ML20237D411

Proposed Tech Specs Reflecting Conversion to Improved TS Re Discussion of Changes & Significant Hazards Evaluations

ML20237D411
Person / Time
Site:	Farley
Issue date:	08/20/1998
From:	SOUTHERN NUCLEAR OPERATING CO.
To:
Shared Package
ML20237D406	List: ML20237D404 ML20237D411
References
NUDOCS 9808260147
Download: ML20237D411 (100)

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Farley Nucicar Plant ITS Conversion Submittal - Electronic Copy Revised DOCS Revised DOCS (Section 2.0)

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2 (o FNP TS Conversion Enclosure 2 - Discussion of Changes to CTS Chapter 2.0 - Safety Limits CTS 2.0 SAFETY LIMITS AND LIMITING SAFETY SETTINGS FNP ITS 2.0 SAFETY LIMITS DOC ILQ SHE DISCUSSION limit be restored within one hour. Considering the importance of the reactor core Safety Limit, the inclusion of this STS requirement to restore to within the limit in one hour is reasonable and provides additional assurance prompt action will be taken to rectify the out oflimit condition.

Therefore, this change is appropriate and applicable to FNP. However, this change represents the addition of a new TS requirement and is therefore considered a more restrictive clunge.

5 A The CTS Action statements associated with Safety Limit 2.1.2 are revised consistent with the STS. The CTS Actions repeat the RCS pressure limit of 2735 psig (SL 2.1.2) within the Action. The STS simply states "If SL 2.1.2 is violated". The use of the STS Action statements does not technically change the CTS Actions. The STS Actions are effectively the same and simply reference the appropriate Safety Limit by specification number instead of re-stating the limit itself. Therefore, this change is considered administrative and is made to conform with the fbnnat and presentation of the STS. i 6 A CTS figure 2.1-1, Reactor Core Safety Limits, is revised consistent with the .

corresponding STS figure and with the main control board indications used  !

to confirm the limits represented by this CTS figure. The PSIA values used in the CTS figure to represent the pressure limit curves are convened into PSIG values. This conversion is consistent with the FNP main control i board pressure indications used to confirm operation within the limits and with the values used in the corresponding STS figure. The conversion of the PSIA values to PSIG values does not alter the limits represented in this CTS figure. The change is made to confbrm with the main control board indications and with the presentation of this information in the STS. As sech, this change is considered admirNrative.

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Chapter 2.0 E2-2-A March,1998 l

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FNP TS Conversion Enclosure 2 - Discussion of Changes Chapter 3.0 - LCO and SR Applicability DOC

_NQ SHE DISCUSSION the LCO must be entered and the Actions times become applicable due to a missed surveillance. As stated in Generic Letter (GL) 87-09, "It is overly

conservative to assume that systems or components are inoperable when a l surveillance has not been performed. The opposite is in fact the case, the vast majority of surveillance demonstrate that systems or components in fact are operable. When a surveillance is missed, it is primarily a question ofoperability that has not been verified by the performance of the required surveillance." Based on the consideration of plant conditions, adequate planning, availability of personnel, the time required to perform the surveillance, the NRC concluded that 24 hours2.777778e-4 days <br />0.00667 hours <br />3.968254e-5 weeks <br />9.132e-6 months <br /> is an acceptable time limit for completing a missed surveillance Although originally approved in GL 87-09 only for LCOs where the allowable outage times of the Actions were shorter than 24 hours2.777778e-4 days <br />0.00667 hours <br />3.968254e-5 weeks <br />9.132e-6 months <br />, SR 3.0.3 provides the allowance for all LCOs. The acceptability of this delay period for all LCOs in the STS, regardless of the allowed outage time for the Actions,is based on the fact that short allowed outage times are generally provided for more safety significant systems and LCOs (i.e.,2 hours2.314815e-5 days <br />5.555556e-4 hours <br />3.306878e-6 weeks <br />7.61e-7 months <br /> for the battery), and if a 24 hour2.777778e-4 days <br />0.00667 hours <br />3.968254e-5 weeks <br />9.132e-6 months <br /> delay is acceptable to a critical system with a 2 hour2.314815e-5 days <br />5.555556e-4 hours <br />3.306878e-6 weeks <br />7.61e-7 months <br /> allowed outage time, it should have less impact on safety if applied to systems with longer allowed outage times  !

(e.g.,7 days). The STS delay of 24 hours2.777778e-4 days <br />0.00667 hours <br />3.968254e-5 weeks <br />9.132e-6 months <br /> is not applicable if the specified  !

frequency of the missed surveillance is less than 24 hours2.777778e-4 days <br />0.00667 hours <br />3.968254e-5 weeks <br />9.132e-6 months <br />. In this case, the specified frequency dictates the delay period. The second and third paragraphs of SR 3.0.3 provide additional clarification regarding the application of this delay and the performance of the surveillance (i.e., if the surveillance is not performed within the delay period then the LCO is declared not met and the Actions times become applicable). j 15 A CTS 4.0.4 is revised consistent with the STS. The STS SR 3.0.4 includes the statement that "This provision shall not prevent entry into Modes or other specified conditions in the applicability that are required to comply with Actions." The addition of this statement to SR 3.0.4 (CTS 4.0.4) provides clarification consistent with a similar statement in LCO 3.0.4 and with the NRC guidance in GL 87-09. The addition of this guidance is considered an administrative change.

l 16 LA The references to the ASME inservice inspection (ISI) requirements are l removed from CTS 4.0.5 consistent with the STS. The requirements in the TS for ASME ISI duplicate existing regulations (10 CFR 50.55a). The references in the TS are therefore not required and have been removed consistent with the STS. These requirements are effectively contained in the current FNP ISI program. Removal from the TS is acceptable since the Chapter 3.0 E2-6 March,1998 1

Faricy Nuclear Plant ITS Conversion Submittal - Electronic Copy Revised DOCS Revised DOCS (Section 3.1)

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FNP TS Conversion Enclosure 2 - Discussion of Changes to CTS j Chapter 3.1 - Reactivity Centrol Systems CTS 3/4.1.3.4 ROD DROP TIME FNP ITS - SR 3.1.4.3 DOC NO SHE DISCUSSION 1 A The CTS 3/4.1.3.4 LCO requirements are effectively retained within the TS in SR 3.1.4.3 consistent with the STS. The STS does not include a corresponding LCO for rod drop time. The STS simply associates rod drop time to rod operability. In the STS, rod operability is addressed by LCO 3.1.4. The CTS 3/4.1.3.4 LCO specifies the required drop time (including start and finish points), rod position, RCS temperature and RCS pump status. All these requirements have been retained within the FNP ITS surveillance SR 3.1.4.3. As this change only reorganizes the CTS requirements to be consistent with the format and presentation and wording of the STS, it is considered an administrative change.

2 LA The CTS 3/4.1.3.4 LCO requirement specifying the rod position in steps that corresponds to the fully withdrawn position and the associated asterisked note is moved into the bases for SR 3.1.4.3. The surveillance requirement simply specifies " fully withdrawn position". The FNP description of fully withdrawn is included in the bases for the SR along with the other surveillance details. The plaa % at of descriptive or detailed information in the bases is consistent with the fonnat and presentation of the STS. Reliance on the information contained in the STS bases is acceptable since changes to the information in the bases is controlled by the Bases Control Program specified in the administrative controls section of the TS.

3 A The CTS 3/4.1.3.4 LCO is revised consistent with the STS. The CTS term

" full length" as used to modify rods in the LCO statements is deleted. This term was dropped in the STS because no Westinghouse plant uses part length rods. Since all control and shutdown rods are full length there is no reason to continue using the descriptive term " full length" rods. As FNP does not use part length rods, the term " full length" is no longer required to differentiate the rod type and is deleted. This change has no technical impact on the TS requirements and is made solely to conform to the applicable format and presentation of this information in the STS.~

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4 A The CTS 3/4.1.3.4 Applicability and Action requirements are effectively retained in the TS within FNP ITS 3.1.4 and the general rules of TS as specified in SR 3.0.4. The CTS Mode of applicability is Modes I and 2 and the CTS action requires that the rod drop time be restored to within the limit Chapter 3.1 E2-1-J March,1998

Farley Nuclear Plant ITS Conversion Submittal - Electronic Copy Revised DOCS Revised DOCS (Section 3.2)

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38 FNP TS Conversion Enclosure 2 - Discussion of Changes to CTS Chapter 3.2 - Power Distribution Limits CTS 3/4.2.2 HEAT FLUX HOT CHANNEL FACTOR - Fo (Z)

FNP ITS 3.2.1 HEAT FLUX HOT CHANNEL FACTOR (Fn (Z))

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_N_Q SHE DISCUSSION Fn(Z) limit discussed previously. Although the sonforming to the intent of the STS surveillance by adding the descriptor " transient" in place of the STS term Fo*(Z) establishes a different term for this Fn(Z) limit, the STS surveillance does not introduce a technical change to the requirements of the CTS. The new term and associated surveillance are introduced by the STS to facilitate the presentation of the nF (Z) limits in the ITS format. As these changes effectively retain the CTS requirements in the format and presentation of the STS, they are considered administrative in nature.

10 L CTS surveillance 4.2.2.2.g.2 is revised consistent with the STS. CTS 4.2.2.2.g.2 requires the Axial Flux Difference (AFD) limits to be revised when Fo(Z) is determined to be increasing. The revised AFD limits are based on the percent that eF (Z) exceeds its limit. CTS 4.2.2.2.g.2 allows 15 minutes to control the AFD to within the new limits. The time allowed by CTS 4.2.2.2.g.2 to control AFD to within the new limits is revised from 15 minutes to 4 hours4.62963e-5 days <br />0.00111 hours <br />6.613757e-6 weeks <br />1.522e-6 months <br />. The STS allowance of 4 hours4.62963e-5 days <br />0.00111 hours <br />6.613757e-6 weeks <br />1.522e-6 months <br /> provides a more reasonable time in which to control the AFD within the revised limits and thereby reduces the potential for operator error. The four hour allowance in the STS is a sufficient restriction considering the reduced potential for operator error and the small likelihood of a severe transient occurring within this time.

I1 A CTS surveillance 4.2.2.2.g.2 is revised consistent with the STS. This CTS surveillance specifies actions to be taken when Fn(Z) exceeds its limit. CTS 4.2.2.2.g.2 requires the Axial Flux Difference (AFD) limits to be revised based on the percent that nF (Z) exceeds its limit. In the STS, this CTS surveillance is presented in Condition B (F*q(Z) not within limit) as the associated Required Action B.I. The presentation of this surveillance requirement as an action in the STS (using the descriptor " transient" in the FNP ITS in place of the STS term F*n(Z)) does not impact the CTS requirements and is considered an administrative change made to conform with the format and presentation of the STS.

l 12 L CTS surveillance 4.2.2.2.g.2 is revised consistent with the STS. The CTS 4.2.2.2.g.2 requirement to reset the AFD alarm setpoints to the modified limits is deleted. CTS 4.2.2.2.g.2 requires the Axial Flux Difference (AFD) limits to be revised (reduced) based on the percent that Fn(Z)

Chapter 3.2 E2-4-B March,1998

N FNP TS Conversion Enclosure 2 - Discussion of Changes to CTS Chapter 3.2 - Power Distribution Limits CTS 3/4.2.4 QUADRANT POWER TILT RATIO FNP ITS 3.2.4 QUADRANT POWER TILT RATIO (QPTR)

DOC N.Q SHE DISCUSSION 1 A The CTS 3/4.2.4

• footnote referring to Special Test Exception 3.10.2 is deleted consistent with the STS. The STS does not use footnotes to reference the applicable test exceptions. In the STS, the test exceptions state the LCOs to which they take exception and are located in the same TS section as the LCOs they affect. As this change does not affect the requirements of CTS 3/4.2.4 or special test exception 3.10.2, and is made only to conform with the format and presentation of this information in the STS, it is considered an administrative change.

Ia M The CTS 3/4.2.4 Mode of Applicability is revised to be consistent with the Mode of Applicability for the Axial Flux Difference LCO. The QPTR Applicability is revised from "above 50% RTP" to "2 50% RTP". ,

Although this change introduces a slightly more conservative Applicability i for the QPTR LCO, it maintains the CTS consistency between the AFD and l QPTR Applicabilities. This change has a minimal impact on plant operation and eliminates the introduction of subtle ditTerences between two  ;

LCO Applicabilities that were previously the same. As a result of this change, Required Action B.1 is also revised to remove the unit from the Mode of Applicability by reducing thermal power to < 50% RTP.

2 M The CTS 3/4.2.4 Actions are revised consistent with the STS. The CTS Action statement "a" and "c" are deleted. All Actions in the STS are based l on exceeding the LCO QPTR limit of 1.02 and do not contain specific Actions if QPTR is less than or equal to or greater than 1.09. This change is consistent with the basic rules of TS and the application of actions when l

the limit specified in the LCO is not met. Therefore, this change is applicable to FNP. As all QPTR Actions are now based on exceeding only the CTS lower limit of 1.02, this change is considered more restrictive.

3 L CTS 3/4.2.4 action a.1 and c.1 require QPTR to be calculated once per hour until either QPTR is restored to within its limit or until thermal power is reduced to less than 50 percent RTP. These CTS actions are replaced with l the STS actions A.2 and A.I. STS Action A.2 requires QPTR to be l determined at least once per 12 hours1.388889e-4 days <br />0.00333 hours <br />1.984127e-5 weeks <br />4.566e-6 months <br /> until QPTR is restored to within its limit. STS Action A.1 requires that power be limited from RTP by 3% for each I % that QPTR exceeds 1.00. The 12-hour interval in the STS action A.2 for determining QPTR is reasonable considering the limits on power required by STS Required Action A.1, which allows 2 hours2.314815e-5 days <br />5.555556e-4 hours <br />3.306878e-6 weeks <br />7.61e-7 months <br /> to ensure Chapter 3.2 E2-1-D March,1998

d FNP TS Conversion Enclosure 2 - Discussion of Changes to CTS Chapter 3.2 - Power Distribution Limits CTS 3/4.2.4 QUADRANT POWER TILT RATIO FNP ITS 3.2.4 QUADRANT POWER TILT RATIO (QPTR)

DOC N_OQ SHE DISCUSSION Alignment Limits LCO would also be applicable.

8 A CTS 3/4.2.4 action statement "d" ir deleted consistent with the STS. CTS action statement "d" states the provisions of Specification 3.0.4 are not applicable. Since the QPTR actions have been modified .ss described above to allow continued operation above 50% RTP, a specific exception to Specification 3.0.4 is no longer required. The STS LCO 3.0.4 contains a

" built in" exception for Actions Conditions that allow continued operation within the applicable Mode of the TS provided the action requirements are met. The revised QPTR actions in Condition A of the STS allow operation above 50% RTP to continue indefinitely provided the Actions are raet. The power limitations required by the STS actions are based on 3% incremental reductions from 100% RTP. Therefore, the STS LCO 3.0.4 will allow power to be increased above 50% when QPTR is not within the required limit. The QPTR actions of the CTS require that power be reduced below 50% within a set completion time and do not allow operation beyond that completion time within the applicable Mode (above 50% RTP) of the QPTR TS. As such, the elimination of the CTS exception to specification 3.0.4 is considered administrative since the CTS allowance to increase power above 50% when QPTR is not within the required limit remains unchanged.

9 A The CTS surveillance 4.2.4.1 is revised consistent with the STS. The CTS surveillance requires QPTR to be verified within the limit above 50% RTP.

The phrase "above 50% power" is deleted. The Mode of applicability of the QPTR TS is 2 50% power. The general rules of TS require the associated surveillance to be performed during the Mode of applicability.

Therefore, the phrase above 50% power in this surveillance is not required l to specify when the surveillance is required to be performed and is redundant to the general rules of the TS. As such, this change is considerw administrative made to conform with the presentation and format of the STS.

10 L The CTS surveillance frequencies 4.2.4.1.a and b are revised consistent l

with the STS. The format is modified to conform with the presentation of the information in the STS. The CTS surveillance frequency requires QPTR to be calculated every 12 hours1.388889e-4 days <br />0.00333 hours <br />1.984127e-5 weeks <br />4.566e-6 months <br /> during steady state operation when -

the alarm is inoperable. The corresponding STS surveillance frequency does not specify a separate frequency when the alarm is inoperable. The 7 Chapter 3.2 E2-6-D March,1998

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FNP TS Conversion l Enclosure 2 - Discussion of Changes to CTS Chapter 3.2 - Power Distribution Limits CTS 3/4.2.4 QUADRANT POWER TILT RATIO FNP ITS 3.2.4 QUADRANT POWER TILT RATIO (QPTR) )

DOC HQ SHE DISCUSSION day frequency of CTS 4.2.4.1.a is applicable whenever the LCO is applicable. The alarm itselfis not directly related to the LCO limit but is one of many indicators that are available to the operator. The additional CTS requirement (12 hour1.388889e-4 days <br />0.00333 hours <br />1.984127e-5 weeks <br />4.566e-6 months <br /> frequency when the alarm is inoperable) is deleted consistent with the STS. The frequency of 7 days takes into account other information and alarms available to the operator in the control l room.  !

11 A The CTS surveillance 4.2.4.2 is revised to conform to the STS and accurately reflect the manner in which the surveillance is actually performed. The CTS surveillance addresses the verification of QPTR when one power range channel is inoperable and power is greater than 75%. In  ;

this condition, the CTS requires that QPTR be verified by the use ofincore  !

instrumentation. The incore detectors do not actually measure QPTR. The INCORE code determines power tilts instead of QPTR, and, in fact, QPTR can be 1.00 with power tilts in excess of 1.00. Therefore, surveillance 4.2.4.2 is actually performed to confirm the accuracy of the excore QPTR measurement by confirming that the normalized symmetric power l distribution (as determined using the incore detectors) is consistent with the QPTR as indicated by the excore detectors as stated in the detailed discussion of the surveillance in the FNP CTS. As such, this more accurate description of the surveillance is converted into the FNP ITS statement of SR 3.2.4.2 and the additional detail is moved to the Bases as discussed in DOC 12-LA. The CTS requirement that this surveillance be performed above 75% power with one power range channel inoperable is moved into a note within the STS SR. The CTS requirement is further modified within the STS to clarify that this surveillance is also applicable when more than one power range instrument channel is inoperable. As the incore instrumentation provides an inherently more accurate indication of core power distribution than QPTR, it is always acceptable to use the incere instrumentation in lieu of the excore channels. In addition, the STS l

surveillance note further clarifies the statement of excore channel operability by qualifying that the " input" from one or more power range instrument channels is inoperable. The STS uses the term " input" to acknowledge that the power range instrumentation may become inoperable but still provide a valid signal to the QPTR circuitry. An example of this would be if the power range neutron flux high trip function output histable L

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N FNP TS Conversion Enclosure 2 - Discussion of Changes to CTS l Chapter 3.3 - Instrumentation CTS 2.2 LIMITING SAFETY SYSTEM SETTINGS CTS 3/4.3.1 REACTOR TRIP SYSTEM INSTRUMENTATION l

FNP ITS 3.3.1 REACTOR TRIP SYSTEM (RTS) INSTRUMENTATION l

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!. Actuation Logic Test requirement increases the frequency specified in the i TS for verifying the interlock logic, this change is considered more restrictive.

l i: 15c LA CTS surveillance requirement 4.3.1.3 is revised consistent with the STS.

. This CTS surveillance contains the RTS Response Time Testing l requirements for the RTS functions. CTS 4.3.1.3 requires that each RTS function be tested on a Staggered Test Basis. The requirement to apply the l Staggered Test Basis and the associated 18 month frequency is explained in

( detail within the CTS surveillance. The corresponding STS surveillance simply specifies Response Time Testing be performed every 18 months on a Staggered Test Basis. The detailed explanation within the CTS surveillance is effectively included in the bases of the corresponding STS surveillance. This CTS surveillance corresponds to the FNP ITS surveillance SR 3.3.1.14. The STS bases explains the required testing in terms of the channels and end actuating devices (RTBs or trains) required to be tested. This STS bases explanation encompasses the description of the required testing contained in CTS 4.3.1.3. The STS and FNP ITS SR 3.3.1.14 do not introduce a technical change to the response time testing requirements of the CTS. Reliance on the information contained in the STS bases for system operability requirements and guidance for performing surveillance requirements is acceptable since changes to the information in the bases is controlled by the Bases Control Program specified in the administrative controls section of the TS.

16 A The title of the " Total Number of Channels" column in CTS Table 3.3-1 is revised to be " Required Channels" consistent with the columns of the corresponding STS Table 3.3.1-1. This change conforms to the STS and is intended to be an administrative change. The new ITS Conditions assigned to each Instrument Function will specify the appropriate action when one or more " Required" instrument channels are inoperable. Any technical 1

differences between the CTS Actions and the STS Actions are discussed in the changes to the Actions of the CTS. Therefore, this change is considered administrative and is made to conform with the STS.

Chapter 3.3 E,2-9-A MP ch,1998

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FNP TS Conversion l Enclosure 2 - Discussion of Changes to CTS Chapter 3.3 - Instrumentation

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l CTS 2.2 LIMITING SAFETY SYSTEM SETTINGS CTS 3/4.3.1 REACTOR TRIP SYSTEM INSTRUMENTATION FNP ITS 3.3.1 REACTOR TRIP SYSTEM (RTS) INSTRUMENTATION lt DOC NO SHE DISCUSSION The third STS Condition J is applicable to both Mode 2 below P-6 and Modes 3,4, and 5 with RTBs closed and the rod drive control system capable of withdrawal. STS Condition J provides the required action when both required source range channels are inoperable. Condition J requires the RTBs be opened immediately. There is no corresponding Action in the CTS for two inoperable source range channels and Specification 3.0.3 may be applied. However, Specification 3.0.3 would allow up to I hour before any action is required to reduce power or change Modes. The immediate i Action required by STS Condition J is more appropriate since this condition represents a loss of both trip and monitoring functions when they I are relied on to mitigate events.

The three STS Conditions added for the source range instrumentation discussed above although applicable and appropriate for FNP contain more limiting, more comprehensive, or more immediate Actions than the CTS and are considered more restrictive changes.

I 32 M The CTS Action statement 5, applicable to the source range instrumentation j in Modes 3,4, and 5 with the RTDs open, is revised consistent with the i corresponding STS Condition L. In this mode of applicability, a single l channel of source range instrumentation is required operable to perform l monitoring functions. The STS Required Channel specifies the same i number of channels as the CTS minimum channels operable requirement

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for this function in these Modes. Therefore, reference to the minimum <

channels operable requirement in this Action statement is no longer necessary (all STS Actions key off the Required Channels) and is deleted.

If the required channel becomes inoperable the CTS requires that SDM be verified within one hour and every 12 hours1.388889e-4 days <br />0.00333 hours <br />1.984127e-5 weeks <br />4.566e-6 months <br /> thereafter. The CTS action provides an alternate method to monitor core reactivity in this Mode. The corresponding STS Condition L revises the reference to verifying SDM to l {

! performing the SDM verification surveillance (SR 3.1.1.1) and adds the '

following Actions to the STS requirements: Suspend positive reactivity additions immediately and close unborated water source isolation valves in one hour. The additional STS Actions go beyond monitoring the core reactivity and provide assurance that the core reactivity remains stable. The Chapter 3.3 E2-19-A March,1998 L---____---_--___---__------_____ J

H$ l FNP TS Conversion Enclosure 2 - Discussion of Changes to CTS 'i Chapter 3.3 - Instrumentation I CTS 2.2 LIMITING SAFETY SYSTEM SETTINGS CTS 3/4.3.1 REACTOR TRIP SYSTEM INSTRUMENTATION FNP ITS 3.3.1 REACTOR TRIP SYSTEM (RTS) INSTRUMENTATION DOC

- N_Q .SHE DISCUSSION 81 A The CTS RTS functions on Table 4.3-1 are revised to correspond to the presentation of these functions on the integrated STS Table 3.3.1-1 ' Any technical changes to the individual itTS functions are discussed separately.

- This change is made solely to conform with the presentation and format of this information in the STS and is not intended to introduce any technical changes. Therefore, this change is considered administrative.

82 L The 2 CTS CFT surveillance for the Manual Reactor Trip function on CTS Table 4.3-1 are revised consistent with the STS. The CTS CFTs for this function are required to be performed at refueling intervals and once before startup if not performed in the previous 7 days (CTS note 1). The CTS surveillance specified for this RTS function are replaced with a single STS surveillance SR 3.3.1.14. STS SR 3.3.1.14 is a Trip Actuating Device Operational Test (TADOT) required to be performed every 18 months. The TADOT is an STS defined test (STS section 1.0) that is one of the surveillance used to replace the CTS CFT surveillance. The introduction of the different STS surveillance tests and the differences from the CTS surveillance are identified and discussed in the markups and DOCS associated with Section 1.0. The STS surveil!ance SR 3.3.1.14 for the

- manual reactor trip function effectively replaces the CTS CFT required at refueling intervals without introducing a technical change to that CTS requirement. ~ All testing required under the CTS for this function is incorporated into the single STS surveillance SR 3.3.1.14. However, the STS surveillance requirements for this function eliminate the CTS requirement to perform a CFT prior to startup. In the STS, all required testing of this RTS function is accomplished during one test performed every 18 months. The STS reduces the frequency of the required testing not the type of testing required. The elimination of the requirement to re-  !

perform the CFT prior to each startup is acceptable based on the remaining g requirement to perform this testing every 18 months which provides i adequate assurance of operability and the known reliability and simplicity of manually actuated functions. In addition, the elimination of this surveillance requirement which must be repeated prior to each startup reduces the number of RTB and bypass breaker cycles (wear) while having j l

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11 1 FNP T S Conversion l Enclosure 2 - Discussion of Changes to CTS l Chapter 3.3 - Instrumentation l CTS 2.2 LIMITING SAFETY SYSTEM SETTINGS CTS 3/4.3.1 REACTOR TRIP SYSTEM INSTRUMENTATION 1

FNP ITS 3.3.1 REACTOR TRIP SYSTEM (RTS) INSTRUMENTATION DOC NO SHE DISCUSSION 85a M The Channel Calibration requirement for the neutro: flux rate trip and )

overpower and overtemperature delta T trip functions is revised consistent with the STS to include a note that requires time constants to be verified l

j within the prescribed tolerance. Each of these functions have time constants specified within their respective setpoints. The addition of this STS surveillance note specifically addresses these time constants and ensures the time constants are maintained within the specified tolerance. Although the CTS Channel Calibration requirement does not specifically address the time constants associated with these RTS functions, the addition of this STS note  !

is applicable to and appropriate for the FNP RTS functions with time constants specified in their setpoints. As this change represents an additional requirement to the CTS, it is considered a more restrictive i change. I 86 I- The CTS power, intermediate, and source range neutron flux trip setpoint CFT surveillance which are required prior to each reactor startup if not performed within the last 31 days (note 10) are revised consistent with the corresponding STS SR 3.3.1.8. The surveillance is revised to be an STS COT and the 31 day allowance provided by CTS note 10 is revised to 92 days consistent with the frequency of the corresponding STS surveillance SR 3.3.1.8. The COT must be performed prior to each reactor startup (Mode 2) to verify the neutron flux trip setpoints are operable during power ascension (to 10% RTP) when the affected neutron flux trip functions are relied on to provide the required protection. The type of testing required remains unchanged, and any differences between the CTS CFT and the STS COT are discussed in the DOCS associated with STS section 1.0, l ' Definitions". The proposed allowance (92 days) for performing this surveillance prior to reactor startup is consistent with the required frequency for most other COTS performed on the RTS functions. Since most RTS and ESFAS functions are considered operable between the required quarterly COTS, including the power range neutron flux channels  :

in Mode 1, the allowance of 92 days for the performance of a COT prior to startup is also acceptable for the power, intermediate, and source range neutron flux trip instrument functions affected by this change. Once the required COT has been performed within 92 days of startup, the neutron Chapter 3.3 E2-54-A March,1998 I _

l 130 l FNP TS Conversion Enclosure 2 - Discussion of Changes to CTS Chapter 3.3 - Instrumentation CTS 2.2 LIMITING SAFETY SYSTEM SETTINGS CTS 3/4.3.1 REACTOR TRIP SYSTEM INSTRUMENTATION FNP ITS 3.3.1 REACTOR TRIP SYSTEM (RTS) INSTRUMENTATION DOC NO SHE DISCUSSION which states that verification of setpoint is not required. The inclusion of this note is consistent with the design of the RCP breaker position actuation of reactor trip in that there is no setpoint associated with this actuation circuitry. The RCP breakers simply actuate contacts open or closed. The inclusion of the STS note, which states no setpoint verification is required, is consistent with the way this surveillance is currently implemented at FNP which is dictated by the system design. Therefore, the addition of this STS note does not result in a technical change to the CTS requirements. As such, the changes discussed above are considcred administrative.

97 LA The CTS Table 4.3-1 note 8 modifying the CFT requirement for the RTS interlocks is revised consistent with the presentation of such information in the STS. CTS note 8 contains descriptive information applicable to the required interlock testing. CTS note 8 describes the required testing as

" Logic only". As the individual RTS instrument channels that comprise each interlock function are assigned specific COT and channel calibration requirements in the RTS LCO, it is appropriate that the required interlock COT consist only of a verification of the interlock logic. Therefore, the CTS " logic only" requirement described in note 8 on RTS Table 4.3-1 is moved into the bases discussion for the COT test of the RTS interlock functions. The placement of the details describing this surveillance in the bases effectively retains the CTS requirements for this surveillance (to verify the interlock logic only) and is consistent with the general philosophy of the STS concerning the location of such detail in the bases.

Reliance on the information contained in the bases for guidance in performing surveillance testing is acceptable since changes to the information in the bases is controlled by the Bases Control Program specified in the administrative controls section of the TS.

98 L The CTS Table 4.3-1 CFT requirement for the RTS interlocks is revised consistent with the STS. The CTS CFT for the RTS interlock functions as modified by note 8 is required to be performed prior to reactor startup if not I performed in the previous 92 days. The CTS requirement is revised L consistent with the corresponding STS COT for these functions. The STS l COT is only required to be performed every 18 months instead of the CTS f

Chapter 3.3 E2-65-A March,1998

13 i FNP TS Conversion Enclosure 2 - Discussion of Changes to CTS Chapter 3.3 - Instrumentation CTS 2.2 LIMITING SAFETY SYSTEM SETTINGS CTS 3/4.3.1 REACTOR TRIP SYSTEM INSTRUMENTATION FNP ITS 3.3.1 REACTOR TRIP SYSTEM (RTS) INSTRUMENTATION DOC NQ SHE DISCUSSION requirement of prior to each reactor startup which may be more frequent than every 18 months. Considering that the individual instrument channels that input to interlock functions are assigned separate quarterly COTS,18 month Channel Calibrations, as well as more frequent channel checks and that the interlocks are logic or relay functions not subject to setpoint drift or other similar setpoint inaccuracies that are applicable to process instrumentation, the STS allowance to verify the interlock function once per 18 months is reasonable and acceptable for FNP. The operability of the FNP RTS instrument channels and interlocks continues to be adequately verified by the STS surveillance requirements. Therefore, this change is acceptable.

99 LA The CTS CFT surveillance assigned to the RTB function on Table 4.3-1 is revised consistent with the STS. The CTS surveillance notes 14 and 15 which describe the testing required by this CFT are moved to the bases for the corresponding STS surveillance. The CTS details of the undervoltage and shunt trip mechanism tests that are required for the RTBs complement and enhance the existing STS bases discussion for this surveillance. The placement of the details describing this surveillance in the bases effcetively retains the CTS requirements for this surveillance and is consistent with the general philosophy of the STS concerning the location of such detail in the bases. Reliance on the information contained in the bases for guidance in performing surveillance testing is acceptable since changes to the information in the bases is controlled by the Bases Control Program specified in the administrative controls section of the TS.

100 A The CTS CFT and associated surveillance note 5 assigned to the RTB function on CTS Table 4.3-1 are revised to a TADOT and formatted consistent with the STS. The TADOT is an STS defined test (STS section 1.0) that is one of the surveillance used to replace the CTS CFT surveillance. The introduction of the different STS surveillance tests and the differences from the CTS surveillance are identified and discussed in the markups and DOCS associated with Section 1.0. The conversion of this CTS CFT into the STS TADOT does not reduce the CTS surveillance requirements for this function. The TADOT surveillance continues to Chapter 3.3 E2-66-A March,1998

l38 FNP TS Conversion Enclosure 2 - Discussion of Changes to CTS Chapter 3.3 - Instrumentation CTS 2.2 LIMITING SAFETY SYSTEM SETTINGS CTS 3/4.3.1 REACTOR TRIP SYSTEM INSTRUMENTATION FNP iTS 3.3.1 REACTOR TRIP SYSTEM (RTS) INSTRUMENTATION DOC NO SHE DISCUSSION specific guidance such as the subject STS note. However, the CTS RTS LCO Action requirements are identified with individual Instrument Functions listed in the TS and clearly may be applied individually and separately for each instrument Function. In the absence of any guidance to the contrary, the only reasonable way to apply the CTS RTS Action requirements to multiple instrument functions is in a manner similar to ihat prescribed in the STS. As such, the addition of this STS note providing guidance for the application of Action Conditions is considered a clarification that is consistent with the use and application of the CTS and not a technical change to the CTS. Therefore, this change is considered administrative and is made to confonn with the presentation and format of this information in the STS.

109 M The CTS RTS monthly Channel Calibration assigned to the power range neutron flux channels is revised consistent with the corresponding STS RTS SR 3.3.1.3. The CTS note 3 on Table 4.3-1 is revised by the addition of requirements which modify the required performance of the surveillance.

The addition is in the form of a standard format STS note which specifies a time limit and power level at which the surveillance becomes due.

Although not specified in the CTS, this additional requirement further defines the specified frequency for this surveillance consistent with the vendor recommendations for performing this calibration and ensures a timely performance of this requirement. Therefore, the additional requirements imposed by the STS are appropriate and applicable for FNP.

As the inclusion of this STS note adds requirements not currently specified in the CTS, this change is considered more restrictive.

I10 M The CTS RTS daily channel calibration assigned to the power range neutron flux channels is revised consistent with the corresponding STS RTS SR 3.3.1.2. This CTS surveillance recnires the power range channels to be adjusted consistent with a calorimetric heat balance on a daily basis when power is 215% RTP. The CTS note 2 on Table 4.3-1 which modifies the

! CTS surveillance is revised to include a time limit in addition to the l

currently required power limit. The addition of a time limit for the l performance of this surveillance after reaching 15% power is consistent Chapter 3.3 E2-73-A March,1998 l

I

/d FNP TS Conversion Enclosure 2 - Discussion of Changes to CTS Chapter 3.3 - Instrumentation CTS 3/4.3.2 ENGINEERED SAFETY FEATURE ACTUATION SYSTEM INSTRUMENTATION FNP ITS 3.3.2 ENGINEERED SAFETY FEATURE ACTUATION SYSTEM INSTRUMENTATION (ESFAS)

FNP ITS 3.3.5 LOSS OF POWER (LOP) DIESEL GENERATOR (DG) START INSTRUMENTATION FNP ITS 3.3.6 CONTAINMENT PURGE AND EXHAUST ISOLATION INSTRUMENTATION DOC NO SHE DISCUSSION 5 A The CTS 3/4.3.2 Actions are revised by the addition of a note which afTects all Actions consistent with the STS. The STS note states that " Separate Condition entry is allowed for each Function". The STS note provides a clarification regarding the procedure for entering Actions Conditions in the STS. The STS note is described in Section 1.0 of the STS which provides guidance in the use and application of the STS. The note is required by the STS format conventions to allow each Actions Condition to be applied as necessary to an inoperable instrumentation Function listed on STS Table 3.3.2-1. The format conventions applicable to the CTS do not include specific guidance such as the subject STS note. However, the CTS ESFAS LCO Action requirements are identified with individual Instrument l Functions listed in the TS and clearly may be applied individually and separately for each instrument Function. In the absence of any guidance to the contrary, the only reasonable way to apply the CTS ESFAS Action requirements to multiple instrument functions is in a manner similar to that prescribed in the STS. As such, the addition of this STS note providing guidance for the application of Action Conditions is considered a clarification that is consistent with the use and application of the CTS and not a technical change to the CTS. Therefore, this change is considered I

administrative and is made to conform with the presentation and format of this infonnation in the STS.

6 A The title of the " Total Number of Channels" column in CTS ESFAS Table 3.3-3 is revised to be " Required Channels" consistent with the columns of the corresponding STS Table 3.3.2-1. This change conforms to the STS and is intended to be an administrative change. The new ITS Conditions assigned to each Instrument Function will specify the appropriate action when one or more " Required" instrument channels are inoperable. Any technical differences between the CTS Actions and the STS Actions are i

Chapter 3.3 E2-5-B March,1998 i _ _ _ _ _ _ _ _ _ _ _ _ _ _ _ _ _ _ A

/Y8 FNP TS Conversion Enclosure 2 - Discussion of Changes to CTS Chapter 3.3 - Instrumentation CTS 3/4.3.2 ENGINEERED SAFETY FEATURE ACTUATION SYSTEM INSTRUMENTATION FNP ITS 3.3.2 ENGINEERED SAFETY FEATURE ACTUATION SYSTEM INSTRUMENTATION (ESFAS)

FNP ITS 3.3.5 LOSS OF POWER (LOP) DIESEL GENERATOR (DG) START INSTRUMENTATION FNP ITS 3.3.6 CONTAINMENT PURGE AND EXHAUST ISOLATION INSTRUMENTATION DOC

?LQ SHE DISCUSSION discussed in the changes to the Actions of the CTS. Therefore, this change is considered administrative and is made to conform with the STS.

I 7 A CTS ESFAS Table 3.3-3 is revised consistent with the STS to include all I

applicable information for each ESFAS function. The conversion of the I CTS Table into the integrated STS Table is intended to be a change in the format and presentation of this information. Any technical changes

resulting from the reformat of this information are addressed in the DOCS l associated with the individual changes made to the CTS requirements identified throughout the markup of CTS 3.3.2. Therefore, the reformat of I

this CTS information to conform with the STS presentation is considered an l

administrative change. l 8 A CTS Table 3.3-3 is revised to incorporate a clarification to the Applicable Modes column. The phrase "or other specified conditions" is added to the l Applicable Modes column title. This change conforms with the STS and is intended to cover the notes used to modify the Modes listed in this column.

Since the notes which modify the Modes in this Table create "other I conditions" in addition to the Modes defined in STS Section 1.0, this change provides a more appropriate column title that remains consistent with the intent of the CTS. As such this change is considered administrative and is made to conform with the STS.

9 A CTS ESFAS Table 3.3-3 is revised to incorporate an additional column for the surveillance requirements associated with each function listed on the table. The addition of this column is consistent with the format and presentation of the corresponding Table 3.3.2-1 in the STS. In the STS, only one Instrument Table is provided. The integrated STS Table 3.3.2-1 contains all the information for each instrument function. The details of changes made to the CTS surveillance and any technical differences Chapter 3.3 E2-6-B March,1998 i

{. /Y7 FNP TS Conversion g Enclosure 2 - Discussion of Changes to CTS Chapter 3.3 - Instrumentation CTS 3/4.3.2 ENGINEERED SAFETY FEATURE ACTUATION SYSTEM -

l INSTRUMENTATION FNP ITS 3.3.2 ENGINEERED SAFETY FEATURE ACTUATION SYSTEM INSTRUMENTATION (ESFAS)

FNP ITS 3.3.5 LOSS OF POWER (LOP) DIESEL GENERATOR (DG) START l INSTRUMENTATION FNP ITS 3.3.6 CONTAINMENT PURGE AND EXHAUST ISOLATION jj INSTRUMENTATION

DOC

_N_Q SHE DISCUSSION with the format of this information in the STS and are considered l administrative.

12 LA The Channels To Trip column of CTS ESFAS Table 3.3-3 is deleted L consistent with the STS. The corresponding STS ESFAS Table 3.3.2-1

i. does not include this information. The Channels To Trip column on CTS l l Table 3.3-3 contains information describing the ESFAS design features. {'

L This descriptive information provides pertinent system information but is not an essential requirement of the ESFAS LCO. The ESFAS design features are detailed in the FSAR (7.3) and other FNP design description documentation including the TS bases. The requirements for the ESFAS j design are controlled by the required industry standards (IEEE 279,'etc.),

L- federal regulations (General Design Criteria), and specific NRC requirements and guidelines pertaining to the ESFAS. Changes to the plant design are controlled in accordance with the Quality Control Programs in l place which are also required by federal regulations (10 CFR 50.54). In I

addition, changes to the plant design as described in the FSAR are subject l to the review requirements of 10 CFR 50.59. Adequate control of the ESFAS " channels to trip" design exists outside of the technical

specifications. Therefore, removing this information from the technical specifications does not significantly decrease the level of control on this l plant design feature.

13 A ' The Minimum Channels Operable column of CTS ESFAS Table 3.3-3 is deleted consistent with the STS. The corresponding STS ESFAS Table 3.3.2-1 does not include this information. The STS simplifies the presentation of the number of channels necessary for each function on the ESFAS Table in a single column which is titled Required Channels. All Actions for an inoperable instrument channel in the STS key off the Required Channels specified for the affected function. The replacement of

. Chapter 3.3 - E2-8-B March,1998

/55

FNP TS Conversion Enclosure 2 - Discussion of Changes to CTS Chapter 3.3 - Instrumentation CTS 3/4.3.2 ENGINEERED SAFETY FEATURE ACTUATION SYSTEM INSTRUMENTATION FNP ITS 3.3.2 ENGINEERED SAFETY FEATURE ACTUATION SYSTEM INSTRUMENTATION (ESFAS)

FNP ITS 3.3.5 LOSS OF POWER (LOP) DIESEL GENERATOR (DG) START INSTRUMENTATION FNP ITS 3.3.6 CONTAINMENT PURGE AND EXHAUST ISOLATION INSTRUMENTATION DOC NQ SHE DISCUSSION consistent with the STS. The CTS lists this function twice as CTS function 5.a and CTS function 8.c. The CTS listing for function 8.c only refers to function 5.a and does not contain any additional requirements. Therefore, consistent with the presentation of this information in the STS, the P-14 interlock designation is moved to CTS function 5.a and the existing CTS function 8.c which only referenced function 5.a is deleted. This reformat of the CTS does not introduce a technical change to the CTS and is consistent with the STS presentation of this information. Therefore, this change is considered administrative.

27 A The CTS turbine trip and feedwater isolation function is revised by the addition of safety injection to the initiating functions consistent with the STS. The addition of a separate line item for the safety injection initiation of turbine trip and feedwater isolation is consistent with the FNP design and provides a more complete list ofinitiating functions. The addition of safety injection as an initiating function serves only to provide a complete list of initiating functions and to clarify the relationship of safety injection to the automatic actuation of the turbine trip and feedwater isolation function.

The applicable requirements for safety injection are all addressed under the safety injection function and no additional or new requirements are implied or expressed by the inclusion of safety injection under the turbine trip and  ;

feedwater isolation function. Therefore, the addition of this function to the initiating functions is considered administrative and is made to conform with the presentation and format of this information in the STS.

28 L The CTS applicability for the SG water level high-high initiating function

' for turbine trip and feedwater isolation is revised consistent with the STS and the FNP design. The CTS requires this instrumentation operable in Mode 2 regardless of the status of the feedwater lines (isolated or i

Chapter 3.3 E2-16-B March,1998 l

4

/69 FNP TS Conversion Enclosure 2 - Discussion of Changes to CTS Chapter 3.3 - Instrumentation CTS 3/4.3.2 ENGINEERED SAFETY FEATURE ACTUATION SYSTEM INSTRUMENTATION FNP ITS 3.3.2 ENGINEERED SAFETY FEATURE ACTUATION SYSTEM INSTRUMENTATION (ESFAS) l FNP ITS 3.3.5 LOSS OF POWER (LOP) DIESEL GENERATOR (DG) START l INSTRUMENTATION j FNP ITS 3.3.6 CONTAINMENT PURGE AND EXHAUST ISOLATION INSTRUMENTATION l DOC BLQ SHE DISCUSSION of operable RCS loops (RCPs) required in any given Mode of operation.

The deletion of this information from the instrumentation TS does not reduce the requirements placed on the number of operable RCPs or the RCP l electrical supply busses or the undervoltage instrumentation on those l

busses. This change does not introduce a technical change to the CTS and l only alters the presentation of this requirement to conform with the STS.

Therefore, this change is considered administrative.

33 LA The CTS ESFAS auxiliary feedwater auto start on SI and trip of main feedwater pump functions are revised consistent with the STS. The CTS functions include descriptive information regarding the specific auxiliary '

feedwater pumps that ace started. The information describing the start of the motor-driven auxiliary feedwater pumps is moved to the bases for both these functions consistent with the presentation of this information in the STS. The requirements for this instrumentation to be operable remain in the TS. Only the description of the pumps actuated is moved to the bases.

This change does not introduce a technical change to the CTS requirements for this instrumentation. The placement of descriptive details in the bases is consistent with the philosophy of the STS, and in this case, also conforms with the presentation of this information in the STS. Reliance on the information contained in the STS bases for system operability requirements and design information is acceptable since changes to the information in the bases is controlled by the Bases Control Program specified in the administrative controls section of the TS.

34 M The CTS auxiliary feedwater start requirement on trip of the main feedwater i pumps is revised consistent with the STS format of this information and the FNP design. This CTS ESFAS function consists of two channels on each main feedwater pump. Each channel senses a stop valve (LP and HP)

Chapter 3.3 E2-20-B March,1998

/40 FNP TS Conversion -

Enclosure 2 - Discussion of Changes to CTS Chapter 3.3 -Instrumentation

, CTS 3/4.3.2 ENGINEERED SAFETY FEATURE ACTUATION SYSTEM

. INSTRUMENTATION FNP ITS 3.3.2 ENGINEERED SAFETY FEATURE ACTUATION SYSTEM INSTRUMENTATION (ESFAS)

' FNP ITS 3.3.5 LO' SS OF POWER (LOP) DIESEL GENERATOR (DG) START INSTRUMENTATION FNP ITS 3.3.6 CONTAINMENT PURGE AND EXHAUST ISOLATION INSTRUMENTATION DOC

_N_Q SHE DISCUSSION position on the main feedwater pump steam turbines. Each valve position limit switch operates a separate contact necessary to auto start the auxiliary feedwater pumps. The stop valves on both main feedwater pumps must be closed in order to generate an auxiliary feedwater pump auto start. The auto start of each auxiliary feedwater pump requires that 4 separate contacts close (one from each turbine stop valve). The FNP design requires that 2 channels per pump be operable in order to actuate the auxiliary feedwater pumps. A failure of any one of the 4 total channels could prevent the

. auxiliary feedwater pump start. Considering the auxiliary feedwater pump auto start on trip of all main feedwater pumps is nct credited in any safety analyses, the number of other auxiliary feedwater pump auto start functions available, and the anticipatory (backup) nature of this trip, the FNP design of the trip of all main feedwater pumps function is acceptable. However, the applicable CTS action (#23) for this ESFAS function is based on "with ,

less than the minimum channels operable" or 1 channel per pump and not j on less than the total channels operable (2 per pump). Typically, the  !

number ofITS required channels is equal to the number of channels upon i which the Actions are based (in this case I channel per pump). This minimum channels operable and Action relationship in the CTS results in i no required Action applicable when a single channel per main feedwater i pump is inoperable. Thus, the CTS Action statement # 23 is only I l

applicable when no operable channels exist on a main feedwater pump. As the auxiliary feedwater pump auto start function is inoperable with the loss

! of any channel, the CTS Action effectively allows a loss of this function without requiring any action be taken. In order to assure the function remains operable or an Action is applicable, the required channels specified l in the FNP ITS and on which the Action is based is increased to 2 channels per pump instead of the CTS 1 channel per pump. Therefore, the FNP ITS  !

Requ! red Channels for this function is made consistent with the FNP design Chapter 3.3 E2-21-B March,1998 E .

/fo2 FNP TS Conversion Enclosure 2 - Discussion of Changes to CTS Chapter 3.3 - Instrumentation CTS 3/4.3.2 ENGINEERED SAFETY FEATU'RE ACTUATION SYSTEM INSTRUMENTATION FNP ITS 3.3.2 ENGINEERED SAFETY FEATURE ACTUATION SYSTEM INSTRUMENTATION (ESFAS)

FNP ITS 3.3.5 LOSS OF POWER (LOP) DIESEL GENERATOR (DG) START INSTRUMENTATION FNP ITS 3.3.6 CONTAINMENT PURGE AND EXHAUST ISOLATION INSTRUMENTATION DOC-

_N_Q SHE DISCUSSION which is the number of channels upon which the CTS and STS Actions are based. This change is also one of terminology and presentation, the number .

of channels upon which the Action is based remains unchanged. The use of required channels in the STS effectively replaces the CTS use of total channels without introducing a technical change to CTS Action requirements for these functions. Similarly, the CTS phrase "and the rninimum channels operable requirement is met"is not required in the STS and has also been deleted. This CTS phrase precedes the allowance to place an additional channel in bypass for surveillance testing of another channel and ensures sufficient channels are operable to allow another channel to be bypassed without losing the function provided by this ESFAS instrumentation. In the STS, the Conditions are structured such that only one channel of a function may be inoperable in each Action Condition (One u channel inoperable). The STS Action Condition and the STS rules of usage are structured to ensure the minimum channels required remain operable. If more than one channel per function becomes inoperable and no Actions Condition exists to address this situation, LCO 3.0.3 must be entered as that ESFAS instrument function may be lost. Therefore, the CTS statement requiring the minimum channels operable as a condition to bypass another channel is not required in the STS. In addition, the CTS Action contains R the phrase " operation may proceed provided ..." which preceded the Action requirements. This CTS phrase is not used in the STS and is deleted from the CTS. In the STS, once the action is met, operation may always proceed (unless the Actions state otherwise). This particular Action allows operation to continue once the channel is placed in bypass and therefore, the general rules of usage in the STS will allow Mode changes to be made when this Action is applicable. Thus, the CTS phrase serves no purpose in the STS and its deletion does not introduce a technical change to the requirements of the _TS. Additionally, the CTS Action is revised by the

.. Chapter 3.3 E2-29-B March,1998 i

i

/75 FNP TS Conversion Enclosure 2 - Discussion of Changes to CTS Chapter 3.3 - Instrumentation CTS 3/4.3.2 ENGINEERED SAFETY FEATURE ACTUATION SYSTEM

. INSTRUMENTATION FNP ITS 3.3.2 ENGINEERED SAFETY FEATURE ACTUATION SYSTEM INSTRUMENTATION (ESFAS)

FNP ITS 3.3.5 LOSS OF POWER (LOP) DIESEL GENERATOR (DG) START INSTRUMENTATION FNP ITS 3.3.6 CONTAINMENT PURGE AND EXHAUST ISOLATION INSTRUMENTATION DOC N_Q SHE DISCUSSION channels which is the number of channels upon which the CTS and STS Actions are based. This change is also one of terminology and presentation, the number of channels upon which the Action is based remains unchanged.

. The use of required channels in the STS etTectively replaces the CTS use of total channels without introducing a technical change to CTS Action requirements for these functions. In addition, the CTS Action contains the phrase "startup and/or power operation may proceed provided ..." which preceded the Action requirements. This CTS phrase is not used in the STS and is deleted from the CTS. In the STS, once the action is met, operation may always proceed (unless the Actions state otherwise). This particular Action allows operation to continue once the channel is placed in trip and therefore, the general rules of usage in the STS will allow Mode changes to -

be made when this Action is applicable. Thus, the CTS phrase serves no purpose in the STS and its deletion does not introduce a technical change to the requirements of the TS. Similarly, the CTS phrase "The minimum L; channels operable requirement is met; however" is not required in the STS and has also been deleted. This CTS phrase preceeds the allowance to place a channel in bypass for surveillance testing of another channel and ensures suffici:nt channels are operable to allow the inoperable channel to be bypassed without losing the function provided by this ESFAS instrumentation. In the STS, the Conditions are structured such that typically only one channe'l of a function may be inoperable in each Action Condition (One channel inoperable). The STS Action Condition and the STS rules of usage are structured to ensure the minimum channels required remain operable. If more than one channel per function becomes inoperable ,

I and no Actions Condition exists to address this situation, LCO 3.0.3 must be entered as that ESFAS instrument function may be lost. Therefore, the CTS statement requiring the minimum channels operable as a condition to bypass an inoperable channel is not required in the corresponding STS Chapter 3.3 E2-36-B March,1998

_ _ _ = __ ____________- __________- _-_ _ __ _ __ _ __. .___ ____

FNP TS Conversion Enclosure 2 - Discussion of Changes to CTS Chapter 3.3 - Instrumentation l

1 CTS 3/4.3.2 ENGINEERED SAFETY FEATURE ACTUATION SYSTEM l INSTRUMENTATION ]

t FNP ITS 3.3.2 ENGINEERED SAFETY FEATURE ACTUATION SYSTEM INSTRUMENTATION (ESFAS)

FNP ITS 3.3.5 LOSS OF POWER (LOP) DIESEL GENERATOR (DG) START INSTRUMENTATION FNP ITS 3.3.6 CONTAINMENT PURGE AND EXHAUST ISOLATION INSTRUMENTATION I I

DOC l

.HQ SHE DISCUSSION

. position limit switch operates a separate contact necessary to auto start the auxiliary feedwater pumps. The stop vahres on both main feedwater pumps must be closed in order to generate an auxiliary feedwater pump auto start.

The auto start of each auxiliary feedwater pump requires that 4 separate contacts close (one from each main feedwater pump turbine stop valve).

The FNP design requires that 2 channels per pump be operable in order to actuate the auxiliary feedwater pumps. A failure of any one of the 4 total channels could prevent the auxiliary feedwater pump start. Considering the auxiliary feedwater pump auto start on trip of all main feedwater pumps is not credited in any safety analyses, the number of other auxiliary feedwater pump auto start functions available, and the anticipatory (backup) nature of  ;

this trip, the FNP design of the trip of all main feedwater pumps function is  !

acceptable. The CTS Action statement applicable to this function (#23) is )

based on the minimum channels operable requirement or 1 channel per

- pump. The CTS Action is applicable when one less than the minimum -

channels are operable or no channels are operable on a main feedwater {

pump. The number of required channels in the FNP ITS has been revised as explained in DOC 34 to include all 4 (2 per pump) channels to ensure an 3 Action is applicable as soon as one channel is inoperable. However, when one channel of this ESFAS function is inoperable (can not perform its safety function) this ESFAS function is lost. All 4 channels must be j operable in order for this instrumentation to perform its intended safety J l- function. As such, the proposed FNP ITS Action for this function is revised j to addresses "one or more inoperable channels" on "one or more pumps". j If one inopetable channel results in a loss of this function, a second or third inoperable channel does not result in any further degradation of this ESFAS function and should logically be addressed by the same Actions Condition as a single inoperable channel. The proposed revision of this Action is ,

effectively consistent with the intent of the CTS Action which allowed a f i

l Chapter 3.3 E2-41-B March,1998 I l-j 1

t____ - - _ - - - _ - - . - - - - . . - _ - - _ - - _ - - - - - - - _ _ .- --- - I

19 3 FNP TS Conversion Enclosure 2 - Discussion of Changes to CTS Chapter 3.3 - Instrumentation CTS 3/4.3.2 ENGINEERED SAFETY FEATURE ACTUATION SYSTEM INSTRUMENTATION FNP ITS 3.3.2 ENGINEERED SAFETY FEATURE ACTUATION SYSTEM INSTRUMENTATION (ESFAS)

FNP ITS 3.3.5 LOSS OF POWER (LOP) DIESEL GENERATOR (DG) START INSTRUMENTATION FNP ITS 3.3.6 CONTAINMENT PURGE AND EXHAUST ISOLATION INSTRUMENTAUON DOC NJ_Q SHE DISCUSSION channels in the STS effectively replaces the CTS use of total channels without introducing a technical change to CTS Action requirements for these functions. In addition, the CTS Action contains the phrase "startup and/or power operation may proceed provided ..." which preceded the Action requirements. This CTS phrase is not used in the STS and is deleted from the CTS. In the STS, once the action is met, operation may always proceed (unless the Actions state otherwise). This particular Action allows operation to continue once the channel is placed in trip and therefore, the geneial rules of usage in the STS will allow Mode changes to be made when this Action is applicable. Thus, the CTS phrase serves no purpose in the STS and its deletion does not introduce a technical change to the requirements of the TS. Similarly, the CTS Action 24b phrase "The minimum channels operable requirement is met; however"is not required in the STS a id has also been deleted. This CTS phrase preceeds the allowance to place a channel in bypass for surveillance testing of another channel and ensures sufficient channels are operable to allow the inoperable channel to be bypassed without losing the function provided by this ESFAS instrumentation. In the STS, the Conditions are structured such that only one channel of a function may be inoperable in a typical (One channel inoperable) Action Condition. The STS Action Condition and the STS rules of usage are structured to ensure the minimum channels required remain operable. Ifmore than one channel per function becomes inoperable and no Actions Condition exists to address this situation, LCO 3.0.3 must l

be entered as that ESFAS instrument function may be lost. Therefore, the l CTS statement requiring the minimum channels operable as a condition to bypass an inoperable channel is not required in the corresponding STS ,

Condition which only allows one channel inoperable per bus. . Additionally, j the CTS Action is revised by the deletion of the reference to specification 4.3.2.1. The CTS Action references specification 4.3.2.1 regarding the ,

I l Chapter 3.3 E2-44-B March,1998

177 FNP TS Conversion Enclosure 2 - Discussion of Changes to CTS Chapter 3.3 - Instrumentation CTS 3/4.3.2 ENGINEERED SAFETY FEATURE ACTUATION SYSTEM INSTRUMENTATION FNP ITS 3.3.2 ENGINEERED SAFETY FEATURE ACTUATION SYSTEM INSTRUMENTATION (ESFAS)

FNP ITS 3.3.5 LOSS OF POWER (LOP) DIESEL GENERATOR (DG) START INSTRUMENTATION FNP ITS 3.3.6 CONTAINMENT PURGE AND EXHAUST ISOLATION INSTRUMENTATION DOC EO SHE DISCUSSION requirements on plant operation and are therefore considered a more restrictive change.

62 A CTS Action statement 24 applicable to the loss of voltage and degraded grid voltage ESFAS instrument functions is revised consistent with the format of the STS and with the FNP specific design of the loss of power instrument functions. The Corresponding STS Condition A is written to clearly address these functions on a per train basis. The STS utilizes a "per bus" requirement for these functions. The corresponding FNP design utilizes these functions on a per train basis. Each train containing more than one bus protected by these relay functions. The STS wording (on a "per bus" basis or the FNP equivalent "per train" basis) although not specifically included in the CTS Action statement is implicit in the LCO requirement for these functions. The CTS LCO specifies these functions on a per bus basis (ESFAS Table 3.3-3 Function 7). However, each train of ESF 4.16kV consists of more than one bus and relay protection for the entire train is only installed on one bus in each train. Therefore, the actual design of the FNP LOP is more accurately stated as being on a per train basis. As such, Action statement 24 may be applied on a "per train" basis without changing the technical intent of the CTS requirement. The inclusion of the STS convention "on a per... basis" in the CTS Actions is a clarification of the FNP design and the relationship between the Action and the LCO requirements for these functions. The Action is constructed to

provide an adequate remedial measure for each affected train and the l application of this Action on a "per train" basis ensures the continued safe operation of each affected train. In addition, CTS Action #24 is revised by the addition of references to Function 1 and 2. These FNP specific references replace the corresponding STS Condition A wording of"one or more functions". The STS Condition was written assuming only two Chapter 3.3 E2-49-B March,1998 L ______ ___________. . _ _ _ .

l W9

' FNP TS Conversion {

Enclosure 2 - Discussion of Changes to CTS Chapter 3.3 - Instrumentation 1

CTS 3/4.3.2 ENGINEERED SAFETY FEATURE ACTUATION SYSTEM INSTRUMENTATION I FNP ITS 3.3.2 ENGINEERED SAFETY FEATURE ACTUATION SYSTEM INSTRUMENTATION (ESFAS) i FNP ITS 3.3.5 LOSS OF POWER (LOP) DIESEL GENERATOR (DG) START INSTRUMENTATION l FNP ITS 3.3.6 CONTAINMENT PURGE AND EXHAUST ISOLATION INSTRUMENTATION f

DOC NO SHE DISCUSSION functions are addressed by LCO 3.3.5 and that the Actions of LCO 3.3.5 are applicable to both these functions. However, as discussed in other DOCS, FNP has included a specific degraded grid alarm function in STS LCO 3.3.5. The inclusion of this alarm function in response to an NRC commitment, alters the number of functions and introduces Actions specific to one function. Therefore, the corresponding STS Condition A and CTS Action #24 are altered to clearly identify this Condition with the loss of voltage and degraded grid voltage Functions 1 and 2 on FNP ITS specific

. Table 3.3.5-1. The FNP ITS contains a Table listing the 3 LOP functions and associated requirements. Function 3 is the FNP specific Alarm function which has a separate set of Actions applicable. The changes discussed above revised the CTS Action to be consistent with the format of the STS and to account for the new FNP specific LOP function. These changes do not introduce a technical change to the CTS. Therefore, these changes are considered administrative.

63 A The CTS ESFAS LOP Actions are revised by the addition of a note which affects all Actions consistent with the STS LOP LCO 3.3.5. The STS note states that " Separate Condition entry is allowed for each Function". The STS note provides a clarification regarding the procedure for entering Actions Conditions which are applicable to multiple instrument functions in the STS. The STS note is described in Section 1.0 of the STS which provides guidance in the use and application of the STS. The note is required by the STS format conventions to allow each Actions Condition to be applied as necessary to an inoperable LOP instrumentation Function.

The format conventions applicable to the CTS do not include specific guidance such as the subject STS note. However, the CTS ESFAS LCO Action requirements are identified with individual Instrument Functions listed in the ESFAS TS and c%arly may be applied individually and Chapter 3.3 E2-50-B March,1998 I

l

Mo 1 FNP TS Conversion  !

Enclosure 2 - Discussion of Changes to CTS i Chapter 3.3 - Instrumentation j i

CTS 3/4.3.2 ENGINEERED SAFETY FEATURE ACTUATION SYSTEM INSTRUMENTATION FNP ITS 3.3.2 ENGINEERED SAFETY FEATURE ACTUATION SYSTEM INSTRUMENTATION (ESFAS)

FNP ITS 3.3.5 LOSS OF POWER (LOP) DIESEL GENERATOR (DG) START INSTRUMENTATION FNP ITS 3.3.6 CONTAINMENT PURGE AND EXHAUST ISOLATION INSTRUMENTATION DOC NO SHE DISCUSSION separately for each instrument Function. In the absence of any guidance to the contrary, the only reasonable way to apply the CTS ESFAS Action requirements to multiple instrument functions is in a manner similar to that prescribed in the STS. As such, the addition of this STS note providing guidance for the application of Action Conditions is considered a clarification that is consistent with the use and application of the CTS and not a technical change to the CTS. Therefore, this change is considered administrative and is made to conform with the presentation and format of this information in the STS.

64 A CTS Table 3.3-4 contains the trip setpoints and allowable values associated with the ESFAS functions. Consistent with the STS, the CTS setpoints are moved into the STS integrated Table 3.3.2-1. The STS does not contain a separate Table for trip setpoints. The values for these setpoints are moved essentially unchanged, except where specifically noted by other DOCS, into the corresponding location in the STS Table. Changes to the setpoints or functions associated with the setpoints are discussed in other DOCS. As this change documents the movement of this information within the TS, it is considered an administrative change.

65 M The CTS setpoints for the ESFAS steam line pressure low function are revised consistent with the STS and the actual FNP setpoints. Footnote (c) is added to the setpoint values for this ftmetion. Footnote (c) contains the applicable lead / lag time constants for these setpoints. The time constants are assumed in the FNP safety analyses associated with this ESFAS function. Therefore, consistent with the STS, these time constants are included in the ESFAS TS setpoints. Although, these time constants are l considered part of the required setpoint and their inclusion in the TS completes the setpoint requirement for the associated function, the addition Chapter 3.3 E2-51-B March,1998 i i

_ __________. D

lY FNP TS Conversion Enclosure 2 - Discussion of Changes to CTS Chapter 3.3 - Instrumentation

(

CTS 3/4.3.2 ENGINEERED SAFETY FEATURE ACTUATION SYSTEM INSTRUMENTATION FNP ITS 3.3.2 ENGINEERED SAFETY FEATURE ACTUATION SYSTEM INSTRUMENTATION (ESFAS)

FNP ITS 3.3.5 LOSS OF POWER (LOP) DIESEL GENERATOR (DG) START INSTRUMENTATION FNP ITS 3.3.6 CONTAINMENT PURGE AND EXHAUST ISOLATION l

INSTRUMENTATION DOC MQ SHE DISCUSSION functions and provide a more accurate test description applicable to those functions. The new tests refine the test description applicable to each j function to more closely fit that function. The new STS defined tests were

, introduced and discussed in detail in the Defmition Section of the TS (1.0).

The new STS test definitions by themselves are not intended to introduce technical changes (other than those previously discussed in section 1.0) to the CTS requirements. The individual CTS sun'eillances affected by the introduction of new test titles are discussed separately in the DOC for each affected SR. As any technical changes are also discussed separately, this change only documents the implementation of the various STS surveillance in place of the CTS Channel Functional Test and is considered an administrative change.

75 A The applicable Modes for the surveillance on CTS Table 4.3-2 are deleted.

All changes to the applicable Modes for each ESFAS function are marked-up on CTS Table 3.3-3 and discussed in the DOCS associated with those changes. The changes identified and DOCS for the applicable Modes of each ESFAS function on CTS Table 3.3-3 apply to the applicable Modes listed on Table 4.3-2. As the applicable Modes for each ESFAS function on CTS Table 3.3-1 dictate when the surveillance for each function are required and all changes to Table 3.3-1 have been identified and discussed

previously, the applicable Modes on Table 4.3-1 are simply deleted. As the STS contains only one Table (3.3.2-1) and does not list the functions or applicable Modes twice, this change is made to conform with the format l and presentation of this information in the STS and does not introduce a technical change. Therefore, this change is considered administrative.

76 A The list ofindividual CTS surveillance on Table 4.3-2 is modified consistent with the STS to include the surveillance requirement for a r

Chapter 3.3 E2-56-B March,1998

l%

FNP TS Conversion Enclosure 2 - Discussion of Changes to CTS Chapter 3.3 - Instrumentation CTS 3/4.3.2 ENGINEERED SAFETY FEATURE ACTUATION SYSTEM INSTRUMENTATION FNP ITS 3.3.2 ENGINEERED SAFETY FEATURE ACTUATION SYSTEM INSTRUMENTATION (ESFAS)

FNP ITS 3.3.5 LOSS OF POWER (LOP) DIESEL GENERATOR (DG) START INSTRUMENTATION FNP ITS 3.3.6 CONTAINMENT PURGE AND EXHAUST ISOLATION INSTRUMENTATION DOC NQ SHE DISCUSSION response time test where applicable. Each ESFAS function on Table 4.3-2 for which a response time is identified in FSAR section 7.3 is assigned the 1 corresponding FNP ITS response time surveillance requirement SR 3.3.2.9

{

consistent with the presentation of this information in STS Table 3.3.2-1. '

The STS response time surveillance assigned to each ESFAS function requires the same testing at the same frequency as specified in the CTS. The significant effect of the addition ofindividual response time surveillance requirements is to re-organize the CTS presentation of a few generic surveillance requirements at the beginning of the ESFAS LCO into individual assignments to each ESFAS function on the integrated STS ESFAS function Table 3.3.2-1. The CTS requirement to perform ESFAS l function response time testing relied entirely on the list of response times in the FSAR to identify the functions requiring a response time test. The i assignment of the STS response time surveillance to each FNP ESFAS function is consistent with the response time test requirements identified in the FSAR (7.3) for these ESFAS ftmetions and provides more specific TS guidance consistent with the STS presentation of this information.

Therefore, this change does not alter the CTS requirements and is considered administrative.

77 A The Channel Functional Test (CFT) requirement associated with the manual ESFAS functions on CTS Table 4.3-2 is revised consistent with the STS.

The CTS "R"(defined in CTS Table 1.2 as 18 months) CFT requirement for testing manual ESFAS functions is replaced by FNP ITS SR 3.3.2.6 consistent with the STS. This STS 18 month TADOT surveillance replaces l l

the CTS CFT requirement including the associated footnote (1) which l specified this testing be performed every 18 months. The ESFAS Table I

footnote I which modified this CTS CFT :s no longer required and is deleted. The STS TADOT effectively requires the same level of testing he Chapter 3.3 E2-57-B March,1998

l FNP TS Conversion l

Enclosure 2 - Discussion of Changes to CTS Chapter 3.3 - Instrumentation CTS 3/4.3.2 ENGINEERED SAFETY FEATURE ACTUATION SYSTEM INSTRUMENTATION FNP ITS 3.3.2 ENGINEERED SAFETY FEATURE ACTUATION SYSTEM INSTRUMENTATION (ESFAS)

FNP ITS 3.3.5 LOSS OF POWER (LOP) DIESEL GENERATOR (DG) START INSTRUMENTATION FNP ITS 3.3.6 CONTAINMENT PURGE AND EXHAUST ISOLATION INSTRUMENTATION DOC l NO SHE DISCUSSION restrictive change.

80 A The CTS Channel Check surveillance requirement for the ESFAS functions on Table 4.3-2 is replaced with the STS Channel Check surveillance SR 3.3.2.1. The STS surveillance replaces the CTS requirement without introducing a technical change. The CTS frequency of"S"is defined in the CTS (definition section Table 1.2) as every 12 hours1.388889e-4 days <br />0.00333 hours <br />1.984127e-5 weeks <br />4.566e-6 months <br />. Therefore, the STS SR 3.3.2.1 Channel Check frequency of 12 hours1.388889e-4 days <br />0.00333 hours <br />1.984127e-5 weeks <br />4.566e-6 months <br /> is consistent with the CTS requirement. As the STS SR 3.3.2.1 and the CTS Channel Check surveillance requirements are essentially the same, this change is considered administrative.

81 M The CTS refueling Channel Calibration surveillance requirement for the ESFAS functions on Table 4.3 2 is replaced with the STS 18 month Channel Calibration surveillance FNP ITS SR 3.3.2.7. The specific differences between the CTS and STS Channel Calibration definitions are discussed in the DOCS associated with the changes made to the definition section (1.0) of the TS. The CTS refueling frequency for this surveillance is defined in CTS section 1.0 as every 18 months. Therefore, the frequency requirement for this surveillance remains unchanged. The STS Channel Calibration surveillance includes a note which specifies that the time constants associated with the ESFAS setpoints must also be verified. The addition of this note represents a new TS requirement for FNP. Time constants have been added to CTS ESFAS setpoints consistent with the STS and with the applicable FNP specific safety analyses assumptions. The addition of these time constants is discussed in another DOC. The addition of a specific requirement to verify time constants is reasonable and appropriate for FNP considering the addition of the time con.stant values to l l the CTS ESFAS setpoints. The requirement to verify the time constants l l

l Chapter 3.3 E2-60-B March,1998 4

l l

i Ftriey Nuclear Plant ITS Conversion Submittal - Electronic Copy Revised DOCS l

l Revised DOCS (Section 3.3 - Balance) 1 I.

f E____________.__.____.__. . . _ _ _ _ _ _ _ . _ _ . _ _ _ _ _ . . _ _ _ _

FNP 'IS Conversion L Enclosure 2 - Discussion of Changes to CTS I

Chapter 3.3 - Instrumentation CTS 3/4.3.3.1 RADIATION MONITORING INSTRUMENTATION FNP ITS 3.3.3 POST ACCIDENT MONITORING INSTRUMENTATION FNP ITS 3.3.6 CONTAINMENT PURGE AND EXHAUST ISOLATION INSTRUMENTATION FNP ITS 3.3.7 CREFS ACTUATION INSTRUMENTATION I FNP ITS 3.3.8 PRF ACTUATION INSTRUMENTATION FNP ITS 3.4.15 RCS LEAKAGE DETECTION INSTRUMENTATION DOC NQ SHE DISCUSSION instrumentation, LCO 3.3.7, and STS FBACS (FNP specific PRF) actuation instrumentation, LCO 3.3.8. The CTS 3/4.3.3.1 Actions a and b effectively allow a 4 hour4.62963e-5 days <br />0.00111 hours <br />6.613757e-6 weeks <br />1.522e-6 months <br /> delay to adjust the channel's setpoint before declaring a l

radiation monitoring channel inoperable. In the corresponding STS Actions for these monitors, there is no delay in declaring the affected channel inoperable. The Actions for an inoperable channel are applied immediately.

In addition, the STS Actions do not distinguish the type ofinoperability and are applied whenever the radiation monitor channel is inoperable for any reason. As the applicable STS Actions for these radiation monitors in LCO 3.3.3, LCO 3.4.15, LCO 3.3.7, and LCO 3.3.8 either allow much more time than 4 hours4.62963e-5 days <br />0.00111 hours <br />6.613757e-6 weeks <br />1.522e-6 months <br /> to restore the channel to opersble status or require the periodic performance of some remedial action at an interval which is greater than 4 hours4.62963e-5 days <br />0.00111 hours <br />6.613757e-6 weeks <br />1.522e-6 months <br />, the elimination of the CTS delay period in declaring these radiation monitor channels inoperable has a minimal impact on plant operation.

However, this change eliminates a CTS allowance to delay declaring a required channel inoperable. Therefore, this change is considered more restrictive.

4 A For the radiation monitors in CTS 3/4.3.3.1 associated with actuation of the containment purge and exhaust isolation (R24A&B), Table 3.3-6 monitor 2.b.i.a, which remains within the TS, CTS Actions a and b are effectively retained. The CTS 3/4.3.3.1 Actions a and b allow a 4 hour4.62963e-5 days <br />0.00111 hours <br />6.613757e-6 weeks <br />1.522e-6 months <br /> Action time to adjust the channel's setpoint before declaring the channel inoperable and taking the Action specified in CTS Table 3.3-6. The STS LCO 3.3.6 for the containment purge and exhaust isolation contains a similar 4 hour4.62963e-5 days <br />0.00111 hours <br />6.613757e-6 weeks <br />1.522e-6 months <br /> Action requirement in Condition A, but addresses an inoperable radiation monitor l channel instead of a setpoint outside the limit. In STS LCO 3.3.6, the radiation monitor alarm / trip setpoints being within the specified limit is considered an inherent part of the operability of each monitor and is not Chapter 3.3 E2-3-C March,1998 1

L___._______ _ _ _ . _ _ __ . _ _ . _ . _ _ _ _ _ _ . _ _ . _ _ _ _ _ . _ _ _ _ _ _ _ _ _ _ _ _ _ _ _ _

72_

FNP TS Conversion Enclosure 2 - Discussion of Changes to CTS Chapter 3.3 - Instrumentation CTS 3/4.3.3.1 RADIATION MONITORING INSTRUMENTATION FNP ITS 3.3.3 POST ACCIDENT MONITORING INSTRUMENTATION FNP ITS 3.3.6 CONTAINMENT PURGE AND EXHAUST ISOLATION INSTRUMENTATION FNP ITS 3.3.7 CREFS ACTUATION INSTRUMENTATION FNP ITS 3.3.8 PRF ACTUATION INSTRUMENTATION FNP ITS 3.4.15 RCS LEAKAGE DETECTION INSTRUMENTATION DOC NO SHE DISCUSSION 18 L The CTS 3/4.3.3.1 applicability footnotes g and h used for the control room ,

isolation radiation monitors (R35A&B), the fuel storage pool area radiation j monitors (R25A&B), and the containment purge and exhaust radiation j monitors (R-24A&B) are revised consistent with the STS by the deletion of

" movement of heavy loads over irradiated fuel" from both notes and the j addition of"During Core Alterations" to CTS note h.

The Spent Fuel Storage Pool Building Bridge Crane is the only crane with the potential to move loads over the stored fuel in the spent fuel pool.

However, the fuel storage racks are designed to withstand a bounding load drop without damaging the stored fuel as described in FSAR section 9.1.2.3. Crane operations over the spent fuel pool are prevented from i exceeding the analyzed limit by administrative controls in compliance with j NUREG-0612. The administrative controls required to be implemented by NUREG-0612 and associated NRC Generic letter, as documented in the

~

FNP response to NUREG-0612 and the NRC SER for that response, provide adequate assurance that the operation of the bridge crane will not include lifting loads over stored fuel that have the potential to damage the fuel (also see DOC for relocating the Spent Fuel Storage Pool Building Bridge Crane CTS 3/4.9.7.1). The FNP requirement for administrative controls to prevent movement ofloads, with an impact energy greater than the analyzed limit, over fuel stored in the spent fuel pool is also explicitly stated in the FNP FSAR (last sentence of section 9.1.2.3).

, The movement ofloads over irradiated fuel in containment is addressed by f the development of safe load paths consistent with the guidance provided in

! NUREG-0612 and the addition of the STS applicability of Core Alterations for the affected radiation monitor instrumentation. The movement ofloads f

Chapter 3.3 E2-15-C March,1998

W FNP TS Conversion Enclosure 2 - Discussion of Changes to CTS Chapter 3.3 - Instrumentation I

CTS 3/4.3.3.1 RADIATION MONITORING INSTRUMENTATION l

FNP ITS 3.3.3 POST ACCIDENT MONITORING INSTRUMENTATION FNP ITS 3.3.6 CONTAINMENT PURGE AND EXHAUST ISOLATION INSTRUMENTATION i FNP ITS 3.3.7 CREFS ACTUATION INSTRUMENTATION FNP ITS 3.3.8 PRF ACTUATION INSTRUMENTATION I

FNP ITS 3.4.15 RCS LEAKAGE DETECTION INSTRUMENTATION DOC NO SHE DISCUSSION inoperable) allowance to perform the Actions in Modes 1-4 and LCO 3.9.3 provides the alternative Action to suspend Core Alterations and movement ofirradiated fuel vsemblies within containment which removes the plant from the applicable Modes of the TS. The additional times provided by STS LCO 3.6.3 are reasonable to allow the required actions to be accomplished and take into consideration the availability of redundant isolation valves in the same penetration that may still be capable of automatically isolating and the small likelihood of an event occurring within the times that would require the affected valve (s) to isolate. In addition, the attemative Action provided by LCO 3.9.3 to remove the plant from the applicable Mode of the TS is reasonable considering that the Action is required immediately and once accomplished eliminates the potential for a design basis fuel handling accident for which the radiation monitors are required. Therefore, the adoption of these STS Actions for the containment purge and exhaust isolation radiation monitors is acceptable.

21 L CTS 3/4.3.3.1 Action statement 27 applicable to the control room emergency filtration system (CREFS) radiation monitors (R35A&B) is revised extensively to be consistent with the Actions provided in the corresponding STS LCO 3.3.7. CTS Action Statement 27 specifies that with one channel less than the minimum operable requirement, the CREFS must be placed in the emergency recirculation mode of operation within one hour.

The control room isolation radiation monitors function to isolate the control room air intake upon high radiation. The isolation of the control room ventilation prevents radioactivity from being drawn into the control room air intake and allows the operators to manually start the CREFS emergency Chapter 3.3 E2-21-C March,1998

D FNP TS Conversion Enclosure 2 - Discussion of Changes to CTS

Chapter 3.3 - Instrumentation CTS 3/4.3.3.1 RADIATION MONITORING INSTRUME.NTATION FNP ITS 3.3.3 POST ACCIDENT MONITORING INSTRUMENTATION FNP ITS 3.3.6 CONTAINMENT PURGE AND EXHAUST ISOLATION INSTRUMENTATION FNP ITS 3.3.7 CREFS ACTUATION INSTRUMENTATION FNP ITS 3.3.8 PRF ACTUATION INSTRUMENTATION FNP ITS 3.4.15 RCS LEAKAGE DETECTION INSTRUMENTATION DOC NO SHE DISCUSSION 29 A The surveillance requirements identified on CTS Table 4.3-3 are revised to indicate their FNP ITS corresponding SR number. If the surveillance and frequency remain the same, no additional COC is assigned for the change to the FNP ITS number. The change is considered to be made to conform with the STS format and presentation of this information and is considered to be administrative. In addition, the channel functional test requirement is revised to be a channel operational test consistent with the STS terminology. The differences between the STS and CTS test definitions are discussed in the DOCS associated with the definitions in Section 1.0 of the TS. As such, the use of the STS term channel operational test on table 4.3-3 is considered an administrative change made to conform with the STS terminology. Any technical changes made to the surveillance on CTS Table 4.3-3 are identified with a separate DOC.

30 L The CTS surveillance requirer 6ent for the containment area radiation monitors is revised consistent with the corresponding STS surveillance SR 3.3.3.1. The CTS surveillance requires a shiftly (12 hours1.388889e-4 days <br />0.00333 hours <br />1.984127e-5 weeks <br />4.566e-6 months <br />) channel check to be performed on the radiation monitors. The corresponding STS post accident monitoring surveillance (SR 3.3.3.1) requires the same channel check be performed every 31 days. The STS basis for the 31 day frequency is the fact that operating experience has demonstrated that channel failures l are rare and that this surveillance only ser xs to supplement less formal, but more frequent channel indication verifications made during the course of normal plant operation. As such the 31 day frequency is sufficient to demonstrate channel operability without introducing a significant change in the probability of a channel failure going unnoticed. The STS basis for the 31 day frequency for performing channel checks of this instrumentation is applicable to FNP and therefore, this change is acceptable.

l Chapter 3.3 E2-29-C March,1998 l

I t

L_.___ __ _._____.___

FNP TS Conversion Enclosure 2 - Discussion of Changes to CTS Chapter 3.3 - Instrumentation CTS 3/4.3.3.5 REMOTE SHUTDOWN INSTRUMENTATION FNP ITS 3.3.4 REMOTE SHUTDOWN SYSTEM DOC NQ SHE DISCUSSION 1 M The CTS 3/4.3.3.5, remote shutdown instrumentation LCO is revised consistent with STS 3.3.4. The CTS LCO statement is revised to eliminate references to " monitoring instrumentation channels" and " external readouts". In addition, the STS Table 3.3.4-1 is referenced instead of the CTS Table 3.3-9. The LCO statement is expanded by the use of the STS term " remote shutdown system functions" to include transfer and control circuits as well as indications. The revL.ed LCO statement and new Table 3.3.4-1 include instrumentation previously not addressed by the CTS. The control and transfer circuits added to this LCO are those necessary to shutdown the plant from a remote location using safety grade equipment.

The specific instrumentation added to this LCO is consistent with that identified in FNP FSAR Section 7.4 to meet the requirements of 10 CFR 50, Appendiu, GDC 19 upon which this STS LCO is based. Therefore, the addition of this instrumentation to the remote shutdown LCO is appropriate for and applicable to FNP. However, the addition of this instrumentation to the FNP TS introduces new TS requirements and is therefore considered more restrictive.

2 M CTS 3/4.3.3.5 Action statement "a"is revised consistent with the STS 3.3.4 Conditions A and B. The CTS Action statement which only addresses less than the required monitoring channels operable is revised to address one or more inoperable remote shutdown functions. This change expands the CTS Action to include the new remote shutdown transfer and control functions.

The revision of this CTS Action is consistent with the change made to the CTS LCO statement to include control and transfer circuits as well as monitoring channels. Therefore, the addition of this instrumentation to the remote shutdown Actions is appropriate for and applicable to FNP.

However, the addition of this instrumentation to the FNP TS introduces new TS requirements and is therefore considered more restrictive.

3 M The CTS 3/4.3.3.5 default Action to be in hot shutdown within the next 12 hours1.388889e-4 days <br />0.00333 hours <br />1.984127e-5 weeks <br />4.566e-6 months <br /> is revised consistent with the STS. The CTS Action is revised to include the standard default Action requirement to be in Mode 3 within 6 I

hours prior to the existing CTS Action to be in Mode 4 in 12 hours1.388889e-4 days <br />0.00333 hours <br />1.984127e-5 weeks <br />4.566e-6 months <br />. The combination of these two shutdown Actions is standard throughout the STS and in most cases in the CTS. Incorporation of this additional Action confomis with the STS 3.3.4 Condition B Required Actions and the l Chapter 3.3 E2-1-E March,1998 l

L-.____-__-._____-.._.-

l lo9 FNP TS Conversion Enclosure 2 - Discussion of Changes to CTS Chapter 3.3 - Instrumentation-CTS 3/4.3.3.8 ACCIDENT MONITORING INSTRUMENTATION CTS 3/4.6.4.1 HYDROGEN ANALYZERS FNP ITS 3.3.3 POST ACCIDENT MONITORING INSTRUMENTATION

, , DOC

!' - NO SHE DISCUSSION 1 A The title and LCO statement of CTS 3/4.3.3.8, Accident Monitoring .l Instrumentation are revised consistent with the STS. The title is revised to

" Post Accident Monitoring Instrumentation" which more accurately describes the instrumentation function. Consistent with other STS

l. instrument LCOs,- the instruments listed in the Table associated with the LCO are labeled as Functions. These changes conform with the presentation and format of the STS but do not introduce technical changes

,. to the requirements of the CTS. Changes which afTect the required l- instrumentation or Actions are discussed in the DOCS associated'with those changes. As such, this change only affects the terminology used in the LCO and is considered administrative.

L ,

l l 2 A The CTS 3/4.3.3.8 Action which provides an exception to Specification 3.0.4 is revised consistent with the STS. The format and presentation of the i CTS exception is revised to conform with the standard note format of the STS. The exception to Spec.fication 3.0.4 remains unchanged. The only effect of this change is to convert the CTS exception into the STS format for the same exception.. As such, this change is considered administrative. i l

l. 3 A The CTS 3/4.3.3.8 Actions are modified by a note consistent with the STS. j i

The STS note which allows separate Condition entry for each inoperable j function is added to CTS 3/4.3.3.8 consistent with STS 3.3.3. The STS note provides a clarification which allows the Actions Conditions to be ,

applied to each function individually. The use and application of this STS

note is described in Section 1.3 of the STS. The addition of this STS note  !

l is consistent with the FNP application of CTS 3/4.3.3.8 Action statements )

on CTS Table 3.3-11. The CTS Action statements are applicable to each l inoperable channel listed on Table 3.3-11. The CTS Actions may be l

applied to each channel listed on Table 3.3-11 separately. As such, the i addition of the STS note provides a clarification which does not introduce a

[ technical change to the way in which the CTS Actions are applied.

. Therefore, this change is made to conform with the format and presentation of this information in the STS and is considered administrative. .

4 A CTS 3/4.3.3.8 surveillance 4.3.3.8 is revised consistent with the STS. The .;

Chapter 3.3 E2-1-G March,1998 i -

IIL FNP TS Conversion Enclosure 2 - Discussion of Changes to CTS Chapter 3.3 - Instrumentation CTS 3/4.3.3.8 ACCIDENT MONITORING INSTRUMENTATION CTS 3/4.6.4.1 HYDROGEN ANALYZERS FNP ITS 3.3.3 POST ACCIDENT MONITORING INSTRUMENTATION DOC NO SHE DISCUSSION cases, the CTS Required channels column requires two channels operable I and the minimum channels operable colunm requires one channel operable.

Therefore, the CTS Action statements generally address one channel i inoperable (less than required) and two channels inoperable (lcss than the minimum). The corresponding STS Conditions A and C are based on a

. single column of" required" channels and address one or more functions with a single inoperable channel (Condition A) and one or more functions with two inoperable channels (Condition C). In addition, the STS wording i in Conditions A and C describing "one or more functions with..."is consistent with the manner in which the CTS Actions 1-4 are applied to the  ;

instrument functions listed on Table 3.3-11. As the CTS Actions are applied separately to each individual instrument function, the STS wording describing "one or more functions with..." does not introduce a technical change to the way the CTS Actions are applied. The addition of the STS wording "one or more functions with..." represents a change to conform with the format and presentation of this information in the STS. Therefore, the changes made to CTS Actions 1-4 described above are considered administrative.

7 L CTS 3/4.3.3.8 Action statements 1 and 3 on Table 3.3-11 are revised consistent with the corresponding STS Condition A. These CTS Actions address a single inoperable channel and allow 7 days to restore the inoperable channel to operable status. The time allowed to restore an

' inoperable channel is revised from 7 days to 30 days consistent with the time allowed in the corresponding STS Condition A which also addresses a single inoperable channel. The allowance of 30 days to restore an l

l inoperable channel to operable status is based on industry operating

. experience and takes into account the remaining operable channel or L

l attemative instruments that may be used to monitor the parameter, the

l. passive nature of the instrument (no critical automatic action is assumed to occur from these instruments), and the low probability of an event requiring post accident monitoring instrumentation during the 30 day interval. As such, the 30 day Completion Time is applicable to and appropriate for the FNP accident monitoring instrumentation. Therefore, the revision of the CTS 7 day Completion Time to the STS 30 day Completion Time is Chapter 3.3 E2-3-G March,1998 a _ _ - _ _ _ _ _ _ - - _ _ - _ _ - _ _ - - . _ _ - _ . _ _ _ - _ - - _ - _ _ _ _ _ _ _ - - - - _ _ _ _ _ _ - _ _ _ _ - _ _ _ _ _ _ _ _ _ _ - _ _ _ -

lM FNP TS Conversion Enclosure 2 - Discussion of Changes to CTS Chapter 3.3 - Instrumentation CTS 3/4.3.3.8 ACCIDENT MONITORING INSTRUMENTATION i i

CTS 3/4.6.4.1 HYDROGEN ANALYZERS i

FNP ITS 3.3.3 POST ACCIDENT MONITORING INSTRUMENTATION l DOC l i

b'O SHE DISCUSSION j water level indication system. This CTS footnote describes a channel of I level indication and defines what is required for an operable channel. In the STS, this information is typically found in the bases. The description of what is required for an operable system is a standard component of the STS i bases. As such, the CTS footnote is more appropriately located in the )'

bases. Reliance on the information contained in the STS bases for system operability requirements is acceptable since changes to the information in the bases is controlled by the Bases Control Program specified in the j administrative controls section of the TS.

21 A CTS 3/4.3.3.8 Table 4.3-7 is deleted consistent with the STS. This CTS table contains a list of the post accident monitoring instruments and the surveillance associated with each instrument. The CTS Table is referenced I by CTS surveillance 4.3.3.8. The surveillance, including the frequency are the same for all instruments. A channel check is done monthly (31 days) and a channel calibration is done during a refueling (18 months). These surveillance requirements are replaced with the corresponding STS surveillance SR 3.3.3.1 and SR 3.3.3.2 which are applicable to all instruments in the LCO. These STS surveillance effectively require the same surveillance at the same frequencies for the same instrumentation.

l Any technical changes to the CTS surveillance are discussed in the DOCS associated with CTS surveillance 4.3.3.8. As such, this change documents ,

the replacement of CTS Table 4.3-7 with the separate STS surveillance SR l 3.3.3.1 and SR 3.3.3.2 for all instrumentation addressed by this LCO. This change is made to conform with the format and presentation of this information in the STS and is not intended to introduce a technical change.

Therefore, this change is considered administrative, j 22 A CTS 3/4.6.4.1, Hydrogen Analyzers, is moved from the containment section of the CTS to the instrumentation section and placed in the post accident monitoring ITS consistent with the location of these requirements in the i STS 3.3.3. The hydrogen analyzers (monitors) are identified in RG 1.97 as post accident monitoring instrumentation. As such, the inclusion of this instrumentation in the post accident monitoring LCO is appropriate. As the requirements for this instrumentation remain within the TS, this change is Chapter 3.3 E2-11-G March,1998

(~2l FNP TS Conversion Enclosure 2 - Discussion of Changes to CTS Chapter 3.3 - Instrumentation CTS 3/4.3.3.8 ACCIDENT MONITORING INSTRUMENTATION CTS 3/4.6.4.1 HYDROGEN ANALYZERS FNP ITS 3.3.3 POST ACCIDENT MONITORING INSTRUMENTATION DOC N_O SHE DISCUSSION 25 L CTS 3.6.4.1, hydrogen analyzers, is revised consistent with STS 3.3.3, post accident monitoring, by the addition of a note affecting the Actions. The Actions of CTS 3.6.4.1 are modified by a note which takes exception to the requirements of LCO 3.0.4. The addition of this note allows changes to be made in the Mode of operation of the plant while an Action is applicable to one or both hydrogen analyzers. The addition of this note conforms with the provisions of the STS post accident monitoring LCC 3.3.3. The allowance to take exception to the provisions of LCO 3.0.4 is acceptable due to the passive function of the instrumentation (no automatic safety functions are performed by the hydrogen monitors), the ability to use alternate methods (sampling) to determine hydrogen concentration, the ability to use purge, dilution, and recombiner systems to limit the hydrogen concentration in the containment, and the low probability of an event requiring the hydrogen analyzers. As such, this change conforms with the STS and is applicable to and appropriate for FNP.

26 A CTS 3.6.4.1, hydrogen analyzers, is revised consistent with STS 3.3.3, post accident monitoring, by the addition of a note affecting the Actions. The Actions of CTS 3.6.4.1 are modified by a note which allows separate Condition entry for each instrument function listed in the post accident monitoring TS. This STS note is used where the LCO is applicable to several separate functions or components and where the Actions may be applied individually to each item covered by the LCO. The use and application of this note is discussed in section L3 of the STS. The application of this note to the hydrogen analyzers in the STS post accident monitoring LCO is consistent with the separate CTS LCO and Actions for hydrogen analyzers. In the CTS, separate LCOs address the hydrogen analyzers and accident monitoring instrumentation and therefore, individual Actions can be applied to the hydrogen analyzers simultaneously with any Actions that may be applicable to the accident monitoring functions. As such, the addition of this STS note to the TS requirements for the hydrogen analyzers in the post accident monitoring LCO is consistent with the CTS licensing basis for this instrumentation. Therefore, this change is considered administrative.

[ Chapter 3.3 E2-13-G March,1998 ,

l l N FNP TS Conversion Enclosure 2 - Discussion of Changes to CTS j Chapter 3.3 - Instrumentation I

J CTS 3/4.3.3.8 ACCIDENT MONITORING INSTRUMENTATION I CTS 3/4.6.4.1 HYDROGEN ANALYZERS FNP ITS 3.3.3 POST ACCIDENT MONITORING INSTRUMENTATION DOC j N_Q SHE DISCUSSION represents an additional operating restriction for FNP. The addition of an Action to place the unit in Mode 4 is consistent with the need for this instrumentation to monitor post accident conditions and the fact that a design basis accident could occur in Mode 3. As such, the inclusion of an Action to be in Mode 4 is applicable to and appropriate for FNP.

29 L CTS surveillance 4.6.4.1 which requires a channel calibration to be l performed on the hydrogen analyzers every 92 days on a staggered test basis is revised consistent with the STS surveillance SR 3.3.3.2. The STS surveillance interval for this channel calibration is 18 months and does not require staggered testing. The extension of the CTS channel calibration frequency for the hydrogen analyzers to 18 months is consistent with the frequency of channel calibrations specified for the more safety significant RPS and ESFAS instrument channels. The hydrogen analyzers do not function to actuate components or systems required to mitigate accidents.

The hydrogen analyus provide indication only and are not needed to function during or even immediately after a design basis accident. With no ,

containment purge or hydrogen recombiner in operation, the hydrogen j generation rate after a LOCA is sufficiently low so that 50 days are required {

for the hydrogen concentration in containment to build up from 3% to 4.1% i (FSAR 15.4.1.9). A failure of the hydrogen analyzers would not preclude the hydrogen recombiners or containment purge system from being placed in operation at any time after an accident to limit the potential hydrogen concentration within containment. In addition, manual sampling may be initiated at any time to verify the containment hydrogen concentration.

Therefore, the 18 month channel calibration frequency used for RPS and ESFAS channels is adequate and acceptable for the hydrogen analyzers.

30 LA CTS surveillance 4.6.4.1, for the channel calibration of the hydrogen )

analyzers is revised consistent with the corresponding STS surveillance SR l 3.3.3.2 for the channel calibration of post accident monitoring instruments.

The CTS surveillance contains details regarding the makeup of the sample gases used for calibration. The STS surveillance does not contain such details. Therefore, the CTS information regarding the sample gases used during the channel calibration are moved into the bases for the Chapter 3.3 E2-15-G March,1998 l l

l

1 I

Fraley Nuclear Plant ITS Conversion Submittal - Electronic Copy i Revised DOCS i

l l

I i

i Revised DOCS (Section 3.4)

l22.- FNP TS Conversion Enclosure 2 - Discussion of Changes to CTS Chapter 3.4 - RCS CTS 3/4.4.1.4 REACTOR COOLANT LOOPS AND COOLANT CIRCULATION COLD SHUTDOWN FNP ITS 3.4.8 RCS LOOPS - MODE 5 - LOOPS NOT FILLED -

DOC N_Q SHE DISCUSSION be performed and to avoid an undue risk to the public health and safety. As such, the proposed change is a less restrictive requirement that provides justifiable operational flexibility.

9 M The surveillance requirements of CTS 3/4.4.1.4 are revised consistent with the STS. A new surveillance (SR 3.4.8.2) is added to the CTS to verify operability of the second non-operating RHR loop every 7 days. Since two operable RHR loops are required to meet the LCO, the STS contains appropriate surveillance to verify compliance with the LCO. The verification of breaker alignment and indicated power for the non-operating RHR pump relied on to meet the LCO is also consistent with the CTS requirements in other TS for RCS loops. As such, the new surveillance is  ;

consistent with the requirements used in other CTS to verify the LCO is  ;

I met and is applicable to FNP to ensure this LCO is met. However, the addition of this new surveillance requirement represents a more restrictive l

change.

l I

l i

I i

I.

l 4

Chapter 3.4 E2-4-G March,1998

G3 FNP TS Conversion Enclosure 2 - Discussion of Changes to CTS Chapter 3.4 - RCS i

CTS 3/4.4.2 SAFETY VALVES - SHUTDOWN (MODES 4 AND 5)

FNP ITS - NA DOC l NO SHE DISCUSSION 1 R The pressurizer safety valves protect the RCS from being pressurized above the RCS pressure Safety Limit. In the STS, the pressurizer safety valves are required operable to provide overpressure protection from operating conditions (Modes 1-3) down to the RCS temperature at which the low temperature overpressure protection system (RHR relief valves) are required operable (Mode 4 s 325 F). Therefore, the FNP ITS LCO 3.4.10, Pressurizer Safety Valves, and the FNP ITS LCO 3.4.12, Low Temperature Overpressure Protection System, requirements provide continuous RCS overpressure protection. As such, the CTS 3/4.4.2, Safety Valve -

Shutdown, requirement for a single pressurizer safety valve to be operable during all of Modes 4 and 5 is not required for RCS overpressure protection. In addition, the operability of a single safety valve in Modes 4 and 5 is not an assumption of any safety analysis for the mitigation of a

design basis accident or transient in Modes 4 and 5.

The FNP specific application of the NRC selection criteria to this Technical Specification is consistent with the findings of the Westinghouse generic evaluations documented in WCAP-11618. " Methodically Engineered Restructured and Improved Technical Specifications, MERITS Program -

Phase II Task 5, Criteria Application," November,1987 and the findings of the NRC as documented in the "NRC Staff Review of NSSS Vendor Owners Groups Application of The Commission's Interim Policy Statement Criteria To Standard Technical Specifications", Wilgus/Murley letter dated May 9,1988 including revisions by NUREG-1431, Revision 1," Standard Technical Specifications, Westinghouse Plants".

The specification for Safety Valves - Shutdown does not contain requirements for installed instrumentation that is used to detect, and indicate in the control room, a significant abnormal degradation of the reactor coolant pressure boundary. Therefore, Safety Valves - Shutdown does not satisfy Criterion 1.

The specification for Safety Valves - Shutdown does not contain requirements for process variables, design features, or operating restrictions that are initial conditions of a DBA or transient analysis that either assumes the failure of or presents a challenge to the integrity of a fission product I

Chapter 3.4 E2-1-H March,1998

/FS l FNP TS Conversion q l

Enclosure 2 - Discussion of Changes to CTS 1

[ Chapter 3.4 - RCS 1

CTS 3/4.4.10.2 PRESSURIZER FNP ITS - N/A DOC NQ SHE DISCUSSION 1 R Since the pressurizer normally operates in temperature ranges above those for which there is a reason for concern of nonductile failure, temperature limits are placed on the pressurizer to assure compatibility of operation with the fatigue analysis performed in accordance with the ASME Code requirements. However, a failure of pressurizer integrity would result in an j analyzed event (loss of coolant accident) for which numerous systems and  !

components are required and retained in the Technical Specifications. j Therefore, the pressurizer temperature limits are not relied on to prevent or j mitigate a DBA or transient, nor are these limits an operating restriction i that is required to preclude an unanalyzed accident or transient (Criterion 2).

The FNP specific application of the NRC selection criteria to this Technical Specification is consistent with the findings of the Westinghouse generic j evaluations documented in WCAP-11618," Methodically Engineered J Restructured and Improved Technical Specifications, MERITS Program -

Phase II Task 5, Criteria Application," November,1987 and the findings of l the NRC as documented in the "NRC Staff Review of NSSS Vendor )

Owners Groups Application of The Commission's Interim Policy Statement l Criteria To Standard Technical Specifications", Wilgus/Murley letter dated May 9,1988 including revisions by NUREG-1431, Revision 1, " Standard Technical Specifications, Westinghouse Plants".

The Pressurizer Temperature Limits are not installed instrumentation that is .

used to detect, and indicate in the control room, a significant abnormal j degradation of the reactor coolant pressure boundary. Therefore, Pressurizer Temperature Limits do not satisfy Criterion 1.

The Pressurizer Temperature Limits are not a process variable, design feature, or operating restriction that is an initial condition of a DBA or i transient analysis that either assumes the failure of or presents a challenge to the integrity of a fission product barrier. Therefore, Pressurizer Temperature Limits do not satisfy Criterion 2.

l The Pressurizer Temperature Limits are not a structure, system, or component that is part of the primary success path and which functions or actuates to mitigate a DBA or transient that either assumes the failure of or l

presents a challenge to the integrity of a fission product barrier. Therefore, Chapter 3.4 E2-1-R March,1998

/%

FNP TS Conversion Enclosure 2 - Discussion of Changes to CTS Chapter 3.4 - RCS 1

l Pressurizer Temperature Limits do not satisfy Criterion 3. l l

The Pressurizer Temperature Limits are not a structure, system, or component which operating experience or probabilistic safety assessment i has shown to be significant to public health and safety. Therefore, Pressurizer Temperature Limits do not satisfy Criterion 4.  ;

Each Technical Specification proposed for relocation has been evaluated to identify ifit contains requirements that are addressed by PRA, and if addressed, to determine if the Specification is imponant to risk (i.e.,

contains constraints of prime imponance in limiting the likelihood or severity of the accident sequences that are commonly found to dominate risk). Documents utilized to evaluate the risk insights relevant to the FNP Technical Specifications proposed for relocation include the generic evaluations performed by Westinghouse in WCAP-11618," Methodically Engineered Restructured and Improved Technical Specifications, MERITS Program - Phase II Task 5, Criteria Application," November,1987, the FNP PRA submitted in response to Generic Letter 88-20, and any other published PRA studies found to be applicable to FNP in a generic manner.

The FNP Technical Specifications proposed for relocation were found not to be important to risk.

The specification for Pressurizer Temperature Limits will be relocated to the Technical Requirements Manual (TRM). Changes to the TRM will be controlled consistent with the provisions of 10 CFR 50.59.

Chapter 3.4 E2-2-R March,1998 L

/60 FNP TS Conversion Enclosure 2 - Discussion of Changes to CTS  ;

Chapter 3.4 - RCS l CTS 3/4.4.10.3 OVERPRESSURE PROTECTION SYSTEMS FNP ITS 3.4.12 LOW TEMPERATURE OVERPRESSURE PROTECTION SYSTEM DOC NLQ SHE DISCUSSION  ;

1 M The CTS 3/4.4.10.3 title and LCO statement are revised consistent with the STS. The CTS title is revised by the addition of" low temperature". This  !

change only clarifies the application of the CTS LCO. The LCO statement is revised by the addition of requirements for the charging pumps and j accumulators. The requirement for the charging pumps is not new and is only moved into the CTS for overpressure protection from the CTS 3/4.1.2.3 for Charging Pumps Shutdown. Although the accumulators may have been isolated by plant procedures during an RCS cooldown and depressurization, the addition of the requirement to isolate the accumulators  !

l is a new TS requirement for FNP. As the requirement to isolate the accumulators is related to a possible RCS overpressurization event at lower temperatures, this requirement is applicable to FNP. However, as the LCO is revised to include the new requirement for accumulators this change is considered more restrictive.

2 A The CTS 3/4.4.10.3 LCO statement is further revised consistent with the STS by the removal of the requirement for the RHR relief valve isolation valves to be open. As open isolation valves are inherent in the requirement to have operable relief valves, the CTS LCO requirement for open isolation valves remains in the TS as a surveillance requirement (SR 3.4.12.3). As this change is made to conform with the format and presentation of this information in the STS, and does not introduce a technical change, it is considered administrative.

3 A The CTS 3/4.4.10.3 Applicability is modified by the addition of 3 notes consistent with the STS and the CTS.

l Note 1 addresses the RCS temperature at which the requirement to have j only one charging pump available for injection into the RCS becomes j effective. This Note is derived from an

• footnote to CTS 3/4.1.2.3 l applicability (see markup of CTS 3/4.1.2.3 on a subsequent CTS page in j Enclosure 1). As this change is consistent with the CTS temperature I requirements for charging pump herability and only reformats the location of this footnote consistent with the location of the charging pump requirements in the STS, this change is considered administrative.

Note 2 consists of the STS applicability note that modifies the requirement Chapter 3.4 E2-1-S March,1998

M FNP TS Conversion Enclosure 2 - Discussion of Changes to CTS Chapter 3.4 - RCS CTS 3/4.4.10.3 OVERPRESSURE PROTECTION SYSTEMS FNP ITS 3.4.12 LOW TEMPERATURE OVERPRESSURE PROTECTION SYSTEM DOC NO SHE DISCUSSION to isolate the accumulators. The more restrictive change that added the requirement to isolate accumulators was discussed previously. The addition of this note provides more specific guidance on the application of the requirement to isolate accumulators. As such, this change is also considered administrative made to support the addition of the accumulator isolation requirement discussed previously.

Note 3 simply relocates the existing CTS exception to Specification 3.0.4 into the applicability consistent with the STS. CTS 3.4.10.3 action statement "d" currently contains the exception to specification 3.0.4. The change to move this exception into an applicability note is consistent with the format and presentation of this type ofinformation in the STS. As such, this change is considered administrative.

4 M CTS 3/4.4.10.3 is revised by the addition of new Actions Conditions consistent with the STS. New Conditions A, B, and C are added. The proposed Conditions and Required Actions address the new LCO requirements for only one charging pump operable and for the accumulators to be isolated. The proposed Conditions provide reasonable actions and allowances for completing them if the new LCO requirements are not met.

The new actions provide adequate remedial measures or remove the plant from the Mode of Applicability. As such the new Conditions are applicable and appropriate to FNP. However, the addition of these Conditions and actions in the FNP TS represent new requirements not previously addressed by the TS. As such, the addition of these Conditions and Required Actions is considered a more restrictive change.

5 M The CTS action statement "b"is revised consistent with the STS. The additional plant conditions of other Required Actions or Completion Times not met and if the LTOP system is inoperable for any reason other than addressed by the other Actions Conditions are included in this CTS action statement. The inclusion of these additional plant conditions provide a comprehensive set of TS Conditions to address not meeting the LTOP l

LCO. The associated required action to depressurize the RCS and provide a i

vent path ensures RCS overpressure protection and places the plant in a safe condition. As such, the addition of these plant conditions to CTS Action statement "b" is applicable to FNP. However, as these conditions were not Chapter 3.4 E2-2-S March,1998

/67- FNP TS Conversion Enclosure 2 - Discussion of Changes to CTS Chapter 3.4 - RCS CTS 3/4.4.10.3 OVERPRESSURE PROTECTION SYSTEMS FNP ITS 3.4.12 LOW TEMPERATURE OVERPRESSURE PROTECTION SYSTEM DOC NLQ SHE DISCUSSION previously addressed in the CTS, this change is considered more restrictive.

6 A The CTS 3.4.10.3 action statement "c"is revised consistent with the format of the STS. The CTS action requires a special report be made in the event an RHR relief valve is used to mitigate an RCS pressure transient. In the STS, the special reports section (CTS 6.9.2) does not exist. As such, it is proposed to move this reporting requirement to the Monthly Operating Report (STS 5.6.4). The STS monthly operating report is required every 30 days and contains related information regarding challenges to pressurizer relief and safety valves. Therefore, the CTS reporting requirement for the RHR relief valves will be adequately addressed by inclusion in the monthly operating report where other safety and relief valve reporting requirements reside. As this change is not intended to introduce a technical change and is made to conform with the format and presentation of this information in the STS, it is considered an administrative change.

7 A The CTS specific action statement "d" is moved into the notes to the applicability consistent with the presentation of similar information in the STS. The CTS action statement contains a plant specific (not in STS) j exception to Specification 3.0.4. As this change does not introduce a I technical change to the CTS, this change is considered administrative.

i 8 LA CTS surveillance 4.4.10.3.1.a is revised to remove the specific valve j numbers from the TS. In the STS, such detailed information is contained in )'

documents outside of the TS. As such, the valve numbers in this CTS requirement are moved into the corresponding section of the FNP ITS bases for this surveillance (SR 3.4.12.3). The placement of such information in l l the bases is acceptable based on the change control provided by the bases l control program contained in the administrative section of the ITS. In i addition, editorial changes are made to use the STS term " required" RHR valve instead of stating "when the RHR relief valve is being used...".

9 A CTS surveillance 4.4.10.3.1.b is revised consistent with the deletion of l

Specification 4.0.5 in the STS. In the STS, Specification 4.0.5 does not exist and the Inservice Testing Program is referenced directly. In addition, CTS 4.4.10.3.1.b is also revised to combine it with CTS 4.4.10.3.1.c consistent with the implementing plant procedures. The same surveillance l

Chapter 3.4 E2-3-S March,1998

N,3 FNP TS Conversion Enclosure 2 - Discussion of Changes to CTS Chapter 3.4 - RCS CTS 3/4.4.10.3 OVERPRESSURE PROTECTION SYSTEMS FNP ITS 3.4.12 LOW TEMPERATURE OVERPRESSURE PROTECTION SYSTEM DOC NO SHE ' DISCUSSION procedure (STP 628.0, relief valve setpoint verification) is used to meet both CTS 4.4.10.3.1.b and c. The only difference between the requirements is the increase in the scope of testing specified in the inservice testing program. The base frequency of testing is one valve every 18 months on a staggered test bases. However, if the scheduled valve exceeds the setpoint

' by 3% or greater the scope of testing is expanded per the inservice testing program to include the remaining relief valve. The application of these two frequencies is explained in the ITS bases for this FNP surveillance.- As such, the frequency of the proposed FNP ITS surveillance SR 3.4.12.5 includes "In accordance with the Inservice Testing Program and Every 18 i months on a Staggered Test Basis". This change is consistent with the format and presentation of similar information in the STS, and because no technical change is intended, it is considered an administrative change. -

10 A The CTS surveillance 4.4.10.3.1.c is revised consistent with the terminology used in the STS. The CTS surveillance uses the term " rotating basis" to describe the surveillance interval. In the STS, the defined term Staggered Test Basis applies. The definition of Staggered Test Basis as scated in the STS, results in the same surveillance interval as described by "at least once every 18 months on a rotating basis" in the CTS. As such j this change is considered administrative made to conform with the )

1 presentation and format of the STS.

11 A The CTS surveillance 4.1.2.3.2 from the Reactivity Control Systems )

I Chapter is moved into the RCS over pressure pronction LCO consistent with the STS as SR 3.4.12.1. The CTS 4.1.2.3.2 surveillance addresses the requirement that only one charging pump may be capable ofinjecting into the RCS when one or more cold leg temperatures is less than or equal to 180 F. This requirement is related to low temperature RCS pressure h control and therefore belongs with the LTOP system TS. The CTS l < surveillance is also revised to change inoperable to incapable ofinjecting l into the RCS consistent with the STS. As the CTS requirement to render l the pump inoperable was intended to prevent injection into the RCS and the l possible overpressure condition that injection might cause, the STS term of l

" rendering the pump incapable of injecting into the RCS" effectively accomplishes the same thing as the CTS (inoperable) but defines the requirement more precisely. In aidition, this CTS surveillance is also

' Chapter 3.4 E2-4-S March,1998 )

l

)

/4 FNP TS Conversion Enclosure 2 - Discussion of Changes to CTS l Chapter 3.4 - RCS CTS 3/4.4.10.3 OVERPRESSURE PROTECTION SYSTEMS i-FNP ITS 3.4.12 LOW TEMPERATURE OVERPRESSURE PROTECTION SYSTEM DOC l

' N_.Q .SHE DISCUSSION revised to remove the reference to the stated Mode of Applicability (except I when the reactor vessel head is removed)' consistent with the STS. As the l: proposed FNP ITS 3.4.12 applicability excludes this specific condition (head removed) it is not necessary to repeat the Mode of applicability in the

l. surveillance requirements. As such, the movement of this surveillance to the RCS chapter and revisions described above do not introduce technical changes and are considered administrative in nature.

12 LA The CTS surveillance 4.1.2.3.2 (from the Reactivity Control Systems L Chapter) is further revised, consistent with the STS, to remove the specific l means by'which 'a charging pump is rendered incapable ofinjecting into the RCS. The CTS surveillance specifies that the motor circuit breakers are removed from their electrical power supply circuits. This method, as well l

!- as another, are discussed in the STS bases for this surveillance. In the STS, l specific guidance for meeting the stated TS requirement is typically not b included in the TS. As such, the CTS guidance for meeting this  ;

L requirement is moved into the bases for the corresponding STS l

! surveillance. The placement of such information in the bases is acceptable based on the change control provided by the bases control program ,

contained in the administrative section of the ITS.

13 .A The

• footnote to the applicability of CTS 3.1.2.3 is moved into the RCS LCO for over pressure protection. This CTS footnote specifies the RCS L temperature at which the requirement to have only one charging pump capable'ofinjecting water into the RCS becomes applicable. Since this ,

requirement functions to prevent overpressurizing the RCS with two charging pumps injecting water, it belongs in the RCS overpressure l protection LCO consistent with the STS. As such, this

• footnote is moved into the notes for the applicability of the proposed FNP ITS 3.4.12. As this change is made to conform with the format and presentation of similar L

i information in the STS and does not introduce a technical change, it is considered administrative.

i Chapter 3.4 E2-5-S March,1998

FNP TS Conversion I Enclosure 2 - Discussion of Changes to CTS )

I Chapter 3.4 - RCS i

l CTS 3/4.4.11 RCS STRUCTURAL INTEGRITY j l

FNP ITS - N/A j DOC N_Q SHE DISCUSSION 1 LA The CTS 3/4.4.11, Structural Integrity, LCO, Actions, and Applicability are j removed from the TS consistent with the STS. The RCS Structural Integrity LCO requires ASME Code Class 1,2, and 3 components maintained in accordance with the Inservice Test (IST) and Inspection Programs (ISI) as required by CTS Specification 4.0.5 and in accordance l with CTS augmented inspection surveillance 4.4.11.2 and 4.4.11.3 (RCP flywheel inspections and main steam piping weld inspections). In the STS, specification 4.0.5 does not exist. The ISI program is a requirement of 10 CFR 50.55a and will continue to be maintained in accordance with the applicable regulation. In the STS, the requirement to maintain an IST program is retained in the TS as Specification 5.5.8, Inservice Testing Program specified in the Administrative Controls section ofTS. Therefore, the FNP IST program will also continue to be maintained in the same manner. The augmented inspection requirements specified in CTS 4.4.11.2 and 4.4.11.3 will also be retained in the administrative controls section of the TS as Specification 5.5.7, Reactor Coolant Pump Flywheel Inspection Program and Specification 5.5.16, Main Steamline Inspection Program, and continue to be maintained in the same manner. All the test and inspection requirements specified in CTS 3/4.4.11 are either retained in the TS as required programs or required by regulation. As such, a separate LCO to specify these requirements is unnecessary and redundant.

The required ASME Code Class 1,2, and 3 components addressed by the inspection and test requirements of CTS 3/4.4.11 are associated with the operability of structures, systems, and components that are required operable by TS, such as the RCS Loop requirements, or ECCS aperating and shutdown TS requirements. As such, the individual TS Applicabilities and Actions for those structures, systems, and components found to be inoperable due to inoperable ASME Code Class 1,2, or 3 component (s) are applicable. Therefore, the separate Applicability and separate Actions of CTS 3/4.4.11 for the ASME Code Class 1,2, and 3 components are unnecessary and possibly confusing in lieu of the existing TS requirements addressing the potentially affected structures, systems, and components.

Reliance on the TS mquirements applicable to the affected structures, systems, and components is acceptable since those TS requirements provide l adequate remedial measures and Completion Times specific to the affected Chapter 3.4 E2-1-T March,1998

/4 FNP TS Conversion Enclosure 2 - Discussion of Changes to CTS Chapter 3.4 - RCS CTS 3/4.4.11 RCS STRUCTURAL INTEGRITY l

FNP ITS - N/A l DOC 1 NO SHE DISCUSSION  ;

l structure, system, or component. l l

2 A CTS 3/4.4.11 surveillance 4.4.11.2 and 4.4.11.3 are moved into the program section of the TS Administrative Controls as Specification 5.5.7, l Reactor Coolant Pump Flywheel Inspection Program and Specification )

5.5.16, Main Steamline Inspection Program, consistent with the STS. The  ;

CTS surveillance requirements 4.4.11.2 and 4.4.11.3 require inspections l performed in addition to those required by the ISI and IST programs. CTS l

4.4.11.2 requires the RCP flywheels to be inspected per the i recommendations of regulatory position c.4.b of Regulatory Guide 1.14 revision 1, August 1975. CTS 4.4.11.3 requires inspection of main steam piping circumferential and longitudinal welds. As CTS 3/4.4.11 does not exist in the STS and the STS Administrative Controls contain the IST and RCP flywheel inspection programs, it is appropriate that CTS requirements 4.4.11.2 and 4.4.11.3 also be moved into the program section of Administrative Controls. Since these CTS requirements are not changed and remain in the TS, this change is considered administrative.

3 L CTS surveillance 4.4.11.2 requires each RCP flywheel to be inspected in accordance with Reg ulatory Position C.4.b of Regulatory Guide 1.14. This CTS surveillance is revised consistent with the latest NRC approved guidance for Westinghouse Plant RCP flywheel inspections. WCAP-14535A," Topical Report on RCP Flywheel Inspection Elimination",

November,1996 and the associated NRC SER dated September 12,1996 (included in the "A" version of the WCAP) allow the RCP flywheel inspection interval to be once per 10 years in lieu of the RG 1.14 requirements for plants with flywheels made from the SA 533 B material.

WCAP-14535 concludes that continued inspections of RCP flywheels are not necessary and overall plant safety would be increased by eliminating these inspections due to a reduction in man rem dose and the potential for flywheel damage during disassembly and reassembly for inspection. The NRC SER for WCAP-14535 however, approves a 10 year inspection interval for all plants with SA 533 B flywheel material. The FNP RCPs

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have flywheels made from this material and therefore qualify for the generically approved extended inspection interval. This extended inspection i interval continues to cc..servatively assure the integrity of the RCP I flywheels while providing an increase in plant safety by reducing the l 1

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/47 FNP TS Conversion Enclosure 2 - Discussion of Changes to CTS

Chapter 3.4 - RCS

- CTS 3/4.4.11 RCS STRUCTURAL INTEGRITY FNP ITS - N/A DOC' NQ ' SHE' DISCUSSION number of inspections required which will reduce man rem exposure and the potential for damaging the flywheels during disassembly and reassembly. This change is acceptable based on the findings of WCAP-14535A and the approval of the NRC in the associated SER.

l Chapter 3,4 E2-3-T March,1998 O________-__--_______________________ .

FNP TS Conversion Enclosure 2 - Discussion of Changes to CTS Chapter 3.4 - RCS CTS 3/4.4.12 REACTOR VESSEL HEAD VENTS FNP ITS - N/A DOC NQ SHE DISCUSSION 1 R The RCS Vents are provided to exhaust non-condensable gases and/or steam from the RCS which could inhibit natural circulation core cooling following any event involving a loss of ofTsite power and requiring long term cooling, such as a loss-of-coolant accident (LOCA). Their function, I capabilities, and testing requirements are consistent with the requirements ofItem II.B.1 of NUREG-0737, " Clarification of TMI Action Plan Requirements," however, the operation of RCS Vents is not assumed in any safety analysis. This is because the operation of the vents is not part of the primary success path for any design basis event. The operation of these I

vents is an operator action after the event has occurred, and is only required when there is indication that natural circulation is not occurring. Therefore, this specification is proposed for relocation. .

l The FNP specific application of the NRC selection criteria to this Technical Specification is consistent with the findings of the Westinghouse generic evaluations documented in WCAP-11618," Methodically Engineered Restructured and Improved Technical Specifications, MERITS Program -

Phase II Task 5, Criteria Application," November,1987 and the findings of the NRC as documented in the "NRC Staff Review of NSSS Vendor Owners Groups Application ofThe Commission's Interim Policy Statement Criteria To Standard Technical Specifications", Wilgus/Murley letter dated May 9,1988 including revisions by NUREG-1431, Revision 1," Standard Technical Specifications, Westinghouse Plants".

The RCS Vents are not installed instrumentation that is used to detect, and indicate in the control room, a significant abnormal degradation of the reactor coolant pressure boundary. Therefore, RCS Vents do not satisfy Criterion 1.

! The RCS Vents are not a process variable, design feature, or operating restriction that is an initial condition of a DBA or transient analysis that either assumes the failure of or presents a challenge to the integrity of a l

fission product barrier. Therefore, RCS Vents do r.ot satisfy Criterion 2.

The RCS Vents are not a structure, system, or component that is part of the primary success path and which functions or actuates to mitigate a DBA or transient that either assumes the failure of or presents a challenge to the integrity of a fission product barrier. Therefore, RCS Vents do not satisfy Chapter 3.4 E2-1-U March,1998 l

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FNP TS Conversion ,

Enclosure 2 - Discussion of Changes to CTS j Chapter 3.4 - RCS

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CTS 3/4.4.12 REACTOR VESSEL HEAD VENTS FNP ITS - N/A DOC b'Q SHE DISCUSSION Criterion 3.

The RCS Vents are not a structure, system, or component which operating experience or probabilistic safety assessment has shown to be significant to public health and safety. Therefore, RCS Vents do not satisfy Criterion 4.

Each Technical Specification proposed for relocation has been evaluated to identify ifit contains requirements that are addressed by PRA, and if addressed, to determine if the Specification is important to risk (i.e., I contains constraints of prime importance in limiting the likelihood or severity of the accident sequences that are commonly found to dominate risk). Documents utilized to evaluate the risk insights relevant to the FNP Technical Specifications proposed for relocation include the generic evaluations performed by Westinghouse in WCAP-11618," Methodically Engineered Restructured and Improved Technical Specifications, MERITS Program - Phase II Task 5, Criteria Application," November,1987, the FNP PRA submitted in response to Generic Letter 88-20, and any other published PRA studies found to be applicable to FNP in a generic manner.

The FNP Technical Specifications proposed for relocation were found not to be important to risk.

The specification for RCS Vents will be relocated to the Technical Requirements Manual (TRM). Changes to the TRM will be controlled consistent with the provisions of 10 CFR 50.59.

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l FNP TS Conversion Enclosure 2 - Discussion of Changes to CTS Chapter 3.5 - ECCS CTS 3/4.5.3 ECCS SUBSYSTEMS - Tavg < 350 F FNP ITS 3.5.3 ECCS - SHUTDOWN DOC-HQ SHE DISCUSSION 1 A The CTS 3/4.5.3 title and LCO are revised to be consistent with the STS.

The term "as a minimum" is deleted from the LCO as the LCO always states the minimum requirements. The LCO statement is also revised to refer to ECCS " train" instead of" subsystem". This change is made solely to conform to the STS terminology. As such, these changes are considered

, administrative in nature.

l- 2 LA The CTS 3.5.3 LCO statement is further revised to be consistent with the STS. The LCO statement details describing system operability are I

contained in the bases for LCO 3.5.2. In the STS, operability descriptions are more detailed and contained entirely in the TS bases. Placement of this information in the bases is acceptable due to the bases control program in the administrative controls section of the STS. This program provides an appropriate level of control for changes to the TS bases.

3 A The CTS 3.5.3 LCO statement regarding the operability of the ECCS flow path and "being manually realigned" provides the allowance for the RHR system to be aligned for the cooldown mode of operation and be manually realigned to the ECCS injection mode of operation if required. This CTS allowance is effectively retained in the STS as a note in the LCO statement.

This reformatting of the information contained in the CTS LCO statement is made to conform with the presentation and format of this information in the STS. As such, this change is considered administrative in nature.

4 -LA The CTS action statement "a" is revised to be consistent with the STS. The action statement becomes Condition B in the FNP ITS and the description of the charging subsystem (pump and flow path) is replaced by the term subsystem. The subsystems that comprise an ECCS train are described in l detail in the bases of LCO 3.5.2. Placement of this information in the bases is acceptable due to the bases control program in the administrative controls l section of the STS. This program provides an appropriate level of control l for changes to the TS bases.

I 4a L CTS 3.5.3 action statement "a" is revised consistent with the allowance provided in STS LCO 3.5.2. The CTS action is revised by the addition of an action which provides an allowed outage time of 72 hours8.333333e-4 days <br />0.02 hours <br />1.190476e-4 weeks <br />2.7396e-5 months <br /> for the required ECCS centrifugal charging subsystem to be inoperable provided Chapter 3.5 E2-1-C March,1998

So l FNP TS Conversion Enclosure 2 - Discussion of Changes to CTS Chapter 3.5 - ECCS CTS 3/4.4.7.2 RCS OPERATIONAL LEAKAGE (CONTROLLED LEAKAGE ONLY)

FNP ITS 3.5.5 SEAL INJECTION FLOW l

DOC b'Q SHE DISCUSSION which the appropriate flow can be determined based on the delta between the RCS pressure and the charging discharge header pressure. The information in the CTS LCO and the additional requirement for charging discharge header pressure is contained as a single point on this graph. The points on the graph are based on FNP-specific safety analysis assumptions  !

which provide the relationship between seal injection flow, RCS pressure, and charging discharge header pressure over a range of values for each of these parameters. The surveillance requirement will require the flow to be within ECCS safety analysis limits. Therefore, the figure in the Bases must maintain those limits. The verification of seal water flow within the limit by establishing a reference differential pressure is more consistent with the method used to determine the seal water flow values assumed in the applicable ECCS safety analyses. As such, this change is applicable to FNP. Since this change introduces an additional requirement in the TS, it is (

considered more restrictive.

l 5 M The CTS surveillance 4.4.7.2.1.c for verification of seal water flow is revised consistent with the STS. The CTS surveillance contains an exception to the provisions of Specification 4.0.4 for entry into modes 3 and  !

4. The CTS exception to specification 4.0.4 allowed the perfomiance of this surveillance to be delayed until the RCS pressure was within the specified limits. The CTS surveillance contains no specific time limits for performing this surveillance after entering Modes 4 or 3. In the STS, there are no exceptions to the equivalent SR 3.0.4. Instead of specifying a blanket exception to the requirement to perform all surveillance prior to )

entering the Mode of applicability or other specified conditions, the STS specifies the conditions under which the surveillance must be performed and a specific time in which it should be performed after the specified conditions are met. In this way no exceptions for the performance of surveillance requirements are required in the STS. The STS surveillance SR 3.5.5.1 for verifying seal injection flow specifies the equivalent RCS pressure that was required by the CTS for performing this surveillance (2215-2255 psig) and also specifies a time (4 hours4.62963e-5 days <br />0.00111 hours <br />6.613757e-6 weeks <br />1.522e-6 months <br />) within which the l surveillance must be performed after the specified pressure is reached and I stabilized. The time allowed by the STS for performing the surveillance is consistent with the time allowed by the CTS action statement b to restore the seal water injection flow to within limit ifit is found outside the limit Chapter 3.5 E2-3-F March,1998

Forley Nuclear Plant ITS Conversion Submitta! - Electronic Copy

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FNP TS Conversion Enclosure 2 - Discussion of Changes to CTS Chapter 3.6 - Containment Systems CTS 3/4.6.1.3 CONTAINMENT AIR LOCKS FNP ITS 3.6.2 CONTAINMENT AIR LOCKS DOC NQ SHE  : DISCUSSION Conditions separately for each inoperable air lock. As explained in STS

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l section 1.3, " Completion Times", this note allows a separate Completion {

Time to be established for each airlock. The application of this note in the i STS is based on the Action requirements providing sufficient remedial measures when applied individually to each component or system addressed ,

in the TS. As the FNP air locks are consistent with the air locks addressed in the STS, the provision of this note is applicable to and acceptable for FNP.

The third STS note affecting the CTS 3/4.6.1.3 Actions provides guidance to direct the user to the Containment LCO (3.6.1) if the air lock leakage results in the total containment leakage exceeding the limit required by LCO 3.6.1. This note provides a clarification and does not introduce a technical change. As such, the addition of this note is considered an administrative change.

3- L The CTS 3/4.6.1.3 Actions are revised consistent with the STS. The CTS actions are revised to specifically include "one or more" inoperable air locks. The STS actions are applicable to each air lock individually and each STS condition may be applicable to more than one air lock at a time.

. Therefore, consistent with the format and presentation of the STS, the - ~

action Conditions for an inoperable air lock use the term "one or more air locks" to describe the applicability of each Condition. This clarification of the applicability of the required actions is acceptable since the level of assurance (for containment leakage) provided by accomplishing the required actions is not reduced when applied to each air lock individually.

The action requirement for an operable air lock door closed and locked in each inoperable air lock remains unchanged and continues to ensure the air locks provide the required containment isolation. In addition, the action requirement (STS action C.1) that air lock leakage must immediately be evaluated against the overall containment leakage required by LCO 3.6.1,

' " Containment", assures that if the overall containment leakage limit is exceeded (due to air lock leakage) the conservatively short Completion j Time of LCO 3.6.1 (1 hour1.157407e-5 days <br />2.777778e-4 hours <br />1.653439e-6 weeks <br />3.805e-7 months <br />) would be applied. Therefore, the prime  !

concern of containment operability (overall leakage within the assumptions  ;

of the 'safety analysis) continues to be addressed in an appropriate manner by the STS air lock actions.

- Chapter 3.6. E2-2-C March,1998 l

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59 FNP TS Conversion Enclosure 2 - Discussion of Changes to CTS Chapter 3.6 - Containment Systems CTS 3/4.6.1.3 CONTAINMENT AIR LOCKS

~ FNP ITS 3.6.2 CONTAINMENT AIR LOCKS DOC

! NO- SHEJ DISCUSSION l TS required actions, as well as other activities on TS related equipment or equipment required to support TS equipment (see TS bases for full description of note). The allowance to make a required containment entry l- under these circumstances is acceptable considering the low probability of L an event occurring that would pressurize the containment during the short period of time that the operable air lock door (required to be locked closed) is open for containment entry and exit. In addition, the allowance provided by this note may reduce the potential risk incurred during a plant transient (shutdown) that could result from the failure to perform a required activity on a TS related system inside containment.

5 M CTS 3/4.6.1.3 action statement a.1 and b are revised by the addition of a one hour time limit, consistent with the STS, in which to verify closed an air lock door. The addition of the one hour time limit to the CTS actions imposes a new restriction in the CTS. However, the one hour limitation is a reasonable time in which to accomplish the required action and ensures prompt verification of containment air lock isolation and is therefore applicable and appropriate for FNP. The addition of an explicit time limitation for these CTS actions is considered a more restrictive change.

6- A CTS 3/4.6.1.3 action statement' a.1 is revised by the deletion of the option to restore the inoperable air lock door to operable status. This change is made consistent with the STS. In the STS, restoration to operable status is always an option for any system or component and need not be specifically stated in every action. As this change does not introduce a technical revision to l; . the intent of the CTS and is made to conform with the format and

( presentation of this information in the STS, the change is considered administrative.

7 L CTS 3/4.6.1.3 action statement a.2 contains a requirement that limits continued operation with one air lock door inoperable until the performance of the next overall air lock leakage test. This limitation on continued operation with a single inoperable air lock door is deleted consistent with the STS, In the condition of one door inoperable and the operable door locked closed, the air lock remains capable of performing its intended safety function (containment isolation). In the STS, operation with a single air lock door inoperable is permitted to continue indefinitely provided the

~ Chapter 3.6 - E2-4-C March,1998 c-_--_ _ _ _ _ _ _ - - - _ - - - - - . - - _ _

63 FNP TS Conversion Enclosure 2 - Discussion of Changes to CTS Chapter 3.6 - Containment Sy:,tems CTS 3/4.6.1.3 CONTAINMENT AIR LOCKS FNP ITS 3.6.2 CONTAINMENT AIR LOCKS s

DOC NQ- SHE DISCUSSION 14 L The CTS 3/4.6.1.3 surveillance 4.6.1.3.b is revised consistent with the STS. 1 This CTS surveillance verifies the operation of the air lock door interlock mechanism every 6 months. The Frequency is revised to 24 months.

Typically, the air lock door interlock is installed after each refueling outage, verified operable with this surveillance and not disturbed until the next :

refueling outage. When an air lock is opened during times the interlock is required, the operator first verifies that one door is completely shut before 1 attempting to open the other door. Therefore, the interlock is not challenged except during actual testing of the interlock. Failure of this

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surveillance, which attempts to open the second door while the first door is -

not completely closed, effectively results in a loss of containment integrity.

Procedures and training do not allow this interlock to be challenged for ingress and egress. This surveillance is contrary to processes and training of conservative operation when the interlock function is required. Revising the Frequency to 24 months allows testing of the interlock during outage periods which avoids the potential for loss of containment operability if the 1 surveillance were performed with the reactor at power. This change is )

acceptable given the purely mechanical nature of this interlock, controls which are in place to ensure that the interlock is not challenged during power operation, and the fact that performing this surveillance during outage conditions avoids the potential for loss of containment operability if the surveillance were performed with the reactor at power.

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N FNP TS Conversion Enclosure 2 - Discussion of Changes to CTS Chapter 3.6 - Containment Systems I

CTS 3/4.6.1.7 CONTAINMENT VENTILATION SYSTEM FNP ITS 3.6.3 CONTAINMENT ISOLATION VALVES DOC NO EllE DISCUSSION .

allowed by the STS provides a more reasonable total time (24 hours2.777778e-4 days <br />0.00667 hours <br />3.968254e-5 weeks <br />9.132e-6 months <br />) to affect repairs on the leaking purge supply and exhaust isolation valves. The additional time is a sufficient restriction, given the low likelihood of an event occurring during this time that would challenge the containment boundary, the STS actions that specifically require additional leakage testing of the valves used to isolate the affected penetration, and the fact that the actions of STS LCO 3.6.1," Containment", ultimately become applicable ifleakage from a purge supply and exhaust penetration results in exceeding the overall containment leakage rate acceptance criteria (1.0 L,).

The actions of LCO 3.6.1 provide an appropriately conservative I hour completion time to restore leakage to within the overall containment limit assumed in the safety analysis. Purge supply and exhaust penetration leakage may cause the combined type B and C leakage to exceed the 0.6 L, limit but total containment leakage may still be below the overall containment leakage rate limit of 1.0 L, and therefore be within'the assumptions of the applicable safety analysis.

7 A The CTS 3/4.6.1.7 Action Statement b.1 is deleted consistent with the STS.

This CTS action statement requires that the containment purge supply and exhaust penetration leakage be restored to within the limit. In the STS, it is implicit in all actions that restoration to meet the requirements of the LCO is an always an option and therefore, STS actions typically do not explicitly require restoration to meet the LCO requirements. As such, the deletion of this explicit CTS restoration action is considered an administrative change made to conform with the presentation and format of this information in the STS.

8 M The CTS 3/4.6.1.7 Action Statement b.2 is revised consistent with the STS.

This CTS action requires that the affected containment purge supply and exhaust penetrations be isolated to reduce leakage to within the limit. The CTS requirement specifies the possible combinations of vr' ss to be used for isolating the affected penetrations. The CTS action is completely replaced by the STS LCO 3.6.3 Actions D.1, D.2, and D.3 for containment purge supply and exhaust penetrations exceeding the leakage limit. The STS action D.1 effectively requires the same remedial action (affected penetration be isolated) however the STS only specifies the minimum isolation requirement of at least one closed and deactivated automatic valve, Chapter 3.6 E2-3-G March,1998 t-_______--___.-._______

. 63 FNP TS Conversion L

l-Enclosure 2 - Discussion of Changes to CTS l- Chapter 3.6 - Containment Systems CTS 3/4.6.3 CONTAINMENT ISOLATION VALVES FNP ITS 3.6.'3 CONTAINMENT ISOLATION VALVES r DOC N_O SHE DISCUSSION penetration flowpath. This note conforms with the STS administrative l, conventions for Condition entry as described in Section 1.3, " Completion

' Times" of the STS. It is also consistent with the equivalent CTS actions

! - ("one or more" containment isolation valves may be inoperable). As such, the addition of this note is required for the administrative conventions of the STS and does not introduce a technical change.

Notes 3 and 4 provide guidance in determining when other applicable TS I

may be entered due to an inoperable containment isolation valve and/or excessive leakage. The STS format contains directions within certain TS for entering other related TS when applicable. The note is considered additional information contained in the STS to prompt the user when other TS may be applicable. The addition of Notes 2 and 3 is intended to provide guidance for the use of the STS only, and is not intended to introduce a technical change to the CTS.

1 4 A The CTS 3/4.6.3 action statement is revised consistent with Condition A of the STS. The term " penetration" is used consistently in STS 3.6.3, the penetration is what must be isolated to maintain containment integrity.

This term is used in the STS as a single penetration may have more than one flow path and multiple isolation valves on each' side of containment.

Therefore, the term flow path is also used to encompass all types of isolation valve / penetration variations. In addition, the action is revised to L clarify that it only applies when a single isolation valve in a penetration flow path is inoperable. Therefore, the CTS requirement to maintain an operable isolation valve in each affected penetration is no longer necessary l~ (the STS Condition only applies for one inoperable isolation valve) and has been deleted consistent with the STS. A statement is also added to the CTS action to exempt purge valve leakage. The STS contains a separate Condition to address the leakage of the purge supply and exhaust valves.

Note that changes affecting the purge supply and exhaust valve TS

! requirements are documented in CTS 3/4.6.1.7, " Containment Ventilation System". Therefore, changes made to the CTS action statement are required to conform with the presentation and format of this information in the STS and are considered administrative.

5. A The CTS 3/4.6.3 action statement is revised by the addition of a note Chapter 3.6 E2-2-J March,1998 E-- -___ - __ _ ____ _  :

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FNP Ts Conversion Enclosure 2 - Discussion of Changes to CTS l Chapter 3.7 - Plant Systems i i

CTS 3/4.7.1.2 AUXILIARY FEEDWATER SYSTEM J l

FNP ITS 3.7.5 AUXILIARY FEEDWATER (AFW) SYSTEM I doc i NO SHE DISCUSSION one AFW train is restored to operable status. The intent of the CTS and STS Action in this condition (no AFW operable) is to prevent placing the plant in a Mode where the AFW system would be required operable for heat removal. The addition of the STS note to this Action provides a clarification of the intent of this Action and assists in avoiding potential I conflicts within the TS that may cause the plant to be placed in a Mode where the AFW was required. The addition of this STS note is consistent {

with the intent of the CTS Action and conforms with the presentation and format of this information in the STS. Therefore, this change is considered administrative.

6 M The CTS surveillance 4.7.1.2.1 is revised consistent with the STS. This CTS surveillance requires that each AFW pump be demonstrated operable pursuant to Specification 4.0.5. The CTS surveillance is revised to replace the general reference to Specification 4.0.5 with a specific STS test acceptance criterion;" verifying the developed head of each AFW pump at the flow test point is 2 the required developed head". The CTS surveillance does not contain a direct reference to a specific acceptance criterion but relies on Specification 4.0.5 which in turn contains requirements for an Inservice Testing Program. The proposed STS acceptance criterion is consistent with standard industry pump testing methods and therefore is applicable to FNP. However, the addition of a specific test criterion in lieu of the existing reference to a testing program is considered a more restrictive change.

7 L CTS surveillance 4.7.1.2.1 is revised consistent with the format of the  :

corresponding STS surveillance. This surveillance requires that each AFW pump be demonstrated operable and contains an exception to Specification 4.0.4 for the turbine-driven pump to allow entry into Mode 3 for testing.

This exception is required to allow for adequate steam pressure to test the turbine-driven pump. The CTS exception to the provisions of 4.0.4 is replaced with a more specific note in the ITS surveillance SR 3.7.5.2 which j l allows a 72 hour8.333333e-4 days <br />0.02 hours <br />1.190476e-4 weeks <br />2.7396e-5 months <br /> delay in the requirement to perform this surveillance after J the time Tavg reaches 547 F. The proposed ITS note is consistent with the format and presentation of this information in the STS but contains FNP specific requirements (72 hours8.333333e-4 days <br />0.02 hours <br />1.190476e-4 weeks <br />2.7396e-5 months <br /> and 547 F). The current FNP exception to the provisions of Specification 4.0.4 does not contain a time limit or a l

l Chapter 3.7 E2-3-B March,1998 l ,

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FNP TS Conversion Enclosure 2 - Discussion of Changes to CTS Chapter 3.7 - Plant Systems 4

CTS 3/4.7.1.2 AUXILIARY FEEDWATER SYSTEM FNP ITS 3.7.5. AUXILIARY FEEDWATER (AFW) SYSTEM DOC N_O SHE- DISCUSSION specific steam pressure. Therefore, the proposed FNP specific requirements i for this exception are based on the TS Completion Time allowed to restore an inoperable AFW pump to operable status (72 hours8.333333e-4 days <br />0.02 hours <br />1.190476e-4 weeks <br />2.7396e-5 months <br />) and the current FNP

AFW turbine-driven pump surveillance test procedures which reference Tavg instead of SG pressure. The proposed 72 hours8.333333e-4 days <br />0.02 hours <br />1.190476e-4 weeks <br />2.7396e-5 months <br /> is reasonable considering that this time has already been determined to be acceptable for an inoperable AFW pump, and the fact that the most probable outcome of performing any surveillance is that the equipme~n t tested is found to be operable. As such, this is an appropriate time allowance for performing the initial operability verification of an AFW turbine-driven pump. The FNP specific initial test condition utilizing RCS temperature is acceptable based on the direct relationship between RCS temperature and SG pressure and the fact that operating experience has proven the current FNP test {

procedures adequate to verify the turbine-driven AFW pump performance. i

. Consistent with the STS, the proposed FNP ITS note does not restrict

. performance of the turbine-driven AFW pump to Mode 3 as does the CTS exception to Specification 4.0.4. As such, the adoption of the STS note format introduces a less restrictive change to the CTS requirements.

However, the proposed FNP ITS note restricts the time allowed before the surveillance must be performed. The time restriction provided by the note ensures the surveillance is performed in a timely manner (consistent with the TS time allowed to restore an otherwise inoperable AFW pump) and provides the required allowance to reach the plant conditions necessary to perform the turbine-driven AFW pump testing. The proposed change is made to conform with the format of the STS surveillance notes and includes requirements that provide a sufficient limit on plant operation to ensure the required equipment is maintained operable. Therefore, this change is acceptable.

8 A The CTS surveillance 4.7.1.2.1 is revised consistent with the STS by replacing the general reference to Specification 4.0.5. This CTS surveillance requires that each AFW pump be demonstrated operable pursuant to Specification 4.0.5. The CTS surveillance simply references Specification 4.0.5 for the acceptance criteria as well as the Frequency of the required testing. The STS provides a specific acceptance criterion (discussed previously) and a revised reference for the surveillance Chapter 3.7 E2-4-B March,1998

N FNP TS Conversion Enclosure 2 - Discussion of Changes to CTS

y. Chapter 3.7 - Plant Systems CTS 3/4.7.1.2 AUXILIARY FEEDWATER SYSTEM FNP ITS 3.7.5 AUXILIARY FEEDWATER (AFW) SYSTEM DOC' BLQ SHE DISCUSSION Frequency. As the STS no longer contains a Specification 4.0.5, the STS ~

specifies a Frequency in accordance with the Inservice Testing Program.

The STS specifies a Inservice Testing Program directly in the Administrative Controls section of the TS and does not use a specification -

corresponding to CTS 4.0.5. Since CTS 4.0.5 contains requiments regarding the Inservice Testing Program, which are applicable to the Frequency of the surveillance, the direct reference to the Inservice Testing Program in the Frequency of the STS surveillance is consistent with the CTS surveillance 4.7.1.2.1 requirements, Therefore, this change is made to conform with the presentation and format of this information in the STS and is considered an administrative change.

9 LA The CTS surveillance 4.7.1.2.2.a.1,2, and 3 are revised consistent with the STS. These 3 CTS surveillance verify valve positions every 31 days.

Each of the 3 CTS surveillance address different valves and contains specific requirements for those valves. The corresponding STS surveillance consists of a single surveillance that simply verifies all valves are in the correct position. Therefore, the CTS surveillance are revised to be a single surveillance which verifies all the AFW system valves are in the correct position. The specific valve position guidance c'ontained in the CTS surveillance 4.7.1.2.2.a.3 is moved into the bases for the proposed new SR 3.7.5.1. The description of the correct po_sition for the affected valvec will be contained in the bases discussion for the new single valve position surveillance. The placement of descriptive infonnation 'or guidance for .

performing a surveillance in the bases for the surveillance is consistent with the philosophy of the STS for this type of detail. Reliance on the information con _tained in the STS bases for guidance in performing the associated surveillance is acceptable since changes to the information in the b bases is controlled by the Bases Control Program specified in the

' administrative controls section of the TS.

9a A CTS surveillance ' 4.7.1.2.2.a.2 is revised to be in Su note format and included in STS SR 3.7.5.1. This CTS surveillance provision provides an exception for verifying the full open position of the AFW flow control valves when those valves are being used for controlling SG level during low power operation (less than or equal to 10% RTP) or when the AFW system is not in automatic control, such as when AFW pump testing is l

. Chapter 3.7 E2-5-B March,1998

(

3 FNP TS Conversion Enclosure 2 - Discussion of Changes to CTS 1 Chapter 3.7 - Plant Systems CTS 3/4.7.1.2 AUXILIARY FEEDWATER SYSTEM FNP ITS 3.7.5 AUXILIARY FEEDWATER (AFW) SYSTEM DOC NO SHE DISCUSSION restoration of a single inoperable steam line (7 days vs 3 days) is reasonable. The proposed Completion Time of 7 days is based on the availability of the redundant operable steam supply line, the availability of the redundant motor-operated AFW pumps, and the low probability of an event occurring during this time that would require the inoperable steam supply line. Therefore, this change is acceptable.

12 L The CTS surveillance 4.7.1.2.2.b is revised consistent with the STS. The CTS surveillance verifies the actuation of each automatic valve in the flow path. The corresponding STS surveillance limits the required automatic valve verifications to valves that are not locked, sealed, or otherwise secured in position. The CTS surveillance is revised to incorporate the STS automatic valve testing limitation. The allowance not to test such valves is based on the valves being fixed in the position required for the system to perform its intended safety ftmetion (automatic actuation is not required) and that valves locked, sealed or otherwise secured in position are subject to administrative controls which ensure the valve remains in the required position. Therefore, this change is acceptable.

13 LB The CTS surveillance 4.7.1.2.2.b and c are revised consistent with the STS. These surveillance include requirements to verify automatic component actuation upon receipt of specified test signals. The STS replaces " test signals" with " actual or simulated actuation signals". The CTS surveillance is revised consistent with the STS to provide the allowance to utilize a simulated or actual signal to verify the required automatic actuations. This change allows satisfactory automatic actuations (required equipment / system operation is verified) that occur due to an actual automatic actuation signal to fulfill the surveillance requirement.

Operability is adequately demonstrated in either case as the affected equipment or system cannot discriminate between an actual or simulated (test) signal. This change is considered less restrictive as it provides an alternate method to satisfy the surveillance requirement to verify automatic system actuation.

14 LA The CTS surveillance 4.7.1.2.2.b and c are revised consistent with the STS. These CTS surveillance contain requirements to verify automatic equipment actuations on specific test signals. The corresponding STS surveillance do not contain a list of specific signals and only refer to an Chapter 3.7 E2-7-B March,1998 E-__-----.--.-------_--------------------------- - - - - - l

FNP TS Conversion Enclosure 2 - Discussion of Changes to CTS  !

Chapter 3.7 - Plant Systems CTS 3/4.7.3 COMPONENT COOLING WATER SYSTEM FNP ITS 3.7.7 COMPONENT COOLING WATER (CCW) SYSTEM DOC

_N_Q SHE DISCUSSION 1 A The CTS 3/4.7.3 LCO statement is revised consistent with the STS. The term "at least"is deleted. As the intent of the LCO statement is to specify the minimum requirements, the descriptive phrase "at least" is redundant and unnecessary and is not used in the STS. The word " independent" describes a design feature of the system.~ The STS includes a sufficient description of the system design and related operability requirements in the bases and system design requirements are adequately maintained by existing QA/QC programs which are intended to control plant design and configuration. In addition, the TS also specify and control the electrical power supply operability and availability requirements for the CCW System. Therefore, the word " independent" is unnecessary and is also deleted from the LCO statement consistent with the STS. The CTS LCO statement is also revised by the use of the word " trains" in place of" loops".

This change is made to maintain consistency with the STS terminology in this and other TS. The STS terminology " trains" is consistent with the intent of the CTS LCO requirement for loops. The changes described above are considered clarifications and enhancements that do not introduce technical changes to the intent of the CTS or affect plant design, and are made to conform with the presentation and format of this information in the STS. Therefore, these changes are considered administrative.

2 A The CTS 3/4.7.3 Action statement is revised consistent with the STS. The terminology and phrasing used in the CTS is revised and the Action statement is divided into 2 Action Conditions. These revisions do not introduce technical changes to the intent of the CTS, and are made to i conform with the presentation and format of this information in the STS.

Therefore, these changes are considered administrative.

3- M The CTS 3/4.7.3 Action statement is revised consistent with the STS. A note is added to the CTS Actions that requires entry into the applicable Conditions and Required Actions of LCO 3.4.6,"RCS Loops Mode 4" for

l. RHR loops made inoperable by CCW LCO 3.4.6 contains Actions L Conditions to address various combinations ofinoperable RCS and RHR l loops and requires immediate action be taken. If the RHR loop affected by ]

the inoperabb CCW train was required operable to meet LCO 3.4.6, then the note requires that the applicable Action Condition of LCO 3.4.6 he 3 entered. If the RHR loop affected by the inoperable CCW train was not V \

Chapter 3.7 E2-1-G March,1998 I

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$ FNP TS Conversion Enclosure 2 - Discussion of Changes to CTS Chapter 3.7 - Plant Systems CTS 3/4.7.4 SERVICE WATER SYSTEM FNP ITS 3.7.8 SERVICE WATER SYSTEM (SWS)

DOC' NO. SHE . DISCUSSION Therefore, these changes are considered administrative.

4. M The CTS 3/4.7.4 Action statement is revised consistent with the STS. Two notes are added to the CTS Actions that require: 1) Entry into the applicable Conditions and Required Actions of LCO 3.8.1,"AC Sources-Operating,"

for the emergency Diesel Generator (DG) made inoperable by the SWS and,

2) Entry into the applicable Conditions and Required Actions of LCO 3.4.6, "PCS Loops Mode 4" for RHR loops made inoperable by SWS. LCO 3.8.1 contains Actions Conditions applicable to the DGs required operable. LCO 3.4.6 contains Actions Conditions to address various combinations of inoperable RCS and RHR loops and requires immediate action be taken. If the RHR loop affected by the inoperable SWS train was required operable to meet LCO 3.4.6, then the note requires that the applicable Action Condition of LCO 3.4.6 be entered. If the RHR loop affected by the inoperable SWS train was not used to meet LCO 3.4.6, there is no applicable Condition in LCO 3.4.6 to enter. The STS note provides support / supported system guidance required due to the immediate actions of the RCS LCO and the DG Actions which address the potential for a loss of safety function. This additional guidance is necessary since the STS includes LCO 3.0.6 which precludes entering a supported system TS unless

. specifically directed by the support system LCO. Although consistent with i the operability requirements of the RHR system and DGs at FNP, this additional TS requirement was not previously specified in the FNP TS.

Therefore, the addition of these notes is considered more restrictive. ,

I l

5 Not used.

6 LA The CTS surveillance 4.7.4.b is revised consistent with the STS. The CTS surveillance verifies the actuation of automatic SWS valves on a Safety injection test signal. The CfS surveilhnce statement contains a requirement that the surveillance be performed "during shutdown" and L specifies the signal being tested as " Safety Injection." In the STS, the 18 month frequency is typically used when the surveillance must be performed during shutdown conditions. The corresponding STS surveillance bases f

discussion contains a discussion of the 18 month frequency and describes it I' as based on the need to perform this surveillance under the conditions that apply during a unit outage. Therefore, the CTS surveillance qualification of

. Chapter 3.7 E2-2-H March,1998 f.

/oI FNP TS Conversion Enclosure 2 - Discussion of Changes to CTS Chapter 3.7 - Plant Systems CTS 3/4.7.4 SERVICE WATER SYSTEM FNP ITS 3.7.8 SERVICE WATER SYSTEM (SWS)

DOC

_N_O SHE DISCUSSION reasonable considering the fact that the affected valves are secured in the position required to perform their intended safety function and no automatic actuation is required. In addition, the position of valves locked, sealed or otherwise secured in position is administratively controlled and verified in accordance with existing key / lock control, tagging, or other applicable valve position / alignment procedures.

9 M CTS 3/4.7.4 is revised consistent with the STS by the addition of a surveillance requirement to verify automatic SWS pump start. Although, the SWS pump auto start function is currently tested as part of ESF actuation surveillance tests performed at FNP, placing a specific surveillance requirement for this testing in the SWS TS identifies the applicable equipment LCO supported by this test requirement. In addition, this change is consistent with the STS organization of testing requirements j and places all the SWS system requirements in the same TS. However,  !

since this change adds a specific test requirement that did not previously exist within the TS, it is considered a more restrictive change.

10 L The CTS surveillance 4.7.4.a is revised consistent with the STS. This j surveillance verifies that SWS valves that are not locked, sealed, or otherwise secured in position that are in the flow path servicing safety- '

related equipment are in the correct position. The surveillance is performed every 31 days. The surveillance is modified by the addition of an STS note which provides guidance regarding the isolation of SW to individual components. The STS note clarifies that the SWS is not {

rendered inoperable by the isolation of flow to individual components. The  !

addition of the STS note w reasonable and acceptable considering that the isolation ofindividual con ponents from the SWS reduces the heat load and flow requirements on the SWS which does not render the system inoperable and the fact that the definition of operability would require the isolated components without required cooling water to be considered inoperable.  !

The SWS is still capable of performing its intended safety function for the remaining operable components it services and individual TS requirements including LCO 3.0.6 and the Safety Function Determination Program in Section 5.0 address the inoperable supported components and provide the appropriate actions for those components. The isolation ofindividual components does not prevent the SWS from performing its safety function l

l Chapter 3.7 E2-4-H Mareh,1998 L_ _ >

/ o ~2 FNP TS Conversion Enclosure 2 - Discussion of Changes to CTS

,_ Chapte.t 3.7 - Plant Systems CTS 3/4.7.4 SERVICE WATER SYSTEM FNP ITS 3.7.8 SERVICE WATER SYSTEM (SWS)

DOC NLQ - SHE DISCUSSION for the remaining components serviced, however, isolation of the valves to those components results in a failure to meet the SWS valve position surveillance (CTS 4.7.4.a.). Therefore, the addition of this note also provides a necessary exception to SR 3.0.1 which states that failure to meet an SR constitutes failure to meet the LCO.

11 L The CTS 3/4.7.4 SWS Actions are revised by the addition of a new FNP

, specific Actions Condition B. This FNP specific Action is not included in l- the corresponding STS Actions and is intended to address an FNP specific -

. design feature not previously included in the TS. The FNP specific Action

! addresses the condition where one automatic SWS turbine building

( isolation valve is inoperable in each train of SWS. The FNP SWS design includes two redundant automatic turbine building isolation valves in series configuration in each SWS train. The valves close automatically on an SI L

signal to isolate the turbine building SWS loads and ensure adequate SWS

l. flow to essential components. . When one or two of these valves becomes )

inoperable in a single SWS train, the SWS surveillance (CTS 4.7.4.b) for verification of automatic valve actuation is not met for the affected automatic valve (s) and the associated SWS train may be declared 1 inoperable. However, when two of these automatic isolation valves become inoperable, one in each train of SWS, the Actions do not contain a

Condition in the CTS or STS that would be applicable and therefore, an entry into LCO 3.0.3 may be made. However, entering LCO 3.0.3 in this l

! condition would be overly conservative considering that there are two L automatic turbine building isolation valves in each SWS train and that in i this condition one automatic valve in each SWS train still remains fully j operable. In addition, two 100% capacity SWS remain available to provide j the required system safety function. Therefore, the isolation function performed by these valves is not lost and each SWS train remains capable j of performing its intended safety function, only the reliability of the turbine i building isolation function in each SWS train is affected, and entry into LCO 3.0.3 is not appropriate under these circumstances. As such, this design feature of the FNP SWS is not adequately addressed in either the {

CTS or the STS and requires an FNP specific Actions Condition to provide i an appropriate re::toration time. The proposed FNP Condition B, for one inoperable automatic turbine building isolation valve in each SWS train,  ;

requires that both inoperable valves be restored to operable status in 72 l 1

Chapter 3.7L E2-5-H March,1998

/o3 FNP TS Conversion Enclosure 2 - Discussion of Changes to CTS Chapter 3.7 - Plant Systems CTS 3/4.7.4 SERVICE WATER SYSTEM

. FNP ITS 3.7,8 SERVICE WATER SYSTEM (SWS)

DOC-NQ SHE DISCUSSION hours. The Completion Time of 72 hours8.333333e-4 days <br />0.02 hours <br />1.190476e-4 weeks <br />2.7396e-5 months <br /> is reasonable considering that the function performed by these valves is not lost in either SWS train (one automatic turbine building isolation valve in each train remains operable),

the fact that there are two 100% capacity SWS trains available to perform the required safety function of the system, and the low likelihood of an event occurring during this time that would require the isolation function provided by these valves. However, the reliability of the isolation function perfomied by the automatic turbine building isolation valves is reduced.

The 72 hour8.333333e-4 days <br />0.02 hours <br />1.190476e-4 weeks <br />2.7396e-5 months <br /> Completion Time places an adequate limit on plant operations to compensate for the reduced reliability of the turbine building isolation function and to ensure that the system is returned to full operability or the plant placed in a condition where this isolation function is no longer required in a timely manner. The addition of this FNP specific SWS Actions Condition is acceptable based on the redundant design of the-automatic turbine building isolation function in each SWS train, the fact that such a design feature is not currently addressed in the technical specifications, and to prevent an unwarranted entry into LCO 3.0.3 resulting in an unnecessary plant shutdown.

12 LA The FNP specific CTS surveillance 4.7.4 is revised to improve the accuracy and clarity of the surveillance and make it more consistent with similar l surveillance in the STS. This surveihance verifies the integrity of the L buried SW system piping by performing a visual inspection of the surrounding ground area. The descriptive terminology " leak tight" is removed from this surveillance and placed in the associated bases for FNP ITS SR 3.7.8.4. The revision of this surveillance eliminates prescriptive detail and clarifies the intent of the surveillance. The placement of this information in the bases is consistent with the format and presentation of l sirailar information in the STS. In addition, the movement of this information to the bases is acceptable due to tl e level of control provided by the Bases Control Program in the Administrative Controls section of the TS.

Chapter 3.7 E2-6-H March,1998 f

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/6- FNP TS Conversion Enclosure 2 - Discussion of Changes to CTS Chapter 3.7 - Plant Systems CTS 3/4.7.7.1 CONTROL ROOM EMERGENCY FILTRATION / PRESSURIZATION SYSTEM (CREFS)

FNP ITS 3.7,10 CONTROL ROOM EMERGENCY FILTRATION / PRESSURIZATION SYSTEM (CREFS)

DOC" NQ SHE DISCUSSION 1 L The CTS 3/4.7.7.1 applicability is revised consistent with the guidance provided in the STS. The applicability of the CREFS LCO is revised to eliminate Modes 5 and 6 and add Core Alterations. In addition, the associated CTS Action statements are revised to reflect the applicable Mode changes. The revised CREFS applicability is Modes 1-4, during movement ofirradiated fuel, and during Core Alterations. The removal of Modes 5 and 6 from the FNP applicability is consistent with the description of this applicability in the bases of the STS CREFS LCO, FNP design, and the applicable FNP safety analysis. In the applicability section of the STS bases, the requirement to have CREFS operable in Modes 5 and 6 is based on a waste gas decay tank rupture analysis for a plant design that includes outside waste gas decay tanks. The FNP waste gas decay tanks are inside the auxiliary building and the control room air intake is from outside the l

' building. In addition, the waste gas decay tank rupture analysis, as {

described in FNP FSAR 15.3.5, takes no credit for any plant filtration or {

ventilation system. For FNP, the CREFS design basis accident of concem l in Modes 5 and 6 is a fuel handling accident. The Applicabilities of movement ofirradiated fuel and Core Alterations address the plant conditions when the potential for a fuel handling accident exists and require the CREFS operable during those conditions independent of an operating Mode. Therefore, the deletion of Modes 5 and 6 is acceptable considering the CREFS applicability (during movement ofirradiated fuel assemblies and Core Alterations) is consistent with the applicable design basis accident assumptions for the FNP CREFS, 2 L The CTS 3/4.7.7.1 applicability is revised consistent with the STS by the deletion of" movement ofloads over irradiated fuel".

The Spent Fuel Storage Pool Building Bridge Crane is the only crane with i - the potential to move loads over the stored fuel in the spent fuel pool. ,

However, the fuel storage racks are designed to withstand a bounding load  !

drop without damaging the stored fuel as described in FSAR section 9.1.2.3. Crane operations over the spent fuel pool are prevented from exceeding the analyzed limit by administrative controls in compliance with

' NUREG-0612. The administrative controls required to be implemented by  !

j Chapter 3.7 E2-1-J March,1998 i

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! FNP TS Conversion Enclosure 2 - Discussion of Changes to CTS Chapter 3.7 - Plant Systems

)

CTS 3/4.7.7.1 CONTROL ROOM EMERGENCY FILTRATION / PRESSURIZATION SYSTEM (CREFS)

FNP ITS 3.7.10 CONTROL ROOM EMERGENCY FILTRATION / PRESSURIZATION SYSTEM (CREFS)

DOC NLQ SHE DISCUSSION 12 A The "+" footnote to CTS surveillance 4.7.7.1.d.4 is deleted. This footnote provides a specific time for the completion of the mechanical heater testing required by ASME N510-1989. This footnote will no longer apply after its stated deadline of the unit i 15th refueling outage scheduled for the fall of 1998. As this note will expire before the FNP ITS is implemented, it is deleted from the FNP ITS version of this LCO. The deletion of this expired note from the FNP ITS LCO is considered an administrative change to remove text that is no longer applicable.

2 i

Chapter 3.7 E2-7-J March,1998 u_ = __ __ - ___-___ -___ ____ _ ______- ___ ____ _________ . _ _ _ . _ _ - _ _ _ _ . _ _ _ _ _ .__ . ___ _____ __ __-_ ___ _ ____-___.

/I3 FNP TS Conversion Enclosure 2 - Discussion of Changes to CTS I Chapter 3.7 - Plant Systems CTS 3/4.7.7.2 CONTROL ROOM AIR CONDITIONING SYSTEM (CRACS)

FNP ITS 3.7.11 CONTROL ROOM AIR CONDITIONING SYSTEM (CRACS)

DOC ,

NO SILE DISCUSSION 1 L- The CTS 3/4.7.7.2 applicability is revised consistent with the guidance provided in the STS. The applicability of the CRACS LCO is revised to j eliminate Modes 5 and 6 and add during Core Alterations. In addition, the  !

associated CTS Action statements are revised to reflect the applicable Mode changes. The revised CRACS applicability is Modes 1-4, during movement ofirradiated fuel, and during Core Alterations. The removal of Modes 5 and 6 from the FNP applicability is consistent with the description

)

of this applicability in the bases of the STS CREFS and CRACS LCOs, FNP design, and the applicable FNP safety analysis. The FNP CRACS is required to support operation of the CREFS recirculation filtration subsystem and provide control room cooling when the control room ventilation is in the emergency filtration / pressurization mode of operation.

In the applicability section of the STS bases, the requirement to have CREFS operable in Modes 5 and 6 and therefore the requirement for CRACS to be operable in these Modes, is based on a waste gas decay tank rupture analysis for a plant design that includes outside waste gas decay tanks. The FNP waste gas decay tanks are inside the auxiliary building and the control room air intake is from outside the building. In addition, the waste gas decay tank rupture analysis, as described in FNP FSAR 15.3.5, takes no credit for any plant filtration, ventilation, or air conditioning -

system. For FNP, the CREFS and CRACS design basis accident of concern in Modes 5 and 6 is a fuel handling accident. This is the only design basis accident in these Modes that assumes operation of the CREFS and therefore requires operation of the CRACS. The Applicabilities of movement of irradiated fuel and Core Alterations address the plant conditions when the potential for a fuel handling accident exists and require the CREFS and CRACS operable during those conditions independent of an operating Mode. Therefore, the deletion of Modes 5 and 6 is acceptable considering ,

the CREFS and CRACS applicability (during movement ofirradiated fuel assemblies and Core Alterations) is consistent with the applicable design l basis accident assumptions for the FNP CRACS.

2 L The CTS 3/4.7.7.2 applicability is revised consistent with the STS by the j deletion of" movement ofloads over irradiated fuel".

l The Spent Fuel Storage Pool Building Bridge Crane is the only crane with the potential to move loads over the stored fuel in the spent fuel pool.

. Chapter 3.7 - E2-1-K March,1998

Farley Nuclear Plant ITS Conv:rsion Submittal - Electronic Copy l Revised DOCS r

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Revised DOCS (Section 3.8)

)

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f k ,

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$2-- FNP TS Conversion l Enclosure 2 - Discussion of Changes to CTS l f Chapter 3.8 - Electrical Power Systems l

l l

CTS 3/4.8.1.1 AC SOURCES - OPERATING l

l FNP ITS 3.8.1 AC SOURCES - OPERATING DOC NLQ SHE DISCUSSION

1 A The CTS 3.8.1.1 LCO statement (parts a and b) is revised consistent with l the STS. Typical changes eliminating unnecessary phrases containing "as a minimum" and " independent" are implemented in this LCO as in other CTS  ;

LCOs. LCOs only specify the minimum requirements and the STS bases i describes in detail the operability requirements for the equipment specified in the LCO. The STS term "qt.alified"(meaning 10 CFR 50, Appendix A, l GDC 17 qualified) is used in the LCO and effectively replaces the CTS descriptions regarding independent and redundant power supplies. This is further described in the STS bases. An STS phrase describing the DG capability is added to the CTS LCO statement consistent with the similar description for the offsite circuits. The revisions described above and other editorial changes made to the CTS LCO statement are not intended to introduce technical changes and are considered administrative changes  ;

made to conform with the format and presentation of this information in the STS.

2 LA The CTS 3.8.1.1 LCO statement description of"DG Set" is moved to the i l

bases consistent with the treatment of descriptive text in the STS. The LCO requirement remains the same, that is, two DG sets are required operable. l What constitutes an acceptable DG set is explained in the bases. Reliance on the information contained in the STS bases for guidance in applying the associated LCOs is acceptable since changes to the information in the bases i is controlled by the Bases Control Program specified in the administrative j controls section of the TS.

2a M The CTS 3.8.1.1 LCO statemer is revised consistent with the  ;

corresponding STS LCO 3.8.1 Ly the addition of LCO item c. LCO item c '

adds the operability requirement for the train A and train B autamatic load sequencers. This STS requirement for the operability of the automatic load sequencers is required for plants with an electrical system design that requires the sequencer to be operable to support both the DG and the offsite circuit associated with that train. If the sequencer was required solely to l

support the associated DG, an inoperable sequencer would result in an inoperable DG and no separate LCO requirement to distinguish the sequencer operability would be necessary. The FNP electrical system is 7

I designed such that the sequencer is required to sequence loads on the DG when no offsite power is available. In addition, when offsite power is Chapter 3.8 E2-1-A March,1998

i Farley Nuclear Plant ITS Conversion Submittal- Electronic Copy i

Revised DOCS Revised DOCS (Section 3.9) i i

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1 28 FNP TS Conversion l

Enclosure 2 - Discussion of Changes to CTS j Chapter 3.9 - Refueling Operations l

CTS 3/4.9.2 INSTRUMENTATION )

l FNP ITS 3.9.2 NUCLEAR INSTRUMENTATION

! DOC -

N_O SHE DISCUSSION l 5 A The CTS Action statement (c) regarding the provisions of specification 3.0.3 being not applicable is deleted consistent with the STS. This statement is no longer required as the STS LCO 3.0.3 clearly states that it is only applicable in Modes 1 through 4. This change is administrative made l to conform with the STS format and presentation of this information.

6 L The CTS Channel Functional Test requirements of 4.9.2.b and c for the source range neutron flux monitors are deleted and a Channel Calibration '

requirement is added. This change is consistent with the STS and adds the normal STS Channel Calibration for nuclear instrumentation (including the i

note excepting the neutron detectors). In Mode 6, the source range )

monitors are required for indication only, there are no required setpoints )

associated with these instruments in this Mode. In this capacity, the source range instrumentation is typically used to read or hear a change in counts per second (CPS) relative to previous readings, not precise CPS indication.

The source range instrumentation is monitored for significant changes in count rate which are important to evaluate the change in core status. Even the accepted convention defining criticality only requires a slowly increasing count rate be verified. Consistent with the STS, indicating i instruments require Channel Checks and Channel Calibrations. The more frequent COTS are applied only to those channels with required operational interlocks or setpoint actuations. In Modes 1,2, and 3, the source range monitors perform required actuation functions and quarterly COTS are required for the source range monitors in those Modes. In addition, the 18 month Channel Calibration and the 12 hour1.388889e-4 days <br />0.00333 hours <br />1.984127e-5 weeks <br />4.566e-6 months <br /> Channel Check are typically all that is required for indicating instruments and have proven effective in maintaining those instruments operable. Therefore, the proposed Mode 6 STS Channel Calibration and existing Channel Check requirements for the source range monitors are adequate to assure their operability, considering the more frequent COTS performed on this instrumentation in other Modes, the effectiveness of these surveillance requirements in maintaining other l

indicating instruments operable, and the accuracy required of these instruments in Mode 6.

7 M A Channel Calibration surveillance requirement is added to CTS 3/4.9.2 consistent with the STS. The new surveillance is required to be performed every 18 months. As the previously required Channel Functional Tests are l

Chapter 3.9 E2-3 B March,1998 i

A______-_____________-_-____________________ . _ _ _ _ _

S FNP TS Conversion Enclosure 2 - Discussion of Changes to CTS

, Chapter 3.9 - Refueling Operations CTS 3/4.9.8,1 RESIDUAL HEAT REMOVAL AND COOLANT CIRCULATION - ALL WATER F.EVELS l

FNP ITS - 3.9.4 RESIDUAL HEAT REMOVAL AND COOLANT CIRCULATION - HIGH I WATER LEVEL DOC NQ SHE DISCUSSION 1 A The title and applicability of CTS 3/4.9.8.1 are revised consistent with the STS. The phrase "high water level" replaces "all water levels" in the title and the applicability is revised to add "with the water level greater than or equal to 23 feet above the reactor vessel flange" to Mode 6. This revision is consistent with the bases for the CTS. When the water level is equal to or greater than 23 feet above the reactor vessel flange a large heat sink is available for core cooling and adequate time exists to restore cooling if the single required RHR loop fails. Since CTS 3.9.8.2 (Low water level) is applicable when the water level is less than 23 feet above the reactor vessel flange and requires two RHR loops in operation, the appropriate applicability for CTS 3.9.8.1 (one RHR Loop required) is "with the water level equal to or greater than 23 feet above the reactor vessel flange". The incorporation of this change provides a clear separation between the Applicabilities of the two RHR Loop TS based on water level but will not )

introduce a technical change to the current applicable requirements (additional changes required to conform with the STS are made to CTS 3/4.9.8.2 to facilitate the independence of these two TS and address the "all water levels" requirement of CTS 3/4.9.8.1). This revision conforms with the STS, is consistent with the CTS bases, will not ir.troduce a technical change, and clarifies the applicability of these TS. As such, this change is considered administrative.

2 M The LCO statement of CTS 3/4.9.8.1 is revised consistent with the STS to include the requirement for the RHR Loop to be operable as well as in l operation. The inclusion of the requirement tc be operable is consistent with the intent of the CTS requirement but was not explicitly stated in the LCO. The additien of" operable"in the LCO explicitly invokes the TS definition for operability. As such, the proposed change is considered more restrictive.

3 A The CTS action statement "a" requirement to suspend all operations

( involving an increase in the decay heat load is replaced with the STS requirement to suspend loading irradiated fuel assemblies in the core. This revision provides a more specific action for the operators and addresses the

( only significant method by which the decay heat load may be increased in Chapter 3.9 E2-1-1 March,1998

I d7 FNP TS Conversion Enclosure 2 - Discussion of Changes to CTS Chapter 3.9 - Refueling Operations i

CTS 3/4.9.10.1 - WATER LEVEL - REACTOR VESSEL - FUEL ASSEMBLIES FNP ITS - 3.9.6 - REFUELING CAVITY WATER LEVEL DOC

_N_O SHE DISCUSSION represents a more restrictive action is appropriate for FNP. ]

l 7 A The CTS 3.9.10.1 action statement regarding the provisions of specification 3.0.3 being not applicable is deleted consistent with the STS. This statement is no longer required as the STS LCO 3.0.3 clearly states that it is only applicable in Modes 1 through 4. This change is administrative made to conform with the STS format and presentation of this information.

8 M The action to suspend Core Alterations immediately is added to the CTS 3.9.10.1 action statement consistent with the STS. The addition of the l defined term Core Alterations in the applicability expands the applicability to include the movement of control rods (except for latching and j unlatching), fuel, sources, er other reactivity control components within the reactor vessel with the vessel head removed and fuel in the vessel. The addition of the corresponding new action to suspend Core Alterations is consistent with the revised applicability. Since the movement of control rods in the vessel is considered a Core Alteration, the action to suspend Core Alterations effectively incorporates the action of CTS 3.9.10.2 (control rods) into the FNP ITS LCO 3.9.6 and eliminates the need for a second water level LCO for control rods. Additionally, the new action to suspend Core Alterations effectively covers the CTS 3.9.10.1 requirements regarding movement of new fuel over the vessel where it could potentially cause a design basis accident (failure of an irradiated fuel assembly). Thus, in this regard, the proposed change is consistent with the FNP design basis accident analysis and current licensing basis. However, the introduction of this action statement is new and may potentially affect additional aspects of operation. Therefore, this change is considered more restrictive.

9 L The CTS surveillance requirement 4.9.10.1 is revised consistent with the STS. The requirement to verify the level 2 hours2.314815e-5 days <br />5.555556e-4 hours <br />3.306878e-6 weeks <br />7.61e-7 months <br /> prior to entering the Mode of Applicability is deleted. The general rules of use and applicability for TS (specifically SR 3.0.4) require that all surveillance requirements be successfully met and current prior to entering the Mode of Applicability.

In this case, the refueling cavity water level would have to be verified within the required limit within 24 hours2.777778e-4 days <br />0.00667 hours <br />3.968254e-5 weeks <br />9.132e-6 months <br /> prior to entering the Mode of l

Applicability for this LCO. Since the general rules for TS require that the water level be verified prior to entering the Mode of applicability, and the I

Chapter 3.9 E2-3-L March,1998

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h FNP TS Conversion Enclosure 2 - Discussion of Changes to CTS j l Chapter 10,11, and 12 )

i CTS 3/4.11.2.5 WASTE GAS MONITORING FNP ITS - N/A

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DOC NQ SHE DISCUSSION

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j 1 LA CTS 3/4.11.2.5, Waste Gas Monitoring, is removed from the TS consistent with the content of the STS. This CTS contains requirements for the concentration of oxygen and hydrogen in the gaseous radwaste treatment system. In the STS, the requirement to maintain controls on the concentration of oxygen and hydrogen (explosive gases) is addressed by the Administrative Controls Program for Explosive Gas and Storage Tank Radioactivity Monitoring in Section 5.0 of the STS. The STS Program specifies controls to limit potentially explosive gas mixtures contained in the Waste Gas Holdup System and that a surveillance program be maintained to ensure the limits are met. CTS 3/4.11.2.5, contains the ,

specific limits on the concentration of oxygen and hydrogen gas in the gaseous radwaste treatment system and the surveillance necessary to ensure the limits are not exceeded. Therefore, CTS 3/4.11.2.5'is proposed i to be added to the FNP Explosive Gas and Storage Tank Radioactivity 1 Monitoring Program which will be contained in the FNP Technical j Requirements Manual (TRM). The CTS requirements for explosive gas concentrations will be moved into the TRM program without introducing a technical change to the requirements specified in CTS 3/4.11.2.5. Placing CTS 3/4.11.2.5 in the TRM is acceptable since changes to the requirements contained in the TRM will be controlled in accordance with 10 CFR 50.59.

In addition, the Explosive Gas and Storage Tank Radioactivity Monitoring Program specified in the administrative controls section of the TS provides additional controls on the CTS 3/4.11.2.5 requirements contained in the TRM.

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l 26 FNP TS Conversion Enclosure 2 - Discussion of Changes to CTS j Chapter 4.0 - Design Features CTS 5.0 DESIGN FEATURES FNP ITS 4.0 DESIGN FEATURES DOC l N_O SHE DISCUSSION the STS.

8 A CTS 5.6.1.1.c, d, and e are revised consistent with the STS. Descriptive terms (fuel assemblies and storage racks) are added to conform with the statements in the STS. As these changes merely add descriptive material to the existing material in the CTS, and do not change the meaning of the  ;

statements, they are considered administrative changes made to conform with the presentation and format of this material in the STS.

9 A CTS 5.6.1.1.g is revised by the addition of the words " Unit I only" prior to the statement concerning damaged fuel assembly storage. Since the FNP ITS will be a single volume, applicable to both Units, this addition is  ;

i necessary to clarify that damaged fuel is only stored in the Unit I spent fuel pool. As this change is only made to allow combining the Unit TS and identifying the differences between the Units, and introduces no technical change to the CTS, it is seen as an administrative change.

10 A CTS 5.6.1.2.c. I and 2 are renumbered and reworded to conform with the format and presentation of the information in the STS. The term

" maximum nominal" is moved into the statements concerning the fuel weight percent in the new fuel storage pits thereby allowing the deletion of the leading phrase "A maximum nominal enrichment of:". The descriptive name " Westinghouse" is deleted. This information is contained in numerous places in the FSAR (Chapters 4.0,15.0, etc.). Deletion of such information is consistent with the philosophy for placement of descriptive or detailed information in the STS. In addition, reliance on the FSAR content is acceptable based on the fact that changes to this information will be controlled, as are all changes to the FSAR, via the 10 CFR 50.59 process.

11 LA CTS 5.7, Component Cyclic or Transient Limit, is removed from the Design features section of the TS consistent with the content of the STS.

This CTS specification requires that the components identified be maintained within the limits identified for each component. The i requirement to maintain these components within the required limits is i retained in the FNP ITS, consistent with the STS, as an Administrative Controls Program 5.5.5, Component and Cyclic or Transient Limit. The f

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9 FNP TS Conversion Enclosure 2 - Discussion of Changes to CTS Chapter 5.0 - Administrative Controls L

CTS 6.0 ADMINISTRATIVE CONTROLS i

l FNP ITS 5.0 ADMINISTRATIVE CONTROLS DOC NO SHE DISCUSSION restriction regarding the STA in the note to Table 6.2-1 is deleted. This change is reasonable considering that the STS still requires the designated individual to hold an active SRO license (except in Modes 5 and 6) and the fact that the allowance for an RO or STA to replace the SS is only applied i on a temporary basis, and for the RO, only in Modes 5 and 6. Furthermore, j the allowance for an RO to replace the SS in Modes 5 and 6 is acceptable j because the level of training required for an RO is very close to that required for an SRO, the small likelihood of a severe event occurring due to the reduced temperature and pressure conditions present in Modes 5 and 6, and the fact that the reactor is shutdown and the plant is in a more stable condition. As such, the STS allowances for temporarily replacing the SS

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are reasonable and acceptable for FNP as well. Finally, CTS 6.1.2 is

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revised to eliminate the specific job title of" Shin Supervisor". This change l will eliminate the need for nonessential technical specification changes due l to organizational orjob title changes. As the proposed change still requires an individual with a SRO license to be responsible for the control room command function and specifies the requirements of those individuals which can assume this function in the absence of the responsible SRO, this change is acceptable.

3 A CTS section 6.2.1 paragraphs a-d are revised editorially to conform with the i STS. Minor changes are made to paragraphs a-d which do not impact the I technical requirements of the CTS. These changes are made solely to conform with the STS and are considered administrative changes.

4 A The title of CTS . sections 6.2.2 and 6.3, are revised consistent with the STS.

The STS uses the term " Unit" instead of" Facility". In addition, the STS includes a lead in sentence to this section of the TS which introduces the following items in the section. These changes are necessary to conform with the STS format and presentation of this information and are not intended to revise the technical requirements of the CTS. Therefore, these changes are considered administrative.

5 LA CTS section 6.2.2.a of Facility Staffis removed and replaced with the staffing requirements for non-licensed operators consistent with the STS.

CTS section 6.2.2.a references Table 6.2-1 for the operating shin crew Chapter 5.0 E2-2-A March,1998

~~1 l FNP TS Conversion i Enclosure 2 - Discussion of Changes to CTS Chapter 5.0 - Administrative Controls CTS 6.0 ADMINISTRATIVE CONTROLS FNP ITS 5.0 ADMINISTRATIVE CONTROLS DOC hQ SHE DISCUSSION composition requirements. In the STS, there is no corresponding Table to CTS Table 6.2-1. The STS includes specific provisions for the non-licensed shift crew members (ITS 5.2.2.a and g) as well as the minimum i l

requirements for licensed operators (5.2.2.b) and references the appropriate Federal Regulations which mandate the staffing requirements for licensed operators (ITS 5.2.2.c). CTS Table 6.2-1 contains information redundant to the existing federal regulations for licensed operator staffing requirements and the provisions of STS 5.2.2.a, b, c, and g. The elimination of Table 6.2-1 and all references to it in the Facility Staff section are acceptable considering that the requirements for licensed operator staffing is addressed by 10 CFR 50.54 (k)(1) and (m), and STS 5.2.2.b and the non-licensed staff I requirements are retained in STS 5.2.2.a and g. These changes conform with the format and presentation of this information in the STS.

6 A A new paragraph e is added under CTS 6.2.2 Facility Staff consistent with the STS. The new paragraph contains an exception to the shift crew composition that was previously specified in CTS Table 6.2-1 CTS Table 6.2-1 is replaced by specific STS sections (5.2.2.a and g) or reference to the appropriate Federal Regulations. The new paragraph contains an exception to the required shift crew composition applicable for up to two hours to accommodate unexpected absences. The ITS paragraph 5.2.2.c is not new.

This exception corresponds to the CTS exception on page 6-5 which is associated with the deleted Table 6.2-1. The CTS shift crew exception is revised to address the deletion of CTS Table 6.2-1 and the new paragraph c references the appropriate ITS section (5.2.2.a and g) for nonlicensed staff and the appropriate Federal Regulation for licensed staff requirernents. The inclusion of this STS paragraph does not introduce a technical change to the CTS requirements and is necessary due to the format and presentation of this information in the STS (no Table 6.2-1). Therefore, this change is

l. considered administrative.

l 7 A CTS paragraph 6.2.2.b which specifies additional requirements regarding licensed operators is revised consistent with the CTS requirements for senior reactor operators (SROs) in Table 6.2-1. In the STS, there is no corresponding Table to CTS Table 6.2-1. The requirements for SRO Chapter 5.0 E2-3-A March,1998 L --- - -_-- - _ _ - - - _ _ _ _ __ _ _ - - - - . _ _ _ - - - - - _ - - _ _ _ _ _ _ _ - - - - - - - - -

l 75 FNP TS Conversion Enclosure 2 - Discussion of Changes to CTS Chapter 5.0 - Administrative Controls l

CTS 6.0 ADMINISTRATIVE CONTROLS FNP ITS 5.0 ADMINISTRATIVE CONTROLS i DOC NO SHE DISCUSSION specify the minimum staffing oflicensed senior reactor operators and reactor operators.

12 M The CTS section 6.2.2 is revised by the addition of paragraph g addressing the Shift Technical Advisor (STA). CTS section 6.2.4 which currently addresses the STA is replaced by the more comprehensive STS section - 5.2.2.g which further defines the STA qualifications and responsibilities.

The additional material contained within STS 5.2.2.g is consistent with the NRC generic guidance regarding STAS and is therefore applicable to FNP.

As the STS paragraph 5.2.2.g contains additional requirements for the STA position, beyond those specified in CTS 6.2.4, the addition of STS 5.2.2.g to the FNP TS is considered more restrictive.

12a A CTS 6.3.1 which discusses facility staff qualifications is revised to eliminate a specific job title for the " Health Physics Supervisor". The specific title has been replaced with the term "the senior individual in charge of Health Physics". The revision of this title is necessary to eliminate the need for nonessential technical specification changes due to organizational or title changes. The use of the term "the senior individual in charge of Health Physics" is not intended to modify the existing health physics organizational structure or responsibilities. The proposed change is a change in terminology only for the designated individual and does not introduce a technical change to the CTS or the FNP health physics organization. Therefore, this change is considered administrative.

13 LA CTS Table 6.2-1, Minimum Shift Crew Composition, is deleted consistent with the STS. In the STS, there is no corresponding Table to CTS Table 6.2-1. The STS includes specific provisions for licensed and non-licensed shift crew members (ITS 5.2.2.a and g) as well as the minimum requirements for licensed operators (5.2.2.b) and references the appropriate Federal Regulations (10 CFR 50.54(m)(2)(i)) which mandates the minimum staffing requirements for licensed operators (ITS 5.2.2.c). CTS Table 6.2-1 contains information redundant to the existing federal regulations for licensed operator staffing requirements and the provisions of STS 5.2.2.a, b,

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c, and g. The elimination of Table 6.2-1 and all references to it in the Facility Staff section are acceptable considering that the requirements for Chapter 5.0 E2-7 A March,1998

FNP TS Conversion Enclosure 2 - Discussion of Changes to CTS Chapter 5.0 - Administrative Controls j CTS 6.0 ADMINISTRATIVE CONTROLS FNP ITS 5.0 ADMINISTRATIVE CONTROLS DOC NO SHE DISCUSSION l testing, maintenance, and parts procurement requirements necessary to maintain the AAC as a Class !E component. This CTS requirement is removed from the TS. The FSAR section 8.3.1.1.7.3 currently specifies that the AAC source is a dedicated Class IE diesel generator. The repetition of this fact in the TS does not provide additional safety benefits to the plant. In addition, FNP has implemented the Maintenance Rule (10 CFR 50.65) which requires the performance and condition of components be monitored against established goals to provide reasonable assurance that )

the component is capable of fulfilling its intended function. The j Maintenance Rule also requires that performance and condition monitoring '

activities and associated goals and preventive maintenance activities be evaluated periodically and adjustments made where necessary to ensure an )

appropriate balance is maintained between preventing equipment failures and equipment unavailability due to monitoring or maintenance activities, l The testing, maintenance, availability, and reliability of the FNP dedicated Class 1E diesel generator AAC source is adequately addressed by the FNP implementation of the Maintenance Rule which includes the AAC diesel  ;

generator. As such, CTS 6.8.1.j(i) is not required to ensure the AAC source is a dedicated Class IE diesel generator or that it is properly tested and maintained to ensure its reliability. Therefore, the deletion of this CTS requirement is consistent with the content of the corresponding STS section, does not impact plant safety, and is acceptable.

26 A CTS 6.8.1.j(ii) requires that the NRC be notified if the AAC source is out of service for greater than 10 days. This CTS requirement is essentially an FNP specific reporting requirement and as such is moved into ITS section 5.6, Reporting Requirements. The NRC notification requirement of CTS 6.8.1.j(ii) remains unchanged. This requirement is simply moved to a more appropriate location where similar reporting requirements reside.

Therefore, this change is considered administrative.

27 LA CTS 6.8.2, contains requirements for the procedure and policy review process, including changes made to the procedures and policies. CTS 6.8.2 references CTS 6.5 for guidance in the required reviews. CTS 6.5 contains requirements applicable to the Plant Operations Review Committee (PORC), the Nuclear Operations Review Board (NORB), and the Technical Chapter 5.0 E2-13-A March,1998

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FNP TS Conversion Enclosure 2 - Discussion of Changes to CTS Chapter 5.0 - Administrative Controls I

CTS 6.0 ADMINISTRATIVE CONTROLS FNP ITS 5.0 ADMINISTRATIVE CONTROLS I DOC N_Q SHE DISCUSSION solely to conform with the format and presentation of this information in the STS.

40 A CTS 6.8.3 which contains requirements for Administrative Controls Programs is revised consistent with the STS by the addition of a new program. The Ventilation Filter Testing Program, STS 5.5.11, is added to the CTS program section of Administrative Controls. This STS program is based on the CTS surveillance requirements for the Control Room Emergency Filtration System (CREFS), and the Penetration Room Filtration (PRF) System. This program retains key elements (acceptance criteria) for the required surveillance testing of the CREFS and PRF System. Other changes to the CTS surveillance requirements for the CREFS and PRF System are documented and discussed in the DOCS associated with those changes in TS section 3.7 (Plant Systems) which contains the surveillance requirements for these systems. As this program retains existing CTS requirements, and does not introduce any technical changes to these requirements, the addition of this program is considered administrative.

41 A CTS 6.8.3 which contains requirements for Administrative Controls Programs is revised consistent with the STS by the addition of a new program. The Explosive Gas and Storage Tank Radioactivity Monitoring Program, STS 5.5.12, is added to the CTS program section of Administrative Controls. This STS program is based on the CTS 3/4.11.1.4,3/4.11.2.5,3/4.11.2.6, and 3/4.3.3.11 requirements for monitoring and limiting the contents of waste gas and liquid storage tanks.

These CTS have been removed from the TS as discussed and documented in the DOCS associated with each of the atTected TS. The intent of the STS 5.5.12 program is to retain within the TS the essential requirements of these CTS to monitor and limit explosive gases and the radioactivity of stored liquid and gaseous effluents. The program requires that the current technical specification limits continue to be applied to control the levels of explosive and radioactive gaseous and liquid effluents stored on site.

Therefore, this program provides assurance that the content of the liquid and gaseous effluents stored on site are adequately controlled. Considering that the removal of the affected technical specifications are discussed in the Chapter 5.0 E2-21-A March,1998 L__._ _ . _ _ _ . _ _ _ _ _ _ _ . _ _ _ _ _ _ _ _ _ _ _ . _ _

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l FNP ITS 5.0 ADMINISTRATIVE CONTROLS DOC NQ SHE DISCUSSION that CTS requirement. CTS 6.8.1.j contained a requirement to notify the NRC when the AAC source has been out of service for more than 10 days.

This CTS requirement is moved into the reporting requirement section of administrative controls consistent with the location of other requirements to notify the NRC. This FNP specific reporting requirement remains unchanged except for its location within the TS. Therefore, this change is considered administrative and made to conform more closely with the format and presentation of sirnilar information in the STS.

68 LA CTS 6.10, which contains requirements for Record Retention, is completely j removed from the CTS consistent with the content of the STS. CTS 6.10 j contains requirements applicable to records which must be retained for 5 j years and records required to be retained for the duration of the operating license. The Record Retention requirements contained in CTS 6.10 are moved, intact, into the FNP Quality Assurance Program. The placement of

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these requirements in the Quality Assurance Program is acceptable since subsequent changes to the requirements will be controlled in accordance with 10 CFR 50.54(a). The placement of the FNP Record Retention requirements in the Quality Assurance Program is consistent with the guidance found in the NRC Administrative Letter 95-06 which recommends the preferred location for CTS requirements that are removed from the Administrative Controls section of the TS.

CTS 6.11, Radiation Protection Program, is deleted consistent with the i 69 LA content of the STS. This program requires procedures to be prepared for personnel radiation protection consistent with 10 CFR 20. These procedures provide protection for the facility personnel and have no impact on nuclear safety or the health and safety of the public. A specific requirement to have procedures to implement 10 CFR 20 is contained in 10 CFR 20.1101(b). In addition, periodic review of these procedures is specifically required by 10 CFR 20.1101(c). Therefore, CTS requirement 6.11 is redundant to requirements in the Federal Regulations and is not necessary or required to be in the TS. The deletion of CTS 6.11 is acceptable since the applicable Federal Regulations can be relied on to

( assure the procedures reqeired by 10 CFR 20 are implemented and maintained at FNP.

Chapter 5.0 E2-33-A March,1998 l