L-23-269, Application to Revise Technical Specifications to Adopt TSTF-569, Revision of Response Time Testing Definitions

Application to Revise Technical Specifications to Adopt TSTF-569, Revision of Response Time Testing Definitions

ML24129A016
Person / Time
Site:	Beaver Valley
Issue date:	05/07/2024
From:	Blair B Vistra Operations Company
To:	Office of Nuclear Reactor Regulation, Document Control Desk
References
L-23-269
Download: ML24129A016 (1)

Text

L-23-269 May 7, 2024 A TIN: Document Control Desk U.S. Nuclear Regulatory Commission Washington, DC 20555-0001

SUBJECT:

Beaver Valley Power Station, Unit Nos. 1 and 2 Docket No. 50-334, License No. DPR-66 Docket No. 50-412, License No. NPF-73 I

Beaver Valley Power Station Barry N. Blair Site Vice President P.O. Box 4 200 State Route 3016 Shippingport. PA 15077 724-682-5234 10 CFR 50.90 Application to Revise Technical Specifications to Adopt TSTF-569, "Revision of Response Time Testing Definitions" Pursuant to 10 CFR 50.90, Vistra Operations Company LLC is submitting a request for an amendment to the Technical Specifications (TS) for Beaver Valley Power Station, Unit Nos. 1 and 2.

Vistra Operations Company LLC requests adoption of TSTF-569, "Revise Response Time Testing Definition,"

which is an approved change to the Improved Standard Technical Specifications (ISTS), into the Beaver Valley Power Station, Unit Nos. 1 and 2, Technical Specifications (TS). The proposed amendment revises the TS Definitions for Engineered Safety Feature (ESF) Response Time and Reactor Trip System (RTS) Response Time. provides a description and assessment of the proposed changes. Attachment 2 provides the existing TS pages marked to show the proposed changes. Attachment 3 provides revised (clean) TS pages. provides existing TS Bases pages marked to show the proposed changes for information only.

Approval of the proposed amendment is requested by May 7, 2025. Once approved, the amendment shall be implemented within 90 days.

There are no regulatory commitments contained in this submittal. If there are any questions, or if additional information is required, please contact Jack Hicks, Senior Manager, Licensing, at (254) 897-6725 or jack.hicks@luminant.com.

I declare under penalty of perjury that the foregoing is true and correct. Executed on May 7, 2024.

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Beaver Valley Power Station, Unit Nos. 1 and 2 L-23-269 Page2 Attachments:

1. Description and Assessment of the Proposed Change

2. Proposed Technical Specification Changes (Mark-Up)

3. Revised Technical Specification Pages

4. Proposed Technical Specification Bases Changes (Mark-Up, for Information Only) cc:

NRC Region I Administrator NRC Resident Inspector NRC Project Manager Director BRP /DEP Site BRP /DEP Representative

L-23-269 Description and Assessment of the Proposed Change Page 1 of 4

Subject:

Adoption of TSTF-569, Revise Response Time Testing Definition

2.0 ASSESSMENT

2.1 Applicability of Safety Evaluation 2.2 Variations

3.0 REGULATORY ANALYSIS

3.1 No Significant Hazards Consideration Determination 3.2 Conclusions 4.0 ENVIRONMENTAL EVALUATION L-23-269 Page 2 of 4

1.0 DESCRIPTION

Vistra Operations Company LLC requests adoption of TSTF-569, Revision 2, Revise Response Time Testing Definition, which is an approved change to the Improved Standard Technical Specifications (ISTS), into the Beaver Valley Power Station (BVPS), Unit Nos. 1 and 2, Technical Specifications (TS).

The proposed amendment revises the TS Definitions for Engineered Safety Feature (ESF) Response Time and Reactor Trip System (RTS) Response Time.

2.0 ASSESSMENT

2.1 Applicability of Safety Evaluation Vistra Operations Company LLC has reviewed the safety evaluation for TSTF-569, Revision 2, provided to the Technical Specifications Task Force in a letter dated August 14, 2019 (ADAMS Accession No. ML19176A188). This review included a review of the NRC staffs evaluation, as well as the information provided in TSTF-569, Revision 2. Vistra Operations Company LLC has concluded that the justifications presented in TSTF-569, Revision 2, and the safety evaluation prepared by the NRC staff are applicable to BVPS Unit Nos. 1 and 2 and justify this amendment for the incorporation of the changes to the BVPS TS.

2.2 Variations Vistra Operations Company LLC is proposing the following variations from the TS changes described in the TSTF-569 or the applicable parts of the NRC staffs safety evaluation dated August 14, 2019.

1. The BVPS TS Bases utilize a different numbering of the Surveillance Requirements (SR) in comparison to TSTF-569. TSTF-569 states SR 3.3.1.16 is for RTS Instrumentation; however, BVPS use SR 3.3.1.14. Additionally, TSTF-569 states SR 3.3.2.10 is for Engineered Safety Feature Actuation System (ESFAS) Instrumentation; however, BVPS use SR 3.3.2.9. These differences are administrative in nature and do not affect the applicability of TSTF-569 to BVPS.

2. The BVPS TS Bases utilize a different reference format than the Standard Technical Specifications on which TSTF-569 was based. Specifically, the BVPS TS Bases do not itemize references for the documents referenced within the TSTF-569 TS Bases change. Therefore, the TS Bases change identifies the documents rather than noting a reference. This difference is administrative and does not affect the applicability of TSTF-569 to the BVPS TS.

3. The BVPS TS Bases contain requirements that differ from the Standard Technical Specifications on which TSTF-569 was based. Specifically pertaining to RTS Instrumentation SR 3.3.1.14 and ESFAS Instrumentation SR 3.3.2.9. The BVPS TS Bases contain the additional allowance for the use of WCAP-15413, Westinghouse 7300A ASIC-Based Replacement Module Licensing Summary Report to provide bounding response times where 7300 cards have been replaced with ASICs cards. WCAP-15413 is referenced in the technical evaluation of TSTF-569 as a topical report that the NRC staff evaluated and confirmed to provide additional detailed justification that forms the basis for the methodology in Attachment 1 to TSTF-569, Revision 2.

The applicability of this difference is specific to ASIC cards that have replaced 7300 cards and does not affect the applicability of TSTF-569 to the BVPS TS.

3.0 REGULATORY ANALYSIS

3.1 No Significant Hazards Consideration Determination Vistra Operations Company LLC requests adoption of TSTF-569, Revise Response Time Testing Definition, which is an approved change to the Improved Standard Technical Specifications (ISTS), into the Beaver Valley Power Station (BVPS), Unit Nos 1 and 2, Technical Specifications (TS). The proposed L-23-269 Page 3 of 4 amendment revises the TS Definitions for Engineered Safety Feature (ESF) Response Time and Reactor Trip System (RTS) Response Time.

Vistra Operations Company LLC has evaluated whether 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 amendment involve a significant increase in the probability or consequences of an accident previously evaluated?

Response: No.

The proposed change revises the TS definition of RTS and ESF instrumentation response time to permit the licensee to evaluate using an NRC-approved methodology and apply a bounding response time for some components in lieu of measurement. The requirement for the instrumentation to actuate within the response time assumed in the accident analysis is unaffected.

The response time associated with the RTS and ESF instrumentation is not an initiator of any accident.

Therefore, the proposed change has no significant effect on the probability of any accident previously evaluated.

The affected RTS and ESF instrumentation are assumed to actuate their respective components within the required response time to mitigate accidents previously evaluated. Revising the TS definition for RTS and ESF instrumentation response times to allow an NRC-approved methodology for verifying response time for some components does not alter the surveillance requirements that verify the RTS and ESF instrumentation response times are within the required limits. As such, the TS will continue to assure that the RTS and ESF instrumentation actuate their associated components within the specified response time to accomplish the required safety functions assumed in the accident analyses. Therefore, the assumptions used in any accidents previously evaluated are unchanged, and there is no significant increase in the consequences.

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

Response: No.

The proposed change revises the TS definition of RTS and ESF instrumentation response time to permit the licensee to evaluate using an NRC-approved methodology and apply a bounding response time for some components in lieu of measurement. The proposed change does not involve a physical alteration of the plant (no new or different type of equipment will be installed). The proposed change does not alter any assumptions made in the safety analyses. The proposed change does not alter the limiting conditions for operation for the RTS or ESF instrumentation, nor does it change the surveillance requirement to verify the RTS and ESF instrumentation response times are within the required limits. As such, the proposed change does not alter the operability requirements for the RTS and ESF instrumentation, and therefore, does not introduce any new failure modes.

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 amendment involve a significant reduction in a margin of safety?

Response: No.

The proposed change revises the TS definition of RTS and ESF instrumentation response time to permit the licensee to evaluate using an NRC-approved methodology and apply a bounding response time for some components in lieu of measurement. The proposed change has no effect on the required RTS and L-23-269 Page 4 of 4 ESF instrumentation response times or setpoints assumed in the safety analyses and the TS requirements to verify those response times and setpoints. The proposed change does not alter any safety limits or analytical limits in the safety analysis. The proposed change does not alter the TS operability requirements for the RTS and ESF instrumentation. The RTS and ESF instrumentation actuation of the required systems and components at the required setpoints and within the specified response times will continue to accomplish the design basis safety functions of the associated systems and components in the same manner as before. As such, the RTS and ESF instrumentation will continue to perform the required safety functions as assumed in the safety analyses for all previously evaluated accidents.

Therefore, the proposed change does not involve a significant reduction in a margin of safety.

Based on the above, Vistra Operations Company LLC concludes that the proposed change 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.

3.2 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.

4.0 ENVIRONMENTAL EVALUATION The proposed change 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 change does not involve (i) a significant hazards consideration, (ii) a significant change in the types or significant increase in the amounts of any effluents that may be released offsite, or (iii) a significant increase in individual or cumulative occupational radiation exposure. Accordingly, the proposed change 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 change.

L-23-269 Proposed Technical Specification Changes (Mark-Up)

(2 pages follow)

Definitions 1.1 1.1 Definitions ENGINEERED SAFETY The ESF RESPONSE TIME shall be that time interval from FEATURE (ESF) RESPONSE when the monitored parameter exceeds its actuation setpoint TIME at the channel sensor until the ESF equipment is capable of performing its safety function (i.e., the valves travel to their required positions, pump discharge pressures reach their required values, etc.). Times shall include diesel generator starting and sequence loading delays, where applicable. The response time may be measured by means of any series of sequential, overlapping, or total steps so that the entire response time is measured. In lieu of measurement, response time may be verified for selected components provided that the components and methodology for verification have been previously reviewed and approved by the NRC, or the components have been evaluated in accordance with an NRC approved methodology.

INSERVICE TESTING The INSERVICE TESTING PROGRAM is the licensee PROGRAM program that fulfills the requirements of 10 CFR 50.55a(f).

LEAKAGE LEAKAGE shall be:

a.

Identified LEAKAGE

1.

LEAKAGE, such as that from pump seals or valve packing (except reactor coolant pump (RCP) seal water injection or leakoff), that is captured and conducted to collection systems or a sump or collecting tank;

2.

LEAKAGE into the containment atmosphere from sources that are both specifically located and known to not interfere with the operation of leakage detection systems; or

3.

Reactor Coolant System (RCS) LEAKAGE through a steam generator to the Secondary System (primary to secondary LEAKAGE);

b.

Unidentified LEAKAGE All LEAKAGE (except RCP seal water injection or leakoff) that is not identified LEAKAGE; and

c.

Pressure Boundary LEAKAGE LEAKAGE (except primary to secondary LEAKAGE) through a fault in an RCS component body, pipe wall, or vessel wall. LEAKAGE past seals, packing, and gaskets is not pressure boundary LEAKAGE.

Beaver Valley Units 1 and 2 1.1 - 3 Amendments 318 / 209

Definitions 1.1 1.1 Definitions QUADRANT POWER TILT QPTR shall be the ratio of the maximum upper excore detector RATIO (QPTR) calibrated output to the average of the upper excore detector calibrated outputs, or the ratio of the maximum lower excore detector calibrated output to the average of the lower excore detector calibrated outputs, whichever is greater.

RATED THERMAL POWER RTP shall be a total reactor core heat transfer rate to the (RTP) reactor coolant as specified in the Licensing Requirements Manual, and shall not exceed 2900 MWt.

REACTOR TRIP SYSTEM The RTS RESPONSE TIME shall be that time interval from (RTS) RESPONSE TIME when the monitored parameter exceeds its RTS trip setpoint at the channel sensor until loss of stationary gripper coil voltage.

The response time may be measured by means of any series of sequential, overlapping, or total steps so that the entire response time is measured. In lieu of measurement, response time may be verified for selected components provided that the components and methodology for verification have been previously reviewed and approved by the NRC, or the components have been evaluated in accordance with an NRC approved methodology.

SHUTDOWN MARGIN (SDM)

SDM shall be the instantaneous amount of reactivity by which the reactor is subcritical or would be subcritical from its present condition assuming:

a.

All rod cluster control assemblies (RCCAs) are fully inserted except for the single RCCA of highest reactivity worth, which is assumed to be fully withdrawn. However, with all RCCAs verified fully inserted by two independent means, it is not necessary to account for a stuck RCCA in the SDM calculation. With any RCCA not capable of being fully inserted, the reactivity worth of the RCCA must be accounted for in the determination of SDM, and

b.

In MODES 1 and 2, the fuel and moderator temperatures are changed to the nominal zero power design level.

SLAVE RELAY TEST A SLAVE RELAY TEST shall consist of energizing all slave relays in the channel required for channel OPERABILITY and verifying the OPERABILITY of each required slave relay. The SLAVE RELAY TEST shall include a continuity check of associated required testable actuation devices. The SLAVE RELAY TEST may be performed by means of any series of sequential, overlapping, or total steps.

Beaver Valley Units 1 and 2 1.1 - 5 Amendments 278 / 161

L-23-269 Revised Technical Specification Pages (2 pages follow)

Definitions 1.1 1.1 Definitions ENGINEERED SAFETY The ESF RESPONSE TIME shall be that time interval from FEATURE (ESF) RESPONSE when the monitored parameter exceeds its actuation setpoint TIME at the channel sensor until the ESF equipment is capable of performing its safety function (i.e., the valves travel to their required positions, pump discharge pressures reach their required values, etc.). Times shall include diesel generator starting and sequence loading delays, where applicable. The response time may be measured by means of any series of sequential, overlapping, or total steps so that the entire response time is measured. In lieu of measurement, response time may be verified for selected components provided that the components and methodology for verification have been previously reviewed and approved by the NRC, or the components have been evaluated in accordance with an NRC approved methodology.

INSERVICE TESTING The INSERVICE TESTING PROGRAM is the licensee PROGRAM program that fulfills the requirements of 10 CFR 50.55a(f).

LEAKAGE LEAKAGE shall be:

a.

Identified LEAKAGE

1.

LEAKAGE, such as that from pump seals or valve packing (except reactor coolant pump (RCP) seal water injection or leakoff), that is captured and conducted to collection systems or a sump or collecting tank;

2.

LEAKAGE into the containment atmosphere from sources that are both specifically located and known to not interfere with the operation of leakage detection systems; or

3.

Reactor Coolant System (RCS) LEAKAGE through a steam generator to the Secondary System (primary to secondary LEAKAGE);

b.

Unidentified LEAKAGE All LEAKAGE (except RCP seal water injection or leakoff) that is not identified LEAKAGE; and

c.

Pressure Boundary LEAKAGE LEAKAGE (except primary to secondary LEAKAGE) through a fault in an RCS component body, pipe wall, or vessel wall. LEAKAGE past seals, packing, and gaskets is not pressure boundary LEAKAGE.

Beaver Valley Units 1 and 2 1.1 - 3 Amendments /

Definitions 1.1 1.1 Definitions QUADRANT POWER TILT QPTR shall be the ratio of the maximum upper excore detector RATIO (QPTR) calibrated output to the average of the upper excore detector calibrated outputs, or the ratio of the maximum lower excore detector calibrated output to the average of the lower excore detector calibrated outputs, whichever is greater.

RATED THERMAL POWER RTP shall be a total reactor core heat transfer rate to the (RTP) reactor coolant as specified in the Licensing Requirements Manual, and shall not exceed 2900 MWt.

REACTOR TRIP SYSTEM The RTS RESPONSE TIME shall be that time interval from (RTS) RESPONSE TIME when the monitored parameter exceeds its RTS trip setpoint at the channel sensor until loss of stationary gripper coil voltage.

The response time may be measured by means of any series of sequential, overlapping, or total steps so that the entire response time is measured. In lieu of measurement, response time may be verified for selected components provided that the components and methodology for verification have been previously reviewed and approved by the NRC, or the components have been evaluated in accordance with an NRC approved methodology.

SHUTDOWN MARGIN (SDM)

SDM shall be the instantaneous amount of reactivity by which the reactor is subcritical or would be subcritical from its present condition assuming:

a.

All rod cluster control assemblies (RCCAs) are fully inserted except for the single RCCA of highest reactivity worth, which is assumed to be fully withdrawn. However, with all RCCAs verified fully inserted by two independent means, it is not necessary to account for a stuck RCCA in the SDM calculation. With any RCCA not capable of being fully inserted, the reactivity worth of the RCCA must be accounted for in the determination of SDM, and

b.

In MODES 1 and 2, the fuel and moderator temperatures are changed to the nominal zero power design level.

SLAVE RELAY TEST A SLAVE RELAY TEST shall consist of energizing all slave relays in the channel required for channel OPERABILITY and verifying the OPERABILITY of each required slave relay. The SLAVE RELAY TEST shall include a continuity check of associated required testable actuation devices. The SLAVE RELAY TEST may be performed by means of any series of sequential, overlapping, or total steps.

Beaver Valley Units 1 and 2 1.1 - 5 Amendments /

L-23-269 Proposed Technical Specification Bases Changes (Mark-Up, for Information Only)

(4 pages follow)

RTS Instrumentation B 3.3.1 BASES SURVEILLANCE REQUIREMENTS (continued)

- NOTE -

The following alternate means for verifying response times (i.e.,

summation of allocated times) is only applicable to Unit 2.

Response time may be verified by actual response time tests in any series of sequential, overlapping or total channel measurements, or by the summation of allocated sensor, signal processing and actuation logic response times with actual response time tests on the remainder of the channel. Allocations for sensor response times may be obtained from:

(1) historical records based on acceptable response time tests (hydraulic, noise, or power interrupt tests), (2) in place, onsite, or offsite (e.g.,

vendor) test measurements, or (3) utilizing vendor engineering specifications. WCAP-13632-P-A, Revision 2, "Elimination of Pressure Sensor Response Time Testing Requirements," provides the basis and methodology for using allocated sensor response times in the overall verification of the channel response time for specific sensors identified in the WCAP. Response time verification for other sensor types must be demonstrated by test.

WCAP-14036-P-A, Revision 1, "Elimination of Periodic Protection Channel Response Time Tests," and WCAP-15413, "Westinghouse 7300A ASIC-Based Replacement Module Licensing Summary Report" provide the basis and methodology for using allocated signal processing and actuation logic response times in the overall verification of the protection system channel response time. The allocations for sensor, signal conditioning, and actuation logic response times must be verified prior to placing the component in operational service and re-verified following maintenance that may adversely affect response time. In general, electrical repair work does not impact response time provided the parts used for repair are of the same type and value. Specific components identified in the WCAP may be replaced without verification testing. One example where response time could be affected is replacing the sensing assembly of a transmitter. WCAP-15413 provides bounding response times where 7300 cards have been replaced with ASICs cards.

The response time may be verified for components that replace the components that were previously evaluated in WCAP-13632-P-A and WCAP-14036-P-A provided that the components have been evaluated in accordance with the NRC approved methodology as discussed in to TSTF-569, Methodology to Eliminate Pressure Sensor and Protection Channel (for Westinghouse Plants only) Response Time Testing, (Ref 11).

Beaver Valley Units 1 and 2 B 3.3.1 - 58 Revision 29 For Information Only

RTS Instrumentation B 3.3.1 BASES SURVEILLANCE REQUIREMENTS (continued)

As appropriate, each channel's response must be verified at the Frequency specified in the Surveillance Frequency Control Program.

Each verification shall include at least one logic train such that both logic trains are verified at least once per the stated Frequency specified in the Surveillance Frequency Control Program. Response times cannot be determined during unit operation because equipment operation is required to measure response times. The Surveillance Frequency is controlled under the Surveillance Frequency Control Program.

SR 3.3.1.14 is modified by a Note stating that neutron detectors are excluded from RTS RESPONSE TIME testing. This Note is necessary because of the difficulty in generating an appropriate detector input signal. Excluding the detectors is acceptable because the principles of detector operation ensure a virtually instantaneous response.

REFERENCES 1.

Westinghouse Setpoint Methodology for Protection Systems, WCAP-11419, Rev. 6 (Unit 1) and WCAP-11366, Rev. 7 (Unit 2).

2.

UFSAR, Chapter 7 (Unit 1 and Unit 2).

3.

UFSAR Chapter 14 (Unit 1) and UFSAR Chapter 15 (Unit 2).

4.

IEEE-279-1971.

5.

10 CFR 50.49.

6.

Westinghouse Nuclear Safety Advisory Letter NSAL-00-016, Rod Withdrawal from Subcritical Protection in Lower Modes, December 4, 2000.

7.

WCAP-14333-P-A, Rev. 1, Probabilistic Risk Analysis of the RPS and ESFAS Test Times and Completion Times, October 1998.

8.

WOG-06-17, WCAP-10271-P-A Justification for Bypass Test Time and Completion Time Technical Specification Changes for Reactor Trip on Turbine Trip, June 20, 2006.

9.

WCAP-15376-P-A, Rev. 1, Risk-Informed Assessment of the RTS and ESFAS Surveillance Test Intervals and Reactor Trip Breaker Test and Completion Times, March 2003.

10.

Amendment No. 282 (Unit 1) and Amendment No. 166 (Unit 2),

December 29, 2008.

11. to TSTF-569, Methodology to Eliminate Pressure Sensor and Protection Channel (for Westinghouse Plants only)

Response Time Testing" Beaver Valley Units 1 and 2 B 3.3.1 - 59 Revision 11 For Information Only

ESFAS Instrumentation B 3.3.2 BASES SURVEILLANCE REQUIREMENTS (continued)

(1) historical records based on acceptable response time tests (hydraulic, noise, or power interrupt tests), (2) in place, onsite, or offsite (e.g.,

vendor) test measurements, or (3) utilizing vendor engineering specifications. WCAP-13632-P-A, Revision 2, "Elimination of Pressure Sensor Response Time Testing Requirements," dated January 1996, provides the basis and methodology for using allocated sensor response times in the overall verification of the channel response time for specific sensors identified in the WCAP. Response time verification for other sensor types must be demonstrated by test.

WCAP-14036-P, Revision 1, "Elimination of Periodic Protection Channel Response Time Tests," and WCAP-15413, "Westinghouse 7300A ASIC-Based Replacement Module Licensing Summary Report" provide the basis and methodology for using allocated signal processing and actuation logic response times in the overall verification of the protection system channel response time. The allocations for sensor, signal conditioning, and actuation logic response times must be verified prior to placing the component in operational service and re-verified following maintenance that may adversely affect response time. In general, electrical repair work does not impact response time provided the parts used for repair are of the same type and value. Specific components identified in the WCAP may be replaced without verification testing. One example where response time could be affected is replacing the sensing assembly of a transmitter. WCAP-15413 provides bounding response times where 7300 cards have been replaced with ASICs cards.

The response time may be verified for components that replace the components that were previously evaluated in WCAP-13632-P-A and WCAP-14036-P provided that the components have been evaluated in accordance with the NRC approved methodology as discussed in to TSTF-569, Methodology to Eliminate Pressure Sensor and Protection Channel (for Westinghouse Plants only) Response Time Testing, (Ref 8).

Testing of the final actuation devices, which make up the bulk of the response time, is included in the testing of each channel. The final actuation device in one train is tested with each channel. The Surveillance Frequency is controlled under the Surveillance Frequency Control Program.

This SR is modified by a Note that clarifies that the turbine driven AFW pump is tested within 24 hours2.777778e-4 days <br />0.00667 hours <br />3.968254e-5 weeks <br />9.132e-6 months <br /> after reaching 600 psig in the secondary side of the SGs.

Beaver Valley Units 1 and 2 B 3.3.2 - 53 Revision 29 For Information Only

ESFAS Instrumentation B 3.3.2 BASES REFERENCES 1.

UFSAR Chapter 14 (Unit 1) and UFSAR Chapter 15 (Unit 2).

2.

IEEE-279-1971.

3.

Westinghouse Setpoint Methodology for Protection Systems, WCAP-11419, Rev. 6 (Unit 1) and WCAP-11366, Rev. 7 (Unit 2).

4.

10 CFR 50.49.

5.

WCAP-10271-P-A, Supplement 2, Rev. 1, June 1990.

6.

WCAP-14333-P-A, Rev. 1, Probabilistic Risk Analysis of the RPS and ESFAS Test Times and Completion Times, October 1998.

7.

Amendment No. 282 (Unit 1) and Amendment No. 166 (Unit 2),

December 29, 2008.

8. to TSTF-569, Methodology to Eliminate Pressure Sensor and Protection Channel (for Westinghouse Plants only)

Response Time Testing Beaver Valley Units 1 and 2 B 3.3.2 - 54 Revision 29 For Information Only