ML20217G434
| ML20217G434 | |
| Person / Time | |
|---|---|
| Site: | FitzPatrick  |
| Issue date: | 10/14/1999 |
| From: | POWER AUTHORITY OF THE STATE OF NEW YORK (NEW YORK |
| To: | |
| Shared Package | |
| ML20217G433 | List: |
| References | |
| NUDOCS 9910210287 | |
| Download: ML20217G434 (300) | |
Text
{{#Wiki_filter:I y- J
, ESW System and UHS 3.7.2 3.71 PLANT SYSTEMSL 3.7.2L Emergency Service Water'(ESW) System and Ultimate Heat Sink (VHS)
.LCO 3.7.2 , Two ESW subsystems and UHS shall' be OPERABLE.
' APPLICABILITY: MODES 1, 2,'and 3.
ACTIONS: CONDITION REQUIRED ACTION COMPLETION TIME A. One ESW subsystem --
-- - NOTE- -- -----
inoperable. Enter applicable Conditions and Required Actions._of LC0 3.8.1, "AC Sources-Operating," for emergency diesel generator subsystem -l made inoperable by ESW. A.1 Restore the ESW 7 days subsystem to OPERABLE.
. status.
One division of B. required deicing. - - NOTES - -- --
' heaters inoperable. Enter applicable Conditions and Required Actions of AliQ LCO 3.8.1 for emergency diesel' generator subsystem l UHS temperature- made inoperable by deicing s 37'F. heaters.
B.1 Restore'the division of 7 days deicing heaters to
' OPERABLE' status.
O 3;7-3 o- JAFNPP! ~ Amendment (ITS Submittal Rev. C) 9910210287 991014 PDR ADOCK 05000333 s a P PDR
1 z AC Sources-Operating 3.8.1 i
~ ,Os Q
- 3.8? ELECTRICAL POWER SYSTEMS' 3.8.1 AC Sources-Operating LC0' 3.8.1 The following AC electrical power sources shall be OPERABLE:
i
- a. Two reserve circuits between'the 115 kV transmission network and the plant Class 1E AC Electrical Power Distribution System; and l
- b. Two emergency diesel generator (EDG) subsystems. ;
APPLICABILITY: MODES 1, 2, arid 3. ACTIONS CONDITION REQUIRED ACTION COMPLETION TIME l l A. One_ reserve circuit A.1 Perform SR 3.8.1.1 1 hour l inoperable. for OPERABLE reserve j O V circuit. AND i Once per 8 hours thereafter-AND A.2 Declare required 24 hours from feature (s) with no discovery of no reserve power reserve power to available inoperable one division ; when the redundant concurrent with required feature (s) inoperability of are inoperable. redundant required feature (s) 1 AND (continued) i -( m JAFNPP ' 3.8 1 Amendment I (ITS Submittal Rev. C)
AC Sources-Operating , 3.8.1 O b ACTIONS CONDITION REQUIRED ACTION COMPLETION TIME 4 A. (continued) A.3 Restore reserve 7 days circuit to OPERABLE status. AND 21 days from discovery of l failure to meet LC0 B. One EDG subsystem B.1 Perform SR 3.8.1.1 1 hour l inoperable. for OPERABLE reserve circuit (s). AND Once per 8 hours thereafter AND , A V B.2 Declare required feature (s), su) ported 4 hours from discovery of by the inoperaale EDG Condition B subsystem, inoperable concurrent with when the redundant inoperability of required feature (s) redundant are inoperable, required feature (s) AND (continued) o O JAFNPP 3.8 2 Amendment (ITS Submittal Rev. C) t
re ; o AC Sources-Operating 3.8.1 ji -ACTIONS L CONDITION REQUIRED ACTION l COMPLETION TIME , B. -(continued) B.3.1 Determine OPERABLE 24' hours L EDG subsystem'is not l- -) p ~ inoperable due to l common cause. failure. l
.98 B.3.2 Perform SR 3.8.1.2 for OPERABLE EDG 24 hours l subsystem.
l AND l B.4 - Restore EDG subsystem l to OPERABLE status. 14 days
)
AND' i 21 days from -j
' discovery of lure to meet-(continued) l 1
l
-JAFNPP 3.8 3 Amendment (ITS Submittal Rev. C)
( ; f f AC Sources-Operating , 3.8.1 (y Q' ACTIONS (continued) ! CONDITION REQUIRED ACTION COMPLETION TIME i
~
\
C. Two reserve circuits C.1- Declare required 12 hours from l inoperable. feature (s) inoperable discovery of when the redundant Condition C l required feature (s) concurrent with are inoperable. inoperability of redundant required I feature (s) AND i C.2 Reduce THERMAL POWER 36 hours l to < 45% RTP. AND C.3 Restore one reserve 7 days l j circuit to OPERABLE I status, j j D .- One reserve circuit -
-- NOTE - --
l inoperable. Enter applicable Conditions and Required Actions of AND LCO 3.8.7, " Distribution Systems-0mrating," when One EDG subsystem Coniiition ) is entered with l ; inoperable, no AC power source to any division.
]
D.1 Restore reserve 12 hours l i circuit to OPERABLE status. D.2- Restore EDG subsystem 12 hours l to'0PERABLE status.
, (continued)
- ,] Ls
'JAFNPP -3.8 4 Amendment (ITS Submittal Rev. C)
r-ll J J ( AC Sources-Operating { 3.8.1 - .!
)
1 ACTIONS- (continued)
- CONDITION- REQUIRED ACTION COMPLETION TIME I
L E. Two EDG subsystems, E.1 Restore one EDG 2 hours l l inoperable. ' subsystem to OPERABLE status. l 4 F. Required Action and F.1 'Be in MODE 3. 12 hours l l Associated Completion Time of Condition A, AND-B, C, D, or E not met.
' ' ~
l L- F.2 Be in MODE 4. 36 hours
~
.G. -Three or more AC G.1 Enter LCO 3.0.3. Immediately l .
Sources inoperable. 1 O O
' JAFNPP 3.8 5 Amendment (ITS Submittal Rev. C)
y l ' AC Sources-Operating 3.8.1 ip d ~ SURVEILLANCE REQUIREMENTS: SURVEILLANCE FREQUENCY
, .SR 3.8.1.1 Verify correct breaker alignment and 7 days indicated power availability for each reserve circuit.
l-l l SR' 3.8.1.2- Verify each EDG subsystem starts from. ! standby conditions, force parallels, and achieves: a. =in s 10 seconds voltage
= 3744 V and frequency a 58.8 Hz: and l b steady state voltage a 3744 V and i'
! s.4400 V and frequency = 58.8 Hz and 31 days
-s 61.2 Hz.
1 i { SR 3.8.1.3 - ---- NOTES - - ' 1. EDG loadings may ~ include gradual l loading as recommended by the ! manufacturer, j '2. Momentary transients outside the load l range do not invalidate this test. ,. 3. This Surveillance shall be conducted l on only one EDG subsystem at a time. L 4. This SR shall be preceded by and l immediately follow,' without shutdown,
! a successful performance of SR 3.8.1.2.
l ........................................... \ j Verify each EDG subsystem is paralleled 31 days l with normal, reserve or backfeed power and L, each EDG is loaded and operates for a 60 minutes at a load a 2340 kW and i j, s 2600 kW. (continued) A.
.V e i JAFNPP
~
3.8 6 . Amendment l' (ITS Submittal Rev. C)
AC Sources-Operatir.g 3.8.1 [ SURVEILLANCE REQUIREMENTS (continued) SURVEILLANCE FREQUENCY I SR - 3.8.1.4 Verify each day tank contains a 327 gal of 31 days
- fuel oil. j
)
SR 3.8.1.5 Check for and remove accumulated water from 31 days each day tank. SR 3.8.1.6 Verify that each EDG fuel oil transfer 92 days system operates to automatically transfer fuel oil from its storage tank to the associated day tank. 1 I l SR 3.8.1.7 Verify automatic and manual transfer of 24 months plant power supply from the normal AC power l source to the reserve circuit. l SR 3.8.1.8 -- -
-- -- - NOTE- - - - --
l If performed with the EDG aralleled with normal, reserve or backfee power, it shall l be performed within the power factor limit. However, if grid conditions do not permit, the power factor limit is not required to i be met. Under this condition the power ! factor shall be maintained as close to the ! i limit as practicable. ! Verify each EDG subsystem rejects a load 24 months gieater than or equal to its associated ! single largest post accident load, and i following load rejection, the frequency is I s 66.75 Hz. I l (continued)
'O !
'Q i JAFNPP 3.8 7 Amendment I (ITS Submittal Rev. C) I ll
AC Sources-Operating 3.8.1 l (,a 1 .. SURVEILLANCE' REQUIREMENTS (continued) SURVEILLANCE FREQUENCY
.SR 3.8.1.9 -- --
-- NOTE- - - - - - -
This Surveillance shall not be performed in MODE 1, 2, or 3. , j 3 Verify on an actual or simulated loss of power. signal:
- a. De energization of emergency buses; 24 months
- b. Load shedding from emergency buses:
and
- c. EDG subsystem auto starts from standby' condition, force parallels, and:
- 1. energizes permanently connected loads in s 11 seconds, i l
- 2. energizes auto connected shutdown loads,
- 3. maintains steady itate voltage ;
2 3830 V and s 4400 V, !
- 4. maintains steady state frequency ,
a 58.8 Hz and s 61.2 Hz, and ! l
- 5. supplies permanently connected and I auto connected shutdown loads for j 2 5 minutes.
J (continued) j 1 1 L l
-7s j V !
'JAFNPP. 3.8 8 Amendment
-(ITS Submittal Rev. C)
{
F AC Sources-0perating 3.8.1 t
; /^y V SjJRVEILLANCF' REQUIREMENTS (continued) ,
)
SURVEILLANCE FREQUENCY i SR 3.8.1.10 -- - NOTE - -- - This Surveillance shall not be performed in
~ MODE 1 or 2.
Verify on an actual or simulated Emergency 1 Core Cooling System (ECCS) initiation signal each EDG subsystem auto starts from standby condition, force parallels, and: 24 months
- a. In s 10 seconds after auto start and during tests, achieves voltage a 3744 V, frequency 2 58.8 Hz;
- b. Achieves steady state voltage a 3744 V and s 4400 V and frequency 2 58.8 Hz and s 61.2 Hz;
- c. Operates for > 5 minutes:
!O t d. Permanently connected loads retain l 'd energized from the reserve or backfeed i power system; and . 1
- e. Emergency loads are auto connected in the prescribed sequence from the reserve or backfeed power system.
i (continued) I 1 t
~,
JAFNPP 3.8 9 Amendment (ITS Submittal Rev. C) i
AC Sources-Operatug 3.8.1 f3 v 5 1 SURVEILLANCE REQUIREMENTS (continued) I SURVEILLANCE FREQUENCY h SR 3.8.1.11 - -
- - -NOTE - - - --- -
l Homentary transients outside the load and power factor ranges do not invalidate this test. Verify each EDG subsystem operating within 24 months the 3ower factor limit operates for 2 8 1ours:
- a. For 2 2 hours each EDG loaded 2 2730 kW and s 2860 kW, and
- b. For the remaining hours of the test c each EDG loaded 2 2340 kW and s 2600 kW.
, (continued) O JAFNPP. . 3.8 10 Amendment (ITS Submittal Rev. C)
AC Sources-0perating 3.8.1 SURVEILLANCE' REQUIREMENTS: ~ (continued) SURVEILLANCE FREQUENCY SR 3.8.1.12. NOTE --- - - --- This Surveillance shall not be performed in MODE 1, 2,'or 3; Verify, on an actual or simulated loss of power signal in conjunction with an actual-or simulated ECCS initiation signal-24 months
- a. De energization of emergency buses:
- b. Load shedding from emergency buses:
.and-
- c. EDG subsystem auto starts from standby condition, . force parallels, and:
- 1. energizes. permanently connected loads in s 11 seconds, .
- 2. energizes auto connected emergen_cy loads in the prescribed sequence.
- 3. achieves steady state voltage 2 3830 V-and s 4400 V,
'4. achieves steady state frequency 2 58.8 Hz and s 61.2 Hz, and
- 5. supplies permanently connected
'and auto connected emergency loads for a 5 minutes.
O JAFNPP. 3.8 11 Amendment (ITS Submittal Rev. C) i.
p l , [ AC Sources-Shutdown 3.8.2 3.8' ELECTRICAL POWER SYSTEMS. 3.8.2 . AC Sources-Shutdown
.LC0 3.8.2. The following AC electrical power sources shall be OPERABLE:
, a. -One reserve circuit between the 115 kV transmission network and the plant Class 1E AC electrical power distribution subsystem (s) required by LC0 3.8.8,
" Distribution Systems-Shutdown"; and
- b. One emergency diesel' generator (EDG) subsystem capable l of supplying one division of._the plant Class 1E AC electrical power distribution subsystem (s) required by LC0 3.8.8.
APPLICABILITY: MODES 4 and 5. During movement of irradiated fuel assemblies in the secondary containment. '( L l L "l l JAFNPP. 3.8 12 Amendment L (ITS Submittal Rev. C)
AC Sources-Shutdown 3.8.2 i - ACTIONS
'md CONDITION REQUIRED ACTION COMPLETION TIME
.A. (continued) A.2.4 Initiate action to Imediately restore required reserve zwer circuit t to OPERA 3LE status.
~
B. One required EDG B.1 Suspend CORE Immediately subsystem inoperable. ALTERATIONS. l AND B.2 Suspend movement of Immediately irradiated fuel assemblies in secondary containment. AND B.3 Initiate action to Immediately suspend OPDRVs. AND i l B.4 Initiate action to Immediately restore required EDG l subsystem to OPERABLE l status. f JAFNPP 3.8 14 Amendment (ITS Submittal Rev. C)
c 1 Diesel Fuel Oil, Lube Oil, and Starting Air 3.8.3
)l 3.8 ELECTRICAL POWER SYSTEMS 3.8.3 Diesel Fuel 011,. Lube Oil, and Starting Air LC0 3.8.3 The stored diesel fuel oil, lube oil, and starting air subsystem shall be within limits for each required emergency i diesel generator (EDG).
APPLICABILITY: When associated EDG subsystem is required to be OPERABLE. l ACTIONS-
..................................... NOTE - --- ----- - --- - - ---- ---
Separate Condition entry is allowed for each EDG. CONDITION REQUIRED ACTION CCMPLETION TIME A. One or more EDGs with A.1 Restore fuel oil 48 hours (3 () fuel oil level level to within
< 32,000 gal and limits.
> 28,000 gal in storage tank.
B. One or more EDGs with B.1 Restore lube oil- 48 hours lube oil inventory inventory to within
< 168 gal and limits.
> 144 gal.
C. One or more EDGs with C.1 Restore stored fuel 7 days stored fuel oil total oil total
.particulates.not particulates to.
within limit, within limit. - (continued) ; i l (3 ( /. JAFNPP 3.8-16 Amendment (ITS Submittal Rev. C) 1
Diesel Fuel Oil, Lube Oil, and Starting Air 3.8.3 lm ACTIONS (continued) CONDITION REQUIR.ED ACTION COMPLETION TIME I i D. One or more EDGs with D.1 Restore stored fuel 30 days new fuel oil oil properties to properties not within within limits.
. limits.
l l E. One or more EDGs with E.1 Restore required 48 hours required starting air starting air receiver receiver pressure . pressure to within
< 180 psig and limits, a 150 psig.
F. Required Action and F.1 Declare associated Immediately l. associated Completion EDG subsystem l ; Time of Ccndition A, inoperable. l rm B, C, D, or E not met. 1 (') % One or more EDGs with diesel -fuel oil, lube oil, or starting air subsystem not within limits for reasons other than Condition A, B. C, D, or E. p y l O G JAFNPP 3.8 17 Amendment (ITS Submittal Rev. C)
E Programs and Manuals 5.5 l,j- 'l 5.5 Programs and Manuals 5.5.12 Safety Function Determination Proaram (SFDP) (continued)
- 1. A required system redundant to system (s) supported by the inoperable support system is also inoperable; or l l
- 2. A required system redundant to system (s) in turn j supported by the inoperable supported system is also inoperable; or
- 3. A required system redundant to support system (s) for the sup)orted systems (1) and (2) above is also inoperaale.
The SFDP identifies where a loss of safety function exists. If a loss of safety function is determined to exist by this 3rogram, the appropriate Conditions and Required Actions of the _C0 in which the loss of safety function exists are required to be entered.
]
5.5.13 CONFIGURATION RISK MANAGEMENT PROGRAM (CRMP) The CRMP provides a proceduralized risk informed assessment to manage the risk associated with equipment inoperability. The program applies to technical specification structures, systems, or 73 components for which a risk informed allowed outage time has been
'V granted. The program is to include the following:
- a. Provisions for the control and implementation of a Level 1 at power internal events PRA-informed methodology. The assessment is to be capable of evaluating the applicable plant configuration.
- b. Provisions for performing an assessment prior to entering the plant' configuration described by the Limiting Condition for Operation (LCO) Condition (s) for preplanned activities.
- c. Provisions for performing an assessment after entering the plant configuration described by the LC0 Action Statement for unplanned entry into the LCO Condition (s).
- d. Provisions for assessing the need for additional actions after the discovery of additional equipment out of service conditions while in the plant configuration descr'. bed by the LC0 Condition (s).
- e. Provisions for considering other applicable risk significant contributors such as Level 2 issues and external events, qualitatively or quantitatively.
1 i \
-%)
JAFNPP 5.0 18 Amendment (ITS Submittal Rev. C) a.-
q O' VOLUME 4 l i ITS 3.4 THRU 3e10 BASES I i i This page provided as a place holder and to assist personnel updating the JAFNPP ITS submittal to Revision C. Discard this page along with pages removed in accordance with the page replacement instructions. f 4 O l
ESW System and UHS B 3.7.2 BASES -(continued) APPLICABILITY In MODES 1, 2, and 3 the ESW System and UHS are required to be OPERABLE to support OPERABILITY of the equipment serviced by the ESW System. Therefore, the ESW System and UHS are ' required to be OPERABLE in these MODES. In MODES 4 and 5, the OPERABILITY requirements of the ESW System and UHS are determined by the systems they support and therefore, the requirements are not the same for all facets of operation in MODES 4 and 5. Thus, LC0 3.8.2, "AC ) Sources-Shutdown " which requires the ESW System to be l l OPERABLE, will govern ESW System operation in MODES 4 and 5. l l ACTIONS A.1 ? l' With one ESW subsystem inoperable, the ESW subsystem must be restored to OPERABLE status within 7 days. With the plant in this condition, the remaining OPERABLE ESW subsystem is adequate to perform the heat removal function. Hoyever, the overall reliability is reduced because a single active component failure in the OPERABLE ESW subsystem could result l f% in loss of ESW function, d The 7 day Completion Time is based on the redundant ESW System ca) abilities afforded by the OPERABLE subsystem, the low probaaility of an accident occurring during this time period, and is consistent with the allowed Completion Time for restoring an inoperable EDG subsystem. l Required Action A.1 is modified by a Note indicating that l the applicable Conditions of LC0 3.8.1, "AC Sources- ! Operating," be entered and Required Actions taken if the inoperable ESW subsystem results in an inoperable EDG subsystem. This is in accordance with LCO 3.0.6 and ensures l the proper actions are taken for this component. l B.1 l With one division of deicing heaters inoperable, the deicing heaters must be restored to OPERABLE status within 7 days. With the plant in this condition, the remaining 0PERiCLE division of deicing heaters is adequate to perform the required function. However, the overall reliability is n V (continued)
'JAFNPP B 3.7-10 Revision 0 (ITS Submittal Rev. C)
7-ESW Systems and UHS B 3.7.2
' BASES ACTIONS [LJ (continued)
, reduced because a single failure in the OPERABLE division of deicing heaters could result in loss of ESW and RHRSW function.
The 7. day Completion' Time is based on the redundant-capabilities afforded by the OPERABLE division of deicing heaters, the low probability of an accident occurring during this time period, and is consistent with the allowed Completion Time for restoring ar, inoperable EDG subsystem. Required Action B.1' is modified by a Note indicating that-the applicable Conditions of LC0 3.8.1 be entered and Required Actions taken if the inowrable division of deicing heaters results in an inoperable EDG subsystem. This is in l accordance with LC0 3.0.6 and ensures the proper actions are taken for this component.
- C.1 and Cl l ..
If,the ESW subsystem cannot be restored to OPERABLE status !:k within the associated Completion Time, or both ESW subsystems are inoperable or the UHS is determined inoperable the plant must be placed in a MODE in which the LC0 does not apply. To achieve this status, the plant must
'be placed in at least MODE 3 within 12 hours and in MODE 4 <
within 36 hours. The allowed Completion Times are I reasonable,~ based on operating experience, to reach the ! required plant conditions from full power conditions in an orderly manner and without challenging plant systems. SURVFILLANCE .SR- 3.7.2.1 REQUIREMENTS This SR verifies the water level in the screenwell to be sufficient'for the proper operation of the ESW and RHRSW pumps (net positive suction head and pump vortexing are considered in determining this limit). The 24 hour
. Frequency is based on operating experience related to trending of the parameter variations during the applicable MODES.
(continued) JAFNPP. B 3.7 11 Revision 0 (ITS Submittal Rev. C)
AC Sources-Operating B 3.8.1 L .. O BASES (continued) LC0 Two reserve circuits between the 115 kV transmission network and the plant Class 1E Distribution System and two separate i and independent EDG subsystems each consisting of two EDGs i ensure availability of the required power to shut down the reactor and maintain it in a safe shutdown condition after an abnormal operational transient or a postulated DBA. Reserve power circuits are those that are described in the UFSAR, and are part of the licensing basis for the plant. Each reserve circuit must be capable of maintaining rated frequency and voltage, and accepting required loads during ! an accident, while connected to the emergency buses. Each reserve circuit consists of one of two independent 115 kV transmission network power sources (Lighthouse Hill substation or Nine Mile Point Unit One Nuclear Station l 115 kV switchyard to the South Oswego substation), the
- incoming switchyard breakers and disconnect devices to reserve station service transformer (RSST) 71T 2 or 71T 3, and the respective circuit path including feeder breakers to l the 4.16 kV emergency b 10500 or 10600. Either 115 kV transmission network er source may be credited for l n)
- ("
supplying either one, ut only one, of the reserve circuit RSSTs and associated emergency bus. l The Limiting Condition for Operation may be met with the ;
- 115 kV North and South bus disconnect open or closed. With i the disconnect closed, the automatic opening feature must be
! OPERABLE. Additionally the automatic transfer capability ; from the normal source to the reserve circuits must be i OPERABLE. 1 Each EDG subsystem must be capable of starting, accelerating i to rated speed and voltage, force paralleli,1g and connecting to its respective emergency bus on detection of bus undervoltage. This sequence must be accomalished within 10 seconds. Each EDG subsystem must also 3e capable of accepting required loads within the assumed loading sequence intervals, and must continue to o>erate until reserve power . can be restored to the emergency auses. These capabilities are required to be met with the EDGs in standby with the engines at ambient conditions. Additional EDG capabilities must be demonstrated to meet required Surveillances, e.g., capability of each EDG to reject a load greater than or l equal to the load of a core spray pump. (continued) JAFNPP B 3.8 5 Revision 0 (ITS Submittal Rev. C)
~ AC Shurces-Operating B 3.8.1
. BASES LC0 - Proper. sequencing of loads, including tripping of (continued) . nonessential 1oads. is a required function-for EDG OPERABILITY.
The"AC sources must be separate and independent (to the'
' extent: possible). of other AC sources. . For the EDGs, the
. separation and independence are complete. For the offsite v AC sources, the separation and independence:are to the Lextent. practical. Al reserve circuit that is not connected to an emergency bus is required to have OPERABLE automatic transfer interlock mechanisms.to its associated emergency bus to support OPERABILITY of that circuit.'
. APPLICABILITY The AC sources are required to be OPERABLE in MODES 1, 2.
and 3 to ensure that:
- a. Acceptable fuel design limits and reactco coolant pressure boundary limits are not exceeded as a result i of abnormal operational transients; and O b '. Adequate' core cooling'is provided and containment OPERABILITY and other vital functions are maintained in the event of a postulated DBA.
'The AC-power requirements for MODES 4 and 5 are covered in LC0 3.8.2, "AC Sources-Shutdown."
ACTIONSt AJ To ensure a highly reliable power source remains with one
. reserve circuit inoperable, it is necessary to verify the availability of the remaining' reserve circuit on a more frequent basis. Since the Required Action only specifies
" perform." a failure of SR 3.8.1.1 acceptance criteria does not result.in a Required Action not met. However, if a second reserve circuit fails SR 3.8.1.1, the second reserve circuit is inoperable, and Condition C, for two reserve l circuits inoperable. is entered.
(continued) JAFNPP B 3.8 6 Revision 0 (ITS Submittal Rev. C)
AC Sources-Operating B 3.8.1
- O ' Bases
- ACTIONS' eu2 .(continued) required feature's function: however, function'is not lost.
The 24 hour. Completion Time takes into account the component OPERABILITY of. the redundant counterpart to the inoperable required feature. Additionally, the 24 hour. Completion Time takes into' account the capacity and capability of the i remaining AC sources, a reasonable time for repairs, and the 1
. low probability of a DBA occurring during this period.
'A.3 l With one reserve circuit-inoperable, the. reliability of the reserve power is degraded, and the potential for a loss of reserve power is increased, with attendant potential for a challenge to the plant safety systems. In this condition, however, the remaining OPERABLE reserve circuit and EDGs are adequate to supply electrical power to the plant Class 1E Distribution System.
The 7 day Completion Time takes into account the redundancy, capacity and capability of the remaining AC sources, reasonable time for repairs, and the low probability of a DBA occurring during this period. The second Completion Time for Required Action A.3 establishes a limit on the maximum time allowed for any combination of required AC power sources to be inoperable l 1 during any single contiguous occurrence of failing to meet the LCO. If Condition A is entered while, for instance, an EDG subsystem is inoperable, and that EDG subsystem is l l subsequently restored OPERABLE,.the LC0 miy already have
-been not met for up to 14 days. This situation could lead to a total of 21-days, since initial. failure to meet the LCO.Lto restore the reserve circuit. At this time, an EDG' the reserve circuit l subsystem could again restored OPERABLE andbecome inoperable, an-additional 14 days (for a total of 35 days)-allowed- rior to complete restoration of the LCO.
The 21 day Comple ion Time provides a limit on the time t
-allowed in a spcified condition after discovery of failure to meet the LCo. This limit is considered reasonable for situations in which Conditions A and B are entered concurrently. The."ANQ" connector between the 7 day and 21 day Cort'etion Times means that both Completion Times apply ,
simultr.eousl
- must be met. y, and the more restrictive Completion Time i
) -JAFNPP B 3.8 8 (continued)
Revision 0 (ITS Submittal Rev. C)
=
AC Sources-Operating B 3.8.1
/\
b BASES ACTIONS A.3 (continued)
.Similar to Required Action A.2, the second Completion Time of Required Action A.3 allows for an exception to the normal
" time zero" for beginning the allowed outage time " clock."
This exception results in establishing the " time zero" at the time the LC0 was initially not met, instead of at the time that Condition A was entered. B.1 I To ensure a highly reliable power source remains with one EDG subsystem ino>erable, it is necessary to verify the l availability of t1e reserve circuits on a more frequent basis. Since the Required Action only specifies " perform," , a failure of SR 3.8.1.1 acceptance criteria does not result in a Required Action being not met. However, if a circuit fails to pass SR 3.8.1.1, it is inoperable. Upon reserve circuit inoperability, additional Conditions must then be entered. l IL2 ! l l' Required Action B.2 is intended to provide assurance that a loss of reserve power, during the period that an EDG subsystem is inoperable, does not result in a complete loss of safety function of critical systems. These features are designed with redundant safety related divisions (i.e., single division systems are not included) equipment. l Redundant required features failures consist of inoperable i features associated with a division redundant to the division that has an inoperable EDG subsystem. The Completion Time is intended to allow the operator time l to evaluate and repair any discovered inoperabilities. This ; Completion Time also allows for an exception to the normal
" time zero" for beginning the allowed outage time " clock."
In this Required Action the Completion Time only begins on discovery that both: q l O V (continued) JAFNPP B 3.8 9 Revision 0 l (ITS Submittal Rev. C) I
AC Sources-Operating B 3.8.1 BASES ACTIONS E l (continued)
- a. An inoperable EDG subsystem exists; and
- b. A redundant required feature on the other division is inoperable.
If, at any time during the existence of this Condition (one EDG subsystem inoperable), a redundant required emergency I core cooling or containment cooling feature subsequently becomes inoperable, this Completion Time begins to be tracked. Discovering one EDG subsystem-inoperable coincident with one ' or more inoperable required support or su3 ported features, or both, that are associated with the OPERABLE EDG subsystem results in starting the Completion Time for the Required i Action. Four hours from the discovery of these events i existing concurrently is acceptable because it minimizes risk while allowing time for restoration before subjecting the plant to t ansients associated with shutdown. The remaining OPERABLE EDG subsystem and reserve circuits I are adequate to supply electrical power to the plant O Class 1E Distribution System. Thus, on a component basis,. D single active failure protection for the required feature's function may have been lost: however, function has not been l 1 lost. The 4 hour Completion Time takes into account the component OPERABILITY of the redundant counterpart to the inoperable required feature. Additionally, the 4 hour Completion Time takes into account the capacity and capability of the remaining AC sources, reasonable time for repairs, and low probability of a DBA occurring during this period. B.3.1 and B.3.2 Required Action B.3.1 provides an allowance to avoid unnecessary testing of the OPERABLE EDG subsystem. If it l can be determined that the cause of the in_ operable EDG subsystem does not exist on the OPERABLE EDG subsystem, SR 3.8.1.2 does not have to be 3erformed. If the cause of
- inoperability exists on other EXi subsystem, the EDG
! subsystem is declared inoperable upon discovery, and Condition E of LC0 3.8.1 1s entered. V (continued) l JAFNPP B 3.8 10 Revision 0 (ITS Submittal Rev. C) f i L I
AC Sources-0perating B 3.8.1
. BASES L
ACTIONS B.3.1 and B.3.2 (continued) Once the failure is repaired, and the' common cause failure l' no longer exists, Required Action B.3.1 is satisfied. If the cause of the initial inoperable EDG subsystem cannot be confirmed not to exist-on.the remaining EDG subsystem, l performance of SR 3.8.1.2-suffices to provide assurance of I continued OPERABILITY of the remaining EDG subsystem. l L In the event the inoperable EDG subsystem is restored to l l OPERABLE status prior to completing either B.3.1 or B.3.2, l
.the plant corrective action program will continue to evaluate the common cause possibility. This continued
-evaluation, however, is no longer under the 24 hour constraint imposed while in Condition B.
!- According to Generic Letter 8415 (Ref. 7), 24 hours is a L reasonable time to confirm that the remaining OPERABLE EDG subsystem is not affected by the same problem as the inoperable EDG. B4 l The design of the AC Sources allows operation to continue in L Condition B for a period that should not exceed 14 days. In i
- Condition B, the remaining OPERABLE EDG subsystem and I reserve circuits are adeguate to supply electrical power to the plant Class.1E Distribution System. The 14 day
, Completion Time takes into account the-capacity and l capability of the remaining AC sources, reasonable time for ! repairs, and low probability of a DBA occurring during this period. .In addition, the 14 day completion time is based on g
. a risk informed assessment of the EDG subsystem inoperability. EDG subsystem inoperability and the simultaneous inoperability of other plant equipment is addressed -in accordance with Smcification 5.5.13, ,
Configuration Risk Management )rogram (CRMP). The second Comoletion Time for Required Action B.4 establishes a limit on the maximum time allowed for any combination of required AC power sources to be inoperable
-during any single contiguous. occurrence of failing to meet the LCO. If Condition B is entered while, for instance, a reserve circuit is inograble and that circuit is '
L subsequently restored to OPERABLE, the LC0 may already have been not met for up to 7 days. This situation could lead to a total of 21 days, since initial failure of the LC0, to restore the EDG subsystem. At this time, a reserve circuit could again become inoperable, the EDG subsystem restored OPERABLE,_ and an additional 7 days (for a total of 28 days) allowed prior to complete restoration of the LCO. The [ (continued)
-JAFNPP B 3.8 11 Revision 0 (ITS Submittal Rev. C) '
AC Sources-Operating B 3.8.1 BASES ACTIONS B.4 (continued) 21 day Completion Time provides a limit on the time allowed in a specified condition after discovery of failure to meet the LCO. This limit is considered reasonable for situations in which conditions A and B are entered concurrently. The "AND" cornector between the 14 day and 21 day Completion j Times means that both Completion Times apply simultaneously, and the more restrictive must be met. Similar to Required Action B.2, the second Completion Time of Required Action B.4 allows for an exception to the normal
" time zero" for beginning the allowed outage time " clock."
This exception results in establishing the " time zero" at the time that the LC0 was initially not met, instead of the 1 time that Condition B was entered. ! O l (continued) JAFNPP B 3.8 12 Revision 0 (ITS Submittal Rev. C)
AC Sources-0perating B 3.8.1 f A' ,) - BASES t ACTIONS (continued) a 1 C.1. C.2 and C.3 Required Action C.1 addresses actions to be taken in the event of inoperability of redundant required . features concurrent with inoperability of two reserve circuits. Required Action C.1 reduces the vulnerability to a loss of l function. The-Completion Time for taking these actions is reduced to 12 hours from that allowed with one division without reserve power (Required Action A.2). The rationale for the reduction to 12 hours is that a Completion Time of 7 ) (}- days for two required offsite circuits inoperable is l 1 1 l
- ('N .
(,,jF _ (continued) JAFNPP B 3.8 13 Revision 0 L (ITS Submittal Rev. C) I b
[ AC Sources-Operating i
- B 3.8.1 j
/~~T
! U BASES i ACTIONS C.1. C.2 and C.3 (continued) l acceptable based upon the assumption that two complete safety divisions are OPERABLE. When a concurrent redundant required feature failure exists this assumption is not the case, and a shorter Completion Time of 12 hours is appropriate. These features are designed with redundant safety related divisions. (i.e., single division systems are not. included in the list). Redundant required features failures consist of any of these features that are inoperable because any inoperability is on a division redundant to a division with inoperable reserve circuits. ; The Com)letion Time for Required Action C.1 is intended to l allow t1e operator time to evaluate and repair any discovered inoperabilities. This Completion Time also allows for an exception to the normal " time zero" for beginning the allowed outage time " clock." In this Required Action, the Completion Time only begins on discovery that both: p a. Both reserve circuits are inoperable; and
- b. A redundant required feature is inoperable.
If, at any time during the existence of this Condition (two reserve circuits inoperable), a redundant required feature subsequently becomes inoperable, this Completion Time begins to be tracked. 0)eration may continue in Condition C for a period that l s1ould not exceed 7 days. This level of degradation means that the reserve power system may not have the capability to effect a safe shutdown and to mitigate the effects of an accident; however, the onsite AC sources have not been degraded. This level of degradation generally corresponds to a total loss of the immediately accessible reserve power sources. Because of the normally high availability of the reserve sources, this level of degradation may appear to be more severe than other combinations of two AC sources inoperable that involve one or more EDG subsystems inoperable. l However, two factors tend to decrease the severity of this degradation level: l% V (continued) JAFNPP B 3.8-14 Revision 0 (ITS Submittal Rev. C)
1' AC Sources-Operating B 3.8.1
/m t
'b BASES l i ACTIONS C.1. C.2 and C.3 (continued) l
- a. The configuration of the redundant AC electrical power ,
system that remains available is not susceptible to a single bus or switching failure: and
- b. The time required to detect and restore an unavailable reserve power source is generally much less than that required to detect and restore an unavailable onsite AC source.
With both of the reserve circuits inoperable, sufficient onsite AC sources are available to maintain the plant in a safe shutdown condition in the event of a DBA or transient. In fact, a simultaneous loss of reserve AC sources, a LOCA, and a worst case single active component failure were postulated as a part of the design basis in the safety analysis. However, Required Action C.2 is intended to l reduce the consequences of any DBA or transient event by requiring a reduction in THERMAL POWER to < 45% RTP. The consequences of DBA and transients are reduced at lower l
. THERMAL POWER leve k The limit of < 45% RTP ensures I sufficient power is available to support operating onsite loads, maintains stability of the 345 kV transmission i network, maintains stability of the feedwater system by allowing both feedwater pumps to be in service, and retains the reactor scram associated with the turbine trip above 29% l RTP. The 36 hour Completion Time allows normal plant operation to continue for approximately 24 hours prior to j init:ating any transient and still allows approximately 12 hours to reduce THERMAL POWER to < 45% RTP in an orderly and t.arefully controlled manner. The 36 hour Completion Time also allows more resources to be dedicated to restoration of at least one reserve power source during the first 24 hours after entering Condition C than would be possible if a power l reduction to < 45% RTP was required within rsme shorter time period and thus it allows sufficient time ta correct any minor causes of ino wrabilities without commencing a plant power reduction. T1e 7 day Completion Time in Required Action C.3 provides a period of time to effect restoration l of both reserve circuits commensurate with the importance of maintaining AC electrical power system capable of meeting its design criteria.
(continued) l JAFNPP-' B 3.8 15 Revision 0 l (ITS Submittal Rev. C) i
i 1 AC Sources-Operating B 3.8.1 ] t !V BASES l l ACTIONS C.1. C.2 and C.3 (continued) l 1 l 'With the available reserve AC sources two less than required l by the LCO, operations may continue for 7 days if both reserve sources were found to be inoperable concurrently. In this situation Conditions A and C must be entered l concurrently. If both reserve circuits are restored within 7 days, unrestricted operation may continue. If only one l offsite source is restored within 7 days, entry into Condition F is required. If the reserve circuits were not l l found to be inoperable concurrently, the Completion Time of Required Action A.3 must be met for the first inoperable circuit in accordance the guidance of Section 1.3 (Completion Times). This will ensure that the maximum time two inoperable circuits could be inoperable simultaneously i without entering Condition F is limited. l l 1 0.1 and D.2 l i Pursuant to LC0 3.0.6, the Distribution Systems-0perating ACTIONS would not be entered even if all AC sources to it i,q were inoperable, resulting in de energization. Therefore, 'Q the Required Actions of Condition D are modified by a Note to indicate that when Conaition D is entered with no AC source to any 4.16 kV eaergency bus ACTIONS for LC0 3.8.7,
" Distribution Syste:rs-0perating " must be immediately entered. This allows Condition D to provide requirements l l
for the loss of the reserve circuit and one EDG subsystem without regard to whether a division is de energized. LC0 3.8.7 provides the appropriate restrictions for a de energized division. According to recommendations in Regulatory Guide 1.93 l (Ref. 8), operation may continue in Condition D for a period that should not exceed 12 hours. In Condition D. individual redundancy is lost in both the reserve power system and the onsite AC electrical power system. Since power system l redundancy is provided by two diverse sources of power, however, the reliability of the power systems in this Condition may appear higher than that in Condition C (loss l of both reserve circuits). This difference in reliability is offset by the susceptibility of this power system configuration to a single bus or switching failure. The 12 hour Completion Time takes into account the capacity and capability of the remaining AC sources, p d (continued) JAFNPP B 3.8 16 Revision 0 (ITS Submittal Rev. C) L
- AC Sources-Operating l B 3.8.1 lp
,V t BASES ACTIONS D.1 and D.2 (continued) l t reasonable time for re3 airs, and the low probability of a DBA occurring during t1is period. El I With two EDG subsystems inoperable, there is no remaining onsite AC source. Thus, with an assumed loss of offsite electrical power, insufficient onsite AC sources are available to power the minimum required engineered safeguards functions. Since the offsite electrical power system is the only source of AC power for the majority of l engineered safeguards equipment at this level of l degradation, the risk associated with continued operation I for a very short time could be less than that associated with an immediate controlled shutdown. (The immediate shutdown could cause grid instability, which could result in a total loss of AC power.) Since any inadvertent Main Generator trip could also result in a total loss of offsite AC power, however, the time allowed for continued operation is severely restricted. The intent here is to avoid the ,O l risk associated with an immediate controlled shutdown and to .V minimize the risk associated with this level of degradation. According to the recommendations in Regulatory Guide 1.93 (Ref. 8), with both EDG subsystems inoperable, operation may l continue for a period that should not exceed 2 hours. l F.1 and F.2 l If the inoperable AC electrical power sources cannot be ! restored to OPERABLE status within the associated Completion Time, the plant must be brought to a MODE in which the LC0 i does not apply. . To achieve this status, the plant must be brought to at least MODE 3 within 12 hours and to MODE 4 within 36 hours. The allowed Completion Times are , reasonable, based on operating experience, to reach the I recuired plant conditions from full power conditions in an l orcerly manner and without challenging plant systems. ' G.1 Condition H corresponds to a level of degradation in which i all redundancy in the AC electrical power supplies has been ! l 1 (~
')
v (continued)
'JAFNPP B 3.8 17 Revision 0 (ITS Submittal Rev. C) i
AC Sources-Operating B 3.8.1 BASES ACTIONS. L1 ~(continued) l lost. At this severely degraded' level, any further losses in the AC electrical power. system will cause a loss of s function. Therefore, no additional time is justified for continued operation. The plant is required by LCO 3.0.3 to commence a controlled shutdown. SURVEILLANCE: The AC sources are designed to permit inspection and i REQUIREMENTS testing of'all important areas and features, especially I those that'have a standby function, in accordance with Reference 1. Periodic component tests are supplemented by extensive functional tests during. refueling outages (under simulated accident conditions). The SRs for demonstrating the OPERABILITY of the EDG subsystems are in general l conformance with the recommendations of Safety Guide 9 (Ref. 3), Regulatory Guide 1.108 (Ref. 9), and Regulatory Guide 1.137 (Ref. 10). Where the SRs discussed herein specify steady state voltage and frequency tolerances, the following summary is applicable. The minimum steady state (o output voltage of 3830 V is approximately 92% of the nominal 4160 V output voltage. This value, which is slightly-greater than that specified in ANSI C84.1 (Ref.11), allows
- for voltage drop to the terminals of 4000 V motors whose minimum operating voltage is specified as 90% or 3600 V. It also allows for voltage drops to motors and other equipment down through the 120 V level where minimum operating voltage is also usually specified as 90% of name plate rating. The.
specified maximum steady state output voltage of 4400 V is - equal to the maximum operating voltage specified for 4000 V l motors. It ensures that for a lightly loaded distribution system, the voltage at the terminals of 4000 V motors is no more than the maximum rated operating voltages. The specified minimum and maximum frequencies of the EDG are 58.8 Hz and 61.2 Hz, respectively. These values are equal to i 2* of the 60 Hz nominal frequency and are derived from the recommendations found in Safety Guide 9 (Ref. 3). l SR 3.8.1.1 [ l' - This SR' ensures proper circuit continuity for.the reserve AC !: - electrical' power -supply to the plant distribution network and availability of reserve AC electrical power. The breaker alignment verifies that each breaker is in its (continued) < JAFNPP. B 3.8 18 Revision 0 (ITS Submittal Rev. C) i
I AC Sources-Operating B 3.8.1 ( l (3 i .) BASES ' SURVEILLANCE .S_R 3.8.1.1 (continued) I i REQUIREMENTS j correct position to ensure that emergency buses and loads I can be or are connected to their reserve power source and that appropriate independence of reserve circuits is maintained. Reserve circuit alignment verification can be , accomplished by verifying that a reserve circuit bus is energized and that the status of reserve circuit supply breakers and disconnects displayed in the control room is correct. Reserve source power availability can be verified by communication with Niagara Mohawk, for the Nine Mile Point Unit One switchyard and South Oswego substation, and l the New York Power Pool for the Light House Hill substation. ' The 7 day Frequency is adequate since breaker position is i not likely to change without the operator being aware of it i and because its status is displayed in the control room. In ; addition, the Frequency is adequate since administrative ' controls are in place which re distribution system 3roblems,affecting quire plant notification aower of availability, from both Niagara Holawk and the New Yor( Power Pool. ,3, SR 3.8.1.2 U This SR helps to ensure the availability of the onsite electrical power supply to mitigate DBAs and transients and maintain the plant in a safe shutdown condition. I For the purposes of this testing, the EDGs are started from standby conditions. Standby conditions for an EDG mean that the diesel engine coolant and oil are being continuously circulated and temperature is being maintained consistent with manufacturer recommendations. This SR requires that, at a 31 day Frequency, the EDG subsystem starts from standby conditions, force parallels, and achieves required voltage and frequency within 10 seconds. The 10 second start requirement supports the assumptions in the design basis LOCA analysis of UFSAR, Section 6.5 (Ref.12), l lV (continued) JAFNPP B 3.8 19 Revision 0 (ITS Submittal Rev. C)
p-t AC Sources-Operat-ing B 3.8.1 (3 V BASES i SURVEILLANCE SR 3.8.1.2 (continued) REQUIREMENTS In addition to the SR requirements, the time for the EDG to reach steady state operation is periodically monitored and the trend evaluated to identify degradation of governor and voltage regulator performance. The 31 day Frecuency for SR 3.8.1.2 is consistent with Regulatory Guice 1.108 (Ref. 9). This Frequency provides adequate assurance of EDG subsystem OPERABILITY, while j minimizing degradation resulting from testing. SR 3.8.1.3 This SR verifies that the EDG subsystems are capable of l synchronizing and accepting greater than or equal to the eguivalent of the maximum expected accident loads. A minimum run time of 60 minutes is required to stabilize engine temperatures, while minimizing the time that the EDG subsystem is paralleled with the normal, reserve or backfeed power source. ( Although no power factor requirements are established by this SR, the EDG is normally operated at a power factor between 0.8 laaging and 1.0. The 0.8 value is the design rating of the .5 ine, while 1.0 is an operational
~
limitation to ensure circulating currents are minimized. The load band is provided to avoid routine overloading of the EDG. Routine overloading may result in more frequent teardown inspections in accordance with vendor recommendations in order to maintain EDG OPERABILITY. The 31 day Frequency for this Surveillance is consistent with Safety Guide 9 (Ref. 3). Note 1 modifies this SR to indicate that diesel engine runs for this Surveillance may include gradual loading, as recommended by the manufacturer, so that mechanical stress and wear on the diesel engine are minimized. Note 2 modifies this SR by stating that momentary transients because of changing bus loads do not invalidate this test. Similarly, momentary power factor transients above the limit do not invalidate the test. n. (continued) JAFNPP B 3.8 20 Revision 0 (ITS Submittal Rev. C) _=
p M .
- l. >
AC Sources-Operating B 3.8.1 BASES SURVEILLANCE SR 3.8.1.3 (continued) REQUIREMENTS ' Note 3 indicates that this SR should be conducted on.only one EDG subsystem at a time in order to avoid common cause l failures that might result from normal, reserve or backfeed l power source perturbations. Note 4 stipulates a prerequisite requirement for performance l l of this SR. A: successful EDG subsystem start must precede this test to credit satisfactory performance. SR 3.8.1.4. This SR provides' verification that the level of fuel oil in the day tank is at or above the level.at which the low level alarm is annunciated. The level is expressed as an ; ecuivalent volume in gallons- and is selected to ensure acequate fuel oil'for a minimum of 1.8 hours of EDG operation at full load. The'31 day Frequency is adequate to ensure that a sufficient
. supply 'of fuel oil is available, since low level alarms are t (-
provided and plant operators would be aware of any large
.uses of. fuel oil during this period.
.SR 3.8.1.5 i
' Microbiological fouling is a major cause of fuel oil degradation. There are numerous bacteria that can grow in fuel oil and cause fouling, but all must have a water environment in order to survive. . Removal of water from the i fuel oil day tanks once every 31 days eliminates the necessary environment for bacterial survival. This is the 1 most. effective means of controlling microbiological fouling.
l- In addition. it eliminates the potential for water entrainment in the. fuel oil during EDG operation. Water may come from any of several sources, including condensation, ground water,: rain water, contaminated fuel oil. and breakdown of the fuel- oil by bacteria. Frequent checking L cfor and removal of accumulated water minimizes fouling and provides: data regarding the watertight integrity of the fuel oil system. The Surveillance Fre Regulatory Guide 1.137 (Ref. 10).quency This SR is is consistent with for preventive maintenance. The presence of water does not necessarily D) A (continued)
- JAFNPP B 3.8 21 Revision 0
- f. (ITS Submittal Rev. C) s t
( (.
AC Sources-0perating B 3.8.1
.O U BASES SURVEII.LANCC SR 3.8.1.8 REQUIREMENTS (continued) Each EDG is provided with an engine overspeed trip to prevent damage to the engine. Recovery from the transient ;
caused by the loss of a large load could cause diesel engine i overspeed, which, if excessive, might result in a trip of the engine. This Surveillance demonstrates the EDG capability to reject the largest single load without exceeding predetermined frequency and while maintainng a , specified margin to the overspeed trip. The largest 3;ngle l l load for each EDG is a core saray pump (1250 bhp). This j Surveillance may be accomplis 1ed by- . l
!, a. Tripping the EDG output breaker with the EDG subsystem I carrying greater than or equal to its associated single largest post accident load while paralleled to l normal, reserve or backfeed power, or while solely supplying the bus: or j b. Tripping its associated single largest )ost accident
- load with the EDG solely supplying the aus.
(9 Consistent with Safety Guide 9 (Ref. 3), the load rejection l 'd test is acceptable if the diesel speed does not exceed the l nominal (synchronous) speed plus 75% of the difference l between nominal speed and the overspeed trip setpoint, or l 115% of nominal speed, whichever is lower. The Frequency of 24 months, takes into consideration plant conditions required to perform the Surveillance, and is intended to be consistent with expected fuel cycle lengths. i This SR is modified by a Note. In order to ensure that the EDG is tested under load conditions that are as close to l design basis conditions as possible, the Note requires that, if paralleled with normal, reserve or backfeed power, testing must be performed using a power factor s 0.9 unless j the grid conditions do not permit. In this condition the i test is performed with a power factor as close to the design rating of the machine as practicable. This power factor is chosen to be representative of the actual design basis inductive loading that the EDG subsystem would experience. (continued) JAFNPP B 3.8 23 Revision 0 (ITS Submittal Rev. C) .
y AC Sources-Operating B 3.8.1 1 1 L O sists SURVEILLANCE 'SR 3.8.1'.9' REQUIREMENTS . (continued) . Consistent with Regulatory Guide 1.108.(Ref. 9), paragraph 2.a.(1), this SR demonstrates the as designed i operation of the onsite power sources due to.an emergency l bus loss of power (LOP) signal. . This test verifies all actions required following receipt of the. LOP signal, including-shedding of the nonessential loads and ' energization of-the emergency buses and respective loads from the EDG subsystem. It further demonstrates the capability of the EDG subsystem to automatically achieve the i required voltage and frequency within the specified time. J TheEDGautostarthimeof11secondsisderivedfrom requirements of the accident analysis'for responding to a 1 design basis large break LOCA. The Surveillance should be ' j continued for a minimum of 5 minutes in order to demonstrate that all starting transients have decayed and stability has been achieved. ( The requirement to verify the connection and power supply of l permanent and auto connected loads is' intended to O ! V satisfactorily show-the relationship of these loads to the EDG subsystem loading logic. In certain circumstances, many of these loads cannot actually be connected or loaded without undue hardship or potential for undesired operation. For instance, Emergency Core Cooling Systems (ECCS) injection valves are not desired to be. stroked open, or
. systems are not capable of being operated at full flow, or RHR systems performing a decay heat removal function are not desired to be realigned to the ECCS mode of operation. In lieu of actual demonstration of the connection and loading of these loads,-testing that adequately shows the capability of the EDG subsystem to perform these-functions is acceptable. This testing may include any series of sequential, overlapping, or total steps so that the entire conneci. ion and loading sequence is verified.
I The Frequency.of-24 months, takes into consideraticr. plant conditions required to perform the Surveillance, and is intended to be consistent with expected fuel cycle lengths. ! i This SR is modified by a Note. The reason for the Note is l h (continued) JAFNPP. B 3.8 24 Revision 0 (ITS Submittal Rev. C)
AC Sources-Operating B 3.8.1 A Q BASES SURVEILLANCE SR 3.8.1.9 (continued) REQUIREMENTS that performing the Surveillance would prevent a reserve circuit from performing in accordance with its normal service, perturb the electrical distribution system, and challenge safety systems. SR 3. 8. L1_0 This SR dumonstrates that the EDG subsystem automatically starts, force parallels and achieves the required voltage and frequency within the specified time (10 seconds) from the design basis actuation signal (LOCA signal) and operates for a 5 minutes. The 5 minute period provides sufficient time to demonstrate stability. SR 3.8.1.10.d and SR 3.8.1.10.e ensure that permanently connected loads and emergency loads are energized from the reserve power system on a LOCA signal without a LOP signal. The requirement to verify the connection and power supply of permanent and auto connected loads is intended to satisfactorily show the relationship of these loads to the O V loading logic for loading onto reserve power. In certain circumstances, many of these loads cannot actually be connected or loaded without undue hardship or potential for undesired operation. For instance, ECCS injection valves are not desired to be stroked o of being ooerated at full flow, pen, systems or RHR systems areaerforming not capable a decay heat removal function are not desired to se realigned to the ECCS mode of operation. In 1leJ of actual demonstration of the connectior, and loading of these loads, testing that adequately shows the capability of the EDG subsystem to perform these functions is acceptable. This testing may include any series of sequential, overlapping, or total steps so that the entire connection and loading sequence is verified. In addition to the SR requirements, the time for the EDG to reach steady state operation is periodically monitored and the trend evaluated to identify degradation of governor and voltage regulator performance. l The Frequency of 24 months takes into consideration plant conditions required to perform the Surveillance and is l e(n) l v (continued) JAFNPP B 3.8 25 Revision 0 (ITS Submittal Rev. C)
AC Sources-Operating B 3.8.1 (3 V BASES SURVEILLANCE SR 3.8.1.10 (continued) REQUIREMENTS intended to be consistent with the expected fuel cycle lengths. Operating experience has shown that these components usually pass the SR when aerformed at the 24 month Frequer. y. Therefore, the requency is acceptable from a reliability standpoint. This SR is modified by a Note. The reason for the Note is l that durine operation with the reactor critical, performance of this Surveillance could potentially cause perturbations to the electrical distribution systems that could challenge continued steady state operation and, as a result, plant safety systems. SR 3.8.1.11' Consistent with IEEE 387 (Ref.14), Section 7.5.9 and Table 3, this SR requires demonstration that the EDGs can run continuously at full load capability for an interval of not less than 8 hours-6 hours of which is at a load equivalent to 90100% of the continuous rating of the EDG, O and 2 hours of which is at a load equivalent to 105% to 110% O of the continuous duty rating of the EDG. The EDG starts for this Surveillance can be performed either from standby or hot conditions. The provisions for gradual loading, discussed in SR 3.8.1.3, are applicable to this SR. In order to ensure that the EDG subsystem is tested under load conditions that are as close to design conditions as possible, testing must be performed using a power factor s 0.9. This power factor is chosen to be representative of the actual design basis inductive loading that the EDG subsystem could experience. A load band is provided to avoid routine overloading of the EDG subsystem. Routine overloading may result in more frecuent teardown inspections in accordance with vendor recommencations in order to maintain EDG OPERABILITY. The 24 month Frequency is consistent with the recommendations of IEEE-387 (Ref. 14), Section 7.5.9 and I i I o U (continued) JAFNPP B 3.8 26 Revision 0 (ITS Submittal Rev. C)
AC Sources-Operating B 3.8.1 BASES: SURVEILLANCE SR 3.8.1.11 (continued) REQUIREMENTS i Table 3 which takes into consideration plant conditions l required to perform the Surveillance: and is intended to be l consistent with expected fuel cycle lengths. This Surveillance is modified by a Note. The Note states
- that momentary transients due to changing bus loads
, do not invalidate this test. Similarly, momentary power !- factor transients above the limit do not invalidate the test. ( -SR 3.8.1.12 In the event of a DBA coincident with an emergency bus loss of. power signal, the EDGs are required to supply the necessary power to Engineered Safeguards systems so that the fuel, RCS, and containment design' limits are not exceeded. This SR demonstrates EDG operation, as discussed in the Bases for SR 3.8.1.9,-during an emergency bus LOP signal in conjunction with'an ECCS initiation signal. In lieu of
- (~ actual demonstration of connection and loading of loads, testing that ade uately shows the capability of the EDG subsystem to per orm these. functions is acceptable. This testing may include any series of sequential, overlapping, or total steps so that.the entire connection and loading sequence is verified.
The Frequency of 24 months takes into consideration plant conditions required to perform the Surveillance and is intended to be consistent with an expected fuel cycle length of 24 months.
- This SR is modified by a Note. The reason for the Note is l that performing the Surveillance would prevent a reserve circuit from performing in accordance with its normal service, perturb the electrical distribution system, and challenge safety systems. .
I i i-i' (continued) LJAFNPP. B 3.8 27 Revision 0 (ITS Submittal Rev. C) l
l AC Sources-Operating B 3.8.1 8ASES (continued) l ) REFERENCES 1. uFSAR Section 16.6.
- 2. -UFSAR, Chapter 8.
- 3. Safety Guide 9. Selection Of Diesel Generator Set
-Capacity For Standby Power Supplies, March 1971.
- 4. UFSAR, Chapter 6.
- 5. UFSAR, Chapter 14.
- 6. 10 CFR 50.36(c)(2)(ii).
- 7. Generic Letter 84 15 Proposed Staff Actions To Improve And Maintain Diesel Generator Reliability, July 1984.
- 8. Regulatory Guide 1.93, Availability Of Electric Power Sources, December 1974.
- 9. Regulatory Guide 1.108 Revision 1. Periodic Testing g of Diesel Generator Units Used As Onsite Electric g Power Systems At Nuclear Power Plants August 1977.
- 10. Regulatory Guide 1.137, Revision 1, Fuel 0il Systems for Standby Diesel Generators October 1979.
- 11. ANSI C84.1, Voltage Ratings for Electric Power Systems and Equipment, 1982. ;
- 12. UFSAR, Section 6.5.
- 13. ASME Boiler and Pressure Vessel Code, Section XI.
)
- 14. IEEE 387, IEEE Standard Criteria for Diesel Generator Units Applied as Standby Power Supplies for Nuclear Power Generating Stations, 1995.
.g 'd JAFNPP B 3.8 28 Revision 0 (ITS Submittal Rev. C)
}
AC Sources-Shutdown B 3.8.2
~
BASES j 1 APPLICABLE The AC sources satisfy Criterion 3 of 10 CFR 50.36(c)(2)(ii) SAFETY ANALYSES (Ref. 1). (continued) LC0 One reserve circuit capable of supplying the plant Class 1E power distribution subsystem (s) of LCO 3.8.8, " Distribution Systems-Shutdown," ensures that all required imds are powered from reserve power. An OPERABLE EDG sub;ystem, l associated with a 4.15 kV emergency bus required OPERABLE by
'LC0 3.8.8, ensures that a diverse power source is available for providing electrical power su3 port assuming a loss of the reserve circuit. Together, 0)ERABILITY of the required
. reserve circuit and EDG subsystem ensures thc availability l 4 of sufficient AC sources to operate the plant in a safe manner and to mitigate the conseguences of postulated events during shutdown (e.g., fuel handling accident.s and reactor vessel draindown).
The reserve circuit must be capable of maintaining rated freauency and voltage while connected to its respective 4.16 kV emergency bus, and of accepting required loads during an accident. Reserve circuits are those that are described in LCO 3.8.1 Bases and the UFSAR and are part of (oJ- the licensing basis for the plant. l The required EDG subsystem must be capable of starting
.acceleratingtoratedspeedandvoltage,forceparalleiing, connecting to its respective cmergengy bus on detection of bus undervoltage, and acce) ting required loads. This sequence must be accomplis 1ed within 10 seconds. The i required EDG subsystem must also be capable of accepting required loads within the assumed loading seguence intervals, and must continue to operate until reserve or backfeed power can be restored to the emergency buses.
These capabilities are required to be met with the EDG subsystem in standby with engines at ambient conditions. l Proper sequencing of loads, including tripping of nonessential loads, is a required function for EDG subsystem i OPERABILITY. The necessary portions of the Emergency Service Water System and Ultimate Heat Sink are also required to provide appropriate cooling to the required EDG subsystem. In addition, proper seguence ocoration is an I integral part of reserve circuit OPERABILITY since its inoperability n
- V (continued)
JAFNPP B 3.8 31 Revision O' (ITS Submittal Rev. C)
AC Sources-Shutdown B 3.8.2 BASES ACTIONS suspension of irradiated fuel assembly movement are not (continued) postponed due to entry into LC0 3.0.3. A.1 A reserve circuit is considered inoperable if it is not available to one required 4.16 kV emergency bus. If two 4.16 kV emergency buses are required per LC0 3.8.8 one division with reserve power available may be capable of supporting sufficient required features to allow continuation of CORE ALTERATIONS, fuel movement, and operations with a potential for draining the reactor vessel. By the allowance of the option to declare required features inoperable with no reserve power, ap3roariate restrictions can be implemented in accordance wit 1 t1e affected required feature (s) LCOs' ACTIONS. Required features remaining powered from a reserve power circuit, even if that circuit is considered inoperable because it is not aowering other required features, are not declared inoperaale by this Required Action. { D A.2.1. A.2.2. A.2.3. A.2.4. B.1. B.2. B.3. and B.4 b With the reserve circuit not available to all required I 4.16 kV emergency buses, the option still exists to declare { l all required features inoperable per Recuired Action A.1. i Since this option may involve undesirec administrative I efforts, the allowance for sufficiently conservative actions is made. With the required EDG subsystem inoperable (or l with the required reserve circuit inoperable and Required i Action A.1 not taken), the minimum required diversity of AC j power sources is not available. It is, therefore, required to suspend CORE ALTERATIONS, movement of irradiated fuel assemblies in the secondary containment, and activities 4 that could result in inadvertent draining of the reactor vessel. Suspension of these activities shall not preclude completion of actions to establish a safe conservative condition. l These actions minimize the probability of the occurrence of ' postulated events. It is further required to immediately initiate action to restore the required AC sources and to continue this action until restoration is accomplished in order to provide the necessary AC power to the plant safety systems. q Q (continued) JAFNPP B 3.8 33 Revision 0 (ITS Submittal Rev. C)
AC Sources-Shutdown B 3.8.2 f3 V BASES ACTIONS A.2.1. A.2.2. A.2.3. A.2.4. B.1. B.2. B,3. and B.4 (continued) The Completion Time of immediately is consistent with the required times for actions requiring prompt attention. The restoration of the required AC electrical power sources should be completed as quickly as possible in order to minimize the time during which the plant safety systems may be without sufficient power. Pursuant to LCO 3.0.6. the Distribution System ACTIONS would not be entered even if all AC sources to it are inoperable, resulting in de energization. Therefore, the Required Actions of Condition A have been modified by a Note to indicate that when Condition A is entered with no AC power to any required 4.16 kV emergency bus. ACTIONS for LCO 3.8.8 must be immediately entered. This Note allows Condition A to provide requirements for the loss of the reserve circuit whether or not a division is de energized. LCO 3.8.8 provides the appropriate restrictions for the situation involving a de energized division. O V SURVEILLANCE REQUIREMENTS SR 3.8.2.1 SR 3.8.2.1 requires the SRs from LC0 3.8.1 that are necessary for ensuring the OPERABILITY of the AC sources in other than MODES 1, 2, and 3. SR 3.8.1.7 is not required to be met since only one reserve circuit is required to be OPERABLE. Refer to the corresponding Bases for LC0 3.8.1 for a discussion of each SR. This SR is modified by a Note. The reason for the Note is l to preclude requiring the OPERABLE EDG subsystem from being paralleled with the reserve >ower network or otherwise rendered inoperable during tie performance of SRs, and to preclude de energizing a required 4.16 kV emergency bus or disconnecting a required reserve circuit during, performance of SRs. With limited AC sources available, a single event could compromise both the required reserve circuit and EDG subsystem. It is the intent that these SRs must still be capable of being met, but actual performance is not required l i during periods when the EDG subsystem and reserve circuit is l required to be OPERABLE. l
. REFERENCES 1. 10 CFR 50.36(c)(2)(ii).
l l o , O JAFNPP B 3.8 34 Revision 0 (ITS 3ubmittal Rev. C)
Diesel Fuel Oil, Lube 011, and Starting Air B 3.8.3 f3 V BASES-LCO The starting air system is required to have a minimum (continued) capacity for five successive EDG starts without recharging or realigning the air start re eivers. APPLICABILITY The AC sources (LC0 3.8.1 and LC0 3.8.2) are required to ensure the availability of the required power to shut down , the reactor and maintain it in a safe shutdown condition i after an abnormal operational transier.t or a postulated DBA. Because stored diesel fuel oil, lube oil, and starting air subsystems support LC0 3.8.1 and LC0 3.8.2, stored diesel fuel oil, lube oil, and starting air are required to be within limits when the associated EDG subsystem is required l to be OPERABLE. ACTIONS The ACTIONS Table is modified by a Note indicating that separate Condition entry is allowed for each EDG. This is acceptable since the Required Actions for each Condition n arovide appropriate compensatory actions for each inoperable EDG. Complying with the Required Actions for one inoperable (" ) EDG may allow for continued operation, and subsequent inoperable EDG(s) governed by separate Condition entry and application of associated Required Actions. I M With fuel oil level < 32,000 gallons in a storage tank, the 7 day fuel oil supply for an EDG is not available. However, the Condition is restricted to fuel oil level reductions that maintain at least a 6 day sup)1y (28,000 gallons). These circumstances may be caused ay events such as:
- a. Full load operation required for an inadvertent start I while at minimum required level; or
- b. Feed and bleed operations that may be necessitated by increasing particulate levels or any number of other oil quality degradations.
h (V (continued) JAFNPP B 3.8 37 Revision 0 (ITS Submittal Rev. C)
Diesel Fuel Oil, Lube Oil, and Starting Air B 3.8.3 A V BASES ACTIONS Ed (continued) limits for reasons other than addressed by Conditions A, B, C, D, or E, the associated EDG subsystem may be incapable of l performing its intended function and must be immediately declared inoperable. SURVEILLANCE SR 3.8.3.1 REQUIREMENTS This SR provides verification that there is an adequate inventory of fuel oil in the' storage tanks to support each EDG's operation for 7 days at full load. The 7 day period is sufficient time to place the plant in a safe shutdown condition and to bring in replenishment fuel from an offsite location. The 31 day Frequency is adequate to ensure that a sufficient L supply of fuel oil is available, since plant operators would be aware of any large uses of fuel oil during this period. O C' ) SR 3.8.3.2 ) 1 This SR ensures that sufficient lubricating oil inventory is available to supwrt at least 7 days of full load operation for each EDG. T1e 168 gal requirement is based on the EDG l manufacturer's consumption values for the run time of the i EDG. Implicit in this SR is the requirement to verify the '
- capability to transfer the lube oil from its storage ,
i location to the EDG, when the EDG lube oil sump does not hold adequate inventory for 7 days of full load operation without the level reaching the manufacturer's recommended minimum level. ' ! A 31 day Frequency is adequate to ensure that a sufficient lube oil supply is onsite, since EDG starts and run time are closely monitored by the plant staff. SR 3.8.3.3 The tests of new fuel oil prior to addition to the storage tanks are a means of determining whether new fuel oil is of the appropriate grade and has not been contaminated with
/\
V (continued) JAFNPP: B 3.8-40 Revision 0 (ITS Submittal Rev. C)
O VOLUME 5 OPERATING LICENSE AND CTS APPENDIX A & B (RETS) MARKUP PAGES IN CTS ORDER i i i This page provided as a place holder and to assist personnel updating the JAFNPP ITS submittal to Revision C. ~O V Discard this page along with pages removed in accordance with the
-page replacement instructions.
)
l 1 9 0 -
i h e +ro n 65 l
-ta- p, l 3 0 L. r e, oreeec-ten Q
'DM,49 The licensee s' hall implement and maintain in effect all }
D provisions of the approved fire protection program as described in the Final Safety Analysis Report for the i facility and as approved in the SER dat'ed ' November 20, 1972: the SER Supplement No. 1 dated l February 1, 1973: the SER Supplement No. 2 dated ! 0ctober 4, 1974; the SER dated August 1, 1979: the SER I Supplement dated October 3, 1980 the SER Supplement g i dated February 13, 1981; the NRC Ietter dated m l February 24, 1981: Technical Specification Amendments E 34 (dated January 31, 1978), 80 (dated May 22, 1984), 5 134 (dated July 19, 1989), 135 (dated 0 September 5, 1989), 142 (dated October 23, 1989), 164 4 i (dated August 10, 1990), 176 (dated January 16, 1992), 1 f 177 (dated February 10, 1992), 186 (dated y February 19, 1993), 190 (dated June 29, 1993), 191 * (dated July 7, 1993), 206 (dated February 28, 1994) and 214 (dated June 27, 1994); and NRC Exemptions and associated safety evaluations dated April 26, 1083, July 1, 1983, January 11, 1985, April 30, 1986. September 15, 1986 and September 10, 1992 sub]ect to h, the following provision: f.e s lu t The licensee may make changes to the approved fire i [ s ua protection program without prior approval of the
' pa, Commission only if those changes would not adversely affect the ability to achieve and d3d[ maintain safe shutdown in the event of a fire.
~p-p ep) (4) <6s -s ms T se neri ev7 . .
(A')
- -gis pro 4rw provada w m/s h "'"m.e ~
h eenM.aCl u-euemens a e scram e reduce) l leakage from the systems outside containment that would ' or could contain highly radioactive fluids during a i
.]
7 serious transient or accident to as low as practical _NgET levels.g This program shall include the following: peru e.e eJ .-
- 1. sr* ewi n i ehm eM ahlfshind maintenance and periedic I hb visual inspection requirements, and fn emou s) >
- 2. FLeak test requirements for the systems at a
) frequency not to exceed % =ary cycle intervals. -
@ reen n. Ment eerine m '
.The license shall implement a program which will sure the ca bility to ac rately dete ine the u
' f 2. 3. 0 k " .(, ai orne iodin concentration in areas vit to the
( q 2 , o ,5 mit ation of or *ecovery from n accident. *his gct.+) progr shall ine de the follo 'ng: L.P q mp . n f
} { 1. Tr ning of per nnel,
- 2. Proce ures for meni cring, and
- 13. Provisio s for mainte (nee of sampi and lysis quipment.
Th% 7 4 W b Revision C . M
fa9 ., ,
<qi 9 $ 4' 1 0 -@ upI? 4_, i;; 4 s y e. y ni l u
- l,'1T Oh !t Gll i
- a=
if , ca s e :8 'I - 1 111 1 111 [ d g $ h. l lllll l [ ' S ; blyj j D N!!!!!!8!dlI 1 1 + ! h i pI hj
. . 1 4 e ae n! j !
th 1 1 li 4 1 dlirrl1t 1pl' 34 ' l ill G gj6s!ND iv s , - e 9 lyy3 i l i4 k 4
?
t
! .f hl!ep!g}lIlkII 4, l e o!ili' n!djHii;,n j f
' ! (
Q j l t ,1 n [!I
]'l 8
' ; ib18dIQ;!j"Il,ah,}
u
!! . l!]!5j illll !!
If ! I! [ ! ll
- 2g 3 s -
l2l1 N $ O hi gy -
Dq 9 _ E . 3 _C( .d. . Q 3 - e-f5T O e g (
=
ht ee w r - M biNh h e. m o s d d g r e T ol b : v eht t n e ec n l f.. t ah g e md r i ui if oi t io s _ s o w t euN n r nqc t sdD h d r wt r ndRsoO t o o aer et pnt ee vE o n _ e u lo= ol = e s k esiwhT r I p f r r ees aesipS s a _ m r haa l o 4 e e o d ll t i aad r t C - m o pi l u cr eoMm. O i J' hicUe s oE h g c e oBaeur r r vpA2la a e eA] f r 2h r 1 v e p to n= _ t a a J. l s54oah t f o b dh pe t r C 1 - e s si t N ce n haMeEnwCnRtsCh dans . _n ph-e- 7 _4 o ea sw a
. g n sS ddtpN R e N folleti n
o r p y q e e uw _ i r o 1 lmt se ibo o it s AAe h nI e n i i "v b o e ;r. n l s s r p ee e ceTeXnio t t g e Nn e a. al n i 4 nh v v em t t f c o- t n nsc i t n de nh , o k a- n hTDin I eOmMe r vo ec g e c l a vhl vf ocfot t b aiyiH. o b 6 dt ioie l h p n e gr s yi g a h laer e rvN
.e t
n I N qi t r uoi npo t t r t i v r e s dI a l i l p ad( es ein nXp 5 ef lf aS cc s hi h t n duo e e sI _ mp Oea C epale Rrecne eod nl i r t,. q i n s n piodn50a5 a 5. tnab s o, we et h __ C e m beC yh A t T
- e i
u q L AncOih N es ug q e f r os w mtca n ue r g5. i n0mdCaoo t df r a Nar v r s t lo pSeo i e5 ar n g iu mfo e . le or ns dt ocb engelein l
.q e snt h .b Oif I
l e uoa si s nlo ef f oth ice oodsn _ a T vn ms ir ds n - Ar oeis e Sstacpaei R t.. of o mr ve ea gwl n e . it e Ruil , h e ndVg
. les p Si b odo 4 t r i es0 ebe P e dn ar iule t
c . n .. pi t n E c pM 4 qb s ene c s5f ie Son
.i t ar a i Oh ol i s ea t aVRlF 0c , ue N
n Cpilas e5 ef sh wmmFo aolen i uol t ph Rc ed r n eC r i e qce o s i c post s gaTnt o n ep l nRs e r c s0eF C ini nr or v ior _ d r e e m I. r d e .i e cp vc u oP t l e u hi s e na S Nt t n niti hd am t e a es1 it dtid t _ [ c. f t u a s o r _ n - a Oig= t e == m r i yeinf umt pi ere er i Rs e e b nnPb w1 r yr 0ndni _ it n o ]t Ceu4a I T ma8 r t o f r e t rd n aeipo Li h ieOq t c u vN r a I i aeaQ u 4 c,,# , " - C 3ht Apo2 o pvEmh wst Re uh Ss 4 g.t 1 M e, g U
- 0. L _
A IE gM 4 a. 3 D I E s c t i
' I[5 S
' }lfo~ r L t o l I s r e w hi e 't o i ) r e e A t l 1 e sn l a (s d r n e o e s mNn O i n c t no oi t i s ypotri m ) t n ( s
't a . ouo n m hiht I ea n .i a e cl nafoL g(2 n e n fic de t
e t oTd e) t o lecd nAomnr avspc lend o t t t 8 oh e dci eef i icvgmE e rL bd np i it ico i bariv r er oomdneRmor r ar E opox r e c er o anamenL diDeM p r eue l c aP enf f p dr me nB Ai co: pE oh oOsl e esqh b o y ot (m E l t p e o o et o t deeyO yct n s oetsRpsL c y cCsu i r e S i E p e B ), f hn hf e n t othmh nansh t st ni ePar A (s o st i T R gf o ameclaN id d ei n l t r m nt ol t nu e sos ocRn i t ( e hahO ed neu t ab sdecrs.r o ent yst Nhnio nno nw t f e sI T miiv ed o sad paeruceotsP i f E ias r seslel aun r r aueli t t ib 1 IOwea wi r o yit t i t sh onD I wn mcb edt sIi Ot ,i p o w lce aO T e I dndt neoiO s r d nf i N ui qe oe cb yi nI s I s) is i w n eUe b h o 4d deer mreLC rbfop r f4 0 1
)3 e.aot i hu nE com eh l v ,ylen e D
Nnt noC r t nl e e o omd r eI n a gh emd . l c t l 2t u o ye r oo 3 2 O t O e orpL Nn r alo s ceeut s r oh nS eape h n , Cer sl diqriasNA Oid i r r cmot tr 1 1 L beaa p v leuti I T e t
,s r eid oyoisi ob uis qv s ,
t at wd i v e snyop i r t r t o e J 2 A AoOees r e'c reeh pTI O Ct a t l mle earye pwsBiuo
, orbE cioo e r 2-Nnr ir n pN t o .T At ebl r euLi nNC f s ol E r O l's f I ouisOdeA qerI emR ht s
e t syer aba r meh ,o ,Ac e f n e i mieyc tc lol x Jit 8 9 n p )s( ER m h,h o a si b e t t Thne i r o n 1-dor aa n s pei Aso i r i moTuiE Cnt P wa bop ,gi t ymP t l e f r l r 4 Rni Nt l eAi yst unoenac e seOOdnh t derr e noO n f E odOdd t si nl r s 8 7 l pn ,eib afiye t eiw einpi t Pi OioTiCi t nI eohod t mi c og h me sp gyet i f si e ht vu o o oqcsh is 1 -
- mbsrieiOr e 7 6 otiwlb O O f f .
n d nC c( wsiu om ce eo epa t a a me t 3 aogAeNeie r o t t t cos r nt ) s s e r eiT ve 9 -
- a e . sNc s
c n d ps O c m ph r oi u r yduinf r f oenl t. rh taat i t 3 5 o dt r d c .eWl i d t . . e u t ne i eat aT ae i I nrd ee t t ae q sen o s o oni . aOp r p t i enwr r n N o . i n ii%inDrdp1 f ci I
? g a e we r
a n rmr i s iet e N. t l u ev .)2 Da ad
- mlyis t t
- s. em n-s, t n
O - t n yi r e c! ohNomms us eewempn cd medi( r u T t Uo ppi p e C o t nphs .,st awCatiOchna c el s i q e ht e, ur ouoos n e r rd qdnHn umm i .i
.u m L _
C E st up r _ Wd3 spCniar asis t qod .q d E c a '. e n e d 0 3 i. t .
. t c
F
. fm A d t
e
% 4 e
O
, n N' k e., h % "w. e 8 1
p t O f _ c e - L 0 , % % a, w
< tt e *1 boj o C
p9 rWhf. h **- oT o (L - Y -
# & A !*
O
@ , [dx e' i ; p)),
j.ii jJ ,i lil,l , , t ' ' 4,i . t1 i,,,!ii:! " H it 1 1"lelj$rll.IP a m i 1 . ! R ii at ' ' pn4 19 :a - 1l.hsil Ili 3 I ki n u s{ll:jiillagi?!l.I!u!hliiM 1 a 1 milg,t
, g i
O ' 111l1
~ ' "
II U O ! pult 11 b ij- p!silAlii$ l ijgl; n j'$(s! h9 []j si l q
!p li i
1 : bli 3 2 c l1 }k W 1A! pa{Il}i 2h
}l{i$[l$1l$[!![f{ h } II!! i!!
llkilIflIIIllilli0ljidllQl a an ~ O
7-g f -
- f. {
l
} j/
J O.f % o h e Toltbe o eh n eh bt i t wdeuN hg r o ,d e n if i co c t J-G Bt t o oh
)s -
.v a
- c. M k _
.s o e dEoMmo/
n ry
- f. dr wt p -
s [ - i
. e ErdeemioO mes e e u od e rI r s S a oBobo t r whT r
.J mhef eaf ortC pG e ; pS o o-y .pA2l1 a C r =
G ' o4eet hE - sraetrhea e e o .
. a e
,i a
b S E f r2hr po tnsa e a e v l m poah em dans g sit g E e C . R- .Chceet i t t r v b2h g n o t nph etnh e eaow s n h t p N :e N of f ffn i s b I e r p y s eeh e e u et m t)(sbot l i t a chTnIeX ls s i v w emon s br i np e ee xt . o a e tf oe c e Nnsleweem t lmhd eol . no s
+ a R o
ndnC ovr oc wo a t i ,ti i d Omhe mt nc t l I vfo cf'f _) h . ea s y B :. ^e. nt . Te Dintnpo I r d E e^ _6 M c o aee I p5 i c hlevN e uoi N qle eod t t nXp5 a h :.
,we e na 4, t
n duo ee r sI T um p Oee cne C Rre n si r r e pi od0 mtca n5 5. ist o df h et 3 s . M mbeCC e yh A
- e i
u Lepo e u q AncO eo Bhq er f o ue n5a0mdC e r n eoo d(Eo i r at q e: umfohed Omforuea esnt cl e Ner v I e Tvn sl e ns a f pS o engel bo ode /e . st i rds j r pv M W e _h acpae m, Rut eais Ar Rt nioeeof nr ve s l e ,h e ( eetesE cml ieo p E Ss dar o P ens pM
- w o
es0 cs5f ne e .f S-4 e' - e q, n eM s odr t G r n e pi vn - aVMR0 ue er mimmr uoE u n oqceSo i OhoE ns t esgaTnt C ph pil a e
- fo E s i
ed c r eCt ior F e5 r , f ,sh ost eo _ p@ , g r ea o n u s0o ; oPnr tr n cs1 r g
)g ve r r em.d ol en e .ie -
*c 3
u tn ni t hdam g ,.i
%g h i t i hise *a e dido t SNt oum t
r t n w n aIOigor tTmoho t iumt y o i n i piu rd Li f er e ier {" 'anP i r 0nd 1 aeap ni r I tn oet hcOq g. f o aCeu4 r t e r e e C h t Apo2p Es nhwstipoRt
%J _
0 ' P . P N 4 D E
]7 F
5 O A J f r o s tA e mNn L t o e c t o _tr _e e s iyp r e we oh t {6 d i f e s _ouo r e d n en r e O i n t n i _ t e r i t e t o a c clnefo a J^ a t e hohti oTd I el e c s ahe e cd t t t oi dd nAomnv r ee o ;f i iemEM vgrLo er s eist rh ena b at l l b ie arivrr oeca neRmor r e opord:ico do nBr
= i
,i fs o )at hl cpi ri r e ue esqh Ae t' ce f
rm rE yoi mE.a s p e ct aP bo enf t o oret o l r )s t i oatsRpi os2 wp doh e ee yO yct nSsl l t s i pl u( ct ( Eaiomin a nt gf . idn o B. mte ofmhnanuENnu int t emeceOedhah t a nt eP eisOs neu t t
.r se v t e e dNt sdmaWo n d e i yst O. _
emt e) O n i r Nh nio nno nwfe sTmi t I i v osad puceoewsdr f d ey s au l t ei bi3 t l cere mao Owre wiishnDin I ed aer mcbesnd ni1 Di _ dt wpnot ap( Tn r s _ it t t o rC _ I Te aoyd I Dao dndt t r ne nf sNuiqe olwOe i oe cb yi no l s ylen er yda )s or noHt e eiSa sUo i d rbf e op o ye r oo r eL % _ NmiuEnom O c a s .dr e ipLNn t h onoCrh t nl iele o s o m p c n (tnunhi edet dDf id o t ce eaphn c e t 7 r c r ob qt ee g spsc e n, en imot oit ofy noOe LcM Cer l eut i AOi tr o eio i v b peaaiqasriNTe f I d s uir r r s tr enyop e 2 AoOersevieeh L , pl 2 ec r pTI OCt a t mle ,ye e ar weimiah Cse u mt s ioleyc 5, Nnri nr t pN o . tat s teblab f o t t n l t OEfouisOdeAh e q sr a mep yer t t hOor oc sebd oi isf h e mtc olix o a sb ie 9 1 Thne r erI emRti r e eT Rr I s ), s dor ea n spei rl r l , goe e sis c f Aso moTuiECntPwa bop unoenf m2 n el ) t wsela s.o det er i ERntiNileAi i odOdd t n oOys a. t f sinb l i ynr i e ir n pi s vu oo S eiaf osindto( einpr n u l t ? Pi nI eohod hp , s t OioTiCimic f t egm .. mbsreit i n r iUeow l oqcsi h 2 d t i r bho mre eiT t n nC Aeciwsr t uo . eoepad connn:g a )s,o,onl a4t . l d e v S e ogc n d pN eteno ph roc t t s rhie o1 yd s n f i d E (mEih 2 hu d e o ie soc nnd t t
= s neees oCnLeoBeBs i
Ls gS t t it aat nwt r t t r n N o mlyin nme ss u t dht I e t a aTadpte e ger ede aisieg neminDr p eit n d t n n mr esne sAsAin i i I i t n msus~ f f e r ecoi R yR i u wlo i s yiLc ic i eie r ppi op e
~
t n pdrEt b sE c o r phsiOcelohNomisqe-eest htewreoouioPu ur n r P e eGoC~ ummmiu e m hs t ewCatchno qod eq C upr(h e t WdpspL cOsOstphot f i r - Ecede d n f' e 0 . ,I 8 m 3 D. E F A O gN MTTf, Q e gN O
pid i.6
- Q w <
O N qgf y i . li D
, ! /.
"il d'
; .r s
W i ]l '< R' :i 2 ;g ff i 4 ril n g
# r 9
" g ji .I' i 4 - o W d*
Df, }r! b, u. a I 4 I u . ,, h j
- b. c i K. s
${ {- ]j f $
]#
!l a
li ,a i< .o
.0 y C f ,
R' I b i '.5 q i & ? l
'1 4 '%
-i 3
>=
g s. s s" D O s ja 66 lh W M G J O Y E O
i 4
\
s}
; ,, \
1 b u, n b t 1 . 1 i?{a gg,1
'i a '
5 t g D1 r 1,>$1 9 4es i $ e o k i k. [ e iM$kb{kT
.9 1
I .
" s -. g1g 3
o s
* % 3 e i .
~
) ld \ 1;ai"\,l',
sq1, lh,\ \
'19 W\p 'i \
s
,3 \
\
d s ,,,e \k \
=
- W1A +
a \ 6s \Q bli ' all 4ttil i l e 1 c .i lib %3d9' gp n m -
- n. ?
r1 1 g~' 1 4 \ e+7 g}M g?g5 D g3,%ge e al VI a < il e ' 1 $1 b 3 2 O , C"y
T - O 4 O W ih
- 11,i e 11 "gl1 isi C- .
o
+ lae{ l]
- i d e iHI e
-sit \ ,i
-I i
4 m o i e ,
=
t
-] is k "
l j eh N j i 3 3al. ae 3.<]j fi Ij}gI. R E fijj !' gj fl.1 3 e U a s
!6
- On" s O gr vi
,,= 3 %@ l eg .o- 1%
Ap . a 3 t ~' *ni
". J
'M h< !
1 - 11 ih-
- .! g,3 o c se DI i i *g g 2 5 e S
qg M l-[rji e s 2 g, 5
~ '
n 7 L %! - li
! k 2
.i$$
11,5 a N ( l u
&.$.521 3 8 ,s l'a i
P
;i a (2 4 A !"i ! $
Q <"= % C d[l]a5b'ui3 Q j g {q& _ _ i 5 m l.- E
l o T~ ' ' e
- l. f I I
%_s =
i' . v
,, 11 i ts j 1 1 j n! $ -
- a. e .]li
))j s, > ?.;
l{> I t sc IE I 1 1 !}; 8 te f l{-lhh.b,ll
, .x ., , >l' 3 I;llh i
l eme e e I ji,h h.a5% $2 0
)
o o e gp.gpi e i i 1 1 . . .. 5 8L i w ilj l
~
i !iH
!,ilI((i]3li l
'! } ii!Isi i!} I *
,h,$
l (iIill'l!$ I{I jl ll tih I ii b.1 s fi jlliilif 1, 3 l I 1 P jx lla
,a ,. i in ! .
ugl1 af ."
. g e\
Ya , (< l O lla)fI
$7 su a fm *O
4 om3
~
J1'ih@11? l,
.k ]jn 1
i I 4 {li t
<lj!. ,i o
1 }j !ppq Hj} }: Il i
- 4 1lIIi l !!!11l3TT c'
t,f a 1911 I!llid 3 ia I I w?u% ae 4 Q 1)
- S e
[g,((4 g ,j O p
;]i 1q i : i11 p 11 Vi! z{is!!igi t
l!
!! Oil!I jf{IlJ{f) i 1iliu I ! t
&r ios v. pa > ,
e' 1 O d 3 l 'a
$ ' d, b -
)
g f l , _ O f s s he r h a s icv ho t wv s e . l t i g mr
- 1 e 2 f
e su e vet o f v ola y ht v 4 ue r oh e 1 rm 2 e(( /e .. nh e eh s ssi sr f { _ 3 nht yn aolo t si r e _ ot o plch y at p o 4 ppm y lj s s mf o b%te teeo l ht 3 C 3 a os3 ie0f w1 a a t e D r n s c ey s diant m o id dhe nt af o o r v t A v2e eah v et t eh u miq r we o t d a gg gSd o
. e g
a i i o s v s p R e l l m e a va te onc l f a r l hs v rh et e e i o a sin f s p_ r a c
/
J e l e v o s yat o sut s ntc e a i l e e h d e by f oi r b E e w o gS&ev nv l e vh f t ie no e g al oSt r Da l t y e a e e r t o hs d e f n a 1 pBt % o Q l hom t i nAde ] s h ev t ss ne
, t s
e er e A rSck. _ edt hnr a c dl o sthu y4 _ t 2 t at s e nv i s L L s o mTt6 0% hn s - v oeuo f l n n csTie r e
~
fr e ynm p heas J. lepi l ne i r a e t gmd o t pd ye hwe m od y obn e t a e e e t ll t ep e st L a b iindvl b u mio n hs 4 d Gv s'- hr e oa h l n ebs a er t u a t n ret ot s e p ' Tps M st h mfet . c t _ P f 6 Q h -
- 4-A P @ ' _
N L # . F 9' _ O A J l l h a s gi nadl t o n r e g q 3,
- L.
2-egQo r ht id wno ds
} 2 2
e n e l
'l
- b n _ l 0 o M.
b wd u e ot on b a 3 t .3 ot i r e 0 t t s 3s l l a t ofice r ic ro v ic l p g 8 N R. t (3 no f r 6e w h s r et s opcl i p a s- ed gn c 3 D o r o t a s s es ae t 7 o a alla (.0 M ok t c r ea t es r o n t 2 r .2 ea s. psav e t o dle22 1 . r ot r nt r h r a nn 5 e o e o ean o N1 ht t co ndt ec D. e epr e M
.yn . epidaed .
0 r uwle "5 9 e t o m' s r mvr o e v 3 v st s s /r
- 7 1
B dor n c ph e o n o l a .
.t m o v t t oi nw ae edel it a f cr o r M gb vn r /, eiut M sno na oas ic i t T
l ir i e tat aa c s eb F d i t if r 0 i c /yoer sr e 9 1 E. d i t epao12ae e p t r p S ed ymhe l t n 1
- 8. no s i E. 2 he c S T het 6 M
t 3c ih f st yi 8. 5 e o t n 2 nk oo i hw3s pd n ien v s n I d n-aru i 3. 4 ict r eo e o e se a et iuo t r r is e t yd I o H n wiatc t t i v o 5 ee cdt ee N c omirac pr f e e a f l aboa r t g ii sati ns r ed pec eicpr p t n Sa wpeme e ee aae hper r cdi e Tori rm
-t ep h m f
l p to. b s teh t T d A I
. n I
2 5 e 6 3
$. 4e A m
(
]M OU V w
Tt ' C (A
0 E 0&. 1 1jtl'1/ pa 4 1 lj}q l~ v n
] [ ! ,;g a x 5I 3, I I I, i P . ,1w 5-
}j *j i I a! ,
L1 38 N l o
!il:_ilb J I1 :1@
l fI 3
, qle e
,,: r F. '
g ; u, r2
- 1 4 g qa i.
a
- 1 11 !
11 :i
,{
Nm s li fI
,i f
e i u
, 4 {
's %
O in
- n. * ~ ~
V
- 4 I,
6 4 = m 0 '
)
. i j
i, [I{ = Sg j 2 t* o' 9 k
% m{1.. t.h
.Y E & E 1 '. M U q (
Y N U 1 5 13 j i 6 t h[/ i ; pj kIkr a i v1i*r S 8 l j.g z i ( .: e :
.o 3.g i g g i : ,
"J v s
I e w E. j fI g 5' j
. ! l I- ;
g' M ;3 4 * '
.! {! j t 1' 3 I 35[.jla[
4 eli ef3i ,! a ,a = ll'h' Msi' e
" ? g i, I *5 AO 3s s n-L:
A& I e)R i fp e i "j F 4fJ t } *
/- $ Es 2 <l i, 'i2 ~.
is f ( 4 m. gy 4 4Y$
- bi .
b $~ 2 b , h. . b e s { $ l l 4 Y i!h 4 ~.' : s P ';i - el d .: r o w+ dCL <g g ? .i i ;t - i O i o'
..(~- $ .k r ,\
wT ' " *4
+ .e l
l 3 - 3 4 m 3 ! :l 5 , 3. < y 3 3 4 2 Si ' 0 EE0 t -E 'i $ ! ! T 4f4 tie kia , i> j .l fi g 43,.e 3.4
<g*
- ~. !
o _tir. 'E , l
!~f t'dk hf.13 l-
.3 ) i 2"+
G7' , +' T
43 $*
- y 4Eit1 <
~
{ ta w4Y 4?f i idi re; ll ev.ij < t<<=z 13 5'o[,y$j,7 J4i 5
,, 2 se y +
l
I O e
,h Ojif~e bg P s i- in hI i n it i li pl t '1 3 2s i
~32 d 2 k$ I #
1 7 83 d -a
'1 ! $ M j. li ? ?!l i ". 4 4 2 j lll]e10 t
1j1 [p[p r u t r
!!l 4 il ;; e 4 or ute :i ll ju 3 i a l i il jQ1k l I l
i }=e . d t m u l ,u.lj i['M3 pr in F s k' }" o s "i e an h s ie si. ,t ts iqi. aaei i - b lip e 4 t n.-J; 31, I!gI o 7 3 1<L a i {3
; ; l } ((i { 11 l i; e,k=i e q {ip -
ai - 4
$- f l f gaj{l'1igpN eJAulf!!i}h!!h u m a ,
3 ;t i ' Y $ rjg O % e
O 3, g 8 Q . s ek d w y e n beo c o yi t ri e g h
*, ll e l
l a t 's c f n t 6 t.a li a abetbwrnoe uac h ei sd r ootb id t e rk f l l oair nasotl roldtca ac o
,4 C fs C aa rl t e s rel mtf i nwlo rerni e el sh c y 5 n y i nuew o ee if ifee sbenirset do l i a g y e e i e-ph e t a tii g a sb n. s m cil a cah r ret e ts i v
NR e hiDl r ,ept f ehl il fr
*- e
?
t s ch at en a w yh s t nd e csnaoeWbedb
.tomptil dl ee~
a nv 5' S y r e w
,sremme n
hogeel rl0t era orcl K e i i t t r t d e el 0 t t ec naes s ct ar 2. ut t oa n a pe t h t eh hs n s ai e c e r h po ormyocf meEStaaa5 ssn o r hetrdn .; o e yh r p d ii m ea p C
- cgnoetl et ndta r o A a att reh i a eld a a al td a e g s h e p
y enritl ett n c esuet sa .dnsid ra e c n cedni nieenoauoatuo rsai
) e g O d r G i t pb l maDI nl d Oa
't r
e ' n m . . c o E 1 2 [sO ( 9 B
]4 B 4 3 L J3 ,4 _ b O .
e R {S ge od r l F g d g b l nn toea rf . ne o snf p l .s ii n ci n r 7 o old s i n it l mio a mi ra l el e I p I I h 3. ri ml oarie o i eel ph a di c u t l er ol n c o pt . eh atodnbn A - F s s B. o cetrp ocrnt ao nna e ueeslh n yi
, yceilh sono i O t A p l
i nt r ad e e s tl t / J ra e 9. ct i otdahesn se ur td agGhoe2 een 4 aao esl tt rdebguhdhw n ei ai Td
- wt3a ty t C pe.e op r
al enosmn hnvif s il esretili tib t n amscoiianetns he t free afvDrid o elttcro o n A g tort a cxc 2. e eneli usAdlh nat e r vrerypouA l pcooh ett oi l m itre 8. th emsol n de moecbur i
.ohi meedb n cs .hci O. vt 5
t e s y l9 ce A. 9. 3n
,h e . irr tf e r.issma eeneiaotcbhoo etD s y r h yl e csw ern il el sei .ee tbeussgrtee arnsyranhlfRo iiae en etbI tad c
t A L t S e wn hl ommdf natti hirt mdmsn a e s tb rr .sder ct taenr Emadr .hd r f 31.tio a yo e7 n e g ef ai vhoe7 el neytl dt; r e pt r ll f p adrpI ed ratcp ttaapa o o w o n 3. e i i el ns drieo.rn o e i tte.seayne dnst od .c s _ s f po y c dfv teonsetvm
- 9. sn oEeyec fo ri e d S ol eht a C
td i e3ea aahr ifn.c dsu li oer aie gt n x cer v ph ad t t d rah anhegmnxurcn dsuroedodr et nesve rexis cbrt s aanin ._ p# o s a nioei erosh ,lo niooi r l A bii4.ld a a rftoraapme du t e ac o c metvr rctosebmt sc rhsat r oesl eo y c n l ipe e d 5. rhiat ei rl st e7t ow ret rysei sa metnr aettnreseia ow hee t l ch k a h n. o
) e av s fi 9. e r o r e p o r a a yh x n r o r r p o o e o r yh tl 4 d
e r asi3h eced t F po s o n o ed St ei Fpot o n b G c a s t s p2 a6e t e e n m hepnn . i' w o E Tbsai 1 2 ( c 9 B 3
- M
. l M
O 7
f Og g l 4 u2 _ t p d n r o s, n D e a
- e. 9, ,, o h e c ht g t
a g
, i c
I n, ; ,, t a . t b n a ie wlb n r e n la ou n eg. ,g t t ns h c d it e g i l t e nwa c e ear ns r a g n ee s hf iw n aje n eG ee 8 i v . 33 mt ur b(- wdle e sl , np s l na t e t sb l i t s t i od hme t e wre da o e a aos e i ut g r o - ri r p g gA t t sa '() eu el u mni t on ew r eb r il e Ss nr d a da ne r oh n od D o ni n t nh v ie ur opa f ctm a r ey et o
. u o, me n I *Y g ss r ed c
afh a o s m ee c e c ha t i nr oo c: eg b nn ne n im n na wer l i y s pf om iprbce nym b
- a l
- t. (-.
t sy i it f mg: me l
- ed s.
r yi A s oi dlie s oe e me ou yst wo te e a sth dt s h ,cs ef r tebt s r t c c:s r n ny al a y u iymt n eh t t cts a k* C dSEu e am sf i oo t te e t s ef q e43 p: am t oS c r a rar t p ri e pva S6o b rdd yro l be 4 n
. se 6 r ee eo he ht t l e oa o8 ge ait n et r
f a r oe e e v tr e ad ts o i o s _ c nh et t a r e ct eh pracb t l e or pl u em c- _ nhrh e i gn ac n q t t t e d gg e r ai ie t,ne et oef ar n pia yn. v _
? hd l n e ts ,s o nf a ep ev s uf e t osr e _
S ui sen u g t n G ntd o l oaa r b3. s e w he Geo e r r a. m o a
> R 2
ed i e o ir8. G l ce A l hn p l edo i-.or mte A d d m s mtsl o 9. se on n . eef t i e a m s, c ye ell y c3e di nedm N. opom bo -? laigen t r : 4 ie dic ci r L ck nc 2_D owne a nDee e i l De ac ena - ee r o t y y iyta g yae '; nm cr a t gh r e sg L- nl e se v nce dr t r e c e o er e a nt r crb s mn e hc e s a nt e s n P Acg A pd oie oe n t ei g n c gnm t t t mb e_ g a am ti f e l c e uee er l r l ie cr o emc e r oe emts g ela n m mn e h pn e or EdS mey hh sgteh WSEdf
) a r . .
i d Ts O (E a b. c M 't n o c T 41
.(g .
5 h. l ( 9 (3 8, gE g l 5 T f-1 P "t , O P 4 3 3 N F t f t-r f t 3g l I ho )r 'S I A J l e s e y {5 E {s e n w a Dle, d o 4d nw e t e ya b io r gl pf4ot a on eca r 3 n e edr 1i c r e ne ep p is a mes hnn i t a e s mt s e p [l N 5 2 go oD t oe es t a o r n r o c f o cg , ei n on se yl r s me f a dl e dl 2 St u 2
- 2 on nos 3 i
Eb 8 r ao eo " wia e ce i d oeh f e L 3 e 2
"g ht t
d : eemet t ao ow t r h t I W 2 r t (
~
f n es 9 ou t e ne t m haler[h t eo er in h I nf 4 htath l t f Geh e - 2~, or o s t e bi l t w W ni bs t l sraw o i t ae n fhbt a e hd t a t ^ o - eh bt se e pu s i r 2 i
- e Dot it 3 aN - S em ar _drnpAs yna d n
t 6 ? m s e .a o s ho ao c s t s o Wd L "'* it e i s pj. e o sb ro un l i st ne ebe c o a i 3 hm r y em t gob r l d l o o Au 4' 2' *o ; 1 t e toa Re e mi c et ar c t 5, r t cd vs t a mde # f c. tey s a4 e-ay e Enp 0 e r uo 4 f aSr r 1 r eS ho h/%1 t 0 a ro t f o do dd ee st o t /e 0 nt aa ue nc ce e bem r
'r sy de M ** e .
ix t m n nee o edt t c r t e d" w ._ N o m o ne a ha s y a u o l e t t
) r oo Wms (e rh D n
d f ct w - e *" h e
't
( n o c 3
. f,k - 4 5
. d m
n e 6 8 f 9 % 4ae** ] }F A m O E f 3 o [M T.5%*W'a 3
" r dr
- T T' c J. os C
g {A oe r b i T c c A {A
42 O h!sri;b il I111tiimb e 4 3 tu - il
;=i r .
a b . . 3 5
, .i i e g . i g ti h al i
/ k dk 3 dl
- l. W'P"L j O ~~
i
- e. ,,',
s i iS$ ,1 11 Q a i i le n"
} 3 il I i n p E
d dII sl i M g y a f 1 , 1* x 1fIk$" lH "
}, k O
e o _1, ' f sh>l i c B II$j $q i {p ]i;) tab _.h
- 4 4. > si-np 1 8 i
d d M* il l '{eg"a p 2 1 ga a p , g
- l. i; 1
$ 11 aj ,1 ** 1.
t 3 4 1.1 I
;g >n u _{I o y
O I i k fj h l' Q.s k n h i rp
~ -
i 4 o "n b{% 3-{3e le 3i e,1 a, o . i l l i oo e. t 24 e i
\bh k3 hk
.
- T 1 2: :: *
{ \9, 3 4)al 1 d"A I g g 11 2 4i a
% 3 '
;} !
O ii !
i! ji l'lI ii O I k 6 - 3 2
, l r 8 , Q l
4 3 C t.a 9 n o 2 c
- 3 n. e. i i
s v e.
~g 3
J. C.
%R e y '
S
' S T
$e-J b j__ 4 e -
n l b 4 a c
$ h u
Vf
)
d c
't n A P o t o
P c N ( N F 9 A 4 D. O J l s s . e .k a g ei s d yan ni e e s n n ht e e e n omr v l l l i h e e t n se o t e ebC l un eto d' o b i pt e s a t s s a y n b a a r anD ehe pe ag f u e f ed o amsceedrarA hniahr it c pd l e pt hnt a r r hame i e en3 i n t n l ossf int t oo .or s f r r o af o ict et f f ieoe r dni o or ba ie B. he ota s s n o e nt hosiaoo,iu sq b 9 cl n n c e i w c yit g g t n yt snnn emr e al e a ncelio i wrb t s lnres e oof ool ti i l w o u o at.ey i inh
,idmt e e o nie r t cdl eg a o ds ae nr g o sae d odie a nt annsr aee yo t
eD s e p C. uf 0 er t r
' htaGl dt eoa n 't ari c f
e a pS 0. e 0 h t u he ur sw, c dnlomd go ot e ht ss nge t ehet af i i t sreola 3 ro 0, S m ncstc nu osd on r stdri e ,oe e c cf neocnt4 d do l eie o pt sebe ,n a na cl o i i Degpe odthie l no s6 l o ce y s l ei scsyot r os e dr op io l e suca t rf C t eiS iemnldnacn scr S r se oo a hf s s od t o o ksnouinni ht uoeTict r e s ah f t r a t c du f m n t f r vt e et oaoec t t e 'p r vt i n n ot r o i ee e n e ndcre o nt cma l ere asepww i u e ar s sne.w i t l w t e f a m l ear D oal sne e ie n's m S o n i y h ccha ofoen .magros -t t ubh l e v r nt e iaa dp nr o sde delGs nto"l,am t ehni t i t 3 hs c oG dr m ehr ot on kr t i 5 aotdeir mun he o" see b aml oe nrt ocnci 2 e reiegaorsnao l t r t sl vio r c nwds f a e i r y . nt t o r us r u snc e s t e el n u oles 3 r oyoc vD 0a mr y ef t p eme i i eand e ahl a pbr ehee ecr t 8 Ft Sca no0r e r oi ut t O hnD,hrorW ti y s dsmceodu e 0,ein uhn r e mc~el r wf o nu o hia 4 e eq8 ua e addesesdmso r va n N c W p6 G r 4 q w e e t,l btieep , l os Ped n e,r g o aniiu r r sleaiie semrr t a edepr euu s s s u d
't Co hompet upoqq rt evf rue l
eqdw s.. n o 3 AM WmEsopreeo ap no -. e.. ( c _ e
. n.
9 D A 3 O I l
4 4' r, ~
),A 99 & c '
E i i i!!i1l5[*"3df$ i 4 o i o d $ tb ! 8!! @ $ ! d OO i a 1
" !!j 3l 2 a
'ilz e4 ] a 4 f b .
i h e 4 a , es - Ih ") (\^/ seg i e g O ta ri1lMC? C{lji: 3 1p j kIr}p{N]}jo hi i i . 1- ? I i j a3 1]Ik! !"1.gi- 11
? $j ll =!!a I qljl}$
1 lj{]}fil! Pi i{j e ig ip le' n{ai a
. gi; i
]
d, i
!"g{lth!!h'l'{+!
jfy{, 5 - 9S T
'g, , i o
'k '18 O 5rb i *6 "$$
)
o erf' p 4
;;6 4 4e 3
g 4 i Y. 3 , aN Li
*i9
\
0 F
-o 6 q
p ^ V g b n o D hkhh[kI g ta i ' 'k , Wg' ni Yg$0
~s 3
\
O
a Sn @c:,I c _c o.'44 : gl], g gj @pll 1 4 j a i i 1 1:' u tj p *r ' h! i l( al i ~ 0 la al al li s n. H ;: %
! t, h a mi: :ry k ?
ja'fid ll! bli W}ll:1 bi ? 1 o Al ' :: ' g :: gl l'ig,']"n"a' d s? & Q e i
'i tn :
m o 11 11 r!! I 1p
!,! I,l. j thj'll m ,i l n.
2 f-f
.a i.
1 l >l i n ? ' *= 1$'11lllj]<= 5 - ,g
~
o~ ~ v f O . r . . . .
ni
- o. h:d)*~
g d 3 <( mh; l _ ti l a e sq r.VfII
] 4c}
u .
, ? '
I $Il N 4 e $ l'lj h]!k N !t jj i4 j !3 Il flI;! " o
]1T' s 1] ul ls ,
1 l a3 jag !.] [;n.i 1 E P ' jl *j f e
,5
-j s a n
~
r p O l3:' s:\ s en *" 1 t'b*"{ 5 sn 2 l u i
- 1. 1 1 1 rg i Uo v# e! i1:.g >
l:,],i.0, mi z n4 4, 4, a: ii -
=
~
r 8
- ~*1 i o ;
d i <5 4E ji i l h.se[ <j jj l{g}s a 2 :! s> u 4) h,[Ipalllll l,1
. 1 =
# I j i3 {jgf d a I i
a .;i; 84 (f., e vo ~ j C3 { l hkUI}$i A;.3k iSb I O
F {
$ e e e' o a f.f O C w g. $ . Cye.us er ~
Y
, T< wo W L'* g C74l hp d4 [d '
/_
(h) The iollowing recores shall be retained for the uration of the Facility Operating License
\
- 1. Records of any drawing chan a c'flecting e facility 4 mod ications made to systems and equipment described ign safe Analysis Report. the Final 2.
Records f nu sad irradiated fue inventory, fuel transfe a and assembly usamp histories. -
- 3. Records of sility radiation and co asiaation surveys.
4. Recorda of rad ties esposure for all 1 ividuals entering radi ion control areas.
- 5. Records of gaseous and liquid radioactive
**'A'**** " terial released to the f u peop a , po'evocitJ co m oU *tu t % aj 4.
ff* f 6compeaents transientidentified or operational cycles for those. facility in Esa4e 4.NF3.7 __ M. g gg f Rec as of training and qu ification for current plas statf. abers of the
- 8. Records of ta-service inspectio g y.
Technica Specifications. performed pursuant t these h 4.CP
- 9. Records of ality Assurance activi les required by the O Assurance sal. lity ,
- 10. Records of to ews performed for chang made to procedures equipment or a views of tests and exper ats pursuant to 10 Crt 50.59.
11 secords of meetin of the PORC and the FR
- 12. ecords for saviro y ovisions of paragr stal Qualification which re severed under the b 6.15.
l
- 13. mec who rds of the service ife of all hydraulic and echanical anubbers, inc1 failure could adve sely affect any safety-r ated system, ag the date at whi the service life couse es and associated instal . tion and maintenante anneadacht. N records as of the effe ive date of this -
1.11 \ RAaIATIhN PROTtcTICW 140enAM \ precedure for persoon radiation pr tection shall b repare ad adh for ed to for 11 plaat ope tions. Thes procedures shal be ates to me tain radiat esposures ceived asiste practi ace as ta below the li ta specifie in 10 crtduriaf 2s aso ration a d le. The y cedures shal include pia ing, preparatio and training, or operatie and maintena e activitie t They shall a o include es sure alloca on, radiati and contas ation control techniques, nd iinal det ieflag. (Taenas.nt n.. x. x. n creer dated Octoser 24, 1980 M yS; .ts, t.D / 235 h e k OE Revision C
$"g.e.tI o n 6.I j
~~
O - g as O k (PCF) (6.'16PROCESSCONTROLPROGRAM A. The pCP shall be a manual containing operational informatio concerning the solidification et radioactive wastes from liquid systems. -
*,. The PCP shall be saintained at the plant consistent with these Technical Specifications and with approved plant
. procedures.
C. Revisions of the PCP:
- 1. shall be submitted to the Commission in the Sesiannual Radioactive Effluent Release Report for the period in which the revisions were made effective. This submittal shall contain:
- a. sufficiently detala d information to support the rationale for the revisions without benefit of additional informations b a determination that the revision did not reduce the overall conformance of the solidified waste product to existing criteria for solid wastes; and
- c. documentation that the revision has been reviewed and found acceptable by the 70RC.
- 2. shall become effective upon issue following review and ac_ceptance by the PORC.
CFFS T't DOSE CALCULA?!CN MANUAL fCDCM) ff,f, l , g, A. The CDCM shall describe'the methodology and parameters L to be used in the calculation of offsite doses due to radioactive gaseous and liquid effluents and in the calculation of gaseous and effluents sonitoring instrumentation alara/againes tris setpoints/consisten wti% r ta appA1 As I.cca taese ethnica spe icati . y Q2
- 3. ;
eo shall saintai d at the laat an shall lect opted nodolo s and c ulation pr edures. _
- l Amendment No. 93 258b .
NEY II8 b*l l Wyaw.D Revision C l
dec +Eo a [.[ C in rke S w oS a.
' C * * !* * ' * * ' #* leu jeg.We c,p y h5" i . 0 C. Eevisiese of the ODCNs of +e e.dee obc.ar pr of o r-q o.,urre.,,r sw M 1 g,g* ,, c,3 m 1.
J shall be enheitted to the Ceente 1= ne ====mm \ Radleastive Effluent telease toyert for the period is which the i revielene woro sede(arrest 6 shall oestaine IMS@ {. f. l. C . l.@)) a. nffieleat1F detailed informaties Q ~nsdoew= u suppenWsae 's3 i '2fde.li fr tas\reviele su (i ernstae submit shall r&t er ist of u4 taforma a 1 sed e of Q with page red arewi' with rey M te O ther with_ appropriate evalue-less f, f, l, C, . l,g g justifying the twielene)s
@a4 i e4 er g,fgg t
- b. a daterminaties that the revielee d it1&& han Dedeed the asy or reliability ofA dose salemisticas er sospoint f-,
eff[wvae , detesialaationes and e eteret of rever Ar ser4riseew/ fid/Ja vu'reas/) M
]
g N [s.g.i.c.1] i. .4411 m en. e eti,e - 1.a
""'***" "' * 'ts M.'. . ,,,
a W and
,a ., * , , u .g. , y a ,.
8.18 on unerrte APTame to ainreat=PTvu rasiio, am;:- aan ene_en.
,, , , . . . ....e Ml
- h. Major modifications to radisastive weste systeme (11guld, gaseems and solid):
f
- 1. shall he reported to tL Commissies is the Semiannual Radienstive Efflaset Release k9:ert for the period is which the modificaties is sempleted and made operatieaal. The discussion of each modificaties shall contains
- a. a summary of the syslaaties that led to the determinaties that the modifietties 'ess14 he sede la asserdamse with 10 CFR 50.50s
'a . sufficient Laformaties to support the reases for the modification witnest benefit of additional or supplemental informations and
- e. a descripties of the equignost, sempeemste and processee savelved and the interfaces with other plaat f ethe hotherity aer eleet to enheit the informaties called for is this Speetfacaties as part of the asemal 10 CFR S0.59 Safety Besameties asport.
a -.
- See t [ e4 AS Revision C
g.c. /O4 I .5' A\ ( {f,f POSTACCIDENT SAMPUNG PROGRAM and mamtair hd *Nsure the S eraan m osa ne a eamianna im=== capacihty to octam and analyze reactor cooiant. radioactive iodines and particulates in plant gaseous ofnuants. and contamment atmosphere samples under acodont conditions. The program shalt include the following: A) Training of personnel, B) Procedures for sampling and analyses, C) Provisions for mamtenance of sampling and analysis S $ PRIMARY CONTAINMENT LEAKAGE RATE TESTING PROGRAM Id # r Y" g -.. r= - ---- a d@T M leakace rate toebng of the Pnmary Containment as requered by 10 CFR 50.54 (o) and 10 CFR 50, Apperdx J Ophon B. as modrfied by approved exemphons. This program shall be in accordance with the guide 6mes contamed in Regulatory Guide 1.163, "Performath Contamment Leak. Test Program', dated September 1995, as modified by the excephon that Type C tesang of valves not isolab6e from the containment free ser spsee may be accomphshed t y pressunzabon in the reverse direction provided that testmg m this manner provides equrvaient or more conservative results than testmg in the accident direchen. If potenbal atmosphenc leakage paths (e g., valve stem packmg) are not subjected to test pressure, the portons of the valve not exposed to test pressure shall be subjected to leakage rate measurement dunng regularly scheduled Type A testmg. A list of these valves, the leakage rate measurement method, and the acceptance entena, thall be containe(. in the Program. b E The peak Pnmary Containment intomal pressure for the design basis loss of coolant acodont (P.), is 45 pseg.
$ The maximum allowable Pnmary Containment leakage rate (L.), at P., shall be 1.5% of pnmary contamment set weight per day. l h Tne leakage rate acceptance enteria are:
- 1. Pnmary contamment leakage rate acceptance entena is 51.0 L,.
Dunng urut startup fonoweg testmg ir accordance with thrs program. the leakage rate accootance entens are 5 0.601., for the Type B and Type C tests and 5 0.75 L, for the Type A tests;
- 2. Airiock testmg acceptance entens are:
- a. Overall seriock leakage rate is 5 0.05 L, when tested at 3 P ,
- b. For each door seat, leakage rate is 5120 scfd when tested at 3 P,.
- 3. MSIV rate accootance entena is 511.5 scfh for each MSIV when at g 25 peg gg bThe provisions of S 4.0.8 do not apply to tgtest frequencies speerned L in the Pnmary C t t.eakaos Rate Testina Pasaram. r--
hf The provisions of $ "'e a n Mare applicabie to the Pnmary Containment Leakage Rate Testing Program Sg p. o, s 1 A g / SfV Amendment No. 43G-334, r4 g aprs 9'?- 007 '** (k&q,y[- . U Ne S ,.C g b Revision C
$ e e. h o - S.f JAFNPP 6.19 POSTACCfDENT SAMPLING PROGRAM l A program shall be established, implemented, and maintained which wil; ensure the capability to obtain and analyze reactor coolant, radioachve iodines and parbculates in plant gaseous effluents, and contamment atmosphere samples under accident i conditons. The program shallinclude the following:
A) Training of personr0 B) Procedures for samphnt and analysis. C) Provisions for maintenarce of sampling and analysis 6.20 pAIMARY CONTAINMENT LEAKAGE RATE TESTING PROGRAM A program shall be established to implement the leakage rate to of the Pnmary Contamment as required by 10 CFR 50.54 (c) and 10 CFR 50, x J. Option B. I as modified by approved exernpbons. This program shall be in accordance with the j
- uidelines contamed in R ufatory Guide 1.tS3, " Performance-Based Containment ;
esk. Test Program *, dat September 1995, as modified by the exception that Type C testing of valves not isolab6e from the containment free air space may be accomplished f 1 by pressunzation in the reverse direction provided that testing in this manner provides ! equivalent or more conservative results than testing in the accident direction. If I potential atmospheric leakage paths (e.g., valve stem packmg) are not subjected to test I pressure, the portions of the valve not exposed to test pressure shall be subjected to leakage rate measurement dunng regularly scheduled Type A testeg. A list of these valves, the leakage rate measurement method, and the acceptance critana, shall be contained in the Program. A. The peak Primary Containment intemal pressure for the design basis loss of coolant accident (P.), is 45 psig.
~
B. The maximum allowable Primary Containment leakage rate (L.), at P., shall be 0.5% of primary' containment air weght per day. C. The leakage rate acceptance enteria are: 1
- 1. Primary containment leakage rate acceptance enteria is s 1.0 L,.
During unit startup following testing in accordance with this program, the leakage rate acco tance enteria are s 0.60 L, for the Type B and Type , C tests and s 0.7 L, for the Type A tests:
- 2. Airiock testing acceptance criteria are:
- a. Overall airtock leakage rate is s 0.05 L, when tested at 2 P.,
- b. For each door seal, leakage rate is s 120 scfd when tested at 2 P.
3. MSIV leakage rate acceptance enteria is s 11.5 scfh for each MSIV when tested at 2 25 psg. ; 1 D. The provisions of Specification 4.0.8 do not apply to the test frequencies specified j in the Primary Containment Leakage Rate Testing Program. ; E. TIIe provisions of Specification 4.0.C are applicable to the Primary Containment Leakage Rate Testing Program. J y sers 007)
- Amendment No. 496,234 258e f l0 0 Revision C
$ e dl. '8 s OM I, [
V Nl Y {f,g,;5] Q CONFIGURATION RISK MANAGEMENT PAOGRAM (CRmp) The Configuration Mrkk Managtment ProcMrrn ICRM$provides a proceduralized risk-informed assessment to manage the risk associated with equipment inoperability. The program applies to technical specification structures, systen.s, or components for which a risk informed allowed outage time has been granted. The program is to include the following:
- a. Provisions for the control and implement'ition of a Level 1 at power internal events PRA-informed methodology. The assessment is to be capable of evaluating the applicable plant configuration.
- b. Provisions for performing an assessment prior to entering tne plant configuration described by the Limiting Conditiorgfor Operation (LCOl@~cR'ni)
Q(T!1TBillWPI)for preplanned actrvities.
- c. Provisions for performing an assessment after er.t6 ting the plant configuration d_escribed by the LCO Action Statement for unplanned entry into the LCODeten massmenr.
p M-
- d. [ Provisions for assessing the -d for additional actions after the discovery of additional equipment out-of service conditions while in the plant configuration described 60EticF3TATPmrn
- e. Provisions for considering other applicable risk significant contributors such as Level 2 issues and external events, qualitatively or quantitatively.
0% U gil
'~
Com a:ca N 1 l l l Amendment No. 253 258f.
?aS C b,C k b,
./; j,T - LJ Revision C
6N ,.E3 b% h~ O~ s . A
-i R
m s. t 000 200 1 6,4 O 7l4 e012755 4 1 0 1 1 W R U f* C C C 3 n O /i o
... . .. . . . . . . s
... . ..... . . . ., xy i v
... . .. . . . . . . . e
. h R S
T I
.p.
. . o
.mp N ...
. . . .I o
. o . .
I L ... . ))) -
... .......l
. . . . .e FFF T ... . .. . . . .r. 000 N ...
E
)
r......ic
. . . . .cr
. . . . .ei 50 71 )
3N I S ..se
..rws . .. . .. .Rc 3
1 N l eoss e 50 1 A R
/ ..tPapp.
F .
.a pmi
. n.dR. 473 533 0
1 T N 0n.e1yurew.l 0 H5HPTro o ((( O 0o 2 ud o ngn G I T 1i ( t r etoeoy rrrn fC o wnw oi o A C I astatttc m f nddd O I R A T NC Y C D N O C prta ueswpe t p e di rOTer a eT l l aas Datowl p rr recatd ol o nevSt rtCFC eevl Sau ol oooo T trhF FGOar thr.r .
*A N Set t VerSShva e N
E E
'l l o wr naf er he iwonoyt p n l F d/oF, N S aP bd ittOoea0 t0 O N m sresbce rd m 0 u0 P A % d s u e s r a f l pd r 0 h N R o0ooTFoueal muo1 _.
O N5RL ITRSAISN _ C _ l
~
e s s e ' V e r i u N s ' n e T N E r - o MP t c a [ e M R 5
'S f -
T
)
g, u*g O I3 : ,6,
gbM b r At
^RADICLOGICALAFFLUENT TECHNIC (L SP5CIFICATIONS) pc ITl6l b DEFINITIONS A. Dew Suwaient 1-131 -
The Does Equrveient 1 131 is the concentratum of I 131 (mcrocune/ gram) whch alone would produos the same thyroid dose as the quantdy and isotopic mixture
- of I 131.1-132, 6-133,1 134 and 1 135 actually present. The thyroid dose conversson factors used for this calculacon shall be those tested in Intematenal Cothmiseson on Radmiogeal Protection Pubhcaten 30 (ICRP-30), "Limrts for intake by Workers' or in NRC Regulatory Guale 1.109, Reviemn 1, October 1977.
B. Instrument Channel Cahbrahon See Appendet A Techncal Specificebens. C. Instrument Channel Funcaonal Test See Appendoc A Technical Specmcations. D. Lnatrurnent Chad See Appendut A Technical Specificabons E. Lonic System Funcbon Test See Appendut A Techmcal SWes. F. Mgnberfs) of the Pubhc Member (s) of the Putilic includes all persons who are not occupatonelly
=aa^e m with the facihbes on the NYPA/(NMPC) Niagers Mohawk Power O Cornoration sde. This category does not include employees of the utiltes, its contractors or vendors Also excluded from this category are persons who enter the see to service equipment or to make dehvenes Thee category does metude I
j persons who use portions of the one for recreabonal, occupsbonal, or otner ( purposes nc( associated with the plants. l G. Offnas Tsatment Svetam The Offges Treatment System is the system designed and installed to: reduce radmecuve gaseous effluents by collechng onmary coolant system offgeses from the mem condoneer: and, providing for delay of the offges fu tha purpose of reducmg the total radmechvrty poor to release to the omrironment. (l. 4 $ Dona Cahualaban Manual (OOCM) The 00CM doeoribes the methodology and parameters to be used in the ehtwwl of offste doses due to fattooectwo gaseous and liquid effluents and in the ceiculabert of geneous and liquad effluents monstonng metrumentaten
, alamiltrip act poets and in the conduct of the erwironmental mondonng program.
roSee Appendix t A Tochacet Speedcatonj np,/,,;c.g
'(in 1rs: a.th <I.D
( ' Amendmert No. 94, 7pr5 n-or7 p'rg Pap 'l d ' A O ...i.iOO c
}
s h G-bde b - -- t t I ' 1ADIOLOGICAL E77LITINT TICENICAL $7ECITICATICNS , i
)
1.0 DtTINITIONS l 1 A. Dese teuivalent T-131 ! The Deee Eq=f==ta=* T 'M--is the ceasestration of I-131 (microcu-rie/ gram) which alone would produce the same thytoid dose as the quantity and isotopic sixture af I-131.1-132.1-133. I-134 and 1-133 actually present. The thyroid dose conversion factors used for this calculation shall be those listed in Table III of TID-!&844, "Calcu-
- 1 sties of D~ stance Factors - for Power and Test taaster sites" or in
. NRC Regulatory Guide 1.109, Revision 1. October 1977. ,
1
- 3. Insensent Channel Calthrstion i See Appendix A Technical Specifications. l j
C. Instrument channel Tusettosal Test .
]
see Appendia A Technical Specifications. D. Instruser.e cheek See Appendia A Technical Specifications. E. tasis Systes ?usction Teat see Appendia A Technical Specifiestions. F. Member (s) of the Public Member (s) of the Public includes all persons she are not oc=uyatics-ally asecciated with the facilities on the NTPA/(NMPC) Niagara Mohawk Power Coryeresies site. This category does not include employees of. , the stilittes, its contractors or vendors. Also escluded from this
- i category are persons who enter the site to service equipeent or to seks delivertes. This category does include perseas who use persions l of the site for recreational, occupational, or other purposes not !
associated with the plants. G. Offssa Treatment Systes l The Offgas Treat:4ect System is the systes designed and installed tot . reduce radioactive gaseous affluents by collecting primary coolant . systes effgases from the main condenser; and, providing for delay of I the offsse for the purpose of reducing the tossi radioactivity prior to release to the envirassent. I. Offsite Dese calculation Mansal (CDCM) j The CDCN describes the methodology and parseeters to be used in the salvulaties of effsite deseo due ta radioactive gaseous and liquid effluests and in the calculacios of geseems and liquid .e'ffluents assitoring instrumentation alars/ trip set points and in the conduct of the environmental sonitoring progras. . I. Oeerable ( I See Appendia A Technical Specifications. f v Amendsest No. 93 1 0 00 w3(n's 17-oo7 g Revision C
1 i O'* n .= < -i ,1 t.
.v
. i l=a ! 31 . m
_.e- - - 44
.A. -
.. 3 ) e -
W - = ~ v .t g: j I. ' c1:u 31 :in? i;2 ! '3 1 1.11 i i
- u 1 -yo 4.
1b - .: .
-s4! g= =[ q,2 lk a st .
I 4
!!h- . , vi;!
I h m E4 f!F 13 . ! = :l,Ii -%j c. 1 ." 4
.t
~ a
%. 33,4 A
15)) 3t E : N .e j3q _ g M# :! . : : 3
-b
!. u s'"1'i . s, g 3 l j 3 38 de d, 4 5a -
a u e eI j i,--
,=, ,r-_,
=:2
..i., h_ e
- ac
.e. (1 ,s 42 e- = _l :2 1 =j
== = -
- 1. 2 w e
.t 2 -2 ::2a4 .s u (oJ .
- e. ,
2
. 12 .:-- :2 1 .- - _- i _m ,. .-
2h - I-t s._.[ 1 45: .33 m c,s s c 1e2 1 1,1, . 4!.a 3
, a 1
i i:!
- g. .
_s
- j.:] . 2- -
i4 ) e.* it e
% .* ;Y
- 8 t-
,3- " , .: . . :
4 21 3 m
- I:.el5g:* :-
- J.
39 di3 i "
~i a-lii.
"*f e e s 12
~ 4f: g-is::]
.s 2 I }~k.4,. m i.3 . -b }e3} 2_Nk N.*
k!ab s n 4- v a ,i s j .: - i I:s 2: _,.t j y ep5 y, f m 3 lIM ~ J
.e pga z
ts , A l.y-tt wi
. 3:r+.1-(
- :- n
.4 A
4 j WQ me
\
( r,
\
2 l
;iu Q $ @
~
10 j- Y 4 i D pl331 6 d b d 9 \ 4 T
l O' 5 i f II [ fil1lii- f h 5 !
; it; j't I
i it'idib9 i
, i i .l. gli b,Id ..s b 2 nl l 11 '} }11 } o l glN,I O
'!fl!I{h Y e
hN jd I e
, cg 1.. ],
l u ..i u. : .
. II.
$ } u! ~
, g
~
t , _g 3 o j a .
~d o 5 i
1{ a ni 1 1 1 li]lIy p i1lj J{ l ! i P! i o<s i n,, p s H,m i- - o. a[
~
h; l ua ij i 111 I
;n i d}
oII kh : g g'3 { f D 6 e
?
8 a 4 O
9 O1L S ( 1 / 11D i i se ifi 1 SI NJ J f s'a; ". I? '.1 ' ut e l }{tib{ lg'g g s S H p.g rg
}e !{ 11 ,
!! . $ I I kt o I x ~
/j i t j} jl} '3 ,
dj\i k i 1
, ;4 'f n
{' a 1'V{\a\\W~D l i. n 3 e u 1 k.. 'a:p! l 5 'I l Ib ii1[$ilh1]kMUf g c : o O
~
oT d'
1 O VOLUME 6 ITS 1.0. 2.0 AND 3.0 CONVERSION PACKAGES This page provided as a place holder and to assist personnel updating the JAFNPP ITS submittal to Revision C. Q. - Discard this page along with pages removed in accordance with the page replacement instructions. [ . O
Dg 4 g
}
. (,
[' 3 c. (, d E S e f$y - 4 es g _ h e ol n e
** eh m
e r o
- s t
n d e d ec g n r e il ba 1 bk h e md r ifi oi os
]LTdtuoa ah t
- t ui d r s
wt r o w4euN g n o r nqct sdB h oae et ee t e m oN hah s u S M ndi E s Neair eeioO t 'l whTt r I p m f r r r ees pi l aesi pnt vEn sau eoMm. crpS o - C r o 4e e o t o o
,f t
J' hiUe s oet c gh eA c eBaeurvpA2ta r r e 2h tra a esdoah)t r . b dh pe 1 v C m p to n e ph e n= e-t O isl dans o L lmt libo t l 0 ea s e r ap y 4 si t sw - f o g n N E aMenwCnsCh hs S dt d pN e R iRt e h nIofen N e f i t r etc en f n o s A Ac it uwn o s i s b r oe n Nnel np 7 e ee e xheTaXnio i t o f c o 4 evavvo a em t vhl et . nnsc i t v e
-c e la t b l n r a ), yf ooie e s yi a
h laer dni- owt ela l
.n Dinuoi fhIOmhe Te I r npo t
ec r t R ic e v r dI vf ocf b) dt6 hp nXpp5adf i l f f e s ein i cc s R e rN v . e N qi t s a ef aS hi we eod t,. f t.
-. duo ._. m p Oea cne C Rre na Ni t
. I n s n a 5. nt ab piod 0a5 s o h
sI r e T a r : nt n5 p 5. i t et
- s. beC Lepl a u os df
; yh A t q
e u AncOih l es q e g f w n eca n 0mdCaoo_ pS e o e n 5 e w a Nar v r s o a n g dt i engelei Oife or ns r u mfohe e
. t l n
uoay l h ocb iood sn l f q . l b I nlo ef otice e snt T vn si s s _ R tnio of
. e w Ar oeive ms ea gwl n e Sst acpa ei r d s n e et es p RuilSib t od r i es0 .
h e ndVg e wmm no ar o s s iule enecs5fe Son .iar eb c ml t E d n e pi n P encpM 4 qb t ue la r i Oh ol s i ea l eVRi0c l , il e uoli po qce un n s gat t Cpil ph as Rc i ed r eC F e5 r ef post sh n nre o nt ep l icvc or nRs - d e v r re eml d u hi s e a s ol eni hd. e ien o cp na er c a u s0eFCioPt am t t ni t s1 i r ' u S Nt t t e it n a Ot g= e= m r in umt iere er la e ie b s nnPb r yr 0nd ni w1 aeag dt do i e, 4 yeLi inf s it n t T I imah f o r d ipi h c eOq u vN I i g g a6 "" o3aApo2 C3h Ceu4 erpE mh r t t n aeti wstpo e r a uh . t t R ss 1 4
- 0. 3 gL y 4h "'*
gt" D 4 R. s D . 6; 5 e I t E iy a i [5 , i 7 r L o e o ) r e I t eA t e I sn s w hi e 't N s ai i 1 ( d T r s s yp ot m 't n A e no e mNn O ic n t n no oi ie naf cl oL r i 1 tn s n a ic e . ouo ._ oTd e a g(2 n e t t t hiht I e) it a f d e c io ecd _ odt dt t i nAamn vs pc iemElend o ico . l i 8 r r a e eef i vgr L bd np i nL didem t bariv rer _ ooc naraPenf neRmor er o r dci c aname p E f opox e dr me nB o r eue
*:m y oOsle oh A A, s esqh yoi mE ps pE c p l t t e
deeyO t bo oe cCs u o o ret o t s isRE peBl .f hn hfe i e y ct n t ot mh nanih t h S n gf l m nt emeclaN t l t nu ni t e ePer A (s sto iT .rR sOso r i i dei dn o l i W n eu t i e of hahO ed i t cR nab de so ent y Nhnio nnonwfe sI E rias scr st . t T miv o s ad paer uce otisP f esaun r r aueltQ e l Owe wi i i sh nD I ed wn Ot selpow lce t t b sO f-I r a o yit t t o mcb e s) ,i l h o er mrC N st s wn T e r dnf i ui oe dt 1 s qe derbfop eL r I
,ylen e : cemheUebl 2t 4d I
dndt cb yi l sn( i o Da ot nc neoiO v eh i oo 4 NmiuE O t h a s ome noC
.di r ipL o r Nn r t nl e e soceeut al omd r eh .l n a gh u o ye r eape t 3 2 O
i Cer eidr oyoisis r oh nS h no tr i A Oid' c r o imot it t be p aeiqras eut r 7 r N I t
,s ob uis s . at wIJ t
v 3 AoOee vf ce reeN L sr T e qvorbE cioo r s t r e E t i pT O Ct a mle ,ye enyop e 2-Nnroi r t n pN o .T At s I ebl ear r pwsBi euLi u conNC f s oleyc s., 8 r Oll f q uisOdeA t ab me o .Ae f n i t x y-h sr yer a t t h R phe e n mtc lol a i 8 e o a se e i I Thne erI emR i t n o p s E t b I as n r Aso r i moTuiE Cnt P wa spei b op ,gi t ymP i st,h t e f r dor l - v Rni it Nt l eAin o O_ ys unoenac sdnh er e 4 E odOdd t f l t pn s,eiinb af l ir enteO ye pgyrs etf sie Neiw fh i d. ui on op i r t s 8 3 9 PinI OioTi t eohod h me mbepa sr s ieiOr t aqcsh is - t g r nnC Cimicbu f d om eo e saoiwb l e 3 aog Aciwsr e pNeie t o ce t t s cos omt t r ) s s sNc a t a -
;r eiT rht vi t
8 O.
- e anle.eWli r 3 O c m ph to iruq t
o cnde s ydrui nfo f te d sen os nr t . . t dt i t d c craOp p t iaat r n o e u iinemitaTae i t a I nr d ee ae aisieo i oni-. uv ) nwr e t t e N O n I d pt g er ~ n mr estiad ee2 Da mlyiss l f i ci Dr n nm r t it yicL ohNomms ia ee eewr r ecod r T t op n C urpn mredi n us 1 ppi o t r e est c elis qo u Uo ummmiu i e L C nphsiOch E st awCat up na eh r . ht eoouo osn e W d p s pC n i dqdnHn r t a r asis qod eq E cade d m n e a 0 3 D
~
e. t
- ; c F
. f'mA d et
<c m 4 a '-
O . 0 i Aouna 1 ep s f * { L Qce 8 M d =a c %t tw M M 0 [L _ op5 _ rw6$ L b1M c o h _ ( D
p L l I[ DISCUSSION OF CHANGES !d ITS 3.0 LC0 AND SR APPLICABILITY l i l ADMINISTRATIVE CHANGES A12 L(continued) endorsing the failure to exercise the good practice of restoring systems or components to OPERABLE status before entering the associated MODE or ! other s)ecified condition in the Applicability. Therefore, for normal plant slutdowns the change is not considered to provide any added flexibility. l In addition. ITS SR 3.0.4 states that the SR is only applicable for l entry-into a MODE or other specified condition in the Applicability in MODES 1, 2, and 3.- This phrase has been added since CTS 4.0.D provides no guidance in this area. The change eliminates the restrictions of the SR.when in MODES 4 or 5. Specific restrictions on MODE changes or i f.equired Actions are included in the individual LCOs and discussed in l the appropriate DOCS. These changes constitute editorial rewording, and aresentation preferences consistent with the BWR/4 ISTS, NUREG-1433, Revision 1, and are administrative. ! A13 ITS LC0 3.0.7 is added to provide guidance regarding the meeting of
- e fh Special Operations LCOs in the proposed Section 3.10. These Special
!k Operations LCOs allow specified Technical Specification requirements to be changed (made applicable in part or whole, or suspended) to permit the performance of special tests or operations which otnerwise could not ! be performed. If the Special Operations LCOs did not exist, many other i special tests and operations necessary to demonstrate selected plant performance characteristics, special maintenance activities, and special evolutions could not be >erformed. This specification eliminates the , confusion which would otlerwise exist as to which LCOs apply during the performance of the special test or operation. This is consistent with the intent of Special 0)erations LCOs and without this specified licensed allowance to clange the requirements of another LCO, s conflict l of requirements could be interpreted to exist (incorrectly). Therefore, this change provides only administrative clarification. 1 TECHNICAL CHANGES - MORE RESTRICTIVE M1- CTS 3.0.C requires the unit be placed in COLD SHUTDOWN (MODE 4) within 24 hours if the LC0 or action requirements cannot- be satisfied because of circumstances in excess of those addressed in the Specifications. , ITS LC0 3.0.3 requires that the p12.nt take action within 1 hour to l initiate the shutdown..be in MODE 2 in 9 hours, be in MODE 3 in 13 l hours, and be in MODE 4 in 37 hours (L1). This change requires tne plant to perform the shutdown in a controlled manner which will reduce the chances for a plant transient which could challenge safety systems. q U JAFNPP 6 of 8 Revision C L
a
)
l^ DISCUSSION OF CHANGES / ITS 3.0 ' LC0 AND SR APPLICABILITY l i L TECHNICAL CHANGES - MORE RESTRICTIVE l M1 (continued) Since this ' change requires the plant to take action within 1 hour and to l be at interim conditions. MODE 2.in 9 hours and MODE 3 in 13 hours, this change imooses additional time restraints on operations and therefore, is more r'strictive. e The times are consistent with NUREG 1433, Revision 1 expect for;the time to be in MODE 2. An additional two hours provided , for the time to be in MODE 2 has been specified based on operating l limitations associated with reaching this condition and current l' requirements to be in MODE 2 in another specification (Reactor Protection System). This change has no adverse impact on safety. M2 CTS 4.0.B does not address Frequencies specified as once. ITS SR 3.0.2 includes the phrase "For Frequencies saecified as "once," the above interval extension does not apply." T11s is because the interval l extension concept is based on scheduling flexibility for repetitive
. performance and these Surveillances are not repetitive in nature and essentially have no interval as measured from the previous performance.
- This change precludes the ability to extend these performances O consistent with NUREG 1433 Revision 1. Since CTS 4.0.B can be
! U interpreted to apply the extension to all Surveillances, stating that the extension does not apply imposes additional requirements on operations and therefore, is more restrictive. This change has no I
adverse impact on safety. l TECHNICAL CHANGES LESS RESTRICTIVE (GENERIC)
-None .
j TECHNICAL CHANGES - LESS RESTRICTIVE (SPECIFIC) L1 CTS 3.0.C requires the unit to be placed in COLD SHUTDOWN (MODE 4) within 24 hours if the LCO or action requirements cannot be satisfied because of circumstances in excess of those addressed in the Specification. ITS LC0 3.0.3 allows 37 hours to be in MODE 4 which
- includes the requirements (M1) to initiate the shutdown within 1 hour, l- be in MODE 2 within 9 hours, and be in MODE 3 in 13 hours. This change is considered less restrictive since the time to get to MODE 4 has increased by 13 hours (37 versus 24 hours). This change is acce) table since the compensating actions added in accordance with M1 and t1is extended time to reach MODE 4 will ensure a more continuous reduction in power and reactor coolant tem >erature which is within the specified 77 maximum cooldown rate and wit 1in the capabilities of the plant. This V JAFNPP 7 of 8 Revision C r
y 1
,o DISCUSSION OF CHANGES !
(
) ITS 3.0 LCO AND SR APPLICABILITY TECHNICAL CHANGES LESS RESTRICTIVE (SPECIFIC)
L1 - (continued) reduces thermal stresses on components of the Reactor Coolant System and also reduces the chances for a plant transient which could challenge safety ~ systems. This change is consistent with NUREG 1433 Revision 1. 1
. L2 CTS:4.0.B has had the following sentence added, "If a Com)letion Time requires periodic performance on a "once per..." basis, t1e above Frequency extension applies to each performance after the initial performance." ITS SR 3.0.2 includes this statement which provides the consistency in scheduling flexibility for all performances of periodic requirements, whether they are Surveillances or Required Actions. The intent remains to perform the activity, on the average, once during each specified interval. This change is consistent with NUREG 1433, Revision 1.
L3 When it is determined that a Surveillance was not performed CTS 4.0.C allows ACTION requirements to be delayed for up to 24 hours to permit completion of the Surveillance if the allowable outage time limits of
/7 the ACTION requirements are less than 24 hours. ITS SR 3.0.3 continues V to allow a delay, from the time of discovery, up to 24 hours or up to the limit of the specified Surveillance Frequency, whichever is less.
This change is less restrictive since the delay will now apply to any Surveillance instead of those specifications with ACTION requirements of less than 24 hours. The current dependance to the ACTION allowable outage time is considered not to be necessary since the most probable result of any particular Surveillance being performed is the verification of conformance with the requirements. TECHNICAL CHANGES RELOCATIONS None L
\ ")
JAFNPP. 8 of 8 Revision C
1 I t,: , O! ' VOLUME 11 ITS 3.4 CONVERSION PACKAGES ; This page provided as a place holder and to assist personnel updating l the JAFNPP ITS submittal to Revision C. Q . Discard this page along with pages removed in accordance with the page replacement instructions. I O z
r l l N O inh @:[iMa (9a s =2 tc! EJ V V
.5 4 Il r,
[i E8=
-i.
M ! It l j$f 'I 2D $o fhj Mb [ l f- e. .! h %, d j; e ,I l o 1 { e
- =
t E
=
k s i 2 5 n &Ff gaE
.h 4 1.s 15 ( *> m D ($h 0]5 ~! cl hh 1:
i 21 t ji ~ai 5 sh! LtF h 18 5 j ( a"$ E*S1 e N{17
- o an EE
- 1. !
*; w e ,
O l s w%%6,I 3' g w I g8
" f, g j E" $$1 E ko bt oir '$ $ i 6 Mw6 y a=uE -=
=* =g y
oI e _a g a,
=g; i g
e
& lt aol g 3i k-as s . s - -
E d hs, $ $22" k h* $ a 8 c i " 's p- 2- i a
- o **ji f k-e o sa g ., L .
v ..gI $ i " m. >- q g I. ~ ! m i g 1 1 6 1 . 11 I ag I fl.5 i ! ? lj
! !i
; 31' q!. d. a} Lr}. ij
" H
'a x .
.!! t 3 j'11p m
i f I; 1l21 gal* p! il 1 :t 1
.I.I- i 1
d- IslI2 ~~ 5 31 33 E f g
' 'P k
1
I O m M-T % o M 4 e O o d .h e, > 4 & & 6
-u O
W o-E h 8 O M e E C
'r=
1 m
*r=
r
l l 1 ^ DISCUSSION'0F CHANGES l ITS: 3.4.3 -. SAFETY / RELIEF' VALVES (S/RVs) 1 ADMINISTRATIVE CHANGES Al' In the conversion of.the James A. FitzPatrick Nuclear Power Plant
- l(JAFNPP) Current Technical Specifications (CTS) to the proposed plant specific l Improved Technical Specifications (ITS) certain wording preferences or conventions are adopted which do not result in technical changes. Editorial chan3es, reformatting, and revised numbering are ;
adopted to make the ITS consistent with the conventions in NUREG 1433, J
" Standard Technical _ Specifications. General Electric Plants, BWR/4", '
Revision 1 (i.e., Improved Standard Technical Specifications (ISTS)). A2 -CTS 3.6.E.1 Applicability is "during reactor power cperating conditions i
, and prior.to startup from a cold condition, or whenever reactor coolant pressure-is-greater than. atmosphere and temperature greater than 212*F."
ITS 3.4.3 Applicability is in MODES'1, 2, and 3. The CTS Applicability . of "during reactor power operating conditions," and "whenever reactor ! coolant pressure is greater than atmos)here and tem >erature greater than j 212 F," are encompassed by the ITS MODES of applica)ility. . The CTS j Applicability, " prior to startup from a cold condition," is consistent ; with CTS 3.0.D and-ITS LC0.3.0.4. which require that an LC0 be met prior ' u s to entry into the MODE or other specified condition in the Applicability. Since no technical requirements are altered,- this change
,is administrative. This change is consistent with NUREG 1433.
Revision:1. i I A3- CTS 3.6.E.1~s)ecifies that the Automatic Depressurization System (ADS) valves shall ye OPERABLE as required by CTS 3.5.D. This statement reminds the reader that another Specification-is also Applicable, and is not retained in the ITS. Since no technical requirements are altered, this change is: administrative. This~ change-is consistent with NUREG-
.1433, Revision 1.
A4- LCTS 4.6.E.4 is revised to reflect that only each " required" S/RV need be ! manually opened. Since CTS 3.6.E.1 states that 9 of-11 S/RVs are i
- required to be OPERABLE, and the Technical Specifications.only apply to :
" required" equipment, this change is considered administrative. This l change is consistent with NUREG 1433.-Revision 1. 1
. . l 2A5: - CTS 3.6.E.5 does not require Safety / Relief Valves .(S/RVs) to be operable with reactor coolant temperature > 212'F-.during hydrostatic pressure and leakage testing. This exception is indirectly incorporated into ITS 3.10.1, Inservice Leak and Hydrostatic Testing Operation, which allows
. the reactor to be considered in MODE 4 with the reactor coolant ;
temperature > 212 F. .The CTS 3.6.E.5 exce) tion allows the S/RVs to not be 0perable (as required by CTS 3.6.E.1) w111e performing inservice leak or hydrostatic testing with the average reactor coolant temperature
~
O, ~> 212*F. Since LC0 3.4.3 is not listed as any of the required MODE 3 ' V
<JAFNPP- Page 1 of 5 Revision C h
i L
h U
' DISCUSSION OF CHANGES
~ ITS: 3.4.3. SAFETY / RELIEF VALVES (S/RVs)
TADMINISTRATIVE CHANGES A5::(continued)
~
JLCOs to' be met' in ITS 3.10.1, and the Applicability of LC0 3.4.3 -does
.not include MODE 4.'. S/RVs are not required to_ be Operable. Therefore, since this allowance is indirectly incorporated into ITS 3.10.1, this
-change is' considered to~be an administrative presentation preference.
This change.is consistent with NUREG 1433.. Revision 1. TECHNICAL CHANGES 4 MORE RESTRICTIVE' U 'M1. : CTS 3.6.E.2 requires the reactor to be placed in a cold condition 'within 24 hours if the requirements of CTS 3.6.E.1 can not be met-(less than !
.the minimum number,of Operable safety / relief valves). In ITS 3.4.3 this
. condition is. addressed in ITS 3.4.3 ACTION A. ITS 3.4.3 ACTION A
' requires the plant.to be in MODE 3 in 12 hours (Required Action A.1).. l In addition the time to reach cold condition (MODE 4) has been extended l to 36 hours (see L1). The allowed Completion Times are reasonable., !
. based'on operating experience,Lto reach the required plant conditions 1
from' full ' power conditions in an orderly manner and without challenging E .; splant systems. However, .the.12 hour Completion Time ensures timely J ' action is taken to place the plant in a shutdown condition 0100E 3). 1The consequences'of an overpressurization event is significarAly educed-
'when the plant is shutdown. This change is consistent with NON 1433, LRevision.1 LM2 ' CTS 4.6.Ej requires the safety / relief valves to be manual ' opened every 24~ months.. ITS SR 3.4.3.2 requires this same manual opening but requires the actuation to be initiated on a Staggered Test-Basis for .
each valve solenoid. This:will ensure that a different' solenoid will be Lused to~ actuate _the-' valve every 24 months and is considered more restrictive since.the current requirement .does not-s:ecify which
-solenoid to use. This change is. consistent with NUR:G 1433 Revision 1 land.islnecessary to. ensure both solenoids are Operable.
iTECHNICAL CHANGES" 1LESS RESTRICTIVE (GENERIC) lLA1l LThe" requirement in CTS 4.6.E.2 to disassemble and inspect one l safety / relief. valve every 24 months is proposed to be relocated to the JAFNPP UFSAR because it is a maintenance related activity that does not
.directly relate to S/RV Operability. This inspection is a preventative maintenance type requirement. >The failure to rform this requirement
- does not necessarily result in an ~ino rable S RV. This requirement is oriented toward long . term S/RV Operab lity and does not have an
- JAFNPPJ Page 2 of 5 Revision C t
) , , g
p $/~N DISCOSSION'0F-CHANGES' %) ITSL 3.4.3 SAFETY / RELIEF VALVES (S/RVs) TECHNICAL CHANGES LESS RESTRICTIVE- (GENERIC) [ LA1 (corit'inued)' immediate impact on S/RV Operability..S/RV Operability is verified by
- the SRs maintained in ITS.3.4.3. In addition, procedural controls on
. S/RViinspections are sufficient to ensure that the S/RV receives the i necessary inspections. As a result, this requirement is not necessary
..to be included in the ITS to provide adequate arotection of the aublic l l health and-safety. -Changes to the UFSAR will )e controlled by tie l : provisions of.10 CFR.50.59.
]
p LA2; The methods in CTS 4.6.E.4-for verifying the safety / relief valves has l ' -opened (i.e., while bypassing steam to the condenser. etc) and the detail.that the test must be performed in Run are proposed tc be relocated to the Bases. These details are not necessary to ensure Operability of the S/RVs. 'The requirements of ITS 3.4.3 and the associated SRs are adequate to ensure that the S/RVs are maintained
- Operable. SR 3.4.3.2 will recuire each required S/RV to be manually actuated after reactor' steam come pressure and flow are adequate to Lp perform this test. The Bases.for this SR will prescribe the test method j .and the conditions'for performing the test. In addition, the Bases discusses that the pressure and flow conditions will require the plant
-to be'in MODE.1, which has been shown to be an acceptable condition to
, perform this test. This test will cause a small neutron flux transient l . which may. cause a scram while operating close. to the Average Power Range Monitors Neutron Flux-High' (Startup) Allowable Value in MODE 2. As
- such-these: methods of verification and details that the' plant must be in
! 'Run are-'not necessary to be included in the ITS to provide adequate 3rotection of the public health and safety. Changes to the Bases will , >e controlled-by the provisions of the proposed Bases Control Program l idescribed in. Chapter 5'of the Technical Specifications. ! LA3. 'The requirement in CTS 4.6.E.1 that at least 5 of the 11 S/RVs be bench H : checked or replaced with bench checked valves every 24 months; and that Lall . valves be tested every 48 months are proposed to be relocated to the Inservice Testing Program. The Frequency is revised in-ITS SR 3.4.3.1
-to ."In accordance with the Inservice Testing (IST) Program". ~The L i requirement in ITS SR 3.4.3.1 to verify the lift setpoints of the
- - required S/RVs in accordance with the' Inservice Testing Program is ,
j adequate.to ensure the valves are OPERABLE. Testing of pumps and valves i
.is required to be performed in accordance with Section XI of the ASME j Code and.apalicable Addenda-as required by 10 CFR 50.55a, except where i
" relief;has )een. requested. Therefore this detail is not necessary to be ;
included:in the ITS to provide adequate protection of the public health
~
Jand safetye Changes to the testing Frequency in the IST Program will be i controlled by the provisions of.10 CFR 50.59. yJAFNPP; .Page 3 of 5 -Revision C J , l 0 4
,q DISCUSSION OF CHANGES C) ITS: 3.4.3 SAFETY / RELIEF VALVES (S/RVs) TECHNICAL CHANGES - LESS RESTRICTIVE (GENERIC) LA4 The CTS 3.6.E.5 temaerature allowance of up to 300 F to perform the inservice leak and lydrostatic testing is proposed to be relocated to the Technical Requirements Manual (TRM). Inservice leak and hydrostatic tests are very controlled evolutions involving strict procedural compliance. As a result, the maximum temperature limitation is not necessary to be included in the Technical Specifications to ensure this maximum temperature limitation is not exceeded. The minimum temperatures (at the required pressures) allowed for these tests are determined from the RPV pressure and temperature (P/T) limits specified in ITS 3.4.9, " Reactor Coolant System (RCS) Pressure and Temperature (P/T) Limits." ITS Figure 3.4.9 1 indicates the minimum temperature required at the associated pressures. Operations will ensure these limitations are not exceeded. A minimum temperature limit of approximately 200 F is currently required at a reactor pressure of 1040 psig, therefore adequate margin is available without exceeding the current 300*F limit. In addition, the 300 F limit was chosen based on an analysis which postulated a recirculation line break and examined the capability of the secondary containment to remain intact with the q primary containment breached (drywell head removed) during inservice (b leak and hydrostatic testing with the reactor coolant temperature at 300 F and RCS pressure at 1150 psia. The results of this analysis indicated that the secondary containment would remain intact. Therefore, relocating the current temperature limit to the TRM is acceptable and is not required to remain in the ITS to ensure adequate protection of public health and safety. At ITS implementation. the TRM will be included in the UFSAR by reference. Changes to the relocated requirements in the TRM will be controlled by the provisions of 10 CFR 50.59. TECHNICAL CHANGES - LESS RESTRICTIVE (SPECIFIC) L1 CTS 3.6.E.2 requires the reactor to be pi n d in a cold condition within 24 hours if the requirements of CTS 3.6.E.1 cannot be met (less than the minimum nember of Operable safety / relief valves). In ITS 3.4.3, this condition is addressed in ITS 3.4.3 ACTION A. The proposed requirement. ITS 3.4.3, Required Action A.2, extends the time allowed for the plant to reduce temperature to be in MODE 4. from 24 hours to 36 hours. The , allowed Co 9letion Times are reasonabit, based on operating experience, to reach the required alant conditions from full power conditions in an orderly manner and wit 1out challenging plant systems. The consequences of an accident are not significantly increased because ITS 3.4.3 Required Action A.1 will require the plant be placed in MODE 3 within 12 hours. This change reduces the time the reactor would be allowed to fl J continue to operate once the condition is identified. The consequences JAFNPD Page 4 of 5 Revision C
1 l
.g.
DISCUSSION OF CHANGES lO' ITS: 3.4 3
. SAFETY / RELIEF VALVES (S/RVs)
TECHNICAL CHANGES LESS RESTRICTIVE (SPECIFIC) L1- (continued)- ofLa pressurization event is significantly reduced when the~ reactor is shutdown and a controlled cooldown~is already in progress. This change tis consistent with NUREG 1433, Revision 1. TECHNICAL-CHANGES RELOCATIONS None-s O O ry (d. " Page 5 of 5 JAFNPP- Revision C C
4 [ I! 2 'l I
,40
{< 1 _
- Y; k sjf I f wflI: ai 3 a st f kIl f aaatuy 0
e ,
#ES e3E fh" p h5 e F '! l'el l ij,i Ig 3 ii3:l "le r l$ Iy m l ! iI ! I il f 1 I j l Q gi al i h t ' {i r ai ;
~2 11 : il' I 1 I a!jj I na
} i i [ .. }n (
~
ll i II I 3 IN:II Y {. ' w 1" I o "=[1> i@k-5 i Lb { ,
i ~ T. + O O N N@ y ea -
* >7Es
+
4 b b b r-M 8 O 1 m
=r=
0
m DISCUSSION OF CHANGES
.O ITS: 3.4.9 .RCS PRESSURE AND TEMPERATURE (P/T) LIMITS ADMINISTRATIVE' CHANGES All In the' conversion of the James A. FitzPatrick' Nuclear Power Plant
-(JAFNPP) Current Technical-Specifications (CTS) to the proposed plant specific Improved Technical Specifications (ITS) certain wording preferences or conventions:are adopted which do not result in technical
. changes. Editorial changes. reformatting,-and revised numbering are adopted to make ITS consistent with the conventions in NUREG-1433,-
" Standard Technical Specifications, General Electric Plants, BWR/4",
Revision 1-(i.e.. Improved Standard Technical Specifications (ISTS)). A21 CTS 3;6.A doEs not state any Applicability requirements. ITS 3.4.9 is licable "At all times". Because the CTS does-not specifically state licability requirements, it can be implied that the Specification is
- a o Applicable "At all times". Since no technical requirements are altered, this change is administrative and has no adverse impact on safety.
~
A3 . CTS 3.6.A.5.a is revised by adding.a NOTE'(ITS 3.4.9 Condition A Note) which requires that a determination be made whether the RCS-is acceptable.for continued operation whenever the Condition.is entered,
' regardless of 'whether compliance with the LCO is restored. This change J >
. only provides clarification, because CTS 3~.6.A.5.a already contains this.
' requirement. Since no technical requirements are altered, this change is administrative and has no adverse impact on safety.
A4 CTS 3.6.A.5'is silent with' regard to MODE (S) of Applicability. In the event that Required Actions and Completion Times for restoring I
- compliance with the LC0 are not met, the reactor must be placed in a I
' condition' outside the MODE (S) 'of. Applicability. Since this
. Specification requires that, if the Required Actions and Completion
' Times-are not met, the. reactor be placed in Cold Shutdown (MODE 4). it can be implied that the-Specification is Applicable in MODES 1, 2, and
- 3. Since no technical' requirements are altered, this change is administrative'and has no adverse' impact on safety.
sAS CTS Figure 3.6 1 Part 1 Reactor Vessel Pressure Temperature Limits Through 12 EFPY.and Figure 3.6 1 Part 2 Reactor Vessel Pressure-Tsmperature Limits Through 14 EFPY. are being deleted.- JAFNPP is currently at 13.36 EFPY with approximately 19 months of operation
; anticipated before ITS Implementation. The current 13.36 EFPYs negates theire uirement for Figure 3.6 1 Part 1.-and the operational time until ITS I lementation would negate the requirement to retain Figure 3.6 1 Part . :Since no technical. requirements are. altered, this change is administrative and has no adverse impact on safety.
O :JAFNPP? Page 1 of 8 Revision C 1' n i
s n DISCUSSION OF. CHANGES g ITS: 3.'4.9 RCS PRESSURE AND TEMPERATURE (P/T) LIMITS ADMINISTRATIVE CHANGJJ' A6- The requirement to record the results in CTS 4.6.A.1, 4.6.A.2, 4.6.A 3', and~4.6.A.4-(ITS SRs. 3.4.9.1, 3.4.9.2, 3.4.9.3, 3.4.9.5, 3.4.9.6, 3.4.9.7 and 3.4.9.8) is proposed to be deleted and the requirement will be to verify the associated parameters are within the specified limits. This requirement duplicates the requirements of 10 CFR 50 Appendix B, Section XVII (Quality Assurance Records): maintain records of activities affecting quality, including the results of tests (i.e., Technical Specification Surveillances). Compliance with 10 CFR 50 : A)pendix B'is required by the JAFNPP Operating License. The details of t1e regulations within the Technical- Specifications are repetitious and unnecessary. Therefore, retaining the requirement to perform the associated Surveillances (verifying the specified limits are met) and eliminating the details from Technical Specifications that are found in 10 CFR 50 Appendix B is considered a presentation preference, which is j administrative. '
'A7 -Thermal stresses on vessel components are dependent upon the temperature i difference between the idle loop coolant and the RPV coolant. ITS l SR 3.4.9.5 ensures the tem >erature difference between the idle loop and l O -V the RPV coolant is acce)taale. The requirements to monitor the temperature difference >etween an idle loop and an o>erating loop (CTS 3/4.6.A.6.c) are unnecessary and are deleted since t1ey are redundant to the loop to coolant requirement of ITS SR 3.4.9.5. However, in l accordance with procedures and as discussed in the Bases for ITS i SR 3.4.9.4, the loop to coolant temperature check may use the operating l loop temperature as representative of " coolant temperature". l l
A8 A Note has been added to CTS 4.6.A.1.a and 4.6.A.1.b (Note to ITS j SR 3.4.9.8 and 3.4.9.7, respectively) which clarifies that the ' Surveillances are not required to be performed until 30 minutes after RCS-temperature s 100*F or 120 F, respectively. These requirements are consistent with the CTS requirements. The Frequency of the CTS requirements are every 12 hours (CTS 4.6.A.1.a) or 30 minutes (CTS 4.6.A.1.b) when the reactor vessel head flange falls below the !
. prescribed limit. Therefore, the first required Surveillance is i
.12 hours or 30 minutes after the specified temperature is reached. i These requirements are consistent with the proposed Note therefore this change is considered administrative. This change is consistent with NUREG 1433, Revision 1.
A9 CTS 3.6.A 2 (last paragrapn) does not require High Pressure Coolant Injection (HPCI) Automatic Depressurization System (ADS), Reactor Core Isolation Cooling (RCIC), and Safety / Relief Valves (S/RVs), to be operable with reactor coolant temperature > 212 F or pressures above 100 'p and;150 psig during hydrostatic pressure and leakage testing. These
.JAFNPP Page 2 of 8 Revision C
l l l DISCUSSION OF CHANGES J
-3' ITS: 3.4.9 s
RCS PRESSURE AND TEMPERATURE (P/T) LIMITS wt ADMINISTRATIVE CHANGES A9 (continued) exce)tions are indirectly incorporated into ITS 3.10.1, Inservice Leak and lydrostatic Testing Operation, which allows the reactor to be considered in MODE 4 with the reactor coolant temperature > 212*F. The exceptions allow the HPCI system. ADS, the RCIC system, and S/RVs to not be Operable (as required by CTS 3.5.C.1, 3.5.D.1, 3.5.E.1, and 3.6.E.1 res)ectively) while performing inservice leak or hydrostatic testing wit 1 the average reactor coolant temperature > 212 F or pressures above 100 and 150 psig. Since LC0 3.5.1 (for HPCI and ADS). LC0 3.5.3 (for RCIC), and LC0 3.4.3 (for S/RVs) are not listed as any of the required MODE 3 LCOs to be met in ITS 3.10.1 and the Applicability of LCOs 3.5.1, 3.5.3, and 3.4.3 does not include MODE 4, HPCI, ADS, RCIC, and S/RVs are not required to be Operable. Therefore, since these allowances are indirectly incorporated into ITS 3.10.1, these changes are considered to be an administrative presentation preference. These changes are consistent with NUREG 1433, Revision 1.
/N TECHNICAL CHANGES MORE RESTRICTIVE O M1 CTS 4.6.A.4 requires that RCS aressure and temperature be recorded I within 30 minutes prior to witidrawal of control rods to bring the reactor critical. ITS SR 3.4.9.2 requires this verification to be i
performed within 15 minutes prior to control rod withdrawal for the , purpose of achieving criticality. This Frequency is closer to when the ! control rods will actually be withdrawn and will help ensure the specified are limits are met. Since the time is limited, this change is considered more restrictive but necessary to ensure the specified parameters are within limits prior to control rod withdrawal where the reactor has a potential of becoming critical. This change is consistent with NUREG 14?3, Revision 1. H2 CTS 3.6.A 5 requires that, in the event the RCS pressure and temperature limits are exceeded, it be determined that the RCS remains acceptable for continued operation. There is no Completion Time associated with this requirement. 'ITS 3.4.9 Required Action A.2 Completion Time requires that this determination be made in 72 hours. This change imposes a time constraint where one does not exist, and is therefore more restrictive but necessary to ensure prompt action is taken to verify the RCPB is acceptable for continuous Operation. M3 CTS 4.6.A.6 requires that certain RCS differential temperature measurements be recorded within 30 minutes prior to startu) of an idle (q recirculation loop. ITS SRs 3.4.9.3 and 3.4.9.5 require t1at these JAFNPP- Page 3 of 8 Revision C l t
E , V_ DISCUSSION OF CHANGES O 'ITS: 3.4.9 - RCS PRESSURE.AND TEMPERATURE (P/T) LIMITS
- TECHNICAL CHANGES - MORE RESTRICTIVE M3'-(continued)
- differential. temperature measurements be verified within 15 minutes prior to startup of an idle recirculation -loop. This Frequency is closer to when the pumps will:actually be started and therefore will help ensure lthe specified limits'are met prior to pump startup. Since the time is limited, this change'.is considered more restrictive but necessary to ensure the tem)eratures are within limits )rior to a startup of an idle pump. T11s change is consistent wit 1 NUREG 1433.
Revision'1. M4 CTS.3.6.A is revised by adding a'new action (ITS 3.4.9 ACTION C), which <. requires that action be initiated immediately to restore the )arameters to within limits, and a determination be made as to whether tie-RCS is acceptable for continued operation. prior to entering MODE 2 or 3. ITS 3.4.9 ACTION C is Applicable at all times other than in MODES 1, 2. and.
- 3. .This change imposes additional requirements and is considered more restrictive but necessary for protection of the RCPB.
-TECHNICAL CHANGES - LESS RESTRICTIVE (GENERIC)
LAl- The requirement in-CTS 4.6. A.2, 4.6.A.3, and 4'.6. A.4 that specifies the criteria for ending the surveillances (performed until two consecutive temperature readings are within 5 F of each other) is-proposed to be a relocated to the Bases. Requirements of SR 3.4.9.1 provide adequate d assurance that heatup and cooldown of the RCS will be monitored and maintained within limits. As a result, the manner in which JAFNPP determines that a heatup or:cooldown has been terminated is not necessary for ensuring limits are met. Therefore, the relocated criteria for determining when a heatup or cooldown has terminated is not required to'be in the ITS to provide adequate arotection of the aublic health and safety. Changes to the Bases will >e controlled by t1e provisions of the proposed Bases Control Program described in Chapter 5 of the Technical Specifications. LA2- The details in CTS 3.6.A.S.a to perform an " engineering evaluation" to determine the effects of the out-of-limit condition on the structural integrity of the RCS are proposed to be relocated to the Bases. The-requirement in ITS 3.4.9 Required Actions A.2 and C.2 to determine whether the RCS is acceptable for continued operation is adequate to
' ensure the' proper _ analysis is performed. Therefore, the relocated
. details are not required to.be in the ITS to provide adequate protection of the'public health and safety. Changes to the Bases will be O JAFNPPI Page 4 of 8 Revision C 1 j
i DISCUSSION OF CHANGES
- ITS: 3.4.9 RCS PRESSURE AND TEMPERATURE (P/T) LIMITS
' TECHNICAL CHANGES LESS RESTRICTIVE -(GENERIC) l LA2 '(continued) '
controlled by the provisions of the proposed Bases Control Program described in Chapter)5 of the Technical Specifications.
. LA3 The method. defined in CTS 4.6.A.6 to evaluate the temperature differential using the temperature at the reactor vessel-bottom head
" drain line" is proposed to'be relocated.to.the Bases. The requirement in ITS SR 3.4.9.3 to verify the difference between the bottom head-coolant. temperature.and the reactor pressure vessel (RPV). coolant-
- temperature is'within the limits'is adequate.. As such, these details are not. required to be in the ITS to provide adequate protection of public health and safety. -Changes to the Bases will be controlled by the provisions of the. proposed Bases Control Program described in i
- Chapter'S of:the Technical Specifications.
L LA4: .The CTS 3.6.A.2 (l'ast paragraph) temperature allowance of up to 300'F to ! perform the inservice leak and hydrostatic testing is proposed to be 1 relocated to the. Technical' Requirements Manual (TRM). Inservice leak ,Q: and hydrostatic tests are very controlled evolutions' involving. strict: LV' proceduralicompliance. As 'a result,:the maximum temperature limitation is not' necessary to be included in the Technical Specifications to' ensure this maximum temperature' limitation is not exceeded. The minimum-temperatures (at the required pressures) allowed for these tests are i =
' determined from the RPV pressure and temperature (P/T) limits specified l in ITS 3.4.9, " Reactor Coolant System (RCS) Pressure and Temperature l L (P/T)1 Limits.." ITS Figure 3.4.9 1 indicates the minimum temperature !
required atithe associated pressures Operations will ensure these
. limitations are not exceeded. A minimum temperature limit of ;
approximately 200*F is currently required at a reactor pressure of 1040 L psig, therefore adequate margin is available without exceeding the i ' current 300 F limit. In addition, the 300 F limit was chosen based on l an analysis which postulated a recirculation line break and examined the capability.of the secondary containment to-remain intact with the ; primary containment breached (drywell head removed) during inservice '
~ leak and hydrostatic testing with the reactor coolant temperature at 1300 F and RCS pressure 'at 1150 psia. The results of this analysis
.-indicated that the secondary containment would remain intact. '
1Therefore, relocating the.. current temperature limit to the TRM is. Eacceptable.and-is not required to remain in the ITS to ensure adequate
. protection of: public health and safety. At ITS implementation, the TRM will be included in the UFSAR by reference. . Changes to the relocated requirements'in the:TRM will be controlled by the provisions of 110.CFR.50.59.
JAFNPP Page 5 of-8 Revision C E '
-J
q W DISCUSSION OF CHANGES U ITS: 3.4.9 RCS PRESSURE AND TEMPERATURE (P/T) LIMITS j l TECHNICAL CHANGES - LESS RESTRICTIVE (SPECIFIC) L1 CTS 4.6.A.6 requires verification that the temaerature differential between'the RCS and the reactor vessel bottom lead, and between the RCS and an idle recirculation loop, are within limits prior to startup of the . idle recirculation loop. CTS 3.6.A.6 specifies that this is only to l be met when Reactor Coolant System temperature is > 140 F. These requirements are modified by a Note which states that these P/T verifications are only required to be met in MODES 1. 2, 3. and 4 during recirculation pump startup (Note to SRs 3.4.9.3 and 3.4.9.5). Since the overall Applicability of the Specification is reduced (Surveillance is , no longer required in MODE 5 with temperatures > 140 F) this change is a relaxation of. requirements and is less restrictive. This change is acceptable because in MODE 5. the recirculation pumps are rarely placed in operation, and the overall stress on limiting components is lower.
- Therefore, the differential temperature limits are not required. This change is consistent with NUREG 1433. Revision 1. l
- 1 L2 CTS 3.6.A.6.a requires the temperature differential between the reactor j
. coolant ~ system and the reactor vessel bottom head drain line be 5145 F
- during a recirculation loop startup (CTS 3.6.A.6). ITS 3.4.9 provides ld-l /,N the option to verify the active loop flow exceeds 40% of rated drive flow or the active loop has been operating below 40% rated flow for a period no lenger than 30 minutes. ITS SR 3.4.9.4 has been added which ;
provides this allowance. A Note 2 has been added to the requirements of CTS 3.6.A.6.a (ITS SR 3.4.9.3) which 3rovides the option to perform ITS i l SR 3.4.9.4. .Similarly, a Note 2 has 3een added to proposed ITS i SR 3,4.9.4 which provides the allowance to evaluate the temperature ; differential in SR 3.4.9.3. , This change is necessary to avoid an unnecessary plant shutdown to restart an idle' recirculation loop when the bottom head drain line , temperature indicating channel is inoperable, the drain line is plugged. i or if the drain flow is low. The requirement to ensure the differential i temperature between the bottom head drain line and the reactor coolant is within limits has been established to assure avoidance of a thermal : over stress condition to the Control Rod Drive (CRD) stub tubes and in-core housing welds by sweeping hot water across these relatively cooler vessel structures and associated components. The temperature in the bottom head region is usually measured by monitoring the temperature of 4 flow being drawn out from the bottom head drain line. In the past, JAFNPP has experienced the problem of the bottom head drain line being plugged with debris. In order to have a good temperature reading, it is necessary to have sufficient flow through the bottom head drain line. General Electric has determined an alternate method to the verification N of the differential temperature between the bottom head coolant V Page 6 of 8 Revision C JAFNPP a -
E Uf ' ': .- DISCUSSION OF CHANGES ITS: 3.4.9. RCS PRESSURE AND TEMPERATURE (P/T) LIMITS L , I a
' TECHNICAL' CHANGES LESS-RESTRICTIVE (SPECIFIC)
- L2D(continued)
-temperature and'the reactor pressbre vessel (RPV) coolant temperature l
- prior to starting a recirculatio's pump. This alternative is to verify i L the ' active loop flow exceeds 40% of rated drive flow or the active loop
! has been operating below 40% rated-flow for a period no longer than 30 L E minutes prior to starting the recirculation pump (GE NE 208 041292, , Evaluation of Idle Recirculation loop' Restart without' Vessel Bottom Temperature Indication for JAFNPP Nuclear Power Plant). The GE' alternative'is. based onJan evaluation that collected data of startup
- testing at a BWR/3-and BWR/4 plant. The'results from operating BWR plant provides the basis that if the above ~ restart conditions are met '
stratification in the. lower-plenum region will be avoided since there I will either be sufficient mixing in the lower plenum or there wasn't time for the condition to develop.
-When the active loop flow exceeds-40% of its rated drive flow under one l pump operating condition, the evidence shows, analytically and 1 LJ experimentally, that there is sufficient mixing to prevent the thermal
- 9- stratification in the lower plenum region. In order,' to achieve this- ;
LbL l-flow rate reactor power must be above 25 A RTP to clear the feedwater flow interlock at approximately 20% flow. At 25% RTP and 40% drive l flow, a.GE ' steady state hydraulic computer code predicts the core flow for JAFNPP to be at 35% of' rated. Essentially 'all of this flow is i l predicted to be coming-down the jet pump' diffusers on the active loop into the lower plenum to provide:a . good mixing effect. 1 Test-data concerning lower plenum temperature was'obtained during
- natural circulation startup test of a BRW/4 to confirm that this core J' flow is sufficient ~to ensure that adequate lower plenum mixing takes place under one lcop operation. A stratified condition existed for very j low power levels but it was swept out when core flow reached about 20%
--of rated (corresponding to natural circulation at 5% RTP). This
- indicated that 20% core flow was enough to sweep out the. stratified cold water. _The' 35t core flow, as predicted for.JAFNPP, is well above the
, L20% threshold,' and it dould clearly avoid stratification. In addition, during_a hot restart at a BWR/3 with both recirculation pumps ~at 20%
speed and reactor power at < It RTP, it'was: confirmed that a temperature
~
,m . difference of..< 110 F was maintained between the bottom head drain line ! l and the saturation temperature of the vessel. The core flow at this o condition was estimated to be 20%. The results at the BWR/3 is also i Lconsidered to be conservative for the BWR/4 design at JAFNPP. Test data l from the BWR/3 plant also indicated that stratification does not occur immediately upon low flow conditions. This test data showed that stratification did not occur until'an hour after a main turbine trip and JAFNPP! Page 7 of 8 Revision C L , L y 1 y a
1 6 (y ITS: 3.4.9' DISCUSSION OF CHANGES RCS PRESSURE AND TEMPERATURE (P/T) LIMITS TECHNICAL CHANGES - LESS RESTRICTIVE (SPECIFIC) L2 (continued) recirculation pump trip. On this basis, it is-believed that restoring the 40% drive flow condition within 30 minutes is an acceptable criteria for avoiding lower of the second loop. plenum stratification and allowing subsequent restart JAFNPP has reviewed GE report to evaluate whether the proposed criteria for JAFNPP would be acceptable. The original JAFNPP startup test data for a single recirculation pump operation was examined to determine how far away the plant was from stratification at various flow rates. The results indicate that with a recirculation flow rate of 27.5% (resulting core flow of 5 20 Mlb/hr) and power levels between 25% and 44% of RTP,
'the resulting temperature difference was 5 57 F. In addition, startup test data was reviewed for three tests in which both recirculation pumps were tripped. A maximum differential temperature of 44 F was achieved and this was observed after more than two hours after the pump trip.
. The results of the JAFNPP review is included in JAF-RPT RWR 02076, Rev 0 (Verification of Alternative Operation Conditions for' Idle D.
-(J Recirculation Loop Restart without Vessel Bottom Temperature Indication). There the proposed alternatives 'are considered acceptable i for JAFNPP. l TECHNICAL CHANGES RELOCATIONS None l D JAFNPP. ' Page 8 of 8 Revision C 1
h 1
-VOLUME 12 ITS 3.5 CONVERSION PACKAGES 1
This paga provided as a place holder and to assist personnel updating the JAFNPP ITS submittal to Revision C. O Discard this page along with pages' removed in accordance with the page replacement instructions. 1 k
c i, 4
)
M,
'" s-1i y1 n 1 i,I 11 '3 4
1 1 Eg
~
11 1 *1 0 I t 4os 3 j '
$ 1 1I[i t E"12 k r >$1 e
} H$ [Ia
\\b h,u>
v ~ a e i s -&, ,
\
O \ i 1* i 4 .ai na 1 gi e ri w gjba'i l g{ l h*s. 3
\d d s.
q 1
,o n 14 3
em i., n. 1 1
=
?
g}@ gj5 Df[
, , e VI e
\#
O 3
(O u) O 7 d l N Y o c
.9 I 9 .E!
o e
.c. g V
l e o U e N i l l l m r==
.O h
r-r= 8 n v I; 8 u C r= 8, 8. l
.v, r=
l l 1 l 3 i l l l l
W - 0
- k l O6 jiij
.lla !!_ 8 - = -in %-omt ~ \ *~ z8 . .g* % Ex n 1
482= 5$j m o I d 51*rf Ii i 4 g- 1 g I 4 o
=. %
5 -
]=47,1" e
.a a l se
-e, =a ]sai2 e
s-2 I e e s 8
~
R fi f$$:.5 o i}gh
- a. E2, 1 E
E i,3. l I
~
b ? O I&s 3 a l (n d n N .g 6 ce s l hl m ?d ) I Ef P3 .$ ej NB ~- g Nb3 e "Eh .e ll E lUhis e El i s : e J.sia
-=
g8 <j a <gs i' m. t_g a.2 -s-1 o g to *gE Ej51 .
? 2~
h %ee sh (
!nN;I!;f II iiiN 4*I$
Tff o! 1 N i t ni. e n,= x l b
;21
'v ga=_) a.-
a2 ! ea m g
~l% DJ (.!!]i! E 5E !
-Q =
f. 9 + 1 e O E-E - i S to.J l
-- y l
l f, an= y' O
. d M yo F d8
.? 9 lE S c>
$ AS [,
.=
.= ,
4 1
- l W I 1
I i e ! r== l El y l l F"m" C C h M d - 8 C ! r=
- 8. .
v,
*r=
c I j i l d A U I;
I e .
, DISCUSSION OF CHANGES
{ ITS: 3.5.1 - ECCS - OPERATING ADMINISTRATIVE CHANGES i Al- In the conve sion of the James A. FitzPatrick Nuclear Power Plant (JAFNPP) Current Technical Specification (CTS) to the proposed plant specific Improved Technical Specifications (ITS) certain wording , preferences or conventions-are adopted which do not result in technical ' changes. Editorial changes, reformatting, and revised numbering are
' adopted to make the ITS consistent with the conventions in NUREG 1433.
" Standard Technical Specifications, General Electric Plants, BWR/4,"
Revision'1 (i.e., Improved Standard Technical Specifications (ISTS)). A2 Existing specifications governing Operability and Surveillance Testing , of Core Spray (CTS 3.5.A.1), Low Pressure Coolant Injection (CTS 3.5. A.3), High Pressure Coolant Injection (CTS 3.5.C.1), and Automatic Depressurization System (CTS 3.5.D.1) are proposed to be combined into proposed Specification 3.5.1, Emergency Core Cooling Systems (ECCS)-Operating, in recognition of the interdependence of the 0)erability requirements of.these systems in meeting the assumptions of t1e design basis loss of coolant accident. In addition, su) porting requirements in CTS 3.5.G .(Maintenance of Filled Discharge )iping), and CTS 3.9.F (LPCI H0V' Independent Power Supply) have been included along O ' with the Surveillances of ITS 3.5.1 (SR 3.5.1.1 and SR 3.5.1.5, V. respectively). - This is an administrative change in the format designed to make the Required Actions for inoperable ECCS more understandable to the operator.
.A3 Existing ' surveillance tests to simulate automatic actuation of CS (4.5.A.1.a) LPCI (4.5.A.3), and HPCI (4.5.C.1) are all covered by ITS
'SR 3.5.1.10. This SR is modified by a Note that excludes vessel injection / spray during the Surveillance. However, the Bases indicate that -this test must include actuation of all automatic valves to their required )ositions. Since all active components are testable and full flow can ae demonstrated by recirculation through the test line, coolant injection into the RPV is not required during the Surveillance. This Note, therefore is explicit recognition that proposed SR 3.5.1.10 can be satisfied by a series of overlapping tests. Since surveillance testing of CS (CTS 4.5.A.1.a), LPCI (CTS 4.5.A.3), and HPCI (CTS 4.5.C.1) do not presently require actual injection. and are all currently satisfied by a series of overlapping tests, the addition of the Note excluding vessel injection / spray is an administrative change.
CTS 4.5.D.1 requires a simulated actuation test to be performed on the ADS valves. A Note.is proposed to be added (Note to proposed SR 3.5.1.111 to exclude valve actuation. The valves are actuated per proposed SR 3.5.1.12. Therefore, similar to the ECCS pump Note, this change is administrative. JAFNPP Page 1 of 22 Revision C
m DISCUSSION OF CHANGES
, ITS: 3.5.1 --ECCS - OPERATING
- LADMINISTRATIVE' CHANGES; A4L ' CTS 3.5.C.2 and CTS 3.5.D.3 do not require the High Pressure Coolant Injectioni(HPCI) System and Automatic Depressurization System (ADS) valves.~ respectively, to be Operable during low power physics testing and during reactor operator (criticality) training provided the reactor
; coolant temperature s 212 F. These explicit requirements are not retained'in the ITS. CTS 3.5.D.1: does not require the ADS valves to be -
.0perable in cold condition. According to CTS Definition 1.0.C,_ Cold Condition means that~the reactor coolant tem >erature is s 212 F. -In
- addition, CTS 3.5.C.1 does not require the H)CI System to be Operable I when the-reactor coolant temperature is s 212 F. .Therefore, since there '
are no'0)erability requirements'for the HPCI System and ADS valves
- during tie conditions of CTS 3.5.C.1 and CTS 3.5.D.1, the allowances
~
provided are meaningless and therefore these deletions are considered
. administrative. This cht ,ge is consistent with NUREG 1433, Revision 1.
fA5- CTS 3.5~C.3 does not require High Pressure Coolant Injection (HPCI) to be operable with reactor coolant temperature > 212 F during hydrostatic
; pressure and : leakage testing. This exception is indirectly incorporated a- -
- into ITS 3.10.1, Inservice. Leak and Hydrostatic Testing Operation, which
~ allows the reactor to be considered in MODE 4 with the reactor coolant temperature > 212 F. The exception allows the HPCI system to not be
- Operable (as required by CTS'3.5.C.1)-while performing inservice leak or
! hydrostatic testing wdth the average reactor coolant temperature
> 212*F. 1Since LC0 0.5.1 is'not listed as any of the required MODE 3 i
LCOs to be met'in ITS 3.10.1 and the Applicability of LCO 3.5.1 does not include MODEL4, HPCI is not: required to be Operable. Therefore,'since this allowance is indirectly incorporated into ITS 3.10.1, this change is considered.to be an administrative presentation preference. This change is consistent with NUREG 1433 Revision 1.
- A6 ~ ' CTS '4.5.G.2 requires that. "following any period where these subsystems
- or' systems have not been maintained in a filled condition; the discharge l
piping shall be verified filled with water from the pump discharge valve i to the injection valve prior to declaring the subsystem or. system j
. operable". :In the ITS presentation this type of requirement is handled j
generically by~SR 3.0.1. - SR 3.0.1 states in part that " failure to meet i a Surveillance, whether such failure is experienced during the I
; performance.of the Surveillance or between performances of the I
' Surveillance, shall be a failure to' meet the LC0" and that "Surveillances do not have to be performed on inoperable equipment or *
- variables'outside s)ecified limits." The Bases for SR 3.0.1 clarifies
~these' requirements )y stating "Upon completion of maintenance, 3
- a))ropriate post maintenance, testing is required to declare. equipment j
'0)ERABLE. T11s includes ensuring applicable Surveillances are not -
failed and their most recent performance is in accordance with JAFNPP Page 2 of 22 Revision C
- h. \
h, .n -&
' DISCUSSION OF CHANGES-j, '
LITS: 3.5.1 ECCS OPERATING l , AIM NISTRATIVE CHANGES ^ , ,. ?A6;f(continued)- l l :SR 3;0 2." Thus, anytime'where these subsystem or systems had not been i maintained in a filled condition:SR 3.0.1 would require that the l l subsystems or / systems be verified filled prior to deciaring the ) L . subsystems or systems operable. _ >Therefore, this change is not'a
' technical change and is considered administrative. The change-is consistent with'NUREG 1433, Revision 1.
l A7. . CTS 3.5.A.4.a requires th'at the." reactor shall not be started up with !' the RHR System supplying cooling to the fuel pool." CTS 3.5.A.b.4 l requires that'"the RHR System shall not supply cooling to the spent fuel , L - pool'when.the. reactor coolant temperature-is above 212 F." ' l In.the proposed ITS presentation the ability to change MODES is
- generically controlled.by the provisions of- LC0 3.0.4 which states in 1 part that'"when:an LC0 is not met, entry into a MODE or other specified !
- - condition Lin the Applicability'shall not be made except.when the L associated ACTIONS to be entered >ermit continued operation in the MODE
' 3 W or other specified condition in t1e Applicability for an unlimited period of time." - LC0 3.5.1, Condition A and . Condition B require that the LPCI mode of- RHR be Operable in MODES 1, 2. and 3, or if inoperable the reactor would be required to shutdown in 7 days,12 hours. Therefore LC0 3.0.4' would prevent plant startup with a LPCI subsystem 3
' inoperable'(i.e.,L su) plying cooling to the fuel pool results. in LPCI
'being inoperable). _ikewise,'if the. reactor coolant temperature'is
- above 212*F, with the plant'in MODE 1, 2 or 3 by definition of the MODES Table' (Table 1.11), both subsystems of LPCI would be required to L ;be Operable, and-therefore a loop of RHR could not be used to supply cooling water- to the fuel. pool . Therefore this proposed change causes l no technical.or actual c.hange from present specifications. Therefore, i .the change is considered administrative 'and is consistent with NUREG-1433. Revision 1.
l A8 A new ACTION has.been added to CTS 3.5.A (for the Core Spray Systems and Low Pressure Coolant Injection Systems), CTS 3.5.C (for the High
' Pressure Coolant Injection System) and CTS.3.5.D (for the Automatic u -Depressurization System (ADS)-for all other. conditions not addrested in
- the current Specification or in ITS 3.5.1 Conditions A,'B, D, E, F, G, or H. ; With so.many ECCS Systems inoperable the plant is considered to be 'outside it-design bases and entry into CTS 3.0.C will be required.
ITS 3.5.1 ACTION J.is being proposed which will require immediate entry into LC0 3.0.3 (Required Action J.1) under the same conditions. Since ld 2 the current Technical Specifications will also require entry into CTS l JAFNPPE Page 3 of 22 Revision C l
c Lp DISCUSSION OF CHANGES ld ITS: 3.5.1. ECCS OPERATING ADMINISTRATIVE CHANGESL L
'A8';(continued) 3.0.C. this change-is considered administrative. Changes to action requirements of CTS 3.0.C are covered in the Discussion of Changes for
. ITS LC0 3.0. -In addition. CTS 3.9.F.3 requires that "the reactor shall-be brought to cold condition within 24 hours" when both LPCI independent L
h power supplies are~ made or found to be inoperable. This specific
- default action has been changed to require entry into LC0 3.0.3 since the plant will be outside of its design basis in the condition. This portion of the. change may be considered as more restrictive but since-
'the current Completion Times in CTS 3.9.F.3 and CTS 3.0.C are equivalent this change is classified as administrative. These changes are consistent with NUREG 1433. Revision 1.
.. A9 ~ The requirements in: CTS 3.5.A.3.b and CTS 4.5.A.3.b concerning the LPCI cross tie valves have been simplified into one Surveillance which l requires the verification that the valves are closed and power is removed from the electrical ~ valve operator every 31 days (ITS SR l ,3.5.1 4). The details on how this is performed have been relocated to L
the Bases'in accordance with LA4. Since the current' requirements in both CTS 3.5.A.3.b and 4.5.A.3.b require the valves to be closed and L power to be removed. this change reflects a presentation preference and is considered administrative since identical requirements-have been
' combined into one'. Surveillance (SR 3.5.1.4) in the ITS. This_ change is
,' consistent with NUREG 1433,' Revision 1.
-A10 CTS 3.'5.G.1 requires the associated ECCS pump (e.g.. LPCI and CS) to be declared ino rable for-the purposes of satisfying Specifications 3.5.A. j L 3.5.C and 3. .E. when the associated pump discharge piping cannot be 4
-maintained in a filled condition. This explicit cross reference is not
. required in ITS 3.5.1 since this CTS requirement is included ulong with the requirements of the associated; system. Failure to meet this iSurveill'ance will require direct entry into the appropriate ITS 3.5.1
' ACTION (S). The Operability requirements in CTS 3.5.G.1 and 4.5.G.1 are l i
directly incorporated in the required surveillances of ITS 3.5.1 (SR 3.5.1.1). . ITS SR 3.0.1 states- that SRs shall be met during the MODES or l other specified conditions in the Ap)11cability for. individual LCOs. { a 1 unless otherwise stated-in the SR. railure to meet a Surveillance shall be:a failure to meet the LCO.' Therefore, incorporating the requirement to. verify pump discharge piping is in the filled-condition within the
'SRs associated with ECCS-Operating ensures the associated ECCS pump is declared inoperable when the surveillance is not met. Since there are no changes to any technical requirements this change is considered I administrative. This change is consistent'with NUREG 1433. Revision 1.
q.
- O'JAFNPP Page 4 of 22 Revision C j l
d 4
]
pr L },9 4
.j m DISCUSSION OF CHANGES-ITS: 3.5.1 lQ ECCS OPERATING i
iADMINISTRATIVE CHANGES
- All- -
)iping of the required ECCS subsystem l CTS 4.5.G.1' requires theto prior be vented to t1e s
every testing month of the LPCIdischarge and CS subsystems; This explicit requirement to perform the surveillance prior ? :to the-testing of the.LPCI and CS subsystems has been deleted. The requirement to perform this surveillance every 31 days (ITS SR 3.5.1.1) i L 1s sufficient to ensure the discharge piping is full whenever the system. ;
'is required to be Operable. This change is necessary since the ECCS j
subsystems flow rate Surveillances :(e.g. , CTS 4.5.A.1.b) are no longer i
. tested every month. . The Frequency of these Surveillances have been i I
changed to "In accordance recently approved with the Inservice Technical Specification Licensing~ Testing Program" Amendment 241. in_ . CTS !
;4.5.G.1 should have been modified during the process of the change. l This will make the Surveillance. consistent with other parts of the CTS and is therefore considered to be an administrative since the current Surveillance Frequency is-every 31 days. This change is consistent with .
NUREG 1433. Revision 1. l
- A12 y;
The the-otrebuirement in' CTS 3.9.F.2.a r LPCI inde)endent that operations power supply may continue battery including only if its battery l charger,. and distri >ution system is Operable has been deleted. The 4 requirements of the battery and battery charger are included in ITS 3.8.4,- while the requirements of battery cell parameters are included in . ITS 3.8.6. -ITS 3.5.1-includes the requirements for the inverters and
- l. the associated buses. The Safety Function Determination Program (ITS L 5.5.12) which will,be implemented 'at .ITS implementation will require entry into ITS LCO 3.0.3, when a component in each division is inoperable. In this situation, there .is a loss.of safety function since the flow path of all-~ LPCI pumps is not available. Therefore', the plant must ' shutdown in' accordance with ITS 3.5.1 Required Action J.1 which requires'immediate entry into LC0 3.0.3. The explicit removal of CTS 3'.9,F.2.a.is considered administrative since the inclusion of the Safety Function Determination Program (as reflected in the Discussion of
' Changes' for Section'5.0)' will monitor these types of inoperabilities to ensure there.is no loss of safety function. Entry into proposed LC0 l .3.0.3 will'be required u)on this loss of safety function. This change
.is consistent with the p111osophy of NUREG 1433. Revision 1.
A13 CTS 3.5.D.4-does not require the Automatic Depressurization System (ADS) to be operable with reactor coolant temperature < 300*F during
. hydrostatic pressure and leakage testing. This exception is indirectly incorporated into ITS 3.10.-1, Inservice Leak and Hydrostatic Testing Operation, which allows the reactor to be considered in MODE 4 with the y average reactor coolant temperature > 212'F. The exception allows ADS to not be Operable.- as required.by CTS 3.5.D.1. while performing inservice 1 ak or: hydrostatic testing with reactor pressure > 100 psig JAFNPP, Page 5 of 22 Revision C l
l s !
DISCUSSION OF CHANGES .OV ITS: 3.5.1 - ECCS - OPERATING
. @MINISTRATIVE CHANGES !
-A13 -(continued) l and the average reactor coolant temperature > 212*F. Since LC0 3.5.1 is not listed as any of the required MODE 3 LCOs to be met in ITS 3.10.1 and the Applicability of LC0 3.5.1 does not include MODE 4. ADS is not ;
required to be Operable. Therefore, since this allowance is indirectly ' incorporated into ITS 3.10,1 this change is considered to be an administrative presentation preference. This change is consistent with NUREG 1433. Revision 1. TECHNICAL CHANGES MORE RESTRICTIVE M1- CTS 4.5.C permits up to 10 days of continuous operation from the time steam becomes available until HPCI Surveillances need to be performed. The Note to ITS SR 3.5.1.8 and SR 3.5.1.9 and Note 1 of SR 3.5.1.10 will allow only 12 hours from the time reactor steam pressure and flow are adequate to-perform the test. The 12 hours is deemed to be adequate to perform the testing involved without impacting plant operation. Since fT the relaxation from performing the test has been reduced from 10 days to V~ . 12 hours the change is considered more restrictive. This change will have no impact on plant safety. Instead, it will require that the actual surveillances be performed sooner in the plant startup, and
.thereby demonstrate HPCI Operability sooner than current requirements dictate.
M2 CTS 4.5.C.1 requirement, that HPCI deliver at least 4,250 gpm (see L7) is being divided into two separate Surveillance Requirements SR 3.5.1.8 and SR 3.5.1.9. ITS SR 3.5.1.8 will require a demonstration of the HPCI pump capability at nominal conditions (970 to 1040 psig in the reactor steam dome) every 92 days. ITS SR 3.5.1.9 will require a demonstration of the HPCI pump capability 5 165 psig every 24 months. Dividing the current surveillance into two separate Surveillance Requirements with explicit Frequencies, 'and specifying the reactor vessel pressure ranges constitutes an added requirement. Therefore, this change is more restrictive on plant operation but necessary to ensure HPCI is Operable over its entire operating-range. M3 CTS 3.5.D.1 requires that at least 5 of the 7 ADS valves be Operable.
.ITS LC0 3.5.1 requires that at least 6'of the ADS valves be Operable.
The 3rowsed change also' adds three Actions (ITS 3.5.1 ACTION F, G, and H) w11c1 do not exist in the CTS. ACTION F contains requirements for
-what to do if one of the six required ADS valves are inoperable. The Action allows up to 14 days to restore the inoperable ADS valve. ACTION G limits. continued reactor operation to 72 hours when there is a
-Q
'JAFNPP Page 6 of 22 Revision C
m DISCUSSION OF CHANGES G ITS:-3.5.1 ECCS - OPERATING TECHNICAL CHANGES - MORE RESTRICTIVE M3 (continued) simultaneous inoperability of one required ADS valve (one of the six required ADS valves) and one low pressure ECCS (CS or LPCI) subsystem or one LPCI pump inoperable in each subsystem. ACTION H limits continued
-reactor operation to 72 hours when there is one required ADS valve inoperable and the HPCI system inoperable. These requirements are more restrictive because current requirements would allow continued plant operation under the same conditions. .The current specifications do not ,
have~ any concurrent Actions for inoperable ADS valves and inoperable low ! pressure ECCS Systems. With only five ADS valves Operable or with both a' required ADS valve and a low pressure ECCS subsystem (or one LPCI pump inoperable in each subsystem) inoperable, or with a required ADS valve inoperable and HPCI inoperable, another single failure may place the plant in a condition where adequate core cooling may not be available I during an accident. Therefore, the added more restrictive actions are I appropriate. The addition of new requirements to the Technical Specifications constitutes a more restrictive change. These Completion Times are consistent with the recommendations of a reliability study (Memorandum from R.L.. Baer (NRC) to V. Stello, Jr. (NRC), " Recommended
~
Interim Revisions to LCOs for ECCS Components," December 1, 1975) and-have been found to be acceptable through operating experience, j i M4 CTS 3.5.A.6 requires that the reactor be placed in the cold shutdown condition within 24 hours when the ACTIONS or Completion Times l associated with an inoperable. LPCI or CS System cannot be satisfied. CTS 3.5 C.1.b and CTS 3.5.D.2 require that the reactor be placed in the cold shutdown condition within 24 hours when the ACTIONS associated with an inoperable HPCI or ADS System cannot be satisfied. In addition, CTS l 3.9.F.3 requires that the reactor be brought to cold condition within 24 l hours when both LPCI independent power sup) lies are made or found to be j inoperable. This specific default action las been interpreted to also rNuire entry when the ACTIONS or Completions Times associated with CTS c.9.F.2 is not met since no other exists. ITS 3.5.1 Required Actions C11 and I.1 will require the plant be in MODE 3 within 12 hours under ; the same conditions. Based on operating experience, this Completion
~ Time limit still allows for an orderly transition to MODE 3 without challenging plant systems. This change is more restrictive because it )
j arovides an additional requirement to place the plant in MODE 3 in 12 l lours but is necessary to ensure timely Action is taken to place the l plant in a MODE outside of the Applicability. L . l MS- CTS 4.5.A.5 requires that recirculation pump discharge valves be demonstrated 0)erable (capable of being closed) following "any period of
,p reactor _ cold slutdown exceeding 48 hours". This requirement is proposed .v. JAFNPP Page 7 of 22 Revision C !
r j
l I c . DISCUSSION OF CHANGES ITS: 3.5.1 ECCS OPERATING-TECHNICAL CHANGES MORE RESTRICTIVE M5 (continued) to' be replaced by SR 3.5.1.6 which requires that recirculation pump discharge valve Operability verification be performed once each startup prior to exceeding > 25% RTP. Recirculation pump discharge valves are i not required while the plant is shutdown. The recuirement to perform
- the verification once each startup prior to exceecing 25% RTP is more restrictive.than the existing requirement to aerform the test since the test will now be required to be aerformed wit 1in 31-days of any startup not just a startup from a Cold Slutdown that exceeded 48 hours. This change is necessary to ensure the Operability of the recirculation pump discharge valves are~ adequately maintained.
M6 A new requirement to verify the ADS pneumatic supply header pressure has been added to existing Specifications to ensure adequate pneumatic pressure is available for ADS operation. This new requirement in SR , 3.5.1.3 replaces CTS 4.6.E.3 (see comment LA5), the integrity surveillance of the nitrogen system since it addresses an important characteristic'of OPERABILITY of whether there is sufficient pressure available to permit the actuation of the ADS valves. pneumatic
]'v addition of this new requirement to the Technical Specifications The constitutes a more restrictive change necessary to ensure minimum operability requirements.
M7 CTS 4.9.F.7. the requirement to open the battery charger A C input breakers one at time and to observe proper operation, has been revised to explicitly state the required LPCI inverter output voltage. This SR will require to cycle open and closed each LPCI motor operated valve 1 independent power supply battery charge AC input breaker- and verify that
.each. inverter output voltage is > 576 V and 5 624 V while supplying the respective bus. Since more details are being added this represents a more restrictive change but is necessary to help ensure that the electrical power to the LPCI injection and heat exchanger bypass valves and recirculation discharge valves remains Operable.
M8 _ According to CTS 3.9.F.1, the reactor shall not be made critical unless
. both LPCI HOV Independent Power Supplies are operable which is effectively MODES 1 and 2. ITS 3.5.1 requires the low pressure core injection subsystems to be Operable in MODES-1, 2 and 3. Since the operability of the LPCI MOV Independent Power Supply effects the OPERABILITY of the associated LPCI subsystem, the operability ,
requirements of LPCI MOV Independent Power Supplies have been extended ' to MODE 3. This ensures that each LPCI subsystem will remain operable with the required uninterruptable power supply during reactor conditions
'JAFNPP Page 8 of 22 Revision C l
m l l DISCUSSION OF CHANGES
- (
n) =. ' ITS: 3.5.1 ECCS OPERATING v TECHNICAL CHANGES 'MORE RESTRICTIVE 1 M8 (continued)
- where there is significant core energy. This change is considered more restrictive and has no adverse effect on safety. '
M9 - CTS 4.6.E.4 requires the safety / relief valves to be manual opened every I 24 months. ITS SR 3.4.3.2 requires this same manual opening but requires the actuation to be initiated on a Staggered Test Basis for each valve' solenoid. This will ensure that a different solenoid will be used to actuate the valve every 24 months and is considered more restrictive since'the current requirement does not specify which solenoid to use. This change is necessary to ensure both solenoids are tested within any 48 month period. M10 CTS 3.5.A.'S requires 'all recirculation pump discharge valves to be Omrable prior to reactor startup (or' closed if permitted elsewhere in t1ese specifications). ~ ITS 3.5.1 and associated SR 3.5.1.6 also require all recirculation. pump discharge valves to be Operable. However, if this requirement can not be met, then ITS SR 3.5.1.5 allows the Q-
' 'v associated recirculation pump discharge valve to be "de energized" in the closed position. Requiring the inoperable recirculation pump l
. discharge valve to also be "de energized" in the closed position '
represents an additional restriction on plant operation. This change is
-necessary to ensure the proper flow path for the associated LPCI subsystem.
Mll CTS 4.5.G.3 requires the HPCI System discharge piping to be vented from the high point of the system whenever HPCI is lined up to take suction from the condensate storage tank (CST) on a monthly basis. In ITS SR 3.5.1.1.this requirement must be met whenever HPCI is required to be l Omrable whether it is aligned to the CST or the suppression pool. This clange is considered more restrictive on plant operation but necessary to help prevent a water hammer following an initiation signal. M12 CTS 3.5.A.1 and 3.5.A.3 require the Core Spray (CS) and Low Pressure Coolant Injection (LPCI) Systems,.respectively to be Operable whenever irradiated fuel-is in the reactor vessel and prior to reactor startup from cold shutdown (this covers MODES 1, 2 in the ITS). CTS 3.5.A specifies requirements for the LPCI cross tie valves whenever reactor water temperature is greater than 212*F (this covers MODES 1, 3, and l portions of MODE-2 operations). In addition CTS 3.5.A.5 specifies l requirements:for the recirculation pump discharge valves arior to reactor startup (this covers MODE 1 and 2 in the ITS). T1e ITS Applicability for these components and Systems (Applicability of ITS
.m '3.5.1) are MODES 1, 2 and 3. This change is more restrictive since the i .
JAFNPP Page 9 of 22 Revision C 1 L
, 11 , n b ITS: C RATING TECHNICAL CHANGES MORE RESTRICTIVE- )
, .M12n(continued).
A)plicability.of all portions of the CS and LPCIl subsystems have been clanged to'coverfall three plant operating modes. .This change is necessary to ensure all portions.of these low pressure ECCS Systems are Operable in _HODES where they are" assumed to mitigate accidnts. M13 An' actual .o'r -simulated automatic isolation test (ITS SR 3.5.1.10) has been added to the requirements of. CTS Table'4.2 2 Item 3 (Part-2)
..(Containment. Cooling Subsystem) to.' ensure both a Logic System Functional Test as well-as an actual or: simulated-automatic isolation test is
, performed ~ for all associated Low Pressure Coolant. Injection (LPCI) ;
System Functions. currently included in Table 3.2-2 and.4.2 2. The new l '~ Surveillance will ensure' CTS Table _3.21~ Items 5 and 6 -( ITS Table 3.3.5.1 1: Functions-2.'e and 2.h, Reactor Vessel Shroud Level (Level 0) and' Containment Pressure - High) are properly tested throughout their a operating. sequence. . Although the current test seems to-imply the test j
- is related to the operability of the containment cooling mode, CTS 3.2 2
# : states;that these functions prevent inadvertent operation of containment {
j @. L spray during accident conditions which ensures the 0perability of the, l A./ associated LPCI subsystem. This surveillance is not currently required
'to be' performed, therefore, this change.is considered more~_ restrictive on plant operation-but is added.to enhance plant safety.
p TECHNICAL CHANGES' LESS RESTRICTIVE (GENERIC) LAlf ! CTS 4.5.D.1.b discusses a surveillance requirement for demonstrating that a simulated automatic' ADS actuation.is inhibited by the override switches. The ADS Inhibit Switch Function 'is an operational function ! only and is not~ considered in any' design basis accident or transient.
'It'does provide mitigation of-the consequences of.a non design basis
--ATWS' event: ' however the evaluation summarized in NED0 31466, November L 1987,cdetermined.the11oss of ADS Manual Inhibit Switch Function to be a 1, non significant risk contributor to core damage frequency and offsite i
1 release. Therefore, the requirements specified in CTS 4.5.D.1.b for the l 4
- ADS Inhibit Switch Function did:not satisfy 10 CFR 50.36(c)(2)(ii) and' 3are proposed.to be~ relocated to the Technical Requirements Manual (TRM).
The TRM will be incorporated by reference.into the UFSAR at ITS implementation. Changes to the TRM will be controlled by the provisions
- of- 10f CFR 50.59.
TLA2 The ' details inLCTS 4.5.0.1'.a that the simulated automatic- actuation test for the Automatic-Depressurization' System (ADS) o) ens the pilot valves D/ (controlfvalves)-is proposed to be relocated to t1e Bases. The Q" ' QAFNPP; 'Page-10 of 22 Revision C p j ..
= l DISCUSSION'0F CHANGES ' ITS:'3;5.1 ECCS. OPERATING l
~
, l TECHNICAL CHANGES LESS RESTRICTIVE' (GENERIC)
LA2 (continued)-' I Erequirementtin SR 3.5.1.11 to verify'the ADS actuates on an actual (L1) or simulated-automatic initiation signal every 24 months, the-requirement'in LC0 3.5.1 that the ADS function of six safety / relief valves shall be OPERABLE, the definition of OPERABILITY and the applicability of these requirements ensures the appropriate components
'must be OPERABLE and tested in the-required Frequency. As such, these details-are not required to be in the ITS to provide adequate protection of the public health and safety. Changes to the Bases will be controlled oy the provisions of the proposed Bases Control Program described in: Chapter 5 of the Technical-Specifications. '
~
LA3 The methods'in CTS 4.6-E.4 for verifying the safety / relief valves have
' opened-(i.e., while bypassing steam to the condenser, etc) and the
; detail that the test must be performed in Run are proposed to be <
relocated to the Bases. These details are not necessary to ensure Operability-of the S/RVs. The requirements of ITS LCO 3.5.1 and the
- associated SRs are adequate to ensure that ADS is maintained OPERABLE.
;SR 3.5.1.-13 will require each required ADS valve to be manually actuated after reactor (steam dome pressure and flow are' adequate to perform this test. The Bases for this SR will prescribe the test method and the ;
' conditions.for performing the test. In addition, the Bases discusses that-the' pressure and flow conditions will. require-the plant to be in
- MODE 1,- which has been shown to be an acceptable condition to perform this test.. This test will cause a small neutron flux transient which
!may cause a. scram while operating close to the Average Power Range-Allowable Value in MODE 2. - As Monitors such theseNeutron Flux-High methods.of (Startup)d verification an details that the plant must be in Run are not necessary to be included in the ITS to provide adequate
)rotection of the >ublic health and safety. Changes to the Bases will
)e; controlled by tie 0rovisions of the proposed Bases Control Program described in Chapter .2 of the Technical Specifications,
- LA4' CTS'3.5.A.3.bcontains detailed descri)tions of the requirements of assuring that the LPCI cross tie line >e. isolated. ITS SR 3.5.1.4
^ requires.that the cross tie valves be verified closed and electrical power be removed from the electr1cally powered motor operator, ,
! Additional: details on actual valve numbers and method of valve closing i
. presents informat_ ion that is not. required for assuring that the cross- !
tie' be isolated. JThese: additional details 1are proposed to be relocated to the Bases. As such, these details are-not required to be in the ITS to provide adequate protection of the public health and safety. Changes Lto the Bases will be controlled by the provisions of the proposed Bases i . Control. Program. described in Chapter 5.of the Technical Specifications.
.k 1
JAFNPR . Page'11 of 22 Revision C m .
(py DISCUSSION OF CHANGES ITS: 3.5.1 - ECCS OPmRATING 1 l TECHNICAL CHANGES - LESS RESTRICTIVE (GENERIC) 1 LA5 -The requirement in CTS 4.6.E.3 concerning the integrity of the nitrogen system and: components which provide manual and ADS actuation of the j safety / relief valves are proposed to be relocated to the Technical 1 Requirements _ Manual (TRM) . The system will continue to be required to perform its required safety function to be considered OPERABLE. ITS SR 3.5.1.3 is added (refer to M6) to address the important characteristic of whether there is sufficient pneumatic pressure available to permit the actuation of the ADS valves should an accident occur. The Operability requirements of ITS 3.5.1 for ADS valves and the ITS definition of OPERABLE - OPERABILITY are adequate to ensure the ADS , valves are maintained capable of performing their specified safety function. In addition the surveillance being relocated will continue to be performed and will identify degradation of the ADS nitrogen system pressure retention capabilities. As such, this surveillance is not required to be in the ITS to provide adequate protection of the public health and safety. Changes to the relocated requirement in the TRM will be controlled by the provisions of 10 CFR 50.59. LA6 CTS 4.5.G.1, 4.5.G.2 and CTS 4.5.G.3 present the technical detail of (] the method to be employed to assure that the Core Spray, Low Pressure u Coolant Injection and High Pressure Coolant Injection pump discharge lines are full of water (shall be vented from the high point of the system and water flow observed). The detail pertaining to how these Surveillances are to be performed are proposed to be relocated to the Bases. These details are not necessary to ensure the Operability of the ECCS subsystems. The requirements of Specification 3.5.1,
- ECCS-Operating, and the associated SR 3.5.1.1 are adequate to ensure the ECCS subsystems remain Operable. Therefore, the relocated details are not required to be in the ITS to provide adequate protection of the
_ public health and safety. Changes to the Bases will be controlled by the provisions of the Bases Control Program described in Chapter 5 of the Technical Specifications. LA7 The requirement in CTS 4.5.A.1.d and CTS 4.5.A.1.g to perform motor operator valve and testable check valve testing respectively, for the Core Spray System in accordance with the Frequency of the Inservice Testing (IST) Program are proposed to be relocated to the IST Progran. In addition, these same terts required for the Low Pressure Core Injection System (referenced in CTS 4.5.A.3) and the High Pressure Coolant Injection System (referenced in. CTS 4.5.C.1) are also proposed to be relocated to the IST Program. The IST Program lists all valves required to be tested in accordance with ASME Section XI. In addition, ITS 5.5.7 requires the IST Program to be conducted. These controls are adequate to ensure the required tests are performed at the appropriate .(V 4 frequencies. Therefore, these tests do not need to be repeated in the JAFNPP Page 12 of 22 Revision C
/5 DISCUSSION OF CHANGES V ITS: 3.5.1 ECCS - OPERATING TECHNICAL CHANGES LESS RESTRICTIVE (GENERIC) l LA7 (continued)
Technical Specifications to provide adequate protection of the public health and safety. Changes to the IST Program will be controlled by the provisions of 10 CFR 50.59. LA8 The requirement in CTS 4.9.F.1 and CTS 4.9.F.6 to perform a weekly visual inspection on the LPCI M0V Independent Power Sup31y inverters is proposed to be relocated to the Technical Requirements ianual (TRM). This inspection does not necessarily determine whether the inverter is OPERABLE. The requirement in proposed SR 3.5.1.5 (see comment M7) to verify the LPCI independent power supply inverter output voltage is within the correct limits while supplying the associated bus and the proposed Surveillances in LCO 3.8.4, "DC-Sources" for the LPCI independent power supply batteries ensures an uninterruptable power supply is available to support the LPCI motor operated valves during a design bases accident. As such, this surveillance is not required to be in the ITS to provide adequate protection of the public health and safety. At ITS implementation, the TRM will be incorporated by : reference into the UFSAR. Changes to the relocated requirements in the (U,) TRM will be controlled by the provisions of 10 CFR 50.59. LA9 - The CTS 3.5.C.3 and 3.5.D.4 tem 3erature allowance of up to 300 F to perform the inservice leak and lydrostatic testing is proposed to be relocated to the Technical Requirements Manual (TRM). Inservice leak and hydrostatic tests are very controlled evolutions involving strict procedural compliance. As a result, the maximum temperature limitation is not necessary to be included in the Technical Specifications to ensure this maximum temperature limitation is not exceeded. The minimum temperatures (at the required pressures) allowed for these tests are determined from the RPV pressure and temperature (P/T) limits specified in ITS 3.4.9, " Reactor _ Coolant System (RCS) Pressure and Temperature ! (P/T) Limits." ITS Figure 3.4.9 1 indicates the minimum temperature required at the associated pressures. Operations will ensure these ,
. limitations are not exceeded. A minimum temperature limit of approximately.200 F is currently required at a reactor pressure of 1040 psig, therefore adequate margin is available without exceeding the current 300*F-limit. In addition, the 300 F limit was chosen based on an analysis which postulated a recirculation line break and examined the capability of the secondary containment to remain intact with the primary containment breached (drywell head removed) during inservice leak and hydrostatic testing with the reactor coolant temperature at 300*F and RCS pressure at 1150 psia. The results of this analysis indiccted that the secondary containment would remain intact.
(] Therefore, relocating the current temperature limit to the TRM is LJ Page 13 of 22 Revision C JAFNPP
L DISCUSSION OF CHANGES j
, (o) . ITS: 3.5.1 ECCS OPERATING
{
\
TECHNICAL CHANGES LESS RESTRICTIVE (GENERIC) ! i LA9 (continued) acceptable and is not required to remain in the ITS to ensure adequate protection of public health and safety. At ITS implementation, the TRM will be included in the UFSAR by reference. Changes to the relocated requirements in the-TRM will'be controlled by the provisions of 10 CFR 50.59. J TECHNICAL CHANGES - LESS RESTRICTIVE (GENERIC) LB1 The operability of the Core Spray and RHR level switches on the discharge piping keep full level switch instrumentation in CTS 4.5.G.4 is not directly related to the respective system Operability and are proposed to be relocated to the Technical Requirements Manual (TRM). NUREG 1433 does not specify indication only equi > ment to be Operable to support Operability of a system or component. T1e availability of indications, monitoring instruments, and alarms cre normally controlled s by plant operating procedures and policies. These procedures also (s, control compensatory actions (such as system venting) if the
' instrumentation is inoperable. Therefore, this instrumentation, along !
with the supporting Surveillance, are proposed to be relocated to the TRM. These details are not required to be in the ITS to provide adequate protection of public health and safety. At ITS implementation, the relocated requirement will be incorporated by reference into the UFSAR. Changes to the relocated requirements in the TRM will be controlled by the provisions of 10 CFR 50.59. LB2 CTS 4.5.A.1.e requires daily checks and quarterly tests and calibration of the Core Spray header Delta P Instrumentation. These recuirements are proposed to be relocated to the Technical Requirements Fanual (TRM). This instrumentation provides continuous verification of the integrity
.of' Core Spray piping inside the reactor vessel. NUREG-1433 does not specify alarm only equipment to be Operable to support the Operability of a system or component. The availability of indications, monitoring instruments, and alarms are normally addressed by plant operating procedures and policies. These precedures also control com)ensatory actions if the instrumentation is inoperable. Therefore, t11s instrumentation along with supporting surveillances are proposed to be relocated to the TRM and implemented through plant procedures. These details are not required to be in the ITS to provide adequate protection of public health and safety. At ITS implementation, the relocated
. requirement will .be incorporated by reference into the UFSAR. Changes to' the relocated requirements in the TRM will be controlled by the provisions of 10'CFR 50.59.
JAFNPP Page 14 of 22 Revision C
r DISCUSSION OF CHANGES
.f f- ) , ITS: 3.5.1 - ECCS OPERATING TECHNICAL CHANGES LESS RESTRICTIVE (SPECIFIC)
L1 Existing requirements for actuation testing of CS (CTS 4.5.A.1.a and Table 4.2 2 Note-7). LPCI (CTS 4.5.A.3 and Table 4.2 2 Note 7), HPCI (CTS 4.5.C.1 and Table 4.2 2 Note 7), and ADS (CTS 4.5.D.1.a and Table 4.2 2 Note 7) sti)uiate a simulated automatic actuation test shall be performed. The p1 rase " actual or." in reference to the automatic initiation signal, has been added to.the Surveillance Requirements for verifying that each ECCS subsystem actuates.on an automatic initiation signal. This allows satisfactory automatic system initiations to be used to fulfill the Surveillance Requirements. 0)erability is adequately demonstrated in either case since the ECCS subsystem itself can-not discriminate between " actual" or " simulated" signals. L2 CTS 4.5.A.2 requires the immediate verification that the remaining Core Spray (CS) subsystem and both low pressure coolant injection (LPCI) subsystems are Operable whenever it is determined that one CS subsystem
.is determined to be inoperable. It also requires the verification that the remaining CS subsystem is Operable daily thereafter. CTS 4.5.A.3.a requires the immediate and daily verification that the remaining LPCI subsystem and both CS subsystems are Operable whenever it is determined
.U(l
' that one LPCI subsystem is determined to be inoperable. It also requires the verification that the remaining CS subsystem is Operable daily thereafter. CTS 4.5.C.1.a requires that RCIC, both LPCI subsystems, both CS subsystems, and the ADS System actuation logic be verified to be Operable immediately when it is determined that HPCI is determined to be inoperable. It also requires that the RCIC and ADS Systems logic be
- verified to be Operable daily thereafter. When it is determined that two ADS valves are inoperable, CTS 4.5.D.2.a requires the ADS System actuation logic-for the operable ADS. valves and the HPCI System be verified to be Operable immediately and at least weekly thereaftem Finally, CTS 4.5.D.2.b requires that when it is determined that more than two relief / safety valves of the ADS are inoyerable, the HPCI System shall be verified to be Operable immediately. T1ese explicit verifications have all been deleted except for the verification that RCIC is. Operable when.HPCI is determined to be inoperable but this
. verification has been extended from immediately to within one hour. ITS
'3.5.1 Required Action D.1 requires verification by administrative means that the RCIC System is Operable within 1 hour. These verifications are an implicit part of using Technical Specifications and determining the appropriate Conditions to enter and Actions to take in the event of
' inoperability of Technical Specification equipment. In addition, plant and equipment status is continuously monitored by control room
- personnel. The results of this monitoring process are documented in l records / logs maintained by control room personnel. The continuous i monitoring process includes re evaluating the status of compliance with jp Technical Specification requirements when Technical Specification JAFNPP. Page 15 of 22 Revision C
W \ 3 DISCUSSION OF: CHANGES
-ITS: 3.5.1 ECCS -0PERATING p
TECHNICAL CHANGES J LESS RESTRICTIVE- (SPECIFIC) L2;-(continued); r-L equipment becomes; inoperable using the. control room records / logs as aids.:- Therefore, the explicit requirements to periodically verify the
~
Operability of other systems, subsystems, or components when an ECCS l . component, subsystem, or system.is inoperable-are considered to be. E ; unnecessary for ensuring compliance with the-applicable Technical
- l. : Specification actions.- The RCIC verification has been retained in ITS I
33;5.1'as Required Action D.1 due to the similar high pressure functions
~o f the RCIC subsystem with HPCI and as required by CTS 3.5.C.1.a (RCIC System must -be Operable whenever HPCI is inoperable). Since the 10 mrability requirements of RCIC are included in ITS 3.5.3, this cross cleck between Swcifications is necessary. On the otherhand, the cross checks between ECCS Systems are not'necessary since all ECCS requirements' are included in one Specification (ITS 3.5.1) as described in A3. The Frequency of one hour provides sufficient time to perform
.this administrative check by examining logs or other information to l
determine if RCIC is.out of service for maintenance or other reasons. D L3 The p'ressure at which ADS is required to be Operable in CTS.3.5.D.1.a is C . proposed to'be increased from >100 psig to > 150 psig (ITS 3.5.1 Applicability) to provide consistency with the Operability requirements l
=
for HPCI. The ADS is required to operate to lower the pressure . !
'sufficiently so that the LPCI and CS Systems.can provide makeup to
' mitigate smail: break- LOCA. accidents when HPCI does not actuate. The Core Spray and LPCI systems can begin to inject water into the reactor L pressure vessel at pressures well above 150 psig. The values used in U the JAFNPP plant specific LOCA analysis (NEDC 31317P, " James A.
FitzPatrick Nuclear Power Plant SAFER /GESTR LOCA Loss of Coolant
- Accident Analysis) areL196 psig for LPCI and-265 psig for CS. ;
Therefore,.there is no safety significance in ADS not being Operable i
- between 100 and 150 psig. Along with this change the default action of i CTS 3.5.D.2:to reduce pressure to less than 100 psig has been changed to L reduce reactor steam dome pressure to 's 150 psig consistent with the l
proposed Applicability. These changes are consistent with NUREG 1433,
- Revision 1.
L L4; . CTS,3.5.A.6 requires.that tne reactor be-in the cold condition within
- :24 hours when the ACTIONS for LPCI or CS cannot be satisfied, CTS L 3.5.C.1.b requires that' the reactor be in the cold condition and reactor L . pressure befreduced to less than 150 psig within 24 hours when the L ACTIONS for HPCI cannot be satisfied, and 3.5.D.2 requires that the reactor be placed in'the cold condition and that reactor pressure be reduced to:less than 100 psig (see L2) within 24. hours when the Required n : Actions for~ inoperable ADS' valves cannot be satisfied. In addition,
.. U JAFNPPL Page 16 of 22 Revision C L
l )p l g DISCUSSION OF CHANGES ITS: 3.5.1 ECCS OPERATING
. TECHNICAL CHANGES - LESS RESTRICTIVE (SPECIFIC)
L4 (continuad) CTS 3 9.F.3 requires that the reactor shall be brought to cold condition withi124 hours when both LPCI independent power supplies are made or found to be inoperable. _ This specific default action has been interpreted'to also require entry when the ACTIONS or Completions Times associated with CTS 3.9.F.2 is not met since no other exists. The proposed requirements. LC0 3.5.1, Recuired Actions C.2 and I.2, extend the time allowed for the plant to recuce pressure or be in MODE 4 or to be at s 150 psig respectively, from 24 hours to 36 hours. This change is acceptable sine the compensatory action addef in accordance with M4 and this extended time to reach MODE 4 (or s 150 psig in the case of Recuired Action I.2) will ensure a more continuous reduction in power I anc reactor coolant temperature the specified maximum cooldown rate and within the capabilities of the plant. The additional time to complete these ACTIONS reduces the potential for a plant event that could challenge ' plant safety systems. L5 CTS 3.5.C.1.a allows continued o)eration for a. maximum of 7 days after O v HPCI is determined to be inoperaale. ITS 3.5.1 ACTION D allows continued operation for a maximum of 14 days under the same conditions. As in the existing Specification, the 14. day Completion Time for restoring HPCI is contingent upon the 0)erability of RCIC and all of the ECCS subsystems (ADS, LPCI, and CS). T1e exception, ITS 3.5.1 ACTION E, which all.ows operation for 72 hours with HPCI and one low pressure ECCS subsystem ino>erable or one LPCI pump inoperable in each subsystem is addressed in _6. The 14 day Completion Time is consistent with a reliability study that evaluated the impact on ECCS availability (Memorandum from R.L. Baer (NRC) to V. Stello, JR. (NRC), " Recommended Interim Revisions to LCOs for ECCS Components," December 1, 1975). 4 Factors contributing to the acceptability of allowing continued operation for 14 days with HPCI inoperable include: the similar functions of HPCI and RCIC, and that the RCIC is capable of performing i
~ the HPCI function, although at a substantially lower capacity: the !
l continued availability of the required complement of ADS valves and the l ADS system's capability in response to a small break LOCA: and, the continued availability of the full complement of low pressure ECCS '
-subsystems which, in conjunction with ADS, are capable of responding to l a small break LOCA. >
l l' L6 ITS 3.5.1 ACTION E establishes Required Actions and Completion Times for the situation when the HPCI System and me low pressure ECCS (CS or LPCI) subsystem or one LPCI pump in each subsystem are inoperable. The proposed Specification is less restrictive than CTS 3.5.C. which allows continued operation if HPCI is inoperable only if the ADS subsystem, the , JAFNPP Page 17 of 22 Revision C j L
y ( 7- -DISCUSSION OF CHANGES A :ITS: 3.5.1 -ECCS. OPERATING l L iTECHNICAL CHANGES LESS RESTRICTIVE (SPECIFIC) , L6 (continued) L l' RCIC System, both LPCI subsystems and both core. spray subsystems are I l L 0perable. The-accident analysis presented in NEDC-31317P, " James A. L FitzPatrick' Nuclear Power Plant SAFER /GESTR LOCA Loss of Coolant . L Accident Analysis", March 1997,. indicates that the plant is protected by j the ADS System and the remaining ECCS subsystems when the HPCI' System ; and a low pressure ECCS subsystem (or one LPCI pump in each subsystem) ' are ino)erable. ' However, with both the HPCI System and a low i
... ECCS=su) system inoperable (or one LPCI pump in each subsystem) pressure
, another.
L single failure may place the plant in a condition where adequate core L cooling may not be available during an accident. Therefore, an l allowable outage time of 72 hours has been assigned to either restore l the inoperable HPCI' System or the low pressure ECCS subsystem (s). This Completion Time is consistent'with the recommendations of a reliability study;(Hemorandum from R.L. Baer-(NRC) to V. Stello, Jr. (NRC), :
" Recommended Interim Revisions to LCOs for ECCS Components," December 1. l
.1975) and has been found to be acceptable through operating experience.
. Furthermore, the change is considered acceptable since not requiring an l immediate plant shutdown reduces the-potential for an unnecessary
. shutdown transient.
L7- - The flow rates.specified in CTS 4.5.A.3 (8.910 gpm) for the Low Pressure ; , . Injection System.(LPCI) and CTS 4.5.C.1 (4250 gpm) for the High Pressure L , Injection System-(HPCI) have been decreased to 7700 gpm and 3400 gpm,- L respectively. These proposed values are consistent with the values used in the plant -specific LOCA analysis reflected in NEDC 31317P Revision 3, ' March 1997 (James A. FitzPatrick Nuclear Power-Plant SAFER /GESTR LOCA Loss'of Coolant . Accident Analysis)' The SAFER /GESTR LOCA analysis for l. FitzPatrick was performed with NRC requirements and demonstrates conformance with the ECCS acceptance criteria of 10 CFR 50.46 and 10 CFR 50, Appendix.K. A' sufficient number of plant specific break isizes were evaluated to establish the behavior of both the nominal and E Appendix K peak cladding temperature (PCT) as a function of break size. l Different single failures were also. investigated in order to clearly identify the; worst' cases. The FitzPatrick specific analysis was performed with a conservatively high Peak Linear Heat Generation Rate i :and:a conservatively low Minimum Critical Power' Ratio (MCPR). The u Licensing' Basis' PCT for JAFNPP is 1620 F, which is well below the PCT limit'of 2200 F. The Upper Bound PCT. limit is 1600 F. The calculated Upper Bound PCT for the analysis is 1310'F. With the explicit Lverification that the-Licensing Basis PCT for JAFNPP is greater than the Upper Bound-(95th percentile) PCT, the level of safety and conservatism of this, analysis meets the NRC approved criteria. Therefore, the
-requirements of Appendix K are satisfied with the proposed flow rates LJAFNPP- Page 18 of 22- Revision C
P - DISCUSSION OF CHANGES. ITS:'3.5.1 ECCS - OPERATING TECHNICAL' CHANGES L'SS E RESTRICTIVE' (SPECIFIC) , 1 L7: ;(cont'inueb) , l
- p and the change'is considered acceptable. . In addition, the IST Program i
i n
- requires'.the trending of ECCS pump pressure, flow rate, and vibration.
1Whenever -the parameters fall..within the 'IST Alert Range the test L frequency is required to be doubled until the cause 'of the deviation is l' . determined and the condition corrected. If a parameter falls within the IST required.' action range, the associated pump (s) must be declared inoperable and the appropriate Condition (s) of ITS 3.5.1 must be. entered. Since'the requirements of the IST Program will continue to monitor the' status of ECCS pumps and 3rovide corrective actions at a more. conservative action level than-tie ITS values, the reduction in the
. CTS flow rates have little or no impact on plant operations.
L8- ITS 3.5'.1 Condition A (second part) has been added to allow continued operation, for 7l days with one _ low pressure coolant injection pump inoperable in each subsystem and ITS 3.5.1 ACTION B has been added to allow continued operation for 72 hours in the event one LPCI pump in one l 4or both subsystems and one CS' subsystem are inoperable. CTS 3.5.A.2 and l L CTS 3;5.A.3.a-require the plant to shutdown under the same conditions in' ' ! 'accedance with the CTS 3.0.C implying that the plant is outside design basis. The plant analysis summarized in NEDC 31317P Revision 3, March 1- :1997 (James A. FitzPatrick Nuclear Power Plant SAFER /GESTR LOCA Loss of
~j - Coolant Accident Analysis), shows that adequate core. cooling is provided
'in these conditions even if the break occurs on a pipe connected to one
- of the 69ERABLE.ECCS pumps (recirculation discharge pipe or Core ~ Spray
>ipe). . The Licensing Basis PCT for JAFNPP is 1620*F, which is well
)elow the PCT. limit of 2200'F. The Upper Bound PCT limit is 1600*F.
o The calculated Upper Bound PCT for .the analysis is 1510*F. With the L -explicit verification that the Licensing Basis PCT.for JAFNPP is greater than the Upper Bound (95th percentile) PCT, the level of safety and conservatism ~ of this analysis meets the NRC approved criteria. Therefore, the requirements'of Ap>endix K are satisfied in this
' configuration. However, in the a>ove described conditions, the redundancy is reduced such that an additional single active component failure may not maintain the ability to provide adequate core cooling.
~
The 7 day and 72 hour Completion Times are consistent with the j
- recommendations of a reliability study (Memorandum from R L. Baer (NRC) t to V. Stello, Jr. (NRC), " Recommended Interim Revisions to LCOs for ECCS Components," December 1,1975) and have been found to be acceptable through operating experience. 'Furthermore, this change is considered ;
acceptable 'since not requiring an immediate plant shutdown reduces the i potential for an unnecessary shutdown transient. eJAFNPPL . Page 19 of 22 Revision C j I
- _J
n DISCUSSION OF CHANGES i ) ITS: 3.5.1 ECCS - OPERATING TECHNICAL-_ CHANGES - LESS RESTRICTIVE (SPECIFIC) L9 The details in CTS 3.9.F.1 related to the specific inverter buses (MCC-155 and MCC-165) required to be in service are proposed to be deleted. l l These details are not necessary to ensure the L)CI inverter and buses remain Operable. The proposed definition of OPEPABLE OPERABILITY specifies that a system is considered OPERABLE when it is capable of
- performing its specified safety function (s) and when all necessary attendant equipment are capable of performing their related support function (s). The inverter buses support the OPERABILITY of the LPCI System valves, which must automatically align upon receiving an automatic actuation signal-so that the LPCI pumas can inject water into !
the vessel. Thus, the inverter buses support t1e OPERABILITY of the LPCI subsystem valves which in turn support the OPERABILITY of the LPCI System. Therefore, implicitly by the definition of OPERABILITY and the requirement that ECCS injection subsystem must be OPERABLE is sufficient to ensure this equ.ipment is maintained Operable. In addition, the requirement of ITS SR 3.5.1.5 (M7) to verify each LPCI motor operated valve independent power supply inverter out)ut voltage is 2 584 and; 616 V while supplying the respective bus (wlich describes the required n equipment) helps to ensure the required equipment is maintained Operable. The Bases also provides a ' description of the type of t V) equipment required by the Specification. L10 CTS 3.9.F.2.c requires, if one independent power supaly becomes inoperable, the inoperable independent power supply 3e isolated from its associated LPCI. MOV bus, and this bus be manually switched to its alternate power source. If this cannot be met CTS 3.0.C must be entered and the )lant must be in COLD SHUTDOWN within 24 hours. This change deletes t11s requirement since CTS 3.5.A.2 allows a 7 day ! Completion Time for any other LPCI subsystem inoperability with no other compensatory actions. The CTS action is sometimes impractical since the most important action is to repair the inoperable LPCI MOV Independent
-Power Supply, perform the required tests to ensure OPERABILITY and place it into service once again. This change will allow operations to concentrate on restoration of the equipment rather than to simply switch the bus to its alternate power source. In addition, since the LPCI M0V Independent Power Supply System is an attribute of maintaining LPCI Operable'.. a 7 day allowed outage time is provided for these conditions ,
consistent with the existing time allowed for other conditions when a ! LPCI subsysten is inoperable and with the allowance in CTS 3.9.F.2 for J one LPCI HOV Independent Power Supply. This change will provide consistency in ITS ACTIONS for the various LPCI System degradation. , With a LPCI subsystem inoperable, the risk associated with continued operation for a short period of time could be less than that associated with a plant shutdown. This change is acceptable since the accident I
.b JAFNPP Page 20 of 22 Revision C t i
p - DISCUSSION OF CHANGES Q . ITS: 3.5.1 ECCS OPERATING TECHNICAL CHANGES LESS' RESTRICTIVE -(SPECIFIC)
.L10 (continued) analysis' can-be satisfied with the remaining LPCI independent power supply. system.
L11. CTS 3.9.F.2.b' requires the performance of additional Surveillances on .l the OPERABLE LPCI H0V Independent Power Su) ply. System if one LPCI M0V - 1 Independent Power Sup ly System is inoperaale. The proposed change deletes the additiona recuirements. This change will allow credit to be taken for normal periocic' Surveillances as a. verification of l OPERABILITY and availability of the remaining'LPCI H0V Independent Power I Supply subsystem components. The LPCI MOV Independent Power Supply i
. System is a very reliable system, therefore this' CTS requirement would j rarely be required to be 3erformed. In addition, the Frequencies i specified to verify 0PERA3ILITY of the remaining LPCI com>onents are !
adequate to ensure equipment OPERABILITY. As stated in NRC Generic l Letter 87 09, "It is overly conservative' to assume that systems or components are inoperable when a' surveillance requirement has not been performed. The opposite is in fact the case: the vast majority of surveillances demonstrate the systems or components in fact are
-0perable." Therefore reliance on the specified surveillance intervals does not result in a reduced level of confidence concerning the equipment' availability. Also, the ITS'and current BWR operating
-philosophy' accept the philosophy of system OPERABILITY based on j
, satisfactory performance of monthly, quarterly, refueling interval, ' post maintenance or other specified performance tests without requiring additional, testing when another system is inoperable (except for diesel generator testing, which_is not being changed). ;
~
L12 A Note has been added to CTS 4.5.A.3 (ITS SR 3'.5.1.2 Note) that allows the;LPCI subsystems to be' considered OPERABLE during alignment and operation in decay heat removal below the RHR cut in permissive in MODE 3,' if capable.of being manually realigned and not otherwise inoperable. In: MODE 3 all control rods are inserted, and with the reactor steam dome pressure less than the RHR cut in >ermissive pressure, a reduced complement of low pressure ECCS su) systems should provide the required ' cooling;.thereby allowing operation of RHR shutdown cooling, when necessary. 'This allowance will avoid an unnecessary entry into the iACTIONS.of proposed ITS 3.5.1 which in turn may require the initiation of a plant shutdown which is the objective of aligning a LPCI subsystem in the decay heat removal mode. Removing decay heat will in turn place ': the plant outside the Applicability of the Specification where even fewer ECCS Systems are required to be Operable. - This change is acceptable since it avoids an unnecessary entry into ITS 3.5.1 ACTIONS and llows operators to concentrate on the controlled shutdown and place JAFNPP Page 21 of'22 Revision C p L j
i j DI'SCUSSION OF CHL6ES. [ ITS: 3.5.1 ECCS OPERATING' TECHNICAL CHANGES'- LESS RESTRICTIVE (SPECIFIC) L12: (continued) the; reactor lin' a safe condition outside the ' Applicability of ITS 3.5.1. This change is consistent.with NUREG-1433,. Revision 1. L13, LThe explicit requirement ~.in CTS _4.5.D.1 to open "all" Automatic Depressurization System (ADS) pilot valves during the performance of the
. simulated automatic actuation test has been modified. ITS SR 3,5.1.11 requires the verification that ADS actuates on an actual (L1) or simulated automatic initiation signal. This change is less restrictive
'since this test will only require the pilot valves (solenoids) associated with six (6) Operable ADS valves to be tested during the performance of the Surveillance. This change is acceptable since only
" required" equipment must be OPERABLE to satisfy the conditions of the LCO. ITS 3.5.1 LC0 will require 6 ADS valves (M3) to be Operable since~-
.only five (5) ADS valves are needed to meet the safety analysis. This ensures the single criteria can be met. When the Surveillance is
. performed'.if 6 pilot ~ valves own, the Surveillance and LC0 are met.
This change.is consistent wit 1 the philosophy in NUREG 1433, Revision _1.
.L14 CTS 3.5.C.1.b requires pressure to be reduced to less than 150 psig.
ITS 3.5.1 Required Action I.2 requires reactor steam dome pressure to be reduced to 5 150 psig. This change is slightly less restrictive since a reduction in reactor. steam dome pressure to only 150 psig will be
; considered as satisfying the requirement, whereas in the CTS reactor.
l steam dome pressure must-be reduced to < 150 psig. This change is acceptable since it places the plant outside of the current and proposed licability of the HPCI System in CTS 3.5.C.1 (ITS 3.5.1 licability). This change.is consistent with NUREG 1433. Revision 1. TECHNICAL CHANGES RELOCATIONS None o l i. 1 sp}.
,\
.JAFNPP Page 22 of 22 Revision C
]
A ,
2 y I i v 3 - t A ' O 8 3, (J r. - s e n r _ a e . w eb to i he s l p - og cE Gp ne a r. n y sy ai r r o nt c 5s eh e a a gl e M D D e f p ai sd et o s v f e aa rvs dih ut e s v 4 2 g 3 1 2 9 l el vr f m eas o u e. c r r r ee o C e s a mw eh r ahg od ui e nt n a o p g o p p o l t r a ew l n - 3, w ost , a s e e e t ah o S ed eie c c _ fi nw s e c wg i s { r eyme n n n e. plpit m o c a I r j5 g i C F O O O i v 3 C I ep r f s 4
) wh oa 4 e
hue oe ) d y R shr o n e 7 l ato f M s t e )s r y e
't r ea t e gheemt e t ep a c vr ad d nt e t l e one
. p s
e s gt e ob n n e d t u R s e a v ophh tl eb aut t e h tr u t q n i o_ te e hec eq i sr bmt( 6- hrht e ses inn. dit p C ce d t e u n tsetcvehs oEedne n aw) e o p , si o eil tb se s a ar a t -
- e u t
? (t wdeit es ,is e r rbu p e t t m aelue e t okino cs h pmf cwop 9- e e dn a l p - l mrtdwm e oe Auutoeo l e
or i OO i t ai s i(leh t t C o aihdt i ml et t s
*- I s t s r ce e yutnuethsc ot oe r r e mh oc yd s n f v ? e r Seismh i g mtces i reaotsny opr s r n o l
e t i uh 7 { o C Cimio r I Croesr d vetf n srt t e e or e e {n [ SAT V (m wsioic %o Aw V\ o Rpst pf
) a b
- d t
c y .
'r a e r M _
n . 7 3, 3 o R b p P E 5 -
- 3. i s I.I P
[ 7["# i.rte g
. 3 1 0
9 5 2 K 2 F A 4 E
. g" AN o L FgL h
R 1 J l 5 " 5 -)s r O r o e k i u a d ht rpdQ e de
- et e I -
r c e a he tbw l
% di i
wdn he o r v h t r c no er eo t r p i v o r ps 3 ed hn t a t o a o r pF . ga n t* l s ho t frdo" r piFe s s t nt _ r i 4 t e ,* c t uc 6 e pee 2 e. 2 e
- iem ne poe da 0 ol v 1 1 v n ef :- lr e m* bo r
e ar c r o-r as t 46 e r orb a 2 e ;n t cpeas l d n - ey b t t eneJ ee= od b "- e cd S e v s s aF e g' due eS sI di n a o 2.is e o: eae t5 wet l'
) anh teC l oth ri n E. e t de es r r e R 1 4
C vi2e r p1 met rP ne eH p ci dnth 5. ur nb hn 2 I C o 2 son oeh e w a i3t a a;ti . R t0 icn E. hg g w ie nr ;ne I c5n a1 a m ,d u et M t i ir a
?
e on da 5. np j o nd p ? n e r h e sttedm t t ? n e 3i se nt ssl t o . h eer yab m f d0 eei set nro c a hhe t t e Seir s Yo e5 c1 t mc d el
?
tn ipiH) sepepa s se r ot ? C r e o C yie n / n t e s n t sp I n ne s s el _5 M. es Cane a R e ef i i ye s o s e rpety i s mb I hba oc t e
?
i t s yie eo el s pE s o ? i S sr hf s s rlo s r et ro srd s uhQoe n t o i egn ehnt a ? e iu ? t e Cs es t tdnhie at ot r ud gsi e wsec ogna C y rcMde I h S 9. r C r r hsi ue t rt l r orru pnipr oe C Rgo F d q 4 C a H rs s m epr eassde et ae r et s n nt
- i v
i r iem nopnhp el hcs t ee wimt a eic hu a r 0 o L o r r e n f I tor oarctoh e0 r N dd t e c pt biout o p Lt TdrC 3 p t n t a o n o R e
@ T 4 d
n s f M~ n e 5 3
@g )y " 8 A
m
} f
]A O 3 pJ f.
7 l I l 1'
^
N or W I f L I o e C i TC "' {L b^i [ A '[
^
DISCUSSION OF CHANGES ITS: 3.5.3 RCIC SYSTEM i ADMINISTRATIVE CHANGES j Al In the conversion of the James A. FitzPatrick Nuclear Power Plant I
.(JAFNPP). Current Technical Specification (CTS) to the proposed plant j specific Improved Technical Specifications (ITS) certain wording )
. preferences or conventions are adopted which do not result in technical (
changes. Editorial changes, reformatting, and revised numbering are i' adopted.to make the ITS consistent with the conventions in NUREG 1433,
" Standard-Technical Specifications, General Electric Plants. BWR/4,"
Revision 1 (i.e., Improved Standard Technical Specifications (ISTS)). A2 CTS 3.5.G.1 requires the RCIC pump to be considered inoperable when the associated pump discharge piping cannot be maintained in a filled l condition. This will require entry into CTS 3.5.E where 7 days (L1) is I allowed to restore the RCIC System to Operable status. In the ITS, the requirement that the RCIC discharge piping must be filled is reflected in SR'3.5.3.1. Therefore, since this SR is directly related to the operability requi.ements of the RCIC System, this cross reference can be deleted and this-change considered administrative. This change is consistent with NUREG 1433, Revision 1. O O' A3. CTS 4.5.E.1.a (ITS SR 3.5.3.7) is modified by Note 2 that excludes vessel injection / spray during the Surveillance. Tha Bases indicates that this test must include actuation of all automatic valves to their i requird aositions. Since all active components are testable and full i flow can )e demonstrated by recirculation through the test line, coolant injection into the RPV is not required during the Surveillance. This
. Note, therefore, is explicit recognition that ITS SR 3.5.3.7 can be satisfied by a series of overlapping tests. Since surveillance testing of RCIC (CTS 4.5.E.1.a) does not presently require actual injection, and '
is currently satisfied by a series of overlapping tests, the addition of
.the Note excluding vessel injection / spray is an administrative change.
A4 CTS 3.5.E.4 does not recuire the RCIC System be operable during
- hydrostatic pressure anc leakage testing with the reactor coolant temperature > 212 F. This exception is indirectly incorporated into ITS
.3.10.1 (Inservice Leak and Hydrostatic Testing Operation) which allows the plant to be considered in MODE 4 with the average reactor coolant temperature > 212 F. The CTS 3.5.E.4 exception allows the RCIC System l' to not be Operable (as required in the Applicability of ITS 3.5.3) while performing inservice leak or hydrostatic test with the average reactor coolant temperature > 2127. Since LC0 3.5.3 is not listed as one of the required MODE.3 LCOs to be met in ITS 3.10.1 and the Applicability of LC0 3.5.3 does not include MODE 4 RCIC is not required to be .
Operable. Therefore, since the allowance is indirectly incorporated into ITS 3.10.1 this change is considered to be an administrative
?
JAFNPP Page 1 of 7 Revision C I
h
,q DISCUSSION OF CHANGES Q ITS: 3.5.3 RCIC SYSTEM ADMINISTRATIVE CHANGES A4 (continued) presentation preference. This change is consistent with NUREG 1433,
' Revision 1.
A5 CTS 3.5.E.3 does not require the Reactor Core Isolation Cooling (RCIC) System to be Operable during low power physics testing and during
. reactor operator training provided the reactor coolant temperature is s 212 F. This explicit requirement is not retained in the ITS. CTS 3.5.E.1 does not require the RCIC System to be Operable when the reactor coolant temperature is s 212*F. Therefore, since there are no Operability requirements for the RCIC System during the conditions of CTS 3.5.E.3, the allowances provided are meaningless and therefore this deletion is considered administrative. This change is consistent with NUREG 1433, Revision 1. l TECHNICAL CHANGES MORE RESTRICTIVE O.
O M1 CTS 3.5.E.2 requires the reactor to be placed in the cold condition and pressure less than 150 psig within 24 hours when CTS 3.5.E cannot be , met. This requirement is proposed to be replaced by ITS 3.5.3 Required I Actions B.1 and B.2 which recuire the plant be in MODE 3 within 12 hours and to reduce reactor steam come pressure to s 150 psig within 36 hours (see L2) under the same condition. Based on operating experience this Com)letion Time limit still allows for an orderly transition to MODE 3 wit 1out challenging plant systems. This change is more restrictive because it provides an additional requirement to place the plant in MODE 3 in 12 hours prior to requiring reactor steam dome pressure to be 1 5 150 psig. I M2 CTS 4.5.E.1 requirement, to permit up to 10 days of continuous operation i from the time steam becomes available until RCIC Surveillances need to be performed. is being changed. The Note to ITS SR 3.5.3.5 and SR 3.5.3.6 and Note 1 of SR 3.5.3.7 allow only 12 hours from the time reactor steam pressure and flow are adequate to perform the test. The 12 hours allows sufficient time to achieve stable conditions for testing and provides a reasonable time to comalete the SR without impacting
. plant operation. Reducing the allowaale time to perform the test, from 10 days to 12 hours, imposes additional operational limitations. This change will require that the actual surveillances be 3erformed sooner in the plant startup, and thereby demonstrate RCIC 03eraaility sooner than current requirements dictate. Therefore, this clange is considered more restrictive but necessary to ensure Operability within a reasonable p time period when the equipment is required to be Operable.
~JAFNPP Page 2 of 7 Revision C 1
E l I
< l l
DISCUSSION OF CHANGES g ITS: 3.5.3 RCIC SYSTEM TECHNICAL CHANGES ~MORE RESTRICTIVE
. M3 The CTS 4.5.E.1.d'recuirement, that RCIC deliver at least 400 gpm againstla system heac corresponding to a reactor vessel pressure of l- l1,195 psig,to 150 psig,.is being divided _into two separate Surveillance L . Requirements SR 3.5.3.5 and SR 3.5.3.6. ITS SR 3.5.3.5, will require L demonstration 'of the RCIC aump capability at the high reactor vessel
- ' pressure each 92 days, wit 1 reactor pressure 2 970 psig and_s 1040 psig.
ITS SR 3.5.3.6 will require demonstration of the RCIC pump capability at the low reactor' vessel' pressure every 24 months with reactor pressure s 165 psig. .This change will: ensure the RCIC System is-tested at both the. high and low pressures ~ at the proposed Frequencies and is therefore L considered more. restrictive on plant operation but necessary to ensure ! . RCIC remains Operable over its full operating range. M4 -CTS 4.5.G.3 requires the RCIC System discharge piping to be vented from the high point of.the system whenever RCIC is lined up to take suction i from the condensate storage tank-(CST). In ITS SR 3.5.3.1, this i requirement must be met whenever RCIC is required to be Operable, not '
- just when RCIC is lined up to take suction from the CST. This change is considered more restrictive on plant operation but necessary to' help !
l(7 prevent a water.. hammer following an -initiation signal . l %.) l~ MS- . CTS 4.5.E.1.e and CTS 4.5.E.1.c require the RCIC testable check valves and the motor. operated valves, respectively, to be tested for Operability. :ITS 3.5.1 is more explicit .on the actually testing requirements. ITS SR 3.5.3.3 will.. require the RCIC System injection testable check valve to be cycled fully closed and fully opened. ITS SR L :3.5.3.4 will require the RCIC System motor operated valves to be cycled i lfully closed and fully opened. These proposed testing requirements are l
-more_ explicit-than the current requirements and therefore considered '
more restrictive. - CTS 4.5.E.1.e states- there is more than one testable check valve.- This-in fact is not the case, therefore this portion of
- the change is considered administrative. These requirements will continue to help ensure the RCIC operates as designed for those events
.where the normalLfeedwater system is not available.
L .M6 CTS:4;5.E.1.C. requires that the RCIC testable check valves be tested for ! -- Operability following any period of reactor cold shutdown exceeding 48 ; hours if not performed during the preceding.92 days. This requirement zis proposed to be replaced by_SR 3.5.3.3 which requires the test to be performed'once each startup prior to exceeding > 25% RTP. In addition, a Note has been added consistent with the current requirement that the test is not required.to be performed if performed within the previous 92 days. The RCIC. injection . testable check valve (see M5) is not required
- while the plant is shutdown. The requirement to perform the
< verification once each.startup prior.to exceeding 25% RTP is more fJAFNPP! Page 3-of 7 Revision C l
i ,
'!a
l
^ DISCUSSION OF CHANGES
~
) ITS: 3.5.3 RCIC SYSTEM TECHNICAL CHANGES MORE RESTRICTIVE M6 (continued) restrictive than the existing requirement to perform the test since the
. test will now be required to be performed'during any startup not just a startup from a Cold Shutdown that exceeded 48 hours (if not performed ;
within the previous 92 days). This change is necessary to ensure the l Operability of the RCIC injection testable check valve is adequately maintained. TECHNICAL CHANGES LESS RESTRICTIVE (GENERIC) LA1 The details of CTS 4.5.E.1.a footnote
- that states " automatic restart on a low water level signal which is subsequent to a high water level signal", are proposed to be relocated to the Bases. The Bases for SR 3.5.3.7 states in part that "this test also ensures the RCIC System will automatically restart on an RPV low water level (Level 2) signal received subsequent to an RPV high water level (Level 8) trip." The requirement in ITS SR 3.5.3.7 is adequate to ensure the RCIC automatic
- /,_.h actuation capability is verified to ensure Operability. As such, these V details are not requirvi to be in the ITS to provide adequate protection i of the public health and rafety. Changes to the Bases will be !
controlled by the provisions of the proposed Bases Control Program described in Chapter 5 of the Whnical Specifications. , LA2 The details in CTS 4.5.G.3 which describe the method to be employed to assure that the RCIC discharge piping'is full of water (shall be vented from the high point of the system and water flow observed) are proposed
-to be relocated to the Bases. These details are not necessary to ensure the Operability of the RCIC System. The requirements of LC0 3.5.3 (RCIC System) that the RCIC System must be 03erable and the associated Surveillances are adequate to ensure t1e RCIC System remains Operable.
Therefore, the relocated details are not required to be in the ITS to provide adequate protection of-the' public health and safety. Changes to the Bases will be controlled by the provisions of the Bases Control Program described in Chapter 5 of the Technical Specifications. i t LA3 The CTS 3.5.E.4 tem >erature allowance of up to 300 F to perform the inservice leak and lydrostatic testing is proposed to be relocated to l the Technical Requirements Manual (TRM). Inservice leak and hydrostatic l tests are very controlled evolutions involving strict procedural compliance. ' As a result, the maximum temperature limitation is not necessary to be included in the Technical Specifications to ensure this maximum temperature limitation is not exceeded. The minimum 7% temperatures.(at the required pressures) allowed for these tests are b JAFNPP Page 4.of 7 Revision C l l l e a
o DISCUSSION OF CHANGES
'Q ITS: 3.5.3 RCIC SYSTEM i
TECHNICAL CHANGES LESS RESTRICTIVE (GENERIC) { LA3 (continued) ' determined .from the RPV pressure and temperature (P/T) limits specified in ITS 3.4.9, " Reactor. Coolant System (RCS) Pressure and Temperature (P/T) Limits." ITS Figure 3.4.9 1 indicates the minimum temperature required at~the associated pressures. Operations will ensure these limitations are not exceeded. A minimum temperature limit of approximately 200*F is currently required at a reactor pressure of 1040 psig,_therefore adequate margin is available without exceeding the ! current 300'F limit. In addition. the 300 F limit was chosen based on an analysis which postulated a recirculation line break and examined the l capability of the secondary containment to remain intact with the primary containment breached (drywell head removed) during inservice leak and hydrostatic testing with the reactor coolant temperature at 300 F and RCS pressure at 1150 psia. The results of this analysis indicated that the secondary containment would remain intact. Therefore.-relocating the current temperature limit to the TRM is acceptable and is not required to remain in the ITS t-o ensure adequate protection of public health and safety. At ITS implementation the TRM (] v will be -included in the UFSAR by reference. Changes to the relocated requirements in the TRM will be controlled by the provisions of 10 CFR 50.59. t TECHNICAL CHANGES LESS RESTRICTIVE (SPECIFIC) L1 ~_ CTS 3.5.E.1 allows continued operation for a maximum of 7 days after RCIC is determined to be inoperable. ITS 3.5.3 Required Action A.2 allows continued operation for a maximum of 14 days under the same onditions. As in the existing Specification, the 14 day Completion Time for restoring RCIC is contingent upon the Operability of HPCI. The 14 day completion time is based on a reliability study that evaluated the impact on ECCS availability (Memorandum from R.L. Baer (NRC) to V. Stello, JR.-(NRC), " Recommended Interim Revisions to LCOs for ECCS Components," December 1. 1975). The main factor contributing to the acceptability of allowing continued operation for 14 days with RCIC
-inoperable is the similar functions of HPCI and RCIC, and that the HPCI is capable of performing the RCIC function, at a substantially higher
-capacity.
L2 - CTS 3.5.E.2 recuires the reactor be in the cold condition and reactor pressure be recuced to less than 150 psig within 24 hours when CTS 3.5.E cannot be met. ITS 3.5.3 Required Actions B.1 and B.2 requires the plant to be in MODE 3 within 12 hours (M1) and to reduce reactor steam
-A (T -dome pressure to s 150 psig within 36 hours under the same conditions.
J JAFNPP Page 5 of 7 Revision C
]
I (qy DISCUSSION OF CHANGES ITS: 3.5.3 - RCIC SYSTEM i i TECHNICAL CHANGES LESS RESTRICTIVE (SPECIFIC) i l L2 (continued) l This change is less restrictive since the time to reduce pressure has been extend from 24 hours to 36 hours. This change is acceptable since , the compensatory action added in accordance with M1 and this extended I time to be s 150 psig will ensure a more continuous reduction in power j and reactor coolant pressure within the specified maximum cooldown rate j
.and within the capabilities of the plant. The additional time to complete these ACTIONS reduces the potential for a plant event that !
could challenge plant safety systems. I L3 CTS 4.5.E.1.a sti)ulates a simulated automatic actuation test shall be l performed. The parase " actual or," in reference to the automatic i initiation signal, has been added to CTS 4.5.E.1.a (ITS SR 3.5.3.7) for . verifying that each RCIC subsystem actuates on an automatic initiation i signal. This allows satisfactory automatic system initiations to be l used to fulfill the Surveillance Requirements. 0)erability is adequately demonstrated in either case since the RCIC System itself can not discriminate between " actual" or " simulated" signals. L4 CTS 4.5.E.2 recuires the verification that the HPCI System is Operable immediately anc daily thereafter when RCIC is determined to be ; inoperable. These explicit verifications have all been deleted except ' for the verification that HPIC is Operable when RCIC is determined to be ! inoyerable but this verification has been extended from immediately to wit 11n one hour. ITS 3.5.1 Recuired Action A.1 requires verification by administrative means that the FPIC System is Operable within 1 hour. These verifications are an implicit part of using Technical 1 Specifications and determining the appropriate Conditions to enter and-Actions to take in the event of inoperability of Technical Specification equipment. In addition, plant and equi > ment status is continuously monitored by control room personnel. Tie results of this monitoring process are documented in records / logs maintained by control room personnel. The continuous monitoring process includes re evaluating the
. status of compliance with Technical Specification requirements when
~ Technical Specification equipment becomes inoperable using the control
-room records / logs as aids. Therefore, the ex) licit requirement to
' periodically verify the Operability of HPCI w1en RCIC is inoperable is considered to be unnecessary for ensuring compliance with the applicable Technical Specification actions. The hour allowed to verify HPCI Operability provides a period of time to correct the problem commensurate with the importance of maintaining HPCI OPERABLE during I MODES 1, 2 and 3, with reactor steam dome pressure > 150 psig. Also, the initiation of an analyzed event does not assume a completion time to
- q. verify HPCI Operability, and the consequences of an event during the V JAFNPP Page 6 of 7 Revision C l
t
r~ DISCUSSION OF CHANGES
.t -
ITS: 3.5.3 RCIC SYSTEM
-TECHNICAL CHANGES LESS RESTRICTIVE (SPECIFIC)
-L4 -(continued) proposed.1 hour Completion Time are the same as those during the current completion time of "immediately".
L5 CTS 3.5.E.2 requires reactor pressure to be reduced to less than 150 psig. ITS 3.5.3 Required Action B.2 will require reactor pressure be reduced to.s 150 psig. This change is slightly less restrictive since a reduction.in reactor steam dome pressure to only 150 psig will be considered as satisfying the requirement, whereas in the CTS reactor steam dome pressure must be rec'uced to < 150 psig. This change is acceptable since it places the plant outside of the current and proposed A licability of the RCIC System in CTS 3.5.E.1 (ITS 3.5.3 A licability). This change is consistent with NUREG 1433. Revision 1.
' TECHNICAL CHANGES RELOCATIONS
-None 7
'N
)
1 l l l l l l f'y ) (f JAFNPP Page 7 of 7 Revision C 1 i-L 4
VOLUME 15 f ITS 3.7 THRU 3.8.2 CONVERSION PACKAGES This page provided as a place holder and to assist personnel updating the JAFNPP ITS submittal to Revision C. Discard this page along with pages removed in accordance with the
]- . page replacement instructions.
Q
p; I s DISCUSSION OF CHANGES
- J l
ITS: 3.7.2 EP.ERGENCY SERVICE WATER (ESW) SYSTEM AND ULTIMATE HEAT SINK (VHS) ADMINISTRATIVE CHANGES l Al In the conversion of the James A. FitzPatrick Nuclear Power Plant l (JAFNPP) Current Technical Specifications (CTS) to the proposed plant . j specific Improved Technical Specifications (ITS) certain wording ! preferences or conventions are adopted which do not result in technical
- changes. Editorial changes, reformatting, and revised numbering are {
1
- adopted to make the ITS consistent with the conventions in NUREG 1433, i
" Standard Technical Specifications, General Electric Plants BWR/4", !
Revision 1 (i.e., Improved Standard Technical Specifications (ISTS)). l A2 CTS 3.11.D.2 allows 7 days of operation with one Emergency Service Water j System inoperable. A Note is proposed to be added to CTS 3.11.D.2 (ITS
- 3.7.2 Required Action A.1) which would require the applicable Conditions l
and Required Actions of ITS 3.8.1, "AC Sources-0perating," for the Emergency Diesel Generator (EDG) subsystem made inoperable by ESW. This Note is an exception to proposed LC0 3.0.6 which ensures proper ACTIONS l are taken for an inoperable EDG subsystem. This Note is consistent with l i the current requirements in the same CTS requirement which only allows 7 l days of operation if the operable Emergency Diesel Generator System is l G V demonstrated to be operable immediately and daily thereafter. If the other Emergency Diesel Generator System was found to be inoperable CTS 3.11.D.3 must be entered and the plant must be brought to a cold condition. This change is considered administrative since the Note ensures that the appropriate actions of LC0 3.8.1 are taken. Changes to testing requirements in CTS 3.11.D.2 are discussed in L2 and L4. i A3 The ESW instrumentation surveillance requirements specified in CTS 4.11.D.1.e and 4.11.D.1.f have been moved to ITS 3.3.7.3, " Emergency Service Water (ESW) System Instrumentation". Although an instrumentation specification does not currently exist in NUREG 1433, . Revision 1 for the ESW System Instrumentation, the JAFNPP requires the ; proper function of the ESW lockout matrix to ensure safe shutdown loads are automatically supplied during a loss of preferred power. Since the l ESW-instrumentation includes redundant channels, JAFNPP feels that this change is acceptable. Any additional changes to the current requirements concerning ESW System instrumentation is addressed in the Discussion of Changes for ITS 3.3.7.3, therefore this change is considered administrative. A4 The requirements for intake deicing heaters in CTS 3.11.E and 4.11.E have been included with the requirements of Emergency Service Water I (ESW) and the Ultimate Heat Sink (VHS). Since the intake deicing 1 heaters help to ensure adequate flow to the ESW and Residual Heat Removal System this change in format is considered administrative. JAFNPP Page 1 of 9 Revision C
f l 1 p DISCUSSION OF CHANGES ( ITS: 3.7.2 EMERGENCY SERVICE WATER (ESW) SYSTEM AND ULTIMATE HEAT SINK (UHS) l l ADMINISTRATIVE CHANGES l l A7 (continued) i 0)erable in' CTS definition 1.0.-J or in the ITS definition of OPERABLE - 0)ERABILITY in ITS Section 1.0 which require cooling water to be
- available for a system, subsystem, division. component, or device to be
! considered OPERABLE to perform its specified safety function. Since l this Note is only added for clarity, this change is considered administrative. This change is consistent with NUREG 1433, Revision 1. A8 The requirements in CTS 4.11.E.2 to monitor the individual heater 1 current once every 6 months has been changed to require the verification of the required deicing heater power (ITS SR 3.7.2.5). The current is l measured more frequently in CTS 4.11.E.1. This Surveillance ensures that the required deicing heaters are operating as designed ensuring the a)propriate power is produced in each required heater. Since this clange is consistent with current practice, this change is considered administrative.
. (V3 TECHNICAL CHANGES MORE RESTRICTIVE M1 CTS 3.11.D.3 requires the reactor to be placed in a cold condition within 24 hours if the requirements of CTS 3.11.D.2 (one ESW subsystem inoperable) can not be met. CTS 3.11.E.1 requires the same actions when the required deicing heaters are found to be inoperable (see M3 for inclusion of redundant deicing heater divisions). CTS 3.11.D.1 requires both ESW subsystems to be Operable, exce)t as allowed by CTS 3.11.D.2.
CTS 3.11.D.2 addresses the condition wit 1 one inoperable ESW subsystem. Therefore, With two inoperable ESW subsystems entry into CTS 3.0.C is required and the plant must be in COLD SHUTDOWN within 24 hours. In ITS 3.7.2, all default actions for the ESW System and ultimate heat sink (VHS) are covered in ACTION C for clarity consistent with the format of
'NUREG 1433. Revision 1. An additional ACTION has been added to allow time to restore a division of ino>erable deicing heaters to 0)erable status (ACTION B), however this c1ange is addressed in M3. T1e inoperability of two ESW subsystems is addressed in the second part of Condition B. If the Required Action and associated Completion Time of ACTION A (for'one ESW subsystem) or ACTION B (for one division of deicing heaters) is not met entry into the first part of Condition B is required. Finally, if the ultimate heat sink (UHS) is inoperable for reasons other than one division of deicing heaters, entry into the third part to Condition C is required. However this requirement was added in accordance with M2.
A-JAFNPP Page 3 of 9 Revision C
k l c DISCUSSION OF CHANGES l (V ITS: 3.7.2 EMERGENCY SERVICE WATER (ESW) SYSTEM AND ULTIMATE HEAT SINK (VHS) TECHNICAL CHANGES - LESS RESTRICTIVE (SPECIFIC) L3 (continued) ITS 3.7.2. Required Action C.1 will require the plant be placed in MODE 3 within 12 hours. This change reduces the time the reactor would be allowed to continue to operate under the conditions specified above. The consequences of a LOCA are significantly mitigated when the reactor is shutdown and a controlled cooldown is already in progress. This change is consistent with NUREG 1433. Revision 1. L4 CTS 3.11.D.2 requires the o)erable Emergency Diesel Generator System to I be demonstrated to be o)eraale immediately and daily thereafter when it is determined that one Emergency Service Water subsystem is inoperable. The proposed change deletes the explicit requirement to demonstrate the Operability of the Emergency Diesel Generator System (EDG) immediately and daily thereafter. As indicated in A2 a Note has been added which will require immediate entry into LC0 3.8.1 for an EDG subsystem made l inoperable by ESW. ITS 3.8.1 provides a Completion Time of 24 hours for ITS 3.8.1 Required Action B.3.1 to determine the Operable EDG subsystem is not inoperable due to common cause failure or ITS 3.8.1 Required Action B.3.2 will require a performance of SR 3.8.1.2 for the Operable o EDG subsystem. This change provides an additional time to determine Q that the inoperabilities are not due to common cause failure or to demonstrate OPERABLE EDG subsystem availabilit The 24 hour Completion Time, in accordance with Generic Letter 84 15,y.is reasonable time to confirm that the OPERABLE EDG subsystem is not affected by the same problem as the inoperable EDG subsystem based on the low probability of an event during the-additional time period. If the cause of the inoperable EDG subsystem cannot be confirmed not to exist on the OPERABLE EDG subsystem, then performance of ITS SR 3.8.1.2 is required to provide assurance of continued OPERABILITY of the remaining EDG subsystem. The requirement to demonstrate the Operability of the remaining OPERABLE EDG subsystem, thereafter is not necessary since the normal EDG Surveillances in proposed ITS 3.8.1 are sufficient to ensure the remaining EDG subsystem 1s Operable. This change is consistent with l Generic Letter 84 15 and NUREG 1433. Revision 1 and is considered acceptable. L5 The requirement in CTS 4.11.E.2 to monitor individual heater current whenever large deviations are identified in the feeder checks in CTS 4.11.E.1 has been deleted. The requirement in CTS 4.11.E.1 (ITS SR 3.7.2.4) to verify the deicing heater feeder current is within limits (for each division of deicing heaters (M3)) and the requirement in CTS ! 4.11.E.2 (ITS SR 3.7.2.5) to verify the required deicin heater power is within limits (for each division of deicing heaters (M3 ) is sufficient to ensure that the required number of heaters are Opera le. The current requirement in CTS 4.11.E.2 to monitor individual heater current
.(l .
L JAFNPP Page 8 of 9 Revision C i 1 4
\
$$W) Systes and (VHS$
i p 3.7.2 l ACTIONS (continued) CONDITION h REQUIRED ACTION CONPLETION TIME
$ One psubsystes (h ------ NOT ES------
inoper ef re 1. Enter applicable ! an Conditions and Al pp. ! Condi ton [s A Required Actions
}[andCy '
of LCO 3.8.1, 'AC , p Sources- Qwbsys t.e.m] A l ggt Operating,' for [ /c\ diesel generator l f g'g'g} ande inoperable Ly f (4cuit* by @gj} .. 4 l
$1' $ Enter applicab fg Conditions and i utred Actions of 4.8, pg
" Residual # 1 Removal (RHR) i Shutdown Cooling !
System-Hot ! utdown,' for 1 { utdown cooling 4L5/ O, inoperable by 1 Q (PSW]. PSI Restore the subsystem t SW PE LE 14XourV[Ch*4D status. 3 fnni ACTidM S BWR/4 STS 3.7-4 Rev 1. 04/07/95 O Revision C
-- 3 (( INSERT ACTION B i Yb l l l
'8. One division of NOTES - --- -- I required deicing Enter applicable Conditions heaters and Required Actions of inoperable. LC0 3.8.1 for emergency diesel generator subsystem l AND made inoperable by deicing heaters.
UHS temperature - - - - - -
< 37*F.
~
B.1 Restore the division of 7 days ! deicing heaters to ' OPERABLE status. i l
-O insert eeee 3.7 4 ITS Submittal Rev. C ;
Ot1( p $ System and (UHS $ 4 B 3.7.2 BASE 5
- I >
ACTIONS 7"~C,d (cont ved) , S the ti required to reasonably late the Requir Action With one f' subsystem inooerable for
/
Octs gi, ion p . p,onalin ac 1 y)
.n. 1 2 . . v u. dm/ "D able fla + 4
\ Duq r inoperahl . W the B 544 subsystem must 08 l
~
be resto e t_o OPERABLE. status withinpan-m====. With the Y ! in this conettion, tne remaining OPERABLE * ' b *' subsystemais adequate to perfore the heat removal unct n. However, the overall reliability is reduced because a single I pp. S fa11ure in the OPERA 8LE Psubsystemcouldresultinloss _ l of function. g a e. t w ,. w e j - . T Completion Time is based on the redundant ( R.)
-7 SystemcapabilitiesaffordedbytheOPERABLEsubsystem$W) , the low probability of an accident occurring during this time !
period, and is consistent with the allowed Completion Time z for restoring an inoperable g 4 Ws,y by' ra _q Required Actionh.1 is modified byes Note 6 indicating that the applicable Conditions,of LC0 3.8.1, 'AC Sources . De Operating,"lLCD/s.e.u v- .. i t om ,Snutaces) (too mia m 1-- nat tha+ b. . Yi nea be enteree and Recu' red l Qesyste my Act< ons takon if the inoperable $ subsystem results in I an < nooerah' e4G)6 --- . - . .J, 1 7 pp /\ 7 r ensures :- :---(the. This is in accordance with LC0 3.0.6 and /C\ 16 proper actions are taken for the components. , Y a
@b pm M E
.1 = .2
- 05) If the ysubsystemcannotberestoredtoOP status h[ [ /p%
within the associated Completion Time, or both-
; subsystems 4 im on are u,inop(erable or the (LMSt +-is----
r-- --- 1 l'- - - determined inoperable e the d&timust De placed _ p aa4 in a MODE in which the LC0 does not apply. To achieve this status, thejm!5 must be placed in at least MODE 3 within 12 hours and in MODE 4 within 34 hours. The allowed Completion Times are reasonable, based on operating f.M
/ experience, to reach the required p conditions from full (continued) 8 3.7-10 Rev 1, 04/07/95 BWR/4 STS
/' Revision C b
r, 1 g3 Insert ACTION B IL1 With one ' division of' deicing heaters inoperable, the deicing heaters must be restored to OPERABLE. status within 7 days. With the plant in this condition, the remaining OPERABLE division of deicing heaters is adequate to perform the required function. However, the overall reliability is reduced because a single failure in the OPERABLE division of deicing heaters could result in
-loss of ESW and RHRSW function.
The.7 day Completion Time is based on the redundant capabilities afforded by the _0PERABLE division of deicing heaters, the low probability of an accident occurring during-this time period, and is consistent with the allowed Completion Time for restoring an inoperable EDG subsystem. Required Action B.1 is modified by a Note indicating that the applicable Conditions of LCO 3.8.1 be entered and Required Actions taken if the
. inoperable division of deicing heaters results in an inoperable EDG subsystem. l This is in accordance with LCO 3.0.6 and ensures the proper actions are taken for this component. !
l I g - b in ()L Insert Page B 3.7 10 ITS Submittal Rev. C c
7 1 ESW System and UHS 3.7.2 i IO iv 3.7 PLANT SYSTEMS j 3.7.2 Emergency Service Water (ESW) System and Ultimate Heat Sink (VHS) i. LC0 3.7.2 Two ESW subsystems and UHS shall be OPERABLE. APPLICABILITY: MODES 1, 2. and 3. l ACTIONS CONDITION REQUIRED ACTION COMPLETION TIME A. One ESW subsystem -- NOTE - -- inoperable. Enter applicable Conditions and Required Actions of LCO 3.8.1, "AC Sources - Operating," for emergency diesel generator subsystem l made inoperable by ESW. ! (~)
\/ A.1 Restore the ESW 7 days subsystem to OPERABLE status.
B. One division of required deicing NOTES - -- heaters inoperable. Enter applicable Conditions and Required Actions of AND LC0 3.8.1 for emergency diesel generator subsystem l UHS temperature made-inoperable by deicing s 37'F. heaters. B.1 Restore the division of 7 days deicing heaters to OPERABLE status. l l D. M.) JAFNPP 3.7 3 Amendment (ITS Submittal Rev. C)
1 1 ESW System and UHS B 3.7.2
. BASES (continued)
APPLICABILITY In MODES 1, 2 and 3, the ESW System and UHS are required to be OPERABLE to support OPERABILITY of the equipment serviced by the ESW System. Therefore, the ESW System and UHS are required to be OPERABLE in these MODES. ! In MODES 4 and 5, the OPERABILITY requirements of the ESW System and UHS are determined by the systems they support and therefore, the requirements are not the same for all facets of operation in MODES 4 and 5. Thus, LC0 3.8.2, "AC Sources-Shutdown," which requires the ESW System to be OPERABLE, will govern ESW System operation in MODES 4 and 5. ACTIONS M With one ESW subsystem inoperable, the ESW subsystem must be restored to OPERABLE status within 7 days. With the plant in this condition, the remaining OPERABLE ESW subsystem is ! adequate to perform the heat removal function. However, the overall reliability is reduced because a single active component failure in the OPERABLE ESW subsystem could result in loss of ESW function. The 7 day Completion Time is based on the redundant ESW System ca'; abilities afforded by the OPERABLE subsystem, the low proba)ility of an accident occurring during this time . period, and is consistent with the allowed Completion Time I for restoring an inoperable EDG subsystem. ) i Required Action A.1 is modified by a Note indicating that i the applicable Conditions of LC0 3.8.1, "AC Sources-Operating," be entered and Required Actions taken if the inoperable ESW subsystem results in an inoperable EDG ; subsystem. This is in accordance with LC0 3.0.6 and tisures l t the proper actions are taken for this component. l i M With one division of deicing heaters inoperable, the deicing 1 heaters must be restored to OPERABLE status within 7 days. 1 With the plant in this condition the remaining OPERABLE j division of deicing heaters is adequate to perform the ! required function. However, the overall reliability is : A ! V (continued) ! l Revision 0 JAFNPP B 3.7 10 (ITS Submittal Rev. C) !
]
c ,
, ESW Systems and UHS B 3.7.2 n
l BASES , !q
' ACTIONS IL1 (continued) reduced because a single failure 1" the OPERABLE division of I deicing heaters could result in Ns "f FSW and RHRSW function.
The 7 day Completion Time is basea un the redundant capabilities afforded by the OPERABLE division of deicing heaters, the low probability of an accident occurring during , this time period, and is consistent with the allowed l Completion Time for restoring an inoperable EDG subsystem. l Required Action B.1 is modified by a Note indicating that the applicable Conditions of LC0 3.8.1 be entered and Required Actions taken if the inowrable division of deicing heaters results in an inoperable EDG subsystem. This is in l accordance with LC0 3.0.6 and ensures the proper actions are taken for this component. C.1 and C.2
-O C/
If the ESW subsystem cannot be restored to OPERABLE status within the associated Completion Time, or both ESW j 4 subsystems are inoperable, or the UHS is determined inoperable the plant must be placed in a MODE in which the LC0 does not apply. To achieve this status, the plant must j be 31 aced in at least MODE 3 within 12 hours and in MODE 4 3 wit 11n 36 hours. The allowed Completion Times are i reasonable, based on operating experience, to reach the ! recuired plant conditions from full power conditions in an l orcerly manner and without challenging plant systems. SURVEILLANCE SR 3.7.2.1 REQUIREMENTS ! This SR verifies the water level in the screenwell to be i sufficient for the proper operation of the ESW and RHRSW pumps (net positive suction head and pump vortexing are considered in determining this limit). The 24 hour : Frequency is based en operating experience related to j trending of the parameter variations during the applicable ; i MODES. (continued) JAFNPP B 3.7-11 Revis'vi 0 (ITS Submittal Rev. C) 1
4 O ; - n'idI ~o 1i- hk l 5 in i 93 o
- i 1
{' (
- e. 1 s M % t.
- s. t e i ; k 1 5}
3,
$l , A $ qla n }}
z g- M' h. ::a
, t e
u nf 'O $ g s g E
& i $ + : a* [ .1 1,
3 1 i ti o
- y. u
* "g j g', s*il hpjj'2 t
I
! 4 {5 '.B4 g
2 t r Q k , o '
~
i) \\e? f b ie$1 % Yt $,f1 \
~ ( 1.s <
b < u.M 1 \ h s p ;t 13 I 7 2 ik il s si ! 1
\\hf{}\b;M(
, 1
\a w \\\'
jp \ ? %; ( [n
. 11LJ
, 6
>i e t i k
1$ 1
- rb bO S b '
2,3 0 -3 a a 1: . 4 Y,*eEE51 6 tb di6 5 Alo; e g - ie i etib i l
o - /
/
2 . .
/ _
3 f o C n n - o 3 i o . i t s _ a e i v i c g a e _ f i P R c e p
.S k
n . l a _ b - l y - l a _ n _ o _ O i t n . _ t e - i n e g a p i s h T
~
O , i
\
AC/ uU I l g g f'A %G ( 3 _ e, 1 t p d r n e n o e 9,.g,, 4 o ]e h e c ht a t a g i b c g r I = f. , t a . t a ie n e l a n
= t t ns h ln i wlb i n
e g r l oen
. e 8. g ee c wf naj d
c ee ar t r a g n t e ns nea 8 r sz mtr l e np t n a eG bl t i ee hm wde l i
,c s ne t e s t i od t u Rat uo e a e wr ie d o e r r r el sl en l a aos p g 3 qSs t t
) eu da reuq i
e t sa 9- r eb u mniD r on il t e e nre do oh N n ed o nin nh v ne ae ct a Ib 'Y i n f c a r ey et c" ur ops i
. u 0, me ee cn e ha nr ss ir ed afoh n s m
n t oo o.
't t
c;8 t eg syl I ome_ a n i pr oi ceb iy t m b y hn t mg: e c a n iwe m r pf mr e l l 4 de8t. f yh o dlie e s oer e me ou a st 1 "" ts ds t e f r c ebt r t e o t eh ci l g c ci. r n ny ht e.se t a a yo su tysmt in t t a C e SEue a , e45 r oo oS ri l s y s yr ef t am c r a rar t t eaSh l sf o l be n Wc . P: st t r ee nh ht eo he t l e p pv oa ti rs o ba oe r etacb rdd t e m e v t r e or t ad s o 4 i o s m t a e eh ct ge ai r prea l pl u em a et gen nhrh it i r e e. % gg t ac n t v r ai n pas yn. it et e ,ne oef
? Md l n i e ts b
- 3. e w h e a p e nf e r
e v uf s e l os r y e S ?e - ei s ur g t n G ntr d
,s e
t nmo e R 4- ied o m e l oaa o i sr 8. G cll l a i G hn eo r p l edr bo o dmta d d ye 4 ie dl y s mtsl el t o 9. oa c3e sen.eti n idm sf ei e d e ams ne corne r
- ck i c a idi n eno r pl e ei a nc ee 2D yy t own e e r o yt 5 De nDee a
l ytaec a n a pot a o nmre nnle dt g gh c de sg i l r e c e r r et a cr ar crb p e mn ntoie a es mb e v n e eg tatam ore hc ti ents a e ei g n p r oe nt gnm s P er Acgn oe A pd cremc oe f e ge r l ue e r i we e pme r emt l n hh ela nm mnehe l meys
)
d T s O_(Eisgt WSEdfo EdS . a b c
't \ - '
m n o c 4 .(d. b . ' 5
. ] I (3
(
- l.
8 6 l. I
- 3, P
9 g , P 4 3 3 3, 7 QG N N,,{g. L 8 1 F - g 2 A l e ho )r sSS E J s e y n w a ie e d o 4d nr Dl. yab iore pJ4 gl e 1 i o t of e a en ce4 r t a 3 c r p n e s edit s 3 N 1 5 ne t e p g go a me ep i hnn mt stesao[lo nw 2 r oD f t oe i ei n o c o o cg r me e mn dl e f on nos is dl f s yl es r n o - 2 f St u ao o 2 i Eb 3 eg 7 eo ba twia e ce l i d r oeh t e L 3 e 2 eeme s g ht t d i s ao o t r r t w n h t W I 2 f n t est 6 e o u mre t e ne n h h r[h i l eo t h
" er i t N g ,
g nf p at oro is ht t e .
" Geh l t i
w
- J
~
al
- l bi e aw no M gg t ae n dhb hd io et a r ht t a t id de eh' e* sr se e s it 5- sr w 1 3
gg vnp 5 s ot i 3 aW 5 em ar oa o hs yit na n d e E ~G 1 m s e r o is ne s oc c 4t bd *"' , p f_b a eMD p uf O' L it i si n
- a 4 es o s i
r ebe .w *' o 3 hm am o u. d l r y gob l o o 1 a. o
; t t e oa ie r
r t t cd avs l t t cs a et ar c mi C t.e 5 es t y a4 ay e Enpmd e 0 A aS er uo r f 1 eS " ho 6*4 : dro dd ee wro '
- t f ot o r - t /e d 0 2
nt d aa ue n" bom st d ncx e a " r o . eN e o c nee s t e m o i t ne u ha t edt sy t c r a e o u l e d1*W w" Wmsr h e*t t
)
-d f r oo ct e
D o n e t n . m ( o c 3h. S 644d.d e * F h 4
]
5
. d n
e
) 9 d ]6 F m A
- WoT ON 3 i r,
m e [M .@T. f' C r t n d e g (A os m t h i L T. c c A h
1lll 1 o d l 2 I 3 f o C n n i o i o t a e i s c g v i f a e i P R c e p S k n l a b l y l a n o i i t t o n e n e g a p i s h T o , t l
e fi ! O a2 e 1i2 i 1 18,1
\
\
a,1llN!{
- k k ' ik$Nkid!!
t iis t i,g 4
- i. !
0 n gg b : t
;a 1=l ,g i
;$ la \
s i
'm $g .
g { {l k{ g lif 4e ; I {$ k"k"'k la il 0
. l $5$
- d. .
,1 y4\
\ Q
# 1 1 leu={t f". \
d II g l 3 ill p ; z 1ji " j sl
-g y i
sitd3u-lit - k
~
} " }
O I
O _ l I 2 I 3 f o C _ n 7 n _ i o i o _ t a e i s _ c g v i a e _ f i P R c e p
.S .
k n l a . b _ l y l a n i o O t n . t e _ i n - e g a p i s _ h T _ O .
p t I B - 3 2
, I I
n o , 4 _ 3 C t.a % n o e q
- 3 M <- i s
%R i
e 8, J v e sp e s e
' 5 S 7
3 O e l b e a h l c o o
)
d c P P
't
( n o c r( A N t o N 9 0 2 F . A 4 D pb J l g s d s . e .k a ei s e e yan s n
~
l i i e m e ht n le omr etod v o l b a i e lpt _ h e le n t n se ito dr a t a s e bC t s s na b a r anD pe ag f u fuo amsceaarA e y ehe pt hnt a r e ed r ehniahr i lcpd r e en3 l i ossf o ntt oo. R r n bhame t i dne eoe r n ba eb B. i r o af oll intct et aoo f f o or 9 he ota s s sn o n e c e ahosi h w c yi g gt
,iu cl n sq t
n e yt lnr o es al e a etoof i nceio i idl l ool a l w wrb o o l u at.ey s r g snnmemr ii ni
,idmt ee h r t c o dspnaen odie a nt rannsryo t
nie s o saes e p C. ue g er d t age D 'd n 't ur aea
' h t eoa f
e a p S 0. fe0 0 h t u he cmdn g:oo omde ht l ss nge r t tl a-eh- ic t i i tsreola 3 ro 0, S dosw,pminMc ui t osd on e i , af ri e c neoints6 cf c no 4 d l l o pteqemt seb ,n nu n s a a cloto i odthie o cet eicsy os e sb t 'g:_ op pe suca e t rf o Dle y l r yis e m n ldnacn l l C h a t oh S fuoeTi r se c o t a hfeiScs rnksnouiodts nnit o t t r f m n tf r o eet ei t oaoec e r 'p t ti a i n otoegw vtndcr e ec edum i ereate sner e e o nt e ecma l r w s u i ea r f t a m ea r l l sn sepwi D o n mntyh coal cha t sne t - dp ubh sd e e amSon i w i r e iaa delGs nto"l,am r l t e of ee agos k rehni t i 3 nr o e c oG dr n t t i 5 aetdeimu sea ot on ereeiehrocnci he o" 2 f s nt t rn reDigo t sl e a rsnao l t r m aml e nr t i r y emeqnd r co el nwds o r usivsuea e r . mrs y e n e oles t u snc 3 o yoc v o i ahl pb ehr ea t e 8 r hnDeerhr t Ft Sca ef no0r r ot 0aeut i O ti i orWa i c odr y gwf o
..numce uo ds .
e r 0,ein uhn a r e e mc n r N o hia 4 e eq8 u W p6 G r 4 q w s va nieladdesesdms erbtieep c o e n e,go t aniiu l r r sl,semr t n
) P de r eaiier s e d edepr euu sqq s e qd l u w C o hompetupo m
't n
o 3 AM WmEsopreeo rtevf ue r no ap _ d n c e ( 9 3 D A m
/b
/
h I 3 . I f o C n O n i o I i o t a e i s c g v i f a e i P R _ c _ e p S _ k n _ l a b _
~
l y _ l a _ n - i o _ t n _ t e i n e g a p i s h T
l h I_ M f
, 1 . ni .... .,
TI il,i i!
't e
5 i l n!.glh,n e M 1{3ill;p fi I tt Hi *i 11 l1-
]e ii i "
alliI,h i u m, u L iihr daii ei li!!!h 11!1lh
~
L g i >- J; ' o . IOi!
!fi o! !l hllj!!s!}.g!ll l l;s i i h 1 ; 4 I
lliil}i 1f"I di E
!!11vilifu!.0$@!!!h i l jilhlf nil![ldiId lli'lI lpl a
i
.w dill!!!nu}libj
!!l 4
e 1.. 1Pldly . O 1 L
- V--
?! t,
; $ s :- t t i
s L DISCUSSION OF CHANGES
' ITS: 3.8.1 AC SOURCES OPERATING m
LADMINISTRATIVE CHANGES. iIn the conversion of the James A. FitzPatrick Nuclear Power Plant A17 (JAFNPP) Current Technical Specifications ~(CTS).to the proposed plant
'specificilmproved Technical Specifications,(ITS) certain wording preferences or conventions' are adopted which do not result in technical
- changes. ,: Editorial changes ' reformatting, and revised numbering are adopted to'makeLITS consistent with the conventions-in the Standard 1 Technical Specifications. : General Electric Plants. BWR/4, NUREG4433, Revision 11(i.e., . Improved Standard Technical Specifications (ISTS)).
.These changes are administrative, and have no adverse impact on safety.
- A2 - CTS 4.9.B.4 requires, once'every 24 months, the conditions under which l
- the EDG~ system _is required will' be simulated to demonstrate that the-pair.of diesel generators will' start, accelerate, force parallel and
-accept the emergency loads in the prescribed sequence. - ITS SR 3.8.1.12 '
smcifies the conditions and. requires, once each 24 months, verification
- tlat the diesel generator, in response to loss of power signal in conjunction with an ECCS initiation signal will auto start from'a-standby condition and energize as required permanently connected loads within the required time and. auto connected emergency loads-in the
- # prescribed sequence. This change is a presentation preference consistent with JAFNPP current practice, safety analysis assumptions, and interpretation of the requirements of CTS 4.9.B.4. Therefore this change-is. administrative and has no adverse impact on, safety.
A3- CTS 4.9.B.1 requirement to start, accelerate, force parallel and load i each pair of;EDGs and run until both EDGs are at steady state temperature conditions has been divided into two separate Surveillance Requirements..:ITS SR 3.8.1.2' addresses the start requirements-(M7), and ITS SR 3.8.1.3 addresses the Loading requirements (L3). In' addition. ITS SR 3.8.1.3 Note 4 has been'added, to clarify the requirement, that the'SR be preceded'by and immediately follow, without' shutdown, a
. successful performance of SR 3.8.1.2. The addition of ITS SR 3.8.1.3 ;
- Note.4 retains the CTS 4.9.B.1 relationship between starting and loading ;
.the EDGs, and as such does not alter any current testing or technical l requirements. Therefore this change is administrative and has no l p ' adverse 11mpact on safety. ,
l' .A4' - CTS 4.9.B.1 requires' that the paralleled EDG pair be loaded until both L ,
'EDGsLare;at steady state temperature conditions. ITS SR 3.8.1.3' L requires that the loaded EDG pair be run for a 60 minutes. ITS l : SR 3.8.1.3 Bases -states' that the minimum run time of 60 minutes is ,
required to stabilize. engine temperatures. Since this change does not ' alter;any technical requirements since historically these temperatures
.have stabilized at about this time, this change is considered h '
iJAFNPPi _Page 1 of 13 Revision (,
. t I r s L,
m .
- . ?
\
E DISCUSS' ION OF CHANGES I ITS:'3.8.1 < AC SOURCES ! h: .- - OPERATING
)
4 ADMINISTRATIVE CHANGES-A4(continued) I administrative and has no adverse impact'on safety.
- A5 - The details of CTS 3.9.C.2 related to the' Diesel Fuel Oil Transfer
- System 0PERABILITY have been' deleted. :The CTS 4.9.C.2 Surveillance
-Requirement.of the: Diesel Fuel Oil Transfer System necessary to support EDG OPERABILITY is maintained by ITS SR 3.8~' 6. . Additional technical changes:to the' diesel fuel oil transfer system are discussed in L6, L10, I L Land M13. The applicability of the Diesel Fuel' Oil Transfer System is 1 L
currently and will remain associated with EDG OPERABILITY, therefore 1'
- this change in presentation is administrative.
~ l A6 :- , CTS 3.9.B does:not provide specific Actions for. the condition of three
- or more AC sourcesLinoperable'and therefore entry into CTS 3.0.C is required and the plant-must be placed in COLD SHUTDOWN within 24 hours.
, ITS;3.8.1 Condition G has- been: included which specifies all, other - l L ;possible combinations of inoperable AC sources not addressed in the
'other proposed conditions in ITS 3.8.1. Since the ITS format allows C
i i
; multiple. Conditions' to.be entered simultaneously, with three ~or more AC LU '
. sources inoperable,. ACTIONS would be taken'in accordance with ITS 3.8.1,
- and ITS- LC0 3.0.3 entry conditions .would not be met.
l However, L ' consistent with the CTS default to CTS 3.0.C. ITS 3.8.1 Required Action G.1:will' require direct entry into ITS LC0 3.0.3. The changes in time l requirements to' shutdown of CTS 3.0.C~are addressed in ITS Section 3.0 Discussion of Changes M1 and L1. -Therefore this change is considered administrative.- !' ;A7' The' wording-in CTS 4.9.B.5.'a, b and c related to the criteria for determining'whether'a potential common cause EDG failure exists are-L being replaced with ITS 3.8.1- Required Action B.3.1'which requires the-determination whether. the other. Operable EDG and EDG subsystems are not
- inoperabic due to common cause failure. The allowance to extend lthe CTS
- Completion Time of 8 hours to 24 hours is- discussed in L5.' Since the L ; intent of the CTS and ITS wording are identical, this' change is considered' administrative. This. change is consistent with NUREG 1433.
Revision 1. eTECHNICAL-CHANGES i MORE RESTRICTIVE
, L M1" : CTS 3.'93A'requirestheLC0tobemetpriortoniakingthereactor
- critical. This: effectively implies MODES 1 and 2.
ITS 3.8.1
' A)plicability requires' AC sources be OPERABLE in MODES 1. 2, and 3.
p 'T11s change expands the. Applicability of AC electric power source "0" - rJAFNPP , , .Page 2 of.13 Revision C
fi
, 1 l
!~ (' DISCUSSION OF CHANGES ITS: -.3.8.1~- AC SOURCES OPERATING LTECHNICAL CHANGES MORE RESTRICTIVE L -M2 t(continued). - > p L, ~
- An eval'u ation has been performed due to the added test:ng requirements '
' imposed'by SR 3.8.1,7, SR 3.8.1.8 and.SR 3.8.1.11. The evaluation has ,
-concluded:that the additional tests will not impact the reliability of-
)
the EDG: subsystems. Since no similar Specifications' exist, the addition of these'SRs imposes I L , additional o
.This change,perational, consistent with requirements -and ispractice, current operating considered more restrictive.
is considered
-to have no adverse impact on-safety.
4 M3~ CTS 3.9.B.1,.3.9.B.2, 3.9.B.3, 3.9.B.4, and 3.0.E requirements, that the l i plant be placed in cold shutdown (MODE 4) within 24 hours ~ (L2) : if the corresponding AC sources were not ' restored.within the current Completion Times or all of its redundant system (s). subsystem (s).
- train (s), component (s)..or device (s) are OPERABLE, are being added to. .
ITS 3.8.1 Required Action F.1 requires the plant to be in MODE 3 (Hot l 2
~. Shutdown) within 12' hours. This action will ensure that the plant is l L 1placed'in a MODE outside'of the Applicability in a timely manner. Based E .
.on operating experience, the 12. hour Completion Time limit is acceptable
, since it, allows sufficient time .for an orderly transition to MODE 3
-without challenging. plant: systems. The additional requirement, to be in 1
'N00E 3-in 12 hours, is' consistent with NUREG 1433, Revision 1 imposes l additional o i This changeisperational consideredrequirements, and isimpact to;have no adverse considered more restrictive.
on safety. ;
;M4- : CTS -3.9.B.1 and 3.9.B.3 Completion' Times are being added to. . ITS 3.8.1 l Required. Actions A.3 and B.4 include a second Com)letion Time of 21 days from the: discovery of failu'er to meet the LCO. T11s second Completion
- Time' imposes a limit on the maximum time allowed for any combination of
. required AC: power sources to be inoperable during any. single contiguous occurrence of failing to meet the LCO. This restriction is intended to
- prevent exceeding the assumptions.regarding allowed out of service times s ' for an inoperable AC: source as a result of sequential inoperable EDG subsystems and reserve sources. The additional requirement, limiting ;
HT
- the maximum continuous. allowed out of service time, is consistent with NUREGa1433 Revision 1 -imposes additional operational requirements, and 1
is' considered more restrictive. This change is considered to have no L _ . adverse; impact;on safety. , i M5i . CTS 3.9.B.2 allows 7 days _of operation with two inoperable reserve power circuits'. ITS 3.8.1- allows the plant to operate but a power restriction has been added. ITS 3.8.1. Required Action C.2 will require the plant to l
..A ' reduce. THERMAL POWER to < 45% RTP within 36 hours. The reduction in QJ 'JAFNPP' Page 4 of 13 Revision C L
- i. [. 'l t < ,
1 DISCUSSION OF CHANGES p]
. ITS: 3.8.1 AC SOURCES OPERATING l
TECHNICAL CHANGES MORE RESTRICTIVE MS- (continued) power will reduce the consequences of any Design Basis Accident or
- Transient if they were to occur during this 7 day time period. The limit of < 45% RTP will ensure sufficient power is available from the main generator to sup) ort all operating onsite loads and to maintain
. stability of the 345 W transmission network. In addition, maintaining THERMAL POWER at approximately 40% RTP allows continuous operation of two reactor feedwater pumps and minimizes the potential for a reactor trip (and thus a turbine and generator trip) due to loss of one feedwater pump. If a. turbine trip were to occur, the Reactor Protection System trip will not be bypassed at above 29% RTP and a reactor scram will be initiated'directly from the turbine trip (due to turbine stop l valve closure or turbine control valve fast closure). These proposed Required Actions and Completion Times deviate from the NUREG actions for this condition: however, JAFNPP feels that the proposed actions are safer on plant operation since they allow sufficient time for repairs, avoid a complete loss of preferred power, and minimizes the consequences of any design basis accident or transient analysis.
M6- Not Used. M7 CTS 4.9.B.1 requirement, to demonstrate the ability of each EDG subsystem to start, accelerate, and force parallel, is being supplemented. ITS SR 3.8.1.2 requires the EDG subsystem also meet specific values for time, voltage and frequency. These requirements are acceptable based on meeting the values for time, voltage, and frequency consistent with existing plant design, and regulatory requirements. The addition of values for , the requirement ime, forfrequency, voltage, and the EDG subsystems is necessary to to meet specific ensure EDG OPERABILITY and safety analysis assumptions are maintained, is consistent with NUREG 1433, Revision 1, imposes additional operational requirements, and is considered more restrictive. This change is considered to have.no adverse impact on safety. M8 CTS 4.9.B.1 requirement, to load each EDG subsystem, is being
' restricted. ITS SR 3.8.1.3 Note 3 precludes this Surveillance from being performed on more than one EDG subsystem at a time. This change will ensure that at least one EDG subsystem is available to minimize the
! consequences of a design basis accident. This change is considered
- - acceptable since although not recuired by CTS it is consistent with i
current JAFNPP practice. The adcition of ITS SR 3.8.1.3 Note 3 to permit loading of only one EDG subsystem at a time, is necessary to help avoid common cause failures of both EDG subsystems that might result
- O 5 J V
JAFNPP Page 5 of 13 Revision C i-
~
/ i l
(4 DISCUSSION OF CHANGES Q ITS: 3.8.1 AC SOURCES - OPERATING
/
' TECHNICAL CHANGES MORE RESTRICTIVE M8 (continued) from offsite circuit or grid perturbations, is consistent with NUREG-1433. Revision -1, imposes additional operational requirements, and is ,
considered'more restrictive. This change is considered to have no 1 adverse impact on safety. j M9 CTS 4.9.B.4 requires, once every 24 month:,, the conditions under which i the-EDG system is required (loss of power signal in conjunction with an ECCS initiation signal) will be simulated to demonstrate that the pair l of diesel generators will start, accelerate, force parallel and accept ; the emergency loads in the prescribed sequence. This condition, loss of ! power. signal in conjunction with an ECCS initiation signal is addressed in ITS SR 3.8.1.12 (A2). In addition, JAFNPP has included ITS SR 3.8.1.9 and SR 3.8.1.10 which require, once each 24 months. verification i that the EDG subsystem, in response to a loss of power signal or ECCS i initiation signal respectively, will auto start from a standby condition 1 and energize, as required, permanently. connected loads within the required time and auto-
. connected emergency loads in the prescribed sequence. These b- Surveillance Requirements have been added to verify EDGs respond in accordance with the variations in the applicable design requirements.
Addition of- these Surveillance Requirements is consistent with the format in NUREG 1433, Revision 1, imposes additional operational
' requirements, and therefore is considered more restrictive. This change is considered to have no adverse impact on safety.
M10 Not Used. Mll CTS 4.9.B.4 requirement, to demonstrate the ability under required conditions (loss of power signal ECCS initiation signal, loss of power signal in conjunction with ECCS signal) of each EDG subsystem to start, accelerate, : force parallel and accept emergency loads in the prescribed
- sequence, is being supplemented. ITS SR 3.8.1.9, SR 3.8.1.10, and SR 3.8.1.12 require also that the EDG subsystem meet specific values for time, voltage, frequency and loading duration. These requirements verified by current Surveillances are acceptable based on meeting the values.for time, voltage, and frequency consistent with existing plant design and regulatory requirements. The addition of these requirements for the EDG subsystems to meet specific values for time, voltage, frequency and loading duration is necessary to ensure EDG OPERABILITY is maintained, is consistent with NUREG 1433 Revision 1, imposes additional cperational requirements, and is. .;onsidered more restrictive.
This change is considered to have no adverse impact on safety. i
- JAFNPP Page 6 of 13 Revision C
m DISCUSSION OF CHANGES
) ITS: 3.8.1 '
AC SOURCES OPERATING TECHNICAL CHANGES HORE RESTRICTIVE M12 CTS 4.9.B.6 requires that, in the event an EDG subsystem or reserve source is inoperable, the availability of reserve power be assured by verification of correct breaker alignment and that the associated s reserve electrical line is energized, once within one hour and every 8 hours thereafter. There is no CTS requirement to verify correct breaker alignment and indicated power availability for each reserve circuit on a regular basis during MODES 1,2 and 3 if the EDG subsystems ; reserve sources are available. ITS SR 3.8.1.1, a new surveillance, has { been included to verify the reserve circuits breaker alignment and power i availability once every 7 days. This Frequency is considered adequate i since alarms and annunciators exist which will identify problems with j the reserve circuits. The addition of the SR 3.8.1.1 to verify correct l breaker alignment and indicated power availability for each reserve ) circuit every 7 days, is consistent with NUREG 1433, Revision 1. imposes 1 additional operational requirements, and is considered more restrictive. l This change is considered to have no adverse impact on safety, j M13 CTS 3.9.C.2.b. 3.9.C.2.c and CTS 4.9.C.2 do not specify which EDG fuel oil transfer pumps must be OPERABLE. ITS SR 3.8.1.6 will require each C' diesel generator to have at least one transfer pum) capable to transfer V) oil from its corresponding storage tank to day tan ( automatically. If l this recuirement is not met the associated diesel generator must be declarec inoperable. The allowance in CTS 3.9.C.2.b to repair the transfer pumps in 30 days is deleted and the allowed outage time for the associated EDG a) plies. This allowance is 14 days for an EDG subsystem l therefore this clange is more restrictive on plant operation. In addition CTS 3.9.C.2.c has been deleted since the association between the fuel oil transfer system will now correspond to the associated EDG l and not the EDG subsystem. The specification of required transfer pumps l for each EDG and the elimination o" reduction of time to restore the pumas to OPERABLE consistent with'EDG OPERABILITY, is consistent with NUREG 1433, Revision 1. imposes acditional operational recuirements, and i is considend more restrictive. This change is considerec to have no adverse impact on safety. TECHNICAL CHANGES LESS RESTRICTIVE (GENERIC) LA1 The details of OPERABILITY in CTS 3.9.A.1, that " power is available to i the emergency buses from the following power sources", and specific l design details in CTS 3.9.A.1.a. referring to the "115 kV lines and t reserve station transformers", are aroposed to be relocated to the Bases. These details for system OPERABILITY and design are not necessary in the LCO. ITS 3.8.1 LCO which requires two reserve circuits p)
\
JAFNPP Page 7 of 13 Revision C L
DISCUSSION OF CHANGES
- Q,o ITS: 3.8.1 AC SOURCES - OPERATING j
" TECHNICAL CHANGES LESS RESTRICTIVE (GENERIC) l LA1 (continued)' l between the 115 kV transmission network and the plant class 1E AC l Electrical Power Distribution System and the associated ACTIONS and Surveillance Requirements and the definition of OPERABILITY are sufficient to ensure the OPERABILITY of the AC Sources Operating. 1 Therefore, these details are.not required to be in the ITS to provide I adequate protection of the public health and safety. Changes to the '
Bases will be controlled by the provisions of the proposed Bases Control Program in Chapter 5 of the Technical Specifications. LA2 The CTS 4.9.B.3 requirement to check the EDG subsystem instrumentation during the monthly generator test is proposed to be relocated to the Technical Requirements Manual. The requirement does not specify which instrumentation is required to be checked. Based on the definition of l
~ OPERABILITY all instrumentation necessary for the EDGs to operate must
-be OPERABLE. The definition of OPERABILITY ensures that all instrumentation not specified in the Technical Specifications and required for proper diesel generator operation are OPERABLE. As a result, this relocated requirement is not necessary to be included in G the ITS to provide ade
- At ITS implementation,quate protection of the public health and safety.the reloca
'() reference into the UFSAR. Changes to the relocated requirements-in the l Technical Requirements Manual will be controlled by the provisions of 10 CFR 50.59. TECHNICAL CHANGES LESS RESTRICTIVE (SPECIFIC) , Li~ CTS 3.9.B does not provide a specific Action for the condition of one inoperable reserve circuit and one inoperable EDG subsystem. Therefore, if this Condition existed the plant would be required to enter LC0 3.0.C and place the plant in cold shutdown in 24 hours. Therefore, ITS 3.8.1 l ; ACTION D, and associated Required Actions and Completion Times, for one i reserve circuit and one EDG subsystem inoperable, have been added, since
'in this Condition either the OPERABLE reserve circuit or OPERABLE EDGs l are more than' sufficient to bring the plant to a safe shutdown condition. ITS 3.8.1 Required Action D.1 is to restore the reserve l circuit to OPERABLE status within 12 hours or Required Action D.2 is to
- restore the EDG subsystem to OPERABLE status within a Completion Time of 12 hours. The 12 hour com letion Time is based on the capacity and i capability of the remainin AC sources, reasonable time for repairs, and the low probability of a D A occurring during this period. In addition, l
if the Completion Times are not satisfied entry into ITS 3.8.1 Required Action F.1, MODE 3 in 12 hours (M3) and Required Action F.2, MODE 4 in 36 l
't v
JAFNPP Page 8 of 13 Revision C l I
ra ,
.f
,W .
DISCUSSION OF CHANGES Q ITS: 1?. 8.1 AC SOURCES OPERATING TECHNICAL CHANGES LESS RESTRICTIVE -(SPECIFIC) [ LL1' (continued): _
' hours:(L2),:will be required instead'of ITS LC0 3.0.3- since t' .-plant is not'outside its Design Bases.'
The'. addition of ITS 3.8.1 Condition D is considered less restrictive since it allows an additional 12. hours to restore the inoperable . l l sources, However,~ it is considered acceptable since it reduces the risk
.of subjecting the plant ~ to a-shutdown and since other equipment will still be available to sup) ort any-abnormal' operational transient or a
, design bases accident. T11s "lange -is consistent with NUREG 1433, Revision 1, and is appropriatt. based on the design of the JAFNPP AC Sources' .
- L2 . CTS 3.9.B.1, 3.9.B.2, 3.9.B.3,'3.9.B.4, and 3.0.E requirement, that the
~
l plant to be placed in cold shutdown-(MODE 4) within 24 hours is being ! relaxed. ITS 3.8.1 Required Action F.2, extends the time allowed for l the plant to be in MODE 4 from 24~ to 36 hours. This change is in association with the. addition of a new interim requirement. ITS 3.8.1 1 Required Action F.1, which requires the plant to be in MODE 3 in 12 l l m : hours -(M3). : The 36 hour Comp etion Time is based on providing the i lC 'necessary time for the plant to cool'down and reduce pressure in a
. controlled and orderly' manner, and the low probability of a DBA l
' occurring during this period. The additional time to reach-MODE 4-(36 l
- hours) in association with the interim requirement to-be in~ MODE 3 (12. i
;. hours), is consistent with NUREG 1433 Revision 1.- reduces the potential l Lfor a plant event that could challenge plant safety systems, relaxes !
operational time r_equirements,- and therefore is considered to' be less restrictive. L3. CTS 4.9.B.1 requirement, that each EDG subsystem be force paralleled and loaded'to 5200 KW,- and load sharing capability checked, are being relaxed. . ITS SR 3.8.1.3 requires each force paralleled EDG subsystem be l synchronized and each EDG be loaded and o>erate for a 60 minutes at a load a'2340 KW and 5 2600 KW. The EDG su) system load requirements have been relaxed to ensure that the EDGs continuous rating is not required l' to be exceeded every 31 days. The new load range requirement of 90%-
~100% of continuous rating is consistent with the recommendations of
. - Regulatory Guide l.9, Revision'3. This change is acceptable since the ;
EDG full load carrying capability will be. demonstrated during the 8 hour iload test in ITS SR 3.8.1.11. ! L4'- .CTSL4.9.B.4' stipulates that'an automatic starting test, under the l
, ' conditions which the EDG is required to perform will be simulated to i
'O ,
i JAFNPP. .Page 9 of 13 Revision C l j'i' I. n -
b 1 l 3, .,: t-Il ' DISCUSSION OF CHANGES , ! )ITS::3.8.1 AC SOURCES OPERATING l
- . ~
N' i . . . , . . . l ,. TECHNICAL' CHANGES- LESS RESTRICTIVE (SPECIFIC)
)L4;L(continued). ,
b ! demonstrate ~that the pair of diesel generators will start.' accelerate, i force' parallel, and accept the emergency loads in the prescribed
- , -sequence. ITS SRs 3.8.1.9. 3.8.1.10. and 3.8.1.12, include the phrase L " actual or.". in reference to the automatic initiation signal, .for verifying that each EDG starts on-an automatic initiation signal. This-1 chan or "ge is acceptable'since simulated" signals andthe EDGs-cannot' OPERABILITY discriminate is adequately between " actual" demonstrated in
!either case. This change-allows satisfactory automatic system 11nitiations to be:used to-fulfill the Surveillance Requirements, is consistent with the NUREG 1433.. Revision 1, allows alternative operational . requirements, and therefore is'less restrictive. ,
L5 CTS 4.9.B.5'provides a' Completion Time of 8 hours whenian EDG subsystem l 4- ~1s inoyerable to demonstrate, by manual- start.and force paralleling, the o availa)ility of the OPERABLE EDG subsystem or determine that the l. inoperability is due to preplanned maintenance or testing, an inoperable support? system with no potential common mode failure, or an independently testable com)onent with no potential common mode failure. G 'ITS 3.8.1 Required Action 3.3.1 provides a Completion Time of 24 hours - i 'V
;to determine the 0PERABLE EDG subsystem is not' inoperable due to common cause failure or ITS 3.8.1 Required Action B.3.2, perform SR 3.8.1.2 for l
-OPERABLE EDG subsystem. This change provides an additional 16 hours to l .
" determine that the inoperabilities are.not due to common cause failure 1
- ortto demonstrate OPERABLE EDG subsystem availability. The 24 hour
-Completion Time, in accordance with Generic Letter 8415, is reasonable
' time to-confirm that the OPERABLE EDG subsystem is not affected by the j same problem as the inoperable EDG subsystem based on the low
- probability of an event during the additional 16 hours. If the cause of
! the ino)erable EDG subsystem cannot be confirmed not to exist on the OPERABLLEDG: subsystem. then performance of ITS SR 3.8.1.2 is reguired to provide; assurance of continued 0PERABILITY.of the remaining EDG subsystem. This change is consistent with Generic Letter 84 15 and ,. 'NUREG 1433,; Revision 1, relaxes operational requirements, and therefore f'
~is' considered to be less restrictive.
' L6' ' CTS 3.9.C.2.a allowance, for operation to continue for 60 days with one L inoperable fuel oil transfer pump associated with a Diesel Generator E
Esubsystem provided the remaining fuel oil transfer pumps are-L ' demonstrated OPERABLE immediately and weekly thereafter, has been -
. deleted. ITS SR 3.8.1.6 Bases requires only one pump to be OPERABLE for
, each EDG.o Each individual diesel generator is provided with an
- independent fuel oil system consisting of a' main fuel oil storage tank, Ja day tank-and two full capacity , motor driven pumps which are designed O JAFNPP 'Page 10 of 13 Revision C j i
7 . . L f- ~ DISCUSSION OF CHANGES ITS: 3.8.1
- j. AC SOURCES f OPERATING TECHNICAL CHANGES -LESS RESTRICTIVE -(SPECIFIC)
! .L6i .(continued)
- to transferJfuel oil' from the. storage tank to the associated day tank l ' automatically. The selected pump will start automatically when the day l Lt ank level.is < 70 % and the standby pump will start when the day tank
- . level is <'50%.- The fuel oil- transfer -system design includes provisions so that the transfer )um s can be ali ned manuall to transfer oil from 1
.any storage tank ~to t1e ay tank with n each Dies 1 Generator subsystem, i Since one transfer pump is capable of maintaining adequate level-in the I day tank with the diesel generator o)erating at full load, allowing ,
- continuous . operation with one OPERAB_E transfer pump is acceptable. '
~
L7 CTS 3.9.B.1 allows o>eration to continue ~ for 7. days with one reserve power' source ino) era)le provided both Emergency Diesel Generator subsystems are 0)ERABLE. CTS 3.9.B.2 allows operation to continue ~for
'7. days'with two reserve power sources inoperable provided both Emergency Diesel Generator subsystems, all core and containment cooling systems as well as the shutdown cooling ystens'are OPERABLE. CTS 3.9.B.3 allows )
operation to continue for 14 ays with one EDG subs stem inoperable l u provided that.the two reserve er sources are ava lable and the ,
., -remainin -EDG: subsystem is OPE LE. CTS 3.0.E requires the plant to be. l in cold hutdown within 24 hours when a redundant feature is inoperable and the reserve'or.onsite power source of a system, subsystem, train, component or device.is inoperable..
ITS 3.8.1 includes all of the requirements for redundant. system cross checks when AC sources are inoperable.- ITS
' allows 24 hours from. discovery of no reserve.3.8.1, power to Required Action A.2 one division
' concurrent with inoperability of redundant required feature (s) to declare required feature (s) with no reserve when the required feature (s) are inoperable.ITS power available 3.8.1'Re inoperable uired Action B.2 allows 4 hours from discovery of one inoperable EDG s bsystem concurrent with inoperability of redundant required feature (s) to
. declare the required features supported by.the inoperable EDG subsystem
. inoperable when the redundant required. feature (s) are inoperable. ITS 3.8.1 Required Action C.1 allows 12 hours from discovery of two reserve l circuits inoperable concurrent with inoperability of redundant required l
i
. JAFNPP :
Page.11 of 13 Revision C
5 M . DISCUSSION OF CHANGES
. ITS: 3.8.1 : AC SOURCES - OPERATING
- ; TECHNICAL CHANGES LESS RESTRICTIVE (SPECIFIC)
. L7' '.(continued) afeature(s)lto declare required feature (s) inoperable when the redundant
" required feature (s) are inoperable.
Thus, adding the.new ITS 3.8.1' Required Actions A.2, B.2, and C.1 w'ill l
. allow the operator time to evaluate and correct any discovered'
-inoperabilities. This will reduce the risk of subjecting the plant to a
. shutdown while- the ' redundant safety features are inoperable. . This change is acceptable because the remaining OPERABLE ~ power supplies are
. adequate to su mwer to the-onsite emergency distribution
. system. . Thus,pply electrical ) asis, single failure protection for the.
on a component 4 required feature's function may have been lost: however, the safety
-function ~has not been lost. The 4 hour, 12 hour, and 24 hour Completion
- Times take into account the component OPERABILITY of the redundant
-counterpart to the inoperable required feature. By allowing features associated with the inoperable reserve circuit (s) to be declared inoperable, the appropriate ACTIONS can be taken. Additionally, the
' Completion Times take:into account the capacity and capability of the 3 remaining. AC sources,1 reasonable time for repairs, and a low probability 1 f of a DBA occurring during this period. Therefore. this-change is- i
.( o
- considered acceptable-L8t A Note is added.to' CTS 4.9.B.1 requirement for loading the emergency diesel generators (EDGs). ITS SR 3.8.1.3 Note 1, allows gradual loading ,
of the EDGs as recommended by.the manufacturer. . EDG' loading should be i gradual whenever mssible to minimize mechanical stress and wear on the 4 4 diesel engine. T11s change is' considered to be acceptable since the
- starting, loading, subsequent full load omration, and automatic ', tart 1 and loading testing-required by other Tec1nical Specification Surveillances is' adequate to confirm the EDG's capability. ;
- i '>L9. Note'is added to CTS 4.9.B.1 requirement for loading the emergency-
? diesel; generators -(EDGs) . ITS SR 3.8.1.3 Note 2, allows that momentary
. load transients outside of the load range do not invalidate performance of theLSR. Momentary. transients may occur for various reasons during L . loading, unloading, and steady state operation of the EDG. However, l' these transients ~ are quickly restored to within the limits and do not reflect an inability of the EDG to fulfill its function. Therefore, these transients should not be considered as a failure of the Surveillances.
L105 CTS'4.9.C.2 requirement, Surveillance Frequency of once per month, to demonstrate fuel oil transfer system operates to transfer fuel from the 6 . LJAFNPP! ,
' Page:12 of 13 Revision C
~
a NO SIGNIFICANT HAZARDS CONSIDERATION JO ITS: 3.8.1 - AC SOURCES OPERATING. fTECHNICAL CHANGES LESS RESTRICTIVE (SPECIFIC) L1 CHANGE New York Power Authority has evaluated the proposed Technical Specification change and has concluded that it does not involve a significant hazards consideration. Our conclusion is in accordance with the criteria set forth in 10 CFR 50.92. The bases for the conclusion that the proposed change does not involve a significant hazards- consideration are discussed below.
- 1. Does the change involve a significant increase in the probability or l
. consequences of an accident previously. evaluated? j ITS 3.8.1' ACTION D will: allow additional time to o)erate with a reserve l circuit and one EDG subsystem (one or two EDGs witlin the same subsystem) inoperable, before commencing a shutdown if the equipment is not restored to service. Allowing an additional 12 hours does not increase the probability of an accident previously evaluated since - ,
operating with inoperable AC sources does not cause an accident to l occur. The remaining AC sources are adequate to supply the equipment ' necessary to bring the plant to safe shutdown conditions during a DBA or q transient therefore-the consequences of an accident previously evaluated U is not increased.
- 2. Does the change create the possibility of a new or different kind of accident from.any accident previously evaluated?
The proposed change does not involve any physical alteration of plant systems, structures or components, changes in parameters governing normal plant operation, or methods of operation. The proposed change
. provides additional time to repair an . inoperable EDG subsystem or reserve source. Therefore, the possibility of a new'or different kind
= of accident from any accident previously evaluated is not created.
- 3. Does this. change involve a significant reduction in a margin of safety?
The proposed change provides additional time to repair an inoperable EDG subsystem or a reserve circuit. The requirements will still assure that adequate AC sources are available to operate the minimum required equipment. Therefore, this change does not involve a significant reduction in a margin of safety.
~
A
.JAFNPP Page 1 of 14 Revision C
[~ l NO SIGNIHCANT' HAZARDS CONSIDERATION 4 l ITS: 3.8;1 AC SOURCES OPERATING L iTECHNICAL CHANGES - LESS RESTRICTIVE (SPECIFIC) i i , l I - L2 CHANGE ! New York Power 1 Authority has evaluated the proposed Technical Specification change and has~ concluded that -it does not involve a'significant hazards
~ consideration. :0ur' conclusion is in.accordance with the criteria set forth in J L 10 CFR 50.92. The bases for the conclusion' that the proposed change does not l involve a significant hazards consideration are discussed below. l 1
11.. Does the change involve a significant increase in the probability.or. l consequences of an accident previously evaluated? . The proposed change extends the time to Cold Shutdown from 24 hours to i 36 hours when the Actions' associated with CTS 3.9.B.1, 3.9.B.2, 3.9.B.3, i or 3.9.B,4 are not met within the required times. Shutdown Completion l Times:are not, assumed in-the initiation of any analyzed event. Allowing this additional time ~does not increase the probability of an accident previously evaluated since operating with inoperable AC sources does not l cause an accidentito occur. This change in association with the l
. addition ~of a new requirement, ITS 3.8.1 Required. Action F.1, does not- ./ increase the consequences of an accident because ITS 3.8.1, Required l l l' - Action F.1 will require that the plant be placed in MODE 3.within 12 !
hours'(M3)-once the determination is~made that the Required ~ Action or
~
l
- Completion Time associated with the AC source being inoperable cannot be
! : satisfied. The remaining AC sources are adequate to supply the .1 l equipment necessary to bring the plant to safe shutdown conditions 1 during a LOCA or: transient therefore the consequences of an accident :
- previously evaluated is not
- increased. !
! ~ H -2. .Does the change create the possibility of a new or different kind of accident from any accident previously evaluated?= The proposed change will' .not , involve any physical changes to plant L: systems, structures, or. components (SSC), or the manner in which these SSC are operated, maintained, modified,- tested, or insmcted. The change increases the Completion Time to achieve Cold Slutdown from 24-hours to 36 hours. Therefore, this change will not create the L possibility'of a new or;different kind of accident-from any accident previously evaluated.
'3; t Does' this change involve a significant reduction in a margin of safety?
The change. extends the Completion Time to reach Cold Shutdown from 24 hours to 36 hours when the current Actions cannot be satisfied. The
-remaining AC sources are adequate to supply the equipment necessary to O (JAFNPP Page 2.of 14 Revision C l
Qi
1 1 e NO SIGNIFICANT HAZARDS CONSIDERATION i ITS: 3.8.1 AC SOURCES OPERATING TECHNICAL CHANGES LESS RESTRICTIVE (SPECIFICl l L2' CHANGE = 3.- (continued)*
. bring the plant to safe shutdown conditions during a LOCA or transient asliong as the remaining AC sources operate as designed therefore there I is still an adequate margin of safety. ; This change is in association i with the addition of a new requirement. ITS 3.8.1 Required Action F.1, l which will require that the plant be ) laced in MODE 3 within 12 hours
.(M3) once the determination is made t1at the Required Action or Completion Time associated with the AC source being inoperable cannot be )
satisfied. In addition, this change provides the benefit of a reduced potential for a plant event that could challenge safety systems.by providing additional time to reduce pressure in a controlled and orderly manner. Therefore, this change does not involve a significant reduction in a margin of safety. l t '
)
O JAFNPP Page 3 of 14 Revision C
u I L. ) $NQ NO SIGNIFICANT HAZARDS CONSIDERATION?
, ITS: 3.8.1 .AC SOURCES -; OPERATING E
- TECHNICAL CHANGES -~LESS~ RESTRICTIVE (SPECIFIC)-
1 LLSCHANGE-h, New. York Power Authority.has evaluated the proposed Technical ~ Specification
- change and has concluded that it does not involve a significant. hazards consideration. :0ur conclusion is in accordance with the criteria set forth in 10 CFR 50'92; The bases for..the conclusion that:the~ proposed change does not in_volve a significant hazards consideration are: discussed below.
1 p' l '. :Does the change: involve a significant increase in the probability.or - . consequences: of an ' accident' previously evaluated? j The proposed change allows an additional 16 hours _to verify the availability (Operability) of the other EDG subsystem when one-EDG
- subsystem is found to be inoperable. The EDGs are not assumed to be an initiator of any analyzed event. Therefore, this change.does.not
" involve a significant increase in the probability'of an accident ;
previously ~ evaluated. 2 As stated in NRC Generic Letter 87 09, "It 1s overly conservative'to assume that systems'or components are inoperable i
'when a= surveillance requirement has not been' performed. The opposite is
.in. fact: the case: the-vast majority of-surveillances demonstrate the (k- systems or components in fact are operable." Therefore.: reliance on the specified surveillance intervals doesinot result in'a reduced level of confidence concerning the equipment availability. The proposed Completion Time of 24 hours is also in accordance with Generic Letter '
l; L84 15. Additionally, the proposed change does-not involve any )hysical L' changes.to plant systems.: structures, or com . i 'in which these.SSC:are operated,- maintained,ponentsmodified, or (SSC), tested. or t1e manner The- ! L -consequences-of an accident will not be increased because the proposed change-still provides assurance-that a common mode failure has not affected the remaining Operable EDG subsystem while enhancing
' reliability of the remaining Operable EDG subsystem by reducing the
- number of: starts required.
'2. ! Does'the change create the possibility of a new or different kind of
( + . accident from. any accident. previously. evaluated? p l' LThe proposed change:does not involve any physical alteration of plant systems. structures or. components, changes in parameters governing normal plant . operation, or methods of operation. The proposed change
. extends the allowed time to complete' a Surveillance by 16 hours.
-Therefore, the. possibility of a new or different kind of accident from any. accident previously evaluated is not created.
t: v.- Page 6 of 14 Revision C JAFNPP [ --
p
]
1 1 i Vy NO SIGNIFICANT HAZARDS CONSIDERATION (, )' -ITS: 3.8.1 - AC SOURCES - 0PERATING TECHNICAL CHANGES' LESS RESTRICTIVE (SPECIFIC) L5 CHANGE
- 3. Does this change involve a significant reduction in a mc. gin of safety?
The proposed change extends the allowed time to complete a Surveillance by 16 hours. The requirements will still assure adequate AC electrical power is available to operate the minimum required equipment. Thus, , extending the time to verify that the failure of the EDG subsystem will l not result in a common cause failure of the other EDG subsystem or performing proposed SR 3.8.1.2 does not involve a significant reduction in a margin of safety. l
;n l kj i
l lt JAFNPP ~ Page 7 of 14 Revision C n
N0 SIGNIFICANT HAZARDS CONSIDERATION a ITS: 3.8.1 - AC SOURCES 0PERATING'
; TECHNICAL CHANGES - LESS RESTRICTIVE (SPECIFICL
,t-
' L7 CHANGE New York Power Authority has evaluated the proposed. Technical Specification - ;
' change and has concluded that it does not involve a significant hazards !
^ consideration. Our conclusion is:in^accordance with the criteria set forth in
.10 CFR 50.92. fThe basescfor the conclusion that the proposed change does not Linvolve a-significant_ hazards consideration are discussed below. ;
-1; - Does the' change involve a significant increase in the probability or
- consequences of an accident previously evaluated?
..The change increases the Completion Times allowed for declaring required I feature (s), supported ~by the. inoperable AC source, inoperable when the ;
redundant required feature (s) are inoperable concurrent with one or two ' reserve circuits'or one EDG' subsystem inoperable. Although the reserve circuits and EDGl subsystems ~ are used to support mitigation of the consequences of an accident: neither they nor the Completion Times for verifying redundant required features are OPERABLE in the event of AC ] source inoperability are' considered to be the initiator of any G "previously analyzed accident. . Further, equipment powered by the. V inoperable-reserve circuits and EDG subsystems continues to be evaluated
.for: loss of function and previously determined appropriate ACTIONS for-l i
= restoration ~ or repair'of such -inoperabilities continue to be 1 implemented. As. such, the proposed ACTION will not increase the probability of any accident previously evaluated. The proposed ACTION continues to provide ~ adequate assurance of OPERABLE required equipment
-and therefore, does not involve an increase in the consequences of any
, accident previously evaluated.
2'. Does'the ch:nge create the possibility of a new or.different kind of accident from any accident previously evaluated? This change will.not create the possibility of an accident. This change
.will. not physically alter the plant '(no new or different type of equipment will be installed). The changes in methods governing normal l plant operation are consistent with the current safety analysis assumptions- Therefore, this change will not create the possibility of a new or different kind of accident from any accident previously
. evaluated.
- 3. Does this change involve a significant reduction in a~ margin of safety? l This~ change increases the Completion Times allowed for declaring c required feature (s) supported by the inoperable AC source inoperable, k]' MAFNPP Page 10 of 14 Revision C 1
I J
n N0 SIGNIFICANT HAZARDS CONSIDERATION ITS: 3.8.1 - AC SOURCES - OPERATING TECHNICAL CHANGES LESS RESTRICTIVE (SPECIFIC) L7' CHANGE 3..- (continued) when the' red;ndant required feature (s) are inoperable, concurrent with one or two' reserve circuits or one EDG subsystem inoperable. This l change does not involve a significant reduction in any margin of safety since the determination of loss of redundancy or loss of function 1
. continues to be made in the same manner. /~N j
- t; ,
l l
,2 f y-JAFNPP- Page 11 of 14- Revision C
1
, NO SIGNIFICANT HAZARDS CONSIDERATION )
ITS: 3.8.1 AC SOURCES (]% OPERATING '
~ TECHNICAL CHANGES LESS RESTRICTIVE (SPECIFIC)
L8 CHANGE New York Power Authority has evaluated the proposed Technical Specification change and has concluded that it does not involve a significant hazards consideration. Our conclusion is in accordance with the criteria set forth in 10 CFR 50.92. The bases for the conclusion that the proposed change does not involve a significant hazards consideration are discussed below.
- 1. Does the change involve a significant increase in the probability or i consequences of an accident previously evaluated?
l The emergency diesel generators (EDGs) are used to support mitigation of the consequences of an accident: however, they are not considered the initiator of any previously analyzed accident. As such, the allowance i for gradual loading of the EDGs during surveillance testing will not l l increase the probability of any accident previously evaluated. The ITS SR continues to provide adequate assurance of OPERABLE EDGs and therefore, does not involve an increase in the consequences of any accident previously evaluated. l (3) t'
- 2. Does the c.hange create the possibility of a new or different kind of accident from any accident previously evaluated?
The proposed change does not introduce a new mode of plant operation and does not involve physical modification to the plant. Therefore, it does not create the possibility of a new or different kind of accident from any accident previously evaluated.
- 3. Does this change involve a significant reduction in a margin of safety?
The gradual loading of the EDGs does not im)act the capability of the EDGs to perform their safety function and t1e automatic starting and loading required by other SRs is adequate to confirm the EDG's capability. In addition this change provides the benefit of minimizing wear on the EDG engine through the practice of gradual loading whenever possible. As such, this change does' not involve a significant reduction in a margin.of safety. '('-)y JAFNPP Page 12 of 14 Revision C k
~ AC Sources-Operating , 3.8.1 3.8 ELECTRICAL POWER SYSTEMS
'.8.1 - AC Sources-Operating Q
\
sjfMV LCO 3.8.1 PtF1 _The following AC electrical power sources shall be OPERABLE: h 3. 0 I U (surtWTag circuits between the transmission network and the entts(Class 1E AC cal Power
~
, y Distribution Sy t ; og gf ,g g b. h diesel eratch a C j4hree/autostic s quencerfj ( @ O T-APPLICABILITY: MODES 1, 2, and 3.
(3.SA) [M Q ACTIONS CONDITION REQUIRED ACTION COMPLETION TINE p One W y M. A.1 Perform SR 3.8.1.1 1 hour I A. circuit inoperab;e. for OPERABLE
$[g[ E '
h 9,5.[ Once per 8 hours peerve thereafter j b, 0 d [ g;gg (O.6 ') 74g A.2 Declare required 24 hours from feature (s) with no discovery of no
'Ws1G power Vorfsdig power to avai'.able inoperable one division
( 1.73 when the redundant concurrent with required feature (s) inoperability of are inoperable. redundant ! required ! feature (s) AliQ (continued) ; 3.8-1 (l.482SllD , (BWRf4 /5TSJ - umm n ~J k., 9 Revision C l I
F I h
- AC Sources-Operating 3.8 %
?AI ACTIONS CONDITION REQUIRED ACTION COMPLETION TIME
(--kDB]) A3 Restore ([reqyTFedD (72 hpGr!) [23.8 1] A. (continued) bM 4) E a . M ey f failure to meet Tg7 LCO
\ _
[.79,8, F] B. One Great #redt OG ' B.1 Perform SR 3.8.1.1 1 hour inoperable. for OPERABLE b4'7+ E b] D B 'l recusfedD6IEs3R) M circuit (s). %/ Once per 8 hours [ 3.0. h Su g,7, e e m Ge.se rVe-7 thereafter bBs M O B.2 Declare required feature (s),suppor d 4 hours from discovery of
's 7] by the inoperable Condition B /\
inoperable when t e concurrent with /C\ redundant required inoperability of feature (s) are redundant inoperabl e, required feature (s) (siefs+9 (continued) 3.8-2 Rev 1, 04/07/95 BWR/4 STS
..p .
Revision C l l
,V AC Sources-Operating
- 3.B.1 ACTIONS
) b- lj CONDITION REQUIRED ACTION COMPLETION TIME
~
Qusystem es) B. (continued) B.3.1 De OPERABLE h24hhours h b43.I3.b inoper e e to connon cause failure. X/ [LI h s .5+,, B.3.2 Perform SR .1.2 h hours A for OPERABLE /p (M E 6 da-f ['$.9,3,$ B.4 Restore Greadiredb DG c.LS l to OPERABLE status, fubty ff 8e discovery of T-. LMH D3l failure to meet LCO a C. Two @1 equited circults inopera f e. C.1 Declare required feature (s) inoperable 12 hours from discovery of when the redundant Condition C required feature (s) concurrent with [3 /7. B . 2]. are inoperable. inoperability of redundant ( 3. O . ff. ] hsehVh required rL% L -f b&7 feature (s) C o 5 m3 Q M [M S,3 Repqg r onf 3 e to O p m F rerk (continued) CQ [ ANb c.t wa_weuoae eu < 45){ R.T?, - u ko a Q*A BWR/4 STS 3.8-3 Rev 1. 04/07/95 h (O Revision C i
m (O.) AC Sources-Operating 3.8.1 ACTIONS (continued) t CONDITION REQUIRED ACTION COMPLETION TIME D. OneQreapfe ------ -----NOTE - - - ---- circui era e. Enter pplicable Conditions y and red Actions of A!g} LCO .8 k " Distribution Systems-Operating," when One frecum edl Condition D is entered with inoperable, no AC power source to any division. ag,yff Q ____........... _..____. 3g, 0.1 Re e (Freauire 12 hours circuit to LE status. > yesene_ g D.2 RestorerecuneddDG 12 hours
-.-( _
iA bsy . E. Two ror ttwwh E.1 Restore on 2 hours Creani"* 9 Egf reauiredig to 3 inoperable bg OPERABLE status. Sassyste . (continued) O BWR/4 STS 3.8-4 Rev 1, 04/07/95 Revision C
f-O b . AC Soure.cs-Operating 3.8.1 ACTIONS (continued) CONDITION REQUIRED ACTION COMPLETION TIME , ^ ^ _ F. One (required) )
-------REVIEWER'S/ NOTE------- ,
(automatic 1 d This Condition may be deleted sequencer noperable. if the unit de gn is such that any sequ cer failure mode will o y affect the ability a the associated - to pow its respective saf loads following loss of ffsite power inder ndent
,orcoincidentwit! ,a
__I.S.. S.'... ..__. F.1 Restore l;requi d) [12) h ars
/ [ automat 9cloa
/ sequencer) t
( b31
' OPERABLE s tus.
N Y [ C3,aE).RequiredActionand h.1 Be in MODE 3. 12 hours Associated Completion [i.9.6 /] Time of ti A, A.3Q [ ] o . h.2 Be in MODE 4. 36 hours [s 1, SA) 16 2. Three _ re Enter LCO 3.0.3. Immediately
@.1
{ g(,} [A regyrred ces inoperaDie sons otne han CondWionET. , 3.8-5 Rev 1, 04/07/95 BWR/4 STS (~h V Revision C
D U AC Sources-Operating
- 3.8.1 SURVEILLANCE REQUIREMENTS SURVEILLANCE FREQUENCY SR 3.8.1.1 Verify correct breaker alignment and 7 days indicatada ower availability for each h a.6.L,] rptiuped)@TfiTYh circuit.
L.-(r< s en) SR 3.8.1.2 h--/--~M--MNOT16--/-----g-----+ ora ce of SR 3.p l.7 satisfies y [4M.B.h 2. All DG star s may be pr eded by an engine p ube period nd fC lowed by a warmup period prio olo2 din,
&- __ - DB f >
- 3. odified DG st involvin dling A and gradual a synchronous eration t eed may be ed for 'm/ is
/c\
SR as recomm ded by the nufactu er.
/ When modifi start proce res ar not i < used, the ime, voltage nd fr ency toleran s of SR 3.8. must b t.
- w Cwbs ystew) _ t s8dAv l tarts from standb *f {Ksspfcifffdin
, 9,,, T Verify T pavmosisf conditions; chieves st state (Tab 1f 3.f.1-1 (48.B.l) voltage 2d V and 4 )Vand
[m 7] g f requency't p8.8@ Hz an .2$Hz. (continued)
*a
- m (S. IO Sec om 4 5]
l Volta.$G 3,'gsy g V am d
\
kett,aemef h $8*8 NK, (ud b. ) l i 3.8-6 Rev 1, 04/07/95 8WR/4 STS d- Revision C i
l l l AC Sources-Operating O 3.8.1 i SURVEILUUICE REQUIREMENTS (continued) SURVE!LLANCE FREQUENCY i SR 3.8.1.3 ---- -------------NOTES - - - - - - - - - - - - -
- 1. DG loadings may include gradual 33
{tg loading as recommended by the manufacturer.
- 2. Momentary transients outside the load 7mit et d range do not invalidate this test. w:W twwg
( vu ervr
- 3. This Surveillante shall be conducted ononlyonejoGfat a use.pgg {$7df[ov -
@F']
- 4. This SR shall be preceded by and 4 lamediately follow, without shutdown,
[4 27* par a successful perfonnance of SR 3.8.1.2 / t8f
-'Li. # \
Verify each is ndiloaded m gpecttwa _trg [M.6.] a rates for 2 e nutes at a load Tarla talt-tr kW and s kW. OX3 -.(' 2 (2W f.fN Zwo) _ (s SR, 3.8.L4 Verif each day tank Ud anainarrmam D 31 days N . contain(si2 gal of fuel oil, m & r r : SR 3.8.1.5 Check for and remove accumulated water free $319 days ekch day tank tano5 engine asuntee innai. (K1, i
~
w g,4 - SR 3.8.1.6 Verif
& ~D fuel oil transfer syst ira es o b tematically transfer fuel l92l 4days ot fromastorage tankis) to thejday tank
-- - == r -
ji-e9eC.) t ann ___ in. J. 4 (continued) 3.8-7 Rev 1, 04/07/95 8WR/4 STS Revision C
AC Sources-Operating 3.8.1 SURVEILLANCE REQUIREMENTS (continued) SURVEILLANCE FREQUENCY [R 3,8.1.7 ---------- -------nu i t.--- - - - - - - - - - - - D3f
, All DG st s may be preced by an engine prelube riod.
1 Verify e ch DG starts from itandby 184 days conditi n and achieves, i 5 (12] seco
. volta 2 (3740) V and s 4580' Y and freq ncy 2 (58.8) Hz a f [6L.2] .
g ( N - y,----- -
- -- ---- ~. I a, g ySR3.8.1 6 TE---- ---------T O I be pe rued - j This Su e111a e_shall - I
' i jnM00l1or Howww.rg sr vu my y
[M C pas iv- on -nied evasts that safitf4 gg f 03i Ikhi[titJ l i s+ manualg transfer $ 9 months) ! s verify oTSE )Bautomatic power suppi g freethegnormal - Ttr1smurT1 to t (TtB1TEtg i
)
' UL m circuit.
lg l rg[p (continued) l
}
(Asdrce I i 1 l 1 1 i I 3.8-8 Rev 1, 04/07/95 Bn#R/4 STS Revision C 1 I
I O l AC Sources-Operating 3.8. SURVEILLANCE REQUIREMENTS (continued) e h SURVEILtANCE FREQUENCY h <., 4,4 4 083 SR 3.8.1.y 3- ------ - ctB9
- --NOT
'TA -
..... ;;,,, , g, ;g gg . h n g ' ysm'u=r":"JWweve, f s -me l
p.rwiyuay se sewen for i O<P W fa'4** I;a'+ I' i leventi that satijfy this %g4 p.f ry ed 4,L e,m4 6. L Jo , 6 :s se a d i C o.J O s
' If perforised with t lth arr m a power, it sha 1 be d ;N'.###I' #*# f*'#I k'
'wesnaQ[3 ec.,.qcc '
perforised n a ____, ractor < IU.sv. AaiutaJm4'S d*4 #' pa; ;1 g y.a ..u c Verify each rejects a load greater than monthst l or equal to its associated single largest post-accidentload,and$Q $7 29
@ gollowing load re;ection, the gyf s
gr equency is s [54.3F HZ; O L.Within [3 secones roisavi load Trejectio , the voltage is [3740)V and5[ ] V; and 0164 r c. Within 6) seconds fell ing load rejec on, the frequene is 2 [5 .8) Hz and $ (61. Hz. l- , kR 3.8.1.10 ----------- - .---NOTE------- ------- T ) This Surve lance shall not performed in MODE 1 or 2. However, er it say be / 0102 taken f unplanned events hat satisfy / this SR.
. .... L................. ...... ...... j e
Verify ch DG operating a power fact (18 months])
$ [0.9 does not trip a voltage is /
maint ned 5 [4800' Vd int and followp [ a lo rejection o" 2 710L W and;
$[ ] W.f (continued) 3.8 9 Rev 1, 04/07/95 BWR/4 STS Revision C Ms/ tar
O AC Sources-Operating 3.8 SURVEILLANCE REQUIRENENTS (continued) Y h37) SURVEILLANCE FREQUENCY SR 3.8.1. ------------------NOT@---------------- e
",= g g;r, y ; *a r y m A
- 2. This Surveillance shall not be perforised in MODE 1, 2, or 3.
7 {4,cf.8,4 I Verify on an actual or simulated loss of monthsh i
- offsite power signal:
- a. De-energization of emergency buses; ggl
- b. Load shedding from emergency buses;
"" ,4e v e e.,
SUbsyste m]
?"If el
- c. [n:uto-startsfromstandbyconditionf a
a O
- 1. energizes pe nently connected loads in s seconds, g
' 2. energizes auto-connected s utdown 9h I40**UC # cap bgg
{ , (Ml Y g
- 4. frequency 4 maintai)ns steady spate $Hz, and 2f58.8 Hzand5j%1. X6
- 5. supplies permanently connected and aqto-connected shutdown loads for J
2@5$sinutes. (continued) Rev 1, 04/07/95 3.8-10 BWR/4 STS . (~ Revision C
f\ O AC Sources-Operating 3.8.1
}bI g I
SURVEILLANCE REQUIREMENTS (continued) SURVEILLANCE FREQUENCY Cf LS1M w-------------------NOTI @--=ysS b ----
=--
+
h.T . S.(SRn 3.8.1 fl. 1 DE otrts may be # tcoded by ag c engintJrelube perif.f
)c AI
- 2. This Surveillance shall not be y nerfor=ad i5 MODE 1 or 2. er, paken 1his fgun nned CL6S Cere#<
evfnts_thmay satisfy _.
----- g i
l y E Verify on an actual or simulated Emergency months , l Tg'g'{- ) Core signal Cooling each System (ECCS) initiation [DG au o-starts from standby I L Qpep}conditionjand: pays iie (s .
- a. In s )<-
q] Sc ) seconds after auto-start l
, an ag tests, achieves voltage (7{r egggwey]
V Gnd uf 458W, [rn l1)' ( 3749 " fg
- b. Afis [12 econg(~ , fter auttPstaro 74 tand du a taMsJ !chievesgrequency '
e {V} 2 p .8),Hz and sj[61.2) Hz: y K IteAdy m.te Vo lto.g e ;
- c. Operates for 2 45). minutes; h 37## amd
- d. Permanently connected loads remain energized from the power , S 44@ Y *%
systes; and b
- e. Emergency loads n auto-connecte hrnun N'aut.izea ti) ,(yeggryg q,pouper rom the g +
+ ) 1 (continued) b i% 4:k 4, b5cv: ee d seqa v ce Rev 1, 04/07/95 3.8-11 BWR/4 STS m
t Revisien C k -)
l f O AC Sources-Operating 3.8. SURVEILLANCE REQUIREMENTS (continued) FADI
@ l SURVEILLANCE FREQUENCY n
SR 3.8.1.$ ----- -NOT l MomentarytransienTsoutsidetheload k and power facter ranges do not invalidate this test. L armed a a t atinfv in ta
~~ ~ ~
Eg3 ds sf* * (s'4'iC *C Verif each operati (Ehl power factor M sonthsf g7 h e.# operates for 2 @ rs: _
- a. For 2yhours oaded 2 M and A ttWO l
- b. F hours of the tes n
g ,or the oa.dy remaint and a n =} SR 3.8.1.15 --- # --- --NOTE!
- 1. This surveillance shal be perfomed within 5 minutes of s ting down the DG after the DG has rated CL32 2 (1710) kW and g rgloeded Momentary transi ts outside of load range do not in 11date this, test. ,
- 2. All DG starts be preceded by an !
engine prol < period. . Veri each DG : rts and achieves, in (18 mon %s) I
$ 11 seconds.
5 Itagey2[58.8 2 [3740))V and Hz and ) i
,451.2;VandfItr.
i ar. . . s , I f j j (continued) 8WR/4 STS 3.8-13 Rev 1. 04/07/95 ! Revision C O I
O AC Sources-0perating 3.8.1 SURVEILLANCE REQUIREMENTS (continued) SURVEILLANCE FREQUENCY bB2. ["SR3.8.1.18 - -
.-------------NOT - - - - - - - - - - - - - - -
is Surveillance s 1 not be perfo in MODE 1, 2 or l However, credi y i be taken for u anned events th satisfy j this SR. l
- 1 I
Verify into 1 between each se cod [18 months) load bloc s within i [105 of sign interval (for each load se cortimer) i
---------NO SR 3.8.1.
+ w w.bT -------------
-, <----Ogg g A-2 This Surveillance shall not be performed in MODE 1, 2. or 3.
ha s sS O ...._ .===- - - - . _ Verify, on an actual or simulated loss of months [4'9' 0'4] 6fWTTh power signal in conjunction with an actual or simulated ECCS initiation signal: ug7
- a. De-energization of emergency buses; :
- b. Load shedding from emergency buses; h Sub r/r6e@
uto-startsfromstandbycondition{ > fjg
- 1. ' energizes pq ently connected loads in s geconds,
- 2. onergizes auto-connected
-(M9] seeraency loadsJthro p p f Q Mg-(_sequ3ptop geq u e , ,,,, J
[(continued) 3.8-15 Rev 1, 04/07/95 BWR/4 STS Revision C
r- ] l L h JUSTIFICATION FOR DIFFERENCES FROM NUREG 1433 REVISION 1 Q- ITS: 3.8.1 - AC SOURCES OPERATING 1 != l RETENTION OF EXISTING REQUIREMENT (CLB)
)
CLB9- (continued). f a when refueling interval surveillances are performed during power 1 operation, licensees give pro mr regard for their effect on the safe l- operation of the plant. If t1e performance of a refueling interval
- -surveillance during plant operation would adversely affect safety, the -
licensee.should postpone the surveillance until the unit is shutdown for-the refueling or is in a condition or mode that is consistent with the safe conduct of that surveillance". Subsequent Notes have been renumbered as applicable. PLANT SPECIFIC WORDING PREFERENCE OR MINOR EDITORIAL IMPROVEMENT (PA) ! PA1 Changes have been made (additions, deletions, and/or changes to the NUREG) to reflect plant specific system / structure / component nomenclature equipment identification or description.
'q b PLANT SPECIFIC DIFFERENCE IN THE DESIGN (DB)
DB1 The onsite, source of AC electrical power at JAFNPP is provided by two redundant emergency diesel generator (EDG) subsystems, Division 1 and ; Division 2. Each EDG subsystem consists of two Emergency Diesel ! Generators. This change is reflected in ITS LC0 3.8.1.b. in the proposed ACTIONS as well as the associated Surveillances. Based on ; these differences in design, each EDG subsystem is tested in a forced parallel configuration. l L DB2 The JAFNPP AC Sources do not include an automatic sequencer. The LCO,.
-associated ACTIONS, Surveillances, and references to the automatic sequencer have been deleted. The verification that the emergency loads are auto connected in the prescribed sequence will be evaluated in
-accordance with ITS SR 3.8.1.10, SR 3.8.1.12, LC0 3.3.5.1 and LC0 3.5.1.
The subsequent requirements have been renumbered where applicable to reflect this change. l DB3 Not used. l im L(" j'- JAFNPP Page 5 of 8 Revision C
r7 - j
\
JUSTIFICATION FOR DIFFERENCES FROM NUREG 1433. REVISION 1 ITS: 3.8.1 - AC SOURCES - OPERATING DIFFERENCE BASED ON APPROVED' TRAVELER- (TA) TA2 '(continued)l
~
' minimum voltage and frequency within 10 seconds. The minimum and maximum voltage and frequency ranges are applicable only to steady state operation' .
DIFFERENCE BASED ON A SUBMITTED. BUT PENDING TRAVELER (TP) None
. DIFFERENCE FOR ANY REASON OTHER THAN THE ABOVE~(X)
XI ITS 3.8.1 Required Actions B.3.1 and B.3.2 bracketed Completion Time has been revised to reflect changes to CTS 4.9.B.5, which 3rovided the Completion Time of 24 hours (L5) to determine that OPERABLE EDG l subsystems is not ino>erable due to common cause failure or demonstrate EDG sudsystem OPERABI_ITY. l
'X2 ITS SR.3.8.1.2 bracketed EDG voltages (= 3744 and s 4400) and frequencies'(= 58.8 and s 61.2) requirements at. steady state conditions have been provided consistent with values provided by plant engineering calculations.
-X3 ITS SR 3.8.1.3 bracketed EDG loading requirements have been provided consistent with changes identified in' CTS 4.9.8.1 (L3).
X4 ITS SR 3.8.1.4.-a new requirement.(H2), bracketed EDG day tank _ content' requirement (327_ gal) has been provided consistent with the format of NUREG 1433. Revision 1.
-X5' .ITS SR 3.8.1.5, a'new requirement.(H2) bracketed Frequency (31 days) requirement to check the EDG day tank for water has been provided
~ consistent with the format of NUREG 1433 Revision 1.
X6- 'ITS SR 3.8.1.7,'a new requirement (H2), brackets have been removed and
-the requirements to verify automatic and manual-transfer of the plant
)ower supplies from normal to reserve power at a Frequency of 24 months las been provided consistent with the format of NUREG 1433,' Revision 1.
-X7- -ITS SR 3.8.1.8,-'a new requirement (M2), brackets have been removed and the applicable requirements to verify the capability of each EDG to- l
' reject a load greater than or equal to its associated single largest
.JAFNPP Page 7 of 8 Revision C 1
i 'q JUSTIFICATION FOR DIFFERENCES FROM NUREG 1433. REVISION 1
?
j ITS: 3.8.1 AC SOURCES - OPERATING ,
. DIFFERENCE FOR-ANY REASON OTHER THAN THE AB0VE (X)
-X7 -(continued)
' post accident load at a Frequency of 24 months has been provided consistent with the format of NUREG 1433, Revision 1.
X8 LITS SR 3.8.1.9, SR 3.8.1.10, and SR 3.8.1.12, bracketed EDG voltage,
; frequency, loading time and duration requirements have been provided.
. consistent with changes identified.in CTS 4.9.B.4 (M9).
X9 ISTS SR 3.8.1.14 requires each EDG operating at the required power factor to operate for a 24 hours. ITS SR 3.8.1.11, a new requirement (H2), requires each EDG o mrating at the required power factor to operate for > 8 hours. T1e 8 hour duration for this test is considered sufficient to demonstrate EDG Operability. This change is based on the requirements of IEEE Standard 3871995, "IEEE Standard Criteria for Diesel Generator Units Applied as Standby Power Supplies for Nuclear Power Generating Stations." IEEE Standard 387 1995, Section 7.5.9 and Table 3 for the endurance and load test conducted during shutdown / refueling once every two years, state to demonstrate the load ,v Q carrying capability for an interval of not less than 8 hours, of which 2 hours should be at a' load equivalent to the short time rating of the
' diesel generator and 6 hours at a load equivalent to the 90100% of the continuous rating. The IEEE Standard 387 1995. Section 7.5.9 and Table 3 state for the pre operational test, to use 2 hours and 22 hours.
Since the pre o rational test of the diesel generators has been completed at JA NPP and 24 hour duration testing has been successfully performed, an 8 hour duration has been included in ITS SR 3.8.1.11 instead of the 24 hours duration included in ISTS SR 3.8.1.14 for this test. X10 ITS SR 3.8.1.6, brackets have been removed and the requirement to verify automatic operation of each fuel oil transfer system has been included
., consistent with changes identified in CTS 4.9.C.2 (M13).
-X11- ITS 3.8.1 Required Actions A.3 and B.4 second Completion Times have been revised to reflect changes to CTS 3.9.B.1 and 3.9.B.3, which added the l second Completion Time of 21 days from discovery of failure to meet the LC0 (M4).
-X12 .ITS SR 3.8.1.6, brackets have been removed and the Frequency of 92 days l has been: included consistent with changes identified in CTS 4.9.C.2 l- (L10).
X13 ITS 3.8.1 Action C.2 to reduce THERMAL POWER to < 45% RTP in 36 hours l Atg has been added consistent with changes identified in CTS 3.9.B.2 (MS).
.JAFNPP Page 8 of 8 Revision C e
p i i b lq Insert BKGD P7 The onsite standby AC ower sources for 4.16 kV emergency buses 10500 and 10600 consist of two i dependent and redundant EDG subsystems that are self contained and independent of normal, backfeed, and reserve sources. Each EDG i subsystem consists of two EDGs which operate in parallel and are dedicated to ! an emergency power division (1 or 2). The Division 1 EDG subsystem consists i of EDGs A and C and is dedicated to emergency bus 10500. The Division 2 EDG ' subsystem consists of EDGs B and D and is dedicated to emergency bus 10600. The EDGs start automatically on an emergency bus degraded voltage signal, an emergency bus undervoltage (LOP) signal, or a loss of coolant accident (LOCA) signal (i.e., low low low reactor water level signal or high drywell pressure signal). ' As a consequence of a LOP or degraded voltage signal, independent of or coincident with a LOCA signal, the emergency bus undervoltage control logic starts the EDGs. Coincident with the EDG starting and force paralleling, the emergency bus undervoltage control logic trips the 4.16 kV emergency bus tie breakers, trips the emergency bus load breakers (except for the 600 V
. emergency substations). and provides a close permissive signal to the EDG output breakers. The EDGs are automatically tied to their respective emergency buses and if a LOCA condition exists loads are sequentially ' connected to the emergency buses by the programmed restart time delay relays.
The programmed restart time delay relays control the permissive and starting signals to motor breakers to prevent overloading the EDGs. On a LOCA signal alone the EDGs start, force parallel, and operate in the standby mode without tying to the emergency bus. A 3g Insert BKGD P9 V While each emergency power divisioi; is designed to be supplied by an EDG pair, if one of the EDGs within an EDG system were to fail during a LOCA event in l conjunction with a LOP, the programmed restart logic will not start the second residual heat removal pump powered from the 4.16 kV emergency bus associated with the failed EDG so that the remaining EDG in that EDG subsystem is not overloaded. I g V Insert Page B 3.8 2 (ITS Submittal Rev. C)
1 l AC Sources-Operating 8 3.8.1 W LC0 din a ion [oq(requireff automatfc load secuenstr oar rtr (continued) thus] s 11 be OPERABLE.]/ wensese-v3 Qcserwe circuit must be capable o intaining rated frequency and voltage, and accept 1 irequired loads during an accident, while_ connected to the 8 buses.Jtac orrsit si...is sensipsa er in. ing ..- r u a i ......ac to the respective P4 and to SATs, the and 20 transfo es, and ! rWp T the res 4.16 kV we circuit path i buses. Feeder bre ludi feeder bre es rea each ci uit are es to 1 i
)
83.f,ll%~i required the 2F ESF bus; h ver, if 2C 5AT i connected to ESF b 2E (or 26) and 20 T is connected t 2G (or 2E) i the -- inine breakers to 2 and 2$ are not uireg ' i u sPJtem Each must be capabl of starting, ccelerating o russo
@*
- voltage..a onnecting its respectiv us '
on ostection of Dus undervoltage. s se enc must be Qa'cc Pa"I'*8'"3[ accomplished within seconds. Each s a so be wr34 capable of accepting required loads within the assumed loadle seguence intervals, and must continue to operatd ej unti' apuwpower can be restored to theQbuses._ These capabilities are required to be met F a vprivsi n O Ma g D(r s pnyi - -- nma in m hv with thaAna% har #a -i-u -- -nsA n standby with the enginegat amoient concluionA AdditionhDG capabilities must be demonstrated to. ant . _ _ h required Surveillances, e.g., capability of O e JETto d;g (p#*"*'**# 2:enman'dJ '- ~ "'" """"'""" 87 Proper sequencing of loads, including tripping of g ot a. c*e c ure nonessential loads, is a required function for f OPERASILITY. The AC sources must be separate and independen to the extent possible) of other AC sources. For the DGs, the separation and independence are complete. For the 6 [,ggd 'P'tammen, the separation and independence are to the c; n,;43 ertent practical. F mun may y .gt trans... ..
=we -=I et
._ zar s, wisn ra nat vialata b_ a*=+y to ei*4*-
pes w d G_tecuit raamt r = ircuit that is not connected to an 4aa
. is A 4@
..w.n==__to have OPERABLE transfer interl mechanisms to fiF118 bus $ o support OPERA 81LITY of that circuit.
Qu t.4& St w O *
- p (continued)
B 3.g.4 Rev 1, 04/07/95 BINt/4 STS Revision C
AC Sources-Operating B 3.8.1 BASES (continued) b phb y
\ ' S/
APPLICA8ILITY The AC sourcesfangsequenc6s_Dare required to be OPERABLE in MODES 1, 2, anc 3 to ensurT that:
- a. Acceptable fuel design limits and reactor coolant pressure boundary limits are not__ exceeded as a result of M or)abnormalktransients; and g % ., 4
- b. Adequate core cooling is provided and containment OPERABILITY and other vital functions are maintained ,
in the event of a postulated DOA. l The AC power requirements for MODES 4 and 5 are covered in LC0 3.8.2, "AC Sources-Shutdown." ACTIONS L1 To ensure a highly reliable power source remains with one (offEfs) circuit inoperable, it is necessary to verify the availability of the remaining,,reauirse ofM1tekircuit on a c5c/ V e ) more frequent basis. Since the Required Action only specifies "perfors," a failure of SR 3.8.1.1 acceptance O. - criteria does not result in a_ Required Action not met. nowever _if a second w gurrea/ circuit fails SR 3.8.1.1, the ( secondirwi2 circuit is inoperable, and Condition C, for twoNffsits7 circuits inoperable, is entered. [{ueW M m Required Action A.2, which
\ (Subsyste F
onlyapplicslifthedivision
) h7e cannot be powered from a Wur t source is intended to um .e_]
nrovide assurance that an event with coincident single Or __ failureofsneassociatedJpGgdoesnotresultinacomplete less of safety function of critical systems. ' These features are designed with redundant safety related divisions (i.e., single division systems are not included). Redundant required features failures consist of inoperable features g g e g 4_, associated _.with a division redundant to the division that s o me, - hasnoffsin,,powtr> The Completion Time for Required Action A.2 is intended to
. allow time for the operator to evaluate and repair any (continued)
B 3.8-5 Rev 1, 04/07/95 8WR/4 STS Revision C
O AC Sources-Operating B 3.8.1 Y aASES ACTIONS L 1 (continued) eSede?"*d
~_
reliabilityofthe(ffsWe'ssM(is degraded..and the {yeserde L _notential for a loss of ffs1 power is increased, with attendant potential for a c a lenge to the plant safety rstems. In this condition, however, the remaining OPERABLE QQ TMu> circuit and DGs are adequate to supply electrical newer to the 1 1E Distribution System. g ,-g Q O The Completion Ties takes into account the capacity NI and cap ity of the remaining AC sources, reasonable time for repairs, and the low probability of a DBA occurring during this period. The second Completion Time for Required Action A.3 V establishes a limit on the maximum time allowed for any i combination of required AC power sources to be inoperable durina any single continuous occurrence of failing to meet the LC0. If Condition s entered while, for instance, ADGgis inoperable, and tha , s subsequently d'em crtweQ urtnAalF. the LCO say alrea . ave been not met for up to b"Y g B is situation could lead to a total of M since initial failure to meet the LCO, to restore O g h/5 t Pgap circuit. At this stas,
-nopera) e, the circuit tored OPE DG ould again become LE and an additional /
ys) allowed ortor to complete i p,.s6*Ig (for a total o U ation of the LCO. y Completion Ties provides V'gyv a limit on the time allowed a specified condition after p3 do# discovery of failure to meet the LCO. This limit is Kr? considered reasonable for situations in which Conditions A and B are entered concurrently. The 'R E' connector between pg i;ne U2 nouPS AnO6 day CoEpletion Times means that both i C7 N g y Completion Times apply simultaneously, and the more restrictive Completi aust L bg$ug
,g, TA- .2, E*c4 the Completion Time allows for an Required Action (51,wuar t ion to the nomal ' time zero" for beginning the allowed outage time ' clock." This exception results in establishing the ' time zero" at the time the LCO was '
. initially not net, instead of at the time that Condition A was entered.
(continued) B 3.8 7 Rev 1, 04/07/95 BWR/4 STS Revision C l l
( AC Sources-Operating 8 3.8.1 8ASES J ACTIONS M ar (subevste@ (continued) \ ToensureahighlyreliablepowersourceremainswithoneDGf _ inoperable, it_ is necessary to verify the availability of (yese7ve7 the reau wsu eMsTID circuits on a more frequent basis. 1 Since the Requ' red Action only specifies "perfore," a failure of SR 3.8.1.1 acceptance criteria does not result in a Required Action being not met. However, if a circuit fails to pass SR 3.8.1.1, it is inoperable. Upon offsite circuit inoperability, additional Conditions must then be entered. M (9esyste@ Required Action B.2 is intended to provide ran that a noss of qH s inoperable,tBE> power, during the period tnadoes not result in a complete los function of critical systems. These features are designed /\ with redundant safety related divisions (i.e., single /c\ division systems are not included). Redundant required features failures consist of inoperable features associated g with a division redundant to the division that has an me,e,ameg , The Completion Time is intended to allow the operator time to evaluate and repair any discovered inoperabilities. This Completion Time also allows for an exception to the normal
' time zero' for beginning the allowed outage time " clock."
In this Required Action the Completion Time only begins on discovery that both-
- a. An inoperable exists; and QudavM} b. A irodfeatureontheotherdivision((Divjsfon13 l is inoperable. A L _
_ If, at any timelduring the existence of this Condition (one
/g W inoperable), la required feature subsequently becomes rable, this Completion Time begins to be tracked.
OIO8/#1* h Discovering one inoperable coincident with on g or more inoperable required support or support ures,
- or both, that are associated with the OPERABLE results in starting the Completion Time for the Requi ion.
Four hours from the discovery of these event isting
.(continued)
BWR/4 STS 8 3.8-8 Rev 1, 04/07/95 Revision C
i AC sources-operating 8 3.8.1 BASES i ACTIONS L1 (continued) concurrently is acceptable because it minimizes risk while allowing time for restoration before subjecting the to transients associat with shutdown. % ti i (5%sys *e un sg g The remaining OPE DEigfan4ptsefth circuitsJare adequate J to sunoly electrical power tof theplass IE pi Distribution system. inus, on a component' basis, single Afailure protection for the required feature's function may "C'$' have been lost; however, function has not been lost. The 4 hour Completion Time takes in'to account the component OPERASILITY of the redundant counterpart to the inoperable required feature. Additionally, the 4 hour Completion Time takes into account the capacity and capability of the remaining AC sources, reasonable time for repairs, and low probability of a 08A occurring during this period. 1 a.1.1 nd a.1.1 e Q ussysu Required Action B.3.1 rovides an llowance to avoid J O unnecessary test o ERABL detemined that the ause of the ino rable exist on the OPERABL SR 3.8.1. If it oes' no n be ces not avetobe) [M 6% -b6 subsyste,j oerfomed. If the e s of inoperability exists on other DEW . De arp declared inoperable upon discovery, and LsusYs te"' '8 cond tion E of LC0 3.8.1 is entered. Once the failure is repaired, and the common cause failure no longer exists, p \ init< rod Raou< Action 8.3.1 is satisfied. If the cause of the al inoperable 70G annot be confimed not to exist on tne remainingADG rfomance of SR 3.8.1.2 suffices to con ued OPERAaILITY dhowurag hu bsystemV provide assurance j In the event the inoperabTe OG is restored to OPERABLE status prior to completing either B.3.1 or B.3.2, theTplant corrective action progras@(.will continue to evaluate the 1 common cause possibility. This continued evaluation, however, is no longer under the 24 constraint kaaed 1 while in Condition 8. 3 g_y ; 4 According to Generic Letter 84-15 (Ref. 7), A4 ' hours not is a reasonable time to confim that theg0PERABLE affected by the same probles as the inoperable (iw ,}:Q ___ y\ abdM (156 .su s syst eu s gg, (continued) Rev 1, 04/07/95 O 8WR/4 STS B 3.8.g V Revision C
O AC Sources-Operating B 3.8.1 r BASES f (fk.Asism .4 th e. A c. s.u v.es suaws) [6Dt A. Labsyste m " 3> ACTIONS Li b (continued decordinar to Reediatory Guid1 et (n-r 6D operation g to e ntinue in Condition 5 for a period that should not excee - 4 In Condition B, the remaining OPERABLE @ anc c (fgc/4 ..elcircuits are adequate to supply electrical power D <ser4 tha morte Class IE Distribution System. The Uzwourr e.J 603 ospletion Time takes into account the capacity and
@ " *- f capability of the remaining AC sources, reasonable time for LG repairs, and low probability of a DBA occurring during this period. 7jer* O 3.9 t Acn o b B . G.__
h_
- 5" *_ The second Completion Time for Required Action B.4
- establishes a limit on the maximum time allowed for any combination of required AC power sources to be inoperable duri any single contiguous occurrence of failing to meet tio t .
If ' indition B is entered while, for instance, an circuit is inoperable and that circuit is ,_eserv _ subsequentiy restored?SPERABLE, the LC0 any already have 7 ct fs} - This situation could lead M' Dean not set for up flNZ@ since initial failure of the LC0 2 / d efyops a total restore of f44Aoutp, the y At this , an Otta na circuit could A N again become inoperapie, the restgred OPERA 8LE, and an /c\ (,) " "M * * =M itionalczz nours (for a to 1 ofGTanys) allowed ortor to complete restoration of the LCO. The@any completion Time g i l 7 cla ys provides a limit on the time allowed rn a specified condition after discovery of failure to meet the LCO. This X r 2. i limit is considered reasonable for situations in which
' Conditions A and B are entered congurrently. The '8lE' 4
'd dW connector between Ine g2 hout ana t) day Completion Times means that both Completion 11 ass apply simultaneous 1v. and _ _ _ _
l a nd y.i the more restrictive must be met. { eyge) [Sim lav ti)QO Required exception to the Action normal "B.2, the for time zero" Completion beginning the TimeAallows allowed outage time ' clock." This exception results in 74I for. establishing the ' time zero" at the time that the LCO was initially not not, instead of the ties that Condition B was entered. c.1
. Required Action C.1 addresses actions to be taken in the event of inoperability of redundant required features h
(continued) B 3.8-10 Rev 1, 04/07/95 BWR/4 STS Revision C P
pi . C.L 8 7 Insert B 3.8.1 ACTION B.4 In addition, e 14 day completion time is based on a risk informed assessment of the EDG subsystem inoperability. EDG system inoperability and the simultaneous inoperability of other plant equipment is assessed in accordance with- Specification 5.5.13, Configuration Risk Management Program (CRMP). 4 Os - Insert Page B 3.8 10 (ITS Submittal Rev. C)
AC Sources-operating : B 3.8.1 1 8AsES i [1) . h3 - ACTIONS c.1 and C (continued) reserVD concurrent with inoperability of two of % circuits. l Required Action C.1 reduces the vulnerabitity to a loss of function. The Completion Time for taking these actions is - i gge rv e,' - reduced to 12 hours from that allowed with one division CL B 7 without.(f!L1ppower (Required Action A.2?. The rationale for the reduction to 12 hours is that Keou.acoryRide run Guer/e> ariowoa Completion Time of avnsurnfor t id p is N _ reautred offsite circuits inoperable, based upon the Cam t ta.bl e.f assumption that two complete safe visions are OPERA 8LE. When a concurrent redundant required feature failure exists, this assumption is not the case, and a shorter Completion Time of 12 hours is appropriate. These features are designed with redundant safety related divisions, (i.e., single division systems are not included in the list). Redundant required features failures consist of any of these features that are inoperable because any inoperabilit is on a division redundant to a division with inoperable circuits. ggy The Completion Time for Required Action C.1 is intended to h O allow the operator time to evaluate and repair any discovered inoperabilities. This Completion Time also allows for an exception to the normal ' time zero" for beginning the allowed outage time " clock." In this Required Action, the Completion Time only begins on discovery that both: y ,3 ,g g _) g rocci o circuits are inoperable; and p A. , b. A required feature is inoperable. If, at any time during th istence of this Condition (two G ed % h Usn e circuits inoperabl quired feature subsequently becomes_inoperabl , this Completion Time begins ( FeS e W e to be tracked. g dFccording t(Regulator 9 GuidaM3 (RaCID fperation may CLS 9 continue in condition c for a period that should not exceed CTHiPD. This level of degradation means that the g electrical power system does not have the capability to effect a safe shutdown and to sitigate the effects of an
. accident; however, the onsite AC sources have not been degraded. This level of degradation generally corresponds
( Ve.5 evV f). (continued) BWR/4 STS 8 3.8-11 -Rev 1, 04/07/95 Revision C
AC Sources-Operatin 838-C.L t L T3 r1 BASES 1 3 N, ACTIONS C.1 and C (continued) to a total loss of the ismediately accessible offsite power sources. Because of the nomally high availability of the offsite sources, this level of degradation may appear to be more severe than other combinations of two AC sources inoperable A that involve one or more inoperable. However, two /c\ factors tend to decrease severity of this degradation level: fy, ggg
- a. The configuration of the redundant AC electrical power system that remains available is not susceptible to a single bus or switching failure; and
- b. The time required to detect and restore an unavailable power source is generally much less than that required to detect and restore an unavailable onsite AC source. g g With both of the diutiFawMb circuits inoperable, )
p sufficient onsite AC sources are avail &ble te saintain the in a safe shutdown condition in the event of a DBA or J Ih transient. In fact, a simultaneous loss of Wr AC um sources, a LOCA, and a worst case single tailure were %g.m ot postulated as a part of the desian basis " n the safety - analysis. /Thus, t z4 hour c etion T' provides rperiod o ime t effect res ration of of mainta a of the fsite I circu commen urate with t importa ning an AC e ctrical r system pable of ting its esi 7 Im5er 4 ccr ria.c Fccordt A o Regulat Guide (Ref. 6) ith the , j C m d:L'.ou ava11a e offsite sources less than equired b he A l ration may continue f r 24 hours. If two o site QC g LCO, source are resto within 2 hours, unre tricted ration l may c tinue. If ly one o site sourc is resto it within 24 rs, power peration ntinues in ccordanc 6 L B ') C ition A.7 - D.1 and 0.1 s r open. 4 Pursuant to LC0 3.0.6, the Distribution Syst ACTIONS would not be entered even if all AC sources to it were inoperable, (continued) Rev 1, 04/07/95 BWR/4 STS 8 3.8-12 Revision C
q CL8 9 Insert Condition C { Required Action C.2 is intended to reduce the consequences of a DBA or
' transient event by requiring a reduction in THERMAL POWER to < 45% RTP, The
- limit of < 45% RTP ensures sufficient xwer is available to support operating onsite loads, maintains stability of tie 345 kV transmission network, maintains stability of the reactor feedwater system by allowing both feedwater
- ' pumps to be in service, and retains the reactor scram associated with a turbine trip above 29% RTP. The 36' hour Completion Time allows normal plant l
operations to continue for.approximately 24 hours prior to initiating any transient'and still allows approximately 12 hours to reduce THERMAL POWER to <
~
454 RTP. in an orderly. and carefully controlled manner. The 36 hour Completion Time also allowr more resources:to be dedicated to restoration of at least one reserve power source during the first 24 hours after entering Condition C than would be possible if a power reduction to' < 45% RTP was required within some shorter time period:and thus allows sufficient time to correct any minor inoperabilities'without commencing a plant shutdown. The 7 day Completion-Time in Required Action C.3 provides a neriod of time to effect restoration of- l-both reserve circuits commensurate with the importance of maintaining an'AC electrical power system capable of meeting its design criteria.
;With the AC sources, reserve circuits, two less than required by the LCO, operation may continue for 7 days if both reserve circuits were found to be
' inoperable concurrently. In this situation Conditions A and C must be entered l
- concurrently. If both reserve circuits are restored within 7 days, unrestricted o C : within 7 days,peration entry intomay continue.
Condition F is-If only one reserve required. circuit circuits If the reserve is restored l were not found to be inoperable concurrently, the Completion Time of Required
- Action A 3 must be met for the first inoperable circuit in accordance the guidance;of Section 1.3-(Completion Times). This will ensure that the maximum time two reserve circuits could be inoperable simultaneously without entering Condition F:is limited. l 1
Insert Page B'3.8 12. (ITS Submittal Rev. C) 1
AC Sources-operating B 3.8. BASES b V ACTIONS o.1 w 3.2 (continued)
. resulting in de-energization. Therefore, the Required Actions of Condition 0 are modified by a Note to indicate n k that when Cw $1 tion 0 is entered with no AC source to an 1 bus, ACTIONS for LC0 3.8 7, " Distribution (4g Systems-Operating,' must be immediately entered. This ewenemc/ allows Condition D to provide requirements for the loss of 1 A
' circuit and one DGavithgpt regard to whether a -J /c\
divis on s de-energized. C0f3.8 & provices tne gem appropriate restrictions fo a de-enernized division. V Vsosyse_esg l 1.93(Ref.W),operationmay l recow.%,;.,,h> According to)tegulatory Guicontinue in Condition D for a period that should
.g .
12 hours. En Condition D, individual redundancy is lost in _both MtD electrical power system and the onsite AC h electrical power system. Since power system redundancy is rO8" E provided by two diverse sources of power, however, the
-reliability of the power systems in this Condition say 1
I appear higher than that in Condition C (loss of both c,. __uiras-errs 13p circuits). This difference in reliability is offset by the susceptibility of this power system /7 configuration to a single bus or switching failure. The () 12 hour Completion Time takes into account the capacity and capability of the remaining AC sources, reasonable time for repatts, and the low probability of a 08A occurring during this period. O g %. rte *@ ow. nee 7_ Mith tuo > inoperable here is remaining AC source. Thus, with an assumed loss o offsite electr cal power, insufficient E sources are available to epear eM power the minimum reou redfS) functions. Since the offsite
.w(qws s/ electrical power system 1s the only source of AC power for the majority of ESF equipment at this level of degradation, the risk associated with continued operation for a very short time could be less than that associated with an immediate controlled shutdown. (The inmediate shutdown could cause grid instability, which could resul in a total loss of AC power.) Since any inadvertent rator trip could also result in a total loss of offs te AC power,
. however, the time allowed for continued peration is severely restricted. The intent here i to avoid the risk Sh. d)
(continued) Rev 1, 04.07/95 BWR/4 STS B 3.3 13 Revision C
AC sources-operating 8 3.8.1 BASES fkD ACTIONS L1 (continued) associated with an immediate controlled shutdown and egradto on. minimize the risk associated with thi Q_
. Vecom m eat;oh Acconding to[ Regulatory Guide 1.93 ( . , h both inoperable, operation may continue for a period that should g not exceed 2 hours. (?b rgreems;)
'^^
(s) is an essential s port system to the The se offsite rcuit and the DG assoc ted with a given AF bus.] I ccess [Furt more, the sequencer (s) s on the primary systems f pat for most major AC electr ally powered safe red from the associated Fbus.] Therefo , loss of an I s every major ESF stem in the l l ','dvistor). Fbus'ssequencer;aff The[12 hoCompletion Time pro ides a period l hD vD o time to correct the robles commensurate wfY.h the sportance of mainta" ng sequencer OPERA 81LI' This time l 4 hat the probability of i accident l O period requiring also ensure OPERABILITY occurring du ing periods sequen when the sequen r is inoperable is minimal
/ This Conditi is preceded by a Note th allows the Condition t be deleted if the unit gn is such that any ,
sequencer ,ailure mode only affects ability of the y associa DG to power its respect e safety loads unde the condit s. Implicit in this Not is the concept th mode Cond~ ton aust be retained if an sequencer failu a safety re ts in the inability to sta all or part of 1 s when required regardless f power availabf1 y, or sults in overloading the of site power circuit t: a safety Liso bus during an event thereby'the ausing its Condition is failure. applicable implicit in the Note is t not have e sequen . _ to any division that doe 1 -kM2 If the inopei.ble AC electrical power sources cannot be restored to f*ERABLE status within the associated Completion Time,theq st be brought to a MODE in which the LCO o achieve this status, t must be does not app,y. o MODE 4 brought to at lea MODE 3 within 12 hour a
" (continued)
Rev 1, 04/07/95 B 3.3 14 BWR/4 STS Revision C
l O AC Sources-operatin 5 3.8 BASES / ACTIONS _ 1 mad .2 (continued) within 34 hours. The allowed Completion Times are g reasonable, based on operating experience, to reach the trod plant conditions free full power conditions in an o fly manner and without challenging plant systems. G 6e tion corresponds to a level of degradation in which d all ancy in the AC electrical power supplies has been lost. At this severely degraded level, any further losses in the AC electrical power system will cause a loss of function. Therefore, no additional time is justified for continued operation. The ( is required by LC0 3.0.3 to comence a controlled shutsown. p.,g smsYsteAD (2a pr.sud l O SURVEILLANCE REQUIRDIENTS The AC sources are designed to testing of all important areas a ruit inspection and (c,4rm.4 features, especially these that have a standby function, e accordance with I
,Rferu.c lNU wm no. uu6 is mar. m. Periodic component tests are supplemented Dy extensive functional tests rin g TV of denen theA05
;tratina are im sener== aout the Urr.iiABIL
= for The SRs s (under simulate A{,Q with ',he recommensan ens o' Regulatory Guide 1.108 (Ref. ), and Guide 0 9 (Ref. 3),
latory Guide 1.137 (Ref. 10)in --- - -'in snsw. J r A .ty r w ev. ) s ~~.~ g Where the $Rs discussed herein specifyAveltase and_frequenc X
- tolerances, the fellowing sumary is applica61L/The b5-W Y ye As^ l sintaus steady state output voltage of (!L43 V 15 the nominal 4160 V evtput volt . This vaTue, whic
'f s
O*d specified in AN5! C84.1 (Ref.
, allows for voltage operatingdrop ,F g g 1 to the teminals of 4000 V asters these minimum M voltage is specified as 305 er 3600 V. It also allows for w itage drops to actors and other equipment down through the x 4" 120 V level where minimum operating voltage is aise usually specified as 305 of name plate rating. The specified Wo maximum steady state output voltage of f is equal to the anxious operating voltage specified r V motors.
It ensures that for a lightly loaded distribution system.
.the voltage at the terminals of 4000 V actors is no more than the anximum rated operating voltages. The specified (continued)
B 3.8-15 Rev 1, 04/07/95 IWR/4 STS Revision C
.n, v , e
l l O AC Sources-operating l l B 3.8.1 l BASES @ SURVEILLANCE minimum and maximum frequencies of the DG are 58.8 Hz and l REQUIREMENTS 61.2 Hz, respectively. These values are equal to t 2% of I (continued) the 60 Hz nominal frequene and are derived from the recommendations found in Guide @ (Ref. 3).} fafc9 1R 3.a.1.1 This SR ensures proper circuit entinuity for the hAC _ _ gym, electrical power supply to the 3 distribution networkycrere] and availability of a natazac elocurical power. Ine breaker alionment_ver fles that each breaker is in its 'M "' F c a 2 /* ' ,, ,, L correct position t nsure that * - s buses and loads are connected to the VfP58 power source and that a
#gp appropriate independenc4 o" annrarctreuits is maintained ,
( G II2 I M,,,, C The 7 da Frequency is adequate since breaker position is not like y to change without the operator being aware of it l and because its status is displayed in the control room.g Ele s. rT _T - 3 IE N SA 3.R.1.2 and 3R A.a.1 M w.5 6 She help ensure the availability of the q electrical power supply to mitigate DOAs and transients and j maintain the g !I in a safe shutdown condition, g3 TTo sintatz the wear on movi parts that do not get I lubricat when the engine i not running, the SRs have been fled by a Note (No 2 for SR 3.8.1. and Note 1 for SR 8.1.7) to indicate hat all DG sta s for these Survell' es any be proc by an engine p lube peri fo7ewedbyavaraus for to loading. Forthepunosesofthistesting,thefDGsarestartedfrom standby conditions. Standby conditions for plDE mean tha the diesel engine coolant and oil are being tuRtTnvously circulated and temper 6ture is being maintained consistent with annefacturer receamendations. e -3 In order stress and wear diesel engines,
; anauf recommend a modift tart in which the starti of DGs is lietted warsup is lietted o this DB'I. 1*=or . =8 the oss are er 11r accelerstd a synch s speed prior to leadi . Inese start recedures are the ntent of Note 3, which s only applicabl when such modifi start procedures are aded by the nufacturer.
(continued) S 3.5-16 Rev 1, 04/07/95 IWR/4 STS Revision C
m g V Jfsert B SR 3.8.1.1 A Reserve circuit alignment verification can be accomplished by verifying that a reserve circuit is energized and that the status of reserve circuit supply ) breakers and disconnects displayed in the control room is correct. Reserve ! source Mohawk,forpower availability the Nine can Mile' Point beOne Unit verified by communication switchyard with Niagara and South Oswego substation, and the New York Power Pool for the Light House Hill rubstation. j I
]ft3 Insert B SR 3.8.1.1-B
-In-addition, the requency is adequate since administrative controls are in
- place which require plant notification of distribution system problems affecting power availability, from both Niagara Mohawk and the New York Power Pool.
i l I l-Q' - Insert Page B 3.8 16 (ITS Submittal Rev. C) l.
i h *AON+ +. we s e r4 go , .,,w, % e,,,, 9, # 2-
* * # " * * " * " * ' N y 5 *.
- c. o pe r < ,. ,,.
..g et c .,,,,4 e s.iu, ,,4 ,o AC Sources-0perating
$4***4/degn.h.t..
4g.s,, ,4'* 8' '^ "f m%re d 8 3.8.1
**d ' Age w r
? u .c <. pmlt etQ SURVEILLA,4CE st us t 3.3.1.2 Enn su 253.1.7)f(contin ed) requires that, at t y Frequency, thelDG starts from standw conditionsAand achieves required voltage The 9 second start rts the assumptio ign basis
@ 7 and frequency wittin 7 seconds.
reautrement s econ 7 ux;A analysis of F5AR,not Section appinasis46. [(Ref.12). Jhe an 4.s.a.z (s IzNote3q g 6.rs . . . i. - ..s of SR 3.8.1.2). n a modified sta procedure as de ribed , above is used, a modified start is not used. th 12 <=ceneu ( ' start since e--"1
.s.l.i ooes of SR 3.8.1.7 as ten >
a Iz second start t is more restri ve than SR 3.8.1 , and it may be per reed in lie
,of SR 8.1.2. This pro "en i n tha 4 a+ ==+ "a+= 1 of 3R 1. 1.1/
cL63 ("The eEP 31 day Frequency for UR 3.8.1.2Rsai Tahre 3.arl-1J
'tplane r.;;;ratorfissi . . w e": 11s consistent with
.10 bn
"^^^1 story huleeAGD(Ref.D).
3.5. .I is r.. a 6 in codfue tantinaleg as[a=rimEy
=4e+ r wit M ri Letter 84-15 i f. 711 TN Freque provide O adequate assurance of DG degradation resulting from E
ting.h,w. I hil letzing h f63 % sysee q ER 1.B.1.3 d 3
-- dQstems7 This <==am==*= verifies that theht are capable of M vau cted synchronizing and accepting greater than or equal to the with gg3 equivalent of the maximum expected accident loads. A minimum run time of 60 minutes is required to stabilize ine ,no,.w.a.L,veser e v t retures, while minimizing the time that the s_
or her, gass
} M sourse, f g m y,,, g c Althaumh no power factor requirements are established by this SR, the)DG is normally operated at a power factor between {0.8 lagging):.and .05.$1.01 The @1s an operational liettation.8$,value the nachine, ile o is the d ensure circulating currents are minimiz . The load ad isa provided to avoid routine overloading of heIDG. Routine W everloading may result in more frequent teardown inspections in accordance with vendor recommendations in order to maintain O DG OPERABILITY.
(continued) 8 3.8-17 Rev 1, 04/07/95 IWR/4 STS Revision C i t
AC Sources-Operating B 3.8.1 g RASES SURVEILLANCE SR 3.a.1.3 (continued) REQUIREMENTS
- day Frequency for this Surveillance (y ( Js consistent with flegytatN9 Guld Note 1 modifies this (GrVEFTHEta ndicat t diesel l engine runs for this Surveillance may include gradual loading, as reconnended by the manufacturer, so that mechanical stressi '
and wear on the diesel engine are inized. Note 2 modifies this W y stating that acaentary ) transients because of changing bus loads do not invalidate this test. Similarly, somentary power fac rans nts above the limit do not invalidate the test. p, ves erK R.w c s ;
,, p 4ce4 Note 3 indicJates tliat this Knechtmam hould be conducted on
@ only onelDGut a time in order to avoid common cause failures , A po w e.r gr'E that sight result from Infmtaferenume**i8 perturbationL /c\
Note 4 stipulates a prerecuis e) requirement for performanie of this SR. A successful,pG start must recede this test to credit satisfactory perfomanc st 3.a.1.4 This SR provides verification that the/ level of fuel oil in Se[mlesc( T the day tank LP--ae"w+- ? is at or above the aws .t leve1 ~~at unica -- nu -- - ~ = = = = = . The level is expressed as an equivalent volume in gallons, and is selected l ( a ., , ,, u, g j to ensure adequate fuel oil for a minimum of 1,houg of DG j operation at full load menrurs. ,g Q, % l The 31 day Frequency is adequate ensure that a sufficient supply of fuel oil is available, since low level alares are ; provided and,MTTity operators would be aware of any large i uses of fuel oil during this period. i kk st 1.a.1.5 IM i Microbiological fouling is a major cause of fuel oil ; degradation. There are numerous bacteria that can grow in ) l (continued) ! B 3.3 13 Rev 1, 04/07/95 BWR/4 STS Revision C
I l l l ( AC Sources-Operating B3.84 i saSES
'7f 3 J SURVEILLANCE ~ st 3.8.1.6.(continued) Eg REQUIREMENTS f o re ndiv SR ks.li ])g /
SR .1.2. j
'3 " 'b st 3.a.1 _
7 ) 1 G s'TQ {or h e d ec Q - b"h** 7/ransferofeach4.16kV bus power upply from the nomal L"**'dua.t j iiwie mdpto the gTternate orwitz ircuit demonstrates Q j < the vrtnABILITY of the 41tesuswircuit istribution network
.to power the shutdown loads. The preontnFFrequency of the g M.
8 ** 3 Surveillance is based on engineeri@ng judgment taking into (MSST 7/7-h consideration the plant conditions required to perfom the X6 Surveillance, and is intended to be consistent with expected y fuel cycle lengths. Operating experience has shown th t these components usually pass the SR when performed on the mont O _ g( ' Frequency. Therefore, the Frequency was concluded to acceptable from a reliability standpoint.
- s. y
-we is s modi ed by a . The re on for t te F_L,u6 that uring ration the re r critic , perf nce etg 8 of is SR d cause rturbat s to the actrical B 58 3.f.l.7 ~~~ J] di ributio systems at couldt.hallenge c inued eady NI ate o tion and as a ro elant s ety sys+ =
(Creeft aar de '=kaa forrunn' anned eve 6ts thatrsatisfy )Kis . 8h st 3.a.1.m EE Each[DGisprovidedwithanengineoverspeedtriptoprevent damage to the engine. Recovery f the trantient caused by the loss of a large load could cause diesel egine overspeed, which, if excessive, might result n a^- tri t f th engine. This Surveillance demonstrates the DG as e U h= 4cteriseTes anm capability to reject the i3rgest single load witnout exceeding.predetemined enitans wrs> frequency and A- muis maintaining a specified in to the overspeed trio.---- CLB 4 s. - The la est single lo or each is a ros' h=Vheat/enovaDf\ ' (fb7Wh pump (1 bhp . This Surve<1 ance any se accomp' ished by:' g (continued) ., BWR/4 STS. 8 3.8-20 Rev 1, 04/07/95 Revision C
AC Sources-Operating B 3.8.1 BASES f3 I uw a SURVEft. LANCE sR 3.a.1 _ continued) REQUIREMENTS ~
- a. Tripping the DG output breaker with the carrying greater than or equal to its associated single largest post-accident load while paralleled.go oprsite power, or while solel supplying the bus;(orQ',,m/,4'4eI ar tite gg U g,G
- b. Tripping its associated single largest post-accident load -
with the tx e m.w e DG solely supplyina_the@mn:nQ bus.f(zAckroenaud ( spes4 p/,s] C ows;s t e,st- wi4 as r m rea nr i" *- - _ m A ED, the load rejection test c acceptable if the chctsasMip diesel speed does not exceed 75% 5g,4. 4 673w)J a of the difference httween syncnpsnogb s eed and the overspeed cyr trip setpoint, orD 5s neove --..-a peed, whichever is pq lower. / DE A, zc no s, p s repros pcs on.s , c quiva tt 5% of he diffefence betweef nominal naad =ad f fli ?[ o f , the rsp trip tpointf g d /f6e time voltage, nd freque y tolera s specifi in this I SR are rived f Regulat y Guide . ndations for resp e during oad sequen interval. (Ref.3) / rec Th [6]seco specif is equal 60% of t; 10 secon. O __ g (es twto lo d sequene interv associated h at remova (RHR) ' gips during a undervolta oncurre th sequenc g the r idual with a L A. The yo ' age and fr uency sp ified on the us are con stent wit the ocsign ange of th equipmen powered 1 ehstder t:ow by th DG. SR 3 .1.9.a corr ponds to t e maxi frequenc
' g " C'"d'tiovtf. ex sion, whil SR 3.8.1.g. and SR 3. 1.9.c ar steady c' 1 Y r'dfoPrbrw ,s e voltage nd frequen values le -ic, i enver fall ina innd r .etinn I The Re'ennrnrDFrequencys i the stam au s , '* * "
%<- Sur velif a w e e un we recoaguenoattortf Melu i twry suier l . lD1 fd IS Ltended t.
kcunnin6e C:=meF k "f*8e % g u s, aar-
-This SR is modified by u9 y5Notell.fThereasonforNote1isn9e)
Mat, during operation w' th the Teactor critical, performance of this SR could cause perturbations to the electrical TW-1 E distribution systems that could challenge continued steady state operation and,_ as a result, plant safety systems. CCredit may se taken for unclannea events Inst sattsty this_SR. i Pa.rn fieled n order to ensure that thuDG is tested under loaa conal ens #' i
"" * ** '
- O Stat are as close u cesign basis conditions as possible, Note I N"[h,[" Gl) requires that, ifTsynthedhized/to of1R.e3 p r1 testina '
. AThispower must factorbe performed is chosen using to be a power factor representative of s @he actual design C
basis inductive loading that theADG would experience.
~
Fwnisss cowtS evs the,
- Ape.d te cowdit:o s e a r pvs doorm e.ef m ot 8.4yus cr m m:t.
a ,ar*av+41s 4act]o.j
)(. *s e s.re *c.
- e. a.ste easiy orew e. / (continued) 4 wack: e e, a.s e r e t: c.a. 5 e. _ I
~ J B 3.8-21 Rev 1, 04/07/95 BWR/4 STS 1
Revision C l
AC Sources-operating 8 3.8.1 BASES i 0O1 - 1 SURVEILLANCE SR 1.s.1 1b (continod) REQUIREMENTS design basis large break LOCA. The Surveillance should be continued for a minimum of 5 minutes in order to demonstrate that all starting transients have decayed and stability has been achieved. of The requirement te verify the connection and power sup pomanent and autoaconnected loads is intended to satisfactorily show the relationship of these loads to DG7 i i loading logic. In certain circumstance % many of these loads cannot actually be connected or loaded without undue hardship i or potential for undesired operation. For instance, Emergency ! Core Cooling Systems (ECCS) injection valves are not desired to be stroked open, or systems are not capable of being i operated at full flow, or RHR systems performing a decay heat l removal function are not desired to be realigned to the ECCS g mode of operation. In lieu of actual demonstration of the connection and loadine of these loads, testing that adequately I shows the capability of theTDGjystem a perform these ; Q >. functions is acceptable, inis testing may include any series l of sequential, overlapping, or total steps so that the entire l connection and loading sequence is verified. ] The Freauen months l C., L G b frec atiogormaeuiar,o$,fsconsiptentwith/he] n Guide I.108 (Ref/9),j (para ph 2.(.0 if takes into consideration plant conditions required to per' ore the Surveillance, and is intended to be consistent with expected fuel cycle lengths. This SR is modified by ~ tag. ke re on for Note isto) ein1 sue ar anc tear on uns curi esting. Fo the } he des shall started f standby purpos of this testi (M - q cond ions, that is, w h the engine colant and ct inuously circul La' th annufacture and temper commandatio . re maint being d consistant he reason for4N oteGlis
/\
/C\
t t rforming the surveillance wouldEgNba r55me g. 4_ j circuit frospervice, perturb the ,electrica' ! Qesede eistriiUITon system, and challenge safety sM,rpgj- , I (faken forylplannec eyects that sa341sfy thi& air.f TM (yene,Q l l gor.{erm% .m q
.% a.c.c.ord a. -w c .e as t A Q+s m ovwa j, (continued) l 8 3.8-24 Rev 1, 04/07/95 SWR /4 STS Revision C 1
O AC Sources-0oeratin B 3.8. g i.et PM y A i
$URVEILLAllCE 18 1 a 1 dus SR Phi e i REQUIRD U T5 (continued) This C B M TTHEFB demonstrates that the automatically
,A Ta'R Tland achieves the required voltage and frequency within 3M -
the specified ties (IFEl seconds) free the design basis L P * "*I U _ actuation signal nur.A signal) and operates for n [5] ainutes. The [ ; ainute period revides sufficient time to demonstrate
)(10 stabl<ty. SR 3.8.1. d and SR 3.8.1. E.e ensure that permanen connected M and .._.: loads are one ized x free the power system on LOCA si na l GeserVC ; wi tman --- - -rr m. ,
m I C( k L o ! n er*s t ) I J The requi,_a to verny the connection and power supply of permanent and autoconnected loads it, intended to
, _ satisfactorily show the relationship of these loads to the leasing logic for leasing onto ERup power. In certain , l circiastances, many of these loads cannot actually be connected er leaded without undue hardship or potential for undesired operation. For instance, ECCS injection valves are not desired to be stroked open, unen---== = -h O
systems are not capable of being operated at full flow, or RHR systems performing a decay heat removal function are not I desired to be realigned to the ECCS made of operation. In r lieu of actual demonstration of the connection and loading of these loads, testing that adequately shows the capability of ystem to perform these functions is acceptable. This any include any series of seguential, overlapping, or N total steps so that the entire _ connection and loading sequence Th 2. is verified
- 2 M5
' 'The Frequency of .into consideration plant r conditions requi month a to perfors the Surveillance and is L ume. w*we st I I *y . . ..p intended to be consistent with the expected fuel cycle <
3 4.,.. c,. w . a m .. lengths. Operati experience hasishown that these components j
% , o.4, ,,.w usually pass the when performed at sne up mont j o ve r . $ ,. ,, Frequency. Therefore, the Frequency is acceptable ree a ,
, j p*,4,4 n uy :w i reliability standpoint. , ;
~ ~ e .s s n ,,a us w. tea + This SR is modified by 16ste8r. yne son for a11 C x i dent:sy .g 4.<,., -i ..is. _. ans 1..r en vos auri esting. or be start f l o4 1e n n.n, u d ithe of this testi the Ots ;
>+9 requise.c staney itions, that , with the ine cool t and o
- rerna. se, d bei inuously circul ed and t sture ;
taas st with -- --fact r v= " taan reason for 1 is that during operation with the reactor critical, / hitote (continued) l I a 3.8-25 Rev 1. 04/07/g5 SWR /4 STs i ' Revision C Q l
O AC Sources-operating 8 3.8.1 BASES ( SURVEILLANCE sa 1.a.1.la (continued) S REQUIREMENTS
- a. perfoman of the SR will not rende any safety syst or c t inoperable;
- b. PeNo e of the SR will not c se perturbations o any t of the e trical distribution stems that could esult in a cha lenge to steady state ration or to pla safety ystems; and
- c. perf e of the $R, or fail of the SR, wil not i cau , or result in, an A00 w attendant chal enge to !
p1 t safety systems. - - -> En 1.a.1. ,,g g he event of a 00A coincident with81oss of EiWDW power t OGs are required to supply the necessary power to M I systems so that the fuel. K$. and containment designflimits are not exceeded. P h'Yf Fas.aeere.4 f=fes*.(s) This a .co== strates ration, as discussed in T da eme.pse the Bases =".:or a 3.4.1.6,
= sTgnal during a.with in conjunction -==an avECCS amame- =
initiation (bas AoA signal. In lieu of actual demonstration of connection and loading of loads, testing that tely shows the capability 7 of the10E+ system to perfom these tions is acceptable. This testing any include any series of sequential, overlapping, or total steps so that the entire connection and loading sequence is ve . (, The Frequency of d st. takes into consideration plant conditions required to perfore the Surveillance and is intended to be consistant with an expected fuel cycle length
- 2. 4 - of (IP anoths).
This SR is modified by 't d. The reas for note is to
.. . .a. . === seer en sne uns saring ting. For the gr purpose o is testing, t des aunt be tarted f sta d y itions, that i with the ne coolant oi bei and toeper ture
.inuo.usly 4 6 -w circu.l
. _ = =
4- he reason for Note is that oerforming the surveillance would a erff1TP circuit freefservice, perturb the electric Q , ,,, pe, e m isc s s u * * "' & P # p .g i ts d** " f (continued) B 3.8-31 Rev 1, 04/07/95 gWR/4 STS Revision C
i
- 7. ;
l l
' JUSTIFICATION FOR DIFFERENCES FROM NUREG 1433, REVISION 1 1 ITS 3ASES: 3.8.1' AC SOURCES - OPERATING l l
)
X TENTION OF' EXISTING REQUIREMENT (CLB) i
- CLB1 BASES for ITS 3.8.1. Required Actions A.3 and;B.4 Completion Times have l ibeen revised consistent with the JAFNPP' current licensing requirements- '
and references ~to Regulatory Guide 1.93 have been deleted. The changes ! are consistent with the current licensing basis for an inoperable i reserve circuit (7 days) or EDG subsystem (14-days). First and second' l l Completion Times of Re ! to 7 days,' and'6 daysto'quired 21 daysAction A.3 have res)ectively. been
- The changed first from-72 hours and second !
^,~ Completion Times of Required Action 3.4 have been changed from 72 hours i tot 14 days, and 6 days to'21 ~ days respectively. The second Completion Time ' associated with Required Actions' A.3 and B.4, has been included i
. based on Discussion of Changes M4;for this Specification. .;
CLB21:The following NUREG 1433, Revision 1, Surveillance ~ Requirements are generally based upon the recommendations of Regulatory Guide 1.108. JAFNPP has not committed to fully implement this Regulatory Guide but has used its guidance where appropriate consistent with the JAFNPP design and licensing basis, and the recommendations of the EDG manufacturer for testing of.the JAFNPP EDGs. Therefore, the NUREG 1433,
^ Revision 1, Bases for these SRs are not included in the-JAFNPP ITS,:and
. subsequent SRs have been renumbered where applicable.
.ISTS SR-3.8.1.10-is not: included J.n the JAFNPP ITS since it is not
? consistent with current testing practices for the EDGs and tests a .
design feature (EDG capability to reject a full load without overspeed ' tripping or exceeding-the predetermined voltage limits) that is not credited in the JAFNPP accident analysis, although it was satisfactorily
. tested during anitial Startup Testing. No postulated design basis event results in:a full load ~ rejection, and the potential consequences of any postulated single active component failure.or single Operator failure (such as tripping,open'the EDG output circuit breaker) that results in l full load rejection, are bounded.by the potential consequences that-would result from an immediate failure of the EDG subsystem itself.
Furthermore, if the EDG rejects the full load, operator action would be
- l. -required.to re establish these loads, regardless of whether or not the L
EDG overspeeds., Since the accident analysis assumes no operator actions take place in the' first.10 minutes' following an accident, verification , of this design' feature does not materially contribute to the
' demonstration of:EDG Operability.
LISTS SR 3.8.1.13 is not included in the JAFNPP ITS since it tests a
. design feature (the .by)assing of certain EDG automatic trips) that is not credited in the JA NPP. accident analysis. There is no reason to
, expect that the. EDG will not run continuously, as long as it has fuel, once it reaches steady state.
JAFNPP- . Page 1-of 10 Revision C
"n JUSTIFICATION FOR' DIFFERENCES FROM NUREG 1433. REVISION.1 V cITS BASES: 3.8.1 AC. SOURCES OPERATING RETENTION OF EXISTING REQUIREMENT.(CLB) CLB7 The Required Actions and Completion Times of ITS 3.8.1 Condition C for I two inoperable offsite .(revserve) circuits have been modified to reflect I the current licensing basis. The Completion Time to restore one reserve circuit has been extended from 24 hours to 7: days consistent with CTS 3.9.B.2.=-An additional requirement (Required Action C.2) to reduce- l
. THERMAL POWER to <-45% RTP in 36 hours has been added in accordance with
- MS. The Bases has been modified as required to. reflect this change.
SR 3.8.1.8 and SR 3.8.1.11 Notes, which specify these CLB80Surve111ances ITS SR 3.8.1.7,s hall not be performed in MODE 1 or 2, are being deleted.
<This change is~ consistent with the current-JAFNPP' licensing basis which
'does not restrict the MODE in which tha e Surveillances may be-performed.
In addition this change is consistent with Generic Letter (GL) 91'04. Changes'in-. Technical Specification Surveillance Intervals to Accommodate a 24 Month Fuel. Cycle, which states'in part:
" licensees may omit the TS-qualification that an 18 month surveillance
.is to be performed "during shutdown" when specifying the surveillance
" interval as "...at.-least once per REFUELING INTERVAL." Because the terms;" Hot" and'" Cold Shutdown are defined in the TS as operating modes O, or condiN ons,.the added restriction to perform certain surveillances during shutdown may'be mis interpreted. This restriction ensures that a surveillance would only be' performed when it is consistent with . safe plant operation. However this consideration is valid for other surveillances that~are performed during power operation, plant startup, ;
or- shutdown, but is net addressed by restricting the' conduct of these '
- surveillances. ;
L The. staff ~ concludes that the'TS need not restrict surveillances as only being performed during' shutdown. Nevertheless, safety dictates that , L.
~w hen refueling interval surveillances are performed during power :
p operation, licensees give pro)er regard for their effect on the safe ! operation of the plant. If tie performance of a refueling interval-E . affect safety, the surveillance'during plant operation licensee should postpone would adversely' the surveillance until the unit is shutdown for l -the. refueling or is in a condition or mode that is consistent with the safe conduct of.that surveillance".
~
L .
' CLB9- ITS 3.8.1', Required Action B.4 Bases has been modified to reflect
- ~ liLicense Amendment 253 dated July 30, 1999-(TAC No. M94611), which L approved a 14-day. completion time for the restoration of an inoperable
- EDG subsystem based on a risk informed assessment of the inoperable EDG L subsystem and othothere rinoperablinoperablee plant equiment-in
' accoreance ddance with CTS 6.21- (ITS 5.5.13), :onfigurat(on ion Risk ;
' Management Program (CRMP).
O -JAFNPP. Page 4 of 10 Revision C (
n
]
73 JUSTIFICATION FOR DIFFERENCES FROM NUREG 1433. REVISION 1 C/ ITS BASES: 3,8.1 AC MRCES OPERATING PLANT SPECIFIC WORDING PREFERENCE OR MINOR EDITORIAL IMPROVEMENT (PA) PA1 Editorial changes have been made for enhanced clarity or to correct a grammatical / typographical error. PA2 NUREG 1433, Revision 1 ISTS LCOs 3.8.7 and 3.8.8 have been deleted. Therefore, NUREG 1433, Revision 1, ISTS LC0 3.8.9 and LC0 3.8.10 have been renumbered, as JAFNPP ITS 3.8.7 and 3.8.8 respectively, to reflect this change. PA3 Changes have been made (additions, deletions and/or changes to the NUREG) to reflect the plant specific system / structure / component nomenclature, equipment identification or description. PLANT SPECIFIC DIFFERENCE IN THE DESIGN (DB) DB1 JAFNPP was designed and under construction prior to the promulgation of Appendix A to 10 CFR 50 General Design Criteria for Nuclear Power Plants. The JAFNPP Construction Permit was issued on May 20, 1970. The pi proposed General Design Criteria (GDC) were initially aublished for r comment in the Federal Register on July 11, 1967 (32 F1 10213.1 and O published in final form in the Federal Register on February 20, 1971 (36 FR 3256), and amended on July 7, 1971 (36 FR 12733). UFSAR Section 16.6, "Conformance to AEC Design Criteria", describes the JAFNPP current licensing basis with regard to the GDC. ISTS statements concerning the GDC are modified in the ITS to reference UFSAR Section 16.6. 1 DB2 Not used. l l DB3 NUREG 1433, Revision 1 Bases 3.8.1 has been modified to reflect the JAFNPP AC sources design. The onsite source of AC electrical power at JAFNPP is provided by two redundant emergency diesel generator (EDG) subsystems, Division 1 and Division 2. Each EDG subsystem consists of two Emergency Diesel Generators. This change is reflected in ITS LC0 3.8.1.b, in the proposed ACTIONS as well as the associated Surveillances. Based on these differences in design, each EDG subsystem is tested in a forced parallel configuration. These changes reflect
-changes made to the associated Specification.
l l l p l JAFNPP. Page 5 of 10 Revision C i
)
\
t l JUSTIFICATION FOR DIFFERENCES FROM NUREG 1433. REVISION 1 ( (('T
,/ -ITS BASES: 3.8.1 AC SOURCES OPERATING PLANT SPECIFIC DIFFERENCE IN THE DESIGN (DB)
DB4 NUREG 1433, Revision 1, Bases SR 3.8.1.2 Note 1 and Note 3 have been deleted since the idling and gradual acceleration feature is not included in the JAFNPP EDG design. ISTS SR 3.8.1.7 has been deleted I since the quick start (i.e., starting and accelerating to rated speed ) and voltage within a specific time period) will be performed every 31 days. In addition, the ITS SR 3.8.1.7 requirement to reach rated speed and voltage in s 10 seconds has been added to ITS SR 3.8.1.2. These changes reflect changes made to the associated Specification. Subsequent Surveillances have been renumbered as applicable. DB5 NUREG 1433, Revision 1, Bases 3.8.1 has been modf led to reflect the JAFNPP EDG prelube system design. The Notes in ISTS, SR 3.8.1.2 Note 2, SR 3.8.1.11 Note 1. SR 3.8.1.12 Note 1, ar.d SR 3.8.1.19 Note 1, that allow all EDG starts to be preceded by an engine prelube period, have been deleted. The EDGs at JAFNPP run in a continuous prelube mode of operation. These changes reflect changes made to the associated Specification. -q DB6 NUREG 1433, Revision 1, Bases 3.8.1 has been modified to reflect the ( , JAFNPP AC sources design. The JAFNPP AC Sources do not include an V automatic sequencer, The LC0. associated ACTIONS, and Surveillances have been deleted. The verification that the emergency loads are auto-connected in the prescribed sequence will be evaluated in accordance 1 with the ITS SR 3.8.1.10, SR 3.8.1.12 LC0 3.3.5.1 and LC0 3.5.1. These changes reflect changes made to the associated Specification. The subsequent requirements have been renumbered where applicable to reflect this change. DB7 ITS 3.8.1 has been revised to reflect the specific JAFNPP reference requirements of. UFSAR, Chapter 8. DB8 ITS 3.8.1 has been revised to reflect the specific JAFNPP reference requirements of, Safety Guide 9, Selection of Diesel Generator Set Capacity for Standby Power Supplies, March 1971.
.DB9 ITS 3.8.1 has been revised to reflect the specific JAFNPP reference requirements'of, UFSAR, Chapter 6.
DB10 ITS 3.8.1 has been revised to reflect the specific JAFNPP reference requirements of, UFSAR, Chapter 14. b) v JAFNPP Page 6 of 10 Revision C
g
,, JUSTIFICATION FOR DIFFERENCES FROM NUREG 1433. REVISION 1 O ITS. BASES: 3.8.-11 AC. SOURCES OPERATING
- DIFFERENCE BASED'ON AN APPROVED TRAVELER-(TA)
;TA1- (continued)E TSTF 8 Revision 2,. revises'NUREG 1433, Revision 1. SR 3.8.1.8 Note, SR
-3.8.1.4 Note 1, SR 3.8.1.11 Note 2 SR.3.8.1.12 Note 2- SR 3.8.1.14 Note 2.andSR3.8.1.19 Note.2bydeletingthestatementallowingcreditto
- be taken for unplanned events that satisfy this SR. The removal of this
-statement is consistent with additional changes to the Bases for ITS SR 3.0.1 which clarify that credit ma
- satisfyanySR,.notjustthoseinSecgion3.8be 1
taken for unplanned events to LTA2~ The' chances presented in Technical Soecification Task Force (TSTF)
- Technical Specification Change Traveler 163 Revision 2, have been incorporated-into revised Improved Technical Specifications. TSTF-163, Revision 2 - revises EDG SR start : acceptance criteria to specify only minimum ~voitageandfrequencywithin.10 seconds. The minimum and-maximum voltage and frequency ranges are applicable only to steady state operation.
DIFFERENCE BASED ON A SUBMITTED. BUT PENDING TRAVELER-(TP)
;None
- DIFFERENCE FOR ANY REASON OTHER THAN THE ARQV1-(X)
<XI .NUREG 1433, Revision 1, Bases' reference to "the NRC Policy Statement" has been replaced with-10 CFR 50.36(c)(2)(ii), in accordance with 160 FR 36953 effective August 18, 1995.
X21 ITS SR 3.8.1.8,- a new' requirement-(M2), Bases has been revised and the applicable requirements to verify the capability of the'EDG to reject a load greater than or equal to its associated single largest )ost-accident load (core spray pump) at a Frequenc las been
. provided consistent with the format of NUREG y of 1433, 24 months Revision 1.
X3 .ITS 3.8.1 Required Actions B.3.1'and B.3.2 bracketed Completion Time has been' revised to reflect chanaes to CTS 4.9.B.5, which 3rovided the Completion Time of 24 hours- [L5) to determine that OPERABLE EDGs or
. EDG subsgtems are not' inoperable.due to. common cause failure or demonstrate ERA 81LITY
~
~
X4, ~ ITS SR 3.8.18 Bases has been re' vised to reflect changes in ISTS SR 3.8.1.9, Note 2 (CLB3) concerning conditions where the power factor of <- - 0.9 cannot be achieved due to grid conditions or limitations. W Q' ' JAFNPP- Page 8 of.10 Revision C
AC Sources-Operating 3.8.1 I 3.8 ELECTRICAL POWER SYSTEMS' 3.8.1- AC Sources-Operating
. LC0 3.8.1 The following AC electrical power sources shall be OPERABLE:
- a. Two reserve circuits between the 115 kV transmission network and the plant Class 1E AC Electrical Power j v Distribution System; and l
- b. Two. emergency diesel generator (EDG) subsystems.
APPLICABILITY: MODES 1, 2, and 3. ACTIONS
~ CONDITION REQUIRED ACTION COMPLETION TIME l A.. One reserve circuit A.1 Perform SR 3.8.1.1 1 hour inoperable. for OPERABLE reserve '
circuit. AND Once per 8 hours thereafter AND A.2 Declare required 24 hours from feature (s) with no discovery of no reserve power reserve power to available inograble one division when the redundant concurrent with required feature (s) inoperability of are inoperable, redundant required feature (s) AND (continued) -p. v JAFNPP 3.8 1 Amendment (ITS Submittal Rev. C)
AC Sources-Operating 3.8.1
-n
- (J. ACTIONS CONDITION REQUIRED ACTION COMPLETION TIME
'A. (continued) A.3 Restore reserve 7 days circuit to OPERABLE status. AND 21 days from discovery of failure to meet LCO B. One EDG subsystem B.1 Perform SR 3.8.1.1 1 hour 1 inoperable. for OPERABLE reserve circuit (s). AND l
Once per 8 hours thereafter AND O B.2 -Declare required feature (s), su) ported 4 hours from discovery of 1 by the inoperaale EDG Condition B subsystem, inoperable concurrent with l when the redundant inoperability of ' required feature (s) redundant are inoperable. required feature (s) AND (continued) JAFNPP 3.8 2 Amendment (ITS Submittal Rev. C) u
AC Sources-Operating 3.8.1 ACTIONS-CONDITION REQUIRED ACTION COMPLETION TIME
' B ._ (continued)- B.3.1 Determine OPERABLE 24 hours EDG subsystem is not l inoperable due to common cause failure.
08 B.3.2 Perform SR 3.8.1'.2 for OPERABLE EDG 24 hours l subsystem. AND B.4 Restore EDG subsystem l to OPERABLE status. 14 days AND 21 days from , discovery of failure to meet. LC0 (continued) i i f _JAFNPP 3.8 3 Amendment (ITS Submittal Rev. C)
AC Sources-0perating 3.8.1 (O! . ACTIONS (continued) CONDITION REQUIRED ACTION COMPLETION TIME C. Two reserve circuits C.1 Declare required 12 hours from l inoperable. feature (s) inoperable discovery of when the redundant Condition C l required feature (s) concurrent with are inoperable, inoperability of redundant required feature (s) AND C.2 Reduce THERMAL POWER 36 hours l to < 45% RTP. AND C.3 Restore one reserve 7 days l circuit to OPERABLE status, t (3 !U l D. One reserve circuit - NOTE -- - l { inoperable. Enter applicable Conditions and Required Actions of AND LC0 3.8.7. " Distribution Systems-Operating." when One EDG subsystem Condition D is entered with l l inoperable. no AC power source to any division. D.1 Restore reserve 12 hours l circuit to OPERABLE status. OR . D.2 Restore EDG subsystem 12 hours l to OPERABLE status. (continued) n b i JAFNPP 3.8 4 Amendment (ITS Submittal Rev. C)
AC Sources-0perating , 3.8.1 j i
.( ACTIONS: (continued)-
CONDITION REQUIRED ACTION COMPLETION TIME E. Two EDG subsystems E.1 Restore one EDG 2 hours l inoperable, subsystem to OPERABLE status. 1 l F. Required Action and F.1 Be in MODE 3. 12 hours l Associated Completion Time of Condition A. AND
-B. C. D, or E not met. [
G. .Three or more AC G.1 Enter LC0 3.0.3. Immediately l Sources inoperable. !p 1 Lk I , L 1 O JAFNPP- 3.8 5 Amendment (ITS Submittal Rev. C)
AC Sources-Operating 3.8.1
-SURVEILLANCE REQUIREMENTS SURVEILLANCE FREQUENCY SR 3.8;1.1 Verify correct breaker alignment and 7 days indicated power availability for each ]
reserve circuit. I I SR 3.8.1.2 Verify each EDG subsystem starts from , standby conditions, force parallels, and ! achieves: a. in s 10 seconds voltage : a 3744 V and frequency a 58.8 Hz: and I
- b. steady state voltage a 3744 V and 1 s 4400 V and frequency = 58.8 Hz and 31 days i s 61.2 Hz. l SR' 3.8.1.3 - -
NOTES - - -----
- 1. EDG loadings may include gradual
' loading as recommended by the l l-tg (S
manufacturer.
- 2. Momentary transients outside the load range do not invalidate this test.
- 3. This Surveillance shall be conducted on only one EDG subsystem at a time.
- 4. This SR shall be preceded by and immediately follow, without shutdown, a successful performance of SR 3.8.1,2.
Verify each EDG subsystem is paralleled 31 days with normal, reserve or backfeed power and each EDG is loaded and operates for
= 60 minutes at a load a 2340 kW and s 2600 kW.
(continued) pJ JAFNPP 3.8 6 Amendment (ITS Submittal Rev. C)
AC Sources-Operating 3.8.1
.-(p) SURVEILLANCE REQUIREMENTS (continued)
SURVEILLANCE FREQUENCY l SR 3.8.1.4 Verify each day tank contains e 327 gal of 31 days fuel oil. l l SR 3.8.1.5 Check'for and remove accumulated water from 31 days each day tank. SR 3.8.1.6 Verify that each EDG fuel oil transfer 92 days l system operates to automatically transfer i fuel oil from its storage tank to the associated day tank. SR 3.8.1.7 Verify automaticLand manual transfer of 24 months plant power supply from the normal AC power A source to the reserve circuit. V l SR 3.8.1.8. -
-NOTE - - - -
l If performed with the EDG aralleled with normal, reserve or backfee power, it shall l be performed within the power factor limit. However, if grid conditions do not permit. l the power factor limit is not required to l be met. Under this condition the power
.~ actor shall be maintained as close to the limit as practicable.
Verify each EDG subsystem rejects a load 24 months I greater than or equal to its associated J single largest post accident load, and following load rejection, the frequency is i s 66.75 Hz. l l (continued) h JAFNPP- 3.8 7 Amendment (ITS Submittal Rev. C) l i
AC Sources-Operating 3.8.1
' SURVEILLANCE REQUIREMENTS (continued)
SURVEILLANCE FREQUENCY SR :3.8.1.9~ -.
-NOTE - - - - -
L This Surveillance shall not be' performed in MODE 1,.2.-or.3. Verify on.an actual or simulated loss of power signal:
- a. De energization of emergency buses: 24 months ;
- b. Load shedding from emergency buses; and
- c. EDG' subsystem auto starts from standby
-condition, force parallels, and:
- 1. energizes permanently connected loads'in s 11 seconds, j
- 2. _ energizes' auto connected shutdown
--loads,
- 3. maintains steady state voltage
=-3830 V and s 4400 V.
- 4. maintains steady state frequency
= 58.8 Hz and s 61.2 Hz, and
- 5. ' supplies permanently connected and auto connected shutdown loads for
= 5 minutes.
(continued) { i
.m D
JAFNPP '3.8 8 Amendment (ITS Submittal Rev. C) { 1
c AC Sources-Operating 3.8.1 t'y i y SURVEILLANCE REQUIREMENTS (continued) SURVEILLANCE FREQUENCY SR 3.8.1.10 - - NOTE---- - - This Surveillance shall not be performed in MODE 1 or 2. Verify on an actual or simulated Emergency ; Core Cooling System (ECCS) initiation signal each EDG subsystem auto starts from standby condition, force parallels, and: 24 months 1
- a. In s 10 seconds after auto start and during tests, achieves voltage .
= 3744 V, frequency a 58.8 Hz; j i
- b. Achieves steady state voltage a 3744 V i and s 4400 V and frequency a 58.8 Hz j and s 61.2 Hz;
- c. Operates for a 5 minutes:
']
t d. Permanently. connected 1oads remain ) V energized from the reserve or backfeed l power system; and j
- e. Emergency loads are auto connected in the prescribed sequence from the reserve or backfeed power system.
(continued) I (% U JAFNPP 3.8 9 Amendment (ITS Submittal Rev. C) u_
AC Sources-Operating 3.8.1 i3 .Fj SURVEILLANCE REQUIREMENTS (continued) , SURVEILLANCE FREQUENCY SR 3.8.1.11 --- NOTE - - - - l Homentary transients outside the load and power factor ranges do not invalidate this test. Verify each EDG subsystem operating ~ within 24 months the >ower factor limit operates for a 8 1ours:
- a. For = 2 hours each EDG loaded a 2730 kW and s 2860 kW: and
- b. For the remaining hours of the test each EDG loaded a 2340 kW and s 2600 kW.
(continued) ! A V ! O 3.8 10 Amendment JAFNPP (ITS Submittal Rev. C)
t-AC Sources-Operating 3.8.1 1 SURVEILLANCE REQUIREMENTS (continued)'
' SURVEILLANCE FREQUENCY SR 3.8.1.12 - - -
NOTE---- - - ~- - d This Surveillance shall not be performed in H00E 1, 2, or 3. Verify..on an actual or simulated loss of
. power signal in conjunction with an actual
.or simulated. ECCS initiation signal:
24 months
-a. .De energization of emergency buses;
- b. Load shedding from emergency buses; and
- c. EDG subsystem auto starts from standby condition, force parallels, and:
- 1. energizes permanently connected loads in 5 11 seconds,
% 2. energizes _ auto-connected (V emergency loads in the prescribed sequence,
- 3. achieves steady state voltage-a 3830 V and s 4400 V .
- 4. - achieves steady state frequency a 58.8 Hz and.s 61.2 Hz, and
- 5. supplies permanently connected and auto connected emergency loads for a 5 minutes.
1
.-JAFNPP-
.3.8 11 Amendment (ITS Submittal Rev. C)
a AC Sources-Operating
.B 3.8.1 BASES -(continued)-
E I l LC0 - Two reserve circuits between the 115 kV transmission network ! l and the plant Class 1E Distribution. System and two separate j l and independent EDG subsystems each consisting of two EDGs l l ensure availability of the required power to shut down the reactor and maintain it in a safe shutdown condition after
- an abnormal operational transient or a postulated DBA.
(: \ ! Reserve power circuits are those that are described in the l l UFSAR, and are part of the licensing basis for the plant. l Each reserve circuit must be capable of maintaining rated frequency and voltage; and accepting required loads during an accident, while connected to the emergency buses. Each reserve circuit consists of one of two independent 115 kV transmission network power sources (Lighthouse Hill substation or Nine Mile Point Unit One Nuclear Station 115 kV switchyard to the South Oswego substation), the ! incoming switchyard breakers-and' disconnect devices to reserve station service transformer (RSST) 71T 2 or 71T 3, and the respective circuit path including feeder breakers to the 4.16 kV emergency bus 10500 or 10600. Either 115 kV transmission network power source may be credited for supplying either one, but only one, of the reserve circuit RSSTs and associated emergency bus. The Limiting-Condition'for Operation may be met with the 115 kV North and South bus disconnect open or closed. With j the disconnect closed, the automatic opening feature must be OPERABLE. Additionally the automatic transfer capability-from the normal source to the reserve circuits must be
'0PERABLE.
Each EDG subsystem must be capable of starting, accelerating to rated speed and voltage, force paralleling and connecting
- to its
- respective emergency bus on detection of bus undervoltage. This sequence must be accom)lished within 10 seconds. Each EDG subsystem must also >e capable of
. accepting required loads within the assumed loading sequence L intervals, and must continue to o>erate until reserve power
-can be restored to the emergency )uses. These capabilities
.are required to'be met with the EDGs in standby with the engines at ambient conditions. Additional EDG capabilities must be demonstrated to meet required Surveillances, e.g.,
capability of each. EDG to reject a load greater than or l
. equal to the load of a core spray pump.
(continued) l JAFNPP B 3.8 5 . Revision 0 L (ITS Submittal Rev. C)
I AC Sources-Operating B 3.8.1 i BASES LC0 Proper sequencing of loads, including tripping of l (continued) nonessential loads, is a required function for EDG ' OPERABILITY. The AC sources must be separate and independent (to the extent possible) of other AC sources. For the EDGs, the separation and independence are complete. For the offsite AC sources, the separation and independence are to the extent practical. A reserve circuit that is not connected to an emergency bus is required to have OPERABLE automatic l transfer interlock mechanisms to its associated emergency ! bus to support OPERABILITY of that circuit. APPLICABILITY The AC sources are required to be OPERABLE in MODES 1, 2, ; and 3 to ensure that: l
- a. ' Acceptable fuel design limits and reactor coolant pressure boundary limits are not exceeded as a result of abnormal operational transients: and f) b. Adequate core cooling is provided and containment V OPERABILITY and other vital functions are maintained in the event of a postulated DBA.
The AC power requirements for MODES 4 and 5 are covered in LC0 3.8.2, "AC Sources - Shutdown. " ACTIONS ful To ensure a highly reliable power source remains with one reserve circuit inoperable, it is necessary to verify the availability of the remaining reserve circuit on a more frequent basis. Since the Required Action only specifies
" perform," a. failure of SR 3.8.1.1 acceptance criteria does not result in a Required Action not met. However, if a second reserve circuit fails SR 3.8.1.1, the second reserve circuit is inoperable, and Condition C, for two reserve l circuits inoperable, is entered.
e b (continued) JAFNPP B 3.8 6 Revision 0 (ITS Submittal Rev. C) c
AC Sources-Operating B 3.8.1 n. Q BASES ACTIONS A.2 (continued) required feature's function: however, function is not lost. The 24 hour Completion Time takes into account the component OPERABILITY of the redundant counterpart to the inoperable required feature. Additionally, the 24 hour Completion Time takes into account the capacity and capability of the remaining AC sources, a reasonable time for repairs, and the low probability of a DBA occurring during this period. A.3 With one reserve circuit inoperable, the reliability of the reserve power is degraded, and the potential for a loss of reserve power is increased, with attendant potential for a challenge to the plant safety systems. In this condition, however, the remaining OPERABLE reserve circuit and EDGs are adequate to su ply electrical power to the plant Class 1E Distribution S stem. The 7 day Completion Time takes into account the redundancy, capacity and capability of the remaining AC sources, reasonable time for repairs, and the low probability of a p DBA occurring during this period. O The second Completion Time for Required Action A.3 establishes a simit on the maximum time allowed for any combination of required AC power sources to be inoperable during any single contiguous occurrence of failing to meet the LCO. If Condition A is entered while, for instance, an EDG subsystem is inoperable, and that EDG subsystem is l subsequently restored OPERABLE, the LC0 may already have been not met for up to 14 days. This situation could lead to a total of 21 days, since initial failure to meet the l LCO, to restore the reserve circuit. At this time, an EDG subsystem could again become inoperable, the reserve circuit l restored OPERABLE, and an additional 14 days (for a total of 35 days) allowed prior to complete restoration of the LCO. The 21 day Completion Time provides a limit on the time allowed in a specified condition after discovery of failure i to meet the LCO. This limit is considered reasonable for situations in which Conditions A and B are entered concurrently. The "AND" connector between the 7 day and 21 i day Completion Times means that both Completion Times apply simultaneously, and the more restrictive Completion Time must be met. ! !) (continued) JAFNPP B 3.8 8 Revision 0 (ITS Submittal Rev. C) i
l AC Sources-Operating B 3.8.1 f ,em Q BASES ACTIONS A.3 (continued) ! Similar to Required Action A.2, the second Completion Time of Required Action A.3 allows for an exception to the normal
" time zero" for beginning the allowed outage time " clock."
This exception results in establishing the " time zero" at the time the LC0 was initially not met, instead of at the , time that Condition A was entered. l B.1 To ensure a highly reliable power source remains with one EDG subsystem ino3erable, it is necessary to verify the l l availability of t1e reserve circuits on a more frequent basis. Since the Required Action only specifies " perform." ; a failure of SR 3.8.1.1 acceptance criteria does not result j in ' a Required Action being not met. However, if a circuit fails to pass SR 3.8.1.1, it is inoperable. Upon reserve circuit inoperability, additional Conditions must then be , entered. O B.2 Required Action B.2 is intended to provide assurance that a loss of reserve power, during the period that an EDG subsystem is inoperable, does not result in a complete loss of safety function of critical systems. These features are designed with redundant safety related divisions (i.e., single division systems are not included) equipment. Redundant required features failures consist of inoperable features associated with a division redundant to the division that has an inoperable EDG subsystem. The Completion Time is intended to allow the operator time to evaluate and repair any discovered inoperabilities. This Completion Time also allows for an exception to the normal
" time zero" for beginning the allowed outage time " clock."
In this Required Action the Completion Time only begins on discovery that both: Q,n . (continued) JAFNPP B 3.8 9 Revision 0 (ITS Submittal Rev. C)
p q AC Sources-Operating l B 3.8.1 : I (~) BASES J lv 1 ACTIONS B.2 (continued) , a. An inoperable EDG subsystem exists; and
- b. A redundant required feature on the other division is inoperele.
If, at any time during the existence of this Condition (one EDG subsystem inoperable), a redundant required emergency I core cooling or containment cooling feature subsequently becomes inoperable, this Completion Time begins to be tracked. l l Discovering one EDG subsystem inoperable coincident with one l or more inoperable required support or supported features, I or both, that are a.ssociated with the OPERABLE EDG subsystem results in starting the Completion Time for the Required Action. Four hours from the discovery of these events existing concurrently is acceptable because it minimizes risk while allowing time for restoration before subjecting the plant to transients associated with shutdown. The remaining OPERABLE EDG subsystem and reserve circuits l are adequate to supply electrical power to the plant Class 1E Distribution System. Thus, on a component basis, I-) U single active failure protection for the required feature's function may have been lost: however, function has not been ! lost. The 4 hour Completion Time takes into account the l component OPERABILITY of the redundant counterpart to the ! inoperable required feature. Additionally, the 4 hour Completion Time takes into account the capacity and capability of the remaining AC sources, reasonable time for repairs, and low probability of a DBA occurring during this l period. ' B.3.1 and B.3.2 l 1 Required Action B.3.1 provides an allowance to avoid l unnecessary testing of the OPERABLE EDG subsystem. If it l can be determined that the cause of the inoperable EDG subsystem does not exist on the OPERABLE EDG subsystem, SR 3.8.1.2 does not have to be 3erformed. If the cause of inoperability exists on other E)G subsystem, the EDG subsystem is declared inoperable upon discovery, and Condition E of LC0 3.8.1 1s entered. (continued) JAFNPP B 3.8 10 Revision 0 (ITS Submittal Rev. C) l
l AC Sources-Operating B 3.8.1 m V BASES ACTIONS B.3.1 and B.3.2 (continued) ! -Once the failure is repaired, and the common cause failure f no longer exists, Required Action B.3.1 is satisfied. If 4 l the cause of the initial inoperable EDG subsystem cannot be ! l confirmed not to exist on the remaining EDG subsystem, I performance of SR 3.8.1.2 suffices to provide assurance of continued OPERABILITY of the remaining EDG subsystem. l 1 In the event the inoperable EDG subsystem is restored to l l OPERABLE status prior to completing either B.3.1 or B.3.2, the plarit corrective action program will continue to evaluate the common cause possibility. This continued l l evaluation, however, is no longer under the 24 hour I constraint imposed while in Condition B. According to Generic Letter 8415 (Ref. 7), 24 hours is a l reasonable time to confirm that the remaining OPERABLE EDG subsystem is not affected by the same problem as the inoperable EDG. l B.4 The design of the AC Sources allows operation to continue in ' m) ii Condition B for a period that should not exceed 14 days. In i Condition B, the remaining OPERABLE EDG subsystem and l reserve circuits are adequate to supply electrical power to the plant Class 1E Distribution System. The 14 day Completion Time takes into account the capacity and capability of the remaining AC sources, reasonable time for
- repairs, and low probability of a DBA occurring during this
! period. In addition, the 14 day completion time is based on l a risk informed assessment of the EDG subsystem inoperability. EDG subsystem inoperability and the simultaneous inoperability of other plant eguipment is addressed in accordance with Swcification 5.5.13, Configuration Risk Management )rogram (CRMP). The second Completion Time for Required Action B.4
- establishes a limit on the maximum time allowed for any combination of required AC power sources to be inoperable during any single contiguous occurrence of failing to meet the LCO. If Condition B is entered while, for instance, a reserve circuit is inograble and that circuit is
- subsequently restored to OPERABLE, the LC0 may already have
! been not met for up to 7 days. This situation could lead to a total of 21 days, since initial failure of the LCO, to restore the EDG subsystem. At this time, a reserve circuit could again become inoperable, the EDG subsystem restored OPERABLE, and an additional 7 days (for a total of 28 days) allowed prior to complete restoration of the LCO. The q V (continued) JAFNPP B 3.8 11 Revision 0 (ITS Submittal Rev. C)
AC Sources-Operating B 3.8.1 i i& BASES , 3,J ! ACTIONS B.4 (continued) I 21 day Completion Time provides a limit on the time allowed . in a specified condition after discovery of failure to meet l the LCO. This limit is considered reasonable for situations l in which Conditions A and B are entered concurrently. The '
"AND" connector between the 14 day and 21 day Completion Times means that both Completion Times apply simultaneously, and the more restrictive must be met.
Similar to Required Action B.2, the second Completion Time of Required Action B.4 allows for an exception to the normal
" time zero" for beginning the allowed outage time " clock."
This exception results in establishing the " time zero" at the time that the LC0 was initially not met, instead of the I time that Condition B was entered. l l
,m
( i i O
'Q (continued)
JAFNPP B 3.8 12 Revision 0 (ITS Submittal Rev. C) l l
AC Sources-Operating l .. B 3.8.1 h BASES-
~ ACTIONS l (continued)
I 1 l i C.I. C.2 and C.3 Required Action C.1 addresses actions to be taken in the ' event of inoperability of redundant required features concurrent with inoperability of two reserve circuits. Required Action C.1 reduces the vulnerability to a loss of l l function. The Completion Time for taking these actions is i reduced to 12 hours from that allowed with one division l without reserve power (Required Action A.2). .The rationale for the reduction to 12 hours is that a Completion Time of 7 l ' (~3 days for two required offsite circuits inoperable is lV l L
,.y .(j (continued)
JAFNPP B 3.8 13 Revision 0 (ITS Submittal Rev. C) 1 n
e 1 AC Sources-Operating l B 3.8.1 p l l l Q} BASES I l ACTIONS C.1. C.2 and C.3 (continued) l l acceptable based upon the assumption that two complete safety divisions are OPERABLE. When a concurrent redundant required feature failure exists, this assumption is not the
' case, and a shorter Completion Time of 12 hours is appropriate. These features are designed with redundant safety related divisions. (i.e., single division systems are not included in the list). Redundant required features ,
failures consist of any of these features that are I inoperable because any inoperability is on a division redundant to a division with inoperable reserve circuits. The Com)letion Time for Required Action C.1 is intended to l , cllow t1e operator time to evaluate and repair any l discovered inoperabilities. This Completion Time also allows for an exception to the normal " time zero" for beginning the allowed outage time " clock." In this Required Action, the Completion Time only begins on discovery that both:
- a. Both reserve circuits are inoperable; and
- b. A redundant required feature is inoperable.
If, at any time during the existence of this Condition (two reserve circuits inoperable), a redundant required feature l subsequently becomes inoperable, this Completion Time begins to be tracked. 0)eration may continue in Condition C for a period that l s1ould not exceed 7 days. This level of degradation means that the reserve power system may not have the capability to effect a safe shutdown and to mitigate the effects of an accident: however, the onsite AC sources have not been 4 degraded. This level of degradation generally corresponds to a total loss of the immediately accesr.ible reserve power sources. Because of the normally high availability of the reserve , sources, this level of degradation may appear to be more severe than other combinations of two AC sources inoperable that involve one or more EDG subsysteas inoperable. l However, two factors tend to decrease the severity of this degradation level: () O (continued) JAFNPP B 3.8 14 Revision 0 (ITS Submittal Rev. C) l I
[ l AC Sources-Operating l B 3.8.1 ( BASES l
' ACTIONS C.1. C.2 and C.3 (continued) l j
- a. The configuration of the redundant AC electrical power system that remains available is not susceptible to a
_ single bus or switching failure: and j l i b. The time required to detect and restore an unavailable reserve power source is generally much less than that required to detect and restore an unavailable onsite AC source. i l With both of the reserve circuits inoperable, sufficient i onsite AC sources are available to maintain the plant in a safe shutdown condition in the event of a DBA or transient. t In fact, a simultaneous loss of reserve AC sources, a LOCA, , and a worst case single active component failure were l postulated as a part of the design basis in the safety analysis. However, Required Action C.2 is intended to l reduce the consequences of any DBA or transient event by requiring a reduction in THERMAL POWER to < 45% RTP. The consequences of DBA and transients are reduced at lower THERMAL POWER levels. The limit of < 45% RTP ensures (Y sufficient power is available to support operating onsite l () loads, maintains stability of the 345 kV transmission ! network, maintains stability of the feedwater system by I allowing both feedwater pumps to be in service, and retains l the reactor scram associated with the turbine trip above 29% l STP. The 36 hour Completion Time allows normal plant ikeratioa to continue for approximately 24 hours prior to
, initiating any transient and still allows approximately 12 1 hours to reduce THERMAL POWER to < 45% RTP in an orderly and carefully controlled manner. The 36 hour Completion Time o also allows more resources to be dedicated to restoration of at least one reserve power source during the_first 24 hours after entering Condition C than would be possible if a power l reduction to < 45% RTP was required within some shorter time l period and thus it allows sufficient time to correct any j minor causes of inomrabilities without commencing a plant j
! power reduction. T1e 7 day Completion Time in Required l Action C.3 provides a period of time to effect restoration l ! of both reserve circuits commensurate with the importance of maintaining AC electrical power system capable of meeting ! its design criteria. I 1 m f j (continued) ! JAFNPP B 3.8 15 Revision 0 (ITS Submittal Rev. C) L
F AC Sources-Operating B 3.8.1 l
'( BASES ACTIONS C.1. C.2 and C.3 (continued) l With the available reserve AC sources two less than required by the LCO, operations may continue for 7 days if both reserve sources were found to be inoperable concurrently.
In this situation Conditions A and C must be entered l l l concurrently. If both reserve circuits are restored within j 7 days, unrestricted operation may continue. If only one offsite source is restored within 7 days, entry into ) Condition F is required. If the reserve circuits were not l ) found to be inoperable concurrently, the Completion Time of J Required Action A.3 must be met for the first inoperable ! circuit in accordance the guidance of Section 1.3 1 1 (Completion Times). This will ensure that the maximum time I two inoperable circuits could be ir merable simultaneously ! without entering Condition F is lin.:.ed. l l D.1 and D.2 l Pursuant to LCO 3.0.6, the Distribution Systems-Operating ACTIONS would not be entered even if all AC sources to it were inoperable, resu ing in de energization. Therefore, (7 the Required Actions -.ondition D are modified by a Note l C to indicate that whi odition D is entered with no AC source to any 4.16 kV orgency bus ACTIONS for LC0 3.8.7,
" Distribution Systems-Operating," must be immediately entered. This allows Condition D to provide requirements l for the loss of the reserve circuit and one EDG subsystem without regard to whether a division is de energized.
LC0 3.8.7 provides the appropriate restrictions for a de energized division. According to recommendations in Regulator de 1.93 (Ref. 8), operation may continue in Cone O for a period that should not exceed 12 hours. In Cor in D. individual l L redundancy is lost in both the reserve p: system and the onsite AC electrical power system. Since power system redundancy is provided by two diverse sources of power, however, the reliability of the power systems in this Condition m- sppear higher than that in Condition C (loss l of both reserve circuits). This difference in reliability is offset by the susceptibility of this power system configuration to a single bus or switching failure. The 12 hour Completion Time takes into account the capacity and capability of the remaining AC sources, 1 n i hi (continued) JAFNPP B 3.8 16 Revision 0 (ITS Submittal Rev. C) l L
AC Sources-Operating B 3.8.1 BASES ACTIONS D.1 and D.2 (continued) l reasonable time for re) airs, and the low probability of a i DBA occurring during t11s period. E.d l With two EDG subsystems inoperable, there is no remaining onsite AC source. Thus, with an assumed loss of offsite electrical power, insufficient onsite AC sources are available to power the minimum required engineered safeguards functions. Since the offsite electrical power system is the.only source of AC power for the majority of engineered safeguards equipment at this level of degradation...the risk associated with continued operation for a very short time could be less than that associated ) with an immediate controlled shutdown. (The immediate ! shutdown could cause grid instability, which could result Tn a total loss of AC power.) Since any inadvertent Main ) Generator trip could also result in a total loss of offsite AC power, however, the time allowed for continued operation is severely restricted. The intent here is'to avoid the O risk associated with an immediate controlled shutdown and to-minimize the risk associated with this level of degradation.
-According to the recommendations in Regulatory Guide 1.93 (Ref. 8), with both EDG subsystems inoperable, operation may continue for a period that should not exceed 2 hours.
F.1 and F.2 l If the-inoperable AC electrical pouer sources cannot be restored to OPERABLE status within the associated Completion Time, the plant must-be brought to a MODE in which the LC0 does not apply. 'To achieve this status, the plant must be brought to at.least MODE 3 within 12 hours and to MODE 4 within 36 hours. The allowed Completion Times are reasonable, based on operating experience, to reach the recuired plant conditions from full power conditions in an
- orcerly manner and without challenging plant ' systems.
Ctd Condition'H corresponds to a level of degradation in which all redundancy in the AC electrical power supplies has been (continued) JAFNPP' B 3.8 17 Revision 0-(ITS Submittal Rev. C)
y , AC Sources- Jperating B 3.8.1 ( (3 l j BASES l ACTIONS G.1 (continued) l lost. At this severely degraded level, any further losses in the AC electrical power system will cause a loss of function. Therefore, no additional time is justified for continued operation. The plant is required by LC0 3.0.3 to commence a controlled snutdown. , SURVEILLANCE The AC sources are designed to permit inspection and REQUIREMENTS testing of all important areas and features, especially those that have a standby function, in accordance with Reference 1. Periodic component tests are supplemented by extensive functional tests during refueling outages (under i simulated accident conditions). The SRs for demonstrating ' the OPERABILITY of the EDG subsystems are in general l conformance with the recommendations of Safety Guide 9 (Ref. 3), Regulatory Guide 1.108 (Ref. 9), and Regulatory Guide 1.137 (Ref. 10). Where the SRs discussed herein specify steady state voltage and frequency tolerances, the
' following summary is applicable. The minimum steady state output voltage of 3830 V is approximately 92% of the nominal (d
4160 V output voltage. This value, which is slightly greater than that specified in ANSI C84.1 (Ref 11), allows for voltage drop to the terminals of 4000 V motors whose i minimum operating voltage is specified as 90% or 3600 V. It also allows for voltage drops to motors and other equipment down through the 120 V level where minimum operating voltage ! is also usually specified as 90% of name plate rating. The i specified maximum steady state output voltage of 4400 V is equal to the maximum operating voltage specified for 4000 V motors. It ensures that for a lightly loaded distribution system, the voltage at the terminals of 4000 V motors is no more than the maximum rated operating voltages. The specified minimum and maximum frequencies of the EDG are , 58.8 Hz and 61.2 Hz, respectively. These values are equal to i 2% of the 60 Hz nominal frequency and are derived from the recommendations found in Safety Guide 9 (Ref. 3). SR 3.8.1.1 This SR ensures proper circuit continuity for the reserve AC electrical power supply to the plant distribution network and availability of reserve AC electrical power. The breaker alignment verifies that each breaker is in it
/contirued)
JAFNPP B 3.8 18 Revision 0 (ITS Submittal Rev. C)
F l AC Sources-Operating B 3.8.1 r i BASES SURVEILt.ANCE SR -3.8.1.1 (continued) REQUIREMENTS correct position to ensure that emergency buses and loads can be or are connected to their reserve power source and that appropriate independence of reserve circuits is maintained. Reserve circuit alignment verification can be accomplished by verifying that a reserve circuit bus is energized and that the status of reserve circuit supply breakers and disconnects displayed in the control room is correct. Reserve source power availability can be verified by communication with Niagara Mohawk, for the Nine Mile ' Point Unit One switchyard and South Oswego substation, and the New York Power Pool for the Light House Hill substation. The 7 day Frequency is adequate since breaker position is not likely to change without the operator being aware of it and because its status is displayed in the control room. In addition, the Frequency is adequate since administrative controls are in place which require plant. notification of distribution system 3roblems, affecting )ower availability, from both Niagara Molawk and the New Yor( Power Pool. SR 3.8.1.2 i V This SR helps to ensure the availability of the onsite electrical power supply to mitigate DBAs and transients and maintain the plant in a safe shutdown condition. I For the purposes of this testing, the EDGs are started from standby conditions. . Standby conditions for an EDG mean that the diesel engine coolant and oil are being continuously circulated and temperature is being maintained consistent with manufacturer recommendations. This SR requires that, at a 31 day Frequency, the EDG subsystem starts from standby conditions, force parallels, and achieves required voltage and frequency within 10 seconds. The 10 second start requirement supports the assumptions in the design basis LOCA analysis of UFSAR, Section 6.5 (Ref. 12). l,y j f (continued) ! Revision 0 JAFNPP B 3.8 19 (ITS Submittal Rev. C)
p 1 l l AC Sources-Operating B 3.8.1 BASES = (m] l , SURVEILLANCE SR 3.8.1.2 (continued) REQUIREMENTS In addition to the SR requirements, the time for the EDG to reach steady state operation is periodically monitored and the trend evaluated to identify degradation of governor and voltage regulator performance. The 31 day Frecuency for SR 3.8.1.2 is consistent with Regulatory Guice 1.108 (Ref. 9). This Frequency provides adequate assurance of EDG subsystem OPERABILITY, while l minimizing degradation resulting from testing. SR 3.8.1.3 This SR verifies that the EDG subsystems are capable of l synchronizing and accepting greater than or equal to tne equivalent of the maximum expected accident loads. A minimum run time of 60 minutes is required to stabilize engine temperatures, while minimizing the time that the EDG subsystem is paralleled with the normal, reserve or backfeed power source.
/3 Although no power factor requirements are established by U this SR, the EDG is normally operated at a power factor between 0.8 lagging and 1.0. The 0.8 value is the design !
rating of the machine, while 1.0 is an operational i limitation to ensure circulating currents are minimized. ! The load band is provided to avoid routine overloading of the EDG. Routine overloading may result in more frequent l teardown inspections in accordance with vendor recommendations in order to maintain EDG OPERABILITY. The 31 day Frequency for this Surveillance is consistent with Safety Guide 9 (Ref. 3). Note 1 modifies this SR to indicate that diesel engine runs for this Surveillance may include gradual loading, as recommended by the manufacturer, so that mechanical stress and wear on the diesel engine are minimized. Note 2 modifies this SR by stating that momentary transients because of changing bus loads do not invalidate this test. Similarly, momentary power factor transients above the limit do not invalidate the test. (continued) . JAFNPP B 3.8 20 Revision 0 l (ITS Submittal Rev. C) l
c- 3 s 4 AC Sources-Operating B 3.8.1 BASES . l SURVEILLANCE 'SR 3.8.1.3 (continued) REQUIREMENTS Note'3 indicates that this SR should be conducted on only one EDG subsystem at a time in order to avoid common cause failures that might result from normal, reserve or backfeed power source perturbations. Note 4 stipulates a prerequisite requirement for performance of this:SR. A successful EDG subsystem start must precede this test to credit satisfactory performance.
-SR 3.8.1.4 This SR provides verification that the level of fuel oil in !
the day tank is at or above the level at which the low level alarm is annunciated. The level is expressed as an , equivalentvolumeingallons,andisselectedtoensure ' acequate fuel oil for a minimum of 1.8 hours of EDG operation at full load. l The 31' day Frequency is adequate to ensure that a sufficient !
/- supply of fuel oil is available, since low level alarms are i
provided and plant operators would be aware'of any large uses of fuel oil during this period. SR 3. 8.1'. 5 -
-_ Microbiological fouling is a major cause of fuel oil
-degradation. There are numerous bacteria that can grow in fuel oil and cause fouling. but all must have'a water environment _in order to survive. Removal of water from the
-fuel oil day tanks once every 31 days eliminates the necessary environment for bacterial survival. This is the most effective means of controlling microbiological fouling.
In addition, it eliminates the potential for water 4 entrainment in the fuel oil during EDG operation. Water may come from any of several sources, including condensation, ground-water, rain water, contaminated fuel oil, and breakdown of the fuel oil by bacteria. Frequent checking for and removal of accumulated water minimizes fouling and provides data regarding the watertight-integrity of the fuel oil system. The Surveillance Frequency is consistent with Regulatory Guide 1.137 (Ref.-10). This SR is for preventive maintenance. The presence of water does not necessarily p Q- (continued) JAFNPP. B 3.8 21 Revision 0
-(ITS Submittal Rev. C).
AC Sources-Operating B 3.8.1
-( BASES SURVEILLANCE SR 3.8.1.8 REQUIREMENTS' (continued) Each EDG is provided with an engine overspeed trip to prevent damage to the engine. Recovery from the transient caused by the loss of a large load could cause diesel engine overspeed, which, if excessive, might result in a trip of the engine. This Surveillance demonstrates the EDG capability to reject the largest single load without exceeding predetermined frequency and while maintaining a specified margin to the overspeed trip. The largest single load for each EDG is a core s] ray pump (1250 bhp). This Surveillance may be accomplis 1ed by:
- a. Tripping the EDG output breaker with the EDG subsystem carrying greater than or equal to its associated single largest post accident load while paralleled to normal, reserve or backfeed power, or while solely supplying the bus: or
- b. Tripping its associated single largest aost accident load with the EDG solely supplying the aus.
(^ Consistent with Safety Guide 9 (Ref. 3), the load rejection test is acceptable if the diesel speed does not exceed the nominal (synchronous) speed plus 75% of the difference between nominal speed and the overspeed trip setpoint, or 115% of nominal speed, whichever is lower. The Frequency of 24 months, takes into consideration plant conditions required to perform the Surveillance, and is intended to be consistent with expected fuel cycle lengths. This SR is modified by a Note. In order to ensure that the ' EDG is tested under load conditions that are as close to l design basis conditions as possible, the Note requires that, if paralleled with normal, reserve or backfeed power, testing must be performed using a power factor s 0.9 unless the grid conditions do not permit. In this condition the test is performed with a power factor as close to the design rating of the machine as practicable. This power factor is chosen to be representative of the actual design basis inductive loading that the EDG subsystem would experience. (continued) l JAFNPP B 3.8 23 Revision 0 (ITS Submittal Rev. C)
p AC Sources-Operating L B 3.8.1 l-i BASES SURVEILLANCE SR 3.8.1.9 L REQUIREMENTS i (continued) Consistent with Regulatory Guide 1.108 (Ref. 9), paragraph 2.a.(1), this SR demonstrates the as designed I operation of the onsite power sources due to an emergency bus loss of power (LOP) signal. This test verifies all actions. required following receipt of the LOP signal, including shedding of the nonessential loads and energization of the emergency buses and respective loads from the EDG subsystem. It further demonstrates the , capability of the EDG subsystem to automatically achieve the l required voltage and frequency within the specified time. The EDG auto start time of 11 seconds is derived from requirements of the accident analysis for responding to a design basis large break LOCA. The Surveillance should be continued for a minimum of 5 minutes in order to demonstrate that all starting transients have decayed and stability has i been achieved. l The requirement to verify the connection and power supply of , permanent and auto connected loads is intended to l satisfactorily show the relationship of these loads to the f_} u EDG subsystem loading logic. In certain circumstances, many of these loads cannot actually be connected or loaded without undue hardship or potential for undesired operation. For instance, Emergency Core Cooling Systems (ECCS) ' injection valves are not desired to be stroked open, or systems are not capable of being operated at full flow, or RHR systems performing a decay heat removal function are not desired to be realigned to the ECCS mode of operation. In lieu of actual demonstration of the connection and loading of these loads, testing that adequately shows the capability of the EDG subsystem to perform these functions is acceptable. This testing may include any series of sequential, overlapping, or total steps so that the entire
- connection and loading sequence is verified.
The Frequency of 24 months, takes into consideration plant conditions required to perform the Surveillance, and is intended to be consistent with expected fuel cycle lengths. This SR is modified by a Note. The reason for the Note is l l
.p-
, () (continued)
.JAFNPP B 3.8 24 Revision 0 (ITS Submittal Rev. C)
AC Sources-Operating B 3.8.1 m BASES SURVEILLANCE SR 3.8.1.9 (continued) l REQUIREMENTS that performing the Surveillance would prevent a reserve circuit from performing in accordance with its normal service, perturb the electrical distribution system, and challenge safety systems. SR 3.8.1.10 This SR demonstrates that the EDG subsystem automatically I starts, force parallels and achieves the required voltage and frequency within the specified time (10 seconds) from the design basis actuation signal (LOCA signal) and operates for a 5 minutes. The 5 minute period provides sufficient time to demonstrate stability. SR 3.8.1.10.d and SR 3.8.1.10.e ensure that permanently connected loads and emergency loads are energized from the reserve power system on a LOCA signal without a LOP signal. The requirement to verify the connection and power supply of permanent and auto connected loads -is intended to satisfactorily show the relationship of these loads to the 'fl loading logic for loading onto reserve power. In certain 'V circumstances, many of these loads cannot actually be connected or loaded without undue hardship or potential for undesired operation. For instance, ECCS injection valves are not desired to be stroked open, systems are not capable of being operated at full flow, or RHR systems performing a decay heat removal function are not desired to ]e realigned to the ECCS mode of operation. In lieu of actual demonstration of the connection and loading of these loads, testing that adequately shows the capability of the EDG subsystem to perform these functions is acceptable. This testing may include any series of sequential, overlapping, or total steps so that the entire connection and loading sequence is verified. f In addition to the SR requirements, the time for the EDG to reach steady state operation is periodically monitored and the trend evaluated to identify degradation of governor and voltage regulator performance. The Frequency of 24 months takes into consideration plant l conditions required to perform the Surveillance and is n.
.{) (continued)
JAFNPP B 3.8 25 Revision 0 (ITS Submittal Rev. C) l l l t l
i AC Sources-Operating B 3.8.1 [l w BASES i SURVEILLANCE SR 3.8.1.10 (continued) REQUIREMENTS intended to be consistent with the expected fuel cycle
' lengths. Operating experience has shown that these components usually pass the SR when aerformed at the 24 month Frequency. Therefore, the r requency is acceptable from a reliability standpoint.
This SR is modified by a Note. The reason for the Note is l that during operation with the reactor critical, performance of this Surveillance could potentially cause perturbations ; to the electrical distribution systems that could challenge l continued steady state operation and, as a result, plant ; safety systems. I SR 3.8.1.11 Consistent with IEEE-387 (Ref. 14), Section 7.5.9 and Table 3, this SR requires demonstration that the EDGs can run continuously at full load capability for an interval of not less than 8 hours-6 hours of which is at a load equivalent to 90-100% of the continuous rating of the EDG, pl and 2 hours of which is at a load equivalent to 105% to 110% v of the continuous duty rating of the EDG. The EDG starts for this Surveillance can be performed either from standby or hot conditions. The provisions for gradual loading, discussed in SR 3.8.1.3, are applicable to this SR. In order to ensure that the EDG subsystem is tested under load conditions that are as close to design conditions as
-possible, testing must be performed using a power factor s 0.9. This power factor is chosen to be representative of the actual design basis inductive loading that the EDG subsystem could experience. A load band is provided to avoid routine overloading of the EDG subsystem. Routine overloading may result in more frecuent teardown inspections in accordance with vendor recommentations in order to maintain EDG OPERABILITY.
l l The 24 month Frequency is consistent with the l recommendations of IEEE 387 (Ref. 14), Section 7.5.9 and 1 () O (continued) JAFNPP B 3.8-26 Revision 0 (ITS Submittal Rev. C) 1 L
1 AC Sources-Operating I B 3.8.1 LBASES 1
' SURVEILLANCE SR 3.8.1.11 '(continued)
' REQUIREMENTS.
{ Table 3 which takes into consideration plant conditions i required to perform the Surveillance; and is intended to be consistent with. expected fuel cycle lengths.
.This Surveillance is modified by'a Note. The Note states that momentary transients due to changing bus loads do not invalidate this test. Similarly, momentary power {
1
- factor transients above the limit do not invalidate the l test.
SR 3.8.1.12 In the event of a DBA coincident with an emergency bus loss
- of power signal, the EDGs are required to supply the necessary power to Engineered Safeguards systems so that the fuel, RCS, and containment design limits are not exceeded.
This:SR demonstrates EDG operation, as discussed in the Bases for SR 3.8.1.9. during an emergency bus LOP signal in conjunction with an ECCS initiation signal. In lieu of actual demonstration of connection and loading of loads,
. testing that adequately shows the capability of the EDG subsystem to perform these functions is acceptable. This testing may include any series of sequential, overlapping, or total steps so that the entire connection and' loading sequence is verified.
The Frequency of 24 months takes into consideration plant conditions required to perform the Surveillance and is . intended to-be consistent with an expected fuel cycle length ' of 24 months. This SR is modified by a Note. The reason for the Note is l that performing the. Surveillance would prevent a reserve circuit from performing in accordance with its normal service, perturb the electrical distribution system, and challenge safety systems. L-O (continued) l JAFNPP. B 3.8 27 Revision 0 ' (ITS Submittal Rev. C)
r l l AC Sources-Operating B 3.8.1 lq ! I V BASES (continued) { i REFERENCES 1. UFSAR Section 16.6.
- 2. UFSAR, Chapter 8.
- 3. Safety Guide 9 Selection Of Diesel Generator Set Capacity For Standby Power Supplies, March 1971.
- 4. UFSAR, Chapter 6.
- 5. UFSAR, Chapter 14.
- 6. 10 CFR 50.36(c)(2)(ii).
- 7. Generic Letter 84 15 Proposed Staff Actions To Improve And Maintain Diesel Generator Reliability, July 1984.
- 8. Regulatory Guide 1.93, Availability Of Electric Power Sources, December 1974.
- 9. Regulatory Guide 1.108, Revision 1, Periodic Testing of Diesel Generator Units Used As Onsite Electric Power Systems At Nuclear Power Plants, August 1977.
- 10. Regulatory Guide 1.137, Revision 1, Fuel 0il Systems for Standby Diesel Generators, October 1979.
- 11. ANSI C84.1, Voltage Ratings for Electric Power Systems and Equipment, 1982.
- 12. UFSAR, Section 6.5.
- 13. ASME Boiler and Pressure Vessel Code, Section XI.
- 14. IEEE 387 IEEE Standard Criteria for Diesel-Generator Units Applied as Standby Power SuPower Generating Stations l
l O JAFNPP- B 3.8 28 Revision 0 (ITS Submittal Rev. C) L
y, , . .. . . . . . . . . . . . i O M
~. r2 q
i? Q M g } u 15, ut 8TOF e f ,a o a
- f. * -
3 n i 4 e 1 [ .t h $3 I) v di # y i* 5. (2 C h
- 21 r1 3 1, *$
S i j A IU, C2 # t v{ t at *t il 1 [; M u 34 h t 3 , lO a vv
,k $> h , L '
,t sq i g
a a v e kb hl o hs z e i pw - hhf 'I d NVJ9'k'M Y84$ d I O} h,k ikfk fl$ i Sh$$M;i i~ . j^k o 0
@g
& ${ [4 6
.O 2 O< 1 3 f o C _ i t n o b i n o s a e i c g v e i f a . i P R _ c _ e _ p .
.S .
k n l a b l y l _ a n o O i t n t e _ i n e g a p i s h T t m O . m i
p ] l t
, m DISCUSSION OF CHANGES c (a) ITS: 3.8.2 AC SOURCES SHUTDOWN l
ADMINISTRATIVE CHANGES Al~ In the conversion of the James A. FitzPatrick Nuclear Power Plant (JAFNPP) current Technical Specifications (CTS) to the proposed plant specific Improved Technical Specifications (ITS), certain wording preferences or conventions are adopted that do not result in technical changes (either' actual or interpretational). Editorial changes, reformatting, and revised numbering are adopted to make the ITS consistent with the BWR Standard Technical Specifications NUREG 1433, Revision 1 (i.e., Improved Standard Technical Specifications (ISTS)). i A2 The details of CTS 3.9.D, requirement for one offsite (reserve) aower source and one Emergency Diesel Generator (EDG) subsystem OPERAB_E. l whenever any work is being done which has the potential for draining the vessel, secondary containment is required, or core or containment cooling is required, have been deleted. 'ITS LC0 3.8.2 requires the AC 3 power sources to be OPERABLE when required to support ITS LC0 3.8.8, !
" Distribution Systems-Shutdown". In MODES 4 and 5 and during movement '
of irradiated fuel in the secondary containment (M3) the requirement to have one reserve circuit and cae diesel generator OPERABLE is determined by the equipment required to be OPERABLE' by other Specifications in ITS p Sections 3.5. 3.6, and 3.9 as identified .in M1 and M2 below. Changes to d the applicability of those specifications are discussed in the respective sections. Therefore the revised wording is a presentation l l preference consistent with NUREG 1433 Revision 1, and is j administrative.
]
A3 CTS 3.9.D is revised by adding a " Note," which requires that the applicable Condition and Recuired Actions of ITS LC0 3.8.8, 4
" Distribution Systems-Shutcown" be entered when any required division I is de energized as a result of Condition A. In the event AC Sources are inoperable such that a distribution subsystem were inoperable, the proposed LCO 3.0.6 would require taking only the AC Sources ACTIONS: l taking exception to complying with the AC Distribution System ACTIONS.
Since the AC Sources ACTIONS are not sufficiently conservative in this event (e.g., RHR SDC could be inoperable), the added ITS 3.8.2 Required Action Note provides specific direction to take appropriate ACTIONS for l the Distribution System. This format and construction implements the ' existing treatment of this condition since all core or containment cooling systems are required to be declared inoperable (L1). This change is_ consistent with NUREG 1433, Revision 1, and is administrative. I i 1 1 1 p JAFNPP Page 1 of. 4 Revision C i L
F L DISCUSSION OF CHANGES ITS: 3.8.2 AC SOURCES SHUTDOWN I ( TECHNICAL CHANGES MORE RESTRICTIVE i M1 CTS 3.9.D requirement, for one offsite (reserve) AC power source to be l OPERABLE.during the cold shutdown and refueling mode does not specify ) what that circuit must be powering. ITS LC0 3.8.2.a. specifies that the reserve AC power source must be available to supply power to all equipment required to be OPERABLE by ITS LC0 3.8.8. This conservatively i assures the single OPERABLE reserve AC power source is performing a vital function. This change adds a level of Technical Specification control which currently is enforced only via administrative procedures and is necessary to ensure the OPERABLE required reserve AC power source is providing power to support the systems, subsystems or components required to be OPERABLE. This change imposes more specific requirements l on operations, is consistent with NUREG 1433, Revision 1 and is l considered more restrictive. This change is considered to have no l adverse impact on safety. l l M2 CTS 3.9.D requirement, for one Emergency Diesel Generator (EDG) system AC power source to be OPERABLE during the cold shutdown and refueling mode does not specify what that EDG system must be powering. ITS LC0 3.8.2.b,' specifies that the EDG subsystem must be capable of supplying f; power to all equipment required to be OPERABLE by ITS LC0 3.8.8. This V conservatively assures the required OPERABLE EDG subsystem is performing , a vital function. This change adds a level of Technical Specification control which currently is enforced only via administrative procedures and is necessary to ensure the OPERABLE required EDG subsystem AC power source is providing power to sunort the systems, subsystems or l components required to be OPERALE. This change imposes more specific recuirements on operations, is consistent with NUREG 1433, Revision 1 anc is considered more restrictive. This change is considered to have no adverse impact on safety. H3 CTS 3.9.D Applicability of during cold shutdown or refueling modes has been revised to include an additional condition. ITS 3.8.2 Applicability includes the condition for during movement of irradiated fuel assemblies in the secondary containment. These conditions may include MODES 1, 2 and 3 and when there is no fuel in the vessel. This change ensures that the appropriate equipment, necessary to ensure the accident analysis is met, is OPERABLE whenever the operation is performed, imposes additional requirements on operations, is consistent with NUREG 1433 Revision 1 and is considered more restrictive. This change is considered to have no adverse impact on safety. M4- CTS 3.9 Actions have been supplemented by the addition of a Note as a
- consequence of the addition of the Applicability (M3) for during
. movement of irradiated fuel assemblies in the secondary containment.
q JAFNPP Page 2 of 4 Revision C I I m_ _
m , C DISCUSSION OF CHANGES , ITS: 3.8.2 - AC SOURCES. SHUTDOWN { l l 1
-TECHNICAL CHANGES--' MORE RESTRICTIVE M4-_ (continued)
-ITS 3.8.2 ACTIONS Note' states that LC0 3.0.3 is not applicable. If 1 moving irradiated fuel assemblies while in MODES 4 or 5, LC0 3.0.3 is I not a If moving irradiated j fuel.pplicable and assemblies would while not specify in MODES 1,_2,any action.
or 3, the fuel movement is ! independent of reactor operations and the inability to suspend movement in accordance:with the ITS 3.8.2 Required Actions would not be _ sufficient reason to require a reactor shutdown. This Note has been added for clarification and is necessary because although defaulting to LC0 3.0.3 would require the reactor to be shutdown it would not require
' suspension of the activities with a potential:for releasing radioactive materials to the secondary containment. This change, imposes' additional I recuirements on operations, is consistent with NUREG 1433 Revision 1 anc is: considered more restrictive. This change is considered to have !
no adverse impact on. safety. MS. CTS 4.9.D does not include a Surveillance Requirement (SR) for verifying OPERABILITY of AC power sources during cold shutdown or refueling modes. OO ITS SR 3.8.2.1, adds a requirement- for the SRs of ITS LC0 3.8.1, except SR 3.8.1.7, to be applicable. The addition of this Surveillance Requirement ensures the OPERABILITY of AC sources in MODES other than 1, l
-2 . and 3~ : imposes additional. requirements on operations, is consistent with NUREG 1433. Revision 1 and is considered more restrictive. This change.is considered to have no adverse impact on safety. ;
TECHNICAL CHANGES LESS RESTRICTIVE (GENERIC) ;
.None ,
TECHNICAL CHANGES - LESS RESTRICTIVE' (SPECIFIC) L1 CTS 3.9.D actions, .to suspend all work that could cause draining of the
. reactor vessel, suspend' core alterations and handling of irradiated fuel assemblies in the secondary containment, and to declare-required core
- and containment' systems inoperable, if the required EDG subsystem and
- offsite (reserve) power source are not 0PERABLE, have been revised to separate and limit the Conditions and Required Actions for the required reserve circuit or EDG subsystem inoperable. ITS LC0 3.8.2 specifies that the AC power: sources, one reserve circuit.between the 115'kV
' transmission network and the plant Class 1E AC electrical power di.stribution subsystem (s)-(M1), and the required EDG subsystem l f}. '
JJAFNPP- Page 3 of 4 Revision C ['
lq DISCUSSION OF CHANGES ITS: 3.8.2
- j. V AC SOURCES - SHUTDOWN L
TECHNICAL CHANGES LESS RESTRICTIVE (SPECIFIC) L1- (continued) capable of, supplying one division of the )lant Class 1E AC electrical distribution subsystem (s) (M2), be OPERAB_E as required by LC0 3.8.8. l ITS 3.8.2 ACTION A for one required reserve circuit inoperable provides the option of, ITS 3.8.2 Required Action A.1 declaring affected required i feature (s) with no reserve power available, inoperable, or ITS 3.8.2 l Required Action A.2 to suspend, CORE ALTERATIONS, movement of irradiated fuel in the secondary containment, operations with a potential for draining the reactor vessel (0PDRVs), and initiate action to restore required reserve pcaer circuit to OPERABLE status. This change 3rovides the less restrictive option to declare required features inoperaale with no reserve power available, thereby implementing appropriate restrictions in accordance with the affected required feature (s) LC0's ACTIONS, or performing sufficiently conservative actions which would preclude the need for those required features, g In addition, ITS 3.8.2 ACTION B, for one required EDG subsystem l bj inoperable, does not retain, or provide as an option, the CTS 3.9.D action to declare the required core or containment cooling systems inoperable. With the required EDG subsystem inoperable, the minimum l required diversity of AC sources is not available, and as such the more restrictive requirements to sus)end CORE ALTERATIONS, movement of irradiated fuel assemblies in tie secondary containment, and activities that could result in inadvertent draining of the reactor vessel are i imposed. Not retaining this requirement may be consicered administrative, in that suspending these operations would preclude the need for the required features and allows time for the plant to focus on the more important function of restoring AC power required to support the plant safety systems. l These changes, to provide options for an inoperable reserve circuit and delete the requirement to declare required feature (s) inoperable for a required inoperable EDG subsystem, relaxes existing requirements on l operations, are consistent with NUREG 1433, Revision 1, and are considered less restrictive. TECHNICAL SPECIFICATIONS RELOCATIONS None j [J JAFNPP Page 4 of 4 Revision C l u
I~ O' AC Sources-Shutdown 3.8.2 3.8 ELECTRICAL POWER SYSTEMS MI V 3.8.2 AC Sources-Shutdown (fesstiQ &TV0 ' LC0 3.8.2 The followingfAC electrical power sources shall be OPERA 8LE: e a. One *" 'tstas circuit between the transmission L3.*D2 P ' ' aat '* =ad the s nrta Class 1E AC electrical ower distribution subsystem (s) required by LC0 3.8. , (Md
' Distribution Systees-Shutdown": and glepoux<.q) Esau vsce a g pf(2, e w b. Onerdiesel genera (capableofsupplyingone LW.I division of the ass 1E AC electrical Fg distribution subsystem (s) required by LC0 3.8. .
r [330 AertiCA8itiTv: Mo0ES 4 and s. Duri movemen of irradiated fuel assemblies in the CMC econdar contain=nt. O (A % 3.8-18 Ev% OW/99 f
)ggy odeuT) e fo yt O
Revision C I
l i l AC Sources-Shutdown 3.8.2 j 1 PAl ACTIONS (continued) CONDITION REQUIRED ACTION
- CONPLETION TINE
- 8. One required inoperable.
8.1 Suspend CORE ALTERATIONS. Immediately g ale l hubs stem] 8.2 Suspend movement of Inmediately , I irradiated fuel
) assemblies in 1 secondary!
j 3 containment, j Als B.3 Initiate action to Immediately [ suspend OPORVs. j g 6 ) 8.4 Initiate action ', ..aediately restore requiredf)G l s) , Ato OPERA 8LE status. l 1 3 SURVEiLLANCEREQUIRENENTS SURVEILLANCE 2. 9. l . () FREQUENCY (S 4 r i
------------------NOT E- - - - - - - - - - - - - - - - l gN SR 3.8.2.1 The following SRs are requiredfaha-@) ,
l performed: SR 3.8.1.3, 3.8.1.nlitnauerU j SR 3.8.1.11, ism 31m i u m r-- - o 3 ana3 C46f 70ao-s= '=i!=_9.!ad5R1?i k e ._____j i In accordance l with applicable j
@ For SRs AC sources of Specift_ required cation 0.3.1, except to be OPERA SR$
8tE the - SR 3.5.1 5 ER 1 Kl.L7. and SR 3_BH,ZQJ i are applicable. ) Rev I, 04/07/95 BWR/4 STS 3.8-20 Revision C I n/rg /pg 1
O AC Sources-Shutdown B 3.8.2 , 1 Mt Basts. APPLICABLE within the ACTIONS. This allowance is in recognition that SAFETY ANALYSES certain testing and maintenance activities must be (continued) conducted, provided an acceptable level of risk is not exceeded. During MODES 4 and 5, performance of a j significant number of required testine and maintenance I activities is also required. In M00El 4 and 5, the l activities are generally planned and administrative 1y l controlled. Relaxations from typical MODES 1, 2, and 3 LC0 requi m ments are acceptable during shutdown MODES, based on:
- a. The fact that time in an outage is limited. This is a risk prudent goal as well as a su mar economic -
consideration. 4 I
- b. Requiring appropriate compensatory seasures for certain conditions. These may include administrative controls, reliance on systems that do not necessarily aset typical design requirements applied to systems credited in operation M00E analyses, or both.
- c. Prud $ consideration of the risk associated with multip e activities that could affect multiple systems.
O d. Maintaining, to the extent practical, the ability to perfore required functions (even if not meeting MODES 1, 2, and 3 OPERABILITY requirements) with systems assumed to function during an event. In the event of an accident during shutdown, this LC0 ensures the capability of supporting systems necessary for avoiding immediate difficulty, assuming either a loss of all power or a loss of all onsits tesel generator jF***** *=U1c% m The AC sources satisfy Criterion 3 ofr%vrad
%ge Aso.sc(OUdi4(ftf3-Y f % iaa 1 One circuit capable of supp y ng the Class 1E LC0
# . power distributian subsystem (s) of LC0 3.8. 1stribution Systems-Shutdown," ensures that 11 i loads are ,A
. powered fromeruum power. An 0 inssocia_ with Oc arpimtaussen states reatnaeren safety Fealkre frJ D bus verse (y,4, kV ersefjess.yf tred OPERABLE by LCO 3.8 5, ensures (sasys tem) that a d'
- OI N . (continued) 5 3.0-36 Rev 1, 04/07/95 gWR/4 57$
Revision C O z__
l AC Sources-Shutdown O 5 8 3.8.2 BASES N I gas (sudsys % power source is available providi elec r ca' power LCO (continued) support assuming a loss of :ircuit. ether A OPERASILITY of the reg'? circuit and M l
- the availability of su' ficient AC sources to operate the plant in a safe unner and to sitigate the consequences of postulated events during shutdown (e.g., fuel handling accidentsandreactorvesseldraindowgnpmfg
,y The ir 'sr circuit (s) must be canable of P4)2 main a a ng rated ' and volt 11e connected to their re &aativa 4 , and of capting required t.CO J.8J
" 1 au3 (4 4, xV erme.vieac 7 loses thosecuring an'acc that are dent. instno, isas describ9d arr - circuits a saa ans are na t er the w licensing bests for tastust9. ft ine errsus cir.uiT. consiaq
- d. d the 2C or tartup yauxilia in ing pr- r anu anu.J ::t transformer SAT),associat 2C or 20 SA ,
the respo circuit includt f r breakers t all) don.d. ?av41elig,) 4.16 kV ESF beses reeuired LC0 3 .10. / sat >sys m ED4 The requi st De capania of starting, accelerati to A rated speed a oltageoconnecting to its respective en'ev9)M _Dus on detection of pus undervolt and accepting required A gg Dt3 I loads. Tnts s st ccog ished within st also be capable of accepting M io seconds.
-lt e, reavired lo assumed loading seance 'j'[
O ye f yn intervals, and must conti can be restored to the required to be met 6 e va var m s er -W operate until arr m newer ses.. These capabilities are mann suen]f
-Q fs as in a, - user -ima n.u m- pgAin sta =
capabil K1 g A e inelat ambient conditleng,,) 1tional /_c_\ mus stratap so meet irod Su illances/ e. cap 111 of the to reve e stand status on an 1 11e ope ating in par le1 tes modef g ,g,g f g , p.4..-3 fe d i Proper secuencing of loads, including tripping of CbG fy A gm,,y)g ght m W<aM bw nonessentianloads, is a required function for
/ 0PERA81LITV.) n addition, proper sequence operation is an N
/C \
p,,e . .rs.e=1<'"5 g ,,,,,, o va * *e a *d- integral part circuit OPERA 81LITY since its
' ,,, ,,, 4,, m < <v a d inoperabil' apacts the ability to start a maintain g energized]oadsrequiredOPERA8LibyLCO3.8. .$
e4 4, su bsv5**", lils optable for civi ens to De m ting a sing tive ff=4
=j i
qMrwahe) O tff f Vt. shu conditions, pe
, circui ta eaaa=1v all -ired div4=4 a f Ao K transfer
' capability is required for ^ circuits to De considered
- I' riesce de.
(continued) Rev 1, 04/07/95 BWR/4 STS B 3.3 37 Revision C
t 4 ve,4p .vu Sources-Shutdown \ (wreserve. cireu e w.prm ue 8 3.8.2 et Reque & Amun M
**t t 'd- 8M i BASES ACTIONS .A.2.1.A.2.2.A.2.3.A.2.4\R.1.R.2.R.3.andB.4 (continued)
** i t1y'7conservativ actions is made. With the A
. requi Ainoperabl minimum required diversity of AC OC power sources is not allable. It is, therefore, required
- ; to suspend CORE AL"EAATIONS, vement of irradiated fuel assemblies in the()econda containment, and activities
{ sus /sted that could result un inadve t draining of the reactor vessel. - Suspension of these activities shall not preclude completion of actions to establish a safe conservative condition. l These actions minimize the probability of the occurrence of I postulated events. It is further required to immediately initiate action to restore the required AC sources and to continue this action until restoration is accesplished in o$r to provide the necessary AC power to the plant safety
'C6Ms.
The Completion Time of immediately is consistent with the required times for actions requiring prompt attention. The restoration of the required AC electrical power sources s should be completed as quickly as possible in order to minimize the time during which the plant safety systems any 1 Os be without sufficient power. 1 Pursuant to LC0 3.0.6, the Distribution System ACTIONS would not be entered even if all AC sources to it are inoperable, resulting in de-energization. Therefore, the Required 1 Actions of Condition A have been modified by a Note to
- 4. ll, I6/ eM*} indicate that ondition A is entered with no 3 to any requires bus, ACTIONS for LC0 3.8. be PA3 isuadiately ente . This Note allows Conditi A to provide requirements for the loss of the circuit whether or not a division is de-energized 3.8.9M[
provides the appropriate restrictions for the situation involving a de-energized division. g l SURVEILLANCE
- 1R 3.2.2.1 REQUIREMENTS SR 3.8.2.1 requires the SRs from LCO 3.8.1 that are necessary for ensuring the OPERASILITY of the AC sources in ,
other than MODES 1, 2, and 3. SR3.8.1.$isnotrequiredto 1 (continued) B 3.8-39 Rev 1, 04/07/95 8WR/4 STS Revision C
AC Sources-shutdown B 3.8.2 f41 ' sAsEs SURVE!LLANCE st 1.a 2.1 (continued) O Ne N D REQUIREMENTS pe set since only one circuit is required to be OPERABLE. p a.s.a.a is nos rugvi to se sus cause in
'orCRABLE ) is not re to und o periods gg
$rmrui.of beisynchronit to the offst circuit. 3.8.1.2 is ex ted because tarting i e is n reauired with DGin) tha is nat M ta ha OPro irj Refer to the corresponding Bases for LC0 3.8.1 for a discussion of each SR. gubsyst:em)
This SR is modified by a Note. The reasos for the Note is to preclude requiring the OPERABL DGlWfrom beine parallnled with the fogrstrerpower networn or otherwise S D randered inoperable durine the serformance_of SRs, and to / h yy prsclues esenergizing a requireti em v >= bus or s disconnecting a required armuesc' (eers eAY of SRs. With limited AC sources available,ri:uit a si during h,,performance $ event could compromise both the requi circuit and is the intent that these 3Rs must still be cape of'be',ng O met, but actual rformance is not required during periods ; whenthej@DG __ nd circuit is required to be OPERABLE. seser W) (E"b5(fte*3 h O tsu h ryste@ REFERENCES
~
, e o cf.t to.36G)Nh B 3.6-40 Rev 1. 04/07/95 OWR /4 STS A
Revision C ulu ff s I;
p AC Sources-Shutdown 3.8.2 l 3.8 ELECTRI' CAL POWER SYSTEMS (] 3.8.2 AC Sources-Shutdown . z i LCO 3.8.2 LThe following AC electrical power sources shall be OPERABLE: , (
- a. One reserve circuit between the 115 kV transmission {
. network and the plant Class 1E AC electrical power distribution subsystem (s) required by LC0 3.8.8, {
" Distribution Systems-Shutdown"; and j i
l b. One emergency diesel generator (EDG) subsystem capable l -) of supplying one division of the plant Class 1E AC l l . electrical power' distribution subsystem (s) required by , LC0 3.8.8. I 1 APPLICABILITY: MODES 4 and 5, During movement of irradiated fuel assemblies in the secondary containment. D
'u) i l
l a b];
- /
f l
-JAFNPP 3.8 12 Amendment (ITS Submittal Rev. C)
AC Sources-Shutdown 3.8.2 lC ACTIONS l- CONDITION REQUIRED ACTION COMPLETION TIME I I A. (continued) A.2.4 Initiate action to Immediately restore required ! reserve power circuit to OPERABLE status. B. One required EDG B.1 Suspend CORE Immediately subsystem inoperable. ALTERATIONS. l AND ; B.2 Suspend movement of Immediately irradiated fuel assemblies in secondary containment. AND (G) B.3 Initiate action to Immediately suspend OPDRVs. AND i i B.4 Initiate action to Immediately i restore required EDG subsystem to OPERABLE l status. l l l t i
) '(V i
l JAFNPP 3.8 14 Amendment ! (ITS Submittal , lev. C)
I 1 AC Sources-Shutdown B 3.8.2 f3 g BASES APPLICABLE . 'The AC sources satisfy Criterion 3 of 10 CFR 50.36(c)(2)(ii) SAFETY ANALYSES (Ref. 1) . (continued) LCO- One reserve circuit capable of supplying the lant Class 1E
' power distribution subsystem (s) of LC0 3.8.8,p" Distribution Systems-Shutdown," ensures that all required loads are powered from reserve power. An OPERABLE EDG subsystem, l associated with a 4.15 kV emergency bus required OPERABLE by LC0 3.8.8, ensures that a diverse power source is available
- for providing electrical power sunort assuming a loss of the reserve circuit. Together, O MRABILITY of the required reserve circuit and EDG subsystem ensures the availability l of sufficient AC sources to operate the plant in a safe manner and to mitigate the conseguences of postulated events during shutdown (e.g., fuel handling accidents and reactor vessel draindown).
The reserve circuit must be capable of maintaining rated frequencv and voltage while connected to its respective 4.16 kV ' emergency bus, and of accepting required loads during an accident.' Reserve circuits are those that are described in LC0 3.8.1 Bases and the UFSAR and are part of ie)_ the licensing basis for the plant. The required to accelerating EDG subsystem rated speed andmust be capable voltage, of starting,ing, force parallel connecting to its respective emergency bus on detection of bus undervoltage, and acce) ting required loads. -This sequence must be accomplis 1ed within 10 seconds. The l required EDG subsystem must also be capable of accepting required loads within the assumed loading seguence intervals. and must continue to operate until reserve or backfeed power can be restored to the emergency buses. These capabilities are required to be met with the EDG subsystem in standby with engines at ambient conditions. I Proper seguencing of loads, including tripping of nonessential loads, is a required function for EDG subsystem l OPERABILITY. The necessary portions of the Emergency Service Water System and Ultimate Heat Sink are also required to provide appropriate cooling to the required EDG subsystem. In addition, proper seguence operation is an l ,. integral part of reserve circuit OPERABILITY since its
~inoperability F l l' ! !qg . (cantinued) l JAFNPP B 3.8 31 Revision 0 (ITS Submittal Rev. C)
m AC Sources-Shutdown B 3.8.2 m C 1 BASES
%)
ACTIONS suspension of irradiated fuel assembly movement are not (continued) postponed due to entry into LC0 3.0.3. j A1 A reserve circuit is considered inoperable if it is not i available to one required 4.16 kV emergency bus. If two 4.16 kV emergency buses are required per LC0 3.8.8, one division with reserve power available may be capable of supporting sufficient required features to allow continuation of CORE ALTERATIONS, fuel movement, and operations with a potential for draining the reactor vessel. By the allowance of the option to declare required features inoperable with no reserve power, ap3roariate restrictions can be implemented in accordance wit 1 tie affected required feature (s) LCOs' ACTIONS. Required features remaining powered from a reserve power circuit, even if that circuit is considered inoperable because it is not aowering other required features, are not declared inoperaale by this Required Action. 7 A.2.1. A.2.2. A.2.3. A.2.4. B.1. B.2. B.3. and B.4 (O With the reserve circuit not available to all required 4.16 kV emergency buses, the option still exists to declare all required features inoperable per Recuired Action A.1. Since this option may involve undesirec administrative efforts, the allowance for sufficiently conservative actions is made. With the required EDG subsystem inoperable (or l with the required reserve circuit inoperable and Required Action A.1 not taken), the minimum required diversity of AC power sources is not available. It is, therefore, required to suspend CORE ALTERATIONS, movement of irradi'ated fuel assemblies in the secondary containment, and activities that could result in inadvertent draining of the reactor vessel. Suspension of these activities shall not preclude completion of actions to establish a safe conservative condition. These actions minimize the probability of the occurrence of postulated events. It is further required to immediately initiate action to restore the required AC sources and to l continue this action until restoration is accomplished in l order to provide the necessary AC power to the plant safety systems. O J (continued) JAFNPP B 3.8-33 Revision 0 (ITS Submittal Rev. C)
p AC Sources-Shutdown B 3.8.2 Y n Q BASES ACTIONS ~ A.2.1. A.2.2. A.2.3. A.2.4. B.1. B.2. B.3. and B.4 (continued)
- 'The Completion Time of immediately is consistent with the L . required times for actions requiring prompt attention. The
- restoration of the required AC electrical power sources l should be completed.as quickly as possible in order to minimize the time during which the plant safety systems may be without sufficient power.
L Pursuant to LC0 3.0.6. the Distribution System ACTIONS would L not be entered even if allL AC sources to it are inoperable, L .resulting in de energization. Therefore..the Required Actions of Condition A have been modified by a Note to L indicate that when Condition A is entered with no AC mwer to any required 4.16 kV einer must be immediately entered.gency bus. allows This Note ACTIONS for LCO Condition A 3.8.8 '
- to provide requirements-for the loss of the reserve circuit l- whether or not a division is de energized. LC0 3.8.8 provides the appropriate restrictions for the situation involving a de energized division.
l SSURVEILLANCE SR 3.8.2.1 ! REQUIREMENTS SR 3.8.2.1 requires the SRs from LC0 3.8.1 that are necessary for ensurinq the OPERABILITY of the AC sources in other than MODES 1, 2. and 3. SR 3.8.1.7 is not required to be met since only one reserve circuit is required to be OPERABLE. -Refer to the corresponding Bases for LC0 3.8.1 for a discussion of each SR. This SR is modified'by a Note. The redson for the Note is l . to oreclude requiring the OPERABLE EDG subsystem from being ! par'lleled a with the reserve 3ower network or otherwise i rendered inoperable during t1e performance of SRs, and to i preclude de energizing a required 4.16 kV emergency bus or t discor.necting a required reserve circuit during performance H of SRs. With limited AC sources available, a single event l could compromise both the required reserve circuit and EDG-l subsystem. It is the intent that these SRs must still be capable of being met, but actual performance is.not required l during periods when the EDG subsystem and reserve circuit is required to be OPERABLE. REFERENCES 1. '10 CFR 50.36(c)(2)(ii), 10-JAFNPP- B 3.8 34 Revision 0 l (ITS Submittal Rev.'C) ). W'
1
\
O ' v0LUME 16 LE 3.8.3 THRU 3.8.8 CONVERSION PACKAGES l This page provided as'a place holder and to assist personnel updating the JAFNPP ITS submittal to Revision C. O Discard this page along with pages removed in accordance with the page replacement instructions. i a i i O i
rq O g
' k
_3 E$h l ~D 3 5 3 i
+
dd i
)Ip: ;q ig a 4 4 t g
ap ip n , 8 ji
;w ;w & i I
4 1"1 1 3
"; 1:
mg -{n%g ! g i= 2 i 1 a = ee i i t t. s a I {k k I u I.ti a 1 ei o *[ i "\,e1 li 9a Or ta i 9 !4 "i Ll I sib, a}, x,1) l! (g 1 4: ug-s
.)
\g" \ 5;"
,(
1 o ao Ob o. h w, a t 24 i
,\ S L; 1 di v A}
44 g
}}
a 11 % u o t si ; e il ll
~
m
= -
=
~
O = a 3 u 8 b ,
= -
3 f o C
=
=
n 2- n - i o i o t s a e i v c g e i a - f i P R c e p w w
.S k .
n - l a b - l y l a - n i o . O t n ~ e t - i n - e g a - p - i s h T -,
~
O i
F O y; A f e i h, , Q {}
- a \
e \ a j0
^
V x8
}hN> a e$qk d (j,Qu O 1 1 (i pI(h{l 5
{ii hfh fj h O
\
$%[% sa 1s i
/
%(i!Yiy\\
\
\ !
O _ 3 , h [, _ 3 f o C n M n _ i o i o t s a e i v c g e i f a i P R c e p
.S .
k _ n l a b l y l a n i o O t n t e i n e g a p i s h T O
~
O 3, g 8 , 3 s
. d e -
n y e n beo k c e t ri o yi g a t 's hc l
; ll e l i n t t h ei sd r 6
li i t a abetbwrnoe uac t i o- ootb rk l fs n roldt ca ac b c om1s asotl aa rl a C y rol ifee a mtf i o r e el i do sbenirset g nwl erni nuew t e l sh ee c y-if 6 n o - i e- m ph e cil a t atii ga cah ret y sb e e i i s e hiDl r , epthehi v NR il
*- ch at en
?
t s y a w yh s t nd e csnaoeWbedb
.tptl om i dl eh a
d nv~ ai e S' S r
.sn remme e i i hogeel rl 0t era orcl K t oa p hs t nc oer e
rQ e tt r td e el 0tt ec h . w naes ct ar 2. ut n a pe t o ormyocf n s P C meESt aaa5 n hetrd , ; cgnoetl et ndta p d oeyhr ssn ii o m r a - {A a e i a-att reh eldaaaltdaegs enritl esuet sa ,dnsid i a ett n-h p e
. cedni rsai ra c _
)
d g nieenoauoat uo Od r Gi t pbl maDI Oa nl
't e Q
n m . . 5 . o E 5 2 ( c ? 9 B
. he 0 -
4 L. 8 l 2 L h_ b - O . e {S R M
}
r l ge od b g d g l nn t oea rf . ne o snf _ P l .s ii n ci n r 7 o old s i n it l mio _ P e
- 3. ri ml oarie t l er mi ra l el e [
' M h o ieel ph a di c u ol a eh atodnbn A -
F s cet rp ocrnt ao c c pt . , yceilh sono i
- A s B. o nna e ueeslh n yi l O r J r e a 9.tc i otdahesn se ur td een p
4 i nt r ad e e s aao esl tl t neiai s
- wt3a op pe.r e
ty al enosmn agGhoe2 tib t tt rd eb g w hd h w amscoiianotns o n C :a. hnvif s t n ho af vDrid cxc 2. e t ort eneli usAdlh il esretili t ree o f vrerypouA elttcro oi A q itre B. h emsol n de nat e r l pcooh ett _ m t moecbur ohi meedb n cs .hci i t. t e
- 9. n i rr tf ,i ssma etD .csw e
il sei,ee tbeussgrtee tad en O. . s e e r s y r h yl ern arnsyranhlfRo C - y l9c A. 3 .hwne . eeneiaotcbhoo el iiae etbi c L u - S e hl ommdf natti hirt md m s m a e s f 3 1. t io th rr sder ct t aenr E meineytl nd r ,h d r ayoe7negef ai vhoe7 de eo e pt rll f p adrpied rat cp tt aapa o w o o n 8. cd y i e i taonsetvm drieo.rn o eins e i tte,seayne dnst od s
,c s p td 9. x n P f v aie oEeyec f o ri e d S ol ehta p#
ie3eo aahr cer rah anhe gmnxurcn cbrt s C gt n x v ph a d t d aanin . A
- ifa.c ll dsu oer erosh t
,lo dsuroedodr niooirft oraapme et dunesve r exis o r
9 3 t J nioei y bact l 4. ldo a rctoseb mt sc a r oesl eo l pee d 8. crhiat metvr ei e7t rhsat o c n i ow ret rl st rysei sa met nr hee ow aett nreseia t l ch l
% n. -
)
d e g a v s ft 9. e r o r e p o r a a yh xn asi3h F po s o n o ed St ei r o r r p o o e o r yh tl4 Fpot onbGcastsp haEt n _
't r
e e aced t n m hepnn ; . l e. o c E Tbsai 1 2 d n _ ( e _
. m -
9 B A 3 _
- /s _
l i h O
O - 3 8, - 3 f o C - n (p n i o i o t s a e i v c g e i a f i P R c e p
.S k
n - l a b l y . l a n i o _ O t n t e - . i n _ e g _ a p i s _ h _ T _ O i
l M'T DISCUSSION OF CHANGES Q lITS:~3,8.3 DIESEL-FUEL OIL, LUBE OIL,-AND STARTING AIR
- ADMINISTRATIVE CHANGES-LA1 ~In the conversion ~of the James' Ai FitzPatrick Nuclear Power Plant (JAFNPP)' Current Technical Specifications (CTS) to the proposed plant specific Improved. Technical Specifications (ITS) certain wording
! preferences or conventions are adopted which do not result in technical changes. Editorial changes,.' reformatting, and revised numbering are adopted to make ITS consistent with the conventions in the Standard
-Technical Specifications, General Electric Plants, BWR/4, NUREG 1433, ,
' Revision;1 (i.e., Improved Standard Technical Specifications (ISTS)). 1 These changes are administrative. and have no adverse impact on safety.
A2- CTS does not restrict the.use of' separate Condition entry for each EDG. l ITS 3.8.3 ACTIONS are preceded by a Note which specifically allows l
. separate Condition entry for each EDG. In conjunction with ITS Section 1.3.-- Completion Times, this Note provides explicit instructions for '
proper application of the new Specification. It is intended that each Required Actic be applied. separately for each affected EDG regardless i of whether it d-been applied previously for inoperable diesel fuel oil, lube'oi. ? starting air functions. This change is considered administrative since_the same allowance is provided in both CTS and ITS. iTECHNICAL CHANGES MORE RESTRICTIVE M1 CTS 3.9.C and 3.9.C.3 requirement, to restore fuel oil storage quantity for each operable pair of Diesel Generators (each EDG subsystem) from < l 64,000. gallons (7 days'at full load) to a 64,000 gallons within 48
-hours, is being changed. ITS SR 3.8.3.1 requires verification, every 31
' days, that each fuel oil storage tank contain a 32,000 gallons. The
- portion of this change from 64,000 gallons per pair to 32,000 gallons per EDG is considered administrative. In addition, ITS 3.8.3 ACTION A requires, that should the diesel fuel oil for any one EDG decrease to <
32,000 gallons (7 days) and > 28,000 galkn: (6 days), it be restored to a 32,000 gallons within 48 hours. Also 1 5 3.8.3 ACTION F has been added to; declare the affected EDG subsystem inoperable if the Required l Action ~ and associated Completion Time for ACTION A is not met or if the EDG fuel oil is-not within limits for any other reason. Addition of the low limit on the amount of diesel fuel available and ACTION F is
;necessary to ensure EDG subsystem OPERABILITY, is consistent with NUREG- l 1433, Revision 1, imposes additional operational requirements, and is' considered'more restrictive. This change is considered to have no
- adverse impact on safety. .;
M2 CTS 3.9.C provides requirements for diesel fuel, an EDG support system. ITS.3.8.3 adds the' appropriate LC0 requirements and associated ACTIONS, and Surveillance Re_quirements to ensure the EDG lube oil inventory, an JAFNPP. Page.1 of 5 Revision C
b Q
?ITS: 3.8.3 DISCUSSION'0F CHANGES DIESEL FUEL OIL, LUBE OIL, AND STARTING AIR lIECHNICAL CHANGES J MORE' RESTRICTIVE
-M2L (continued):
, .EDG support system, . is within limits. ITS LC0 3.8.3 requires lube oil to be within limits for each EDG required to be OPERABLE. ITS SR 3.8.3.2 establishes and verifies lube oil inventory is = 168 gallons '(7-days at full ioad) each 31 days. In addition ITS 3.8.3 ACTION B,
,establishestherequirementtorestorelubeoilinventorytowithin
' limits ~within 48 hours for'one or more EDGs.with lube oil- inventorv
< 168 gallons and > 14Igallons (6 days at full 1oad). Also ITS 3.B.3 ACTION F has been added to declare the affected EDG subsystem inowrable l
if the Required Action and associated Comoletion Time for ACTION 3 is
- not met or if the.EDG lube oil'is not within limits for any other l reason. Adding the diesel lube oil LCO-limitation, Surveillance
; Requirement,'and associated ACTION, is necessary to ensure EDG subsystem l OPERABILITY, is consistent with NUREG 1433, Revision 1, imposes (
' additional. operational requirements, and is considered more restrictive. I This change 1s considered to have no adverse impact on safety. 1 H3 'ITS 3.8.3 adds the appropriate LC0 requirements and associated ACTIONS, and Surveillance Reauirements to ensure the EDG" fuel oil, an EDG support s stem, is within 1fmits. ITS LC0 3.8.3 re uires diesel fuel oil to be-
.Q.
wfthin limits .for each EDG required to be OhERABLE. ITS SR 3.8.3.3 I
~U - establishes and verifies fuel oil properties of new and stored-fuel oil are tested in accordance with, and maintained within the limits and Frequency.of the Diesel Fuel Oil Testing Program (ITS 5.5.10). In
. addition,-ITS 3.8.3 ACTION C. establishes the requirement to restore
-fuel oil total particulates to within limit within 7 days. for one or more EDGs with total particulates not within limits. In addition ITS I 3,8.3-ACTIOND,establishestherequirementtorestorestoredfueioil j properties to within -limit within 30 days, for one or more EDGs with i total particulates not within limits. Also ITS 3.8.3 ACTION F has been added to declare the affected EDG subsystem inoperable if the Required l Action and associated Completion Time Jor. ACTIONS C or D are not met or
.if the EDG fuel oil is not within limits for any other reason l consistent with the Applicability. Adding the diesel fuel oil LC0 limitation,- Surveillance Requirement and associated ACTIONS is
'necessarytoensureEDGsubsystemOP$RABILITY,isconsistentwithNUREG- l ,
1433,: Revision 1, imposes additional operational requirements, and is ! considered more restrictive. This change is considered to have no j adverse impact on safety. 1 i M4 LCTS 4.9.B.2 requirement, to check diesel starting air -is being l
- supplemented. ITS 3.8.3-adds the appropriate LCO requirements and
' associated ACTION, and Surveillance Requirements to ensure the EDG required-(only one of the two air receivers, and' associated air start
' header, per EDG is required since each air receiver has the required
,d Q,
{ , JAFNPP; ,Page 2'of 5 Revision C
.l f i
k
_ _ n , t x o 3 O . DISCUSSION'0F CHANGES V ITSL 3.8.33 DIESEL FUEL' OIL,' LUBE OIL, AND STARTING AIR iTECHNICAL CHANGES MORE RESTRICTIVE-M4 (continued) startin air receivers,-an EDG su caacity)ITSLC0$.8.3reuiresdieselstarkportsfstem,iswithin' limits. 1n ai to-be within. limits u'
'for each EDG required to .0PERABLE. ITS SR .8.3.4-establishes and
- 'forverifies' requiredInstarting 5 starts). additionair ITS receiver 3.8.3bTION A E, establishes theressure is a 180 psig (c F
-re uirement to restore required starting air receiver pressure to a 180
/ps g within 48 hours, for one or more EDGs with required starting air :
-receiver. ressure < 180 and a 150 psig (minimum requirement for 1 i start . ' lso ITS 3.8.3 ON F has been added to declare-tne affected EDG s bsystem inoperable if the Required Action:and associated l 1
'C letion Time for ACTION E is not met or if the EDG starting air R
'su system is not within limits for any other reason, consistent with the Applicability. . Adding the diesel starting air receiver pressure LC0
' limitation Surveillance Reouirement, and associated ACTION-is necessary-toensure.8DG<subsystemOPERABILITY,isconsistentwithNUREG1433, l 4
. Revision 1, imposes additional operational requirements. and is ' 1 considered more restrictive. This change is considered to have no adverse impact on_ safety.
TECHNICAL CHANGES LESS' RESTRICTIVE (GENERIC) LAl" :The' operational details of CTS 4.9.C. which require that the quantity of
. diesel; fuel available in each storage tank be manually measured once per l month and compared to the reading of the local level indicators to ,
, ensure-the proper operation thereof, is being relocated to the Technical 1 uirements Manual. The requirements of 'ITS SR 3.8.3.1 to verify each 1- oil storage tank contains.m 32,000 gallons of fuel each 31 days-is
- sufficient to ensure the required fuel is available to supmrt EDG i
-OPERABILITY.. Therefore these details are not reguired to m in the ITS :
to provide adequate protection'of the oublic health and safety. At ITS im lementation, the relocated items will be incorporated by reference in o the UFSAR. Changes to the relocated items in the Technical
. Requirements Manual will .be controlled by the provisions of
')10 CFR 50.59. <
l LA2' The' details of CTS 4.9.C.1, which lists fuel oil properties are being i
- relocated to the-Technical Requirements Manual. The requirements of ITS SR 3.8.3.3~ to verify fuel oil properties of new and stored fuel oil are Ltestedlin accordance with, and maintained-within the limits and Frequency of.the Diesel Fuel-Dil Testing Program (ITS 5.5.10) is sufficient to-ensure the diesel fuel oil is acceptable to support EDG
. OPERABILITY.Therefore these details are not reguired to be in the ITS
- Lto provide. adequate protection of-the public health and safety. At ITS h.
IJAFNPP Page 3;of 5 Revision C
f' DISCUSSION OF CHANGES d ITS: 3.8.3 - DIESEL FUEL OIL, LUBE OIL, AND STARTING AIR TECHNICAL CHANGES LESS RESTRICTIVE (SPECIFIC) L3 (continued) 4 psig. The-requirement to check the EDG air start compressor for operation is unnecessary and is proposed to be deleted. The requirement to verify pressure.is a 180 asig in the air receiver is sufficient to ensure proper operation of t1e EDG starting air compressor and its ! ability to recharge air receivers since if the EDG starting air i compressor was inoperable, it would not be possible to maintain the required pressure in the associated air receiver. In addition, with the - air receiver pressure = 180 psig, sufficient air start capacity is l available for each EDG without the aid of the EDG air start compressor. If the EDG air compressor could not operate to maintain the required air start receiver pressure, then ITS 3.8.3 ACTION E must be entered, and l de>ending on the air start receiver pressure, the associated EDG suasystem may be required to be declared inoperable immediately and l a)propriate ACTIONS taken. As a result, the change has no impact on the aqility to maintain the associated EDG subsystem Operable. l ( -TECHNICAL SPECIFICATIONS RELOCATIONS None l 1 I i A'J
'JAFNPP Page 5 of 5 Revision C i
n :.
E , l, - fg NO SIGNIFICANT. HAZARDS CONSIDERATION y: ITS: 3.8.3. DIESEL FUEL OIL, LUBE.01L, AND STARTING AIR TECHNICAL-CHANGES < LESS RESTRICTIVE (SPECIFIC) eL3 CHANGE New York Power Authority has evaluated the proposed Technical Specification L . change and has concluded that it'does notiinvolve a significant- hazards
, : consideration. 2 0ur conclusion is in accordance with the criteria set forth in
~ L- 10-CFR 50.92. -The' bases?for the-conclusion that the proposed change does not' involve a significant hazards-consideration-are discussed below. u-
- 1. Does the change' involve a significant increase in the probability or iconsequences of an accident previously evaluated?
i' This change proposes to delete the explicit' requirement to check the EDG air' start compressor.for operation and its ability to recharge air l receivers. This change does not~ result in any hardware or operating procedure changes. .The..EDG air. start system is not considered as an l initiator of any previously analyzed accident. Therefore, this change ;
- does not significantly increase the frequency of such accidents. The '
. role off the air' start system is in supporting the Operability of the ,
. associated EDG to mitigate the consequences of accidents. The- '
$O;. requirement to verify pressure is a 180 psig in the air receiver is ' ' N./ sufficient to ensure proper operation of the EDG starting air compressor and its ~ ability to recharge air receivers since if the EDG starting air compressor was inoperable, it would not be possible to maintain the required pressure:in_the associated air receiver. In addition, with the l '- air receiver pressure = 180 'psig, sufficient air start capacity is available for each EDG without the aid of the EDG air start ~ compressor. If the EDG air compressor could not operate to maintain the required air start receiver pressure, then the ACTIONS of ITS 3.8.3 must be entered, L 'and depending on the air start receiver pressure, the associated EDG ! subsystem may be required to be declared inoperable immediately and l
-appropriate ACTIONS taken. The change has no im maintain the. associated EDG subsystem Operable. pact on As a result, the ability to accident [
)
consequences are. unaffected by the deletion of the explicit requirements j," for checking the-operation of the EDG air start compressor and its ability to recharge air receivers. Therefore, this change.will not involve a significant increase in the probability or consequences of an Jaccident previously evaluated. i 2.. .Does the change create the possibility of a new or different kind of accident;from-any accident previously evaluated? This change proposes to delete the explicit requirement to check the EDG air start compressor for operation--and its ability to recharge air receivers. Since the EDG air compressor must still be capable of-maintaining the'. associated air receiver pressurized to = 180 psig (as JAFNPPs Page 5 of 6 Revision C i i
o p s q NO SIGNIFICANT. HAZARDS CONSIDERATION Q ITS: 3.8.3 DIESEL FUEL OIL, LUBE OIL, AND STARTING AIR
-TECHNICAL CHANGES LESS RESTRICTIVE (SPECIFIC)
L3 CHANGE
- 2. (continued) required by ITS SR 3.8.3.4) to maintain EDG Operability, the possibility for a new or different kind of accident is not created. Therefore, this change does' not create the possibility of a new or different kind of accident from any previously analyzed accident.
- 3. Does this change involve a significant reduction in a margin of safety?
The proposed deletion of the requirement to check the EDG air start compressor for operation and its ability to recharge air receivers does not impact any margin of safety. The requirement to verify pressure is a 180 psig in the air receiver is sufficient to ensure proper operation , of the EDG. starting air compressor and its ability to recharge air l receivers since if the EDG starting air compressor was inoperable, it j would not be possible to maintain the required pressure in the ; n associated. air receiver. In addition, with the air receiver pressure (dT = 180 psig, sufficient air start capacity is available for each EDG without the aid of the EDG air start compressor. Control of the availability of, and necessary compensatory activities, for the EDG air l start compressor, are addressed by plant procedures and policies. If the EDG air compressor could not operate to maintain the required air start receiver pressure, then ITS 3.8.3 ACTION E must be entered, and de>ending on the air start receiver pressure, the associated EDG suasystem may be required to be declared inoperable immediately and l a)propriate ACTIONS taken. As a result, the change has no imaact on the aaility to maintain the associated EDG subsystem Operable. Tierefore. l 4 this change does not involve a significant reduction in a margin of l safety. 7 JAFNPP Page 6 of 6 Revision C
Diesel Fuel 011 Lube Oil, and Starting Air 3.8.3
- 05) 3.8 ELECTRICAL POWER SYSTEMS
@I P
3.8.3 Diesel Fuel 011, Lube Oil, and Starting Air [14,[ LCO 3.8.3 The stored diesel fuel oil lube oil, and starting air
- - subsystem s d diese LMG generator 11 be within limits for each requirekme<l qeng 3)
W 1E04 When associated s required to be OPERA 8LE. {3 a,c] APPLICA81LITY: SussystewQ ACTIONS
.......__. ..__. ... _ _...____..N0TE--
l - ------------..-.-. -.--.-----.
!$. ..$ .!"[55.f5. . $5.! I.i. *. ..__... _____ ___.______
CONDITION REQUIRED ACTION COMPLETION TINE !
~ ems
- 39. f.[- A. One or more with A.1 Restore fuel oil 48 hours
' fuel oil level level to within
/ @, (>Jm unu ) gal and \, XI limits. z w so; gal in / 5 [M9 storage tank.
- 8. One or no th 8.1 Restore lube oil 48 hours lube il inventory inventory to within i limits. l x l1'
- gal 8 i- andMD gp F** D ?
with C.1 Restoreifueloil 7 days C. One or more stored fuel total total particulates to L particulates not within limit. f'"3] within limit. (ca.itinued) 3.5-21 (Rev f. 04 Af/92 ' I YA tiid/4 fD 411 Ame,>et maQ i \* y s TRFNPC Revision C
Diesel Fuel 011, Lube 011, and Starting Air 3.8.3 pal , J ACTIONS (continued) COMITION REQUIRED ACTION COMPLETION TIME 0.1 Restore stored fuel 30 days D. One or more new fuel oil oil properties to {AA3,) roperties not within within limits. inits.
~
NWi$ E. One or more 04s ! E.1 Resto tarting air 48 hours startine ai receiver receiver pressure to [] pressu < sig 2rdoisms. h)Aiu Iwi tsj l g N N F. Required Action and F.1 Declare associa a Ismediately
# t associated Completion inoperable.
1 '"$ "
- s pa),4t a p kabsfSteWQ W 3 & A, B, C, Door 6)
PA One or more CD with .] diesel fuel oil, lube l oil, or starting air l subsystem not within limits for reasons other than Condition A, B, C, D, or E. 3,s.gg Rev 1, 04/07/95 BWR/4 STS Revision C 1
r Diesel Fuel 011. Lube Oil, and Starting Air B 3.8.3 3ASE3 u bsysted) AppLICA81LITY and starti i ir are required to be within limits when the A (continued) associated is required to be OPERABLE. LO
' ACT!0lts The ACTICIts Table is edified by a flots i cating that separate Condition entry is allowed for each20G. This is acceptable, since the Required Actions for each condition i provide appropriate coupensatory actions for each inoperable (
ou o 1 ton separate Condition entry and app cat 181Fo associated Required Actions. g FWin fs.ss , a l <vs\ 4 12S** .P' d*~'O y is a s tee nse 4*.s k f ,
,the7dayfueloilsupplyforf is not available. However, the Condition .s restricted to fuel oil 6 level reductions that maintain at least a 6 day supple /
These circumstances may be caused by events such as:
- a. Full load operation required for an inada rtent start while at minimum required level; or
- b. Feed and bleed operations that may be necessitated by increasing particulate levels or any number of other oil quality degradations.
This restriction allows sufficient time for obtaining the requisite replacement volume and performing the analyses required prior to addition of the fuel oil to the tank. A period of 48 hours is considered sufficient to complett restoration of the required level prior to declaring the inoperable. This period is acceptable based on the remaining capacity (> 6 s), the fact that will be initiated to obtain enishment, and the ou probability of an event during this brief period, cM*d P6 L1 16 0
. With lobe oil inventory < b al, sufficient lube oil to support 7 days of continuou operation at full load conditions may not be availab e. However, the Condit. ion is 6
(continued) B 3.g.43 Rev 1, 04/07/95 j SWR /4 STS Revision C O I
Diesel Fuel 011, Lube Oil, and Startin5 Air Q 8 1*1 dm s :.. . a, .4 .a 8 pm U s.. aa +. no . a . -, u-x , IAEES c.> w iu+. n ie c s4. +>.a 1sg,4_gaustus. ACTICIts R d (continued) g the fuel oil properties were outside limits, there is high j likelihood that t would still be capable of performing / its inten6ed function. c g 09eced g W1 tarting air receiver press < psig, sufficient DBf capacity for five successive does not exist. However, as long as the receiver pressure is W g m psig, there is adeouate capacity for at least one f start attment, and the 33E can be considsred DPENABLE while the air receiver pressun is restored to the required limit. A period of 48 hours is considered sufficient to complete restoration to the required pressure prior to declaring the 0G inoperable. This pertad is acceptable based t e remaining air start capacity, the fact that most s arts are accomplished on the first attempt, and the low probtbility of an event during this brief period. P6 [e $ IL.,.ti 9.a A. B.C . O # u O' With a Required Action and associated Completion Ti ast, or the stored diesel fuel oil, lube oil, or starting air subsystem not er thin limits for reasons other tha not {l3, t'0,, addressed Dy conett' ens A MS E, the associated y be incapable of performing its 'n W function and t be immediately declared inoperable. (subsysteg SURVE!LLANCE st 2.a.3.1 REQUIRDUTS Titts SR provides verification that there is an adequate inventory of fuel oil in the storage tanks to support uch OS's operation for 7 days at full load. The 7 day period is sufficient time to place the aumLin a safe shutdown condition and to bring in replant'shasatifuel from an offsite
, location, pi.us
. The 31 day Frequency is adequate to ensure that a sufficient supply of fuel oil is avallele, since @g"TE74T 7tifli ai%
(continued) l SWR /4 sTs a 3.8-45 Rev 1. 04/07/85 Revision C
b L Diesel Fuel 011. Lube Oil, and Starting Air
- 3.8.3 L
l3.8 ELECTRICAL POWER SYSTEMS
~3.8.3- Diesel Fuel Oil,- Lube Oil, and'. Starting Air LC0 '3.8.3 The' stored ' diesel fuel oil, lube oil, and starting air subsystem shall be within limits for each required emergency
-diesel generator (EDG).
APPLICABII.ITY:- When associated EDG subsystem is requ1 red to be OPERABLE. l ACTIONS l
.....................................N0TE - -- -- -- - - . -
Separate Condition entry is allowed for each EDG. i CONDITION REQUIRED ACTION- COMPLETION TIME A. .One'or more EDGs'with A.] Restore fuel oil 48 hours ! O(7 . fuel oil level level to within ! (./ . < 32,000. gal and limits. l
> 28,000 gal in !
' storage tank.
l B. One or more EDGs with B.1' Restore-lube oil 48 hours
. lube oil inventory' inventory to within l
< 168 gal and ' limits.
> 144 gal.
l a C. One or more EDGs with C.1 Restore ~ stored fuel 7 days ! stored-fuel oil total oil total ! particulates not- particulates to ! within limit, within limit. (continued)' l l ! JAFNPP. 3.8 16' Amendment
- (ITS Submittal Rev. C) o
Diesel Fuel Oil, Lube Oil, and Starting Air 3.8.3 l Lo l ACTIONS' (continued) CONDITION REQUIRED ACTION COMPLETION TIME l D. .0ne or'more'EDGs with D.1 Restore stored fuel 30 days new fuel oil oil properties to
. properties not within .within limits.
l
, limits.
L i E. One or more EDGs with- E.1 Restore required 48 hours required starting air starting air receiver receiver pressure pressure to within
< 180 psig and limits.
g = 150.psig. j .F. Required Action and F.1 Declare associated Immediately
- associated Completion EDG subsystem l Time of Condition A, inoperable.
B -C, D, or E not met. < m
- One or more EDGs with.
--diesel. fuel oil, lube t oil. or starting air i . subsystem.not within
. 'limitt for reasons other.than'
~ Condition A, B C, D,-
or E. I L l O l
'JAFNPP.
3.8 17 Amendment (ITS Submittal Rev. C) h L
Diesel Fuel Oil, Lube Oil, and Starting Air B 3.8.3
<Q Q BASES LC0 The starting air system is required to have a minimum (continued) capacity for five successive EDG starts without recharging or realigning the air start receivers.
APPLICABILITY The AC sources (LC0 3.8.1 and LC0 3.8.2) are required to ensure the availability of the required power to shut down l the reactor and maintain it in a safe shutdown condition i after an abnormal operational transient or a postulated DBA. Because stored diesel fuel oil, lube oil, and starting air subsystems support LC0 3.8.1 and LCO 3.8.2, stored diesel fuel oil, lube oil, and starting air are required to be within limits when the associated EDG subsystem is required l to be OPERABLE. ACTIONS The ACTIONS Table is modified by a Note indicating that separate Condition entry is allowed for each EDG. This is acceptable, since the Required Actions for each Condition 3rovide a oropriate compensatory actions for each inoperable
/ EDG, Com lying with the Required Actions for one inoperable \ EDG may a low for continued operation, and subsequent inoperable EDG(s) governed by separate Condition entry and application of associated Required Actions.
A.1 With fuel oil level < 32,000 gallons in a storage tank, the 7 day fuel oil supply for an EDG is not available. However, the Condition is restricted to fuel oil level reductions that maintain at least a 6 day sup)1y (28,000 gallons). These circumstances may be caused )y events such as:
- a. Full load operation required for an inadvertent start while at minimum required level: or
- b. Feed and bleed operations that may be necessitated by increasing particulate levels or any number of other oil quality degradations.
1 i ()
. ,m (continued)
JAFNPP B 3.8 37 Revision 0 (ITS Submittal Rev. C) ' t A
Diesel Fuel 011. Lube Oil, and Starting Air B 3.8.3 / \ () BASES ACTIONS F.1 (continued) limits for reasons other than addressed by Conditions A, B, C,- D, or E, the associated EDG subsystem may be incapable of l performing its intended function and must be imwdiately declared inoperable. SURVEILLANCE SR 3.8.3.1 REQUIREMENTS This SR provides verification that there is an adequate inventory of fuel oil in the storage tanks to support each EDG's operation for 7 days at full load. The 7 day period is sufficient time to place the plant in a safe shutdown condition and to bring in replenishment fuel from an offsite location. The 31 day Frequency is adequate to ensure that a sufficient supply of fuel oil is available, since plant operators would be aware of any large uses of fuel oil during this period. O V SR 3.8.3.2 This SR ensures that sufficient lubricating oil inventory is available to supmrt at least 7 days of full load operation for each EDG. T1e 168 gal requirement is based on the EDG manufacturer's consumption values for the run time of the EDG. Implicit in this SR is the requirement to verify the capability to transfer the lube oil from its storage location to the EDG, when the EDG lube oil sump does not hold adequate inventory for 7 days of full load operation without the level reaching the manufacturer's recommended minimum level. A 31 day Frequency is adequate to ensure that a sufficient lube oil supply is onsite, since EDG starts and run time are closely monitored by the plant staff. SR 3.8.3.3 The tests of new fuel oil prior to addition to the storage tanks are a means of determiniN whether new fuel oil is of the appropriate grade and has not been contaminated with O V. (continued) JAFNPP B 3.8 40 Revision 0 (ITS Submittal Rev. C)
-\_ D) VOLUME 18 3 l ITS 3.10 AND 4.0 CONVERSION PACKAGES j 1
)
l This page provided as a place holder and to assist personnel updating the JAFNPP ITS submittal to Revision C. O Discard this page along with pages removed.in accordance with the page replacement instructions. i I v
f' Sp ec;$:c aton 1.10. ) l
' Insert New Soecification 3.10.1 g Insert new specification 3.10.1," Inservice Leak and Hydrostatic Testing Operation," as shown in the JAFNPP Improved Technical Specifications.
i 1 1 O l-l 1 l l l i l l l O e,'/' Revision C a
n ITS: 3.10.1
. DISCUSSION OF CHANGES
() INSERVICE LEAK AND HrDR0 STATIC TESTING OPERATIONS ADMINISTRATIVE CHANGES. None l TECHNICAL CHANGES - MORE RESTRICTIVE None l TECHNICAL CHANGES - LESS RESTRICTIVE (GENERIC) None l TECHNICAL CHANGES - LESS RESTRICTIVE (SPECIFIC) I
. L1 The CTS definition of Shutdown Mode (CT3 Definition 1.0.I.3) requires
. the plant to be considered in Hot Shutdown (ITS MODE 3) when average coolant temperature is greater than 212 F. ITS 3.10.1. Inservice Leak i
- and Hydrostatic Testing Operation, is added consistent with NUREG 1433, (l
v Revision 1, to permit the reactor to be considered to be in MODE 4 (Cold Shutdown).provided certain conditions (MODE 3 requirements for secondary containment, secondary containment isolation valves Standby Gas Treatment System, and secondary containment isolation instrumentation) are met while the reactor is pressurized and the average coolant temperature is above 212 F during the performance of inservice leak and hydrostatic testing of the Reactor Coolant System (RCS). In addition, the CTS require a number of systems, including primary containment, to be Operable when average coolant temperature is above 212 F. This change will allow the primary containment to be open for frequent, unobstructed access to wrform inspections during inservice leak and hydrostatic testing. T11s change will also allow outage activities on various systems to continue while remaining consistent with MODE 4 applicable requirements that are in effect prior to and immediately following inservice leak and hydrostatic testing. As stated above, secondary containment will be maintained during inservice leak and hydrostatic-testing and all required systems with the reactor in MODE 4 vill be Operable in accordance with the Technical Specifications. Because the inservice leak and hydrostatic testing is performed with the reactor nearly water solid (except for an air bubble for pressure control), at low decay heat values, and near MODE 4 conditions, the stored energy in the reactor core will be very low. L Urder these conditions, the potential for failed fuel and a subsequent L increase in reactor coolant radioactivity is minimized. The RCS would '- ; /~3 rapidly depressurize in the event of a large pressure boundary leak and lQ /JAFNPP Page 1 of 2 Revision C u
n X.. DISCUSSION OF CHANGES ( ITS: 3.10.1 INSERVICE LEAK AND HYDR 0 STATIC YESTING OPERATIONS
~
)
TECHNICAL CHANGES - LESS RESTRICTIVE (SPECIFIQ L1- (continued) the low pressure ECCS systems Operable in MODE 4 would be adequate to keep the core flooded. This would ensure that the fuel would not be uncovered and would not exceed the 2200*F peak clad limit. An analysis . was per_ formed to determine the reactor building pressure and temperature l effects if a RCS pressure boundary pipe break occurred during the l inservice leak and hydrostatic testing at a reactor coolant temperature l of'300 F and pressure of 1150 psia. A 24 inch reactor recirculation ! line break was assumed in the analysis because it is considered the most i conservative pipe break with primary containment open (drywell head removed) during the test. The analysis results show that a recirculation line break during inservice leak and hydrostatic testing would not result in a reactor building (secondary containment) pressure : rise sufficient to breach (blow out) the sheet metal building siding and thus result in a breach of secondary containment. In addition, the analysis results show that without credit for drywell cooling and reactor building HVAC operation the increase in reactor building ambient temperature is small and bounded by design basis loss of coolant (s - accident and main steam line break analyses. Therefore, it can be concluded that the consequences relative to control room and offsite doses are bounded by previously analyzed accidents. Further, requiring secondary containment, secondary containment isolation valves, Standby Gas Treatment System, and secondary containment isolation instrumentation to be Operable will assure that potential airborne radioactivity from leaks can be filtered through the Standby Gas Treatment System. This will ensure that doses from any leak or pipe break remain within the_ limits of 10 CFR 100. Finally, allowing primary containment to be ope b ing the performance of inservice leak and hydrostatic testing wiii allow frequent, unobstructed access to the drywell for inswction 'and detection of small leaks before significant inventory loss las occurred. For these reasons the allowance provided by LC0 3.10.1 is acceptable. TECHNICAL CHANGES RELOCATIONS
.None.
O_
~
JAFNPP Page 2 of 2 Revision C
l i e NO SIGNIFICANT HAZARDS CONSIDERATIONS l ITS: 3.10.1 INSERVICE LEAK AND HYDROSTATIC TESTING OPERATION TECHNICAL CHANGES - LESS RESTRICTIVE (SPECIFIC) L1 CHANGE New York Power Authority has evaluated the proposed Tecnnical Specification change identified as " Technical Changes Less Restrictive" and has determined that it does not involve a significant hazards consideration. This i determination has been performed in accordance with the criteria set forth in l
.10 CFR 50.92. .The bases for the determination-that the proposed change does not involve a significant hazards consideration are discussed below. '
- 1. Does the change involve a significant increase in the probability or consequences of an accident previously evaluated?
The 3roposed change allows Reactor Coolant System (RCS) inservice leak
- and lydrostatic testing to be performed with average reactor coolant temperature in excess of 212 F with primary containment open and not consider the plant to be in MODE 3 provided certain conditions are met.
The probability of a leak or a pipe break in the RCS pressure boundary during inservice leak and hydrostatic testing is not increased by allowing the test to be performed with primary containment open and reactcc coolant temperature to exceed 212*F because the RCS is designed
/_}
k - for temperatures exceeding 550 F with similar pressures. In addition, because an inspection is being performed on the RCS pressure boundary while it is being pressurized, the probability of a small leak going unnoticed and resulting in a pipe break is reduced. An analysis was
. performed to determine the reactor building pressure and temperature effects if a pipe break occurred during the inservice leak and hydrostatic testing at a RCS temperature of 300 F and pressure of 1150
)sia. A 24 inch recirculation line break was used in the analysis
>ecause it was considered the most conservative pipe break with primary containment open during testing. This analysis has concluded that a recirculation line break during the performance of the test would not result in a rise in reactor building pressure sufficient to cause a breach of the reactor building (secondary containment). Furthermore, this analysis has shown that without credit for drywell cooling and reactor building HVAC operation, the increase in the reactor building ambient temperature is small and bounded by design basis loss of coolant accident and main steam line break analyses. This change will require that secondary containment, secondary containment isolation valves, Standby Gas Treatment System, and secondaiy containment isolation instrumentation be Operable and capable of handling airborne radioactivity from leaks that could occur during the performance of inservice leak and hydrostatic testing. Requiring secondary containment to be Operable will conservatively ensure that potential airborne radioactivity from leaks or pipe breaks will be filtered through the
(~T Standyby Gas Treatment System, thereby minimizing radioactivity releases V JAFNPP Page 1 of 3 Revision C i L
m NO SIGNIFICANT HAZARDS CONSIDERATIONS O ITS: 3.10.1 INSERVICE LEAK AND HYDR 0 STATIC TESTING OPERATION l TEC'HNICAL' CHANGES - LESS RESTRICTIVE (SPECJELC.)_ L1 CHANGE
-1. (continued)_
to the environment. RCS pressure boundary leaks would typically be detected by inspections during the test before significant inventory loss occurred. Thistis an integral part of the inservice leak and hydrostatic testing operation. Inservice leak and hydrostatic testing is typically performed following refueling at low decay heat values and thus the stored energy in the reactor core will be sufficiently low that even with the loss of inventory following a recirculation line break, core coverage would be maintained and the fuel would not exceed its peak clad temperature limit. Therefore, no significant release _ of fission products would occur. Therefore, this change will not involve a significant: increase in the probability or consequences of an accident previously evaluated.
- 2. LDoesthechangecreatethepossibilityofanewordifferentkindof accident from any accident previously evaluated?
-The proposed change does not involve any physical change to plant
-structures, systems, or components (no new or different type of equipment will be installed and no equipment will be removed).. The
- change will not alter assumptions made in the safety analyses.
Therefore, the change will not create the-possibility of a new or (different kind of accident from sny accident previously evaluated.
< 3 .- Does this changeLinvolve a significant reduction in a margin of safety?
The proposed change allows RCS inservice leak and hydrostatic testing to be performed with average reactor coolant temperature in excess of 212*F
-with primary containment open and not consider the plant to be in MODE 3 provided certain conditions are met. Secondary containment will be required to_ be_ maintained during.the test and all required systems with ,
the. reactor in MODE 4 will be Operable in accordance with the Technical j
-Specifications. Because the~ inservice leak and hydrostatic tests are performed nearly water sLlid (except for an air bubble for pressure
. control). at low decay heat values, and near MODE 4 conditions, the
$ stored 4 energy in the reactor core will be very low. Under these conditions, the potential for. failed fuel and a subsequent increase in coolant radioactivity is minimized. The RCS would rapidly depressurize in the event of a large leak and the low pressure ECCS systems normally l Operable in MODE 4 would be adequate to keep the core flooded. This
.Page 2 of 3 Revision C
~
?JAFNPP-
>q l
e NO SIGNIFICANT HAZARDS CONSIDERATIONS L e)' E( ITS: 3.10.1 INSERVICE LEAK AND HYDROSTATIC TESTING OPERATION
- . TECHNICAL CHANGES - LESS RESTRICTIVE (SPECIFIC) l L1 CHANGE' l
- 3. (continued) would ensure that the fuel would not be uncovered and would not exceed l the 2200 F peak clad temperature limit. Further, requiring secondary
! containment, secondary containment isolation valves, Standby Gas l Treatment, and secondary containment isolation instrumentation to be Operable will assure that potential airborne. radioactivity from leaks can be filtered through the Standby Gas Treatment System. This will ensure that control room and offsite doses will remain within the limits
- of 10 CFR 100. Finally, allowing primary containment to be open during
! the performance of inservice leak and hydrostatic testing will allow I frequent, unobstructed access to the drywell for inspection and detection of small leaks before significant inventory loss has occurred. [ Therefore, the proposed change does not involve a significant reduction in a margin of safety. im. l-d l I A V JAFNPP Page 3 of 3 Revision C
Inservice Leak and Hydrostatic Testing Operation 3.10.1 b l 3.10 SPECIAL OPERATIONS I 1 3.10.1 Inservice Leak and Hydrostatic Testing Operation 3.10.1 The average reactor coolant temperature specified in {L[LCO Table 1.1-1 for MODE 4 may be changed to "NA," and operation , considered not to be in MODE 3; and the requirements of l 6 LCO 3.4g, " Residual Heat Removal (RHR) Shutdown Cooling { System-cold Shutdown," may be suspended, to allow performance of an inservice leak or hydrostatic test
~P h ' provided the following MODE 3 LCOs are met:
- a. LC0 3.3.6.2, " Secondary Containment Isola on .
Instrumentation," Functions @,3,4an of y )gl l Table 3.3.6.2-1; . j
- b. LC0 3.6.4.1, " Secondary Containment";
- c. LCO 3.6.4.2, " Secondary Containment Isolation Valves j (SCIVs)"; and
- d. LCO 3.6.4.3, ' Standby Gas Treatment (SGT) System." )
I 0,LBl j APPLICABILITY: MODE 4 with average reactor coolant temperature > h 'F.
%sD ' -
I l l 1 l t Qg 3.10-1 ev 1, 04/07/93lgP N *S ggpp] A aud <uQ Revislort C
Inservice Leak and Hydrostatic Testing Operation 3.10.1 ACTIONS ________...___________...__...__.....N0TE------------------. --------------_-- Separate Condition entry is allowed for each requirement of the LCO. CONDITION REQUIRED ACTION CONPLETION TINE A. One or more of the A.1 ------NOTE ---- above requirements not Required Actions to met, be in MODE 4 include reducing average reactor coolant . s
~
OI \ Enter the applicable Ismediately Condition of the affected LCO. l 9 11 l 0 8 A.2.1 Suspend act1<ities that could increase the average reactor Immediately coolant temperature or pressure. Alm A.2.2 Reduce average 24 horri reactor coalant t ture to s F. gig _ cLB J BWR/4 STS 3.10-2 Rev 1, 04/07/95 Revision C
Inservice Leak and Hydrostatic Testing Operation 3.10.1 SURVEILLANCE REQUIREMENTS SURVEILLANCE FREQUENCY I SR 3.10.1.1 Perform the applicable SRs for the required According to
^
A MODE 3 LCOs. the applicable /C\ SRs O l ( BWR/4 STS 3.10-3 Rev 1, 04/07/95 Revision C
7 JUSTIFICATION FOR DIFFERENCES FROM NUREG-1433. REVISION 1 ITS: 3.10.1 - INSERVICE LEAK AND HYDROSTATIC TESTING OPERATION RETENTION OF EXISTING REQUIREMENT (CLB) CLB1 The average reactor coolant temperature has been revised to reflect the transition temperature of 212*F used in ITS Table 1.11 to define MODES 3 and 4 which is consistent with the CTS definition of COLD SHUTDOWN. PLANT-SPECIFIC WORDING PREFERENCE OR MINOR EDITORIAL IMPROVEMENT (PA) PA1 The proper LC0 number has been used. PLANT SPECIFIC DIFFERENCE IN THE DESIGN (DB) DB1 The brackets have been removed and the appropriate Functions of ITS Table 3.3.6.2-1 have been included consistent with the design and current licensing basis. DIFFERENCE BASED ON AN APPROVED TRAVELER (TA) O None V ! DIFFERENCE BASED ON A SUBMITTED. BUT PENDING TRAVELE_B (TP) None DIFFERENCE FOR ANY REASON OTHER THAN THE AB0VE (X) None JAFNPP Page 1 of 1 Revision C
Inservice Leak and Hydrostatic Testing Ooeration B 3.10.1 O BASES (continued) b APPLICABLE Allowing the reacto to be considered in MODE 4 during SAFETY ANALYSES hydrostatic or le esting, when the reactor coolant temperature is > 'F, effectively provides an exception to MODE 3 requirements, includi 0PERASILITY of primary containment and the full camp t of redundant Emergency
}I Core Cooling Systems. SinceJu hydrostatic or leak tests
( areand perfomos nearly water solic at low decay heat values, near MODE 4 conditions, the tored energy in the reactor core will be very lou. Under these conditions, the f/3
/g h o *h potential for failed fuel and a sub coolant activity above the LC0 3.4. c Activity," limits are minimized. In addition, the secondary in accordance with this Iguys( M ) containment will be special Operations LCO,OPERABLE, and wi ll be capable of handling any airborne radioactivity or steam-leaks that could occur during the perfomance of hydrostatic or leak testing. The required pressure testing conditions rovide adequate -
assurance that the consequences of a be conservatively bounded by the consequences of t postuisted main steam lina break outside of primary containment rince in Reference 5. Therefore, these requirements A 4 will conservatively limit radiation releases to the /_Ch environment. ,, ,. , w pg; In the event of a large prfmary system iean, the reactor O pl\ vessel would rapidly depressurize, allowing the low pressure core cooling systems to operate. The capability of the low pressure coolant injection and core spray subsystems, as required in MODE 4 by LCO 3.5.2, 'ECCS-Shutdown," would be more than adequate to kaep the core flooded under this low decay heat load condition. Small system 1saks would be detected by leakage inspections before significant inventory loss occurred. - For the purposes of this test, the protection provided by nomally required MODE 4 applicable LCOs, in addition to the secondary containment requirements required to be met by this Special Operations LCO, will ensure acceptable consequences during normal hydrostatic test conditions and during postulated accident conditions.,
compliance with Special l As described Operations in LC0 LCOs 3.0.7,l, and therefore, no criteria of is optiona l 1
l ll (continued) B 3.10-2 Rev 1, 04/07/95 gmP.STs Revision C l O 1 l o
I Inservice Leak and Hydrostatic Testing Operation I B 3.10.1 rA! (d.E (c%Nbb . APPLICABLE
\
ane ma, rolict Sta+ 7 apply. Special Operations LCOs l SAFETY ANALYSES provise riex1hi'ity to perform certain operations by (continued) appropriately modifying requirements of other LCOs. A discussion of the criteria satisfied for the ether LCOs is ' preytded in their respective Bases. N~ LC0 As described i LC0 3.0.7 rations C0isoptional.compliancewiththisSpecial Operation at reactor coolant !
#y temperat > M F can be in accordance with Table 1.1-1 for MODE operation without meeting this special operations em** * *;l LC0 or it ACTIONS. This option any be reestred due to P/T 93 4 t5 ka its, tver which require testing at t @ ratures D/ h *,pa h t- _
> F. %ne narir. ,ityarvice test iveir ..y. s
/uh 8 Ag
,p DpEg/re' 4ed valves to in a " ". orevepiting the sar ILFYf A es , If it is desired to perfore these tests while complying with I I yi this Special Operations LCO, then the MODE 4 applicable LCOs M'8 and specified MODE 3 LCOs must be met. This Special g Operations LC0 allows changing Table 1.1-1 temperature li
$ sy.mits nostem- forshutdown."fP, 3.4) Cold MODEThe 4' Residual to "NA" additionalHeat and suspehding Removal requirements theCoel (MHR) Shutdown for re O sit secondary containment LCOs to be met will provide sufficient rotection for operations at reactor coolant temperatures
@F for the purpose of performing either an inservice caj leak or hydrostatic test.
This LC0 allows primary containment to be open for frequent unobstructed access to perfore inspections, and for outage activities on various systens to continue consistent with the MODE 4 applicable requirements that are in effect immediately prior to and 1sumediately after this operation. , l APPLICABILITY The MODE 4 performance 1nservice 7trementsleak mayoronly be modified hydrettatic tet : for theso untM "8' these operations can be considered asJin riuur. 4, even uough
- the reactor coolant temperature is >f e 'F. The additional requirement for secondary containment OPERABILITY according
. to the imposed MODE 3 requirements provides conservatism in the response of the unit to any event that say occur.
Operations in all other MODES are unaffected by this LCo. F (continued) SWR /4 STS 8 3.10-3 Rev 1, 04/07/95 Revision C
Inservice Leak and Hydrostatic Testing Operation h v B 3.10.1 BASES (continued) SURVEILLANCE SR 3.10.1.1 REQUIREMENTS . The LCOs made applicable are required to have their Surveillances met to establish that this LCO is being met. i A discussion of the applicable SRs is provided in their
-pA 4 respective Bases.
REFERENCES g 1. American Society of Mechanical Engineers, Boiler and Pretr. e Vessel Code, Section XI. F FSAR, Section Q15 g 0J Q 4,[,,/ g 3 1. k tocre 70.% (d c tW& f 2., Thf-calc-mvLY-o2Z5% R an'*onli b6\ rer HEtF A-nm.iys>s b,13 vavostout_
% my s ,m H
k S , Ikf - CAL C - R 8 C - 03 400i Ilt Csio" Q. m-t:- 4 kmur ema:.y w+, l
'~ a %vs En R are. 8,.c a y ,;,g H yd v o, A 34 g ggg I
BWR/4 STS B 3.10-5 Rev 1, 04/07/95 Revision C
p I . I L,- . JUSTIFICATION FOR DIFFERENCES FROM NUREG 1433. REVISION 1 ji ITS BASES: 3.10.1 INSERVICE LEAK AND HYDR 0 STATIC TESTING OPERATION RETENTION OF EXISTING REQUIREMENT (CLB) CLB1.The average reactor coolant temperature has been revised to reflect the i transition temperature of 212 F used in ITS Table 1.1-1 to define MODES l i 3 and 4 which is consistent with the CTS definition of COLD SHUTDOWN. PLANT SPECIFIC WORDING PREFERENCE OR MINOR EDITORIAL IMPROVEMENT (PA) PA1 Editorial changes have been made for enhanced clarity. PA2 The proper LCO number has been used. l PA3 Typographical / grammatical error corrected. PA4 . Changes have been made to reflect the plant specific nomenclature. ' PLANT SPECIFIC DIFFERENCE IN THE DESIGN (DB) D DB1 A plant specific analyses were performed which show that even if a l recirculation line break occurred during the performance of this test, the consequences would be conservatively bounded by the consequences of ; the postulated main steam line break outside of primary containment. l These analyses have been included as References 2 and 3 and subsequent l i references have been renumbered, where applicable. ' DB2 The brackets have been removed and the proper plant specific reference < has been provided.- DIFFERENCE BASED ON AN APPROVED TRAVELER (TA) None
,01FFERENCE BASED ON A SUBMITTED. BUT PENDING TRAVELER (TP)
' None lf) y'~
Page 1 of 2
~
JAFNPPl Revision C
Inservice-Leak and Hydrostatic Testing Operation B 3.10.1 BASES APPLICABLE above the LC0 3.4.6, "RCS Specific Activity " limits are SAFETY ANALYSES minimized. In addition, the secondary containment will be (continued) OPERABLE, in accordance with this Special Operations LCO, and will be capable of handling any airborne radioactivity i or steam leaks that could occur during the performance of I hydrostatic or leak testing. The required pressure testing conditions provide adequate assurance that the consequences of a recirculation line break (Ref. 2 and 3) will be l conservatively bounded by the consequences of the postulated main steam line break outside of primary containment i described in Reference 4. Therefore, these requirements l ; will conservatively limit radiation releases to the l environment. In the event of a large primary system leak, the reactor vessel would rapidly depressurize, allowing the low pressure core cooling systems to operate. The capability of the low ] pressure coolant injection and core spray subsystems, as required in MODE 4 by LC0 3.5.2, "ECCS-Shutdown," would be more than adequate to keep the core flooded under this low i decay heat load condition. Small system leaks would be I detected by leakage inspections before significant inventory l loss occurred. j For the purposes of this test, the protection provided by normally required MODE 4 applicable LCOs, in addition to the secondary containment requirements required to be met by this Special Operations LCO, will' ensure acceptable consequences during normal hydrostatic test conditions and during postulated accident conditions. As described in LC0 3.0.7, compliance with Special Operations LCOs is optional, and therefore, no criteria of 10 CFR 50.36(c)(2)(ii) (Ref. 5) apply. Special Operations l LCOs provide flexibility to perform certain owrations by appropriately modifying requirements of other .COs. A discussion of the criteria satisfied for the other LCOs is provided in their respective Bases. LC0 As described in LC0 3.0.7, compliance with this Special Operations LC0 is o)tional. ' Operation at reactor coolant
-temperatures > 212 can be in accordance with Table 1.11
, for MODE 3 operation without meeting this Special Operations LC0 or its ACTIONS. This' option may be required due to P/T (continued)
JAFNPP B 3.10 2 Revision 0 ! (ITS Submittal Rev. C) e --
F: Inservice Leak and Hydrostatic Testing 03eration 3 3.10.1 I BASES (continued) REFERENCES 1.. American Society of Mechanical Engineers, Boiler and Pressure Vessel Code, Section XI.
- 2. JAF CALC MULT 02238 Revision 1, JAF HELB Analysis >
During Hydrostatic Test May 27. 1999.
- 3. JAF CALC RBC 03400, Revision 0. Evaluation of Reactor Building Ducts and Doors for Recirc. Break During Hydro, August 9, 1999.
- 4. UFSAR, Section 14.6.1.5.
- 5. 10 CFR 50.36(c)(2)(ii).
1 C i l i i 1 i i i { i Q(s . JAFNPP B 3.10 5 Revision 0 i (ITS Submittal Rev. C) i
i O. VOLUME 19 l ITS 5.0 CONVERSION PACKAGE: CTS 6.0, CTS RETS AND GENERIC NSHC ,
-1 l
This page provided as a place holder and to assist personnel updating the JAFNPP ITS submittal to Revision C. O Discard this page along with pages removed in accordance with the page repir. cement instructions. 'O i l 4
c ben *b c Ai RADIOLOGICALAFFLUENT TECHNIO(L SPEClFICATIONS) peITS:l'Y'l* DEFINITIONS y A. Done hwaw,e :-$31 The Doce Equivaient 1 131 is the concentmtion of I 131 (microcune/giam) which alone would produce the same thyroid dose as the quantity and isotopic mixture of 1131. l 132,1133,1134 and 1135 actually present. The thyroid does j conversen factors used for this calculaten shall be those heted in Intematumal J Commiseen on Radmiogical Protecnon Publicanon 30 (ICRP 30), "Limds for intake by Workers" or in NRC Regulatory Guide 1.109, Revneon 1. October 1977. .
- 8. Instrument Channel Cahbranon See Appendet A Techncei Specifications.
C. Instrument channel Funcnonal Test See Appendix A Techmcal Specificatons. D. Instrument Chedt See Appendix A Technical Specrfications. E. Loac svateh Funcnon Test See Apporxhx A Techncal Specifications. F. Membertal of the Pubhc Memberts) of the Public includes all persons who are not occupaeonelly A i =aa-*M with the facihties on the NYPA/(NMPC) Niagara Mohawk Power Cswn,si sde. This category does not include employees of the utihties. Its contractors or vendors Also excluded from this category are persons who enter the sde to service equipment or to make dehvenes This category does mctude ) , persons who use portions of the sde for rocn * 'onal, occupaconal, or other [ I l purposes not associated with the plants. G. Offnas Treatment Svetam The Offges Treatment System is the system designed ard metailed to: reduce radioactive gaseous the mam condoneer, effluents and, providmg by of for delay collechng the offgas fcpnmary coolant the purpose of system offgasen fro rdw the total radioactivity pnor to release to the envwonment. J ( /. 4 @ Offada Dona Cakadation Manual fODCM) The OOCM desenhos the methodology and parameters to be used in the calculebon of offsite doses due to rettioactive gaseous and hquid effluents and in the calculeben of gaseous and liquid effluents mondonng instrumentaten
, alarm /tnp set points and in the conduct of the enviis.e% mondonng program.
T Ooerabie L See Appendix A Techncal SM rd/i*lo#I "O 1 76 : Getb r /.D Amendment No. 64, p rs n o n gag Ry ( J & . Revision C
-- G dH . .-
n v : m-mADietectcAt zntenT : ca:cA:. SrzcmeAnews 1.0 DEFINITIONS 1, A. Dese feuivalent I-131 ' The Dese s4=1*=1 =a a ?-131..is the ceasestraties of I-131 (microcu-rie/ gram) which alone would produce the same thyroid dose as the quantity and isotopic mixture of I-131.1-132. I-133.1-134 and I-133 actually present. The thyroid dose conve~rsion factors used for this calculaties shall be those listed in Table III of TID-14444. "Calcu-
- lation of Distance yesters for Power and Test taaster sites" or in j , Ntc Regulatory Guide 1.109. Revision 1. October 1977.
- 3. Instrament channel Calibration
' See Appendix A Tashaical Specifications.
C. Instrument Channel funettonal Test , See Appendiz A Technical Spesifications. D. Instrument cheek l See Appendix A Technical Specifications. l l E. tacic Svetes function Test See Appendia A Technical Specifications.
- 7. Member (s) of the Public Member (s) of the publis" includes all persons who are not ocawpation-ally associated with the facilities on the NTFA/00(FC) Miagars Mohawk power Corporaties site. This categety does not include employees of.
the stilities, its contractors or vendors. Alse excluded from this
- category are perseas who enter the site to servise equipseat or to aske deliveries. This category does Laclude perseas who use portions of the site for recreational, scrapacional, or other purposes not assettated with the plaats.
C. Offtas Treetsent Systes The Off gas Treatnect Systes is the systes designed and installed tot rednes radioactive gaseous affluents by es11ecting primary coolant systes offgases from the sais esadenser: and, providing for delay of the offgas for the purpose of reducias the total radioactivity prior to release to the environment. I. Off site Dese Calculation Manual (CDc0 The CDCN describes the methodology and perseeters to be ased in the caleviaties of offsite doses due es radioactive gaseous and liquid effluests and La the calculation of gaseous and liquid .e*ffluents semitoring instrumentation alars/ trip eat points sad La the conduct of the savironmental monitoring progtse. I. Oserable () See Appendix A Technical Specifications. / l ~ Amesdaent No. 33 1
. Der 0 gc3pg q7.vo7
\
- ~' *
- 2. ;-f d /
Revision C
-- $se.d on 5.$ -_
(Sa.a. CTS CA*h % [6.'14pA0CtssCoNTROLPROGRAM (pCp) A. The pCp shall be a manual containing clerational informatic concerning the solidification of radioattive wastes from ) liquid systems. j
- s. The pCp shall be maintained at the plant consistent with '
the.e Technical specifications and with approved plant procedures. C. Revisions of the pCp: I
- 1. shall be submitted to the Commission in the semiannual Radioactive affluent Release Report for the period in which the revisions were made effective. This submittal shall contains
- a. sufficiently detailed information to support the rationale for the revisions without benefit of additional informations b _a determination that the revision did not reduce the overall conformance of the solidified waste product to existing criteria for solid wastest and
- c. documentation that the revision has been reviewed and found acceptable by the pCRC.
O ~
- 2. shall become effective upon issue following review and acceptance by the poRC.
(. 3. ' opps::r oosa CALCetAT:oM MAncAz, (ceCx) f, f, l
- A. The CDCM shall describe *the methodology and parameters j' to be used in the calculation of offsite doses due to l radioactive gaseous and liquid effluents and in the l calculation of gaseous and effluents monitoring instrumentation alara/trin setpoints/consisten wi t.q r un app 11 Ae I.cas ntaines taese echnica spe icati .
A2
- s. eo shall maintai d at the laat an shall r est opted hodolo e and ca ulation pc edures. ___
i,- Amendment No. 93 238b W IIS b" { {5p w.D _ ke3 d 1[ b ' Revision C l
CTS INSERT 258b 1 o b.. The OOCH shall also contain the radioactive effluent controls and radiological environmental monitoring activities and descriptions of the information.that should be included in the Annual Radiological Environmental Operating, and Radioactive Effluent Release, reports required by Specification 5.6.2 and Specification 5.6.3. O 1 i a-A Revision C
)
$g:.+[e a ${
~
gC_ L k entee i* N +e in ries 4 era af a. le 4 / y a e a ,e obcar p,,4 *o,e S/8o copy h3'.8.d C. Revisieme of the occus @,,urre s w ,m m
.I 1.
Lg,g ; 4,3a ana11 he suhnitted to the Camalsates the amarammrim
, IMI @
l nadie=uve nf1=st revistees wette made Effnet al.a. m.,6,i.4ahall ort for u. Laoestains
.hia th. .
l
,s doeme httie=0
{, f. l. C l.(o) a. s_uffieletly detailed informaties se suppers uma
.,,J l '29e.) 1 sair\revisie (I
(1 ernatae summit t r .; shall r&t of ist of u 1 sed saforma e of a N [ w with e to page red meewi t'ith meev ,
.her ith e ,r.,ri.= e,u =u.= 1 f,[, I, t. , l $) (gg g justafying the twisiesels WA ses er i 7,,fg g,1 b. a determinaties est the revieleash tihn tag heddegk the saaer er relianality efideae salestationa er seapotas ,-g 44)urA, *****L***L****
**f* eterkt e 4 r*
- n w ur4* =co/ sidt As Aw=*d] f5
,f1,C,( g ati the stone y hees gigf
[s.t.i. c q .. a.all m e.e of,.eti. _ i. 5. .w3 s aed
""'*"" "' ** ttes Wr ao w .4 *,,,a 9 .y.
6.18 an unstereArtame to nAareareryn r.ruJio. n;:-= ten set.tn . Nll wAarn TamATumrr ETuTmane
- k. Major modifications to radleestive weste systems (liquid, gaseous and solid):
- 1. shall be reported to the Commaissies is the Semiamaual Radiosetive Efflueet Release Report for the period La .hich the modificaties as sempleted and nede operational. The disesssion of eesh andaficaties shall contains
- a. a suonary of the evalesties that led to the determinaties that the modifiesties 'ess14 he made la esserdamse with 10 CFB St.80s
- b. esifieleet informaties to support the reases for the modificaties witheet meestit of additieaal or supplemental Laformations and
- e. a descripties of the equipment, sempeneste and processee o,et e.
involved and the interfaeos with other plaat f ethe heeerity may eleet to submit the Laformaties ealied for la this Speelficaties as part of the asemal le CFR 54.99 Safety Evaluation Segert. e _ ISte hAj t. [ e4 Ab Revision C
-CTS INSERT 258c 1 1R U.-
Each change shall be identified by markings in the margin of the
.affected pages, clearly indicating the area of the page that was changed, and shall indicate the date (i.e., month and year) the change was implemented. '
C1SINSERT258c2 g6 maintain the levels of radioactive effluent control required pursuant to 10 CFR 20.1302, 40 CFR 190,10 CFR 50.36a, and 10 C9 50, Appendix I, and not adversely impact O v
'I -( PM C 6 4 A.5' b Revision C
p ht< o w M
-1s- Aj 7oG M d4 4, n e. ,re e .e- t e J' The licensee s' hall implement and maintain in effect7all) .? L -" i I
provisions of the approved fire protection program as ' described in the Final Safety Analysis Report for the i facility;and as approved in the SER dat'ed
-November 20, 1972; the SER Supplement No. 1 dated February 1, 1973; the SER Supplement No. 2 dated October 4, 1974: the SER dated August 1, 1979 the SER Supplement dated October 3, 1980s the SER 54,flament g dated February 13, 1981; the NRC Letter dated Abruary 24, 1981: Technical Specification Amendments g 34 (dated January 31, 1978), 80 (dated May 22, 1984), E 134 (dated July 19, 1989), 135 (dated September 5, 1989), 142 (dated October 23, 1989), 164 { {
f (dated August 10 1990), 176 (dated January 16, 1992), y 177 (dated February 10, II,9 2 ) , 186 (dated - February 19 1993), 190-(dated June 29, 1993), 191
- i (dated July 7, 1993), 206 (dated February 28, 1994) and 1 214 (dated June 27, 1994); and NRC Exemptions and I associated safety evaluations dated April 26, 1983, July 1, 1983, January 11, 1985, April 30, 1986, September 15, 1986 and September 10, 1992 subject to h, the following provision:
l.e e f u t .The licensee may make changes to the approved fire t ' is tea l protection program without prior approval of the p ,A , Commission only ff those changes would not adversely affect the ability to achieve and
. b"'j maintain safe shutdown in the event of'a fire.
l (4) Svs sm TAceeriev
. f, g g 4 yg % enre w eenkm. =m1 - amens a ermeram v reducto leakage from the systems outside contairs snt that would or could contain highl.y radioactive fluids during a 7 serious transient or accident to as low as practical levels'g This program shall include the followi.g:
n)d 1. sqre., e. e s) .- strpst uim anemm1 Maine maintenance and periodic I b[ i /isual inspection requirements, and n-wwp > 2 eak test requirements for the systems at a
) frequency not to exceed mew cycle intervals. E (5) redine wanteerine N w "
k se fThelicense shall implement a program which will e i sure the ca bility to ac rately date. ine the " A 2. 3. 0 k " 4 ai orne iodin concentration in areas vic 1 to the-(R 2. f.S mit ation of or ecovery from n accident. *his
'~y t .% progr shall inc de the follo 'ng:
pu )r lP; t 1. Tr ning of per nnel, l2. . Proce ures for men. oring, and t l [3. Provisio for mainte nce of sampi and k analysis quipment. T'%c 7 of W b Revision C .
10 CTS INSERT 3a 1 grj O The systems include the Core Spray, High Pressure Coolant Injection, Residual Heat Removal, Reactor Cbre Isolation Cooling, Reactor Water Cleanup, process sampling, and Standby Gas Treatment. 1 i l f I l O ' { ft Revision C
1 e c.b/ 04 I .5' A\ i {f,f POSTACClOENT SAMPLING PROGRAM a nrocram scan ne me=manaa imniaMantaa =na maintainh4 wahsure the capacihty to obtain and analyze reactor cooiant, racicactive iodines and particulates in plant gaseous effluents, and containment atmosphere samples under accident conditions. The program shallinclude the following: A) Trainmg of personnel,
- 5) Procedures for sampling and analysts.
C) Provisions for mantenance of sampling and analysis I $ PRIMARY CONTAINMENT LEAKAGE RATE TESTING PROGRAM du F*f" _ g _.. na
- dr;,;errerd leakage rate testmg of the Pnmary Containment as required by to CFR 50.54 (o) and 10 CFR 50, Appendix J Ophon B, I i
as modrned by approved exemptons. This program shall be in accordance with the - guideimes contamed in Regu',atory Guide 1.163, " Performance-Saeed Contamment Look Test Program", dated September 1995, as modened by the excepcon that Type C tesang of valves not isolable from the contamment free air space may be accomphshed by pressutuabon it' the reverse direction provided that teetng m this manner provides equtve6ent or mork . Wiservatve results than testmg in the accident direchon if potennal atmospheric leakage paths (e g., valve stem pqclung) are not subjected to test pressure, the porcons of the valve not exposed to test pressure shall be sutycted to leakage rate measurement dunng regularty scheduled Type A testeg. A trat of these valves, the leakage rate meesurement method, and the ac:eptance entena, shall be coatame6 in the Program. b 5 The peak Primary Containment intamal pressure for the design base loss of j coolant accident (P,), is 45 pasg. hM The maximum allowable Pnmary Containment leakage rate (L.), at P., shall be l 1.5% of pnmary contamment air weight per day. l gn;e The wakage ,.ie accepiance enteria are: l
- 1. Pnmary contamment leakage rate acceptance entens is 51.0 L,.
l Dunng urut startup followmg testmg in accordance wrth this program, the leakage rate acceptance entens are 5 0.60 L, for the Type 5 and Type l I C tests and 5 0.7$ L, for the Type A tests;
- 2. Airlock testing acceptance enterta are:
Overall erlock leakage rate is 5 0.05 L, when tested at g P,, l
- a. l D. For each door seal, leakage rate is 5120 scfd when tested at g P. ,
MSIV leakage rate accootance entena is 511.5 scfh for each MSIV 3. when tested at 3 25 peig. g,f
. .The provisions of S 4.0
- do not accdy to test frequencies swJed in the Pnmary C Leakane Rate Tesano P ram. r hg The provisions of ANM A n dare apphcable to the Pnmary Containment Leakage Rate Testmg Program.
S g $. 0. 5 1 A SU Ame .n,No _
, ag 1 erers 97-007 k g ,, p,y -
Revision C
l
$< e. h a S. [
JAFNPP pOSTACCfDENT SA'MPUNG PAOGAAM A m shall be , .:ablished, implemented, and maintained which will ensure the ! ity to obtain cd analyze reactor coolant, radioactive iodines and partculates in i plant gaseous effluents, and containment atmosphere samples under accident I condicons. The program shallinclude the following: t A) Training of personnel, 1 B) Procedures for sampling and analysis,
)
C) Provisions for maintenance of sampling and analysis 6.20 PR! MARY CONTAINMENT LEAKAGE RATF TEST 1MG PAOGRAM A program shall be established to implement the leakaos rate testing of the Primary Containment as required by 10 CFR 50.54 (o) and 10 CFR 50, Appendix J, tion B. as modified by approved exemptions. This program shall be in accordance the uidelines contained in Regufatory Guide 1.163, " Performance-Based Containment i sak T:tst Program *, dated September 1995, as modified by the exception that Type C l testing'of valves not isolable from the containment free air space may be accomplished f by pressunzation in the reverse direction provided that tesang in this manner provx$es ; equivalent or more conservatve results than testng in the acr.ident direction. If , potenbal atmospheric leakage paths (e.g., valve stem packing) are not subjected to test I pressure, the porDons of the vah,4 not exposed to test pressure shall be sub}ected to l leakage rate measurement dunng regularly scheduled Type A testng. A list of these valves, the leakage rate measurement method, and the acceptance criteria, shall be contained in the Program. , A. The peak Primary Containment intamal pressure for the design basis loss of coolant accident (P.),is 45 psig.
- 8. The maximum a'!owable Pnmary Containment leakage rate (L,), at P,. shall be ;
0.5% of pnmary containment air weight per day, D C. The leakage rate acceptance enteria are:
- 1. Primary containment leakage rate acceptance criteria is s 1.0 L,.
During unit startup following testing in accordance with this program, the leakage rate acco tance enteria are s 0.60 L, for the Type B and Type C tests and s 0.7 L, for the Type A tests:
- 2. Airtock testing acceptance enteria are:
- a. Overall airiock leadge rate is s 0.05 L, when tested at 2 P,.
- b. For each door seal, leakage rate is s 120 scfd when tested at 2 P..
3. MSIV leakaos rate acceptance enteria is s 11.5 scfh for each MSIV when tested at 2 25 psig.
, D. The provisions of Specification 4.0.8 do not apoly to the test frequencies specified in the Primary Containment Leakage Rate Testing Program.
E. Thi provisions of Specification 4.0.0 are applicable to the Primary Containment Leakage Rate Tesung Program. J Amendment No. 406,234' ( Q sers 007) 258e g,10 0
- v Revision C l-ll l
1 S t c r' o n I.[ Q , $ $ crs:CL/ L { 3 1 (a) TheOperating Facility following License recoros shall be retained for the uration of the
\
- 1. Records of any drawing chan s reflecting facility d med ications made to systems and equipment described ign l Safe Analysis Report. the Final
- 2. Records f sev and 1: radiated fu assembly urnap histories. inventory, fuel transfe a and
- 3. Records of sility radiation and to asiastion salveys.
4 Reeeres sentrol areas. of rad ties espesare for all i ividuals entering radi ' ion S. Records of gaseous and liquid radioactive
**'A'*** terial released to the
" is &op-a ~ peemie,s eonwait s tes .A)
/ 6.
fdg*J 6eespeaants raasientidestified er operational in ganae %cycles Dea.c for these facility _ l g gg ('7 . Rec as of traising and qu ification for entreet plaa statf. abers of the ; [ 3 Records of in-service inspectio gy l Technica specifications. performed pursuant t these h 4,0 "
- 9. Records of Assurance ality Assurance activi les required by the sal. lity
/
- 10. Records equipment er of to ows performed for abang made to procedures views of tests and esper nas pursuant to la CFR S0.39.
11 Records of meetia of the 70Ltc and the SR 1
- 12. eseres for Raviro y ovisions of paragr stal Qualificaties a 6.13. which re oevered under the
- 13. Ree who res of the service ife of all hydrae 11e and chanical snubbers, '
I inel failure seeld adve sely affect any safety-r sted system, ag t3e date at whi instal ties and asistemaa the service life comme a and associated resores as of the effe ive date of this - a t. t 1.11 \ RADIATIbN ran m oW A M M \ precedure for perseen radiacios pr section shall repare ad adt to ed to for 11 plant ope tiens. Thes procedures skal be atee to as taia radiat espeseres asiste practi
'see as fa below the li ta specifie esived dariar a 10 CFR 20 as ration a d le. The y eedures skal include pla tag, preparatio and '
ta tiaing. er operatie and asiatena e activitie They shall a o sure 411eca on, radiati and contaa ation control (includees techniques, ad finaJ den iefing. Amenement No. Jr, g , 92 creer sated Octoser 24, 1980 M p ,. Q , f, 235 Page (( of l Revision C I f!!
CTS INSERT 255 1 [ c1 2 to ensure that components are maintained within O faSe lL "h W Revision C
' @s7. b%
b~ O' d A W
- m. 000 O 0012755 8 e 200 714 4 1 R 1 6,4 1 -
1 R U C f* C C 5 n O
- l. i o _
s - p i v
. . . . . .. . e h R
... ~.
S ... . . . . . p. . T ... . . . . . o . I M mp o I ... . . . . . .I o L ... . . .....L
)))
... .. . . . . rPF T
N
. ......e.
......rcrc 00' 50 E .
.se r......t 71 I
S
)
..rws . . . . . ei
....Rc 3 1
~
N I ..eoss . . . e 50 1 A .tPapp. 0
- R T
/r 0 .ae1yurew.
. pmi n.l
.dR o
473 533 ((( 1 N 0n.H5DPTro O 0o 2 rrrp ud o ngn D 6 I T 1i ( t r etoeop fC o wnw oi o A C I astattt e m f nddd D prta aas O
- I B
A NC N O ueswpe tpedil l natowl p rr ol oooo recatd oio T Y C rOTer nevSt rt crc C a eT eevl Sau T t rhF FGOar th rnr T N Set t VerSShwh N E E wr naf er he iwonoyt pnl PdF
/ o/ _
I l o N S aP bd i t t O o e a 0 t0 O N m sresbce rdm0 u0 P A 1dsuesrafl pd r 0 h M R o0ooTFeueal muo1 ; O N5RL ITRSAISN C _
, l -
e s _ s e ' V . e _ i r u . N _ s _ a _ e r s
\
M P o t c M a [ O e C R f - 5- { T i up O 2 3 [ f m** -
e Oh 3
> b 'QA %
- i. 7,!p l! i Ull p m% a t-jii il :
i 1 i tih!'! Hi *1 i i ]H 19{1!Iuli l! f !!!p8'y }ji R > 11 >st e y lJl}r,ldl11 h01 1 i
; >n! fj d9Lj9lws th; Ni it i g
1 alilli!!!ilu}/- e
/w T6 n?
l . l O *
> y' ,a i .;. l
'l ,lil.: '! i
!!I]1;p]$c ll1 lj};
e i d! 9AlLlill$ ll{l((Ir!ll
!! 11lilli' f!!li'!!
1 11 fDIl! ljjili N, ! l l hlkilll!}fp..i!!,!b
!lIl!!II.
. .nj o illkklk ,! Il !
,1, Y! j g - _
O g /sy p I
e D
# k o @ g { il l$ v d !
*s ,y t ;,i
?. .. i l
4 us1 C+?n' n, a q >
$ p' o W I N Ij i ". -E o
$yI
- i::
h$l g
%~j i bf i.:
rt th E.J r d u .: .; a t e
< . I lg gI
- 1 Y,, j
'I Nj su i 5
.h: :.b. c A .$ ',;
' I - - i l1 s .
1 bib bl q. fl [ j T s 7 s s 4 g ,
% hM M G n i
&. b 0 )
4 = i GIERS i i
~
~ w . w <
O
M (, y M % M '5 ; p a u IU } )2 ff z
)
- #" L I. je 9
5 3 5 7a w-
! s 1
W 3eu u J t n )d e 0 e s s-n ee mh t e a r 1 A h t n G syv yao d se a ey d w '- N i i m t sa o $ n s a i "C edd 4 E s d id o o d 8 e ena t n et l c s r o l v e. vn pes 4 d 2 73g 12 8 t 4C 3 74' ( r e t 2
~
/ 0 s;
r a rrr c ca i p nio eee ppp pop e r r e r t yt g o oit le e d
- p y rn ai m
n s e i t eo hy s w y - eee e e ccc c e r h"f y M C de e r e c -- nnn c- - - c r u / ooo on o n p l p . n n-. n c-nl m e . t
- . o e-o e n/ e s r" w o wc o led s
e e . t s e - i t m a ttt sse s s t t t s e _ c i s i v S S y mt et a ' e er aas a a
- eeo e e a
e j _ r L i v J, e - t s i F lll l l o l r f t n sa yl ttt m AAA A A t t t e y r e se A R r e . t a e t ct ae
~
s m t a nh o t t of nsa l y
~
u
. e in r i
u g em r in T r t i ed e - y cd a r sa h oh e h t
, a, t-e r tee t e ne rnt ytYnor w e nhr et a r
o s a n ew . en ui C e o - t t mt ian s d o G vce cs qe ed r f l s a y yl ym-r dg h qt c e kho oo" m;eh
. i ati e i t r f
e v lde t n r3_nS i j t iei t o ao - e ra r e s n e tr y r-y - es _ b s Ce r u a ndn eo t s l. t m et e tt g fctd _ler i t n ou e-- MO eL v . p _ y vm c a e S ue e _. do i Q c r e w et e n eyng l va n t h Nr rc o ie dti ~A T Ae ul i i M ic nir w oe si t a 8 M f o e D W4 O A1 e cel w. t S _jo/f,A esl ~ . . h d Sifno ~ (2 3 s T i S h (.
]a.
G
%4, 5 r U h. . ~ Jr 3 e I
a
?o e ec y v I ij t
n his f e N' - at t c nh ehen e e .s t t n a b o a l e s e md n hitr
- y icg.aeh d
n au t b i it v ]d e r e c f e r is d d.s e ev it a g hed rcs M h e f ar tof nt n enoue' it c a n a r o^ t epee edn sR rs e e o oa itMl t a ic r e ogn ni o e a in gcuobd dhl wtnrwf I e sc en v l d n-e- n 0 ri a u (r a epca r dt ec t iuk hnsd n unoq a e v o0o elae uit n r ef e ti et n s pti ica id uoye o o e" i1hc t a vw orr enr ie pret wdohees l i l c v^ rdutdeo ac sh e eoa t eleressbn t a r s n '- o- m eeateh pml etde p rt eSro i weh c hth t it c yimn t i o n e i r o aero w etc r t rt nlt r n o c 2 p t t e s a v .t t o ptha eT y leo o t ir ei ug u oau mit s . o c e ote ewra heb ep et l f r r rnre e eet'h efer e e oCro t l y th t r t w e swnee t ei e otd gtn aie ret ah nfe ype ei r n enre l r a e o se t t n I s th n wi r ,le chh . siu uu o gs io msu u st Os . s e n c f eeopen e rr act t eihe dea e r eds tf n n c s # rl rs e ue RSwo wi pw Ut v
~ba e Eet sc i
f ubyncye m ea t e e w eimts sst s A t n i r e c im l ^ os u whTude a t m e6 e sltMrel es t 7 m t n o mere t pr nf oe ese es e nt er a m r
.nt i
r o o o o c
- p t.d o e i t tt wre eu wa n f eots.nll nmr e i e pf o n .
dwenmh f m r ie ore este n s h r, Top l eolei s ch o e e ee t e eia etct r o p e n i t n e h eeen tMsn.t e et e G h ph reee t Prrn
- d uh Te hso nchunir it st a m
o, aw " ht e o n G keheye t nd pa e - rcNunp . t stneh r ehue ee sf eeu i n t d e erw wint t ne eo =l tsefhoto .on d e s . ed oe t ee u i n l ee duos o ot wrra esi o c 9hp 2 a bc aaf t n ne o er no by !^_ys i . n e h ota t - o ntu ir e t l e ngce P n oyn Vvap 8 n s t s E s anut r r cs e r 8 s eo ,a e eta eibe c a (e Ae A A in e ori toim ~ ev rehi w ae tmt t f t, nrmdm e r t c adr t a edovnii t l wwe r nea ct c cee ws - c .r oopt aIee a. li d r a eep e t e 8 e pt eapt md m
*t n
o 3 C ppospI RoSI BrSs e 'E eh b t -ethnieeinaVreli d n e ( c m 7 0 3 O P O R A 1 l l 2 ;I C. M $ 1 t T T 5l7~ _ c w
h Y . O a[ > i 3 ' j 'i gg / , pq l 3, .t .i g n In v j' ei V j 3 g se K 4 3 d .1$ %* I Ig l
,w 1] I=. *
]" '
"I e. j f <-
lj- .; j I a N
' o e
1 r , o x a"g%
}} ::
a e
- [1 gi3e a
, .l .
-; g4 s e w g M .n a
- \
k m i a n 1
" li ll l ii !
e l{li i 1 I
, L U '
O 1M I
\
i
fT" - 1 - E O' a i.t a . W . o
!~ #
k
% .h HU n
=
]
bl
.,3 t 2
i il a i ;l 84
'}i M
; y '
"111 <
t ,i. [". I 1 1 ;2 4 e t it i
.. i B is g 1
e t ll t {( 13 "a 3f{~l "h
~
111 a 1, l
- .39 d r .
Ip ti b y , s cc v i s i d D W
' h e< m l
d ;f 3 4 , 12 3'l Jj j l'4 1 wi
,2 8 a Y2 r
- u. , - e . .
b4 5. t 3 A k A
,a ..
s .: x- $ % 0,~ 05 , i li d
,+2 ;,
i s di l l
)5
- h 41 d .%,n. dC.l ; f .} u.i_{a 9 4 4- sh 1
!YI o i o'*
T,4
~
J # Ig vo l
~3 I E i.. -c *; a . i e N 3 s ,., >, <,$s + ' { vi 4
[*' f LR l4 f d ! j!n c 4. , 3. :. U$ t
} =}i :a e
- t : ? .: 2: 'tf i :
aP . " 1 s t 11 = 31 s"+ l~- w4T I i 43 QY' a +' T
- u4 F. ?4 AT[1; 46 4??
irs; J i' ;evil lit 3
' t 13 0 5
*<=1 0, c ! ',
,i s Di sst E k o 3 2
l
% @ 5 ghjg, }%
O ff n 3f,
!? Il Q !! i I s
;1:
u i
* =lllj i 1
l I p p$$
! h55 ?Y5k hi I k 1 llI lIi ! SI 5 if;j'3!,!!*h<bb$
I$'$[ij! T llfl!!! 9 j uuj ,
- a A
p/ (E n t!! O 1, 51 yll ill lhlt i
}
18 ll j
~
f g K
};l$llll*j!!!!I I 1 ,
hul!IL= 3 45 . y l O . I:
hr * ~ O sN@ N 4,l b l!$ st 3 4 u
. m; c
c h,h hi a. %.(rj '[1 W a
?{g x l: j h; lt lg 3 ia , l>=ii 11 i p1$el, lii g g 1 :i m i i:
~, .
i 8 l*(' *ll!e, l ji 4 e I .l9lY. 1 e!j }ll JJ 3 2 f [ l3:s s 4(7 ' 5 O ,hh a n ! ,:1((!il i i 4 a ' j? a o
.3 a n ]
A i. 1
,- t)s
]8 l
l p4 3 4/ 31 bb ! , l l j 1 ., Qi 1,; i4 3 g 8 i 5 8' $ ~* \ #b haw {# "j
=
h si l lo h.: c i( v.
$ 1 'l
{'{1 t 5'1 E a bi
,I Iga I Th fl l
, Q@{3[ti s s}} {s'I }allH1l]a i
! li} 6 j
!!:i 2e g; ijI ial 4o<
di O
@em _
.s2
CTS Insert 238 1 2 i After each complete or partial replacement of the HEPA filter or charcoal adsorber filter: after any structural maintenance on the HEPA filter or charcoal adsorber housing that could affect the filter system efficiency; and following significant sainting, fire, or chemical release in any ventilation zone communicating wit 1 the system I CTS' Insert 238 2 [Af2.
- After 720 hours of operation: after any structural maintenance on the HEPA filter or charcoal adsorber housing that could affect the filter system efficiency; and following significant sainting, fire, or chemical release in any ventilation zone communicating wit 1 the system l
l O en u .m A Revision C
Q** v D
.s e
- !'-~8.e 3
*!j il p' "ai; 1
t. b 1 h li -
- w' !t. i, j
. =
j - es! !! :q!20 i <? T UJ s 1 i 41 il
=.
- 1
~
~p>Do 4 3bq - -
a >- is = sl= 21.a n<< n4 m I s- , . 4. .. ..f_.b., .
- . .: , p 2 -
m:- t 4
~ o
,s ::1
=
b.. i 4 -
~ ~- s - 1 2 . - l2isi. 3 3 s } u. ~ .2 4 li .il i=M- a.i ,ili 3
3 - e - i o asill! d il.l , a* i
=
gfa:f ;;f e 5 m
*,, .1ii b ..
- = .__,:. . .~s 2, '
Cn 2 : e
- s. u
.:=_,is .
- 1_.
- 1. 2 m in
+
J >- 1,23s
- n- 1 = : s m= a O- ::'
g _
- g
- g,J::! {!
ite z,e :;: m- . - . d2 . 131:: i .3;1 r:
.c
;- , s t I- 11 .
2 :s :;-[ : i 3 1 1,". i. - 4v ,! J*s E 1 ,,]
* .1 =*gj* .
[. == g_j
!'* I 14 3 2' Ij_t. I -.
l
,- Y t gj 1: 3 _l .*:I:,3_m a '
4.,
- s
.. . 1- :-1:*is. s:: -
"di 1et E
a E
%. li 2 .3:i
.3 2:gs.
2 3 ~ ., r
~
= ,, i J' fu, IV 8 1-
.2, ,
-3
- les,: :]_f.i
- I. . " s* i s
2
- -= :
!e te g 1 : :: 6- e: a s:33 a:-
... : :.t t _ = =.. I!.3 -: 3;. : - -
g
, -{. ,j 1 -
! 14 $3! 141!_. ss: : 4 .e a j 6
- l l
-'k r ,l dhe q l id CP $ O' ~
i ii : 1-e. W 4 e q
' uI d 0 $."l7' 6 dw g i
r t
- o- '
0 & e s cg r ,i a511,j;l
.=-
Ii f 4 W'4i l N
, I I
y
- a. #
ig40!hz gj?; 8 i 1 ia I g lN Il 1 q ul i
'?nfillj I
- p. <
l}
. i i
I l fe,N .e. ..c m a x i
. 1,'
pIlq u, 7 ( , I ~S 4 'd P ff l f' O l is a l ! I a l t 11 h. h
.o 5 2[ T h ilyi lj I lf E I
e il l d5 l ! zu i;- I h nj ff, p.
=
Y Jf fg ! r a H,,g g a c5 n v ; I n,a , .$ s i n t- all n ; Y l a- d ; a O $ O
73 o'A5 7 4 / 1 (
% \
i..i. .Mt, 'l 9 4 a1
. l g i. $3 I L e i e s i
\- 1,.
'h'N,v I
i \, } l g, b r 11 hitu V *i ' 1 1 a a "
* .{kkk{
. s e e T
G.a il a - y j n \ o ' \ x ~ 3 1
'{I 'l *> '\ b;
\ b \
\
.\ l 1l 1 18 3 sei a*_"U- "
{*
,k cg g
- 1
- o c
o 's *T H i
I I Se.e taam S,(D '(] M v' [f.i.15] Q CONFIGURATIQN RISK MANAGEMENT PAOGRAM (CR_mp) The Conficuration Rftk Managtment Proosam 6CRM$provides a procec:aralized nsk-informed assessment to manage the risk associated with equipment inoperability. The program applies to technical specification structures, systen.s, or components for which a risk-informed allowed outage time has been granted. The program is to include the following:
- a. Provisions for the control and implementation of a Level 1 at power internal events PRA-informed methodology. The assessment is to be capable of evaluating the applicable plant configuration.
f
- b. Provisions for performing an assessment prior to entering the plant !
configuration q(Sf3TUIt@for describedactrvities, preplanned by the Limiting Conditiopfer Operation (LCOl@ ] f
- c. !
Provisions for performing an assessment after ert6 ting the plant ' configu ation described by the LCO Action Statement for unplanned entry into the LCOS_cten sammerw. j M'
- d. [(Provisions for assessing the need for additional actions after the discovery of '
additional equipment out-of service conditions while in the plant configuration cesctsbed by W ! [' e. Provisions for considering other applicable risk significant contributors such as Level 2 issues and external events, qualitatively or quantitatively. (% Covt dlt.;* n (S $Il l l i Amendment No. 253 258f , potg e 15 o k M, i b ! Revision C 1
s x 7 DISCUSSION 0F CHANGES-ITS:-5.5 (%If PROGRAMS AND MANUALS ' { ADMINISTRATIVE CHANGES i
,.A7-('ontinued).
c is in addition toother specified SRs. These requirements are ;
. adequately addressed in 10:CFR 50.54,10 CFR 50.55a, and the ASME Code, {
and need.not be repeated in the ITS. Since this change does not modify any technical requirements,~it is administrative and has no adverse l impact'on safety. A8 The CTS 4.0.E is revised-to adopt the programmatic description of ITS
- S)ecification 5.5.7, " Inservice Testing Program." This program captures u t1e existing requirements for inservice testing of certain ASME Code Class-1, 2, and 3 pumps and valves as required for plants licensed prior
-to January 1,l1971, which are contained throughout the CTS in various SRs. 'These individual Surveillances are appropriately addressed to reflect this change. Since this change does not modify any technical j requirements, it is administrative and has no adverse impact on safety.
~A9 CTS 4.0.E.2 which specifies, inservice testing activities required by the Code and applicable Addenda'shall be applicable as defined in (7 : Technical Specification 1.0.T has been deleted. CTS 1.0.T which was
() used~for both inservice testing (IST) and TS Surveillance intervals / notations has been deleted (see Discussion of Changes for ITS
- Chapter 1'.0) since'ITS-Surve111ances provide specific Frequencies (e.g.,
7 days, 24 months). ITS 5.5 7.a maintains only those Surveillance Frequencies. consistent with the terminology'and Frequency used in the LASME Boiler and Pressure Vessel Code and applicable to the IST Program. This change is a presentation preference consistent with NUREG 1433. Revision 1, does not modify any technical requirements, and is therefore
' administrative only.
A10. . CTS RETS 2.5, Maximum Activity in Outside Tanks,.and CTS RETS 3.7, Offgas Treatment System Explosive Gas Mixture Instrumentation,
-requirements have.been placed in ITS 5.5.9. Explosive Gas and Storage Tank Radioactivity Monitoring Program,-consistent with NUREG 1433, Revision 1. : As such,-a general 3rogram statement has been' added to
' ensure appropriate-controls:of t1ese requirements are maintained. The changeLis considered a presentation preference only and therefore is an administrative chenge.
All. . CTS. 6.21lcontains programmatic requirements for the Configuration Risk 3 Management Program (CRMP). The terminology has been revised to reflect
- the NUREG-1433, Revision 1, terminology. Since these changes do not
- modify anyltechnical requirements, they are administrative and have no
- adverse ; impact.'on- safety.'
DJAFNPP. Page 2 of'11 Revision C , I v ,
<t i 1
Programs and Manu 1 l 5.5 Programs and Manuals Safety Function Dataruination Proeram (EFDP) (continued) {hMs} 5.5.12 ,
@ A required systes redundant to systee(s) in turn supported by the inoperable supported system is also inoperable; or PA~*2
% A required systes redunda.t to support systee(s) for the supported systems ( and ) above is also inoperable.
The 5FDp identifies where loss 'of safety function exists. If a loss of safety function is detemined to exist by this pregram, the appropriate Conditions and Required Actions of the LCO in which the loss of safety function exists are required to be entered. F-msw+ [. 5 . l 3 CL.T3 6 0 . 5.0 17 Rev 1, 04/07/95 BWR/4 STS r -
' Revision C L___.._
L
-ITS Insert 5.5.13 L3 G CONFIGURATION RISK MANAGEMENT PROGRAM (CRMP)
The CRMP provides a proceduralized risk informed assessment to manage the risk associated with equipment inoperability. The program ap)1ies to technical specification structures. systems. or components for w1ich a risk informed allowed outage time has been granted. The program is to include the following:
- a. Provisions for the control and implementation of a Level 1 at-power internal events PRA informed methodology. The assessment is to be capable of evaluating the applicable plant configuration.
r
- b. Provisions for perforn.ing an assessment prior to entering the plant configura't ion described by the Limiting Condition for Operation (LCO) Condition (s) for' preplanned activities,
- c. Provisions for performing an assessment after entering the plant configJration described by the LC0 Action Statement for unplanned entry into the LC0 Condition (s).
- d. Provisions for assessing the need for additional actions after the discovery of additional equipment out of service conditions while in the plant configuration described by the LC0 Condition (s).
( e. Provisions for considering other applicable risk significant A contributors such as Level 2 issues and external events. qualitatively or quantitatively, i l i l f~ ( )/
Insert Page 5.0 17 (ITS Submittal Rev. C) l
)
l l
- j. ' JUSTIFICATION'FOR DIFFERENCES FROM NUREG 1433 REVISION 1 l
-ITS: 5.5-'- PROGRAMS AND MANUALS RETENTION OF EXISTING REQUIREMENT (CLB)- 1 CLB1 ITS 5.5.6- has bee'n added to reflect-JAFNPP Amendment No. 234 (October 4, 1996), which permitted implementation of- 10 CFR part 50, Appendix J,
~
Option B, .as modified by approved-exemptions, via the Primary Containment Leakage Rate Testing Program. These changes are consistent with pro msed TSTF 52. -ITS 5.5.6,. Primary Containment Leakage. Rate
~
. Testing )rogram, replaces ISTS 5.5.6, Pre stressed Concrete containment
. Tendon Surveillance Program, which was deleted (DB2).
CLB2 ITS 5.5.7-is modified'to state that the IST Program provides controls for "certain ASME Code Class 1, 2, and 3 pumps and valves" as required for plants whose construction permit was issued prior to January 1.1971 in place of "ASME Code Class 1, 2 and 3 components including applicable supports." 10CFR50.55a(f)providestheregulatoryrequirementsforan Inservice Testing (IST) Program, and specifies that ASME Code Class 1, 2 and 3 l Program. pumps10 CFR and valves are those components covered by an IST 50.55a(g) -l Inservice Inspection (ISI) provides Program,regulatory requirements and specifies for an that ASME Code Class
- 1. 2, and 3 components (including supports) are covered by the ISI Program, and that pumps and valves are covered by the IST Program in 10 CFR 50.55a(f). The ISTS does not include ISI Program requirements. as these program requirements have been relocated to plant specific documents.: Therefore, the " applicable support" requirements are deleted
_Os and the components the IST Program applies to (i.e., pumps and valves) are added for clarity, consistent with current licensing basis.
.CLB3 -The Frequencies adooted in ITS-5.5.8, for performance of tests in the l Ventilation Filter Testing Program (VFTP), are consistent with those "
specified in Regulatory Guide l' 52 Revision 2, ixcept for the 24 month Frequencies, which support the change to a 24 month operating cycle. CLB4L ITS 5.5.9 contains statements that specify the methodology to be used for determinin holdup tanks. g quantities of radioactivity present in liquid radwasteConsistent with is contained in the 0DCH, and need not be repeated in the ITS.
' CLB5 ITS 5.5.9 is revised to reflect the current JAFNPP requirement in CTS
'RETS 2.5.a of less than nr equal to 10 curies, excluding Tritium and dissolved or entrained noole gases, for quantity of liquid radioactive I material.in outside storage tanks, 1CLB6: ITS 5.5.13 has been added to reflect License Amendment 253, dated July
' 30,1999 (TAC No. M94611) whi::h added CTS 6.21, Configuration Management
' Program-(CRMP). 1 PLANT SPECIFIC WORDING PREFERENCE OR MINOR EDITORIAL IMPROVEMENT (PA)
PA1 Editorial changes have been made for enhanced clarity or to correct a grammatical / typographical error. O LJAFNPP 'Page 1 of 4 Revision C J l w
~
q l l Programs and Manuals 5.5
,Q U 5.5 Programs and Manuals i
5.5.12 Safety Function Determination Proaram (SFDP) (continued)
- 1. A required system redundant to system (s) supported by the inoperable support system is also inoperable; or
- 2. A required system redundant to system (s) in turn !
supported by the inoperable supported system is also l inoperable; or
- 3. A required system redundant to support system (s) f'r the supported systems (1) and (2) above is also inoperable.
The SFDP identifies where a loss of safety function exists. If a loss of safety function is determined to exist by this )rogram, the appropriate Conditions and Required Actions of the _C0 in which the loss of safety function exists are required to be entered. > 5.5.13 CONFIGURATION RISK MANAGEMENT PROGRAM (CRMP) l The CRMP provides a proceduralized risk informed assessment to manage the risk associated with equipment inoperability. The program applies to technical specification structures, systems, or components for which a risk informed allowed outage time has been {q f granted. The program is to include the following:
- a. Provisions for the control and implementation of a Level 1 at power internal events PRA informed methodology. The assessment is to be capable of evaluating the applicable plant configuration.
- b. Provisions for performing an assessment prior to entering the plant configuration described by the Limiting Condition for Operation (LC0) Condition (s) for preplanned activities. j
- c. Provisions for performing an assessment after entering the plant configuration described by the LC0 Action Statement for unplanned entry into the LOO Condition (s),
a
- d. Provisions for assessing the need for additional actions after the discovery of additional equipment out of service conditions while in the plant configuration described by the LC0 Condition (s).
- e. Provisions for considering other applicable risk-significant i contributors such as Level 2 issues and external events, !
qualitatively or quantitatively. j l l O i JAFNPP 5.0 18 Amendment (ITS Submittal Rev. C) l N}}