to DAEC Instrument

?

specified drift were conservative. Where these Setpont Methodology program.

l assumptions were not validated, histoncal drift was i

utilized directly using the second moment about zero l

t (SMAZ) method desenbed ir$ NEDC-31336-A.

l 14 LCY-2 The Frequency for performmg the Logic System Acceptance of these changes for ITS are OOS Functional Tests required by CTS 4.2.A.2, CTS 4.2.B.2 outside the scope of TSB review and are and CTS 4.2.D.2 are extended in ITS SR 3.3.6.1.9 to contmgent upon staff extendng the STI to

[

facilitate a change to the plant operating cycle from 18 24 months.

l months to 24 months. The extension of the i

Surveillance Test Interval is based on a ten year review of surveillance test fadures and review of the database i

for 10CFR50.65 (Maintenance Rule).

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DAEC ITS 3.3.6.1 PRIMARY CONTAINMENT ISOI.ATION INSTRUMENTATION September 15,1997 L 3.3.6.1f DOC fJFD1 (CHANGE / DIFFERENCE i

~b COMMENT)

STATUS.

i 15 L9 CTS Table 3.2-A requwes Operabelsty of the isolaticn Provide additenal discussion and Function of Offgas Vent Stack - High Radiation dunng justification for this change.

[

venting or purgmg of pnmary containment at any time l

when primary contamment integdty is required. CTS Table 4.2-A requires Surveillance Requirements (SRs) for the Offgas Vent Stack - High Radiation Function performed in Modes 1,2,' 3 and when handhng

[

irradiated fuel in the secondary containme,nt and dunng j

Core Alterations and Operaiions with a Potential for j

Draining the Reactor Vessel (OPDRVs). CTS Table

[

4.2-A requires SRs performed for Modes and L

conditions outside the Modes of Applicatxhty in CTS Table 3.2-A. The Modes 1,2,3 and when handling l

irradiated fuel in the secondary containment and dunng i

Core Alterations and OPDRVs requirement for this Function in Table 4.2-A is replaced in ITS Table 3.3.6.1-1, with a requirement for the SRs bemg current dunng venting or purgmg of pnmary containment when pnmary containment integnty is required. This change is justified based on the Offgas Vent Stack - High

[

Radiation Function only performmg a pnmary containment isolation of the vent and purge paths.

l This justification is weak. Other isolation functions are l

surveilled and required Operable in Modes when they may be used, not when they are actually in use.

l 1

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.. = -

DAEC ITS 3.3.6.1 PRIMARY CONTAINMENT ISOLATION INSTRUMENTATION September 15,1997

3.3.6.1 l LDOC JFDl 1 CHANGE /DIFFERENCEL COMMENT STATUS 16 L8 P57 CTS Table 3.2-A and STS Table 3.3.6.1-1 includes the Provide a safety analysis basis for deleting Manual Initiation Functions for RCIC and HPCI. These this requirement.

Functions are deleted in ITS Table 3.3.6.1-1. Their removal is based on a lack of specific UFSAR safety analysis that takes credit for it.ese Functions.

17 none none The bases for T3.3.6.1-1 fu.ction 2.e, Main Steam Une Provide a JFD discussicn for this change l

tunnel temperature state that 2 cnannels per steam line to the STS. Explair. the trip system are required to be operable foi a total of 16 channels.

configuration for this function.

The table requires 4 channels per trip system in place of the "8" provided in STS.

18 RS,R6 Relocated information is not justified.

Provide additional discussion for the DOC which justifies the proposed change to CTS.

19 P42 Table 3.3.6.1-1 Note (c) is proposed as a replacement Revise the Table using Note (c) as a of Modes 1,2,3 for Offgas Vent Sack Radiation modifier of Modes 1,2,3. Revise Monitor.

Required Action L2. Revise Table 3.3.6.1-1 to include an Allowable Value.

Proposed Required Action L2 should be changed to reference the use of " continuous" attemale monitoring i

methods.

Table 3.3.6.1-1 references the ODCM in place of Allowable Value for radiation monitor.

20 P43 Deterministic criteria are used to extend CTS SR Revise the SR 3.3.6.1 requirements to OOS allowed outage times to 12 hours1.388889e-4 days <br />0.00333 hours <br />1.984127e-5 weeks <br />4.566e-6 months <br /> from 6 hours6.944444e-5 days <br />0.00167 hours <br />9.920635e-6 weeks <br />2.283e-6 months <br /> for adopt the topical report AOT allowances.

RWCU differential flow high. In the STS the SR AOT is based on staff approved topical report.

DAEC ITS 3.3.6.1 PRIMARY CONTAINMENT ISOLATION INSTRUMENTATION September 15,1997

[3.3.6.1:

.DOCJ qJFD-LCHANGE/ DIFFERENCE' iCOMMENT STATUS 21 P62 Revised HPCI Turbine Exhaust function al!owable Acceptance of these changes for ITS -

OOS va!ues.

outside the scope of TSB review and are contingent upon ti~tC approval of NEDC-31336 and its appi.cability to DAEC Instrument Setpoint Methodology program.

I 22 nene none ITS containment cooling system isolation on high Provide a number of channels per trip containment pressure proposes four channels per trip system which is consistent with the design.

i system. CTS is four channels per trip function.

Discuss any CTS differences with a DOC.

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DAEC ITS 3.3.6.2 SECONDARY CONTAINMENT ISOLATION INSTRUMENTATION September 15,1997 3.3.6.2L DOC-

?JFDl 2 CHANGE / DIFFERENCE -

COMMENT STATUS 1

L5 P63 Note 2 to the ITS 3.3.6.2 Actions reflect the operating Delete this proposed change. RPS SR practice of not entering Conditions caused by performing Notes are based on approved topecal Excess Flow Check Valve testing. Thus, ITS 3.3.6.2 reports. Provide a revised topecal report Actions, Note 2, delays entry into the Conditions and for staff review and approval.

Required Actions for two hours while performing ITS SR 3.6.1.3.7, ensuring the length of time that the condition exists is kept to a minimum. The justification discusses the following Functions in relation to this note: 1) HPCI Reactor Vessel Water Level - High, 2) RCIC Reactor Vessel Water Level - High, 3) LPCI Loop Select -

Recirculation Pump Di'ferential Pressure,4) ATWS - RPT Reactor Vessel Water Level-Low Low and 5) ATWS -

RP f Reactor Steam Dome Pressure High. However, none of these instrument Functions are required by ITS

, Table 3.3.6.2-1. Therefore, it is not evident that this note belongs in the ITS 3.3.6.2 Actions. This less restrictive change is based, in part, on NEDC-31336.

2 A.5 Action 26 of CTS Table 3.2-A requires isolating Provide justification for this less restrictive Secondary Containment and starting the Standby Gas change, showing the acceptability of Treatment System. Condition C of ITS 3.3.6.2 requires 1) adding the options of declaring the isolating Secondary Containment OR declaring the associated Secondary Containment associated Secondary Containment isolation isolation Valves / Dampers inoperable and Valves / Dampers inoperable AND 2) starting the Standby declaring the associated SBGT Gas Treatment (SBGT) subsystem (s) OR declaring the subsystem (s) inoperable.

associated SBGT subsystem (s) inoperable. The less restrictive additional options of declaring the associated Secondary Comainment isolation Valves / Dampers inoperable AND declaring the associated SBGT subsystem (s) inoperable are not justified.

i

~ _. _..._ _ _._ _ _ __ _ _ _ _. _ _ _. __...._. _.

DAEC ITS 3.3.8.2 SECONDARY CONTAlWENT ISOLATION INSTRUMENTATION September 15,1997

3.3.6.2?

LDOC-(JFDj

~

fCHANGEIDIFFERENCE JCOMMENT STATUS 3

LCY The Frequency of perfomwng the Logic System Funchonal This extension of the CTS Surveillance OOS Test of CTS 4.2.A.1 (ITS SR 3.3.6.2.5) and the Channel Test interval is outside the TSB scope of Calibration CTS Table 4.2-A (ITS SR 3.3.6.2.cy is review. Acceptance is contmgent upon extended from the operating cycle of 18 months to 24 staff approval of the acceptabihty of months. This is an extension of the CTS 4.2.A.1 extendmg the interval between Logic Surveillance Test Interval. Note, the justificahon for this System Funchonal Tests and Channel change states that "the impact on instrumentation Cahbrations from 18 months to 24 months.

rsliabdity, if any, would be sigtw# cant."

4 LIC The Channel Calibration surveillance interval of CTS Revise this justificahon for this surveillance OOS 4.2.A.1 and CTS Table 4.2-A for the Secondary extension with a justification that is not Containment isolation Instrumentation, Drywell Pressure -

based on Channel Checks. This extension High Funchon (ITS SR 3.3.6.2.4), is extended 3 months to of the CTS Survesitance Test interval is 24 months..The justification for this Surveillance Test outside the TSB scope of review.

Interval extension is based, in part, on channel checks.

Acceptance is contmgent upon staff However, ITS Table 3.3.6.2-1 does not require any approval of the accept &bility of extendmg Channel Checks for this instrumentation.

the interval for Channel Cahbrations from 3 '

months to 24 months.

5 LIC The Channel Cahbration surveillance interval of CTS This extension of the CTS Survedlance OOS 4.2.A.1 and CTS Table 4.2-A for the Secondary Test interval is outside the TSB scope of Containment isolation Instrumentation, Reactor Water review.

Level - Low Funchon (ITS SR 3.3.6.2.4), is extended from 3 months to 24 months. This change is a Surveillance Acceptance is contingent upon staff Test interval extension.

approval of the acceptatulity of extendmg the interval for Channel Cahbrations from 3 months to 24 months.

I

DAEC ITS 3.3.6.2 SECONDARY CONTAINMENTISCM.ATION INSTRUMENTATION Septanber 15,1997 3.3.6.2-DOC JFD CHANGE / DIFFERENCE CCHAMENT STATUS a

6 LAV The Trip Level Settings of CTS Table 32-A are moved to Acceptance of these changes forITS OOS procedures (CTS Table 3.2-A does not speedy ARowable outsda the scope of TSB review and are Values). ITS Table 3.3.6.2-1 specifies ABowaEe Values wdagei-d upon Staff approvalof NEDC-(ITS Table 3.3.6.2-1 does not speedy set #-42) 6

'.e 31336 and its applicability to DAEC instrumentation Funchonc, established in accordne with instnanent Setpoint Methodology p %iwn.

the DAEC Instrument Setpoint Methodo:ogy. The justification does not provide arrf nformation to enable i

verification that the ITS Table 3.3.6.2-1 Allowable Values are implemented correctly.

4 i

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i EAEC ITS 3.3.6.3 LOW-LOW SET (LLS) INSTRUMENTATION September 17,1997 3.3.6.3 DOC JFD CHANGE / DIFFERENCE COMMENT STATUS 1

R.1 The CTS 2.2 Lmtog System Safety Settog for the Low Acceptance of this change of the CTS i

OOS Low Set Valve instrument function Reactor Vessel Steam Setpoot/Allowabte Value is outside the dome pressure - high is 1055 psig. The Allowable Value TSB scope of rmnew and is crod=@wd

[

of ITS Table 3.3.6.3-1 for this funchon is s 1069.21 psig.

upon the w.r vt.tJ4 of the 14.21 psig f

There is no justification addressing the acceptabikty of the change for the Allowable Value over the less restrictive extra 14.21 psig for the Allowable Value Emtog System Safety Settmg.

(s 106921 psig) over the CTS 2.2 Lirratog System Safety j

Settmg (1055 psig).

j i

2 R.1 The CTS 2.2 Limrtog System Safety Settogs for the Low Acc.wytance of CTS Setpoot/AEowable OOS Low Set Valve instrument funchon Low-Low Set Pressure Value is outssde the TC3 scope cf review L

Setponts are - Low Valve: 1020 psig open and 900 psig and is is coiduive d upon the acceptability close. - High Valve: 1025 psig open and 905 psig close.

of the Allowable Value.

The Allowable Values of ITS Table 3.3.6.3-1 for this funchon are Low Valve: 21014 psig and s 1045 open and l

2 893.4 psig and s 925 close.- High Valve: 21019 psig and s 1050 open and 2 893.4 psig ad s 930 close.

There is no justification addressing the acceptabilits of the i

less restrictive Aliowable Value that is speofied less than j

the CTS 2.2 Lmtog System Safety Settmg i

3 R.1 The CTS 2.2 Limiting System Safety Settmgs for the Low Acr eptance of CTS Setpoint/ Allowable Low Set Valve instn.M. funchon Low-Low Set Pressure Vaiue is outside the TSB scope of review Setpomts have a tolerance spec 3=d ofi 25 psi for all and is is cwa swa upon the Wc=yt.244f settmgs. The Allowable Values of ITS Table 3.3.6.3-1 for of the Allowable Value.

l this function allow an tolerance equ: valent to i 15.5 psi (open) and i 15.8 psi (close). There is no justificahon l

addressing the acceptability of the more restnchve tolerance of the Allowable Vaiue.

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l DAEC ITS 3.3.6.3 LOW-LOW SET (LLS) INSTRUttENTATION September 17,1997 t

3.3.6.3 DOC

'_ JFD CHANGE! DIFFERENCE COMMENT STATUS 4

R.1 The Allowable Values of ITS Table 3.3.6.3-1 for the Lew Acceptance of CTS Setpom*JAllowable Low Sat Valve instrument (both the low valve and the.V Value is outside the TSB secpe of review valve). Low-Low Set Pressure Setpoets function are, for and is is wn nyant upon the acceptability

[

u the lower limit of the close function, the same, at 2 893.4 of the ANowable Value for these two

[

psig. The CTS 2.2 Liratog System Safety Settings for valves.

[

the same function is spedfied separately for the two valves - Low Valve: 990 psig close, - High Valve: 905 psig close. There is no justificahon for changmg the 5 psi differential bet;s;;a the two valves to having the same i

ANowable Value.

5 None Logic System Functional Tests are required by CTS Acceptance of this change of CTS 4.1.B.2 at least cnce per operating cycle (18 months).

Surveillance Test interval is outside the ITS SR 3.3.6.3-6 requires the Logic System Funcbonal TSB scope of review and is contig.t Tests every 24 months. There is no justification for upon the acceptability of the 24 month p

changmg the interval between the Logic System interval between Logic System Fur-Functional Tests. This is a change in the Surveillance Tests.

j Test interval from 18 months to 24 months.

6 L1 CTS Table 4.2-8 requires a daily Channel Check for the Revise ITS 3.3.6.3 to include CTS channel Low-Low Set (LLS) Function Setponts instrumentation.

check requrements.

This Channel Check, performed by ec4ing at the control l

panel LLS status lights wtuch indicate the status of the l

logic, is deleted from ITS 3.3.6.3. The justification states that operations personnel will contmue to routinely check i

the LLS status lights.

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I

DAEC ITS 3.3.6.3 LOW. LOW SET (LLS) INSTRUMENTATION September 17,1997 i

.3.3.6.3 DOC JFD CHANGE / DIFFERENCE COMMENT STATUS 7

P31 ITS Table 3.3.6.3-1 requires one Taignpe High Pressure Use the wonis ' channel,* *SRV pressure channel per Safety Relief Va!ve (SRV), with each channel switch cfiannels," and to replace consisting of three pressure switches. The ITS 3.3.6.3,

' instrument (s)* in ITS 3.3.6.3 Bases, and Action B.1, Bases, states each LLS logic" receives inputs ITS 3.3.6.3, Condatrons B and C.

from three SRV pressure switch channels,"(infemng there are three channels per SRV) while ITS 3.3.6.3, Conditions B and C, use the %imiciogy Funcbon 3 instrument (s) inoperable. The use of the word 'chantar is not used consistently throughout these references, and could lead to confusion.

8 L2 Note 2 to the iTS 3.3.6.3 SRs allows an LLS channel to Topical Report GENE-770 allows an LLS be inoperable for up to 6 hours6.944444e-5 days <br />0.00167 hours <br />9.920635e-6 weeks <br />2.283e-6 months <br /> for performing channel to be inoperable for up to 6 hours6.944444e-5 days <br />0.00167 hours <br />9.920635e-6 weeks <br />2.283e-6 months <br /> Surveillances before rsquiring entry into associated for performing Survedlances before Conditions and Required Actions. CTS Table 4.2-H, CTS requinng entry into assacated Conditions

[

Table 42-B, CTS 2.2.1.C, and CTS 42.C.2.g do not and Required Actions. Provide additional provide this allowance for the LLS instrumentation. The infonr Gen to support adopting this topical justification states that during this 6 hour6.944444e-5 days <br />0.00167 hours <br />9.920635e-6 weeks <br />2.283e-6 months <br /> penod, the report.

[

remaining Operable LLS channels are capable of performing the necessary LLS functions. However, there i

is only one channel per LLS valve required for Function 1 l

per ITS Table 3.3.6.3-1.

9 None CTS Table 4.2-8 requires a monthly Channel Funcbonal Provide discussion for this less restrictrve Test of the Low-Low Set Function Setpoints change showing the acceptability of instrumentation. ITS Table 3.3.6.3-1 requires ITS SR adopting Topical Report GENE-770 3.3.6.3.2 for the Low-Low Set Pressure Setpoints allowances for an additional 2 months irutrumentation. ITS SR 3.3.6.32 is required every 92 before repeating the Channel Functional f

days. The less restrictive increase in the surveillance Test for the Low-Low Set Pressure I

interval from monthly to 92 days is not justified.

Setpoints instrumentation.

r L

DAEC ITS 3.3.6.3 LOW-LOW SET (LLS) INSTRUMENTATION September 17,1997 3.3.6.3 DOC JFD CHANGE / DIFFERENCE '

COMMENT STATUS 10 None ITS Table 3.3.6.3-1 requires Channel Funchonal Testing Provide safety basis justification to support of the Tailpipe High Pressure instrumentation per ITS SR the proposal to not perform a Channel 3.3.6.3.1. ITS SR 3.3.6.3.1 is speofic to those porbons of FunchonalTest on the portion of this the instrumentation outside pnmary containment (CTS Funchon's instrumentation loop that is Table 4.2-H, footnote a, is speofic to the relay). There is inside contamment.

no ITS Channel Funct:enai Testing Requirement for the portions of the instrumentation inside primary containment or for the total composite channels. However, ITS Bases for SR 3.3.6.3.1 states the Channel Functional Test ensures the entire channel will perform the intended function.

11 LAV The Limiting Safety System Settings of CTS 2.2 are This change of CTS Setpoot/ Allowable OOR incorporated in ITS Tabie 3.3.6.3-1 for the instrumentation Value is outside the TSB scope of mysew.

Functions, established in accordance with the DAEC Acceptance of this change is cs.tusent on Instrument Setpoint Methodology, based on NEDC-Staff approvalof NEDC-31336.

31336. The justification does not provide information to enable verification that N ITS Table 3.3.6.3-1 Allowable Values are implemented coirectly.

DAEC ITS 3.3.7.1 STANDBY FILTER UNIT (SFU) SYSTEM INSTRUMENTATION September 15,1997 3.3.7.1-

_ DOC lJFD-CHANGE / DIFFERENCE COMMENT L

s <

i i i

1 P23 STS SR 3.3.7.1.3 calibrates the trip units every 92 days.

Provide additional discussion and justification for this This surveillance frequency assures the setpoint is within STS deviation based on current system design, or the Allowable Value, accounting for drift. ITS 3.3.7.1 operational remitation. Discuss the potential for setpoint deletes the requirement to calibrate the trip units every 92 drift resulting in a setpomt outside of the Allowable days because the " instrument loops consist of relays or Value, and resolve the discrepancy bet;;;;a the on-off sensors and do not include trip units." The iTS justification and the Bases.

3.3.7.1 Bases, on the other hand, states the " channels include electronic equipment (e.g., radiation monitors) that compare measured input signals with pre-established setpoints." Thus, the justification and the Bases are not in agreement. The justification does not discuss the potential for setpoint drift resulting in a setpoint outside of the Allowable Value.

2 P33 STS SR 3.3.7.1.1, Channel Check, is required every 12 Provide justification for this STS deviation based on hours. ITS SR 3.3.7.1.1, Channel Check, is required current system design, or operational constraints, every 24 hours2.777778e-4 days <br />0.00667 hours <br />3.968254e-5 weeks <br />9.132e-6 months <br />. There is no justification for this deviation showing the adequacy of a 24 hour2.777778e-4 days <br />0.00667 hours <br />3.968254e-5 weeks <br />9.132e-6 months <br /> Channel Check of from the GTS surveillance frequency.

the SFU system instrumentation.

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DAEC ITS 3.3.7.1 STANDBY FILTER UNIT (SFU) SYSTEM INSTRUMENTA110N September 15,1997 3.3.7.1 DOC JFD OHANGE/ DIFFERENCE COMMENT n

u I I 1 L 3

None STS SR 3.3.7.1.4, Channel Calibration, is required every Provide justification for these STS deviations based on 18 months. ITS SR 3.3.7.1.3, Channel Calibration, is current system design, or operational constraints, required every 24 months. STS SR 3.3.7.1.5, Logic showing the adequacy of 24 month intervais between System Functional Test, is required every 18 months. ITS Channel Cainbrations and Logic System Furdional SR 3.3.7.1.4, Logic System Functional Test, is required Tests of the SFU system instrumentation.

every 24 months. There is no justification for these deviations from the STS surveillance frequencies.

Additional discussion and justification is needed to support the Surveillance Test intervals of ITS SR 3.3.7.1.2, SR 3.3.7.1.3, and SR 3.3.7.1.4.

4 M.1 ITS SR 3.3.7.1.1 establishes the requirement to perform Additional discussion and justification is needed to Channel Checks of the Control Build!:1g intake Area support the Surveillance Test intervals of ITS SR Radiation High Function instrumentation every 24 hours2.777778e-4 days <br />0.00667 hours <br />3.968254e-5 weeks <br />9.132e-6 months <br />.

3.3.7.1.2.

ITS SR 3.3.7.1.2 establishes the requirement to perform 1

Channel Functional Tests of this instrumentation every 92

{

days. No justification is provided to support these Surveillance Test intervals.

5 M.1 P61 ITS SR 3.3.7.1.3 establishes the Allowable Value of the This change to the CTS Setpoint/ Allowable Value is OOS Control Building Intake Area Radiation High Function at outside the TSB scope of review acceptance is s; 50 mR/hr. The CTS does not have this requi.h contingent on the acceptability of the Allowable Value.

No justification is provided to support this Allowable Value.

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DAEC ITS 3.3.8.1 LOSS OF POWER (LOP) INSTRUMENTATION September 16,1997 3.3.8.1 DOC' JFD;

CHANGE / DIFFERENCE.

COMMENT STATUS 1

A.5 CTS Table 3.2-8. Action 33, for the 4.16-kV Emergency ITS 3.3.8.1, Action A, for the 4.16-kV Bus Loss of Voltage Function, requires, with 1 inoperable Erregency Bus Loss of Voltage Funchon, i

channel per bus, declaring the associated emergency DG does not irnplement the CTS Table 3.2-B, inoperable and taking the action required by CTS 3.5.G.1.

Action 33, requirement to declare tne ITS 3.3.8.1, Action A, requires placing that channelin trip associated emergency DG inoperable.

i i

within one hour. If Action A is not completed within one E ither provide justiin Gen for the less and hour, the DG is to be declared inoperable per Action C.

more restrictive changes or revise Action A This introduces two changes - first, the allowance for one for the 4.16-kV Emergency Bus Loss of hour before taking actions, a less restrictive change, and Voltage Function to conform with the CTS second, the requirement to trip the inoperable channel, Table 3.2-B, Action 33, requirement.

which resub in a DG start, as there is only one channel per emergency bus. Thus this is also a more restrictive l

change. While conforming to the STS format, this one i

channel system is not the model that this STS requirement is based on.

2 L1 For an inoperable 4.16-kV Emergency Bus Degraded Provide additional discussion and j

Voltage channel, CTS Tab!e 3.2-B, Action 36, requires justification for this less restncirve change, placing the inoperable channel in the tripped ccndition showmg the acceptability of continumg this within one hour. ITS Table 3.3.8.1-1, Funcbon 2, for the condition for an additional 23 hours2.662037e-4 days <br />0.00639 hours <br />3.80291e-5 weeks <br />8.7515e-6 months <br /> befcre I

same condition, proposes ITS 3.3.8.1, Action B. ITS tripping the inoperable channel. 24 hour2.777778e-4 days <br />0.00667 hours <br />3.968254e-5 weeks <br />9.132e-6 months <br /> l

3.3.8.1 Action B.2, extends the Completion Time from repair times in the STS are based on i

one hour to place the inoperable channel in trip to 24 topical reports.

l hours. The justification does not show the acceptability of l

tolerating this condition for an additional 23 hours2.662037e-4 days <br />0.00639 hours <br />3.80291e-5 weeks <br />8.7515e-6 months <br />. Note -

STS 3.3.8.1, Action A, requires tripping the inoperable channel within 1 hour1.157407e-5 days <br />2.777778e-4 hours <br />1.653439e-6 weeks <br />3.805e-7 months <br />.

l

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DAEC ITS 3.3.8.1 LOSS OF POWER (LOP) INSTRUMENTATION Septemtur 16,1997 3.3.8.1 DOC JFD-1 CHANGE / DIFFERENCE COMMENT STATUS 3

L1 For 2 inoperable 4.16-kV Emergency Bus Degraded Provide justification for this less resticJe Voltage channels, a controlled shutdown per CTS 3.0.3 is change, showing the acceptability of required. ITS Table 3.3.8.1-1, Fum: tion 2, for the same dectanng the associated DG inoperable condition, requires (TS 3.3.8.1, Action B. ITS 3.3.8.1, instead of requinng a a,E",c,1 shutdown Action 8.1, changes the controlled shutdown requrement and the safety basis for proposed Action to declaring the associated DG inoperable within 1 hour1.157407e-5 days <br />2.777778e-4 hours <br />1.653439e-6 weeks <br />3.805e-7 months <br /> of B.1 Cony;etion Time.

discovery of the loss of initiation capability, wtych requires a minimum of two inoperable channels if they are in the same trip system. This change to CTS actions for 2 inoperable channels is not justified.

4 M.1 CTS Table 3.2-B, Action 36, for an inoperable channel of Provide justification for this less restrictive the 4.16-kV Emergency Bus Degraded Voltage and the change, showing the acceptability of 4.16-kV Emergency Transformer Supply - Undervoltage unrestricted continued operation for when Functions, allows continued operation until the next these inoperable channels rare maintained Channel Functional Test, monthly and annually, in the tripped cundiGon.

respectively, with the inoperable channel placed in trip.

ITS 3.3.8.1 proposes continued operation with no restriction limited by the next required Channel Functional Test. This is a less restrictive change that is not justified.

5 LIC The Frequency of performing the Channel Calibration Acceptance of the changes to extend the OOS surveillance of CTS Table 4.2-8 for the 4.16-kV CTS surveillance test intervalis outside emergency bus loss of voltage channels is extended by the TSB scope of review and is contingent ITS SR 3.3.8.1.4 from 12 months to 24 months. The on staff acceptance.

justification is based, in part, on the redundancy of the instrumentation and Channel Checks. However, these R vise the justirn zuon for this surveillance instrument channels have only one channel per 4.16-kV extension with a justification that is not emergency bus, and have no redundancy, nor does CTS based on instrument redundancy or Table 4.2-B require Channel Checks.

Channel Checks.

DAEC ITS 3.3.8.1 LOSS OF POWER (LOP) INSTRUMENTATION September 16,1997 i

3.3.8.1-DOC JFD-CHANGE / DIFFERENCE COMMENT STATUS 6

P32 STS 3.3.8.1 Actions for all inoperable channels are to trip Provide justification for this STS deviation the channel within one hour. ITS 3.3.8.1 Action B, based on current licensirg basis, system proposes placing an inoperable 4.16-kV Emergency Bus design, and opm.'Jonal constraints.

Degraded Voltage channelin trip within 24 hours2.777778e-4 days <br />0.00667 hours <br />3.968254e-5 weeks <br />9.132e-6 months <br />. The justification does not show the STS 3.3.8.1 Actions cannot te adopted for an inoperable degraded voltage channel.

Note - CTS Table 3.2-B, Action 36, requires placing an inoperable 4.16-kV Einm wency Bus Degraded Voltage channel in the tripped condition within 1 hour1.157407e-5 days <br />2.777778e-4 hours <br />1.653439e-6 weeks <br />3.805e-7 months <br />.

f I

7 LAV CTS Table 3.2-B has the Dilowing setpoints for Functions This change to the CTS Setpoints/

OOS 1,2, and 3 respectively of ITS Table 3.3.8.1-1:

Allowable Values is outside the TSB scope 20 2 V 2 28 volts,108 2 V 2111 volts with 8.0 2 t 2 8.5 of review.

seconds time delay, and 65% of rated voltage, respectively. ITS Table 3.3.8.1-1 specifies the following Provide justification for these changes that Allowable Values for Functions 1,2, and 3: 2 595 volts, provides details and shows the adequacy 2 3780 volts with s 8.5 seconds time delay, and 2 2450 of the ITS Table 3.3.8.1-1 Allowable volts.

Values.

8 A4 DOC A.4 states that the CTS requirement for the LOP Provide additionalinformation to support Functions to be Operable when the associated ESF this conclusion.

equipment is required to be Operable in Modes 4 and 5, is equivalent to the ITS Applicability of when the associated DG is required to be Operable per ITS 3.8.2.

10 M2 ITS SR 3.3.8.1.5 proposes a LSFTwith a 24 rnonth Provide justirn Jcui and discussion for the frequency. The 24 rnonth interval is not justified.

proposed SR interval.

i

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DAEC ITS 3.3.3.2 REACTOR PROTECTION SYSTEM (RPS) ELECTRIC POWER MONITORING September 1E,1997

'3.3.8.2 DOC JFD CHANGE / DIFFERENCE COMMENT STATUS 1

LCY The Frequency of performing the Channel Calibration The extension of the CTS Surveillance OOS surveillance of CTS 4.1.B.2 for the RPS Electnc Power Test interval is outside the TSB scope of Monitoring System is extended by ITS SR 3.3.8.22 from review.

18 months to 24 rnonths. The justification for this Surveillance Interval extension is based, in part, on Revise the justificaten for this surveillance instrument Channel Checks. However, CTS 4.1.82 does extension with a justification that is not rot require Channel Checks.

based on instrument Channel Checks.

2 A2 CTS 3.1.8 for the Reactor Protechon System - Elecincal Revise the submittal, as appup%ie, to Protection Assemolies (RPS-EPAs) does not contain a include Mode 3 and Mode 4, when a specific Applicability statement. The proposed iTS control rod is withdrawn.

Applicability specified in ITS 3.3.82 IS consistent with the applicability of the ITS RPS Functions of ITS 3.3.1.1, Modes 1 and 2, and Mode 5 when any control rod is withdrawn from a core cell containing one or more fuel assemblies. However, that Applicability does not support requiremente given in special operations TS.

3 None Neither CTS 3/4.B.1 nor IYS 3.3.8.1 have time delay Resolve the discrepancy between ITS requirements asmciated with the RPS-EPAs. ITS 3.3.82 3.3.82 and the associated Bases. If there Bases, Background, discusses "after a short time delay (if is no time assumed delay in the applicable)." However, the SRs of ITS 3.3.82 do not overvoltage, undervoltage, or h:ve any requirements for time delays associated with the undmL equency trip devices, the overvoltage, undervoltage, or underfrequency trip RPS-discussion in the ITS 3.3.82 Bases, EPAs. Using the wording "after a short time delay (if Background, should be revised to exclude app!icable)" in ITS 3.3.82 Bases, Background, is not discussion of a possible time delay.

appropriate in describing the RPS-E?As.

DAEC ITS 3.3.8.2 REACTOR PROTECTION SYSTEM (RPS) ELECTRIC POWER MONITORING

, September 16,1997 4

3.3.8.2 DOC JFDr CHANGE / DIFFERENCE COMMENT STATUS 4

None CTS 3.1.B.1, w.th a Electncal Proteretion Assembly (EPA)

Prtmde justrfication for this admrustrative for an in-service MG set or attem.ste power supply

' change that changes from a WTic CTS inoperable, allows 72 hours8.333333e-4 days <br />0.02 hours <br />1.190476e-4 weeks <br />2.7396e-5 months <br /> to eitleer restore the allowance to an unspecified ITS arewance inoperable EPA or remove the as sociated inservice power to restore the inoperable EPA to leave the supply from service. ITS 3.3.8.2 Action A, for the same conditiort condition. aRows 72 hours8.333333e-4 days <br />0.02 hours <br />1.190476e-4 weeks <br />2.7396e-5 months <br /> to rerreve the associated inservice power supply from service. There is no discussion orjustification concecim,g the CTS 3.1.8.1 allowance of 72 hours8.333333e-4 days <br />0.02 hours <br />1.190476e-4 weeks <br />2.7396e-5 months <br /> to restore the inoperable EPA that is not inceipurcsied in ITS 3.3.8.2, Action A.

5 M.1 CTS 3.1.8.1 and 3.1.B.2, with inoperable EPAs, do not Revise the sutmtta!ITS 3.3.82, Actions C contain actions that require exiting the applicability of the and D to make cs-Rw.i-,9 changes to the EPAs. ITS 3.3.8.2, Action C, is added for Modes 1 or 2 to proposed ITS to A.w mnMate the revised require a controlled shutdown to Mode 3 in 12 hours1.388889e-4 days <br />0.00333 hours <br />1.984127e-5 weeks <br />4.566e-6 months <br /> if appricabiTity..

Actions A or 8 are not met. ITS 3.3.8.2, Action D is added to address Mode 5 with any control rod wittna wn from a core ceII containing one or more fuel assembres.

O DAEC ITS 3.3.8.2 REACTOR PROTECTION SYSTEM (RPS) ELECTRIC POWER MONITORING i

September 16,1997 I'

3.3.82 DOC

.JFD CHANGEIDIFFERENCE COMMENT STATUS 6

none CTS 4.1.B.2 specifies setpoint " limits" for the foHowing-Provide justifcation for this change that Overvoltage s 132-Vac changes the setpoent " limits" to Allowable Undervoltage 2 108-Vac Values.

Underfrequency 2 57 Hertz l

l ITS SR 3.3.8.2.2 specifies the same limits as AHowable Values:

i Overvoltage s 132-Vac Undervoltage 2108-Vac i

Underfrequency 2 57 Hertz L

There is no justification for changing the setpoint "lirnits" to A!!owable Values," an administrative change that l

changes ~ o nomenclature.

7 P46 The STS 3.3.8.2 Applicability includes Mode 3, and in Revise the submittal, as appivpiiate, to Mode 4 when a control rod is withdrawn. The ITS 3.3.82 include Mode 3 and Mode 4,whers a Applicability does not indude Modes 3 and 4. The control rod is withdrawn

[

justification for this STS deviation states that ITS 3.10.3 and 3.10.4 require ITS 3.3.82 and the RPS-EPAs i

Operable in Modes 3 and 4. ITS 3.3.8.2 does not have l

any ayyivpriate Actions (such as exiting the Apprecability) if Actions for restoring inoperable RPS-EPAs are not t

completed within the specified Completion Time when the RPS EPAs are required in Modes 3 and 4. Therefore ITS 3.3.8 2 is not adequate in Modes 3 and 4, to support ITS 3.10.3 and 3.10.4.

a l

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DAEC ITS 3.3.8.2 REACTOR PROTECTION SYSTEM (RPS) ELECTRIC POWFR MONITORING September 16,1997 3.3.8.2-DOC JFD CHANGE / DIFFERENCE COMMENT STATUS I

8 P46 The STS 3.3.82 Applicability includes Mode 3. The ITS Revise the submittal, as appcep.-iate, to 3.3.82 Applicability does not include Mode 3. The include Mode 3 and Mode 4, when a justification for this STS deviation states the purpose of control rod initt&own the ITS 3.3.82 instrumentation is to ensure the power produced by the RPS MG sets (and attemate source) is of a quality acceptable to the RPS. The RPS-EPAs do not cause a scram, they protect the RPS components from potentia!!y damaging voltage and frequency dips, transients, and excursions. The justification states the Applicability for ITS 3.3.8.2 is consistent with the

, Applicability of ITS 3.3.1.1. However, to fulfil the current licensing basis per the SER associated with CTS l

Amendment 79 ITS 3.3.8.2 must be Applicable whenever HPS components are pc,n.ed, not when the RPS is required.

9 P46 STS SR 3.3.8.2.1, Channel Functional Test, per the note, Make conforming changes to the proposed only requims performance prior to entering Mode 2 or 3 ITS to acc,w.m4 ate the revised from Mode 4, when in Mode 4 for 2 24 hours2.777778e-4 days <br />0.00667 hours <br />3.968254e-5 weeks <br />9.132e-6 months <br />. ITS SR appHcsbility.

3.3.82.1, per the note, only proposes performance prior i

to entering Mode 2 from Mode 3 or 4, when in Mode 4 for 1

2 24 hours2.777778e-4 days <br />0.00667 hours <br />3.968254e-5 weeks <br />9.132e-6 months <br />."

.