JAFP-21-0040, Application to Revise Technical Specifications to Adopt TSTF-264-A, Revision 0, 3.3.9 and 3.3.10 - Delete Flux Monitors Specific Overlap Requirement SRs

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Application to Revise Technical Specifications to Adopt TSTF-264-A, Revision 0, 3.3.9 and 3.3.10 - Delete Flux Monitors Specific Overlap Requirement SRs
ML21134A211
Person / Time
Site: FitzPatrick Constellation icon.png
Issue date: 05/14/2021
From: David Gudger
Exelon Generation Co
To:
Document Control Desk, Office of Nuclear Reactor Regulation
References
JAFP-21-0040
Download: ML21134A211 (18)
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Text

10 CFR 50.90 JAFP-21-0040 May 14, 2021 U.S. Nuclear Regulatory Commission ATTN: Document Control Desk Washington, DC 20555-0001 James A. FitzPatrick Nuclear Power Plant Renewed Facility Operating License No. DPR-59 NRC Docket No. 50-333

Subject:

Application to Revise Technical Specifications to Adopt TSTF-264-A, Revision 0, "3.3.9 and 3.3.10 - Delete Flux Monitors Specific Overlap Requirement SRs" Pursuant to 10 CFR 50.90, "Application for amendment of license or construction permit, or early site permit," Exelon Generation Company, LLC (Exelon), proposes changes to the Technical Specifications (TS), Appendix A of Renewed Facility Operating License No.

DPR-59 for James A. FitzPatrick Nuclear Power Plant (JAF). Exelon requests adoption of TSTF-264-A, Revision 0, "3.3.9 and 3.3.10 - Delete Flux Monitors Specific Overlap Requirement SRs."

The NRC documented its approval of TSTF-264-A, Revision 0, in a letter from William Beckner (NRC) to James Davis (NEI) dated July 26, 1999.

The enclosure provides a description and assessment of the proposed changes. Attachment 1 provides the existing TS pages marked up to show the proposed changes. Attachment 2 provides the existing TS Bases pages marked up to show revised text associated with the proposed TS changes and is provided for information only.

The proposed changes have been reviewed and approved by the sites Plant Operations Review Committee in accordance with the requirements of the Exelon Quality Assurance Program.

Exelon requests approval of the proposed amendments by May 14, 2022. Once approved, the amendments shall be implemented within 60 days.

There are no regulatory commitments contained in this submittal.

Application to Revise Technical Specifications to Adopt TSTF-264-A, Revision 0 May 14, 2021 Page 2 In accordance with 10 CFR 50.91, "Notice for public comment; State consultation,"

paragraph (b), Exelon is notifying the State of New York of this application for license amendments by transmitting a copy of this letter and its attachments to the designated State Official.

Should you have any questions concerning this letter, please contact Enrique Villar at 610-765-5736.

I declare under penalty of perjury that the foregoing is true and correct. Executed on the 14th day of May 2021.

Respectfully, David T. Gudger Senior Manager - Licensing Exelon Generation Company, LLC

Enclosure:

Description and Assessment Attachments: 1. Proposed Technical Specification Changes (Mark-Up)

2. Proposed Technical Specification Bases Changes (Mark-Up) - For Information Only
3. Insert cc: Regional Administrator - NRC Region I w/ Attachments NRC Senior Resident Inspector - JAF "

NRC Project Manager, NRR "

A. L. Peterson, NYSERDA "

B. Frymire, NYSPSC "

Enclosure James A. FitzPatrick Nuclear Power Plant Renewed Facility Operating License No. DPR-59 NRC Docket No. 50-333 Evaluation of Proposed Changes

Subject:

License Amendment Request to Adopt TSTF-264-A, Revision 0, "3.3.9 and 3.3.10 - Delete Flux Monitors Specific Overlap Requirement SRs" 1.0

SUMMARY

DESCRIPTION 2.0 DETAILED DESCRIPTION

3.0 TECHNICAL EVALUATION

3.1 Background

3.2 Justification

4.0 REGULATORY EVALUATION

4.1 Applicable Regulatory Requirements/Criteria 4.2 Precedence 4.3 No Significant Hazards Consideration 4.4 Conclusions

5.0 ENVIRONMENTAL CONSIDERATION

6.0 REFERENCES

LAR to Adopt TSTF-264, Revision 0 Docket No. 50-333 Enclosure Evaluation of Proposed Changes Page 2 of 6 1.0

SUMMARY

DESCRIPTION Pursuant to 10 CFR 50.90, "Application for amendment of license, construction permit, or early site permit," Exelon Generation Company, LLC (Exelon), proposes a change to the Technical Specifications (TS), Appendix A of Renewed Facility Operating License No.

DPR-59 for James A. FitzPatrick Nuclear Power Plant (JAF).

The proposed change revises Specification 3.3.1.1, "RPS Instrumentation," by deleting Surveillances 3.3.1.1.5 and 3.3.1.1.6, which verify the overlap between the source range monitor (SRM) and the intermediate range monitor (IRM), and between the IRM and the average power range monitor (APRM).

2.0 DETAILED DESCRIPTION SR 3.3.1.1.5 and SR 3.3.1.1.6 are being deleted. These Surveillance Requirement (SR) require verification of overlap of Source Range Monitor (SRM) and Intermediate Range Monitor (IRM) channels and verification of overlap of IRM and Average Power Range Monitor (APRM) channels. However, the surveillances function will still be performed by the associated CHANNEL CHECK (SR 3.3.1.1.1). A statement will be added to the TS Bases to clarify that the overlap verification is to be performed as part of the CHANNEL CHECK, SR 3.3.1.1.1.

3.0 TECHNICAL EVALUATION

3.1 Background

The Neutron Monitoring System is a system of incore neutron detectors and out-of-core electronic equipment. The system provides indication of neutron flux, which can be correlated to thermal power level for the entire range of flux conditions that may exist in the core. The source range monitors (SRM) and the intermediate range monitors (IRM) provide flux level indications during reactor startup and low power operation. The local power range monitors (LPRM) and average power range monitors (APRM) allow assessment of local and overall flux conditions during power range operation. Rod block monitors (RBM) are provided to prevent rod withdrawal when reactor power should not be increased at the existing reactor coolant flow rate. The traversing incore probe (TIP) subsystem provides a means to calibrate the LPRM System.

3.2 Justification As stated in TSTF 264-A, SR 3.3.1.1.5 and SR 3.3.1.1.6 (these are equivalent SRs to NUREG 1433 SRs 3.3.1.1.6 and SR 3.3.1.1.7) are unnecessary in that they duplicate requirements of the CHANNEL CHECK required by SR 3.3.1.1.1. Failure of the SR requires that the SRM or IRM be considered inoperable even when they are calibrated and fully OPERABLE in every other way (i.e., capable of performing their safety function). This is true even if it is clear that the overlap does not exist due to failure of the other flux monitors (i.e., IRMs or APRMs) since SR 3.0.1 says that failure to meet the SR is failure to meet the LCO and the SR requires overlap.

LAR to Adopt TSTF-264, Revision 0 Docket No. 50-333 Enclosure Evaluation of Proposed Changes Page 3 of 6 The CHANNEL CHECK also provides the overlap requirement since a lack of expected overlap would constitute failure of the channel to meet the established "agreement criterion." However, the "agreement criterion" can be established to provide this appropriate requirement with the appropriate flexibility to determine the inoperable components and initiate appropriate actions. Therefore, the proposed change still affords adequate assurance of safety when judged against current regulatory standards.

Differences Between the Proposed Change and the Approved Traveler

  • TSTF-264-A deletes NUREG 1433 SR 3.3.1.1.6 and SR 3.3.1.1.7 and all subsequent surveillances were renumbered, and all references to the renumbered surveillances were revised. Renumbering a large number of surveillances in the plant-specific Technical Specifications would result in a prohibitive number of revisions to procedures and training materials. Therefore, in the proposed JAF change, the deleted Surveillances are marked

"(Not used.)" and the subsequent Surveillances are not renumbered.

4.0 REGULATORY EVALUATION

4.1 Applicable Regulatory Requirements/Criteria Title 10 of the Code of Federal Regulations (10 CFR), Part 50, paragraph 36(c)(3), "Surveillance Requirements," states: Surveillance requirements are requirements relating to test, calibration, or inspection to assure that the necessary quality of systems and components is maintained, that facility operation will be within safety limits, and that the limiting conditions for operation will be met.

The proposed change continues to test components to ensure that the necessary quality is maintained. The proposed Surveillance Requirements are consistent with NUREG-1433.

4.2 Precedence Similar License Amendment request:

  • Edwin I. Hatch Nuclear Plant - Request for Technical Specification Amendment Adoption of Previously Approved Generic Technical Specification Changes and Other Changes, letter dated October 10, 2014. NRC approved this request on September 29, 2016.
  • License Amendment Request Adoption of NRC Approved Generic Changes to the Improved Technical Specifications Grand Gulf Nuclear Station, Unit 1 Docket No. 50-416 License No. NPF-29, letter dated March 30, 2005. NRC approved this request on February1, 2006.
  • Duane Arnold Energy Center Docket 50-331 license No. DPR-49 Technical Specification Change Request (TSCR-029): "Adoption of NRC Approved Generic Changes to Improved Technical Specifications" Affected Technical Specifications:

LAR to Adopt TSTF-264, Revision 0 Docket No. 50-333 Enclosure Evaluation of Proposed Changes Page 4 of 6 Sections 1.4, 3.3.1.1, 5.5.2, 5.5.11, letter dated January 28, 2004. NRC approved this request on May 12, 2005.

4.3 No Significant Hazards Consideration Exelon has evaluated whether or not a significant hazards consideration is involved with the proposed amendment by focusing on the three standards set forth in 10 CFR 50.92, "Issuance of amendment," as discussed below:

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

Response: No.

Surveillance Requirement (SR) 3.3.1.1.5 and SR 3.3.1.1.6 are being deleted. These SRs require verification of overlap of Source Range Monitor (SRM) and Intermediate Range Monitor (IRM) channels and verification of overlap of IRM and Average Power Range Monitor (APRM) channels. However, these requirements are unnecessary in that they duplicate requirements of the CHANNEL CHECK required by SR 3.3.1.1.1.

The proposed change does not affect any plant equipment, test methods, or plant operation, and are not initiators of any analyzed accident sequence. The SRM, IRM, and APRM will continue to perform their function as designed. Operation in accordance with the proposed Technical Specifications will ensure that all analyzed accidents will continue to be mitigated as previously analyzed.

Therefore, it is concluded that this change does not significantly increase the probability of an accident previously evaluated.

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

Response: No.

The proposed changes to delete SR 3.3.1.1.5 and SR 3.3.1.1.6 do not involve a physical alteration of the plant (no new or different type of equipment will be installed), do not change the design function of any equipment, and do not change the methods of normal plant operation. The proposed change does not create any new credible failure mechanisms, malfunctions, or accident initiators not previously considered in the James A. FitzPatrick Nuclear Power Plant design and licensing basis.

Therefore, the proposed change does not create the possibility of a new or different kind of accident from any previously evaluated.

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

Response: No.

The proposed change to delete SR 3.3.1.1.5 and SR 3.3.1.1.6 have no effect on any safety analysis assumptions or methods of performing safety analyses. The changes do not

LAR to Adopt TSTF-264, Revision 0 Docket No. 50-333 Enclosure Evaluation of Proposed Changes Page 5 of 6 adversely affect system OPERABILITY or design requirements.

The equipment continues to be tested via the associated CHANNEL CHECK (SR 3.3.1.1.1) in a manner and at a frequency necessary to provide confidence that the equipment can perform its intended safety functions.

Therefore, the proposed change does not involve a significant reduction in a margin of safety Based on the above, Exelon concludes that the proposed amendment presents no significant hazards consideration under the standards set forth in 10 CFR 50.92(c), and, accordingly, a finding of "no significant hazards consideration" is justified.

4.4 Conclusions In conclusion, based on the considerations discussed above, (1) there is reasonable assurance that the health and safety of the public will not be endangered by operation in the proposed manner, (2) such activities will be conducted in compliance with the Commissions regulations, and (3) the issuance of the amendment will not be inimical to the common defense and security or to the health and safety of the public.

5.0 ENVIRONMENTAL CONSIDERATION

A review has determined that the proposed amendment would change a requirement with respect to installation or use of a facility component located within the restricted area, as defined in 10 CFR 20, or would change an inspection or surveillance requirement. However, the proposed amendment does not involve (i) a significant hazards consideration, (ii) a significant change in the types or significant increase in the amounts of any effluent that may be released offsite, or (iii) a significant increase in individual or cumulative occupational radiation exposure. Accordingly, the proposed amendment meets the eligibility criterion for categorical exclusion set forth in 10 CFR 51.22(c)(9). Therefore, pursuant to 10 CFR 51.22(b),

no environmental impact statement or environmental assessment need be prepared in connection with the proposed amendment.

LAR to Adopt TSTF-264, Revision 0 Docket No. 50-333 Enclosure Evaluation of Proposed Changes Page 6 of 6

6.0 REFERENCES

1. TSTF-264-A, Revision 0,"3.3.9 and 3.3.10 - Delete Flux Monitors Specific Overlap Requirement SRs"
2. NUREG-1433, Standard Technical Specifications, General Electric BWR/4 Plants, Volume 1, Revision 4, dated April 2012
3. Letter dated July 26, 1999, from NRR to NEI, Status of TSTFs, (NRC Approval of TSTF-264, Revision 0).

ATTACHMENT 1 Markup of Technical Specifications Pages License Amendment Request to Adopt TSTF-264-A, Revision 0, "3.3.9 and 3.3.10 - Delete Flux Monitors Specific Overlap Requirement SRs" James A. FitzPatrick Nuclear Power Plant Renewed Facility Operating License No. DPR-59 NRC Docket No. 50-333 Unit 1 TS Pages 3.3.1.1-4 3.3.1.1-6

RPS Instrumentation 3.3.1.1

/4NOT USED I SURVEILLANCE REQUIREMENTS (cont inued) /

SURVEI LLA~ FREQUENCY

/?'

SR 3.3.1.1.5 )J~~wre~ge-FROO~H.-f&P.MT-tms P..ri&~H-y i-A-tefmeaiate roAge-mef~&l'-fh~annels o<JerlaiT. >.w*Ji.~-v1~flg-SR~i5 SR 3.3.1.1.6 . . ... ......... . . . . .................. ...... . . ............ ~--------

Only reQt:1trea-te-eemet-tl-tffi..<T~sm MODE 1 .

1'f-,

Ve#fy the IRM ;:;;-: !:.PRM ef:lannels ovefla.!T. HT-ae-sordanee witA tRe-&-."-V~>>laR-ee HeQl:IOP.~Atfel

~NOT USED I ~

SR 3.3.1.1.7 Calibrate the local power range monitors. In accordance with the Surveillance Freq uency Cont rol Program SR 3.3.1.1.8 Perform CHANNEL FUNCTI ONAL TEST. In accordance with the Surveillance Freq uency Control Program SR 3.3.1.1.9 ...... - - - - - - - - ...... . . - - - - - ......... NOTE - -- ......... . . . . . . -- ............... . . . . . .

1. Neutron detectors are excluded.
2. For Functions 1.a and 2.a, not requ ired t o be performed when entering MODE 2 from MODE 1 until 12 hours1.388889e-4 days <br />0.00333 hours <br />1.984127e-5 weeks <br />4.566e-6 months <br /> after entering MODE 2.
3. For Funct ion 2.b, the recirculation loop f low signal portion of the channel is excluded.

Perform CHANNEL CALIBRATION. In accordance with t he Surveillance Frequency Control Program (contin ued)

JAFNPP 3.3.1.1-4 Amendment 301 I

RPS Instrumentation 3.3.1.1 Table 3.3.1.1-1 (page 1 of 3)

Reactor Protection System Instrumentation APPLICABLE CONDITIONS MODES OR REQUIRED REFERENCED OTHER CHANNELS FROM SPECIFIED PER TRIP REQUIRED SURVEILLANCE ALLOWABLE FUNCTION CONDITIONS SYSTEM ACTION D.1 REQUIREMENTS VALUE

1. Intermediate Range Monitors
a. Neutron Flux - High 2 3 G SR 3.3.1.1.1 s 120/125 SR 3.3.1.1.3 divisions of SR 3.3.1.1.4 full scale SR 3.3.1.1.5 SR 3.3.1.1.6 SR 3.3.1.1.9 SR 3.3.1.1.13 5(a) 3 H SR 3.3.1.1.1 s 1201125 SR 3.3.1.1.3 divisions of SR 3.3.1.1.4 full scale SR 3.3.1.1.9 SR 3 .3 .1.1.13
b. Inop 2 3 G SR 3.3.1.1.3 NA SR 3.3.1.1.4 SR 3 .3 .1.1.13 5(a) 3 H SR 3.3.1.1.3 NA SR 3.3.1.1.4 SR 3.3.1.1.13
2. Average Power Range Monitors
a. Neutron Flux - High, 2 2 G SR 3.3.1.1.1 s 15.%' RTP (Startup) SR 3.3.1.1.3 SR 3.3.1.1.4 SR 3.3.1.1.6 SR 3.3.1.1.7 SR 3.3.1.1.9 SR 3 .3 .1.1.13
b. Neutron Flux-High 1 2 F SR 3.3.1.1.1 As s~ecified (Fl ow Biased) SR 3.3.1.1.2 in t e COLR SR 3.3.1.1.4 and s 117.%' RTP SR 3.3.1.1.7 SR 3.3.1.1.8 SR 3.3.1.1.9 SR 3.3.1.1.12 SR 3.3.1.1.13 SR 3.3.1.1.15 (continued)

(a) With any control rod withdrawn fran a core cell containing one or more fuel assemblies.

JAFNPP 3.3.1.1-6 Amendment 274

ATTACHMENT 2 Markup of Technical Specifications Bases Pages FOR INFORMATION ONLY License Amendment Request to Adopt TSTF-264-A, Revision 0, "3.3.9 and 3.3.10 - Delete Flux Monitors Specific Overlap Requirement SRs" James A. FitzPatrick Nuclear Power Plant Renewed Facility Operating License No. DPR-59 NRC Docket No.

50-333 Unit 1 TS Bases Pages B 3.3.1.1-25 B 3.3.1.1-27 B 3.3.1.1-28 B 3.3.1.2-1 B 3.3.1.2-3

RPS Instrumentation B 3.3.1.1 BASES SURVEILLANCE SR 3.3.1.1.1 (continued)

REQUIREMENTS verifying the instrumentation continues to operate properly between each CHANNEL CALIBRATION. For Functions 8 and 9, this SR is associated with the enabling circuit sensing first stage pressure.

Channel agreement criteria are determined by the plant staff based on a combination of the channel instrument uncertainties, including indication and readability. If a channel is outside the criteria, it may be an indication that the instrument has drifted outside its limit.

INSERT 1 The Surveillance Frequency is controlled under the Surveillance Frequency Control Program. The CHANNEL CHECK supplements less formal, but more frequent, checks of channels during normal operational use of the displays associated with the channels required by the LCO.

SR 3.3.1.1.2 To ensure that the APRMs are accurately indicating the true core average power, the APRMs are adjusted to the reactor power calculated from a heat balance if the heat balance calculated reactor power exceeds the APRM channel output by more than 2% RTP.

This Surveillance does not preclude making APRM channel adjustments, if desired, when the heat balance calculated reactor power is less than the APRM channel output. To provide close agreement between the APRM indicated power and to preserve operating margin, the APRM channels are normally adjusted to within

+/- 2% of the heat balance calculated reactor power. However, this agreement is not required for OPERABILITY when APRM output indicates a higher reactor power than the heat balance calculated reactor power.

The Surveillance Frequency is controlled under the Surveillance Frequency Control Program.

A restriction to satisfying this SR when < 25% RTP is provided that requires the SR to be met only at 25% RTP because it is difficult to accurately maintain APRM indication of core THERMAL POWER consistent with a heat balance when < 25% RTP. At low power levels, a high degree of accuracy is unnecessary because of the large, inherent margin to thermal limits (MCPR and APLHGR). At 25% RTP, the Surveillance is required to have been satisfactorily performed in accordance with SR 3.0.2. A Note is provided which allows an increase (continued)

JAFNPP B 3.3.1.1-25 Revision 39

RPS Instrumentation B 3.3.1.1 BASES SURVEILLANCE SR 3.3.1.1.4 (continued)

REQUIREMENTS signal into the associated RPS trip channel. The RPS channel test switches are not specifically credited in the accident analysis. A successful test of the required contact(s) of a channel relay may be performed by the verification of the change of state of a single contact of the relay. This clarifies what is an acceptable CHANNEL FUNCTIONAL TEST of a relay. This is acceptable because all of the other required contacts of the relay are verified by other Technical Specifications and non-Technical Specifications tests at least once per refueling interval with applicable extensions. In accordance with Reference 18, the scram contactors must be tested as part of the Manual Scram Function. The Surveillance Frequency is controlled under the Surveillance Frequency Control Program.

SR 3.3.1.1.5 and SR 3.3.1.1.6 These Surveillances are established to ensure that no gaps in neutron flux indication exist from subcritical to power operation for monitoring core reactivity status.

The overlap between SRMs and IRMs is required to be demonstrated to ensure that reactor power will not be increased into a neutron flux region without adequate indication. This is required prior to fully withdrawing SRMs since indication is being transitioned from the SRMs to the IRMs.

NOT USED The overlap between IRMs and APRMs is of concern when reducing power into the IRM range. On power increases, the system design will prevent further increases (by initiating a rod block) if adequate overlap is not maintained. Overlap between IRMs and APRMs exists when sufficient IRMs and APRMs concurrently have onscale readings such that the transition between MODE 1 and MODE 2 can be made without either APRM downscale rod block, or IRM upscale rod block. Overlap between SRMs and IRMs similarly exists when, prior to fully withdrawing the SRMs, IRMs are above mid-scale on range 1 before SRMs have reached the upscale rod block.

As noted, SR 3.3.1.1.6 is only required to be met during entry into MODE 2 from MODE 1. That is, after the overlap requirement has been met and indication has transitioned to the IRMs, maintaining overlap is not required (APRMs may be reading downscale once in MODE 2).

If overlap for a group of channels is not demonstrated (e.g., IRM/APRM overlap), the reason for the failure of the Surveillance should be (continued)

JAFNPP B 3.3.1.1-27 Revision 39

RPS Instrumentation B 3.3.1.1 BASES SURVEILLANCE SR 3.3.1.1.5 and SR 3.3.1.1.6 (continued)

REQUIREMENTS determined and the appropriate channel(s) declared inoperable. Only those appropriate channels that are required in the current MODE or condition should be declared inoperable.

The Surveillance Frequency is controlled under the Surveillance Frequency Control Program.

SR 3.3.1.1.7 LPRM gain settings are determined from the local flux profiles measured by the Traversing Incore Probe (TIP) System. This establishes the relative local flux profile for appropriate representative input to the APRM System. The Surveillance Frequency is controlled under the Surveillance Frequency Control Program.

SR 3.3.1.1.8 and SR 3.3.1.1.11 A CHANNEL FUNCTIONAL TEST is performed on each required channel to ensure that the channel will perform the intended function. A successful test of the required contact(s) of a channel relay may be performed by the verification of the change of state of a single contact of the relay. This clarifies what is an acceptable CHANNEL FUNCTIONAL TEST of a relay. This is acceptable because all of the other required contacts of the relay are verified by other Technical Specifications and non-Technical Specifications tests at least once per refueling interval with the applicable extensions. Any setpoint adjustment shall be consistent with the assumptions of the current plant specific setpoint methodology. For Function 2.b, the CHANNEL FUNCTIONAL TEST includes the adjustment of the APRM channel to conform to the calibrated flow signal. This ensures that the total loop drive flow signals from the flow units used to vary the setpoint is appropriately compared to a valid core flow signal to verify the flow signal trip setpoint and, therefore, the APRM Function accurately reflects the required setpoint as a function of flow. If the flow unit signal is not within the appropriate flow limit, one required APRM that receives an input from the inoperable flow unit must be declared inoperable. For Function 7.b, the CHANNEL FUNCTIONAL TEST is performed utilizing a water column or similar device to provide assurance that damage to a float or other portions of the float assembly will be detected. For Function 10, the CHANNEL FUNCTIONAL TEST is performed by actually placing the reactor mode switch in the shutdown position.

The Surveillance Frequency is controlled under the Surveillance Frequency Control Program.

(continued)

JAFNPP B 3.3.1.1-28 Revision 39

SRM Instrumentation B 3.3.1.2 B 3.3 INSTRUMENTATION B 3.3.1.2 Source Range Monitor (SRM) Instrumentation BASES BACKGROUND The SRMs provide the operator with information relative to the neutron flux level at very low flux levels in the core.

As such. the SRM indication is used by the operator to monitor the approach to criticality and determine when criticality is achieved. The SRMs are maintained fully inserted until the count rate is greater than a minimum allowed count rate {a control rod block is set at this condition). After SRM to intermediate range monitor CIRM) overlap is demonstrated (as required by £R . . . ). the SRMs are normally fully withdrawn from the co~ SR 3.3.1.1.1 The SRM subsystem of the Neutron Monitoring System CNMS) consists of four channels. Each of the SRM channels can be bypassed. but only one at any given time. by the operation of a bypass switch. Each channel includes one detector that can be physically positioned in the core. Each detector assembly consists of a miniature fission chamber with associated cabling, signal conditioning equipment, and electronics associated with the various SRM functions. The signal conditioning equipment converts the current pulses from the fission chamber to analog DC currents that correspond to the count rate. Each channel also includes indication. alarm. and control rod blocks. However. this LCO specifies OPERABILITY requirements only for the monitoring and indication functions of the SRMs.

During refueling, shutdown. and low power operations. the primary indication of neutron flux levels is provided by the SRMs or special movable detectors connected to the normal SRM circuits. The SRMs provide monitoring of reactivity changes during fuel or control rod movement and give the control room operator early indication of unexpected subcritical multiplication that could be indicative of an approach to criticality.

APPLICABLE Prevention and mitigation of prompt reactivity excursions SAFETY ANALYSES during refueling and low power operation is provided by LCO 3.9.1, "Refueling Equipment Interlocks": LCO 3.1.1, "SHUTDOWN MARGIN CSDM)"; LCO 3.3.1.1. "Reactor Protection System (RPS) Instrumentation": !RM Neutron Flux - High and (continued)

JAFNPP B 3.3.1.2*1 Revision 0

SRM Instrumentation B 3.3.1.2 BASES LCO Special movable detectors, according to footnote (c) of (continued) Table 3.3.1.2-1, may be used in place of the normal SRM nuclear detectors. These special detectors must be connected to the normal SRM circuits in the NMS, such that the applicable neutron flux indication can be generated.

These special detectors provide more flexibility in monitoring reactivity changes during fuel loading, since they can be positioned anywhere within the core during refueling. They must still meet the location requirements of SR 3.3.1.2.2 and all other required SRs for SRMs.

For an SRM channel to be considered OPERABLE, it must be providing neutron flux monitoring indication.

APPLICABILITY The SRMs are required to be OPERABLE in MODES 2, 3, 4, and 5 prior to the IRMs being on scale on Range 3 to provide for neutron monitoring. In MODE 1, the APRMs provide adequate monitoring of reactivity changes in the core: therefore, the SRMs are not required. In MODE 2, with IRMs on Range 3 or above. the IRMs provide adequate monitoring and the SRMs are not required.

ACTIONS A.l and B.1 In MODE 2, with the IRMs on Range 2 or below, SRMs provide the means of monitoring core reactivity and criticality.

With any number of the required SRMs inoperable, the ability to monitor neutron flux is degraded. Therefore, a limited time is allowed to restore the inoperable channels to OPERABLE status.

Provided at least one SRM remains OPERABLE, Required Action A.l allows 4 hours4.62963e-5 days <br />0.00111 hours <br />6.613757e-6 weeks <br />1.522e-6 months <br /> to restore the required SRMs to OPERABLE status. This time is reasonable because there is adequate capability remaining to monitor the core, there is limited risk of an event during this time. and there is sufficient time to take corrective actions to restore the required SRMs to OPERABLE status or to establish alternate IRM monitoring capability. During this time. control rod withdrawal and power increase is not precluded by this Required Action. Having the ability to monitor the core with at least one SRM, proceeding to IRM Range 3 or greater (with overlap required by SR 3.3.1.1.5), and thereby exiting the Applicability of this LCO, is acceptable for ensuring adequate core monitoring and allowing continued operation.

(continued) verified by SR 3.3.1.1.1 JAFNPP B 3.3.1.2-3 Revision 0

ATTACHMENT 3 INSERT License Amendment Request to Adopt TSTF-264-A, Revision 0, "3.3.9 and 3.3.10 - Delete Flux Monitors Specific Overlap Requirement SRs" James A. FitzPatrick Nuclear Power Plant Renewed Facility Operating License No. DPR-59 NRC Docket No.

50-333 INSERT 1 The agreement criteria includes an expectation of one decade of overlap when transitioning between neutron flux instrumentation. The overlap between SRMs and IRMs must be demonstrated prior to withdrawing SRMs from the fully inserted position since indication is being transitioned from the SRMs to the IRMs. This will ensure that reactor power will not be increased into a neutron flux region without adequate indication. The overlap between IRMs and APRMs is of concern when reducing power into the IRM range (entry into MODE 2 from MODE 1).

On power increases, the system design will prevent further increases (by initiating a rod block) if adequate overlap is not maintained. Overlap between IRMs and APRMs exists when sufficient IRMs and APRMs concurrently have onscale readings such that the transition between MODE 1 and MODE 2 can be made without either APRM downscale rod block, or IRM upscale rod block.

Overlap between SRMs and IRMs similarly exists when, prior to withdrawing the SRMs from the fully inserted position, IRMs are above mid-scale on range I before SRMs have reached the upscale rod block.

If overlap for a group of channels is not demonstrated (e.g., IRM/APRM overlap), the reason for the failure of the Surveillance should be determined and the appropriate channel(s) declared inoperable. Only those appropriate channels that are required in the current MODE or condition should be declared inoperable.

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