ML20247E644

Safety Evaluation Supporting Amend 41 to License NPF-43

ML20247E644
Person / Time
Site:	Fermi
Issue date:	09/07/1989
From:	Office of Nuclear Reactor Regulation
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ML20247E637	List: ML20247E634 ML20247E644 ML20247E649
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NUDOCS 8909150341
Download: ML20247E644 (20)

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[ " *'4 UNITED STATES i

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NUCLEAR REGULATORY COMMISSION j

j WASHINGTON, D. C. 20555 e-

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i SAFETY EVALUATION BY THE OFFICE OF NUCLEAR REACTOR REGULATION RELATED TO AMENDMENT NO. 41 TO FACILITY OPERATING LICENSE NO. NPF-43 DETROIT EDISON COMPANY WOLVERINE POWER SUPPLY COOPERATIVE, INCORPORATED FERMI-2

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DOCKET NO. 50-341

1. 0 INTRODUCTION By 1stter dated December 22, 1988, the Detroit Edison Company (DECO or the licensee) requested amendment to the Technical Specifications (TSs) appended to Facility Operating License No. NPF-43 for Fermi-2.

The proposed amendment would revise TS 3/4.3.2 and the associate tables.

The table entries previously

. listed in a section entitled " Containment Isolation" are separated into two sections; one for Primary Containment and one for Secondary Containment isolation functions.

Revisions to table entries, table notations and no-menclature are made to either more clearly reflect the plant configuration, remove duplication or ambiguity, or reflect the new sections of the table.

In addition, the definition of Channel Calibration is revised to better reflect standard industry practice.

The application also includes provisions to allow routine testing of the Reactor Water Cleanup system without necessitating removal of the system from service.

This portion of the application will be handled in a future amendment.

2.0 EVALUATION The proposed changes to the TSs are evaluated individually below.

Under-lined text within the licensee's proposed TSs indicates new or changed language.

Where language is proposed to be eliminated, both the existing and proposed wordings are given.

2.1 Definition of Channel Calibration

.The proposed change to the Definitions section, CHANNEL CALIBRATION (1.4) is underlined.

CHANNEL CALIBRATION 1.4 A CHANNEL CALIBRATION shall be the adjustment, as necessary, of the channel output such that it responds with the necessary range and accuracy to known values of the parameter which the channel monitors.

The CHANNEL CALIBRATION shall encompass the entire channel including the sensor and 8909150341 890907 PDR ADOCK 05000341 P

PDC

alarm and/or trip functions, and shall include the CHANNEL FUNCTIONAL TEST.

The CHANNEL CALIBRATION may be performed by any series of sequential, overlapping or total channel steps such that the entire channel is calibrated.

Calibration of instrument channels with resistance temperature detector (RTD) or thermocouple sensors shall consist of verification of operability of the sensing element and adjustment, as necessary,of the remaining adjustable devices in the channel.

The reason for the change is to provide clarification in the Channel Calibration definition for what constitutes an acceptable calibration of an instrument channel with RTD or thermocouple sensors.

The change reflects standard industry practice and provides assurance that temperature channels are calibrated such that they respond with the necessary range and accuracy to fulfill their safety function.

This proposed change clarifies the intent of the definition when RTD or thermocouple sensors are involved.

The intent of the channel calibration is to adjust the channel output so that the channel responds with known

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range and accuracy.

Most instrument channels contain an adjustable transmitter (sensor) which is also subject to drift.

Thus, for most channels, a channel calibration includes adjustments to the transmitter (sensor) to re establish proper input-output relationships.

Instrument channels with resistance temperature detector (RTO) and thermocouple sensors differ from the typical instrument channel in that the sensor has a fixed input-output response which cannot be adjusted or changed once installed.

The fixed response of the sensor is determined prior to installation and is applied to the remainder of the channel in order to make the necessary adjustments to ensure the proper channel range and accuracy.

Since there is no credible mechanism for the fixed response of the RTD or thermocouple to drift or vary, verification of the proper operation of these sensors does not require the extensive testing required i

of other sensors.

The definition of Channel Calibration does not recognize this distinction.

To clarify the necessary testing requirements for a Channel Calibration, the licensee has proposed a change to the Channel Calibration definition, Specification 1.4, to indicate that calibration of instrument channels with RTD or thermocouple sensors shall consist of verification of the operability of the sensing element and adjustment, as necessary, of the remaining adjustable devices in the channel.

This issue of what constitutes an acceptable Channel Calibration for temperature channels has been previously reviewed by the staff in the closure of Fermi 2 Unresolved Item 341/86032-01 (DRP).

The licensee provided information concerning temperature channel calibrations in letters of October 2, 1986 and October 10, 1986.

The practices described were determined to be in conformance with standard industry practice and l

therefore acceptable.

The change to the definition of Channel Calibration is consistent with the resolution of the above Unresolved Item and is therefore acceptable.

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Based on the above evaluation the staff finds the proposed change to the Technical Specification acceptable.

2.2 TS 3/4.3.2 Isolation Actuation Instrumentation Footnotes, Clarification of the Term " Trip Function" TheproposedchangetoTS3/4.3.2,IsolationActuationInstrumentation, 1

footnotes

• and

• to ACTION b. and c. is an editorial change for clarification.

The proposed changes are underlined.

An inoperable channel need not be placed in the tripped condition where this would cause an isolation to occur.

In these cases, the inoperable channel shall be restored to OPERABLE status within 2 hours2.314815e-5 days <br />5.555556e-4 hours <br />3.306878e-6 weeks <br />7.61e-7 months <br /> or the ACTION required

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by Table 3.3.2-1 for that Trip Function shall be taken.

The trip system need not be placed in the tripped condition if this would cause an isolation to occur.

When a trip system can be placed in the tripped condition without causing an isolation to occur, place the trip system with the most Inoperable channels in the tripped condition; if both systems have the same number of inoperable channels, place either trip system in the tripped condition.

The reason for the change is to circify that the exceptions to the requirements to place a channel and/or trip system in the tripped condition' apply only to situations where no closure of isolation valves would result.

The words "an isolation" are substituted for the "the trip function".

This clarifies that a trip function means an isolation rather than a half-isolation which would result from one trip system being in the tripped condition.

The change provides clearer direction to the plant operators as to when the exception applies and results in the application of the TS require-ments as currently intended.

The change therefore acts to enhance safety.

Based on the above evaluation the staff finds the proposed change acceptable.

2.3 Separation of Primary and Secondary Isolation Functions TS 3/4.3.2, Isolation Actuation Instrumentation, does not clearly address secondary containment isolation.

GE Standard TS (BWR/4) and the TS for similar BWR's have Secondary Containment Isolation and Primary Containment Isolation as separate sections of the tables.

Currently, Fermi 2 TS have l

combined these two sections into a Containment Isolation section.

While this % not incorrect, it does make the tables more difficult to read and understand as the " Valve Groups Operated By Signal" column lists only primary containment valve groups and addresses the secondary containment function by table notations.

The proposed change would add Secondary Containment Isolation as a separate section.

This change is a human 4

4-factors enhancement.

Separation of Primary and Secondary Containment Isolation allows Table 3.3.2-1, Isolation Actuation Instrumentation, to be written in a more clear, precise manner.

The isolation instrumentation requirements for the following signals:

Main Steam Line Radiation - High Main Steam Line Pressure - Low Main Steam Line Flow - High Main Steam Line Tunnel Temperature - High Condenser Pressure - High Turbine Building Area Temperature - High I

apply to the Primary Containment Isolation Function exactly as currently listed for the " Containment Isolation" function.

The requirements for

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these signals are therefore included unchanged in the new " Primary Containment Isolation" section.

The reason for the change is to remove confusion as to what trip functions apply to the Primary Containment and what functions apply to the Secondary Containment.

The change enhances safety by improving the usability of the Table and ensures the currently intended requirements are properly applied.

2.3.1 Reactor Vessel Low Water Level - Level 3 Containment Isolation Table 3.3.2-1, Isolation Actutofon Instrumentation, Item 1.a.1 Current:

1.

Containment Isolation i

a.

Reactor Vessel Low Water Level

1) Level 3 Valve Groups Operated By Signal = 4, 13, 15 Proposed: 1.

Primary Containment Isolation a.

Reactor Vessel Low Water Level 1)

Level 3(e)

Valve Groups Operated By Signal = 13, 15 The reason for this change is to place the low water level signal in the new Primary Containment section.

The listing of valve group 4 is removed i

and table notation (e) modified and applied to this signal to clarify that 1

although all three of the valve groups currently listed actuate on the same signal, Groups 13 and 15 actuate for Primary Containment Isolation purposes and Group 4 for RHR Shutdown Cooling System Isolation purposes.

This proposed change deletes Valve Group 4 since Group 4 is addressed in Section 5 of this table.

Section 1 of the table requires ACTION Lo while Section 5 of the table requires ACTION 25.

These ACTIONS are as follows:

' L ACTION 20 - Be in at least HOT SHUTDOWN within 12 hours1.388889e-4 days <br />0.00333 hours <br />1.984127e-5 weeks <br />4.566e-6 months <br /> and in COLD SHUTDOWN within the next 24 hours2.777778e-4 days <br />0.00667 hours <br />3.968254e-5 weeks <br />9.132e-6 months <br />.

ACTION 25 - Disable in the closed position the affected system isolation valves within 1 hour1.157407e-5 days <br />2.777778e-4 hours <br />1.653439e-6 weeks <br />3.805e-7 months <br /> and declare the shutdown cooling mode of RHR inoperable.

Group 4 valves are the RHR Shutdown Cooling suction valves and the Reactor Vessel Head Spray isolation valves.

ACTION 25 is an appropriate ACTION which would permit continued operation if Group 4 is the only valve group affected.

If.other valve groups are affected, specifically Groups 13'and 15 since they are actuated by the same instrument channels, ACTION 20 would apply as well as ACTION 25, due to Group 4 being listed in section 5 of the table.

This would depend on the location in the circuitry of the malfunction.

Table notation (e) has been revised to state that Groups 4, 13 and 15 are actuated by this isolation signal and is placed in the table where this signal appears.

The' change enhances safety by improving the usability of Table 3.3.2-1

-while ensuring all the necessary requirements are maintained in the new Primary Containment Section.

This reduces the possibility of misinter-pretation by the operator which could result in inappropriate action being taken.

Based on the above evaluations the staff finds the TS change acceptable.

2.3.2 Reactor Vessel Low Water Level - Level 2 Containment Isolation Table 3.3.2-1, Isolation Actuation Instrumentation, Item 1.a.2 Current:

1.

Containment Isolation a.

Reactor Vessel Low Water Level 2)

Level 2 Valve Groups Operated By Signal (1st line) = 2, 10, 11, 16, 17, 18 Proposed: 1.

Primary Containment Isolation a.

Reactor Vessel Low Water Level 2)' Level 2 (d)

Valve Groups Operated By Signal = 2, 12, 14, 16, 17, 18 Table notation (d) would be revised to indicate that the level signal also actuates Groups 2, 10, 11, 12, 14, 16, 17, 18, and ***.

The table notation would be placed in all locations in the table where this signal is listed so that no group will be missed.

The reason for the change is to place the Reactor Vessel Low Water Level-Level 2 in the new Primary Containment Isolation section.

Tne change also removes confusion as to the association between valve groups, signals and trip functions.

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Valve Groups 10 and 11, RWCU inboard and outboard isolation valves, are listed in section 2 of this table.

Listing them in section 1 as well is a i

duplication.

In addition to the duplication, two ACTIONS apply.

These are ACTION 20 from section 1 and ACTION 23 from section 2 of the table.

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The ACTIONS are as follows:

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ACTION 20 - Be in at least HOT SHUTDOWN within 12 hours1.388889e-4 days <br />0.00333 hours <br />1.984127e-5 weeks <br />4.566e-6 months <br /> and in I

COLD SHUTDOWN within the next 24 hours2.777778e-4 days <br />0.00667 hours <br />3.968254e-5 weeks <br />9.132e-6 months <br />.

l ACTION 23 - Close the affected system isolation valves within 1 hour1.157407e-5 days <br />2.777778e-4 hours <br />1.653439e-6 weeks <br />3.805e-7 months <br /> and declare the affected system inoperable.

i ACTION 23 is appropriate for Groups 10 and 11, since operation may continue with RWCU inoperable.

The instrumentation is the same as for the other valve groups listed.

These other valve groups' instrumentation will follow ACTION 20.

Therefore, if the instrumentation was inoperable, ACTION 20 would result.

There is a possibility, however, that the malfunction is in the subsequent circuitry which would affect Groups 10 and/or 11 only.

In this case, ACTION 23 only would apply.

This proposed change would allow for this situation and at the same time avoid a duplication in the table.

The addition of Groups 12 and 14 is addressed in 2.3.3 below.

The change enhances safety by improving the usability of Table 3.3.2-1 while ensuring all the necessary requirements are maintained in-the new Primary Containment Section of Table 3.3.2-1.

These enhancements to the table will result in improved operator performance and reduce the probability of incorrect operator actions when using the table.

Based on the above evaluation the staff finds the changes to the TS acceptable.

2.3.3 Reactor Vessel Low Water Level - Level 2 Valve Groups 12 and 14 Containment Isolation Table 3.3.2-1, Isolation Actuation Instrumentation, Item 1.a.2 Current:

1.

Containment Isolation a.

Reactor Vessel Low Water Level 2)

Level 2 Valve Groups Operated By Signal (2nd line) = 12, 14(b)

Applicable OPERATIONAL CONDITION = 1, 2, 3 and

• ACTION 24 Proposed: Primary Containment Isolation Delete the 2nd line.

Add Groups 12 and 14 to line 1.

Delete OPERATIONAL CONDITION *.

ACTION 20

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ACTION'20 - Be in at least HOT SHUTDOWN within 12 hours1.388889e-4 days <br />0.00333 hours <br />1.984127e-5 weeks <br />4.566e-6 months <br /> and in N

COLD SHUTDOWN within the next 24 hours2.777778e-4 days <br />0.00667 hours <br />3.968254e-5 weeks <br />9.132e-6 months <br />.

i ACTION 24 - Establish SECONDARY CONTAINMENT INTEGRITY with the sundby gas treatment system operating within I hcur.

The reason for the chaage'is to clarify that Valve Groups 12 and 14 (Torus Water Management System.and Drywell and Suppression Pool Ventilation System)'are associated with the Primary Containment Isolation

' function.and not. tha secondary Containment Isolation function.

Groups 12 ard 14 are primary containment isolation valve groups which are required during OPERATIONAL CONDITIDN 1, 2, and 3 for purposes.of.

e maintaining PRIMARY CONTAINMENT INTEGRITY.

The instrument channels which

. provide output to the isolation trip systems for Groups 12 and 14 are the same channels which provide output to theLSecondary Containment-Isolation trip systems.

As currently listed, the conclusion could be drawn that the Primary Containment Isolation Valve Groups 12 and 14 are required to be

. OPERABLE to support SECONDARY CONTAINMENT INTEGRITY.

In order to make the requirements clear, this proposed change to TS Table 3.3.2-1 lists

< Secondary Containment Isolation as section 6 of this table.

In section 1, Primary Containment. Isolation, Groups 12 and 14 do not require an ~appli-

..cability of OPERATIONAL CONDITION

• since PRIMARY CONTAINMENT INTEGRITY is not required during OPERATIONAL CONDITION *.

These groups are required in OPERATIONAL CONDITIONS 1, 2, and 3 and the appropriate ACTION is ACTION 20.

This change results from separating the Containment Isolation section of; Table-3.3.2-1.into two sections, Primary and Secondary Containment Isolation, for human factors consideration.

The change enhances safety by ensuring that the Applicability and Action

-Requirements for.a signal associated with the Primary Containment' Isolation trip function are properly specified.

Based on the above evaluation the staff finds the changes to the TS acceptable.

2.3.4 Drywell Pressure - High Containment Isolation Table 3.3.2-1, Isolation Actuation Instrumentation, Item 1.b Current:

1.

' Containment Isolation b.

Drywell Pressure-High Valve Groups Operated By Signal:

(1st line) 2, 13, 15, 16, 17, 18 ACTION 20 (2nd line) 12, 14(b)

ACTION 24 Proposed: 1.

Primary Containment Isolation b.

Drywell Pressure - High Q 1 Valves Operated By Signal:

Delete the 2nd line.

Add Groups 12 and 14 to line 1.

ACTION 20.

D) ThiTpressure signal actuates Groups 2, 12, 13, 14, 15, 16, 17, 18, and ***.

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The reason for the change is to add the Valve Groups and Action Require-

.ments associated with the Primary Containment Isolation Function of_the Drywell Pressure-High signal to the new Primary Containment section of Table 3.3.2-1.

The change also makes a similar. clarification for Valve

' Groups 12 and 14 as was discussed in 2.3.3 above.

Table notation (j) is-modified-to ensure all Valve Groups associated with the Drywell Pressure-High signal are referenced.

Groups 12 and 14 are required for primary containment isolation..The requirements for starting the Standby Gas Treatment System and. automatic secondary containment isolation on a Drywell Pressure-High signal _are being added to section 6 of Table 3.3.2-1, Secondary Containment Isolation.

Action 20 is the appropriate ACTION for the purpose of Primary Containment _ Isolation.

As stated previously, it is possible that a malfunction of a signal could affect only a particular valve group depending on the location of the malfunction..By including these two

. groups in the list with an ACTION 20 requirement in Section 1, Primary Containment Isolation, and listing the applicable secondary containment group with an ACTION 24 requirement in Section 6, Secondary Containment

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Isolation, the appropriate ACTION will be listed for each isolation function.

New table notation (j) adds additional information to list all groups actuated by this parameter.

'The change enhances safety by improving the usability of the table by grouping all Primary Containment Isolation requirements together separately.

The change further ensures the proper ACTION requirements for the Primary Containment Isolation trip function are specified in the new location.

Based on the above evaluation the staff find the TS change acceptable.

L.2.3.5 Fuel Pool Ventilation Exhaust Radiation - High Containment Isolation Table 3.3.2-1, Isolation-Actuation Instrumentation, Item 1.g Current:

1.

Containment Integrity g.

Fuel Pool Ventilation Exhaust Radiation-High Valve Groups Operated By Signal = 14(b), 16 Applicable OPERATIONAL CONDITION = 1, 2, 3 and

• ACTION 24 l

Proposed: 1.

Primary Containment Integrity g.

Delete this item.

The. reason for the change is.to clarify that the Fuel Pool Ventilation Exhaust Radiation-High d rnal is only associated with the Secondary Containment Isolation Function.

Fuel Pool Ventilation Exhaust Radiation-High is provided for the purpose f

of isolating the secondary containment and starting SGTS.

UFSAR Section 15.7.4, Fuel Handling Accident, discusses the accident in detail.

In this section, credit is taken only for the isolation of the normal ventilation system and the operation of the SGTS.

As the Reactor Vessel Low Watsr - Level 2 and Drywell Pressure Level - High described in 2.3.3 and 2.3.4 above, the valve groups. listed are primary containment isolation

' groups and ACTION 24 applies to secondary containment.

The instrumentation

, channels which provide output to Groups 14 and 16 are the same channels which automatically start SGTS and initiate the secondary containment isolation.

In order to make the requirements for this instrumentation more clear, this proposed change would delete this isolation signal in Section 1, Primary Containment Isolation, and add it to Section 6, Secondary Contain-ment Isolation.

Note (a) to Table 3.6.3-1, Primary Containment Isolation Valves, lists primary containment valve groups and the associated actuation signal for which. instrumentation requirements are included in Specification 3.3.2.

The removal of Fuel Pool Ventilation Exhaust Radiation-High signal from the signals required for Valve Groups 14 and 16 in Table 3.3.2-1 requires a'cofrespondingchangetoTable3.6.3-1 note (a).

The change enhances safety by correctly associating the secondary

. containment isolation signal with the safety function it performs and

. removing unnecessary and incomplete references to a logic for Primary

, ',:' Containment Valve Groups 14 and 16 which is secondary in importance and is not used in any safety analysis.

Based on the above evaluation the staff finds the TS change acceptable.

5.3.6 Manual Initiation - Containment Isolation Table 3.3.2-1, Isolation Actuation Instrumentation, Item 1.h Current:

1.

Containment Isolation h.

Manual Initiation Valve Groups Operated By Signal = 1, 2, 4, 12, 14(b) 15, 16, 17, 18 Applicable OPERATIONAL CONDITION = 1, 2, 3 and *

(b) Also starts the standby gas treatment system Proposed: 1.

Primary Containment Isolation h.

Manual Initiation Valve Groups Operated By Signal = Delete Group 4 Add Groups 3 & 5 Delete nc+3 tion (b)

Applicable OPERATIONAL CONDITION = Delte "and ""

e The reason for the change is to place all Primary Containment Isolation manual initiation requirements in the new Primary Containment section of Table 3.3.2-1.

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p The current section 1 of Table 3.3.2-1, Containment Isolation, addresses both primary and secondary containment isolations.

The proposed section 1 1

addresses' primary containment isolation only.

The proposed Section 6 l-addresses secondary containment isolation.

The application OPERATIONAL 1

CONDITION

• is for those signals which are required for secondary contain-ment isolation.

These requirements have been included in section 6, Secondary Containment Isolation.

Since the primary containment valve groups are required for primary containment isolation, these valve groups remain in Section 1, Primary Containment Isolation with an Applicable OPERATIONAL CONDITION of 1, 2, and 3.

As currently written, the

• Appli-cability appears to apply to all valve groups listed.

This is not the intent.

Group 4 is duplicated in Table 3.3.2-1, Section 5, RHR Shutdown Cooling

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Mode Isolation with ACTION 26 specified.

This is the same ACTION specified in Section 1 of the Table.

The applicable OPERATIONAL CONDITION is 1, 2, and 3.

This is consistent with the applicability of the other primary containment isolation valves.

This proposed change avoids duplication in the table.

Groups 3 (Residual Heat Removal System) and 5 (Core Spray System) are not currently listed.

The instrumentation which automatically initiates the isolation of these valve groups is associated with the Emergency Core Cooling System Actuation Instrumentation and, therefore, not currently listed in this table.

The manual initiation function for isolation of these valves consists of one channel per valve and is not currently included in either Specification.

This proposed change would add them to Section 1 of Table 3.3.2-1, Primary Containment Isolation, to make clear this requirement to maintain a manual isolation capability for each of the valves in these two valve groups for the purposes of primary containment isolation.

The current Specifications for Isolation Actuation Instrumentation and ECCS Actuation Instrumentation only makes

.c clear that the ECCS actuation function is required.

-Table notation (b) has been placed in Section 6 of Table 3.3.2-1, Secondary Containment Isolation, and is no longer useful in this Section 1 location as the standby gas treatment system is associated with the secondary containment.

Based on the above evaluation the staff finds the proposed TS acceptable.

2. 4 Reactor Water Cleanup System (RWCS) Isolation 2.4.1 RWCS Heat Exchanger / Pump /High Energy Piping Area Temperature - High Table 3.3.2-1, Isolation Actuation Instrumentation, Item 2.b Cu:, ent:

2. Reactor Water Cleanup System Isolation

b. Heat Exchanger / Pump /High Energy Piping Area Temperature-High.

Minimum OPERABLE Channels Per Trip System = 1 Proposed: Minimum OPERABLE Channels Per Trip System = 6

7=

The reason for the change is_to clarify the number of required channels

.per trip system based upon each sensor being the part of a separate

• ~

channel.

There are six (6) separate locations which are monitored for ambient ~

temperature high in the RWCS leak detection system.

Each of these areas has two temperature sensors which. input to two separate trip systems, for a total of six channels in each trip system.

These areas monitored are as follows:

RWCS Pump A Room RWCS Pump B Room RWCS Heat Exchanger Room RWCS Phase Separator Room RWCS Open Trench Piping Area RWCS Torus Room Since these areas are located such that a break in one area would not be

' detected by another ambient temperature detector in the same trip system, each of these monitoring channels are required.

In practice, these channels are currently being responded to in the same manner as this proposed change prescribes by applying the requirement on a per area basis.

This proposed change will make the table better reflect the instrumentation installed.

-In addition, the change enhances safety by clearly indicating the required number of channels per trip system and thus reducing the possibility of non-conservative. misinterpretation of the requirement.

Based upon the above evaluation the staff finds the proposed changes acceptable.

2.4.2 Heat Exchanger / Pump Area Ventilation Differential Temperature-High RWCS Isolation Table 3.3.2-1, Isolation Actuation Instrumentation, Item 2.c i

Current:

2. Reactor Water Cleanup System Isolation

c. Heat Exchanger / Pump Area Ventilation Differential Temperature-High Minimum OPERABLE Channels Per Trip System = 1 Proposed: c. Heat Exchanger / Pump / Phase Separator Area i

Ventilation Differential Temperature-High Minimum OPERABLE Channels Per Trip System = 2 The reason for the change is to clarify the plant areas covered by this trip function and the number of channels required to te operable in each trip system.

There are four (4) separate locations which are monitored for differential temperature between the inlet and outlet ventilation air ducts for break detection of the RWCS system.

Two of these differential temperature channels provide input to one trip system and the other two channels input to the other trip system.

The areas monitored are as follows:

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' Division 1 Trip System = RWCS Pump A Room RWCS Heat Exchanger Room Division 2 Trip System = RWCS Pump B Room RWCS Phsse Separator Room As with the ambient temperature monitoring trip function described in 2.4.2 above, the areas are located such that these channels will monitor only_their own specific area.

Therefore, each of the two channels for a given trip system are required to be OPERABLE.

These channels are also currently being responded to in~the same manner as this proposed change prescribes.

This proposed change l

will make the table better reflect the instrumentation installed.

In addition, the change enhances safety by clearly defining the plant areas covered by this trip function and the required number of channels per trip system.

This reduces the probability of a non-conservative misinterpretation l-by.the operator.

Based upon the above evaluation, the staff finds the proposed changes acceptable.

2.4.3 Reactor Vessel Low Water Level-Level 2 RWCS Isolation Table 3.3.2-1, Isolation Actuation Instrumentation, Item 2.e Current:

2. Reactor Water Cleanup System Isolation

e. Reactor Vessel Low Water Level - Level 2 Valves Groups Operated by Signal = 10, 11 (d)

Propused: e. Reactor Vessel Low Water Level - Level 2 (d)

Valve Groups Operated by Signal = 10, 11 The reason for this change is to clarify the applicability of table notation (d).

This proposed change relocates table notation (d) for this parameter to indicate that it applies to the instrumentation channel rather than just to valve group 11.

This notation provides additional information to list all of the valve groups which are isolated by this same instrumentation.

This proposed change is a human factors enhancement to provide additional useful information.

In addition, the change enhances safety by ensuring that the footnote is properly interpreted and does not distract from the proper use of the Technical Specifications.

Based upon the above evaluation the staff finds this change to be acceptable.

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a

• l 2.5 Reactor Core Isolation Cooling (RCIC) Steam Supply Pressure-Low RCIC Isolation

)

Table 3.3.2-1, Isolation Actuation Instrumentation, Item 3.b Current:

3. RCIC System Isolation

b. RCIC Steam Supply Pressure-Low Valve Groups Operated By Signal = 8, 9 Proposed: 3. RCIC System Isolation

b. RCIC Steam Supply Pressure-Low Valve Groups Operated By Signal = 8, 9H 1 (f)

Isolates with simultaneous RCIC Steam Supply Pressure-Low (Isolation Actuation Instrumentation) and Drywell Pressure-High (ECCS Actuation Instrumentation).

The reason for the change is to provide a table notation to completely describe the signals which must be present to cause an isolation of Valve Group 9.

l This proposed change to add a new table notation (f) provides additional information concerning the Group 9 isolation.

Since the Drywell Pressure-High signal is input from ECCS Actuation Instrumentation, it is not listed in this table.

This table notation provides the information to tie these together.

This is a human factors enhancement.

The change enhances safety by ensuring complete information is available to the operator and thereby eliminating a potential point of confusion.

Based upon the above, the staff finds this change to be acceptable.

2. 6 High Pressure Coolant Injection (HPCI) Steam Supply Pressure-Low HPCI Isolation Table 3.3.2-1, Isolation Actuation Instrumentation, Item 4.b Current:

4. HPCI System Isolation

b. HPCI Steam Supply Pressure-Low i

Valve Groups Operated By Signal = 6, 7 Proposed: 4. HPCI System Isolation

b. HPCI Steam Supply Pressure-Low Valve Groups Operated By Signal = 6, 7,(gl (g) Isolates with simultaneous HPCI Steam Supply Pressure-Low (Isolation Actuation Instrumentation) and Drywell Pressure-High (ECCS Actuation Instrumentation)

The reason for the change is to provide a table notation to completely describe the signals which must be present to cause an isolation of Valve Group 7.

The proposed change to add a new table notation (g) provides additional

,information concerning the Group 7 isolation.

Since the Drywell Pressure-

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.'High signal is input:from ECCS Actuation Instrumentation, it is not listed

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in the table.. This table notation provides the information to tie these together.

This is a human factors enhancement.

The change enhances safety by ensuring complete information is available to_the operator and thereby eliminating a potential source of confusion.

j Based upon the above, the staff finds the change to be acceptable.

j 2.7. Segregation of Secondary Containment Isolation Actuation Instrumentation Requirements Table 3.3.2-1, Isolation Actuation Instrumentation, Item 6 Current:

1. Containment Isolation

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Table notation (b)

(b) Also starts the standby gas treatment system.

Proposed:

6. Secondary Containment Isolation The reason for the change is to establish a table section which lists the requirements for those signals associated with the Secondary Containment Isolation function.

Currently, table notation (b) is the only inference that the instrumentation applies to both primary and secondary containment isolations.

This proposed change lists these requirements in a very specific manner in a separate section.

As discussed above, this is consistent with Standard Technical Specifications and general industry practice.

The change enhances safety by providing the requirements for Secondary Containment Isolation Actuation together separately, thus, reducing the possibility of a non-conservative misinterpretation of the requirements.

2.7.1~

Reactor Vessel Low Water Level-Level 2 Secondary Containment Isolatica Table 3.3.2-1, Isolation Actuation Instrumentation, Item 6.a Current:

1. Containment Isolation

a. Reactor Vessel Low Water Level

2) Level 2 Valve Groups Operated by Signal = 2, 10, 11, 16, 17, 18 l

Applicable Operational Condition = 1, 2, 3 l

ACTION

= ACTION 24 Valve Groups Operated by Signal = 12, 14 (b)

Applicable Operational Condition = 1, 2, 3 ACTION

= ACTION 24 Proposed: 6. Secondary Containment Isolation

a. Reactor Vessel Low Water Level - Level 2 (b) (d)

Valve Groups Operated by Signal = ^^^

u, and

• 3 J-Applicable Operational Condition = 1, 2 l

ACTION

= ACTION 24 f

• • • Actuates dampers shown in Table 3.6.5.2-1.

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The reason for the change is to place the requirements for Secondary

' containment Isolation actuation from this signal in the new table section.

The change also ensures other functions of the signal are referenced and provides a connection to the actuation of the secondary containment auto-matic' isolation dampers listed in Table 3.6.5.2-1.

This proposed change is part of the separation of primary and secondary containment isolation into two separate sections in order to specifically address each in appropriate detail.

The primary containment considerations are addressed in items 5) and 6) above.

The footnote (***) refers to Table 3.6.5.2-1 which lists the secondary containment automatic isolation i

dampers that are isolated by this instrumentation.

The current Table 3.3.2-l'does not provide.this relationship.

Table notation (d) identifies all groups actuated by this signal for information purposes.

The change enhances safety by clearly indicating the secondary containment isolation actuation requirements for the Level 2 signal separately in one location while incorporating all of the necessary requirements.

This will reduce the probability of confusion on the part of the operator and reduce the likelihood of a non-conservative misinterpretation of the requirements.

Based upon the above, the staff finds this change to be acceptable.

2.7.2 Drywell Pressure-High Secondary Containment Isolation Table 3.3.2-1, Isolation Actuation Instrumentation, Item 6.b Current:

1. Containment Isolation

b. Drywell~ Pressure-High Valve Groups Operated by Signal = 2, 13, 15, 16, 17,'18 Applicable Operational Condition = 1, 2, and 3 ACTION

= ACTION 20 Valve Groups Operated by Signal = 12, 14(b)

Applicable Operational Condition = 1, 2, 3 ACTION

= ACTION 24 Proposed: 6. Secondary Containment Isolation

b. Drywell Pressure - High (b) (j)

Valve Groups Operated by Signal = ***

Applicable Operational Condition = 1, 2, and 3 ACTION

= ACTION 24

• • • Actuates dampers shown in Table 3.6.5.2-1.

The reason for the change is to place the requirements for secondary containment isolation actuation from this signal in the new table section.

The change also ensures other functions of the signal are referenced and provides a connection to the actuation of the secondary containment automatic isolation dampers listed in Table 3.6.5.2-1.

This proposed change is also part of the separation of primary and secondary containment isolation into separate sections.

The footnote

(***) refers to Table 3.6.5.2-1, which lists the secondary containment automatic isolation dampers that are isolated by this instrumentation.

The current Table 3.3.2-1 does not provide this relationship.

The new table notation (j) identifies all groups actuated by this signal for information purposes.

The change enhances safety by clearly indicating the secondary containment isolation actuation requirements for the drywell pressure signal separately in one location while incorporating all of the necessary requirements.

This will reduce the probability of confusion on the part of the operator and reduce the likelihood of a non-conservative misinterpretation of the requirements.

Based upon the above, the staff finds this change to be

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acceptable.

2.7.3 Fuel Pool Ventilation Exhaust Radiation-High Secondary Containment Isolation Table 3.3.2-1, Isolation Actuation Instrumentation, Item 6.c Current:

1. Containment Isolation

g. Fuel Pool Ventilation Exhaust Radiation-High Valve Groups Operated by Signal = 14(b), 16 Applicable Operational Condition = 1, 2, 3, and

• ACTION

= ACTION 24 Proposed: 6. Secondary Containment Isolation

c. Fuel Pool Ventilation Exhaust Radiation-High (b)

Valve Groups Isolated by Signal = ^^^

Applicable Operational Condition = 1, 2, 3, and

• ACTION

= ACTION 24 The reason for the change is to place the requirements for secondary containment isolation actuation from this signal in the new table section.

The change provides a connection to the actuation of the standby gas treatment system and secondary containment automatic isolation dampers listed in Table 3.6.5.2-1.

Fuel Pool Ventilation Exhaust Radiation-High is currently listed in the Containment Isolation section with Groups 14 and 16 in the " valve groups operated by signal" column along with table notation (b), which states that this instrumentation also starts the standby gas treatment system.

There is nothing stated specifically that the secondary containment automatic isolation dampers listed in Table 3.6.5.2-1 are also operated by this signal.

Table notation (b) referring to the standby gas treat-ment system could be interpreted to mean that secondary containment isolations are also actuated by this signal, but it does not specify so.

Footnote *** states that this signal also actuates umpers shown in Table 3.6.5.2-1.

By specifying this footnote on the Valve Groups Operated by Signal Column, these dampers will now be listed.

The appli-cable OPERATIONAL CONDITIONS 1, 2, 3, and

• remain the same as the current Section 1, as does the specified ACTION 24.

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1The/ change enhances: safety by clearly l indicating the secondary containment ~

Lisolation actuation' requirements for the' Fuel Pool' Exhaust Radiation E,.

signal. separately;inloneflocation while incorporating all of the necessary F

. requirements.

This will reduce the probability;of confusion'on the part.

of the' operator.and. reduce the likelihood ofca non-conservative'misinter-

.pretation'of the requirements.

Based upon the'above, the staff finds.the change to'be acceptable.

E2.7.4 " Manual' Initiation-Secondary Containment-Isolation Table-3.3.2-1, Isolation Actuation-Instrumentation, Item 6.d1

=

Current:

1. Containment Isolation

h. ManuaitInitiation

- ~

Valve Groups Operated by Signal = 1, 2, 4, 12, 13, 14(b),

15,:16,-17, 18 Minimum OPERABLE Channels per Trip System = 1/ valve

ACTION

= ACTION 26 Proposed: 6.: Secondary Containment Isolation

^

d. Manual Initiation (b)-

Valve Groups. Operated by Signal = ***

MinimumOPERABLEChannelsperTripSystem=1_(il*

Applicable Operational: Conditions = 1, 2, 3, and ACTION

-= ACTION 27 (1) Secondary Containment Isolation pushbutTons The reason for the change is'to place the requirements for manual secondary containment isolation actuation in the new table section.

The change: ensures the connection-to the actuation of the standby gas treat-ment system (SGTS) and secondary' containment automatic isolation dampers is' clear and.provides a clear action requirement which includes-the need for.the SGTS.to be placed in operation.

The change also ensures by new

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table notation (i), that the required function is_ clearly indicated.

The secondary' containment automatic isolation dampers (footnote ***) are manually. isolated by Secondary Containment Isolation pushbuttons.

There is one.pushbutton per trip system.

The Minimum OPERABLE Channels Per

' Trip System is listed as 1.

The new table notation (1) identifies-this.

ACTION 26, which'is used for the manual isolation function in all other o

sections of this table, was used as the model in this proposed' change to add a new ACTION 27.

It' reads:as follows:

' ACTION 27 - Restore the manual initiation function to OPERABLE l1 status within 8 hours9.259259e-5 days <br />0.00222 hours <br />1.322751e-5 weeks <br />3.044e-6 months <br /> or establish SECONDARY

~

CONTAINMENT INTEGRITY with the standby aas treatment system operating.

The underlined text is a modification of the wording of ACTION 26, to l

-create ACTION 27 which better applies to the manual initiation function of Section 6 of Table 3.3.2-1, Secondary Containment Isolation.

The ACTION of establishing SECONDARY CONTAINMENT INTEGRITY with the

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Standby Gas Treatment System operating is the result of the closure of the affected isolation dampers.

The change enhances safety by clearly indicating the manual secondary containment isolation actuation requirements separately in one location j

while providing clearer and more complete requirements.

This will provide greater assurance that the requirements will be understood and properly l

applied.

Based upon the above, the staff finds the proposed change to be 1

acceptable.

2.8 Table 3.3.2-1 Note

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Table 3.3.2-1, Isolation Actuation Instrumentation, Table Notations Current:

Footnote *

~i When handling irradiated fuel in the secondary containment and during CORE ALTERATIONS and operations with a potential for draining the reactor vessel.

Proposed:

Footnote

• When handling irradiation fuel in the secondary containment, during' CORE ALTERATIONS, or during operations with a potential for draining the reactor vessel.

The reason for the change is to clearly indicate that the three conditions in the note are intended to make requirements apply whenever an of the three conditions exists rather than whenever all of the three conditions exist.

This proposed change does not alter the intent of the footnote.

This is simply an editorial change to indicate that this is applicable when any of the three conditions apply.

The change enhances safety by reducing the probability of a non-conservative misinterpretation of the footnote.

Based upon the above, the staff finds the change to be acceptable.

2.9 Corresponding Changes to the Remaining Tables Appropriate changes have been made to Table 3.3.2-2, Isolation Actuation Instrumentation Setpoints; Table 3.3.3-3, Isolation Actuation Instrumentation Response Times; Table 4.3.2.1-1, Isolation Actuation Instrumentation Surveillance Requirements.

These changes make these tables consistent.

The proposed changes correspond to the proposed changes to Table 3.3.2-1 previously described in regards to restructuring the tables for separate Primary and Secondary Containment Isolation sections and other format /

nomenclature changes.

This is necessary for consistency between the tables of this Specification.

The changes enhance safety by making the remaining tables consistent with the as-modified Table 3.3.2-1.

This is necessary to fully implement the safety benefits of the changes made in Table 3.3.2-1.

Based upon the above, the staff finds the changes to be acceptable.

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2.10 RWCS Isolation' Time Delay Footnote LTable 3.3.2-3, Isolation Actuation: Instrumentation Response Time, Item 2.a, footnote #

Current:

Table 3.3.2 2. RWCS-Isolation-

a. Differential Flow-High Response Time (seconds) = NA N y

1. with time delay of 45 seconds Proposed: Table 3.3.2-3

2. RWCS Isolation

a. Differential Flow-High Response Time (seconds) = NA Delete footnote #

Table 3.3.2-1

2. RWCS Isolation

a. Differential Flow-High #

1. With time delay of 45 seconds The reason for the change is to ensure that the informational footnote concerning the existence of a 45 second time delay is not construed to be a surveillance test requirement.

Currently, footnote N is applied to the response time for this item in Table 3.3.2-3, Isolation Actuation Instrumentation Response Time.

This is an informational item to inform the user that a time delay of 45 seconds is designed-into the circuitry.

This location of the footnote has led to confusion as to the response time requirement.

The required response time is not applicable (NA).

To avoid this confusion factor, this proposed change deletes the footnote from Table 3.3.2-3 and adds

.it to Table 3.3.2-1, Isolation Actuation Instrumentation, Item 2.a.

This footnote # contains the same information but applies it to the proper table to avoid confusion.

The change does not have any adverse safety impact since the change involves the relocation of a purely informational footnote to a more appropriate. location.

Based upon the above, the staff finds the change to be acceptable.

3.0 ENVIRONMENTAL CONSIDERATION

Pursuant to 10 CFR 51.21, 51.32 and 51.35, an environmental assessment and finding of no significant impact have been prepared and published in the Federal Register on August 31, 1989 (54 FR 36071).

Accordingly based upon the environmental assessment, we have determined that the issuance of this amendment will not have a significant effect on the quality of the human environment.

I,]gdy;

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'.) 4. 0 l CONCLUSION 41We have concluded, based on the considerations' discussed above,Lthat~(1);

ithere'isireasonable' assurance that.the. health and safety of~the'public will;<

not.be. endangered by operation in..the proposed. manner,.and (2).such activities will be conducted in compliance with the' Commission's regulations', and the-

' issuance of this amendment will=not be. inimical to the common defense and.

security.or'to the health and safety __of the public.

r, p ! Principal Contributor:

John Stang I

L

'Date: Sept' ember 7, 1989.

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