ML20236P776

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Proposed Tech Specs 3/4 3-2,3/4 3-11 & B 3/4 3-1b,modifying Source Range Neutron Flux Requirements to Allow Use of Alternate Detectors
ML20236P776
Person / Time
Site: Beaver Valley
Issue date: 07/09/1998
From:
DUQUESNE LIGHT CO.
To:
Shared Package
ML20236P762 List:
References
NUDOCS 9807170143
Download: ML20236P776 (32)
v • d • e


Text

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. ATTACHMENT l-1 l Beaver Valley Power Station, Unit No.1 l ,

Marked-up Technical Specification Page Changes Remove the original marked-up and Insert 2 pages provided in the December 19,1997, original submittal and replace with the attached pages as shown below:

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

INSTRUMENTATION (Continued)

The instrumentation functions that receive input from neutron detectors are modified by a note stating that neutron detectors are excluded from the CHANNEL CALIBRATION. The CHANNEL CALIBRATION for the power range neutron detectors consists of a normalization of the detectors based on a power calorimetric and flux map performed above 15% RATED THERMAL POWER. The power range neutron detector CHANNEL CALIBRATION is performed every 18 months but is not required for entry into MODE 2 or 1 on unit startup because the unit must be in at least MODE 1 to perform the test. The neutron detector CHANNEL CALIBRATION for the source range and intermediate range detectors consists of obtaining detector characteristics and performing an engineering evaluation of those characteristics. The intermediate range neutron detector CHANNEL CALIBRATION is performed every 18 months but is not required for entry into MODE 2 on unit startup because the unit must be in at least MODE 2 to perform the test. The source range neutron detector CHANNEL CALIBRATION is performed every 18 months but 'is not - required for entry into MODE 2 or 3 on unit shutdown because the unit must be in at least MODE 3 to perform the test. The P-6 permissive neutron detector CHANNEL CALIBRATION is performed in conjunction with the intermediate range neutron detectors. The overtemperature AT, P-8, P-9 and P-10 permissive neutron detector CHANNEL CALIBRATIONS are performed in conjunction with the power range neutron detectors.

k 2 BEAVER VALLEY - UNIT 1 B 3/4 3-ic Amendment No.3: l (Peeped denU3 )

INSE'RT 2 suitable detectors (F :: :nd F 20 used in place of primary source range neutron flux monitors F 21 trd F '? are recognized as alternate detectors. Alternate detectors may be used in place of primary source range neutron fl,ux monitors as long as the required neutron flux indication, high flux at shutdown alarm, and source range high neutron flux trip functions are provided.

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

This will preclude any power escalation. With only one source range channel OPERABLE, core protection is severely reduced and any actions that add positive reactivity to the core must be suspended immediately.

Item (b) applies to one inoperable source range neutron flux trip channel when in MODE 3, 4, or 5, with the RTBs closed and the CRD system capable of rod withdrawal. With the unit in this condition, the NIS source range performs the monitoring and protection functions. With one of the source range channels inoperable, 48 hours5.555556e-4 days <br />0.0133 hours <br />7.936508e-5 weeks <br />1.8264e-5 months <br /> is allowed to restore it to OPERABLE status. If the channel cannot be returned to an

' OPERABLE status, 1 additional hour is allowed to open the RTBs. Once the RTBs are open,' rod withdrawal is not possible and the unit enters ACTION 5. The allowance of 48 hours5.555556e-4 days <br />0.0133 hours <br />7.936508e-5 weeks <br />1.8264e-5 months <br /> to restore the channel to OPERABLE status, and the additional hour to open the RTBs, are justified in WCAP-10271-P-A, Supplement 2, Rev. 1, June 1990.

Item (c) applies to , two inoperable source range neutron flux trip channels when in MODE 2, below the P-6 setpoint, and performing a reactor startup, or in MODE 3, 4, or 5 with the RTBs closed and the CRD system capable of rod withdrawal. With the unit in this condition, below P-6, the NIS source range performs the monitoring and protection functions. With both source range channels inoperable, the RTBs must be opened immediately. With the RTBs open, rod withdrawal is not possible and the unit enters ACTION 5.

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

ATTACHMENT 1-2 Beaver Valley Power Station, Unit No. 2 l Marked-up Technical Specification Page Changes l Remove the original marked-up and Insert 2 pages provided in the December 19,1997, ongmal submittal and replace with the attached pages as shown below:

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. 3/4.3 INSTRUMENTATION BASES 3/4.3.1 and 3/4.3.2 REACTOR TRIP SYSTEM AND ENGINEERED SAFETY FEATURES ACTUATION SYSTEM INSTRUMENTATION (Continued) shutdown because the unit must be in at least MODE 3 to perform the test. The P-6 permissive neutron detector CHANNEL CALIBRATION is performed in conjunction with the intermediate range neutron detectors. The overtemperature AT,. P-8, P-9 and P-10 permissive neutron detector CHANNEL CALIBRATIONS are performed in conjunction urith +ha power range neutron detectors.

frAnEnrA7 5,..a.2 MONITORING INSTRUMENTATION 3/4.3.3.1 RADIATION MONITORING INSTRUMENTATIQg The OPERABILITY of the radiation monitoring channels ensures that:

1) the radiation levels are continually measured in the areas served by the individual channels; 2) the alarm or automatic action is initiated when the radiation level trip setpoint is exceeded; and
3) sufficient information is available on selected plant parameters to monitor and assess these variables following an accident. This capability is consistent with the recommendations of NUREG-0737,

" Clarification of TMI Action Plan Requiracer.'cs," October, 1980.

3/4.3.3.2 MOVABLE INCORE DETECTORS The OPERABILITY of the movable incore detectors with the specified minimum complement of equipment ensures that the measurements obtained from use of this system accurately represent the spatial neutron flux distribution of the reactor core. The OPERABILITY of this system is demonstrated by irradiating each detector used and determining the acceptability of its voltage curve.

For the purpose of measuring Fg(Z) or Fh,afull incore flux map is used. Quarter-core flux maps, as defined in WCAP-8648, June 1976, may be used in re-calibration of the excore neutron flux detection system, and full incore flux maps or symmetric incore thimbles may be used for monitoring the Quadrant Power Tilt Ratio when one Power Range Channel is inoperable.

3/4.3.3.3 SEISMIC INSTRUMENTATION The OPERABILITY of the seismic instrumentation ensures that sufficient capability is available to promptly determine the i magnitude of a seismic event and evaluate the response of those features important to safety. This capability is required to permit comparison of the measured response to that used in the design basis for the facility and is consistent with the recommendations of l Regulatory Guide 1.12, " Instrumentation for Earthquakes."

BEAVER VALLEY - UNIT 2 B 3/4 3-5 Amendment No.9e-hWlPf*JM Mi

i INSEkT 2 Suitable detectors (!' - 5 2 ?. c r.d !' 529) used in place of primary source range neutron flux monitors F-2i rd F-?1 are recognized as alternate detectors. Alternate detectors may be used in place of primary source range neutron flux monitors as long as the required neutron flux indication, high flux at shutdown alarm, and source range high neutron flux trip functions are provided.

Note (8) limits the use of alternate detectors (!' 52?. cr.d :: Z} to a monitoring function until a plant design change can provide the capability for directly connecting these detectors into the source range circuits so they can provide the required slarm and trip functions.

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

This will preclude any power escalation. With only one source range i channel OPERABLE, core protection is severely reduced and any actions that add positive reactivity to the core must be suspended immediately.

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

Item (c) applies to two inoperable source range neutron flux trip channels when in MODE 2, below the P-6 setpoint, and performing a reactor startup, or in MODE 3, 4, or 5 with the RTBs closed and the CRD I system capable of rod withdrawal. With the unit in this condition, below P-6, the NIS source range performs the monitoring and protection l functions. With both source range channels inoperable, the RTBs must j be opened immediately. With the RTBs open, rod withdrawal is not  !

possible and the unit enters ACTION 5.

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

ATTACHMENT 2 Beaver Valley Power Station, Unit Nos.1 and 2 l .

Akaniste Source Range Detector Change Description BV-1 Page Change

1. 3/43-2 Removed the source range and alternate source range mark numbers previously proposed.
2. 3/4 3-11 Removed the source range and alternate source range mark numbers previously proposed and moved the application of Note (15) to the words " Source Range."
3. B 3/4 3-lb Replaced this page with page B 3/4 3-Ic since Amendments 214 and 215 caused shifting information to this page.
4. INSERT 2 Removed the source range and alternate source range mark page 2 of 5 numbers previously proposed.

BV-2 Pane Channe

1. 3/43-2 Removed the source range and alternate source range mark

- numbers previously proposed and moved the application of Note (8) to the words " Source Range." Also added the words

" Alternate detectors" to the beginning of Note (8) to clarify the applicability of this note.

2. 3/4 3-10 Removed the source range and alternate source range mark numbers previously proposed and moved the application of Note (15) to the words " Source Range."
3. B 3/4 3-3 Replaced this page with page B 3/4 3-5 since Amendments 91 and 92 caused shifting information to this page. i l
4. INSERT 2 Removed the source range and altemate source range mark page 2 of 5 numbers previously proposed.

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j ATTACHMENT 3 i

Beaver VaBey Power Station, Unit Nos,1 crd 2 Alternate Source Range Detector Requirements & Basis I

INTRODUCTION i At the Beaver Valley Power Station, alternate Source Range (SR) channels are installed in the spare detector wells, 90 from where the normal SR channels are located. It is desirable to have these alternate channels function as on-line backups to the normal SR channels; therefore, the following discussion on the functional requirements for such an application are provided. Two l

conditions must be addressed First, the requirements on the SR channels when the reactor trip breakers are open (MODES 3, 4, & 5) or in MODE 6. Second, the requirements on the SR channels when the reactor trip breakers are cloud in MODES 3,4, & 5. (

REQUIREMENTS Open Reactor Trip Breakers During operation with the reactor trip breakers open or MODE 6, the primary function of the SR channels is to indicate changes in the core reactivity state caused by changes in fission product inventory or boron concentration changes. Specifically, the High Flux at Shutdown alarm provides indication in the control room and in the containment (evacuation alarm). This function must be available for at least one of the operable channels. Audible count rate indication in the control room and containment must also be available from at least one channel. Finally, the SR channel response must be indicated in the control room for any " OPERABLE" SR channel.

Closed Reactor Trip Breakers During operation with the reactor trip breakers closed (MODES 3, 4, & 5), the St. channels not only perform the monitoring function described above, they also are required te generate a reactor trip signal. This is to provide diverse protection from subcritical cordition events to the Intermediate and Power Range channels. For these operating conditions, at additional requirement is that both OPERABLE SR channels must be able to generate a reactor trip signal.

Once permissive P-6 is cleared, the SR Trip Block, high voltage cutoff (as appropriate), and High Flux at Shutdown alarm block must function for all possible SR channels.

Spatial Requirements The placement of the OPERABLE SR channels with respect to each other during either one of the above mentioned conditions is of no consequence. The channels function equally well 90 apart (one in the normal well and one in the spare well) as they do 180* apart. All accidents and evolutions that the SR channels are designed to indicate are spatially symmetric in nature so that the channel placement, with respect to each other, is irrelevant.

Source Placement The location of the secondary source has no bearing on the detector selected as long as the detector is demonstrated to be fully functional via the response check and/or statistical evaluation.

ATTACHMENT 4 l Beaver Valley Power Station, Unit Nos.1 and 2 Proposed License Amendment Request No. 218 and 85  !

Revised Attachment B Marked-up Attachment B s

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', ATTACHMENT B Boavor Valley Powar Station, Unit Non. 1 cnd 2 Proposed Technical Specification Change No. 218 and 85 e

REVISION OF SOURCE RANGE DETECTORS 1

A. DESCRIPTION OF AMENDMENT REQUEST The proposed amendment would revise the source range requirements in Mode 2 (Below P-6), 3, 4, and 5 to incorporate the guidance provided in NUREG-1431 Improved Standard Technical Specifications (ISTS), with some modifications to address plant specific design I features. This change also incorporates two important features:

(1) allows the use of alternate detectors as long as the required  ;

functions are provided, and (2) with inoperable detectors, the I change allows plant cooldown as long as the shutdown margin I accounts for the temperature change. In addition, for Unit 2 Table I 3.3-1, the change modifies the Channels To Trip and Minimum Channels Operable to 0 and 1, respectively, to be consistent with the Unit 1 and ISTS requirements. Table 4.3-1 has been modified for both units to include items "a" and "b" as addressed in Table 3.3-1 and by including a note that exempts the alternate source range detectors from surveillance testing until they are required for operability.

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

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

detectors and Unit 2 has Gamma Metrics neutron detectors that only provide neutron indication to the Control Room and the alternate shutdown panel.

C. JUSTIFICATION Table 3.3-1, Reactor Trip System Instrumentation, Item 6 has been modified to includ: "cr :lternste" len; "ith the unit :pecific

-; urce r:ng: :nd :ltern t detecter merk n" 'er: t: aller the une '

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ATTACHMENT B, continued Proposed Technical Specification Change Nos. 218 and 85 Page 2

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aufficient : ncitivity t: d:qu:t ly :: nit:r re::tivity change; in the :: : Uhil pr viding th: :::: f; n:ti:n:1 require;;nt: th

r:ng: .cutr:r fluu d:t::t:r . */he clarification "(Below P-10)" h:: heen del ted since it could be read to require the source range detectors operable any time when Below P-10. In actuality, the source range detectors are not required operable between P-6 and P-10. This clarification has also been deleted from Table 4.3-1.

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

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

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

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

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

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

ATTACHMENT B, continutd

. ' Proposed Tcchnical Specification Change Nos. 218 and 85 Page 3 Seun Asy Table 3.3-1 for Channel Check since two channels are required operable. Item "b" appli es when the rods are fully inserted and not capable of withdrawal and specif: es an "S" for Channel Check since a qualitative evalua tion of th channel can be performed to verify the channel is indi ating in he approximate range for the expected plant condition and an "R" for Channel Calibration consistent with the ISTS Also on this table, the channel Functional Test frequencies have bee changed to "Q" with Note (8).

Note (8) has been modified to addr s the note applicable to ISTS SR ~ 3. 3.1. 7 to allow a trar sition rom Mode 2 to Mode 3 without first performing a channe: p funct nel test on the source range detectors. The words "Mtenet " been modified by Note (15) so that the alternate source range detectors are not required to be surveillance tested until they are connected to the appropriate circuits and required to be operable.

Bases 3/4.3.1 and 3/4.3.2, Protcctive and Engineered Safety Features (EST) Instrumentation, has been revised by adding the applicable portions of the ISTS Bases describing the source range detectors along with additional discussion concerning the use of "

alternate detectors.

D. SAFETY ANALYSIS The proposed changes will reduce the potential for enforcement discretions or emergency technical specification changes when source range d'a tectors are required but are declared inoperable.

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

Yea 2.2-1 The use of alternate detectors err rddrerred 51 sfdir; "::

cits nct " :nd th: ; .it ; :ifi: ---h -" 'crr te It " 5 Of T;b1 3.3 1. T;.i. is similar to Amendments 175 and 55, fo Units 1 and 2, respectively, which incorporated the use of alter te detectors into specification 3.9.2 for Mode 6. When two stectors are required operable, either the source range det ctors or the alternate detectors are adequate to meet th source range instrumentation requirements. This provides for c nnel separation to ensure redundant channels are available. The statement (Below P-10) can be interpreted to require the source range detectors to

be operable when Below P-10. However, the operator is permitted to remove power from the source range detectors when above P-6, therefore, to reduce the potential for confusion (Below P-10) has been deleted. The alternate detectors must provide the accuracy t

l and sensitivity required to adequately monitor changes in the core reactivity condition. The alternate detectors will be connected to the source range circuits to provide the required neutron flux

! indication, high flux at shutdown alarm, and source range high B-3

f l

ATTACHMENT 9, continued

. Proposed Technical Specification Change Nos. 218 and 85 Page 4

. S ee d e t R es 6"W neutron [ flux tr p. The relative source range and alternate detecto:f locations are shown on Attachment D, Figure 1. Unit 1 has l Install ed spara detectors N-33 and N-34 that are equivalent to l source cange detectors N-31 and N-32 and can be easily connected to i the sot rce range circuits in place of an inoperable source. range detectc r. Unit 2 has installed post-accident neutron flux monitors (Gamma Metric detectors) N-52A and N-52B that at present cannot be directLy connected to the source range circuits without a plant Therefore, Note (8) has been added to the words desigg:,:

":lt:_ change.

t:" that vie edd:d te Table 3.3-1 Item 6 so that the Gamma '

Metric detectors can only be used to provide additional verification of the core reactivity condition until such time as a plant design change is performed to provide the capability for directly connecting the Gamma Matric or other detectors into the source range circuits so they can provide the required alarm and trip functions. Incorporating this ability now will eliminate a future technical specification change that would otherwise be required to implement the plant design change to the detector

%j circuits.

41g g Note (15) has been added to the word 8":1.a..:t:" th:t  :: Odd:d t:

Table 4.3-1 Item 6 to indicate the alternate detectors are exempt from the surveillance requirements until such time as they are connected to the source range circuits and required to be operable.

This is appropriate for the testing of components when those components are not required to be operable but are subsequently demonstrated operable by surveillance testing prior to placing in service. The function of the source range detectors is to provide direct neutron flux monitoring of the core to detect changes in reactivity which would result in a loss of the required shutdown margin. Plant cooldown and xenon decay are recognized as positive reactivity additions, however, they are accounted for in the shutdown margin calculations. The shutdown margin remains essentially unchanged and will be availabla to preclude a criticality event during this evolution. The alternate detectors will provide 1;eutron flux monitoring in place of the source range {

detectors thus assuring core monitoring at a level consistent with the current technical specification requirements. Therefore, there is no loss of function or need for additional compensatory actions and required plant evolutions can be performed while ::elying on the alternate detectors.

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

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

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

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

Along with this, the Unit 2 Table 3.3-1 Item 6.b required number of

" Channels To Trip" and " Minimum channels operable" has been reduced by 1 to 0 and 1, respectively, since the plant is shutdown and the B-4 I

ATTACHMENT B, continutd

'Propoucd Tcchnical Specification Change Nos. 218 and 85 Page 5 rods are not capable of withdrawal. In this condition, the source range detectors do not provide a trip function and the control rods cannot be withdrawn to add positive reactivity. Therefore, the source range detectors only provide indication and the high flux at shutdown alarm so only one channel is required operable. This is consistent with the Unit 1 and ISTS requirements and eliminates a requirement 'to enter Specification 3.0.3 with two channels inoperable since now this condition is addressed in the action statement.

Table 3.3-1 Action 4 applies with the reactor trip breakers closed and the rods capable of withdrawal. ISTS Condition I has been addressed in Item "a" which applies in Mode 2 (Below P-6) with one inoperable detector. This action requires suspension of operations involving positive. reactivity additions. ISTS Condition K has been addressed in Item "b" and applies in Modes 3, 4, and 5 with one

. inoperable detector. This action requires restoring the inoperable channel to operable status within 48 hours5.555556e-4 days <br />0.0133 hours <br />7.936508e-5 weeks <br />1.8264e-5 months <br /> or open the reactor trip breakers in~the next hour. ISTS Condition J is addressed in Item "c" and applies in Modes 2 (Below P-6), 3, 4, and 5 with two inoperable detectors. In this condition, the action is to open the reactor trip breakers immediately. When the reactor trip breakers are open, then Action 5 applies since this action applies in Modes 3, 4, and 5 with the reactor trip breakers open and the rods not capable of withdrawal. This action incorporates ISTS Condition L with Item "aa -requiring suspension of operations involving positive reactivity additions. Note (7) is applied to this item to allow the plant to cooldown as long as the positive reactivity addition resulting from the cooldown is accounted for in the shutdown margin. Item "b" requires closing the unborated water source isolation valves within 1 hour1.157407e-5 days <br />2.777778e-4 hours <br />1.653439e-6 weeks <br />3.805e-7 months <br /> in accordance with Specification 3.1.2.9. This specification identifies- the valves that must be isolated and allows for RCS makeup by allowing those valves to be opened when performing planned boron dilution activities. Item "c" requires performing the shutdown margin requirements of Surveillance Requirement 4.1.1.1.1 or 4.1.1.2, as applicable, within the next hour and every twelve hours thereafter. Completion of'these action requirements addresses those criteria that must be satisfied to ensure that the core is maintained in a safe condition while also providing for plant cooldown which has been accounted for in the' shutdown margin.

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

! l 1 .

ATTACHMENT B, continutd Proposed Technical Specification Change Nos. 218 and 85 Page 6 inserted and are not capable of withdrawal, Item "b" requires a Channel check which involves a qualitative assessment to verify the channel is indicating in the proper range since only one channel is required operable in accordance with Table 3.3-1. Also provided is an "R" frequency for Channel Calibration and a "Q" Channel Functional Test frequency for Modes 3, 4 and 5 consistent with the ISTS. The Channel Functional Test frequency for the source range detectors has been changed to "Q" like the ISTS with Note (8).

Note (8) currently states "Below P-6" and has been modified by allowing a reasonable period of time following the transition from Mode 2 to Mode 3 to perform the source range channel functional test. The transition into Mode 3 with the reactor trip breakers closed involves a short period of time in Mode 3 before the reactor trip breakers are opened during a plant shutdown. The transition time in Mode 3 from when the reactor trip breakers are closed to when they are opened is less than the time required to perform the channel functional test prior to entering Mode 3. Therefore, the ability to enter Mode 3 without first performing the. source range channel functional test is warranted. Following a plant trip, the operators are evaluating the condition of the plant, complying with technical specifications and setting priorities. The selected time is reasonable, based on operating experience, to perform a Channel Functional Test on the source range detectors in an orderly manner and without challenging the operators during plant trip as well as normal plant shutdown operations.

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

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

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

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

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

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

B-6 i

ATTACHMENT B, continutd

. Proposed Tcchnic21 Specification Change Nos. 218 and 85 Page 7 l

(1) Involve a significant increase in the probability or consequences of an accident previously evaluated; or  !

(2) Create the possibility of a new or different kind of I accident from any accident previously evaluated; or l

(3) Involve a significant reduction in a margin of safety.

The following evaluation is provided for the no significant hazards consideration standards.

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

The proposed amendment would modify the reactor trip system instrumentation requirements to permit the use of alternate I detectors in place of inoperable source range detectors. The alternats detectors will be connected to the source range circuitis to provide the required indications and functions.

The alternate detectors are not required to be tested to satisfy the surveillance requirements until they are connected to the source range circuits and required to be operable. The alternate detectors must have the accuracy and sensitivity required to adequately monitor changes in the core reactivity levels. The alternata detectors will provide neutron flux monitoring in place of the source range detectors thus assuring core monitoring at a level consistent with the current technical specification requirements. Therefore, there is no loss of function or need for additional compensatory actions and the operators can perform required plant evolutions while relying on the alternate detectors.

Two operable detectors are required when the control rods are capable of withdrawal. Rod withdrawal and boron dilution add positive reactivity which can significantly affect the reactivity condition of the core, therefore, two monitors are required operable during startup evolutions. Redundant detectors are required to ensure that two source range neutron flux detectors are available to detect changes in core reactivity. These changes provide those indications and functions consistent with the current technical specification requirements where at least two source range detectors are operating and capable of providing the required functions.

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

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

___ ________ _ a

ATTACHMENT B, continued

, ' Proposcd Tschnical Specification Changa Nos. 218 and 85 Page 8 reactivity addition, however, this is accounted for in the shutdown margin calculations. The shutdown margin remains '

essentially unchanged and will be available to preclude a criticality event during this evolution. Inadvertent control rod withdrawal is not a concern, therefore, one source range or alternate detector can adequately monitor the. core neutron flux. The action statements have been modified to address the NUREG-1431 Improved Standard Technical Specification (ISTS) requirements along with incorporating the ability to use alternate detectors in place of the source range detectors.

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

The operability requirements of the source range neutron flux instrumentation will continue -to be met when uning an alternate detector in place of a source range neutron flux detector. No changes are being incorporated that would act to increase the probability of a positive reactivity addition event, therefore, the proposed change will not involve a significant increase in the probability or consequences of an accident previously evaluated.

2. Does the change create the possibility of a new or different kind of accident from any accident previously evaluated?

l The function of the source range detectors is to provide direct neutron flux monitoring of the core to detect positive reactivity additions which would result in a loss of the ';

required shutdown margin. The alternate detectors must provide the ' accuracy and sensitivity required to adequately ,

monitor changes in the core reactivity levels during shutdown and startup activities. The alternate monitors will be connected to the source range circuits to provide the required l indications and functions. Therefore, there is no loss of I function or need for additional compensatory actions and plant shutdown and startup activities can be continued while relying l

on the alternate detectors.

Control rod withdrawal is a method capable of providing rapid positive reactivity addition with boron dilution being a much slower positive reactivity addition method. With the control rods capable of withdrawal, a rod withdrawal event could rapidly initiate core criticality so redundant source range detectors are required operable. This ensures adequate monitoring capability is available to alert the operators of a rapid increase in the core reactivity condition. The maximum reactivity addition due to the boron dilution is slow enough B-8

ATTACHMENT B, continund Propoacd Technical Sp cification Change Nos. 218 and 65 Page'9 to allow the operator to determine the cause and take corrective action before the shutdown margin is lost. These changes will not affect the operability or reliability of the source range instrumentation to provide the required indications and functions. Therefore, the proposed , change will not create the possibility of a new or different kind of accident from any accident previously evaluated.

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

The proposed change will continue to ensure the required source range instrumentation functions are available during shutdown and startup conditions. This change will not reduce the reliability of the source range detectors to monitor the core reactivity condition and provide the appropriate indications or affect the required shutdown margin. Plant operation will continue to be maintained within the shutdown margin requirements of Specification 3.1.1.1 and 3.1.1.2. The required indications and functions are still maintained in accordance with current technical specification requirements and the shutdown margin is unaffected, therefore, the proposed change will not involve a significant reduction in a margin of safety.

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

G. ENVIRONMENTAL CONSIDERATION The proposed amendment chan'es g a requirement with respect to the .

l installation or use of a facility component located within the i restricted area as defined in 10 CFR- Part 20. It has been determined that the proposed amendment involves no significant increase in the amounts, and no significant change in the types of any affluents that may be released offsite, and that there is no significant' increase in individual or cumulative occupational '

l radiation exposure. Accordingly, the proposed amendment meets the eligibility criteria for categorical exclusion set forth in 10 CFR

51. 22 (c) (9) . Pursuant to 10 CFR 51.22 (b) no environmental impact statement or environmental assessment need be prepared in i connection'with the issuance of this proposed amendment.

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

B-9 m

ATTACHMENT 5 Beaver Valley Power Station, Unit Nos. I and 2 Proposed License Amendment Request No. 218 and 85

. Revised Attachment B Typed version with side-bars indicating the areas of change.

( - ._____________ _ _ _

ATTACHMENT B BEnvor Valley Powcr Station, Unit Nos. 1 cnd 2 Proposed Technical Specification Change No. 218 and 85 REVISION OF SOURCE RANGE DETECTORS A. DESCRIPTION OF AMENDMENT REQUEST The proposed amendment would revise the source range requirements in Mode 2 (Below P-6), 3, 4, and 5 to incorporate the guidance provided in NUREG-1431 Improved Standard Technical Specifications (ISTS), with some modifications to address plant specific design features. This change also incorporates two important features:

(1) allows the use of alternate detectors as long as the required functions are provided, and (2) with inoperable detectors, the change allows plant cooldown as long as the shutdown margin accounts for the temperature change. In addition, for Unit 2 Table 3.3-1, the change modifies the Channels To Trip and Minimum Channels Operable to 0 and 1, respectively, to be consistent with the Unit 1 and ISTS requirements. Table 4.3-1 has been modified for both units to include items "a" and "b" as addressed in Table 3.3-1 and by including a note that exempts the alternate source range detectors from surveillance testing until they are required for operability.

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

During the Unit 2 fourth refueling outage, Action 5 was entered because source range detector N-31 was declared inoperable. The requirements of this action were complied with, then source range detector N-32 was tested to verify its operability. This detector was found operable, however, since two detectors were not operable as required by Table 3.3-1 Item 6.b, the potential existed for required entry into Specification 3.0.3 which requires a mode reduction with resulting plant cooldown. However, the required plant cooldown would involve a positive reactivity addition as a result of the RCS temperature reduction, which is contrary to the requirements of Action 5 that specifies no positive reactivity i I

changes. Therefore, this change to the technical specification requirements was requested by the plant to eliminate the potential for a repeat of this event. In addition to correction of the above problem, it was determined that this change should also include the ability to use alternate detectors since Unit I has installed spare detectors and Unit 2 has Gamma Metrics neutron detectors that only provide neutron indication to the Control Room and the alternate shutdown panel.

C. JUSTIFICATION Table 3.3-1, Reactor Trip System Instrumentation, Item 6 has been

{ modified by deleting the clarification "(Below P-10)" since it l l could be read to require the source range detectors operable any

( time when Below P-10. In actuality, the source range detectors are B-1

ATTACHMENT B, continund Propo3rd Technical Specification Changs Nos. 218 and 85 Page 2 not required operable between P-6 and P-10. This clarification has also been deleted from Table 4.3-1.

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

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

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

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

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

Table 4.3-1, Reactor Trip System Instrumentation Surveillance Requirements, Item 6, has been separated into Items "a" and "b" like Table 3.3-1 to specify surveillance requirements based on rod withdrawal capability. Item "a" applies when the rods are capable of withdrawal and provides for an "S" Channel check frequency with an "R" Channel Calibration frequency. This is consistent with Table 3.3-1 for Channel Check since two channels are required operable. Item "b" applies when the rods are fully inserted and not capable of withdrawal and specifies an "S" for Channel Check since a qualitative evaluation of the channel can be performed to l verify the channel is indicating in the approximate range for the  !

expected plant conditions and an "R" for Channel Calibration consistent with the ISTS. Also on this table, the Channel Functional Test frequencies have been changed to "Q" with Note (8).

l B-2

~ _ _ _ _ _ _ _ _ _ _ _ _ _ - _ _ _ _ _ _ _ ___

ATTACHMENT B, continusd Prepo3cd Tcchnical Specification Ch::ngs No3. 218 and 85 Page 3 Note (8) has been modified to address the note applicable to ISTS

, SR 3. 3.1.7 to allow a transition from Mode 2 to Mode 3 without I

first performing a channel functional test on the source range detectors. The words " Source Range" have been modified by Nota l (15) so that the alternate source range detectors are not required to be surveillance tested until they are connected to the l appropriate circuits and required to be operable.

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

' detectors along with additional discussion concerning the use of alternate detectors.

I' D. SAFETY ANALYSIS The proposed changes will reduce the potential for enforcement

! discretions or emergency technical -specification changes when

! source range detectors are required but are declared inoperable.

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

The use of alternate detectors is similar to Amendments 175 and W , l for Units 1 and 2, respectively, which incorporated the use of alternate detectors into Specification 3.9.2 for Mode 6. When two detectors are required operable, either the source range detectors j l or the alternate detectors are adequate to meet the source range

. instrumentation requirements. This provides for channel separation to ensure redundant channels are available. The Table 3.3-1 l statement (Below P-10) can be interpreted to require the source range detectors to be operable when Below P-10. However, the operator is permitted to remove power from the source range detectors when above P-6, therefore, to reduce the potential for

! confusion (Below P-10) has been deleted. The alternate detectors must provide the accuracy and sensitivity required to adequately monitor changes in the core reactivity condition. The alternate detectors will be connected-to the source range circuits to provide the required neutron flux indication, high flux.at shutdown alarm, and source range high neutron flux trip. The relative source range and alternate detector locations are shown on Attachment D, Figure

1. Unit i has installed spara detectors N-33 and N-34 that are equivalent to . source range detectors N-31 and N-32 and can be easily connected to the source range circuits in place of an inoperable source range detector. Unit 2 has installed post-accident neutron flux monitors (Gamma Metric detectors)' N-52A and N-52B that at present_cannot be directly connected to the source range circuits without a plant design change. Therefore, Note (8) has been added_to the words " Source Range" for Table 3.3-1 Item 6 l so that - the Gamma Matric detectors can only be used to provide B-3

l .

ATTACHMENT 3, continusd

. Proposcd Tcchnical Specification Chengo Nos. 218 and 85 Page 4 additional verification of the core reactivity condition until such I

time as a plant design change is performed to provide the capability for directly connecting the Gamma Matric or other detectors into the source range circuits so they can provide the required alarm and trip functions. Incorporating this ability now will eliminate a future technical specification change that would i otherwise be required to implement the plant design change to the detector circuits.

Note (15) has been added to the words " source Range" in Table 4.3-1 l Item 6 to indicate the alternate detectors are exempt from the surveillance requirements until such time as they are connected to the soutce range circuits and required to be operable. This is appropriate for the testing of components when those components are not required to be operable but are subsequently demonstrated operable by surveillance testing prior to placing in service. The function of the source range detectors is to provide direct neutron flux monitoring of the core to detect changes in reactivity which would result in a loss of the required shutdown margin. Plant cooldown and xenon decay are recognized as positive reactivity additions, however, they are accounted for in the shutdown margin calculations. The shutdown margin remains essentially unchanged and will be available to preclude a criticality event during this evolution. The alternate detectors will provide neutron flux monitoring in place of the source range detectors thus assuring core monitoring at a level consistent with the current technical specification requirements. Therefore, there is no loss of function or need for additional compensatory actions and required plant evolutions can be performed while relying on the alternate detectors.

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

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

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

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

Along with this, the Unit 2 Table 3.3-1 Item 6.b required number of

" Channels To Trip" and " Minimum Channels operable" has been reduced by 1 to 0 and 1, respectively, since the plant is shutdown and the rods are not capable of withdrawal. In this condition, the source range detectors do not provide a trip function and the control rods cannot be withdrawn to add positive reactivity. Therefore, the source range detectors only provide indication and the high flux at shutdown alarm so only one channel is required cperable. This is consistent with the Unit 1 and ISTS requirements und eliminates a requirement to enter Specification 3.0.3 with two channels inoperable since now this condition is addressed in the action statement.

B-4

-ATTACHMENT B, continusd Propo3od Tcchnical Specification ChEnga Nos. 218 and 85 -

Page 5 Table 3.3-1 Action 4 applies with the reactor trip breakers closed and the rods capable of withdrawal.

c ISTS Condition I has been

. addressed in Item "a" which applies in Mode 2 (Below P-6) with one inoperable detector. This action requires suspension of operations involving positive reactivity additions. ISTS Condition K has been addressed in Item "b" and applies in Modes 3, 4, and 5 with one inoperable detector. This action requires restoring the inoperable channel to operable status within 48 hours5.555556e-4 days <br />0.0133 hours <br />7.936508e-5 weeks <br />1.8264e-5 months <br /> or open the reactor trip breakers in the next hour. ISTS Condition J is addressed in Item "c" and applies in Modes 2 (Below P-6), 3, 4, and 5 with two inoperable detectors. In this condition, the action is to open the reactor trip breakers immediately. When the reactor trip breakers are open, then Action 5 applies since this action applies in Modes 3, 4, and 5 with the reactor trip breakers open and the rods not capable of withdrawal. This action incorporates ISTS Condition L with Item "a" requiring suspension of operations involving positive reactivity additions. Note (7) is applied to this item to allow the plant to cooldown as long as the positive reactivity addition resulting -from the cooldown is accounted for in the shutdown margin. Item "b" requires closing the unborated water source isolation valves within 1 hour1.157407e-5 days <br />2.777778e-4 hours <br />1.653439e-6 weeks <br />3.805e-7 months <br /> in accordance with- Specification 3.1.2.9. This specification identifies the valves that must be isolated and allows for RCS makeup by allowing those valves to be opened when performing planned boron dilution activities. Item "c" requires performing the shutdown margin requirements of Surveillance Requirement 4.1.1.1.1 or 4.1.1.2, as applicable, within the next hour and every twelve hours thereafter. Completion of these action. requirements addresses those criteria that must be satisfied to ensure that the core is maintained in a safe condition while also providing for plant cooldown which has been accounted for in the shutdown margin.

Table 4.3-1, Item 6, has been modified to include the use of alternate detectors and separated into Items "a" and "b" similar to the changes to Table 3.3-1. When the rods are capable of withdrawal, Item "a" provides an "S" Channel Check and an "R"

' Channel. Calibration frequency consistent with Table 3.3-1 requirements where two channels are required operable. The Channel check ensures that gross failure of the instrumentation has not occurred and the Channel Calibration ensures the entire channel vill perform the intended function. Also provided is a "Q" Channel

.lunctional Test frequency for Modes 2, 3, 4 and 5 consistent with current requirements and the ISTS. When the rods are fully inserted and are not capable of withdrawal, Item "b" requires a Channel Check which involves a qualitative assessment to verify the channel is indicating in the proper range since only one channel is ,

required operable'in accordance with Table 3.3-1. Also provided is l an "R" frequency for Channel Calibration and a "Q" Channel Functional Test frequency for Modes 3, 4 and 5 consistent with the ISTS. The Channel Functional Test frequency for the source range detectors has been changed to "Q" like the ISTS with Note (8).

Note' (8) ~ currently states "Below P-6" and has been modified by allowing a reasonable period of time following the transition from B-5

ATTACHMENT B, continutd Preposcd Tcchnical Sp:cification Chengo Nos. 218 cnd 85

.Page 6 Mode 2 to Mode 3 to perform the source range channel functional test. The transition into Mode 3 with the reactor trip breakers closed involves a short period of time in Mode 3 before the reactor trip breakers are opened during a plant shutdown. The transition time.in Mode 3 from when the reactor trip breakers are closed to when they are opened is less than the time required to perform the channel functional test prior to entering Mode 3. Therefore, the ,

ability to enter Mode 3 without'first performing the source range '

channel functional test is warranted. Following a plant trip, the operators are evaluating the condition of the plant, complying with technical specifications and setting priorities. The selected time is reasonable, based on operating experience, to perform a channel Functional Test on the source range detectors in an orderly manner and without challenging the operators during plant trip as well as normal plant shutdown operations.

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

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

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

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

The Commission may make a final determination, pursuant to the procedures in paragraph 50.91, that a proposed amendment to an operating licanse for a facility licensed under paragraph 50.21(b) or paragraph 50.22 or for a testing facility involves no significant hazards consideration, if operation of the facility in accordance with the proposed amendment would not:

(1) Involve a significant increase in the probability or consequences of an accident previously evaluated; or (2) Create the possibility of a new or different kind of accident from any accident previously evaluated; or (3) Involve a significant reduction in a margin of safety.

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ATTACHMENT 3, continued Propoxd Tschnical Specification Changa Nos. 218 and 85 Page 7-The following evaluation is provided for the no significant hazards consideration standards.

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

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

The alternate detectors are not required to be tested to satisfy the surveillance requirements until they are connected to the source range circuits and required to be operable. The alternate detectors must have the accuracy and sensitivity required to adequately monitor changes in the core reactivity

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

Two operable detectors are required when the control rods are capable of withdrawal. Rod withdrawal and boron dilution add positive reactivity which can significantly affect the reactivity condition of the core, therefore, two monitors are required operable during. startup evolutions. Redundant detectors are required to ensure.that two source range neutron flux detectors are available to detect changes in core reactivity. These changes provide those indications and functions consistent with the current technical specification requirements where at least two source range detectors are operating and capable of providing the required functions.

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

One source range or alternate detector is required when the control rods are fully inserted and are not capable of withdrawal. Plant cooldown is recognized as a positive reactivity addition, however, this is accounted for in the shutdown margin calculations. The shutdown margin remains essentially unchanged and will be available to preclude a criticality event during this evolution. Inadvertent control rod withdrawal is not a concern, therefore, one source range or alternate detector can adequately monitor the core neutron flux. The' action statements have been modified to address the NUREG-1431 Improved Standard Technical Specification (ISTS)

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I-A'IrACHMENT d

B, continusd Propo3Cd TOchnical Specification Chengs Nos. 218 cnd 85 Page 8 l

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requirements along with incorporating the ability to use alternate detectors in place of the source range detectors.

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

The operability requirements of the source range neutron flux instrumentation will continue to be met when using an alternate detector in place of a source range neutron flux detector. No changes are being incorporated that would act to 1 increase the probability of a positive reactivity addition event, therefore, the proposed change will not involve a significant increase in the probability or consequences of an accident previously evaluated.

2. Does the change create the possibility of a new or different kind of accident from any accident previously evaluated?

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

Control rod withdrawal is a method capable of providing rapid positive reactivity addition with boron dilution being a much slower positive reactivity addition method. With the control I

rods capable of withdrawal, a rod withdrawal event could rapidly initiate core criticality so redundant source range l detectors are required operable. This ensures adequate l monitoring capability is available to alert the operators of a rapid increase in the core reactivity condition. The maximum reactivity addition due to the boron dilution is slow enough to allow the operator to determine the cause and take corrective action before the shutdown margin is lost. These changes will not affect the operability or reliability of the

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

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I AITACHMENT D, continu:d Prop 2ccd Tcchnical Specification ChEnga No3. 218 and F5 Page 9

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

The proposed change will continue to ensure the required source range instrumentation functions are available during shutdown and startup conditions. This change will not reduce the reliability of the source range detectors to monitor the core reactivity condition and provide the appropriate indications or affect the required shutdown margin. Plant operation will continue to be maintained within the shutdown margin requirements of Specification 3.1.1.1 and 3.1.1.2. The required indications and functions are still maintained in accordance with current technical specification requirements 1 and the shutdown margin is unaffected, therefore, the proposed change will not involve a significant reduction in a margin of safety.

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

G. ENVIRONMENTAL CONSIDERATION The proposed amendment changes a requirement with respect to the installation or use of a facility component located within the restricted area as defined in 10 CFR Part 20. It has been determined that the proposed amendment involves no significant increase in the amounts, and no significant change in the types of any effluents that may be released offsite, and that there is no significant increase in individual or cumulative occupational radiation exposure. Accordingly, the proposed amendment meets the eligibility criteria for categorical exclusion set forth in 10 CFR

51. 22 (c) (9) . Pursuant to 10 CFR 51.22 (b) no environmental impact statement or environmental assessment need be prepared in connection with the issuance of this proposed amendment.

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

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