ML24339B304
| ML24339B304 | |
| Person / Time | |
|---|---|
| Site: | Grand Gulf, Arkansas Nuclear, River Bend, Waterford |
| Issue date: | 12/04/2024 |
| From: | Couture P Entergy Operations |
| To: | Office of Nuclear Reactor Regulation, Document Control Desk |
| References | |
| CNRO2024-00002 | |
| Download: ML24339B304 (1) | |
Text
Phil Couture Senior Manager Fleet Regulatory Assurance - Licensing 601-368-5102
Entergy Operations, Inc., 1340 Echelon Parkway, Jackson, MS 39213 CNRO2024-00002 10 CFR 50.90 December 4, 2024 ATTN: Document Control Desk U.S. Nuclear Regulatory Commission Washington, DC 20555-0001
Subject:
Application to Revise Technical Specifications to Use Online Monitoring Methodology Arkansas Nuclear One, Units 1 and 2 NRC Docket No. 50-313 and 50-368 Renewed Facility Operating License No. DPR-51 and NPF-6 River Bend Station, Unit 1 NRC Docket No. 50-458 Renewed Facility Operating License No. NPF-47 Grand Gulf Nuclear Station, Unit 1 NRC Docket No. 50-416 Renewed Facility Operating License No. NPF-29 Waterford Steam Electric Station, Unit 3 NRC Docket No. 50-382 Renewed Facility Operating License No. NPF-38 Pursuant to the provisions Section 50.90 of Title 10 Code of Federal Regulations (CFR),
Entergy Operations, Inc.(Entergy) hereby requests a license amendment to the Arkansas Nuclear One (ANO), Units 1 and 2 (ANO-1 and ANO-2), Grand Gulf Nuclear Station, Unit 1 (GGNS), River Bend Station, Unit 1 (RBS), and Waterford Steam Electric Station, Unit 3 (WF3).
The proposed amendment revises Definitions and adds a new "Online Monitoring Program."
Entergy proposes to use online monitoring (OLM) methodology as the technical basis to switch from time-based surveillance frequency for channel calibrations to a condition-based calibration frequency based on OLM results. The proposed change is based on the NRC-approved topical report AMS-TR-0720R2-A, "Online Monitoring Technology to Extend Calibration Intervals of Nuclear Plant Pressure Transmitters."
The Enclosure to this letter provides a description and assessment of the proposed changes to TS for ANO-1, ANO-2, GGNS, RBS, and WF3. Attachments 1 - 15 contain the TS Markups Pages, TS Clean Typed Pages, and the TS Bases Markup (information only) for each site.
Entergy requests approval of the proposed license amendment within one year from acceptance of this submittal. The proposed changes would be implemented within 90 days of issuance of the amendment.
CNRO2024-00002 Page 2 of 3 This letter contains no new regulatory commitments.
Should you have any questions or require additional information, please contact me at 601-368-5102.
In accordance with 10 CFR 50.91, "Notice for public comment; State consultation,"
paragraph (b), a copy of this application, with attachments, is being provided to the designated State Officials.
I declare under penalty of perjury; the foregoing is true and correct.
Executed on December 4, 2024.
Respectfully, Phil Couture PC/chm
Enclosure:
Evaluation of the Proposed Change Attachments to
Enclosure:
- 1.
Technical Specification Mark-ups
- ANO-1
- 2. Technical Specification Mark-ups
- ANO-2
- 3.
Technical Specification Mark-ups
- GGNS
- 4.
Technical Specification Mark-ups
- RBS
- 5.
Technical Specification Mark-ups
- WF3
- 6.
Technical Specification Clean Typed
- ANO-1
- 7. Technical Specification Clean Typed
- ANO-2
- 8.
Technical Specification Clean Typed
- GGNS
- 9.
Technical Specification Clean Typed
- RBS
- 10. Technical Specification Clean Typed
- WF3
- 11. Technical Specification Bases Mark-ups - ANO-1 (Information only)
- 12. Technical Specification Bases Mark-ups - ANO-2 (Information only)
- 13. Technical Specification Bases Mark-ups - GGNS (Information only)
- 14. Technical Specification Bases Mark-ups - RBS (Information only)
- 15. Technical Specification Bases Mark-ups - WF3 (Information only)
Digitally signed by Philip Couture DN: cn=Philip Couture, c=US, o=Entergy, ou=Regulatory Assurance, email=pcoutur@entergy.com Date: 2024.12.04 09:55:35 -06'00' Philip Couture
CNRO2024-00002 Page 3 of 3 cc:
NRC Region IV Regional Administrator NRC Senior Resident Inspector - ANO NRC Senior Resident Inspector - GGNS NRC Senior Resident Inspector - RBS NRC Senior Resident Inspector - WF3 NRC Project Manager
- Entergy Fleet NRC Project Manager
- ANO NRC Project Manager
- GGNS NRC Project Manager
- RBS NRC Project Manager
- WF3 Designated State Official
- Arkansas Designated State Official
- Louisiana Designated State Official
Enclosure CNRO2024-00002 Evaluation of the Proposed Change
CNRO2024-00002 Enclosure Page 1 of 30 TABLE OF CONTENTS 1.0
SUMMARY
DESCRIPTION.............................................................................................. 4 2.0 DETAILED DESCRIPTION............................................................................................... 4 2.1 Background................................................................................................................... 4 2.2 System Design and Operation...................................................................................... 5 2.2.1 Reactor Protection Systems (RPS)........................................................................... 5 2.2.2 The BWR Anticipated Transient Without Scram (ATWS) System............................. 5 2.2.3 Engineered Safeguards Actuation System (ESAS) and Engineered Safety Feature Actuation Systems (ESFAS).................................................................................... 5 2.2.4 Emergency Core Cooling System (ECCS) and Engineered Safety Feature (ESF)... 6 2.2.5 Post Accident Monitoring (PAM)............................................................................... 6 2.2.6 Remote Shutdown Systems...................................................................................... 6 2.2.7 Low Temperature Overpressure Protection (LTOP)................................................. 7 2.2.8 System Evaluation..................................................................................................... 7 2.3 Reason for the Proposed Change................................................................................. 7 2.4 Description of the Proposed Change............................................................................ 8 2.4.1 ANO-1....................................................................................................................... 8 2.4.2 ANO-2....................................................................................................................... 8 2.4.3 GGNS........................................................................................................................ 9 2.4.4 RBS......................................................................................................................... 11 2.4.5 WF3......................................................................................................................... 13 2.4.6 New Program for ANO-1, ANO-2, GGNS, RBS and WF3 TS................................. 14
3.0 TECHNICAL EVALUATION
............................................................................................ 15 3.1 OLM Implementation Process Development............................................................... 15 3.1.1 Determine if Transmitters are Amenable to OLM.................................................... 15 3.1.2 List Transmitters in Each Redundant Group........................................................... 15 3.1.3 Determine if OLM Data Covers Applicable Setpoints.............................................. 15 3.1.4 Calculate Backstops................................................................................................ 15 3.1.5 Establish Method of Data Acquisition...................................................................... 16 3.1.6 Specify Data Collection Duration and Sampling Rate............................................. 16 3.1.7 Identify Data Analysis Methods............................................................................... 16 3.1.8 Establish OLM Limits............................................................................................... 16 3.2 OLM Program Implementation.................................................................................... 16 3.2.1 Retrieve OLM Data.................................................................................................. 17 3.2.2 Perform Data Qualification...................................................................................... 17 3.2.3 Select Appropriate Region of Any Transient Data................................................... 18
CNRO2024-00002 Enclosure Page 2 of 30 3.2.4 Perform Data Analysis............................................................................................. 18 3.2.5 Plot the Average Deviation for Each Transmitter.................................................... 18 3.2.6 Produce a Table for Each Group That Combines All Results................................. 18 3.2.7 Determine OLM Results for Each Transmitter........................................................ 18 3.2.8 Address Uncertainties in the Unexercised Portion of Transmitter Range............... 19 3.2.9 Select Transmitters to Be Checked for Calibration as a Backstop.......................... 19 3.2.10 Perform Dynamic Failure Mode Assessment.......................................................... 19 3.2.11 Produce a Report of Transmitters Scheduled for Calibration Check....................... 19 3.3 OLM Noise Analysis Implementation.......................................................................... 19 3.3.1 Select Qualified Noise Data Acquisition Equipment................................................ 20 3.3.2 Connect Noise Data Acquisition Equipment to Plant Signals.................................. 20 3.3.3 Collect and Store Data for Subsequent Analysis.................................................... 20 3.3.4 Screen Data for Artifacts and Anomalies................................................................ 21 3.3.5 Perform Data Analysis............................................................................................. 21 3.3.6 Review and Document Results............................................................................... 21 3.4 Application Specific Action Items from AMS OLM TR................................................. 21 3.4.1 ASAI 1 - Evaluation and Proposed Mark-up of Existing Plant Technical Specifications......................................................................................................... 21 3.4.2 ASAI 2 - Identification of Calibration Error Source.................................................. 22 3.4.3 ASAI 3 - Response Time (RT) Test Elimination Basis............................................ 22 3.4.4 ASAI 4 - Use of Calibration Surveillance Interval Backstop.................................... 23 3.4.5 ASAI 5 - Use of Criteria other than in AMS OLM TR for Establishing Transmitter Drift Flagging Limit................................................................................................. 23
4.0 REGULATORY EVALUATION
........................................................................................ 23 4.1 Applicable Regulatory Requirements/Criteria............................................................. 23 4.1.1 10 CFR 50.36 Technical Specifications.................................................................. 23 4.1.2 10 CFR Part 50 Appendix A.................................................................................... 24 4.1.3 Regulatory Guide 1.118, Revision 3........................................................................ 24 4.1.4 IEEE Standard 338-1977........................................................................................ 24 4.1.5 IEEE Standard 338-2012........................................................................................ 25 4.2 Precedent.................................................................................................................... 26 4.3 No Significant Hazards Consideration Determination Analysis................................... 26 4.4 Conclusions................................................................................................................. 28
5.0 ENVIRONMENTAL CONSIDERATION
.......................................................................... 28
6.0 REFERENCES
................................................................................................................ 29 7.0 ATTACHMENTS............................................................................................................. 30
CNRO2024-00002 Enclosure Page 3 of 30 1.
Technical Specification Mark-ups - ANO-1............................................................ 30 2.
Technical Specification Mark-ups - ANO-2............................................................ 30 3.
Technical Specification Mark-ups - GGNS............................................................ 30 4.
Technical Specification Mark-ups - RBS............................................................... 30 5.
Technical Specification Mark-ups - WF3............................................................... 30 6.
Technical Specification Clean Typed - ANO-1...................................................... 30 7.
Technical Specification Clean Typed - ANO-2...................................................... 30 8.
Technical Specification Clean Typed - GGNS....................................................... 30 9.
Technical Specification Clean Typed - RBS.......................................................... 30 10.
Technical Specification Clean Typed - WF3.......................................................... 30 11.
Technical Specification Bases Mark-ups - ANO-1 (Information only).................... 30 12.
Technical Specification Bases Mark-ups - ANO-2 (Information only).................... 30 13.
Technical Specification Bases Mark-ups - GGNS (Information only).................... 30 14.
Technical Specification Bases Mark-ups - RBS (Information only)....................... 30 15.
Technical Specification Bases Mark-ups - WF3 (Information only)....................... 30
CNRO2024-00002 Enclosure Page 4 of 30 EVALUATION OF THE PROPOSED CHANGE 1.0
SUMMARY
DESCRIPTION Pursuant to the provisions Section 50.90 of Title 10 Code of Federal Regulations (CFR),
Entergy Operations, Inc.(Entergy) hereby requests a license amendment to the Arkansas Nuclear One (ANO), Units 1 and 2 (ANO-1 and ANO-2), Grand Gulf Nuclear Station, Unit 1 (GGNS), River Bend Station, Unit 1 (RBS), and Waterford Steam Electric Station, Unit 3 (WF3). The proposed amendment revises Definitions and adds a new "Online Monitoring Program." Entergy proposes to use online monitoring (OLM) methodology as the technical basis to switch from time-based surveillance frequency for channel calibrations to a condition-based calibration frequency based on OLM results.
2.0 DETAILED DESCRIPTION
2.1 Background
OLM technologies have been developed and validated for condition monitoring applications in a variety of process and power industries. This application of OLM is used to optimize maintenance of instrumentation and control (I&C) systems including online drift monitoring and assessment of dynamic failure modes of transmitters.
Analysis and Measurement Services (AMS) Topical Report (TR) AMS-TR-0720R2-A, "Online Monitoring Technology to Extend Calibration Intervals of Nuclear Plant Pressure Transmitters" (References 1 and 2) focused on the application of OLM for monitoring drift of pressure, level, and flow transmitters in nuclear power plants. The TR addressed the following topics:
Advances in OLM implementation technology to extend transmitter calibration intervals Experience with OLM implementation in nuclear facilities Comparison between OLM results and manual calibrations Transmitter failure modes that can be detected by OLM Related regulatory requirements and industry standards and guidelines Procedures for implementation of OLM methodology Changes that must be made to existing technical specifications to adopt OLM AMS-TR-0720R2-A provided the NRC with the information needed to approve the AMS OLM methodology for implementation in nuclear power plants. The TR is intended to be used by licensees to support plant-specific technical specification changes to switch from time-based calibration frequency of pressure, level, and flow transmitters to a condition-based calibration frequency based on OLM results and to develop procedures to assess dynamic failure modes of pressure sensing systems using the noise analysis technique.
The NRC staff determined that the methodology outlined in the AMS OLM TR for applying OLM techniques to pressure, level, and flow transmitters can be used to provide reasonable assurance that required TS instrument calibration requirements for transmitters will be maintained. This determination was based on the NRC staff finding that OLM techniques: a) are effective at identifying instrument calibration drift during
CNRO2024-00002 Enclosure Page 5 of 30 plant operation, b) provide an acceptable means of identifying when manual transmitter calibration using traditional calibration methods are needed, and c) will maintain an acceptable level of performance that is traceable to calibration prime standards.
The NRC staff found that implementation of an OLM program in accordance with the approved AMS OLM TR provides an acceptable alternative to periodic manual calibration surveillance requirements upon implementation of the application-specific action items (ASAI) in Section 4.0 of its safety evaluation. The ASAIs are addressed in Section 3.4 below.
2.2 System Design and Operation The transmitters to be included in the Online Monitoring Program provide input to the Reactor Protection Systems (RPS), Engineered Safeguards Actuation System (ESAS),
and Engineered Safety Feature Actuation Systems (ESFAS) and are used for Post Accident Monitoring (PAM), the Remote Shutdown Systems, and Low Temperature Overpressure Protection (LTOP).
2.2.1 Reactor Protection Systems (RPS)
The RPS initiates a unit shutdown, based on the values of selected unit parameters, to protect against violating the core fuel design limits and RCS pressure boundary during anticipated operational occurrences and to assist the Engineered Safety Features Systems in mitigating accidents. The RPS and related instrumentation are identified in various TSs:
ANO-1 Table 3.3.1-1 ANO-2 Table 3.3-1 GGNS Table 3.3.1.1-1 RBS Table 3.3.1.1-1 WF3 Table 3.3-1 2.2.2 The BWR Anticipated Transient Without Scram (ATWS) System The Boiling Water Reactor (BWR) End of Cycle Recirculation Pump Trip (EOC-RPT) instrumentation initiates a recirculation pump trip (RPT) to reduce the peak reactor pressure and power resulting from turbine trip or generator load rejection transients to provide additional margin to core thermal safety limits. The BWR Anticipated Transient Without Scram (ATWS) RPT System initiates an RPT, adding negative reactivity, following events in which a scram does not (but should) occur, to lessen the effects of an ATWS event. The EOC-RPT and ATWS related instruments are identified in various TSs:
GGNS TS 3.3.4.1, and TS 3.3.4.2 RBS TS 3.3.4.1, and TS 3.3.4.2 2.2.3 Engineered Safeguards Actuation System (ESAS) and Engineered Safety Feature Actuation Systems (ESFAS)
The ESFAS and related systems initiate necessary safety systems, based on the values of selected unit parameters, to protect against violating core design limits and the RCS pressure boundary, and to mitigate accidents. The ESAS and ESFAS and related instrumentation are identified in various TSs:
CNRO2024-00002 Enclosure Page 6 of 30 ANO-1 Tables 3.3.5-1 and 3.3.11-1 ANO-2 Table 3.3-3 WF3 Table 3.3-3 2.2.4 Emergency Core Cooling System (ECCS) and Engineered Safety Feature (ESF)
The ESF and related systems initiate necessary safety systems, based on the values of selected unit parameters, to protect against violating core design limits and the RCS pressure boundary, and to mitigate accidents. The ECCS and ESF and related instrumentation are identified in various TSs:
GGNS Table 3.3.5.1-1, 3.3.5.2-1, 3.3.5.3-1, 3.3.6.1-1, 3.3.6.2-1, 3.3.6.3-1, 3.3.6.4-1, TS 3.3.6.5 TS 3.6.3.3, and TS 3.6.5.6 RBS Table 3.3.5.1-1, 3.3.5.2-1, 3.3.5.3-1, 3.3.6.1-1, 3.3.6.2-1, 3.3.6.3-1, TS 3.3.6.4, and Table 3.3.7.1-1 2.2.5 Post Accident Monitoring (PAM)
The primary purpose of the PAM instrumentation is to display unit variables that provide information required by the control room operators during accident situations. This information provides the necessary support for the operator to take the manual actions for which no automatic control is provided and that are required for safety systems to accomplish their safety functions for Design Basis Accidents. The PAM instrumentation is identified in various TSs:
ANO-1 Table 3.3.15-1 ANO-2 Table 3.3-10 GGNS Table 3.3.3.1-1 RBS Table 3.3.3.1-1 WF3 Table 3.3-10 2.2.6 Remote Shutdown Systems The Remote Shutdown System provides the operator with sufficient instrumentation and controls to place and maintain the unit in a safe shutdown condition from a location other than the control room. This capability is necessary to protect against the possibility that the control room becomes inaccessible. The Remote Shutdown System instrumentation is addressed in various TSs:
ANO-2 Bases 3/4.3.3.5 GGNS TS 3.3.3.2 (Also see Updated Final Safety Analysis Report Section 7.4.1.4 "Remote Shutdown System.")
RBS TS 3.3.3.2 (Also see Updated Safety Analysis Report Section 7.4.1.4 "Remote Shutdown System."))
WF3 Table 3.3-9
CNRO2024-00002 Enclosure Page 7 of 30 2.2.7 Low Temperature Overpressure Protection (LTOP)
The LTOP controls prevent RCS overpressure at low temperatures, so the integrity of the reactor coolant pressure boundary is not compromised by violating the pressure and temperature limits. LTOP provides the allowable combinations for pressure and temperature during cooldown, shutdown, and heatup to keep from violating the pressure and temperature limits. The LTOP instrumentation is identified in TS:
ANO-1 TS 3.4.11 2.3 System Evaluation The RPS, ESAS, ESFAS, PAM, Remote Shutdown System, and LTOP transmitters were evaluated in accordance with the methodology in AMS-TR-0720R2-A. The transmitters to be included in the OLM program and the bases for their selection can be found in the following AMS reports:
ANO2302R0, "OLM Amenable Transmitters Report for ANO Unit 1" (Reference 3)
ANO2307R0, "OLM Amenable Transmitters Report for ANO Unit 2" (Reference 4)
GGN2302R0, "OLM Amenable Transmitters Report for Grand Gulf" (Reference 5)
RBD2302R0, "OLM Amenable Transmitters Report for River Bend" (Reference 6)
WAT2302R0, "OLM Amenable Transmitters Report for Waterford" (Reference 7)
Switching from time-based surveillance frequency for channel calibrations to a condition-based calibration frequency will not create any physical changes to the plants.
The changes will not impact how the plants operate. Entergy will use condition-based frequency to determine when transmitter calibrations are needed instead of performing calibrations based on a calendar frequency. Existing calibration methods will be used when it is determined that transmitter calibration is needed.
2.4 Reason for the Proposed Change Entergy is proposing to use the NRC-approved OLM methodology described in AMS-TR-0720R2-A. The use of the NRC-approved OLM methodology ensures that plant safety is maintained by demonstrating that transmitters are functioning correctly.
The OLM methodology encompasses environmental and process conditions in the assessment of transmitter calibration.
The use of condition-based monitoring for transmitter calibration provides additional safety benefits, as described in AMS-TR-0720R2-A. The use of OLM will result in elimination of unnecessary transmitter calibration and associated opportunities for human errors. Elimination of unnecessary calibrations will also reduce calibration-induced damage to transmitters and other plant equipment. The use of OLM provides for timely detection of out-of-calibration transmitters. It eliminates occupational exposure or human error opportunities related to calibration activities that were unnecessary. Experience has shown that human errors during calibration of transmitters that did not require recalibration have resulted in additional repairs to correct the mistakes.
CNRO2024-00002 Enclosure Page 8 of 30 2.5 Description of the Proposed Change Proposed changes are presented below as blue underline for additions and red strikethrough for deletions.
2.5.1 ANO-1 Entergy proposes to change ANO-1 TS 1.0 USE AND APPLICATION, 1.1 Definitions:
CHANNEL CALIBRATION.
Proposed CHANNEL CALIBRATION A CHANNEL CALIBRATION shall be the adjustment, as necessary, of the channel output such that it responds within the necessary range and accuracy to known values of the parameter that the channel monitors. The CHANNEL CALIBRATION shall encompass all devices in the channel required for channel OPERABILITY and the CHANNEL FUNCTIONAL TEST (excluding transmitters in the Online Monitoring Program). Calibration of instrument channels with resistance temperature detector (RTD) or thermocouple sensors may consist of an inplace qualitative assessment of sensor behavior and normal calibration of the remaining adjustable devices in the channel.
The ANO-1 TSs do not have any Definitions for RESPONSE TIME TESTING therefore, no additional changes are required in section 1.1 Definitions.
2.5.2 ANO-2 Entergy proposes to change ANO-2 TS 1.0 DEFINITIONS:
1.9 CHANNEL CALIBRATION, 1.23 REACTOR TRIP SYSTEM RESPONSE TIME, and 1.24 ENGINEERED SAFETY FEATURE RESPONSE TIME.
Proposed TS 1.9 CHANNEL CALIBRATION 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 all devices in the channel required for channel OPERABILITY and the CHANNEL FUNCTIONAL TEST (excluding transmitters in the Online Monitoring Program). The CHANNEL CALIBRATION may be performed by means of any series of sequential, overlapping or total channel steps, and each step must be performed within the Frequency in the Surveillance Frequency Control Program for the devices included in the step.
CNRO2024-00002 Enclosure Page 9 of 30 Proposed TS 1.23 REACTOR TRIP SYSTEM RESPONSE TIME The REACTOR TRIP SYSTEM RESPONSE TIME shall be the time interval from when the monitored parameter exceeds its trip setpoint at the channel sensor until electrical power is interrupted to the CEA drive mechanism. 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 (including transmitters in the Online Monitoring Program), or the components have been evaluated in accordance with an NRC approved methodology.
Proposed TS 1.24 ENGINEERED SAFETY FEATURE RESPONSE TIME The ENGINEERED SAFETY FEATURE RESPONSE TIME shall be that time interval from when the monitored parameter exceeds its ESF actuation setpoint 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 (including transmitters in the Online Monitoring Program), or the components have been evaluated in accordance with an NRC approved methodology.
2.5.3 GGNS Entergy proposes to change GGNS TS 1.0 USE AND APPLICATION, 1.1 Definitions:
CHANNEL CALIBRATION, EMERGENCY CORE COOLING SYSTEM (ECCS) RESPONSE TIME, END OF CYCLE RECIRCULATION PUMP TRIP (EOC RPT) SYSTEM RESPONSE
- TIME, ISOLATION SYSTEM RESPONSE TIME, and REACTOR PROTECTION SYSTEM (RPS) RESPONSE TIME.
Proposed CHANNEL CALIBRATION A CHANNEL CALIBRATION shall be the adjustment, as necessary, of the channel output such that it responds within the necessary range and accuracy to known values of the parameter that the channel monitors. The CHANNEL CALIBRATION shall encompass all devices in the channel required for channel OPERABILITY and the CHANNEL FUNCTIONAL TEST (excluding transmitters in the Online Monitoring Program). Calibration of instrument channels with resistance temperature detector (RTD) or thermocouple sensors may consist of an inplace qualitative assessment of sensor behavior and normal calibration of the remaining adjustable devices in the channel. The CHANNEL CALIBRATION may be performed by means of any series
CNRO2024-00002 Enclosure Page 10 of 30 of sequential, overlapping, or total channel steps, and each step must be performed within the Frequency in the Surveillance Frequency Control Program for the devices included in the step.
Proposed EMERGENCY CORE COOLING SYSTEM (ECCS) RESPONSE TIME The ECCS RESPONSE TIME shall be that time interval from when the monitored parameter exceeds its ECCS initiation setpoint at the channel sensor until the ECCS 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 transmitters in the Online Monitoring Program provided that the methodology for verification has been previously reviewed and approved by the NRC.
Also, on this page, TS 1.0-3a, in the header, a minor editorial change is being made. "1.1 Definitions" is being adjusted to read, "1.1 Definitions (continued)".
Proposed END OF CYCLE RECIRCULATION PUMP TRIP (EOC-RPT) SYSTEM RESPONSE TIME The EOC-RPT SYSTEM RESPONSE TIME shall be that time interval from initial movement of the associated turbine stop valve or the turbine control valve to complete suppression of the electric arc between the fully open contacts of the recirculation pump circuit breaker. 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, except for the breaker arc suppression time, which is not measured but is validated to conform to the manufacturer's design value. In lieu of measurement, response time may be verified for transmitters in the Online Monitoring Program provided that the methodology for verification has been previously reviewed and approved by the NRC.
Proposed ISOLATION SYSTEM RESPONSE TIME The ISOLATION SYSTEM RESPONSE TIME shall be that time interval from when the monitored parameter exceeds its isolation initiation setpoint at the channel sensor until the isolation valves travel to their required positions. 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 transmitters in the Online Monitoring Program provided that the methodology for verification has been previously reviewed and approved by the NRC.
Proposed REACTOR PROTECTION SYSTEM (RPS) RESPONSE TIME REACTOR PROTECTION SYSTEM (RPS) RESPONSE TIME - The RPS RESPONSE TIME shall be that time interval from when the monitored parameter exceeds its RPS trip setpoint at the channel sensor until de-energization of the scram pilot valve solenoids. 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 transmitters in
CNRO2024-00002 Enclosure Page 11 of 30 the Online Monitoring Program provided that the methodology for verification has been previously reviewed and approved by the NRC.
Also, the following minor editorial changes are being made on TS page 1.0-5:
In the header, "1.1 Definitions" is being adjusted to read, "1.1 Definitions (continued)".
For the definition LOGIC SYSTEM FUNCTIONAL TEST which is continued from prior page. The word "(continued)" is located one line to low, "(continued)" is being adjusted to be just after "TEST" to make the definition title cleaner.
In the footer, old amendment number 156 had an errant underline. This underline is being removed.
2.5.4 RBS Entergy proposes to change RBS TS 1.0 USE AND APPLICATION, 1.1 Definitions:
CHANNEL CALIBRATION, EMERGENCY CORE COOLING SYSTEM (ECCS) RESPONSE TIME, END OF CYCLE RECIRCULATION PUMP TRIP (EOC-RPT) SYSTEM RESPONSE
- TIME, ISOLATION SYSTEM RESPONSE TIME, REACTOR PROTECTION SYSTEM (RPS) RESPONSE TIME, and TURBINE BYPASS SYSTEM RESPONSE TIME.
Proposed CHANNEL CALIBRATION A CHANNEL CALIBRATION shall be the adjustment, as necessary, of the channel output such that it responds within the necessary range and accuracy to known values of the parameter that the channel monitors. The CHANNEL CALIBRATION shall encompass all devices in the channel required for channel OPERABILITY and the CHANNEL FUNCTIONAL TEST (excluding transmitters in the Online Monitoring Program). Calibration of instrument channels with resistance temperature detector (RTD) or thermocouple sensors may consist of an inplace qualitative assessment of sensor behavior and normal calibration of the remaining adjustable devices in the channel. The CHANNEL CALIBRATION may be performed by means of any series of sequential, overlapping, or total channel steps, and each step must be performed within the Frequency in the Surveillance Frequency Control Program for the devices included in the step.
Proposed EMERGENCY CORE COOLING SYSTEM (ECCS) RESPONSE TIME The ECCS RESPONSE TIME shall be that time interval from when the monitored parameter exceeds its ECCS initiation setpoint at the channel sensor until the ECCS 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
CNRO2024-00002 Enclosure Page 12 of 30 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 transmitters in the Online Monitoring Program provided that the methodology for verification has been previously reviewed and approved by the NRC.
Proposed END OF CYCLE RECIRCULATION PUMP TRIP (EOC RPT) SYSTEM RESPONSE TIME The EOC-RPT SYSTEM RESPONSE TIME shall be that time interval from initial movement of the associated turbine stop valve or the turbine control valve to complete suppression of the electric arc between the fully open contacts of the recirculation pump circuit breaker. 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 transmitters in the Online Monitoring Program provided that the methodology for verification has been previously reviewed and approved by the NRC.
Proposed ISOLATION SYSTEM RESPONSE TIME The ISOLATION SYSTEM RESPONSE TIME shall be that time interval from when the monitored parameter exceeds its isolation initiation setpoint at the channel sensor until the isolation valves travel to their required positions. 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 transmitters in the Online Monitoring Program provided that the methodology for verification has been previously reviewed and approved by the NRC.
Proposed REACTOR PROTECTION SYSTEM (RPS) RESPONSE TIME The RPS RESPONSE TIME shall be that time interval from when the monitored parameter exceeds its RPS trip setpoint at the channel sensor until de-energization of the scram pilot valve solenoids. 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 transmitters in the Online Monitoring Program provided that the methodology for verification has been previously reviewed and approved by the NRC.
Proposed TURBINE BYPASS SYSTEM RESPONSE TIME The TURBINE BYPASS SYSTEM RESPONSE TIME consists of two components:
- a. The time from initial movement of the main turbine stop valve or control valve until 80% of the turbine bypass capacity is established; and
- b. The time from initial movement of the main turbine stop valve or control valve until initial movement of the turbine bypass valve.
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 transmitters in the Online Monitoring Program provided that the methodology for verification has been previously reviewed and approved by the NRC.
CNRO2024-00002 Enclosure Page 13 of 30 2.5.5 WF3 Entergy proposes to change WF3 TS 1.0 DEFINITIONS:
1.4 CHANNEL CALIBRATION, 1.12 ENGINEERED SAFETY FEATURE RESPONSE TIME, and 1.25 REACTOR TRIP SYSTEM RESPONSE TIME.
Proposed TS 1.4 CHANNEL CALIBRATION 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 all devices in the channel (excluding transmitters in the Online Monitoring Program) required for channel OPERABILITY and the CHANNEL FUNCTIONAL TEST. The CHANNEL CALIBRATION may be performed by means of any series of sequential, overlapping, or total channel steps, and each step must be performed within the Frequency in the Surveillance Frequency Control Program for the devices included in the step.
Proposed TS 1.12 ENGINEERED SAFETY FEATURES RESPONSE TIME The ENGINEERED SAFETY FEATURES RESPONSE TIME shall be that time interval from when the monitored parameter exceeds its ESF actuation setpoint 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 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 (including transmitters in the Online Monitoring Program), or the components have been evaluated in accordance with an NRC approved methodology.
The change to ENGINEERED SAFETY FEATURES RESPONSE TIME is on TS page 1-3. An additional minor editorial change in being made just below this definition. An errant '#' mark is being removed. This is noted on the markup page.
Proposed TS 1.25 REACTOR TRIP SYSTEM RESPONSE TIME The REACTOR TRIP SYSTEM RESPONSE TIME shall be the time interval from when the monitored parameter exceeds its trip setpoint at the channel sensor until electrical power to the CEA drive mechanism is interrupted. The response time may be measured by 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 (including transmitters in the Online Monitoring Program), or the components have been evaluated in accordance with an NRC approved methodology.
CNRO2024-00002 Enclosure Page 14 of 30 2.5.6 New Program for ANO-1, ANO-2, GGNS, RBS and WF3 TS Entergy proposes to add a new Online Monitoring Program TS, as shown below.
Proposed ANO-1 TS 5.5.19, ANO-2 TS 6.5.21, GGNS TS 5.5.15, RBS TS 5.5.17, and WF3 TS 6.5.20 Online Monitoring Program This program provides controls to determine the need for calibration of pressure, level, and flow transmitters using condition monitoring based on drift analysis. It also provides a means for in-situ dynamic response assessment using the noise analysis technique to detect failure modes that are not detectable by drift monitoring.
The Online Monitoring Program must be implemented in accordance with AMS-TR-0720R2-A, "Online Monitoring Technology to Extend Calibration Intervals of Nuclear Plant Pressure Transmitters" (proprietary version). The program shall include the following elements:
- a. Implementation of online monitoring for transmitters that have been evaluated in accordance with an NRC approved methodology during the plant operating cycle.
- 1) Analysis of online monitoring data to identify those transmitters that require a calibration check and those that do not require a calibration check,
- 2) Performance of online monitoring using noise analysis to assess in-situ dynamic response of transmitters that can affect response time performance,
- 3) Calibration checks of identified transmitters no later than during the next scheduled refueling outage, and
- 4) Documentation of the results of the online monitoring data analysis.
- b. Performance of a calibration check for any transmitter where the online monitoring was not implemented during the plant operating cycle no later than during the next scheduled refueling outage.
- c. Performance of calibration checks for transmitters at the specified backstop frequencies.
- d. The provisions of Surveillance Requirement 3.0.3 [for ITS plant, ANO1, GGN, RBS use 3.0.3, for custom TS plant, ANO2, WF3, use 4.0.3] are applicable to the required calibration checks specified in items a.3, b, and c above.
The proposed TS changes are an adaptation from the illustrative changes presented in AMS-TR-0720R2-A that simplify the required plant-specific changes. The proposed Definition changes eliminated the need to modify the Channel Calibration and Response Time Surveillance Requirements. The proposed Online Monitoring Program description was reorganized to better align with the OLM implementation activities.
Also, the following minor editorial changes are being made to insert the new program for each site:
ANO None.
ANO None.
CNRO2024-00002 Enclosure Page 15 of 30 GGNS - TS page 5.0-16c, at the bottom of the page, the double line (indicating the end of the section) is adjusted to a single line with "(continued)"
under it at the right margin. This is due to an additional page being added for the new program.
- TS page 5.0-16c, at the bottom of the page, the double line (indicating the end of the section) is adjusted to a single line with "(continued)"
under it at the right margin. This is due to an additional page being added for the new program.
- None.
3.0 TECHNICAL EVALUATION
3.1 OLM Implementation Process Development This section describes the steps that were performed to implement the OLM program for ANO-1, ANO-2, GGNS, RBS, and WF3 by following the steps identified in AMS-TR-0720R2-A Section 11.1.1. This work is documented in the AMS reports on OLM Amenable Transmitters (References 3 through 7) and OLM Analysis Methods and Limits (References 8 through 12).
The AMS reports on OLM Amenable Transmitters address steps 1-6, from AMS-TR-0720R2-A Section 11.1.1. These steps were designed to arrive at a list of transmitters that can be included in an OLM program and determine how to obtain OLM data. The transmitters to be included in the OLM program and the bases for their selection can be found in the AMS reports on OLM Amenable Transmitters.
3.1.1 Determine if Transmitters are Amenable to OLM AMS-TR-0720R2-A Chapter 12 includes Table 12.4 that lists the nuclear grade transmitter models that are amenable to OLM. Any transmitter model that is not listed in this table should only be added to the OLM program if it can be shown by similarity analysis that its failure modes are the same as the listed transmitter models or otherwise detectable by OLM.
3.1.2 List Transmitters in Each Redundant Group This step establishes how to group the transmitters and evaluates the redundancy of each group.
3.1.3 Determine if OLM Data Covers Applicable Setpoints This step evaluates the OLM data for each group to determine if it covers applicable setpoints. Additional details are described in AMS-TR-0720R2-A Chapter 14.
3.1.4 Calculate Backstops A backstop, as described in AMS-TR-0720R2-A Chapter 13, must be established for each group of redundant transmitters amenable to OLM as a defense against common mode drift. The backstop identifies the maximum period between calibrations without calibrating at least one transmitter in a redundant group.
CNRO2024-00002 Enclosure Page 16 of 30 3.1.5 Establish Method of Data Acquisition OLM data is normally available in the plant computer or an associated data historian. If data is not available from the plant computer or historian, a custom data acquisition system including hardware and software must be employed to acquire the data.
3.1.6 Specify Data Collection Duration and Sampling Rate OLM data must be collected during startup, normal operation, and shutdown periods at the highest sampling rate by which the plant computer takes data. AMS-TR-0720R2-A Chapter 15 describes a process to determine the minimum sampling rate for OLM data acquisition to monitor for transmitter drift. AMS-TR-0720R2-A Chapter 8 describes a process to help determine the optimal sampling rate and minimum duration of OLM data collection.
AMS reports on OLM Analysis Methods and Limits (References 8 through 12) address steps 7-8 from AMS-TR-0720R2-A Section 11.1.1. These steps address the calculation of the OLM limits and establish the methods of OLM data analysis.
3.1.7 Identify Data Analysis Methods OLM implementations must employ both simple averaging and parity space methods for data analysis as described in AMS-TR-0720R2-A Chapter 6.
3.1.8 Establish OLM Limits OLM limits must be established as described in AMS-TR-0720R2-A Chapter 7 for each group of redundant transmitters. Calculation of OLM limits must be based on combining uncertainties of components of each instrument channel from the transmitter in the field to the OLM data storage.
The AMS reports on OLM Analysis Methods and Limits (Reference 8 through 12) provide the OLM Limit calculations for the transmitters that are amenable to OLM at ANO-1, ANO-2, GGNS, RBS, and WF3.
3.2 OLM Program Implementation This section summarizes the steps that must be followed to implement the OLM program for transmitter drift monitoring at ANO-1, ANO-2, GGNS, RBS, and WF3 in accordance with AMS-TR-0720R2-A. The steps described in this section are repeated at each operating cycle at ANO-1, ANO-2, GGNS, RBS, and WF3 to identify the transmitters that should be scheduled for a calibration check using data from periods of startup, normal operation, and shutdown. Additional details regarding the OLM Program Implementation discussed in this section are contained in the AMS reports on the OLM Drift Monitoring Program (References 13 through 17).
AMS-TR-0720R2-A Section 11.1.2 identifies eleven steps that must be followed each operating cycle to identify the transmitters that should be scheduled for a calibration check at the ensuing outage. Table 1 provides a mapping between AMS-TR-0720R2-A Section 11.1.2 and the LAR section where the item is addressed. Implementation of these steps is performed using the AMS Bridge and the AMS Calibration Reduction System (CRS) software programs that were developed by AMS under their 10 CFR Part 50 Appendix B software Quality Assurance (QA) program.
CNRO2024-00002 Enclosure Page 17 of 30 Table 1: Mapping to AMS-TR-0720R2-A Section 11.1.2 Item Step Step Number in Section 11.1.2 of AMS-TR-0720R2-A LAR Section 1
Retrieve OLM Data 9
3.2.1 2
Perform Data Qualification 10 3.2.2 3
Select Appropriate Region of Any Transient Data 11 3.2.3 4
Perform Data Analysis 12 3.2.4 5
Plot the Average Deviation for Each Transmitter 13 3.2.5 6
Produce a Table for Each Group That Combines All Results 14 3.2.6 7
Determine OLM Results for Each Transmitter 15 3.2.7 8
Address Uncertainties in the Unexercised Portion of Transmitter Range 16 3.2.8 9
Select Transmitters to Be Checked for Calibration as a Backstop 17 3.2.9 10 Perform Dynamic Failure Mode Assessment 18 3.2.10 11 Produce a Report of Transmitters Scheduled for Calibration Check 19 3.2.11 3.2.1 Retrieve OLM Data The first step in performing transmitter drift monitoring is to retrieve the OLM data. OLM data must be retrieved during periods of startup, normal operation, and shutdown. The method of data acquisition, data collection duration, sampling rate, and list of sensors whose data will be retrieved have been established as described in Section 3.1 of this document. The OLM data for ANO-1, ANO-2, GGNS, RBS, and WF3 will be retrieved either using the AMS Bridge software which will retrieve data from the Entergy Maintenance and Diagnostic (M&D) center historian and produce binary data files that are compatible with the AMS Calibration Reduction System (CRS) software or as a text files from the Entergy historian or other data sources at each plant site, as applicable.
AMS procedure OLM2201, "Procedure for Online Monitoring Data Retrieval,"
(Reference 18) has been developed for performing the data retrieval using the AMS Bridge software.
3.2.2 Perform Data Qualification OLM data retrieved from plant historians sometimes contains anomalies such as spikes, missing data, stuck data, and saturated data. The portion of data containing these anomalies should be excluded, filtered, and/or cleaned prior to analysis. The AMS CRS software provides functionality for these tasks and will be used to perform data qualification. AMS procedure OLM2202, "Procedure for Performing Online Monitoring
CNRO2024-00002 Enclosure Page 18 of 30 Data Qualification and Analysis," (Reference 19) has been developed for performing data qualification and analysis using the AMS CRS software.
3.2.3 Select Appropriate Region of Any Transient Data The AMS CRS software provides means to select the regions of transient data as described in Step 11 of Section 11.1.2 of AMS-TR-0720R2-A and will be used to perform these selections. This activity is part of OLM data analysis and is addressed in the data qualification and analysis procedure.
3.2.4 Perform Data Analysis Several tasks that must be performed in OLM data analysis for startup, normal operation, and shutdown data including:
- 1. Calculate the process estimate,
- 2. Calculate the deviation of each transmitter from the process estimate and plot the
- outcome,
- 3. Partition the deviation data into region(s) by percent of span,
- 4. Calculate and plot the average deviation for each region versus percent of span,
- 5. Select appropriate process estimation techniques, filtering parameters, and remove any outliers,
- 6. Determine if average deviations exceed OLM limits for any region, and
- 7. Review, document, and store the details and results of analysis.
The AMS CRS software provides functionality for performing these tasks and will be used to perform OLM data analysis. Detailed steps for performing OLM data analysis are provided in the data qualification and analysis procedure (Reference 19).
3.2.5 Plot the Average Deviation for Each Transmitter The AMS CRS software provides functionality for plotting the average deviation for each transmitter as described in Step 13 of Section 11.1.2 of AMS-TR-0720R2-A and will be used to perform this task. This activity is part of OLM data analysis and is addressed in detail in the data qualification and analysis procedure (Reference 19).
3.2.6 Produce a Table for Each Group That Combines All Results The AMS CRS software provides functionality for producing a table for each group of redundant transmitters that combines all results as described in Step 14 of Section 11.1.2 of AMS-TR-0720R2-A and will be used to perform this task. This activity is part of OLM data analysis and is addressed in detail in the data qualification and analysis procedure (Reference 19).
3.2.7 Determine OLM Results for Each Transmitter OLM results must be produced by the OLM analyst upon completion of data analysis for a complete operating cycle. The AMS CRS software provides functionality for producing these results as described in Step 15 of Section 11.1.2 of AMS-TR-0720R2-A and will be used to perform this task. This activity is part of OLM data analysis and is addressed in detail in the data qualification and analysis procedure (Reference 19).
CNRO2024-00002 Enclosure Page 19 of 30 3.2.8 Address Uncertainties in the Unexercised Portion of Transmitter Range The AMS CRS software provides functionality for addressing uncertainties in the unexercised portion of the transmitter ranged as described in Step 16 of Section 11.1.2 of AMS-TR-0720R2-A and will be used to perform this task. This activity is part of OLM data analysis and is addressed in detail in the data qualification and analysis procedure (Reference 19).
3.2.9 Select Transmitters to Be Checked for Calibration as a Backstop The AMS procedure OLM2202 (Reference 19) is also used for maintaining the backstops for OLM. It provides detailed steps for selecting transmitters to be checked for calibration as a backstop as described in Step 17 of Section 11.1.2 of AMS-TR-0720R2-A.
3.2.10 Perform Dynamic Failure Mode Assessment As described in Step 18 of Section 11.1.2 of AMS-TR-0720R2-A, dynamic failure mode assessment must be performed using the noise analysis technique to cover dynamic failures that are not detectable by the OLM process for transmitter drift monitoring.
Details on how this will be addressed for ANO-1, ANO-2, GGNS, RBS, and WF3 are described in LAR Section 3.3.
3.2.11 Produce a Report of Transmitters Scheduled for Calibration Check The results of OLM analysis must be compiled in a report and independently reviewed.
The transmitters that have been flagged must be scheduled for a calibration check at the next opportunity. The AMS CRS software provides functionality for producing this report and will be used to perform this task. This activity is part of OLM data analysis and is addressed in detail in the data qualification and analysis procedure.
3.3 OLM Noise Analysis Implementation Some licensees have extended or eliminated transmitter response time testing requirements with NRC approval based, in part, on the performance of manual calibrations. Manual calibrations will not be performed except on transmitters that are flagged by OLM. The noise analysis methodology is provided in this document to enable licensees to assess the dynamic failure modes of transmitters that are not covered by the OLM process for transmitter drift monitoring.
This section summarizes the steps that must be followed to implement the noise analysis technique for transmitter dynamic failure mode assessment at ANO-1, ANO-2, GGNS, RBS, and WF3 in accordance with AMS-TR-0720R2-A. Additional details regarding the implementation of the noise analysis technique discussed in this section are provided in the AMS reports on Noise Analysis Techniques (References 20 through 24).
As described in Section 11.3.3 of AMS-TR-0720R2-A, six steps must be followed to assess dynamic failure modes of pressure transmitters. Table 2 provides a mapping of the six steps in Section 11.3.3 of AMS-TR-0720R2-A and the section where they are addressed in this document. Implementation of these steps is performed using qualified noise data acquisition equipment and software programs that were developed by AMS under their 10 CFR Part 50 Appendix B software Quality Assurance (QA) program.
CNRO2024-00002 Enclosure Page 20 of 30 For ANO-1, ANO-2, GGNS, RBS, and WF3, the transmitters with response time requirements have been identified in AMS reports on OLM Amenable Transmitters (References 3 through 7).
Table 2: Mapping to AMS-TR-0720R2-A Section 11.3.3 Item Step Step Number in Section 11.3.3 of AMS-TR-0720R2-A LAR Section 1
Select Qualified Noise Data Acquisition Equipment 1
3.3.1 2
Connect Noise Data Acquisition Equipment to Plant Signals 2
3.3.2 3
Collect and Store Data for Subsequent Analysis 3
3.3.3 4
Screen Data for Artifacts and Anomalies 4
3.3.4 5
Perform Data Analysis 5
3.3.5 6
Review and Document Results 6
3.3.6 3.3.1 Select Qualified Noise Data Acquisition Equipment The first step in performing noise analysis is to select qualified noise data acquisition equipment. This equipment must have a valid calibration traceable to the National Institute of Standards and Technology and meet a set of performance criteria detailed Step 1 of Section 11.3.3 of AMS-TR-0720R2-A. The equipment used to acquire data at ANO-1, ANO-2, GGNS, RBS, and WF3 will be the AMS OLM data acquisition system which is comprised of hardware and software that has been developed and tested using AMS 10 CFR Part 50 Appendix B hardware and software QA program.
3.3.2 Connect Noise Data Acquisition Equipment to Plant Signals AMS Procedure NPS1501, "Procedure for Noise Data Collection from Plant Sensors,"
(Reference 25) is used for the connection of the noise data acquisition equipment for performing noise analysis testing. This procedure identifies the locations for connection to process signals as well as the qualified personnel who may connect the data acquisition system at these locations. The noise data acquisition system should be connected to as many transmitters as allowed by the number of data acquisition channels and the plant procedures. Multiple transmitters (e.g., up to 32) can be tested simultaneously to reduce the test time. Each data acquisition channel must be connected to the transmitter current loop as shown in Section 11.3.3 of AMS-TR-0720R2-A.
3.3.3 Collect and Store Data for Subsequent Analysis The noise data should be collected during normal plant operation at full temperature, pressure, and flow and analyzed in real time or stored to be analyzed later. However, noise data taken at other conditions is acceptable as long as there is enough process fluctuation with sufficient amplitude and frequency content to drive the transmitters to reveal their dynamic characteristics. Noise data collection will be performed using AMS
CNRO2024-00002 Enclosure Page 21 of 30 OLM Data Acquisition software which has been developed and tested using AMS software verification and validation (V&V) program which conforms to 10 CFR Part 50 Appendix B. The use of this software for noise data acquisition is addressed in the AMS procedure for performing noise analysis testing (Reference 25).
3.3.4 Screen Data for Artifacts and Anomalies Noise data may contain anomalies that must be excluded, filtered, and/or cleaned prior to data analysis. AMS Procedure NAR2201, "Procedure for Performing Dynamic Failure Mode Assessment Using Noise Analysis," is used for performing noise analysis data analysis (Reference 26) and will be performed using AMS noise analysis software.
3.3.5 Perform Data Analysis Noise data analysis will be performed as described in Section 11.3.3 Step 5 in AMS-TR-0720R2-A using AMS noise analysis software. General data analysis steps for the analyst as well as detailed steps for performing noise data analysis are also provided in the AMS procedure for performing noise analysis data analysis (Reference 26).
3.3.6 Review and Document Results Results of noise data analysis will be reviewed and approved by qualified personnel and documented in a report. This process is detailed in the AMS procedure for performing noise analysis data analysis (Reference 26).
3.4 Application Specific Action Items from AMS OLM TR The NRC approval of the AMS OLM TR required implementation of the ASAIs in Section 4.0 of its safety evaluation. Five ASAIs were identified, and each is addressed below.
3.4.1 ASAI 1 - Evaluation and Proposed Mark-up of Existing Plant Technical Specifications When preparing a license amendment request to adopt OLM methods for establishing calibration frequency, licensees should consider markups that provide clear requirements for accomplishing plant operations, engineering data analysis, and instrument channel maintenance. Such TS changes would need to include appropriate markups of the TS tables describing limiting conditions for operation and surveillance requirements, the technical basis for the changes, and the administrative programs section.
Response to ASAI 1: The proposed changes to the ANO-1, ANO-2, GGNS, RBS, and WF3 Technical Specifications are identified in Section 2.4 and shown in Attachments 1 through 5. The proposed changes modify applicable Definitions and add a new program for OLM in the Administrative Controls. No changes to the Technical Specification tables describing Limiting Conditions for Operation or Surveillance Requirements were necessary.
CNRO2024-00002 Enclosure Page 22 of 30 3.4.2 ASAI 2 - Identification of Calibration Error Source When determining whether an instrument can be included in the plant OLM program, the licensee shall evaluate calibration error source in order to account for the uncertainty due to multiple instruments used to support the transfer of transmitter signal data to the data collection system. Calibration errors identified through OLM should be attributed to the transmitter until testing can be performed on other support devices to correctly determine the source of calibration error and reallocate errors to these other loop components.
Response to ASAI 2: Calibration error is evaluated as part of the calculation of OLM limits as described in Section 3.1.8. The calculation of OLM limits is based on combining uncertainties of components of each instrument channel from the transmitter in the field to the OLM data storage. The OLM data assessment methods described in Section 3.2.7 include guidance to consider calibration errors identified through OLM as coming from the transmitter until testing can be performed on other support devices to correctly determine the source of calibration error and reallocate errors to these other loop components.
3.4.3 ASAI 3 - Response Time (RT) Test Elimination Basis If the plant has eliminated requirements for performing periodic RT testing of transmitters to be included in the OLM program, then the licensee shall perform an assessment of the basis for RT test elimination to determine if this basis will remain valid upon implementation of the OLM program and to determine if the RT test elimination will need to be changed to credit the OLM program rather than the periodic calibration test program.
Response to ASAI 3: ANO-2, GGNS, RBS, and WF3 previously eliminated requirements for performing periodic response time testing based on the periodic calibration of transmitters that are proposed to be included in the OLM program. ANO-2, GGNS, RBS, and WF3 propose to change the basis for response time test elimination to the methodology described in Section 3.3, which is based on the noise analysis methodology described in Section 11.3 of the AMS OLM TR. For ANO-1, prior to conversion to Improved TS (ITS)
(NUREG-1432) (Reference 29 and 30), ANO-1 did not have a requirement for Response Time Test. This can be seen in the application for conversion to NUREG-1432 in this justification: NUREG TS 3.3.1 - Response time testing of the Reactor Protection System (RPS), i.e., NUREG SR 3.3.1.7, is not adopted in ITS. Testing of this type is not required by ANO-1 Current TS. Deletion of these Surveillance Requirements maintains consistency with the current ANO-1 administrative control of these activities and neither removes any current requirement nor adds any additional requirement. This change is consistent with current license basis.
CNRO2024-00002 Enclosure Page 23 of 30 3.4.4 ASAI 4 - Use of Calibration Surveillance Interval Backstop In its application for a license or license amendment to incorporate OLM methods for establishing calibration surveillance intervals, applicants or licensees should describe how they intend to apply backstop intervals as a means for mitigating the potential that a process group could be experiencing undetected common mode drift characteristics.
Response to ASAI 4: The Entergy OLM programs for ANO-1, ANO-2, GGNS, RBS, and WF3 adopt the calibration surveillance interval backstop methods described in Section 3.2.9, which is based on the backstop methodology described in Section 13 of the AMS OLM TR.
The Updated Final Safety Analysis Reports (UFSAR) for ANO-1, ANO-2, GGNS, RBS, and WF3 will be modified to add the use of AMS-TR-0720R2-A to the appropriate parts of Chapter 1. The use of OLM to switch from time-based calibration frequency of pressure, level, and flow transmitters to a condition-based calibration frequency based on OLM results will be added to the appropriate parts of UFSAR Chapter 7, including a list of transmitters included in the OLM program. The appropriate parts of UFSAR Chapter 7 will also be changed to describe the use of OLM assess dynamic failure modes of pressure-type sensing systems using the noise analysis technique to support the continued elimination of transmitter response time testing.
3.4.5 ASAI 5 - Use of Criteria other than in AMS OLM TR for Establishing Transmitter Drift Flagging Limit In its application for a license or license amendment to incorporate OLM methods for establishing calibration surveillance intervals, applicants or licensees should describe whether they intend to adopt the criteria within the AMS OLM TR for flagging transmitter drift or whether they plan to use a different methodology for determining this limit.
Response to ASAI 5: The Entergy OLM program for ANO-1, ANO-2, GGNS, RBS, and WF3 adopt the two averaging techniques (i.e., simple average and parity space) described in Section 6 of the AMS OLM TR for flagging transmitter drift.
4.0 REGULATORY EVALUATION
4.1 Applicable Regulatory Requirements/Criteria 4.1.1 10 CFR 50.36 Technical Specifications Part (3) of this regulation sets the governing requirements for the inclusion of Surveillance Requirements in the Technical Specifications included in the Operating License for a commercial nuclear power plant.
(3) Surveillance requirements. 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.
CNRO2024-00002 Enclosure Page 24 of 30 Entergy proposes to use the AMS OLM methodology for ANO-1, ANO-2, GGNS, RBS, and WF3 as the technical basis to support plant-specific Technical Specification changes to switch from time-based surveillance frequency for channel calibrations to a condition-based calibration frequency based on OLM results.
4.1.2 10 CFR Part 50 Appendix A General Design Criterion 21, "Protection System Reliability and Testability," requires, in part, that plant protection systems be designed to permit periodic testing during reactor operation, including a capability to test channels independently to determine failures and losses of redundancy that may have occurred.
Criterion 21, Protection System Reliability and Testability. The protection system shall be designed for high functional reliability and in-service testability commensurate with the safety functions to be performed.
Redundancy and independence designed into the protection system shall be sufficient to assure that (1) no single failure results in loss of the protection function and (2) removal from service of any component or channel does not result in loss of the required minimum redundancy unless the acceptable reliability of operation of the protection system can be otherwise demonstrated. The protection system shall be designed to permit periodic testing of its functioning when the reactor is in operation, including a capability to test channels independently to determine failures and losses of redundancy that may have occurred."
Entergy proposes to use the AMS OLM methodology for ANO-1, ANO-2, GGNS, RBS, and WF3 as the technical basis to support plant-specific Technical Specification changes to switch from time-based surveillance frequency for channel calibrations to a condition-based calibration frequency based on OLM results. The OLM methodology is also proposed to be used to assess dynamic failure modes of pressure sensing systems.
4.1.3 Regulatory Guide 1.118, Revision 3 Regulatory Guide 1.118, Revision 3, "Periodic Testing of Electric Power and Protection Systems," endorses "with qualification" the IEEE Standard 338-1987, "IEEE Standard Criteria for the Periodic Surveillance Testing of Nuclear Power Generating Station Safety Systems".
AMS proposes to use the AMS OLM methodology as the technical basis to support plant-specific Technical Specification changes to switch from time-based surveillance frequency for channel calibrations to a condition-based calibration frequency based on OLM results.
4.1.4 IEEE Standard 338-1977 This standard contains the following requirements related to calibration:
6.3.3 Channel Calibration Verification Tests. A channel calibration verification test should prove that with a known precise input, the channel gives the required output, analog, or bistable. Additionally, in analog channels, linearity and hysteresis may be checked. If the required output is achieved, the test is acceptable. If the required output is not achieved (for example, the bistable trip did not occur at the required set point or the analog output was out of tolerance) or saturation or foldover is observed and
CNRO2024-00002 Enclosure Page 25 of 30 adjustment or alignment of gain, bias, trip set, etc., is required, the test is unacceptable. Adjustment or alignment procedures are maintenance activities and are outside the scope of this standard. Test results, however, shall be recorded in accordance with ANSI/ANS 3.2-1982, or the equivalent.
Following maintenance or other appropriate disposition of the unacceptable results, a successful rerun of the channel calibration verification test shall be performed.
6.5.2 Changes to Test Interval. The effect of testing intervals on performance of equipment shall be reevaluated periodically to determine if the interval used is an effective factor in maintaining equipment in an operational status.
The following shall be considered:
History of equipment performance, particularly experienced failure rates and potential significant increases in failure rates.
Corrective action associated with failures.
Performance of equipment in similar plants or environment, or both.
Plant design changes associated with equipment.
Detection of significant changes of failure rates.
Test intervals may be changed to agree with plant operational modes provided it can be shown that such changes do not adversely affect desired performance of the equipment being tested. Tests need not be performed on systems or equipment when they are not required to be operable or are tripped. If tests are not conducted on such systems, they shall be performed prior to returning the system to operation.
Entergy proposes to use the AMS OLM methodology for ANO-1, ANO-2, GGNS, RBS, and WF3 as the technical basis to support plant-specific Technical Specification changes to switch to time-based surveillance frequency for channel calibrations to a condition-based calibration frequency based on the OLM results for a given transmitter.
4.1.5 IEEE Standard 338-2012 This standard contains the following requirements related to calibration:
5.3.3.2 On-line monitoring. On-line monitoring (OLM) techniques enable the determination of portions of an instrument channels status during plant operation. This methodology is an acceptable input for establishing calibration frequency of those monitored portions of instrument channels without adversely affecting reliability.
Continuous monitoring shall be employed, e.g., through the plant computer.
Periodic manual testing is either a maintenance or surveillance task and is not on-line monitoring.
On-line monitoring shall ensure that setpoint calculation assumptions and the safety analysis assumptions remain valid.
Entergy proposes to use the AMS OLM methodology for ANO-1, ANO-2, GGNS, RBS, and WF3 as the technical basis to support plant-specific Technical Specification changes to switch to time-based surveillance frequency for channel calibrations to a condition-based calibration frequency based on the OLM results for a given transmitter.
CNRO2024-00002 Enclosure Page 26 of 30 4.2 Precedent The Entergy license amendment request is based the NRC-approved Analysis and Measurement Services Corporation Topical Report AMS-TR-0720R2, "Online Monitoring Technology to Extend Calibration Intervals of Nuclear Plant Pressure Transmitters" (References 1 and 2). One precedent was identified. NRC approved a license amendment request submitted by Southern Nuclear Operating Company for Vogtle Electric Generating Plant Units 1 and 2 to extend calibration intervals of nuclear plant pressure transmitters using AMS-TR-0720R2 (References 27 and 28) 4.3 No Significant Hazards Consideration Determination Analysis Entergy has evaluated the proposed changes to the Arkansas Nuclear One (ANO),
Units 1 and 2 (ANO-1 and ANO-2), Grand Gulf Nuclear Station, Unit 1 (GGNS), River Bend Station, Unit 1 (RBS), and Waterford Steam Electric Station, Unit 3 (WF3)
Technical Specifications (TS) using the criteria in 10 CFR 50.92 and has determined that the proposed changes do not involve a significant hazards consideration.
The proposed changes revise the following TSs:
ANO-1 TS 1.0 USE AND APPLICATION, 1.1 Definitions:
CHANNEL CALIBRATION ANO-2 TS 1.0 DEFINITIONS:
1.9 CHANNEL CALIBRATION, 1.23 REACTOR TRIP SYSTEM RESPONSE TIME, and 1.24 ENGINEERED SAFETY FEATURE RESPONSE TIME GGNS TS 1.0 USE AND APPLICATION, 1.1 Definitions:
CHANNEL CALIBRATION, EMERGENCY CORE COOLING SYSTEM (ECCS) RESPONSE
- TIME, END OF CYCLE RECIRCULATION PUMP TRIP (EOC-RPT)
SYSTEM RESPONSE TIME, ISOLATION SYSTEM RESPONSE TIME, and REACTOR PROTECTION SYSTEM (RPS) RESPONSE TIME RBS TS 1.0 USE AND APPLICATION, 1.1 Definitions:
CHANNEL CALIBRATION, EMERGENCY CORE COOLING SYSTEM (ECCS) RESPONSE
- TIME, END OF CYCLE RECIRCULATION PUMP TRIP (EOC-RPT)
SYSTEM RESPONSE TIME, ISOLATION SYSTEM RESPONSE TIME, REACTOR PROTECTION SYSTEM (RPS) RESPONSE TIME, and TURBINE BYPASS SYSTEM RESPONSE TIME
CNRO2024-00002 Enclosure Page 27 of 30 WF3 TS 1.0 DEFINITIONS:
1.4 CHANNEL CALIBRATION, 1.12 ENGINEERED SAFETY FEATURE RESPONSE TIME, and 1.25 REACTOR TRIP SYSTEM RESPONSE TIME The proposed changes add new Online Monitoring Program TSs, as shown below:
ANO-1 TS 5.5.19 "Online Monitoring Program" ANO-2 TS 6.5.21 "Online Monitoring Program" GGNS TS 5.5.15 "Online Monitoring Program" RBS TS 5.5.17 "Online Monitoring Program" WF3 TS 6.5.20 "Online Monitoring Program" Entergy proposes to use online monitoring (OLM) methodology as the technical basis to switch from time-based surveillance frequency for channel calibrations to a condition-based calibration frequency based on OLM results. Switching from time-based surveillance frequency for channel calibrations to a condition-based calibration frequency will not create any physical changes to the plant. The use of the NRC-approved OLM methodology ensures that plant safety is maintained by demonstrating that transmitters are functioning correctly.
As required by 10 CFR 50.91(a), the Entergy analysis of the issue of no significant hazards consideration is presented below:
- 1. Does the proposed change involve a significant increase in the probability or consequences of an accident previously evaluated?
Response: No The proposed change uses online monitoring (OLM) methodology as the technical basis to switch from time-based surveillance frequency for channel calibrations to a condition-based calibration frequency based on OLM results. Switching from time-based surveillance frequency for channel calibrations to a condition-based calibration frequency will not create any physical changes to the plant. The use of the NRC-approved OLM methodology ensures that plant safety is maintained by demonstrating that transmitters are functioning correctly.
The proposed changes do not adversely affect accident initiators or precursors, and do not alter the design assumptions, conditions, or configuration of the plant or the way the plant is operated or maintained.
Therefore, the proposed changes do not involve a significant increase in the probability or consequences of an accident previously evaluated.
CNRO2024-00002 Enclosure Page 28 of 30
- 2. Does the proposed change create the possibility of a new or different kind of accident from any accident previously evaluated?
Response: No The change does not involve a physical alteration of the plant (i.e., no new or different type of equipment will be installed) or a change in the methods governing normal plant operation. Existing calibration methods will be used when the need for transmitter calibration is determined. The change does not alter assumptions made in the safety analysis but ensures that the transmitters operate as assumed in the accident analysis. The proposed change is consistent with the safety analysis assumptions.
Therefore, the proposed change does not create the possibility of a new or different kind of accident from any accident previously evaluated.
- 3. Does the proposed change involve a significant reduction in a margin of safety?
Response: No The change does not involve a physical alteration of the plant (i.e., no new or different type of equipment will be installed) or a change in the methods governing normal plant operation. The change does not alter assumptions made in the safety analysis but ensures that the transmitters operate as assumed in the accident analysis. The proposed change is consistent with the safety analysis assumptions.
Therefore, the proposed change does not involve a significant reduction in a margin of safety.
4.4 Conclusions In conclusion, based on the considerations discussed above, Entergy concludes:
(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 the health and safety of the public.
5.0 ENVIRONMENTAL CONSIDERATION
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 Part 20, and 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 effluent 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. Accordingly, the amendment meets the eligibility criteria for categorical exclusion set forth in 10 CFR 51.22(c)(9). Pursuant to 10 CFR 51.22(b), no environmental impact statement or environmental assessment need be prepared in connection with the issuance of the amendment.
CNRO2024-00002 Enclosure Page 29 of 30
6.0 REFERENCES
- 1.
AMS letter to NRC, "Submittal of -A Version of Analysis and Measurement Services Corporation Topical Report AMS-TR-0720R2, Online Monitoring Technology to Extend Calibration Intervals of Nuclear Plant Pressure Transmitters (Docket No. 99902075)," (ML21235A493), dated August 20, 2021
- 2.
NRC Form 896, AMS Topical Report -A Verification, (ML21237A490), dated September 22, 2021
- 3.
AMS Report ANO2302R0, "OLM Amenable Transmitters Report for ANO Unit 1"
- 4.
AMS Report ANO2307R0, "OLM Amenable Transmitters Report for ANO Unit 2"
- 5.
AMS Report GGN2302R0, "OLM Amenable Transmitters Report for Grand Gulf"
- 6.
AMS Report RBD2302R0, "OLM Amenable Transmitters Report for River Bend"
- 7.
AMS Report WAT2302R0, "OLM Amenable Transmitters Report for Waterford"
- 8.
AMS Report ANO2303R0, "OLM Analysis Methods and Limits Report for ANO Unit 1"
- 9.
AMS Report ANO2308R0, "OLM Analysis Methods and Limits for Report ANO Unit 2"
- 18. AMS Procedure OLM2201, "Procedure for Online Monitoring Data Retrieval"
- 19. AMS Procedure OLM2202, "Procedure for Performing Online Monitoring Data Qualification and Analysis"
- 25. AMS Procedure NPS1501, "Procedure for Noise Data Collection from Plant Sensors"
CNRO2024-00002 Enclosure Page 30 of 30
- 26. AMS Procedure NAR2201, "Procedure for Performing Dynamic Failure Mode Assessment Using Noise Analysis"
- 27. Southern Nuclear Operating Company letter NL-22-0764 to NRC, "Vogtle Electric Generating Plant - Units 1&2, License Amendment Request to Revise Technical Specification 1.1 and Add 5.5.23 to Use Online Monitoring Methodology,"
(ML22355A588), dated December 21, 2022
- 28. NRC letter to Southern Nuclear Operating Company, "Vogtle Electric Generating Plant, Units 1 And 2 - Issuance of Amendments Regarding Revision to Technical Specifications to Use Online Monitoring Methodology," (ML23115A149), dated June 15, 2023
- 29. Entergy letter to NRC, "Arkansas Nuclear One -Unit 1 Conversion to Improved Standard Technical Specifications," (ML003681623), dated January 28, 2000
- 30. NRC letter to Entergy, "Arkansas Nuclear One, Unit No. 1 - Issuance of Amendment RE: The Conversion to Improved Standard Technical Specifications,"
(ML013050554), dated October 29, 2001 7.0 ATTACHMENTS
- 1.
Technical Specification Mark-ups
- ANO-1
- 2.
Technical Specification Mark-ups
- ANO-2
- 3.
Technical Specification Mark-ups
- GGNS
- 4.
Technical Specification Mark-ups
- RBS
- 5.
Technical Specification Mark-ups
- WF3
- 6.
Technical Specification Clean Typed
- ANO-1
- 7.
Technical Specification Clean Typed
- ANO-2
- 8.
Technical Specification Clean Typed
- GGNS
- 9.
Technical Specification Clean Typed
- RBS
- 10. Technical Specification Clean Typed
- WF3
- 11. Technical Specification Bases Mark-ups - ANO-1 (Information only)
- 12. Technical Specification Bases Mark-ups - ANO-2 (Information only)
- 13. Technical Specification Bases Mark-ups - GGNS (Information only)
- 14. Technical Specification Bases Mark-ups - RBS (Information only)
- 15. Technical Specification Bases Mark-ups - WF3 (Information only)
Enclosure, Attachment 1 CNRO2024-00002 Technical Specification Mark-ups - ANO-1 (3 TS Pages Follow)
Definitions 1.1 ANO-1 1.1-1 Amendment No. 215, 1.0 USE AND APPLICATION 1.1 Definitions
NOTE------------------------------------------------------------
The defined terms of this section appear in capitalized type and are applicable throughout these Technical Specifications and Bases.
Term Definition ACTIONS ACTIONS shall be that part of a Specification that prescribes Required Actions to be taken under designated Conditions within specified Completion Times.
ALLOWABLE THERMAL POWER ALLOWABLE THERMAL POWER shall be the maximum steady state reactor core heat transfer rate to the reactor coolant permitted by consideration of the number and configuration of reactor coolant pumps (RCPs) in operation.
AXIAL POWER IMBALANCE AXIAL POWER IMBALANCE shall be the power in the top half of the core, expressed as a percentage of RATED THERMAL POWER (RTP), minus the power in the bottom half of the core, expressed as a percentage of RTP.
AXIAL POWER SHAPING APSRs shall be the control components with part length RODS (APSRs) absorbers used to control the axial power distribution of the reactor core. The APSRs are positioned manually by the operator and are not trippable.
CHANNEL CALIBRATION A CHANNEL CALIBRATION shall be the adjustment, as necessary, of the channel output such that it responds within the necessary range and accuracy to known values of the parameter that the channel monitors. The CHANNEL CALIBRATION shall encompass all devices in the channel required for channel OPERABILITY and the CHANNEL FUNCTIONAL TEST (excluding transmitters in the Online Monitoring Program).
Calibration of instrument channels with resistance temperature detector (RTD) or thermocouple sensors may consist of an inplace qualitative assessment of sensor behavior and normal calibration of the remaining adjustable devices in the channel.
Programs and Manuals 5.5 ANO-1 5.0-20a Amendment No. 281, 5.0 ADMINISTRATIVE CONTROLS 5.5 Programs and Manuals
- c.
When a RICT is being used, any change to the plant configuration, as defined in NEI 06-09-A, Appendix A, must be considered for the effect on the RICT.
- 1.
For planned changes, the revised RICT must be determined prior to implementation of the change in configuration.
- 2.
For emergent conditions, the revised RICT must be determined within the time limits of the Required Action Completion Time (i.e., not the RICT) or 12 hours1.388889e-4 days <br />0.00333 hours <br />1.984127e-5 weeks <br />4.566e-6 months <br /> after the plant configuration change, whichever is less.
- 3.
Revising the RICT is not required If the plant configuration change would lower plant risk and would result in a longer RICT.
- d.
For emergent conditions, if the extent of condition evaluation for inoperable structures, systems, or components (SSCs) is not complete prior to exceeding the Completion Time, the RICT shall account for the increased possibility of common cause failure (CCF) by either:
- 1.
Numerically accounting for the increased possibility of CCF in the RICT calculation; or
- 2.
Risk Management Actions (RMAs) not already credited in the RICT calculation shall be implemented that support redundant or diverse SSCs that perform the function(s) of the inoperable SSCs, and, if practicable, reduce the frequency of initiating events that challenge the function(s) performed by the inoperable SSCs.
- e.
The risk assessment approaches and methods shall be acceptable to the NRC. The plant PRA shall be based on the as-built, as-operated, and maintained plant; and reflect the operating experience at the plant, as specified in Regulatory Guide 1.200, Revision 2. Methods to assess the risk from extending the Completion Times must be PRA methods approved for use with this program, or other methods approved by the NRC for generic use; and any change in the PRA methods to assess risk that are outside these approval boundaries require prior NRC approval.
Programs and Manuals 5.5 ANO-1 5.0-20b Amendment No.
5.0 ADMINISTRATIVE CONTROLS 5.5 Programs and Manuals 5.5.19 Online Monitoring Program This program provides controls to determine the need for calibration of pressure, level, and flow transmitters using condition monitoring based on drift analysis. It also provides a means for in-situ dynamic response assessment using the noise analysis technique to detect failure modes that are not detectable by drift monitoring.
The Online Monitoring Program must be implemented in accordance with AMS-TR-0720R2-A, "Online Monitoring Technology to Extend Calibration Intervals of Nuclear Plant Pressure Transmitters" (proprietary version). The program shall include the following elements:
- a. Implementation of online monitoring for transmitters that have been evaluated in accordance with an NRC approved methodology during the plant operating cycle.
- 1) Analysis of online monitoring data to identify those transmitters that require a calibration check and those that do not require a calibration
- check,
- 2) Performance of online monitoring using noise analysis to assess in-situ dynamic response of transmitters that can affect response time performance,
- 3) Calibration checks of identified transmitters no later than during the next scheduled refueling outage, and
- 4) Documentation of the results of the online monitoring data analysis.
- b. Performance of a calibration check for any transmitter where the online monitoring was not implemented during the plant operating cycle no later than during the next scheduled refueling outage.
- c. Performance of calibration checks for transmitters at the specified backstop frequencies.
- d. The provisions of Surveillance Requirement 3.0.3 are applicable to the required calibration checks specified in items a.3, b, and c above.
Enclosure, Attachment 2 CNRO2024-00002 Technical Specification Mark-ups - ANO-2 (3 TS Pages Follow)
ARKANSAS - UNIT 2 1-2 Amendment No. 154,157,319,334, DEFINITIONS CONTAINMENT INTEGRITY 1.8 CONTAINMENT INTEGRITY shall exist when:
1.8.1 All penetrations required to be closed during accident conditions are either:
- a.
Capable of being closed by an OPERABLE containment automatic isolation valve system, or
- b.
Closed by manual valves, blind flanges, or deactivated automatic valves secured in their closed positions, except for valves that are open under administrative control as permitted by Specification 3.6.3.1.
1.8.2 All equipment hatches are closed and sealed, 1.8.3 Each airlock is OPERABLE pursuant to Specification 3.6.1.3, 1.8.4 The containment leakage rates are within the limits of Specification 3.6.1.2, and 1.8.5 The sealing mechanism associated with each penetration (e.g., welds, bellows or O-rings) is OPERABLE.
CHANNEL CALIBRATION 1.9 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 all devices in the channel required for channel OPERABILITY and the CHANNEL FUNCTIONAL TEST (excluding transmitters in the Online Monitoring Program). The CHANNEL CALIBRATION may be performed by means of any series of sequential, overlapping or total channel steps, and each step must be performed within the Frequency in the Surveillance Frequency Control Program for the devices included in the step.
CHANNEL CHECK 1.10 A CHANNEL CHECK shall be the qualitative assessment of channel behavior during operation by observation. This determination shall include, where possible, comparison of the channel indication and/or status with other indications and/or status derived from independent instrument channels measuring the same parameter.
ARKANSAS - UNIT 2 1-5 Amendment No. 24,60,157,193,239,324, DEFINITIONS AXIAL SHAPE INDEX 1.22 The AXIAL SHAPE INDEX shall be the power generated in the lower half of the core less the power generated in the upper half of the core divided by the sum of these powers.
REACTOR TRIP SYSTEM RESPONSE TIME 1.23 The REACTOR TRIP SYSTEM RESPONSE TIME shall be the time interval from when the monitored parameter exceeds its trip setpoint at the channel sensor until electrical power is interrupted to the CEA drive mechanism. 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 (including transmitters in the Online Monitoring Program), or the components have been evaluated in accordance with an NRC approved methodology.
ENGINEERED SAFETY FEATURE RESPONSE TIME 1.24 The ENGINEERED SAFETY FEATURE RESPONSE TIME shall be that time interval from when the monitored parameter exceeds its ESF actuation setpoint 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 (including transmitters in the Online Monitoring Program), or the components have been evaluated in accordance with an NRC approved methodology.
PHYSICS TESTS 1.25 PHYSICS TESTS shall be those tests performed to measure the fundamental nuclear characteristics of the reactor core and related instrumentation and 1) described in Chapter 14.0 of the FSAR, 2) authorized under the provisions of 10 CFR 50.59, or
- 3) otherwise approved by the Commission.
SOFTWARE 1.26 The digital computer SOFTWARE for the reactor protection system shall be the program codes including their associated data, documentation and procedures.
PLANAR RADIAL PEAKING FACTOR Fxy 1.27 The PLANAR RADIAL PEAKING FACTOR is the ratio of the peak to plane average power density of the individual fuel rods in a given horizontal plane, excluding the effects of azimuthal tilt.
ARKANSAS - UNIT 2 6-18d Amendment No.
ADMINISTRATIVE CONTROLS 6.5.21 Online Monitoring Program This program provides controls to determine the need for calibration of pressure, level, and flow transmitters using condition monitoring based on drift analysis. It also provides a means for in-situ dynamic response assessment using the noise analysis technique to detect failure modes that are not detectable by drift monitoring.
The Online Monitoring Program must be implemented in accordance with AMS-TR-0720R2-A, "Online Monitoring Technology to Extend Calibration Intervals of Nuclear Plant Pressure Transmitters" (proprietary version). The program shall include the following elements:
- a. Implementation of online monitoring for transmitters that have been evaluated in accordance with an NRC approved methodology during the plant operating cycle.
- 1) Analysis of online monitoring data to identify those transmitters that require a calibration check and those that do not require a calibration check,
- 2) Performance of online monitoring using noise analysis to assess in-situ dynamic response of transmitters that can affect response time performance,
- 3) Calibration checks of identified transmitters no later than during the next scheduled refueling outage, and
- 4) Documentation of the results of the online monitoring data analysis.
- b. Performance of a calibration check for any transmitter where the online monitoring was not implemented during the plant operating cycle no later than during the next scheduled refueling outage.
- c. Performance of calibration checks for transmitters at the specified backstop frequencies.
- d. The provisions of Surveillance Requirement 4.0.3 are applicable to the required calibration checks specified in items a.3, b, and c above.
Enclosure, Attachment 3 CNRO2024-00002 Technical Specification Mark-ups - GGNS (6 TS Pages Follow)
Definitions 1.1 GRAND GULF 1.0-1 Amendment No. 120,229,235, 1.0 USE AND APPLICATION 1.1 Definitions
NOTE------------------------------------------------------------
The defined terms of this section appear in capitalized type and are applicable throughout these Technical Specifications and Bases.
Term Definition ACTIONS ACTIONS shall be that part of a Specification that prescribes Required Actions to be taken under designated Conditions within specified Completion Times.
AVERAGE PLANAR LINEAR The APLHGR shall be applicable to a specific HEAT GENERATION RATE planar height and is equal to the sum of the (APLHGR)
LHGRs for all the fuel rods in the specified bundle at the specified height divided by the number of fuel rods in the fuel bundle.
CHANNEL CALIBRATION A CHANNEL CALIBRATION shall be the adjustment, as necessary, of the channel output such that it responds within the necessary range and accuracy to known values of the parameter that the channel monitors. The CHANNEL CALIBRATION shall encompass all devices in the channel required for channel OPERABILITY and the CHANNEL FUNCTIONAL TEST (excluding transmitters in the Online Monitoring Program). Calibration of instrument channels with resistance temperature detector (RTD) or thermocouple sensors may consist of an inplace qualitative assessment of sensor behavior and normal calibration of the remaining adjustable devices in the channel. The CHANNEL CALIBRATION may be performed by means of any series of sequential, overlapping, or total channel steps, and each step must be performed within the Frequency in the Surveillance Frequency Control Program for the devices included in the step.
CHANNEL CHECK A CHANNEL CHECK shall be the qualitative assessment, by observation, of channel behavior during operation. This determination shall include, where possible, comparison of the channel indication and status to other indications or status derived from independent instrument channels measuring the same parameter.
(continued)
Definitions 1.1 GRAND GULF 1.0-3a Amendment No. 141,145,218, 1.1 Definitions (continued)
DRAIN TIME
- d.
No additional draining events occur; and (continued)
- e. Realistic cross-sectional areas and drain rates are used.
A bounding DRAIN TIME may be used in lieu of a calculated value.
EMERGENCY CORE COOLING The ECCS RESPONSE TIME shall be that time interval SYSTEM (ECCS) RESPONSE from when the monitored parameter exceeds its ECCS TIME initiation setpoint at the channel sensor until the ECCS 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 transmitters in the Online Monitoring Program provided that the methodology for verification has been previously reviewed and approved by the NRC.
END OF CYCLE The EOC-RPT SYSTEM RESPONSE TIME shall be that RECIRCULATION PUMP TRIP time interval from initial movement of the associated turbine (EOC-RPT) SYSTEM stop valve or the turbine control valve to complete RESPONSE TIME suppression of the electric arc between the fully open contacts of the recirculation pump circuit breaker. 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, except for the breaker arc suppression time, which is not measured but is validated to conform to the manufacturer's design value. In lieu of measurement, response time may be verified for transmitters in the Online Monitoring Program provided that the methodology for verification has been previously reviewed and approved by the NRC.
INSERVICE TESTING The INSERVICE TESTING PROGRAM is the licensee PROGRAM program that fulfills the requirements of 10 CFR 50.55a(f).
(continued)
Definitions 1.1 GRAND GULF 1.0-3b Amendment No.
1.1 Definitions (continued)
ISOLATION SYSTEM The ISOLATION SYSTEM RESPONSE TIME shall be that RESPONSE TIME time interval from when the monitored parameter exceeds its isolation initiation setpoint at the channel sensor until the isolation valves travel to their required positions. 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 transmitters in the Online Monitoring Program provided that the methodology for verification has been previously reviewed and approved by the NRC.
La The maximum allowable primary containment leakage rate, La, shall be 0.682% of primary containment air weight per day at the calculated peak containment pressure (Pa).
(continued)
Definitions 1.1 GRAND GULF 1.0-5 Amendment No. 120,156,191,235, 1.1 Definitions (continued)
LOGIC SYSTEM FUNCTIONAL overlapping, or total system steps so that the entire logic TEST (continued) system is tested.
(continued)
MINIMUM CRITICAL POWER The MCPR shall be the smallest critical power RATIO (MCPR) ratio (CPR) that exists in the core for each class of fuel. The CPR is that power in the assembly that is calculated by application of the appropriate correlation(s) to cause some point in the assembly to experience boiling transition, divided by the actual assembly operating power.
MODE A MODE shall correspond to any one inclusive combination of mode switch position, average reactor coolant temperature, and reactor vessel head closure bolt tensioning specified in Table 1.1-1 with fuel in the reactor vessel.
OPERABLE-OPERABILITY A system, subsystem, division, component, or device shall be OPERABLE or have OPERABILITY when it is capable of performing its specified safety function(s) and when all necessary attendant instrumentation, controls, normal or emergency electrical power, cooling and seal water, lubrication, and other auxiliary equipment that are required for the system, subsystem, division, component, or device to perform its specified safety function(s) are also capable of performing their related support function(s).
PRESSURE TEMPERATURE The PTLR is the unit-specific document that LIMITS REPORT (PTLR) provides the reactor vessel pressure and temperature limits, including heatup and cooldown rates, for the current reactor vessel fluence period. These pressure and temperature limits shall be determined for each fluence period in accordance with Specification 5.6.6.
RATED THERMAL POWER RTP shall be a total reactor core heat transfer (RTP) rate to the reactor coolant of 4408 MWt.
REACTOR PROTECTION The RPS RESPONSE TIME shall be that time interval SYSTEM (RPS) RESPONSE from when the monitored parameter exceeds its RPS TIME trip setpoint at the channel sensor until de-energization of the scram pilot valve solenoids. 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 transmitters in the Online Monitoring Program provided that the methodology for verification has been previously reviewed and approved by the NRC.
(continued)
Programs and Manuals 5.5 GRAND GULF 5.0-16c Amendment No. 234, 5.5 Programs and Manuals 5.5.14 Risk Informed Completion Time Program (continued)
- c.
When a RICT is being used, any change to the plant configuration, as defined in NEI 06-09-A, Appendix A, must be considered for the effect on the RICT.
- 1.
For planned changes, the revised RICT must be determined prior to implementation of the change in configuration.
- 2.
For emergent conditions, the revised RICT must be determined within the time limits of the Required Action Completion Time (i.e.,
not the RICT) or 12 hours1.388889e-4 days <br />0.00333 hours <br />1.984127e-5 weeks <br />4.566e-6 months <br /> after the plant configuration change, whichever is less.
- 3.
Revising the RICT is not required if the plant configuration change would lower plant risk and would result in a longer RICT.
- d.
For emergent conditions, if the extent of condition evaluation for inoperable structures, systems, or components (SSCs) is not complete prior to exceeding the Completion Time, the RICT shall account for the increased possibility of common cause failure (CCF) by either:
- 1.
Numerically accounting for the increased possibility of CCF in the RICT calculation; or
- 2.
Risk Management Actions (RMAs) not already credited in the RICT calculation shall be implemented that support redundant or diverse SSCs that perform the function(s) of the inoperable SSCs, and, if practicable, reduce the frequency of initiating events that challenge the functions(s) performed by the inoperable SSCs.
- e.
The risk assessment approaches and methods shall be acceptable to the NRC. The plant PRA shall be based on the as-built, as-operated, and maintained plant; and reflect the operating experience at the plant, as specified in Regulatory Guide 1.200, Revision 2. Methods to assess the risk from extending the Completion Times must be PRA methods approved for use with this program in Amendment No. 234, or other methods approved by the NRC for generic use; and any change in the PRA methods to assess risk that are outside these approval boundaries require prior NRC approval.
(continued)
Programs and Manuals 5.5 GRAND GULF 5.0-16d Amendment No.
5.5 Programs and Manuals 5.5.15 Online Monitoring Program This program provides controls to determine the need for calibration of pressure, level, and flow transmitters using condition monitoring based on drift analysis. It also provides a means for in-situ dynamic response assessment using the noise analysis technique to detect failure modes that are not detectable by drift monitoring.
The Online Monitoring Program must be implemented in accordance with AMS-TR-0720R2-A, "Online Monitoring Technology to Extend Calibration Intervals of Nuclear Plant Pressure Transmitters" (proprietary version). The program shall include the following elements:
- a.
Implementation of online monitoring for transmitters that have been evaluated in accordance with an NRC approved methodology during the plant operating cycle.
- 1)
Analysis of online monitoring data to identify those transmitters that require a calibration check and those that do not require a calibration check,
- 2)
Performance of online monitoring using noise analysis to assess in-situ dynamic response of transmitters that can affect response time performance,
- 3)
Calibration checks of identified transmitters no later than during the next scheduled refueling outage, and
- 4)
Documentation of the results of the online monitoring data analysis.
- b.
Performance of a calibration check for any transmitter where the online monitoring was not implemented during the plant operating cycle no later than during the next scheduled refueling outage.
- c.
Performance of calibration checks for transmitters at the specified backstop frequencies.
- d.
The provisions of Surveillance Requirement 3.0.3 are applicable to the required calibration checks specified in items a.3, b, and c above.
Enclosure, Attachment 4 CNRO2024-00002 Technical Specification Mark-ups - RBS (7 TS Pages Follow)
Definitions 1.1 RIVER BEND 1.0-1 Amendment No. 81,207,215, 1.0 USE AND APPLICATION 1.1 Definitions
NOTE----------------------------------------------------------------
The defined terms of this section appear in capitalized type and are applicable throughout these Technical Specifications and Bases.
Term Definition ACTIONS ACTIONS shall be that part of a Specification that prescribes Required Actions to be taken under designated Conditions within specified Completion Times.
AVERAGE PLANAR LINEAR The APLHGR shall be applicable to a specific planar height HEAT GENERATION RATE and is equal to the sum of the LHGRs for all the fuel rods in (APLHGR) the specified bundle at the specified height divided by the number of fuel rods in the fuel bundle.
CHANNEL CALIBRATION A CHANNEL CALIBRATION shall be the adjustment, as necessary, of the channel output such that it responds within the necessary range and accuracy to known values of the parameter that the channel monitors. The CHANNEL CALIBRATION shall encompass all devices in the channel required for channel OPERABILITY and the CHANNEL FUNCTIONAL TEST (excluding transmitters in the Online Monitoring Program). Calibration of instrument channels with resistance temperature detector (RTD) or thermocouple sensors may consist of an inplace qualitative assessment of sensor behavior and normal calibration of the remaining adjustable devices in the channel. The CHANNEL CALIBRATION may be performed by means of any series of sequential, overlapping, or total channel steps, and each step must be performed within the Frequency in the Surveillance Frequency Control Program for the devices included in the step.
CHANNEL CHECK A CHANNEL CHECK shall be the qualitative assessment, by observation, of channel behavior during operation. This determination shall include, where possible, comparison of the channel indication and status to other indications or status derived from independent instrument channels measuring the same parameter.
(continued)
Definitions 1.1 RIVER BEND 1.0-3 Amendment No. 81,84,193, 1.1 Definitions (continued)
DRAIN TIME (continued)
EMERGENCY CORE COOLING SYSTEM (ECCS)
RESPONSE TIME END OF CYCLE RECIRCULATION PUMP TRIP (EOC-RPT) SYSTEM RESPONSE TIME d.
No additional draining events occur; and e.
Realistic cross-sectional areas and drain rates are used.
A bounding DRAIN TIME may be used in lieu of a calculated value.
The ECCS RESPONSE TIME shall be that time interval from when the monitored parameter exceeds its ECCS initiation setpoint at the channel sensor until the ECCS 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 transmitters in the Online Monitoring Program provided that the methodology for verification has been previously reviewed and approved by the NRC.
The EOC-RPT SYSTEM RESPONSE TIME shall be that time interval from initial movement of the associated turbine stop valve or the turbine control valve to complete suppression of the electric arc between the fully open contacts of the recirculation pump circuit breaker. 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 transmitters in the Online Monitoring Program provided that the methodology for verification has been previously reviewed and approved by the NRC.
(continued)
Definitions 1.1 RIVER BEND 1.0-3a Amendment No.
1.1 Definitions (continued)
ISOLATION SYSTEM RESPONSE TIME The ISOLATION SYSTEM RESPONSE TIME shall be that time interval from when the monitored parameter exceeds its isolation initiation setpoint at the channel sensor until the isolation valves travel to their required positions. 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 transmitters in the Online Monitoring Program provided that the methodology for verification has been previously reviewed and approved by the NRC.
(continued)
Definitions 1.1 RIVER BEND 1.0-5 Amendment No. 81, 114, 129, 1.1 Definitions (continued)
MAXIMUM FRACTION The MFLPD shall be the largest value of the fraction of OF LIMITING limiting power density in the core. The fraction of limiting POWER DENSITY (MFLPD) power density shall be the LHGR existing at a given location divided by the specified LHGR limit for that bundle type.
MINIMUM CRITICAL POWER The MCPR shall be the smallest critical power ratio (CPR)
RATIO (MCPR) that exists in the core for each class of fuel. The CPR is that power in the assembly that is calculated by application of the appropriate correlation(s) to cause some point in the assembly to experience boiling transition, divided by the actual assembly operating power.
MODE A MODE shall correspond to any one inclusive combination of mode switch position, average reactor coolant temperature, and reactor vessel head closure bolt tensioning specified in Table 1.1-1 with fuel in the reactor vessel.
OPERABLE - OPERABILITY A system, subsystem, division, component, or device shall be OPERABLE or have OPERABILITY when it is capable of performing its specified safety function(s) and when all necessary attendant instrumentation, controls, normal or emergency electrical power, cooling and seal water, lubrication, and other auxiliary equipment that are required for the system, subsystem, division, component, or device to perform its specified safety function(s) are also capable of performing their related support function(s).
RATED THERMAL POWER RTP shall be a total reactor core heat transfer rate to the (RTP) reactor coolant of 3091 MWt.
REACTOR PROTECTION The RPS RESPONSE TIME shall be that time interval from SYSTEM (RPS) RESPONSE when the monitored parameter exceeds its RPS trip setpoint TIME at the channel sensor until de-energization of the scram pilot valve solenoids. 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 transmitters in the Online Monitoring Program provided that the methodology for verification has been previously reviewed and approved by the NRC.
(continued)
Definitions 1.1 RIVER BEND 1.0-6 Amendment No. 81, 180, 1.1 Definitions (continued)
SDM shall be the amount of reactivity by which the reactor is subcritical or would be subcritical throughout the operating cycle assuming that:
- a.
The reactor is xenon free;
- b.
The moderator temperature is 68°F; corresponding to the most reactive state; and
- c.
All control rods are fully inserted except for the single control rod of highest reactivity worth, which is assumed to be fully withdrawn. With control rods not capable of being fully inserted, the reactivity worth of these control rods must be accounted for in the determination of SDM.
STAGGERED TEST BASIS A STAGGERED TEST BASIS shall consist of the testing of one of the systems, subsystems, channels, or other designated components during the interval specified by the Surveillance Frequency, so that all systems, subsystems, channels, or other designated components are tested during n Surveillance Frequency intervals, where n is the total number of systems, subsystems, channels, or other designated components in the associated function.
THERMAL POWER THERMAL POWER shall be the total reactor core heat transfer rate to the reactor coolant.
TURBINE BYPASS SYSTEM The TURBINE BYPASS SYSTEM RESPONSE TIME RESPONSE TIME consists of two components:
- a.
The time from initial movement of the main turbine stop valve or control valve until 80% of the turbine bypass capacity is established; and
- b.
The time from initial movement of the main turbine stop valve or control valve until initial movement of the turbine bypass valve.
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 transmitters in the Online Monitoring Program provided that the methodology for verification has been previously reviewed and approved by the NRC.
Programs and Manuals 5.5 RIVER BEND 5.0-16c Amendment No. 213, 5.5 Programs and Manuals 5.5.16 Risk Informed Completion Time Program (continued) c.
When a RICT is being used, any change to the plant configuration, as defined in NEI 06-09-A, Appendix A, must be considered for the effect on the RICT.
1.
For planned changes, the revised RICT must be determined prior to implementation of the change in configuration.
2.
For emergent conditions, the revised RICT must be determined within the time limits of the Required Action Completion Time (i.e.,
not the RICT) or 12 hours1.388889e-4 days <br />0.00333 hours <br />1.984127e-5 weeks <br />4.566e-6 months <br /> after the plant configuration change, whichever is less.
3.
Revising the RICT is not required if the plant configuration change would lower plant risk and would result in a longer RICT.
d.
For emergent conditions, if the extent of condition evaluation for inoperable structures, systems, or components (SSCs) is not complete prior to exceeding the Completion Time, the RICT shall account for the increased possibility of common cause failure (CCF) by either:
1.
Numerically accounting for the increased possibility of CCF in the RICT calculation; or 2.
Risk Management Actions (RMAs) not already credited in the RICT calculation shall be implemented that support redundant or diverse SSCs that perform the function(s) of the inoperable SSCs, and, if practicable, reduce the frequency of initiating events that challenge the functions(s) performed by the inoperable SSCs.
e.
The risk assessment approaches and methods shall be acceptable to the NRC. The plant PRA shall be based on the as-built, as-operated, and maintained plant; and reflect the operating experience at the plant, as specified in Regulatory Guide 1.200, Revision 2. Methods to assess the risk from extending the Completion Times must be PRA methods approved for use with this program in Amendment No. 213, or other methods approved by the NRC for generic use; and any change in the PRA methods to assess risk that are outside these approval boundaries require prior NRC approval.
(continued)
Programs and Manuals 5.5 RIVER BEND 5.0-16d Amendment No.
5.5 Programs and Manuals 5.5.17 Online Monitoring Program This program provides controls to determine the need for calibration of pressure, level, and flow transmitters using condition monitoring based on drift analysis. It also provides a means for in-situ dynamic response assessment using the noise analysis technique to detect failure modes that are not detectable by drift monitoring.
The Online Monitoring Program must be implemented in accordance with AMS-TR-0720R2-A, "Online Monitoring Technology to Extend Calibration Intervals of Nuclear Plant Pressure Transmitters" (proprietary version). The program shall include the following elements:
- a. Implementation of online monitoring for transmitters that have been evaluated in accordance with an NRC approved methodology during the plant operating cycle.
- 1) Analysis of online monitoring data to identify those transmitters that require a calibration check and those that do not require a calibration
- check,
- 2) Performance of online monitoring using noise analysis to assess in-situ dynamic response of transmitters that can affect response time performance,
- 3) Calibration checks of identified transmitters no later than during the next scheduled refueling outage, and
- 4) Documentation of the results of the online monitoring data analysis.
- b. Performance of a calibration check for any transmitter where the online monitoring was not implemented during the plant operating cycle no later than during the next scheduled refueling outage.
- c. Performance of calibration checks for transmitters at the specified backstop frequencies.
- d. The provisions of Surveillance Requirement 3.0.3 are applicable to the required calibration checks specified in items a.3, b, and c above.
Enclosure, Attachment 5 CNRO2024-00002 Technical Specification Mark-ups - WF3 (4 TS Pages Follow)
WATERFORD - UNIT 3 1-1 AMENDMENT NO. 266, 1.0 DEFINITIONS The defined terms of this section appear in capitalized type and are applicable throughout these Technical Specifications.
ACTION 1.1 ACTION shall be that part of a specification which prescribes remedial measures required under designated conditions.
AXIAL SHAPE INDEX 1.2 The AXIAL SHAPE INDEX shall be the power generated in the lower half of the core less the power generated in the upper half of the core divided by the sum of these powers.
AZIMUTHAL POWER TILT - Tq 1.3 AZIMUTHAL POWER TILT shall be the power asymmetry between azimuthally symmetric fuel assemblies.
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 all devices in the channel required for channel OPERABILITY and the CHANNEL FUNCTIONAL TEST (excluding transmitters in the Online Monitoring Program). The CHANNEL CALIBRATION may be performed by means of any series of sequential, overlapping, or total channel steps, and each step must be performed within the Frequency in the Surveillance Frequency Control Program for the devices included in the step.
CHANNEL CHECK 1.5 A CHANNEL CHECK shall be the qualitative assessment of channel behavior during operation by observation. This determination shall include, where possible, comparison of the channel indication and/or status with other indications and/or status derived from independent instrument channels measuring the same parameter.
WATERFORD - UNIT 3 1-3 AMENDMENT NO. 102,175,199,268, DEFINITIONS CORE ALTERATION 1.9 CORE ALTERATION shall be the movement or manipulation of any component within the reactor pressure vessel with the vessel head removed and fuel in the vessel. Suspension of CORE ALTERATION shall not preclude completion of movement of a component to a safe conservative position.
COLR - CORE OPERATING LIMITS REPORT 1.9a The CORE OPERATING LIMITS REPORT is the Waterford 3 specific document that provides core operating limits for the current operating reload cycle. These cycle-specific core operating limits shall be determined for each reload cycle in accordance with Technical Specification 6.9.1.11. Plant operation within these operating limits is addressed in individual specifications.
DOSE EQUIVALENT I-131 1.10 DOSE EQUIVALENT I-131 shall be that concentration of I-131 (microcuries/gram) which alone would produce the same thyroid dose as the quantity and isotopic mixture of I-131, I-132, I-133, I-134, and I-135 actually present. The thyroid dose conversion factors used for this calculation shall be those listed in ICRP-30, Supplement to Part 1, Pages 192-212, Tables titled, "Committed Dose Equivalent in Target Organs or Tissue per Intake of Unit Activity."
- AVERAGE DISINTEGRATION ENERGY 1.11 shall be the average (weighted in proportion to the concentration of each radionuclide in the reactor coolant at the time of sampling) of the sum of the average beta and gamma energies per disintegration (in MeV) for isotopes, other than iodines, with half-lives greater than 15 minutes, making up at least 95% of the total noniodine activity in the coolant.
ENGINEERED SAFETY FEATURES RESPONSE TIME 1.12 The ENGINEERED SAFETY FEATURES RESPONSE TIME shall be that time interval from when the monitored parameter exceeds its ESF actuation setpoint 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 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 (including transmitters in the Online Monitoring Program), or the components have been evaluated in accordance with an NRC approved methodology.
WATERFORD - UNIT 3 1-6 AMENDMENT NO. 175,182,183,199,
- 268, DEFINITIONS RATED THERMAL POWER 1.24 RATED THERMAL POWER shall be a total reactor core heat transfer rate to the reactor coolant of 3716 MWt.
REACTOR TRIP SYSTEM RESPONSE TIME 1.25 The REACTOR TRIP SYSTEM RESPONSE TIME shall be the time interval from when the monitored parameter exceeds its trip setpoint at the channel sensor until electrical power to the CEA drive mechanism is interrupted. The response time may be measured by 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 (including transmitters in the Online Monitoring Program), or the components have been evaluated in accordance with an NRC approved methodology.
REPORTABLE EVENT 1.26 A REPORTABLE EVENT shall be any of those conditions specified in Section 50.73 to 10 CFR Part 50.
SHIELD BUILDING INTEGRITY 1.27 SHIELD BUILDING INTEGRITY shall exist when:
- a.
Each door in each access opening is closed except when the access opening is being used for normal transit entry and exit, then at least one door shall be closed,
- b.
The shield building filtration system is in compliance with the requirements of Specification 3.6.6.1, and
- c.
The sealing mechanism associated with each penetration (e.g., welds, bellows, or O-rings) is OPERABLE.
SHUTDOWN MARGIN 1.28 SHUTDOWN MARGIN shall be the instantaneous amount of reactivity by which the reactor is subcritical or would be subcritical from its present condition assuming all control element assemblies are fully inserted except for the single assembly of highest reactivity worth which is assumed to be fully withdrawn.
WATERFORD - UNIT 3 6-11 AMENDMENT NO. 270, Next Page is 6-14 ADMINISTRATIVE CONTROLS 6.5.20 Online Monitoring Program This program provides controls to determine the need for calibration of pressure, level, and flow transmitters using condition monitoring based on drift analysis. It also provides a means for in-situ dynamic response assessment using the noise analysis technique to detect failure modes that are not detectable by drift monitoring.
The Online Monitoring Program must be implemented in accordance with AMS-TR-0720R2-A, "Online Monitoring Technology to Extend Calibration Intervals of Nuclear Plant Pressure Transmitters" (proprietary version). The program shall include the following elements:
- a. Implementation of online monitoring for transmitters that have been evaluated in accordance with an NRC approved methodology during the plant operating cycle.
- 1) Analysis of online monitoring data to identify those transmitters that require a calibration check and those that do not require a calibration check,
- 2) Performance of online monitoring using noise analysis to assess in-situ dynamic response of transmitters that can affect response time performance,
- 3) Calibration checks of identified transmitters no later than during the next scheduled refueling outage, and
- 4) Documentation of the results of the online monitoring data analysis.
- b. Performance of a calibration check for any transmitter where the online monitoring was not implemented during the plant operating cycle no later than during the next scheduled refueling outage.
- c. Performance of calibration checks for transmitters at the specified backstop frequencies.
- d. The provisions of Surveillance Requirement 3.0.3 are applicable to the required calibration checks specified in items a.3, b, and c above.
Text deleted from center of this page.
Pages 6-12 through Page 6-13 not used
Enclosure, Attachment 6 CNRO2024-00002 Technical Specification Clean Typed - ANO-1 (3 TS Pages Follow)
Definitions 1.1 ANO-1 1.1-1 Amendment No. 215, 1.0 USE AND APPLICATION 1.1 Definitions
NOTE------------------------------------------------------------
The defined terms of this section appear in capitalized type and are applicable throughout these Technical Specifications and Bases.
Term Definition ACTIONS ACTIONS shall be that part of a Specification that prescribes Required Actions to be taken under designated Conditions within specified Completion Times.
ALLOWABLE THERMAL POWER ALLOWABLE THERMAL POWER shall be the maximum steady state reactor core heat transfer rate to the reactor coolant permitted by consideration of the number and configuration of reactor coolant pumps (RCPs) in operation.
AXIAL POWER IMBALANCE AXIAL POWER IMBALANCE shall be the power in the top half of the core, expressed as a percentage of RATED THERMAL POWER (RTP), minus the power in the bottom half of the core, expressed as a percentage of RTP.
AXIAL POWER SHAPING APSRs shall be the control components with part length RODS (APSRs) absorbers used to control the axial power distribution of the reactor core. The APSRs are positioned manually by the operator and are not trippable.
CHANNEL CALIBRATION A CHANNEL CALIBRATION shall be the adjustment, as necessary, of the channel output such that it responds within the necessary range and accuracy to known values of the parameter that the channel monitors. The CHANNEL CALIBRATION shall encompass all devices in the channel required for channel OPERABILITY and the CHANNEL FUNCTIONAL TEST (excluding transmitters in the Online Monitoring Program).
Calibration of instrument channels with resistance temperature detector (RTD) or thermocouple sensors may consist of an inplace qualitative assessment of sensor behavior and normal calibration of the remaining adjustable devices in the channel.
Programs and Manuals 5.5 ANO-1 5.0-20a Amendment No. 281, 5.0 ADMINISTRATIVE CONTROLS 5.5 Programs and Manuals
- c.
When a RICT is being used, any change to the plant configuration, as defined in NEI 06-09-A, Appendix A, must be considered for the effect on the RICT.
- 1.
For planned changes, the revised RICT must be determined prior to implementation of the change in configuration.
- 2.
For emergent conditions, the revised RICT must be determined within the time limits of the Required Action Completion Time (i.e., not the RICT) or 12 hours1.388889e-4 days <br />0.00333 hours <br />1.984127e-5 weeks <br />4.566e-6 months <br /> after the plant configuration change, whichever is less.
- 3.
Revising the RICT is not required If the plant configuration change would lower plant risk and would result in a longer RICT.
- d.
For emergent conditions, if the extent of condition evaluation for inoperable structures, systems, or components (SSCs) is not complete prior to exceeding the Completion Time, the RICT shall account for the increased possibility of common cause failure (CCF) by either:
- 1.
Numerically accounting for the increased possibility of CCF in the RICT calculation; or
- 2.
Risk Management Actions (RMAs) not already credited in the RICT calculation shall be implemented that support redundant or diverse SSCs that perform the function(s) of the inoperable SSCs, and, if practicable, reduce the frequency of initiating events that challenge the function(s) performed by the inoperable SSCs.
- e.
The risk assessment approaches and methods shall be acceptable to the NRC. The plant PRA shall be based on the as-built, as-operated, and maintained plant; and reflect the operating experience at the plant, as specified in Regulatory Guide 1.200, Revision 2. Methods to assess the risk from extending the Completion Times must be PRA methods approved for use with this program, or other methods approved by the NRC for generic use; and any change in the PRA methods to assess risk that are outside these approval boundaries require prior NRC approval.
Programs and Manuals 5.5 ANO-1 5.0-20b Amendment No.
5.0 ADMINISTRATIVE CONTROLS 5.5 Programs and Manuals 5.5.19 Online Monitoring Program This program provides controls to determine the need for calibration of pressure, level, and flow transmitters using condition monitoring based on drift analysis. It also provides a means for in-situ dynamic response assessment using the noise analysis technique to detect failure modes that are not detectable by drift monitoring.
The Online Monitoring Program must be implemented in accordance with AMS-TR-0720R2-A, "Online Monitoring Technology to Extend Calibration Intervals of Nuclear Plant Pressure Transmitters" (proprietary version). The program shall include the following elements:
- a. Implementation of online monitoring for transmitters that have been evaluated in accordance with an NRC approved methodology during the plant operating cycle.
- 1) Analysis of online monitoring data to identify those transmitters that require a calibration check and those that do not require a calibration
- check,
- 2) Performance of online monitoring using noise analysis to assess in-situ dynamic response of transmitters that can affect response time performance,
- 3) Calibration checks of identified transmitters no later than during the next scheduled refueling outage, and
- 4) Documentation of the results of the online monitoring data analysis.
- b. Performance of a calibration check for any transmitter where the online monitoring was not implemented during the plant operating cycle no later than during the next scheduled refueling outage.
- c. Performance of calibration checks for transmitters at the specified backstop frequencies.
- d. The provisions of Surveillance Requirement 3.0.3 are applicable to the required calibration checks specified in items a.3, b, and c above.
Enclosure, Attachment 7 CNRO2024-00002 Technical Specification Clean Typed - ANO-2 (3 TS Pages Follow)
ARKANSAS - UNIT 2 1-2 Amendment No. 154,157,319,334, DEFINITIONS CONTAINMENT INTEGRITY 1.8 CONTAINMENT INTEGRITY shall exist when:
1.8.1 All penetrations required to be closed during accident conditions are either:
- a.
Capable of being closed by an OPERABLE containment automatic isolation valve system, or
- b.
Closed by manual valves, blind flanges, or deactivated automatic valves secured in their closed positions, except for valves that are open under administrative control as permitted by Specification 3.6.3.1.
1.8.2 All equipment hatches are closed and sealed, 1.8.3 Each airlock is OPERABLE pursuant to Specification 3.6.1.3, 1.8.4 The containment leakage rates are within the limits of Specification 3.6.1.2, and 1.8.5 The sealing mechanism associated with each penetration (e.g., welds, bellows or O-rings) is OPERABLE.
CHANNEL CALIBRATION 1.9 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 all devices in the channel required for channel OPERABILITY and the CHANNEL FUNCTIONAL TEST (excluding transmitters in the Online Monitoring Program). The CHANNEL CALIBRATION may be performed by means of any series of sequential, overlapping or total channel steps, and each step must be performed within the Frequency in the Surveillance Frequency Control Program for the devices included in the step.
CHANNEL CHECK 1.10 A CHANNEL CHECK shall be the qualitative assessment of channel behavior during operation by observation. This determination shall include, where possible, comparison of the channel indication and/or status with other indications and/or status derived from independent instrument channels measuring the same parameter.
ARKANSAS - UNIT 2 1-5 Amendment No. 24,60,157,193,239,324, DEFINITIONS AXIAL SHAPE INDEX 1.22 The AXIAL SHAPE INDEX shall be the power generated in the lower half of the core less the power generated in the upper half of the core divided by the sum of these powers.
REACTOR TRIP SYSTEM RESPONSE TIME 1.23 The REACTOR TRIP SYSTEM RESPONSE TIME shall be the time interval from when the monitored parameter exceeds its trip setpoint at the channel sensor until electrical power is interrupted to the CEA drive mechanism. 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 (including transmitters in the Online Monitoring Program), or the components have been evaluated in accordance with an NRC approved methodology.
ENGINEERED SAFETY FEATURE RESPONSE TIME 1.24 The ENGINEERED SAFETY FEATURE RESPONSE TIME shall be that time interval from when the monitored parameter exceeds its ESF actuation setpoint 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 (including transmitters in the Online Monitoring Program), or the components have been evaluated in accordance with an NRC approved methodology.
PHYSICS TESTS 1.25 PHYSICS TESTS shall be those tests performed to measure the fundamental nuclear characteristics of the reactor core and related instrumentation and 1) described in Chapter 14.0 of the FSAR, 2) authorized under the provisions of 10 CFR 50.59, or
- 3) otherwise approved by the Commission.
SOFTWARE 1.26 The digital computer SOFTWARE for the reactor protection system shall be the program codes including their associated data, documentation and procedures.
PLANAR RADIAL PEAKING FACTOR Fxy 1.27 The PLANAR RADIAL PEAKING FACTOR is the ratio of the peak to plane average power density of the individual fuel rods in a given horizontal plane, excluding the effects of azimuthal tilt.
ARKANSAS - UNIT 2 6-18d Amendment No.
ADMINISTRATIVE CONTROLS 6.5.21 Online Monitoring Program This program provides controls to determine the need for calibration of pressure, level, and flow transmitters using condition monitoring based on drift analysis. It also provides a means for in-situ dynamic response assessment using the noise analysis technique to detect failure modes that are not detectable by drift monitoring.
The Online Monitoring Program must be implemented in accordance with AMS-TR-0720R2-A, "Online Monitoring Technology to Extend Calibration Intervals of Nuclear Plant Pressure Transmitters" (proprietary version). The program shall include the following elements:
- a. Implementation of online monitoring for transmitters that have been evaluated in accordance with an NRC approved methodology during the plant operating cycle.
- 1) Analysis of online monitoring data to identify those transmitters that require a calibration check and those that do not require a calibration check,
- 2) Performance of online monitoring using noise analysis to assess in-situ dynamic response of transmitters that can affect response time performance,
- 3) Calibration checks of identified transmitters no later than during the next scheduled refueling outage, and
- 4) Documentation of the results of the online monitoring data analysis.
- b. Performance of a calibration check for any transmitter where the online monitoring was not implemented during the plant operating cycle no later than during the next scheduled refueling outage.
- c. Performance of calibration checks for transmitters at the specified backstop frequencies.
- d. The provisions of Surveillance Requirement 4.0.3 are applicable to the required calibration checks specified in items a.3, b, and c above.
Enclosure, Attachment 8 CNRO2024-00002 Technical Specification Clean Typed - GGNS (6 TS Pages Follow)
Definitions 1.1 GRAND GULF 1.0-1 Amendment No. 120,229,235, 1.0 USE AND APPLICATION 1.1 Definitions
NOTE------------------------------------------------------------
The defined terms of this section appear in capitalized type and are applicable throughout these Technical Specifications and Bases.
Term Definition ACTIONS ACTIONS shall be that part of a Specification that prescribes Required Actions to be taken under designated Conditions within specified Completion Times.
AVERAGE PLANAR LINEAR The APLHGR shall be applicable to a specific HEAT GENERATION RATE planar height and is equal to the sum of the (APLHGR)
LHGRs for all the fuel rods in the specified bundle at the specified height divided by the number of fuel rods in the fuel bundle.
CHANNEL CALIBRATION A CHANNEL CALIBRATION shall be the adjustment, as necessary, of the channel output such that it responds within the necessary range and accuracy to known values of the parameter that the channel monitors. The CHANNEL CALIBRATION shall encompass all devices in the channel required for channel OPERABILITY and the CHANNEL FUNCTIONAL TEST (excluding transmitters in the Online Monitoring Program). Calibration of instrument channels with resistance temperature detector (RTD) or thermocouple sensors may consist of an inplace qualitative assessment of sensor behavior and normal calibration of the remaining adjustable devices in the channel. The CHANNEL CALIBRATION may be performed by means of any series of sequential, overlapping, or total channel steps, and each step must be performed within the Frequency in the Surveillance Frequency Control Program for the devices included in the step.
CHANNEL CHECK A CHANNEL CHECK shall be the qualitative assessment, by observation, of channel behavior during operation. This determination shall include, where possible, comparison of the channel indication and status to other indications or status derived from independent instrument channels measuring the same parameter.
(continued)
Definitions 1.1 GRAND GULF 1.0-3a Amendment No. 141, 145, 218, 1.1 Definitions (continued)
DRAIN TIME
- d.
No additional draining events occur; and (continued)
- e. Realistic cross-sectional areas and drain rates are used.
A bounding DRAIN TIME may be used in lieu of a calculated value.
EMERGENCY CORE COOLING The ECCS RESPONSE TIME shall be that time interval SYSTEM (ECCS) RESPONSE from when the monitored parameter exceeds its ECCS TIME initiation setpoint at the channel sensor until the ECCS 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 transmitters in the Online Monitoring Program provided that the methodology for verification has been previously reviewed and approved by the NRC.
END OF CYCLE The EOC-RPT SYSTEM RESPONSE TIME shall be that RECIRCULATION PUMP TRIP time interval from initial movement of the associated turbine (EOC-RPT) SYSTEM stop valve or the turbine control valve to complete RESPONSE TIME suppression of the electric arc between the fully open contacts of the recirculation pump circuit breaker. 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, except for the breaker arc suppression time, which is not measured but is validated to conform to the manufacturer's design value. In lieu of measurement, response time may be verified for transmitters in the Online Monitoring Program provided that the methodology for verification has been previously reviewed and approved by the NRC.
INSERVICE TESTING The INSERVICE TESTING PROGRAM is the licensee PROGRAM program that fulfills the requirements of 10 CFR 50.55a(f).
(continued)
Definitions 1.1 GRAND GULF 1.0-3b Amendment No.
1.1 Definitions (continued)
ISOLATION SYSTEM The ISOLATION SYSTEM RESPONSE TIME shall be that RESPONSE TIME time interval from when the monitored parameter exceeds its isolation initiation setpoint at the channel sensor until the isolation valves travel to their required positions. 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 transmitters in the Online Monitoring Program provided that the methodology for verification has been previously reviewed and approved by the NRC.
La The maximum allowable primary containment leakage rate, La, shall be 0.682% of primary containment air weight per day at the calculated peak containment pressure (Pa).
(continued)
Definitions 1.1 GRAND GULF 1.0-5 Amendment No. 120,156,191,235, 1.1 Definitions (continued)
LOGIC SYSTEM FUNCTIONAL overlapping, or total system steps so that the entire logic TEST (continued) system is tested.
MINIMUM CRITICAL POWER The MCPR shall be the smallest critical power RATIO (MCPR) ratio (CPR) that exists in the core for each class of fuel. The CPR is that power in the assembly that is calculated by application of the appropriate correlation(s) to cause some point in the assembly to experience boiling transition, divided by the actual assembly operating power.
MODE A MODE shall correspond to any one inclusive combination of mode switch position, average reactor coolant temperature, and reactor vessel head closure bolt tensioning specified in Table 1.1-1 with fuel in the reactor vessel.
OPERABLE-OPERABILITY A system, subsystem, division, component, or device shall be OPERABLE or have OPERABILITY when it is capable of performing its specified safety function(s) and when all necessary attendant instrumentation, controls, normal or emergency electrical power, cooling and seal water, lubrication, and other auxiliary equipment that are required for the system, subsystem, division, component, or device to perform its specified safety function(s) are also capable of performing their related support function(s).
PRESSURE TEMPERATURE The PTLR is the unit-specific document that LIMITS REPORT (PTLR) provides the reactor vessel pressure and temperature limits, including heatup and cooldown rates, for the current reactor vessel fluence period. These pressure and temperature limits shall be determined for each fluence period in accordance with Specification 5.6.6.
RATED THERMAL POWER RTP shall be a total reactor core heat transfer (RTP) rate to the reactor coolant of 4408 MWt.
REACTOR PROTECTION The RPS RESPONSE TIME shall be that time interval SYSTEM (RPS) RESPONSE from when the monitored parameter exceeds its RPS TIME trip setpoint at the channel sensor until de-energization of the scram pilot valve solenoids. 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 transmitters in the Online Monitoring Program provided that the methodology for verification has been previously reviewed and approved by the NRC.
(continued)
Programs and Manuals 5.5 GRAND GULF 5.0-16c Amendment No. 234, 5.5 Programs and Manuals 5.5.14 Risk Informed Completion Time Program (continued)
- c.
When a RICT is being used, any change to the plant configuration, as defined in NEI 06-09-A, Appendix A, must be considered for the effect on the RICT.
- 1.
For planned changes, the revised RICT must be determined prior to implementation of the change in configuration.
- 2.
For emergent conditions, the revised RICT must be determined within the time limits of the Required Action Completion Time (i.e.,
not the RICT) or 12 hours1.388889e-4 days <br />0.00333 hours <br />1.984127e-5 weeks <br />4.566e-6 months <br /> after the plant configuration change, whichever is less.
- 3.
Revising the RICT is not required if the plant configuration change would lower plant risk and would result in a longer RICT.
- d.
For emergent conditions, if the extent of condition evaluation for inoperable structures, systems, or components (SSCs) is not complete prior to exceeding the Completion Time, the RICT shall account for the increased possibility of common cause failure (CCF) by either:
- 1.
Numerically accounting for the increased possibility of CCF in the RICT calculation; or
- 2.
Risk Management Actions (RMAs) not already credited in the RICT calculation shall be implemented that support redundant or diverse SSCs that perform the function(s) of the inoperable SSCs, and, if practicable, reduce the frequency of initiating events that challenge the functions(s) performed by the inoperable SSCs.
- e.
The risk assessment approaches and methods shall be acceptable to the NRC. The plant PRA shall be based on the as-built, as-operated, and maintained plant; and reflect the operating experience at the plant, as specified in Regulatory Guide 1.200, Revision 2. Methods to assess the risk from extending the Completion Times must be PRA methods approved for use with this program in Amendment No. 234, or other methods approved by the NRC for generic use; and any change in the PRA methods to assess risk that are outside these approval boundaries require prior NRC approval.
(continued)
Programs and Manuals 5.5 GRAND GULF 5.0-16d Amendment No.
5.5 Programs and Manuals 5.5.15 Online Monitoring Program This program provides controls to determine the need for calibration of pressure, level, and flow transmitters using condition monitoring based on drift analysis. It also provides a means for in-situ dynamic response assessment using the noise analysis technique to detect failure modes that are not detectable by drift monitoring.
The Online Monitoring Program must be implemented in accordance with AMS-TR-0720R2-A, "Online Monitoring Technology to Extend Calibration Intervals of Nuclear Plant Pressure Transmitters" (proprietary version). The program shall include the following elements:
- a.
Implementation of online monitoring for transmitters that have been evaluated in accordance with an NRC approved methodology during the plant operating cycle.
- 1)
Analysis of online monitoring data to identify those transmitters that require a calibration check and those that do not require a calibration check,
- 2)
Performance of online monitoring using noise analysis to assess in-situ dynamic response of transmitters that can affect response time performance,
- 3)
Calibration checks of identified transmitters no later than during the next scheduled refueling outage, and
- 4)
Documentation of the results of the online monitoring data analysis.
- b.
Performance of a calibration check for any transmitter where the online monitoring was not implemented during the plant operating cycle no later than during the next scheduled refueling outage.
- c.
Performance of calibration checks for transmitters at the specified backstop frequencies.
- d.
The provisions of Surveillance Requirement 3.0.3 are applicable to the required calibration checks specified in items a.3, b, and c above.
Enclosure, Attachment 9 CNRO2024-00002 Technical Specification Clean Typed - RBS (7 TS Pages Follow)
Definitions 1.1 RIVER BEND 1.0-1 Amendment No. 81,207,215, 1.0 USE AND APPLICATION
1.1 Definitions
NOTE----------------------------------------------------------------
The defined terms of this section appear in capitalized type and are applicable throughout these Technical Specifications and Bases.
Term Definition ACTIONS ACTIONS shall be that part of a Specification that prescribes Required Actions to be taken under designated Conditions within specified Completion Times.
AVERAGE PLANAR LINEAR The APLHGR shall be applicable to a specific planar height HEAT GENERATION RATE and is equal to the sum of the LHGRs for all the fuel rods in (APLHGR) the specified bundle at the specified height divided by the number of fuel rods in the fuel bundle.
CHANNEL CALIBRATION A CHANNEL CALIBRATION shall be the adjustment, as necessary, of the channel output such that it responds within the necessary range and accuracy to known values of the parameter that the channel monitors. The CHANNEL CALIBRATION shall encompass all devices in the channel required for channel OPERABILITY and the CHANNEL FUNCTIONAL TEST (excluding transmitters in the Online Monitoring Program). Calibration of instrument channels with resistance temperature detector (RTD) or thermocouple sensors may consist of an inplace qualitative assessment of sensor behavior and normal calibration of the remaining adjustable devices in the channel. The CHANNEL CALIBRATION may be performed by means of any series of sequential, overlapping, or total channel steps, and each step must be performed within the Frequency in the Surveillance Frequency Control Program for the devices included in the step.
CHANNEL CHECK A CHANNEL CHECK shall be the qualitative assessment, by observation, of channel behavior during operation. This determination shall include, where possible, comparison of the channel indication and status to other indications or status derived from independent instrument channels measuring the same parameter.
(continued)
Definitions 1.1 RIVER BEND 1.0-3 Amendment No. 81, 84, 193,
1.1 Definitions (continued)
DRAIN TIME (continued)
EMERGENCY CORE COOLING SYSTEM (ECCS)
RESPONSE TIME END OF CYCLE RECIRCULATION PUMP TRIP (EOC-RPT) SYSTEM RESPONSE TIME
- d.
No additional draining events occur; and
- e.
Realistic cross-sectional areas and drain rates are used.
A bounding DRAIN TIME may be used in lieu of a calculated value.
The ECCS RESPONSE TIME shall be that time interval from when the monitored parameter exceeds its ECCS initiation setpoint at the channel sensor until the ECCS 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 transmitters in the Online Monitoring Program provided that the methodology for verification has been previously reviewed and approved by the NRC.
The EOC-RPT SYSTEM RESPONSE TIME shall be that time interval from initial movement of the associated turbine stop valve or the turbine control valve to complete suppression of the electric arc between the fully open contacts of the recirculation pump circuit breaker. 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 transmitters in the Online Monitoring Program provided that the methodology for verification has been previously reviewed and approved by the NRC.
(continued)
Definitions 1.1 RIVER BEND 1.0-3a Amendment No.
1.1 Definitions (continued)
ISOLATION SYSTEM RESPONSE TIME The ISOLATION SYSTEM RESPONSE TIME shall be that time interval from when the monitored parameter exceeds its isolation initiation setpoint at the channel sensor until the isolation valves travel to their required positions. 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 transmitters in the Online Monitoring Program provided that the methodology for verification has been previously reviewed and approved by the NRC.
(continued)
Definitions 1.1 RIVER BEND 1.0-5 Amendment No. 81, 114, 129,
1.1 Definitions (continued)
MAXIMUM FRACTION The MFLPD shall be the largest value of the fraction of OF LIMITING limiting power density in the core. The fraction of limiting POWER DENSITY (MFLPD) power density shall be the LHGR existing at a given location divided by the specified LHGR limit for that bundle type.
MINIMUM CRITICAL POWER The MCPR shall be the smallest critical power ratio (CPR)
RATIO (MCPR) that exists in the core for each class of fuel. The CPR is that power in the assembly that is calculated by application of the appropriate correlation(s) to cause some point in the assembly to experience boiling transition, divided by the actual assembly operating power.
MODE A MODE shall correspond to any one inclusive combination of mode switch position, average reactor coolant temperature, and reactor vessel head closure bolt tensioning specified in Table 1.1-1 with fuel in the reactor vessel.
OPERABLE - OPERABILITY A system, subsystem, division, component, or device shall be OPERABLE or have OPERABILITY when it is capable of performing its specified safety function(s) and when all necessary attendant instrumentation, controls, normal or emergency electrical power, cooling and seal water, lubrication, and other auxiliary equipment that are required for the system, subsystem, division, component, or device to perform its specified safety function(s) are also capable of performing their related support function(s).
RATED THERMAL POWER RTP shall be a total reactor core heat transfer rate to the (RTP) reactor coolant of 3091 MWt.
REACTOR PROTECTION The RPS RESPONSE TIME shall be that time interval from SYSTEM (RPS) RESPONSE when the monitored parameter exceeds its RPS trip setpoint TIME at the channel sensor until de-energization of the scram pilot valve solenoids. 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 transmitters in the Online Monitoring Program provided that the methodology for verification has been previously reviewed and approved by the NRC.
(continued)
Definitions 1.1 RIVER BEND 1.0-6 Amendment No. 81, 180, 1.1 Definitions (continued)
SDM shall be the amount of reactivity by which the reactor is subcritical or would be subcritical throughout the operating cycle assuming that:
- a.
The reactor is xenon free;
- b.
The moderator temperature is 68°F; corresponding to the most reactive state; and
- c.
All control rods are fully inserted except for the single control rod of highest reactivity worth, which is assumed to be fully withdrawn. With control rods not capable of being fully inserted, the reactivity worth of these control rods must be accounted for in the determination of SDM.
STAGGERED TEST BASIS A STAGGERED TEST BASIS shall consist of the testing of one of the systems, subsystems, channels, or other designated components during the interval specified by the Surveillance Frequency, so that all systems, subsystems, channels, or other designated components are tested during n Surveillance Frequency intervals, where n is the total number of systems, subsystems, channels, or other designated components in the associated function.
THERMAL POWER THERMAL POWER shall be the total reactor core heat transfer rate to the reactor coolant.
TURBINE BYPASS SYSTEM The TURBINE BYPASS SYSTEM RESPONSE TIME RESPONSE TIME consists of two components:
- a.
The time from initial movement of the main turbine stop valve or control valve until 80% of the turbine bypass capacity is established; and
- b.
The time from initial movement of the main turbine stop valve or control valve until initial movement of the turbine bypass valve.
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 transmitters in the Online Monitoring Program provided that the methodology for verification has been previously reviewed and approved by the NRC.
Programs and Manuals 5.5 RIVER BEND 5.0-16c Amendment No. 213, 5.5 Programs and Manuals 5.5.16 Risk Informed Completion Time Program (continued)
- c.
When a RICT is being used, any change to the plant configuration, as defined in NEI 06-09-A, Appendix A, must be considered for the effect on the RICT.
- 1.
For planned changes, the revised RICT must be determined prior to implementation of the change in configuration.
- 2.
For emergent conditions, the revised RICT must be determined within the time limits of the Required Action Completion Time (i.e.,
not the RICT) or 12 hours1.388889e-4 days <br />0.00333 hours <br />1.984127e-5 weeks <br />4.566e-6 months <br /> after the plant configuration change, whichever is less.
- 3.
Revising the RICT is not required if the plant configuration change would lower plant risk and would result in a longer RICT.
- d.
For emergent conditions, if the extent of condition evaluation for inoperable structures, systems, or components (SSCs) is not complete prior to exceeding the Completion Time, the RICT shall account for the increased possibility of common cause failure (CCF) by either:
- 1.
Numerically accounting for the increased possibility of CCF in the RICT calculation; or
- 2.
Risk Management Actions (RMAs) not already credited in the RICT calculation shall be implemented that support redundant or diverse SSCs that perform the function(s) of the inoperable SSCs, and, if practicable, reduce the frequency of initiating events that challenge the functions(s) performed by the inoperable SSCs.
- e.
The risk assessment approaches and methods shall be acceptable to the NRC. The plant PRA shall be based on the as-built, as-operated, and maintained plant; and reflect the operating experience at the plant, as specified in Regulatory Guide 1.200, Revision 2. Methods to assess the risk from extending the Completion Times must be PRA methods approved for use with this program in Amendment No. 213, or other methods approved by the NRC for generic use; and any change in the PRA methods to assess risk that are outside these approval boundaries require prior NRC approval.
(continued)
Programs and Manuals 5.5 RIVER BEND 5.0-16d Amendment No.
5.5 Programs and Manuals 5.5.17 Online Monitoring Program This program provides controls to determine the need for calibration of pressure, level, and flow transmitters using condition monitoring based on drift analysis. It also provides a means for in-situ dynamic response assessment using the noise analysis technique to detect failure modes that are not detectable by drift monitoring.
The Online Monitoring Program must be implemented in accordance with AMS-TR-0720R2-A, "Online Monitoring Technology to Extend Calibration Intervals of Nuclear Plant Pressure Transmitters" (proprietary version). The program shall include the following elements:
- a. Implementation of online monitoring for transmitters that have been evaluated in accordance with an NRC approved methodology during the plant operating cycle.
- 1) Analysis of online monitoring data to identify those transmitters that require a calibration check and those that do not require a calibration
- check,
- 2) Performance of online monitoring using noise analysis to assess in-situ dynamic response of transmitters that can affect response time performance,
- 3) Calibration checks of identified transmitters no later than during the next scheduled refueling outage, and
- 4) Documentation of the results of the online monitoring data analysis.
- b. Performance of a calibration check for any transmitter where the online monitoring was not implemented during the plant operating cycle no later than during the next scheduled refueling outage.
- c. Performance of calibration checks for transmitters at the specified backstop frequencies.
- d. The provisions of Surveillance Requirement 3.0.3 are applicable to the required calibration checks specified in items a.3, b, and c above.
Enclosure, Attachment 10 CNRO2024-00002 Technical Specification Clean Typed - WF3 (4 TS Pages Follow)
WATERFORD - UNIT 3 1-1 AMENDMENT NO. 266, 1.0 DEFINITIONS The defined terms of this section appear in capitalized type and are applicable throughout these Technical Specifications.
ACTION 1.1 ACTION shall be that part of a specification which prescribes remedial measures required under designated conditions.
AXIAL SHAPE INDEX 1.2 The AXIAL SHAPE INDEX shall be the power generated in the lower half of the core less the power generated in the upper half of the core divided by the sum of these powers.
AZIMUTHAL POWER TILT - Tq 1.3 AZIMUTHAL POWER TILT shall be the power asymmetry between azimuthally symmetric fuel assemblies.
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 all devices in the channel required for channel OPERABILITY and the CHANNEL FUNCTIONAL TEST (excluding transmitters in the Online Monitoring Program). The CHANNEL CALIBRATION may be performed by means of any series of sequential, overlapping, or total channel steps, and each step must be performed within the Frequency in the Surveillance Frequency Control Program for the devices included in the step.
CHANNEL CHECK 1.5 A CHANNEL CHECK shall be the qualitative assessment of channel behavior during operation by observation. This determination shall include, where possible, comparison of the channel indication and/or status with other indications and/or status derived from independent instrument channels measuring the same parameter.
WATERFORD - UNIT 3 1-3 AMENDMENT NO. 102,175,199,268, DEFINITIONS CORE ALTERATION 1.9 CORE ALTERATION shall be the movement or manipulation of any component within the reactor pressure vessel with the vessel head removed and fuel in the vessel. Suspension of CORE ALTERATION shall not preclude completion of movement of a component to a safe conservative position.
COLR - CORE OPERATING LIMITS REPORT 1.9a The CORE OPERATING LIMITS REPORT is the Waterford 3 specific document that provides core operating limits for the current operating reload cycle. These cycle-specific core operating limits shall be determined for each reload cycle in accordance with Technical Specification 6.9.1.11. Plant operation within these operating limits is addressed in individual specifications.
DOSE EQUIVALENT I-131 1.10 DOSE EQUIVALENT I-131 shall be that concentration of I-131 (microcuries/gram) which alone would produce the same thyroid dose as the quantity and isotopic mixture of I-131, I-132, I-133, I-134, and I-135 actually present. The thyroid dose conversion factors used for this calculation shall be those listed in ICRP-30, Supplement to Part 1, Pages 192-212, Tables titled, "Committed Dose Equivalent in Target Organs or Tissue per Intake of Unit Activity."
- AVERAGE DISINTEGRATION ENERGY 1.11 shall be the average (weighted in proportion to the concentration of each radionuclide in the reactor coolant at the time of sampling) of the sum of the average beta and gamma energies per disintegration (in MeV) for isotopes, other than iodines, with half-lives greater than 15 minutes, making up at least 95% of the total noniodine activity in the coolant.
ENGINEERED SAFETY FEATURES RESPONSE TIME 1.12 The ENGINEERED SAFETY FEATURES RESPONSE TIME shall be that time interval from when the monitored parameter exceeds its ESF actuation setpoint 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 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 (including transmitters in the Online Monitoring Program), or the components have been evaluated in accordance with an NRC approved methodology.
WATERFORD - UNIT 3 1-6 AMENDMENT NO. 175,182,183,199,
- 268, DEFINITIONS RATED THERMAL POWER 1.24 RATED THERMAL POWER shall be a total reactor core heat transfer rate to the reactor coolant of 3716 MWt.
REACTOR TRIP SYSTEM RESPONSE TIME 1.25 The REACTOR TRIP SYSTEM RESPONSE TIME shall be the time interval from when the monitored parameter exceeds its trip setpoint at the channel sensor until electrical power to the CEA drive mechanism is interrupted. The response time may be measured by 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 (including transmitters in the Online Monitoring Program), or the components have been evaluated in accordance with an NRC approved methodology.
REPORTABLE EVENT 1.26 A REPORTABLE EVENT shall be any of those conditions specified in Section 50.73 to 10 CFR Part 50.
SHIELD BUILDING INTEGRITY 1.27 SHIELD BUILDING INTEGRITY shall exist when:
- a.
Each door in each access opening is closed except when the access opening is being used for normal transit entry and exit, then at least one door shall be closed,
- b.
The shield building filtration system is in compliance with the requirements of Specification 3.6.6.1, and
- c.
The sealing mechanism associated with each penetration (e.g., welds, bellows, or O-rings) is OPERABLE.
SHUTDOWN MARGIN 1.28 SHUTDOWN MARGIN shall be the instantaneous amount of reactivity by which the reactor is subcritical or would be subcritical from its present condition assuming all control element assemblies are fully inserted except for the single assembly of highest reactivity worth which is assumed to be fully withdrawn.
WATERFORD - UNIT 3 6-11 AMENDMENT NO. 270, Next Page is 6-14 ADMINISTRATIVE CONTROLS 6.5.20 Online Monitoring Program This program provides controls to determine the need for calibration of pressure, level, and flow transmitters using condition monitoring based on drift analysis. It also provides a means for in-situ dynamic response assessment using the noise analysis technique to detect failure modes that are not detectable by drift monitoring.
The Online Monitoring Program must be implemented in accordance with AMS-TR-0720R2-A, "Online Monitoring Technology to Extend Calibration Intervals of Nuclear Plant Pressure Transmitters" (proprietary version). The program shall include the following elements:
- a. Implementation of online monitoring for transmitters that have been evaluated in accordance with an NRC approved methodology during the plant operating cycle.
- 1) Analysis of online monitoring data to identify those transmitters that require a calibration check and those that do not require a calibration check,
- 2) Performance of online monitoring using noise analysis to assess in-situ dynamic response of transmitters that can affect response time performance,
- 3) Calibration checks of identified transmitters no later than during the next scheduled refueling outage, and
- 4) Documentation of the results of the online monitoring data analysis.
- b. Performance of a calibration check for any transmitter where the online monitoring was not implemented during the plant operating cycle no later than during the next scheduled refueling outage.
- c. Performance of calibration checks for transmitters at the specified backstop frequencies.
- d. The provisions of Surveillance Requirement 3.0.3 are applicable to the required calibration checks specified in items a.3, b, and c above.
Enclosure, Attachment 11 CNRO2024-00002 Technical Specification Bases Mark-ups - ANO-1 (Information only)
(11 TS Bases Pages Follow)
RPS Instrumentation B 3.3.1 ANO-1 B 3.3.1-19 Amendment No. 215 Rev. 67,82 SURVEILLANCE REQUIREMENTS (continued)
SR 3.3.1.3 A comparison of power range nuclear instrumentation channels against incore detectors shall be performed periodically when reactor power is 20% RTP. The SR is modified by two Notes.
Note 2 clarifies that 24 hours2.777778e-4 days <br />0.00667 hours <br />3.968254e-5 weeks <br />9.132e-6 months <br /> is allowed for performing the first Surveillance after reaching 20% RTP. Note 1 states if the absolute difference between the power range and incore AXIAL POWER IMBALANCE measurements is 2% RTP, the power range channel is not inoperable, but an adjustment of the measured imbalance to agree with the incore measurements is necessary. If the power range channel cannot be properly recalibrated, the channel is declared inoperable. The calculation of the Allowable Value envelope assumes a difference in out of core to incore AXIAL POWER IMBALANCE measurements of 2.5%. Additional inaccuracies beyond those that are measured are also included in the setpoint envelope calculation. The Surveillance Frequency is controlled under the Surveillance Frequency Control Program.
SR 3.3.1.4 A CHANNEL FUNCTIONAL TEST is performed to ensure that the entire channel will perform the intended function. Setpoints must be found within the Allowable Values specified in Table 3.3.1-1. Any setpoint adjustment shall be consistent with the assumptions of the current setpoint analysis.
The Surveillance Frequency is controlled under the Surveillance Frequency Control Program.
The automatic bypass removal feature is verified for the turbine oil pressure trip and the main feedwater pump oil pressure trip functions during the CHANNEL FUNCTIONAL TEST.
SR 3.3.1.5 A Note to the Surveillance indicates that neutron detectors are excluded from CHANNEL CALIBRATION. 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.
A CHANNEL CALIBRATION is a complete check of the instrument channel, including the sensor. The test verifies that the channel responds to the measured parameter within the necessary range and accuracy. CHANNEL CALIBRATION leaves the channel adjusted to account for instrument drift to ensure that the instrument channel remains operational between successive tests. CHANNEL CALIBRATION shall find that instrument errors are within the assumptions of the setpoint analysis. CHANNEL CALIBRATION must be performed consistent with the assumptions of the setpoint analysis. Whenever a sensing element is replaced, the next required CHANNEL CALIBRATION of the resistance temperature (RTD) sensors is accomplished by an inplace cross calibration that compares the other sensing elements with the recently installed sensing element. The Surveillance Frequency is controlled under the Surveillance Frequency Control Program.
Insert:
Alternately, the Frequency for checking the calibration of pressure, level, and flow transmitters may be determined in accordance with the Online Monitoring Program implemented in accordance with AMS-TR-0720R2-A (Ref. 7) and TS 5.5.19, Online Monitoring Program.
RPS Instrumentation B 3.3.1 ANO-1 B 3.3.1-20 Amendment No. 215 Rev. 67,81 REFERENCES
- 1.
SAR, Chapter 7.
- 2.
SAR, Chapter 14 and Chapter 3A.
- 3.
Instrument Loop Error Analysis and Setpoint Methodology Manual, Design Guide, IDG-001.
- 4.
NUREG-0737, "Clarification of TMI Action Plan Requirements," November 1980.
- 5.
- 6.
BAW-1893, "Basis for Raising Arming Threshold for Anticipatory Reactor Trip on Turbine Trip," October 1985.
- 7.
CALC-22-E-0001-11, "ANO-1 TS 3.4.4 LAR Support - RPS Pump-to-Power Monitor Setpoint."
Insert:
- 8. AMS-TR-0720R2-A, "Online Monitoring Technology to Extend Calibration Intervals of Nuclear Plant Pressure Transmitters."
ESAS Instrumentation B 3.3.5 ANO-1 B 3.3.5-10 Amendment No. 215 Rev. 50,67 SURVEILLANCE REQUIREMENTS The ESAS Parameters listed in Table 3.3.5-1 are subject to CHANNEL CHECK, CHANNEL FUNCTIONAL TEST, and CHANNEL CALIBRATION.
SR 3.3.5.1 Performance of the CHANNEL CHECK provides reasonable assurance for prompt identification of a gross failure of instrumentation. A CHANNEL CHECK is normally a comparison of the parameter indicated on one channel to a similar parameter on other channels. It is based on the assumption that instrument channels monitoring the same parameter should read approximately the same value. Significant deviations between the two instrument channels could be an indication of excessive instrument drift in one of the channels or of something even more serious. CHANNEL CHECK will detect gross channel failure; therefore, it is key in verifying that the instrumentation continues to operate properly between CHANNEL CALIBRATIONs.
Agreement criteria are determined by the unit staff, based on a combination of factors including channel instrument uncertainties. If a channel is outside the criteria, it may be an indication that the transmitter or the signal processing equipment has drifted outside its limit.
The Surveillance Frequency is controlled under the Surveillance Frequency Control Program.
The CHANNEL CHECK supplements less formal, but potentially more frequent, checks of channel OPERABILITY during normal operational use of the displays associated with the LCO's required channels.
SR 3.3.5.2 A CHANNEL FUNCTIONAL TEST is performed on each required ESAS analog instrument channel to ensure the entire channel will perform the intended functions. Any setpoint adjustment shall be consistent with the assumptions of the setpoint calculations.
The Surveillance Frequency is controlled under the Surveillance Frequency Control Program.
The RCS low pressure automatic bypass removal feature is verified during its CHANNEL FUNCTIONAL TEST.
SR 3.3.5.3 CHANNEL CALIBRATION is a complete check of the analog instrument channel, including the sensor. The test verifies that the channel responds to a measured parameter within the necessary range and accuracy. CHANNEL CALIBRATION leaves the channel adjusted to account for instrument drift to ensure that the analog instrument channel remains OPERABLE between successive tests. CHANNEL CALIBRATION shall find that measurement errors and bistable setpoint errors are within the assumptions of the setpoint calculations. CHANNEL CALIBRATIONS must be performed consistent with the assumptions of the setpoint calculations.
The Surveillance Frequency is controlled under the Surveillance Frequency Control Program.
Insert:
Alternately, the Frequency for checking the calibration of pressure, level, and flow transmitters may be determined in accordance with the Online Monitoring Program implemented in accordance with AMS-TR-0720R2-A (Ref. 6) and TS 5.5.19, Online Monitoring Program.
ESAS Instrumentation B 3.3.5 ANO-1 B 3.3.5-11 Amendment No. 215 Rev. 50,67 REFERENCES
- 1.
SAR, Chapter 7.
- 2.
SAR, Chapter 14 and Chapter 3A.
- 3.
- 4.
Instrument Loop Error Analysis and Setpoint Methodology Manual, Design Guide, IDG-001.
- 5.
BAW-2441-A, Revision 2, Risk Informed Justification for LCO End-State Changes, September 2006.
Insert:
- 6. AMS-TR-0720R2-A, "Online Monitoring Technology to Extend Calibration Intervals of Nuclear Plant Pressure Transmitters."
EFIC Instrumentation B 3.3.11 ANO-1 B 3.3.11-13 Amendment No. 215 Rev. 12,13,67,82 SURVEILLANCE REQUIREMENTS (continued)
SR 3.3.11.2 A CHANNEL FUNCTIONAL TEST verifies the function of the automatic bypass removal feature, required trip, interlock, and alarm functions of the channel. Setpoints for trip functions must be found within the Allowable Value. (Note that the values for the bypass removal functions are identified in the Applicable MODES or Other Specified Condition column of Table 3.3.11-1 as limits on applicability for the trip Functions.) Any setpoint adjustment shall be consistent with the assumptions of the current setpoint analysis.
The Surveillance Frequency is controlled under the Surveillance Frequency Control Program.
This SR is modified by two notes. For the SG Level - Low function, if the as-found trip setpoint is found to be non-conservative with respect to the Allowable Value specified in TSs, the channel is declared inoperable and the associated TS action statement must be followed. If the as-found trip setpoint is found to be conservative with respect to the Allowable Value and outside the as-found predefined acceptance criteria band of +/- 1.08 inches from the previous as-left value, but is determined to be functioning as required and can be reset to a value equal to the Limiting Trip Setpoint or a value more conservative than the Limiting Trip Setpoint, then the channel may be considered to be operable. If it cannot be determined that the instrument channel is functioning as required, the channel is declared inoperable and the associated TS actions must be followed. If the as-found trip setpoint is outside the as-found predefined acceptance criteria band, the condition must be entered into the corrective action program for further evaluation. The notes for the Channel Functional Test do not apply to the verification of the time delay.
SR 3.3.11.3 CHANNEL CALIBRATION is a complete check of the instrument channel including the sensor.
The test verifies the channel responds to a measured parameter within the necessary range and accuracy. CHANNEL CALIBRATION leaves the channels adjusted to account for instrument drift to ensure that the instrument channel remains operational between successive tests.
CHANNEL CALIBRATION shall find that measurement errors and bistable setpoint errors are within the assumptions of the setpoint analysis. CHANNEL CALIBRATIONS must be performed consistent with the assumptions of the setpoint analysis. The notes contained in SR 3.3.11.2 are also applicable to the CHANNEL CALIBRATION.
The Surveillance Frequency is controlled under the Surveillance Frequency Control Program.
Insert:
Alternately, the Frequency for checking the calibration of pressure, level, and flow transmitters may be determined in accordance with the Online Monitoring Program implemented in accordance with AMS-TR-0720R2-A (Ref. 8) and TS 5.5.19, Online Monitoring Program.
EFIC Instrumentation B 3.3.11 ANO-1 B 3.3.11-14 Amendment No. 215 Rev. 12,13,67,82 REFERENCES
- 1.
- 2.
SAR, Chapter 7.
- 3.
SAR, Chapter 14.
- 4.
Instrument Loop Error Analysis and Setpoint Methodology Manual, Design Guide, IDG-001.
- 5.
SAR, Chapter 10, Figure 10-2.
- 6.
IEEE-279-1971, April 1972.
- 7.
Insert:
- 8. AMS-TR-0720R2-A, "Online Monitoring Technology to Extend Calibration Intervals of Nuclear Plant Pressure Transmitters."
PAM Instrumentation B 3.3.15 ANO-1 B 3.3.15-11 Amendment No. 215 Rev. 22,63,67 SURVEILLANCE REQUIREMENTS (continued)
SR 3.3.15.1 (continued)
Agreement criteria are determined by the unit 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 sensor or the signal processing equipment has drifted outside its limit. If the channels are within the criteria, it is an indication that the channels are OPERABLE.
If the channels are normally off scale during times when surveillance is required, the CHANNEL CHECK will only verify that they are off scale in the same direction. Off-scale low current loop channels are, where practical, verified to be reading at the bottom of the range and not failed downscale.
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 this LCO's required channels.
SR 3.3.15.2 A CHANNEL CALIBRATION is a complete check of the instrument channel, including the sensor. This test verifies the channel responds to measured parameters within the necessary range and accuracy.
The SR is modified by a Note excluding neutron detectors from CHANNEL CALIBRATION. It is not necessary to test the detectors because generating a meaningful test signal is difficult, and there is no adjustment that can be made to the detectors. Furthermore, adjustment of the detectors is unnecessary because they are passive devices, with minimal drift. Finally, the detectors are of simple construction, and any failures in the detectors will be apparent as change in channel output.
For the Reactor Building Area Radiation instrumentation, a CHANNEL CALIBRATION may consist of an electronic calibration of the channel, not including the detector, for range decades above 10 R/hr, and a one point calibration check of the detector below 10 R/hr with a gamma source.
Whenever a sensing element is replaced, the next required CHANNEL CALIBRATION of the resistance temperature detector (RTD) sensors is accomplished by an in-place cross calibration that compares the other sensing elements with the recently installed sensing element.
Whenever a sensing element is replaced, the next required CHANNEL CALIBRATION of the CET sensors is accomplished by an in-place cross calibration that compares the other sensing elements with the recently installed sensing element.
The Surveillance Frequency is controlled under the Surveillance Frequency Control Program.
Insert:
Alternately, the Frequency for checking the calibration of pressure, level, and flow transmitters may be determined in accordance with the Online Monitoring Program implemented in accordance with AMS-TR-0720R2-A (Ref. 6) and TS 5.5.19, Online Monitoring Program.
PAM Instrumentation B 3.3.15 ANO-1 B 3.3.15-12 Amendment No. 215 Rev. 22,63 REFERENCES
- 1.
SAR, Table 7-11A.
- 2.
- 3.
NUREG-0737, 1979.
- 4.
SAR, Section 7.3.4.
- 5.
Insert:
- 6. AMS-TR-0720R2-A, "Online Monitoring Technology to Extend Calibration Intervals of Nuclear Plant Pressure Transmitters."
LTOP System B 3.4.11 ANO-1 B 3.4.11-7 Amendment No. 215 Rev. 51,52,67 SURVEILLANCE REQUIREMENTS (continued)
SR 3.4.11.4 (continued)
For the ERV to be considered OPERABLE, its block valve must be open, its lift setpoint must be set at d 508 psig, testing must have proven its ability to open at that setpoint, and motive power must be available to the two valves and their control circuits. The parameter value of 508 psig does not contain allowances for instrument uncertainty. Additional allowances for instrument uncertainty are contained in the implementing procedures.
With the RCS depressurized, acceptable alternate vent paths include: a) removing a pressurizer safety valve; b) locking the ERV in the open position and disabling its block valve in the open position; c) removing a SG primary manway; c) removing a SG primary hand hole cover; d) removing all control rod drive top closure assemblies (excluding reactor vessel level probe); and e) removing a pressurizer manway.
The Surveillance Frequency is controlled under the Surveillance Frequency Control Program.
SR 3.4.11.5 The CHANNEL CALIBRATION for the LTOP ERV opening logic, including the ERV setpoint, ensures that the ERV will be actuated at the appropriate RCS pressure by verifying the accuracy of the instrument string. The calibration can only be performed in shutdown. The Surveillance Frequency is controlled under the Surveillance Frequency Control Program.
REFERENCES
- 1.
10 CFR 50, Appendix G, Fracture Toughness Requirements.
- 2.
Generic Letter 88-11, Pressurizer Surge Line Thermal Stratification.
- 3.
ANO-1 LTOP Safety Evaluation Report (1CNA058302) dated May 5, 1983.
- 4.
Response to NRC Request for Additional Information (1CAN117608) dated November 15, 1976.
- 5.
Response to NRC Request for Additional Information (1CAN127602) dated December 3, 1976.
- 6.
Response to NRC Request for Additional Information (1CAN037716) dated March 24, 1977.
- 7.
Exemption from Certain Requirements of 10 CFR 50, Appendix G, and 10 CFR 50.61 for initial NIL Ductility Reference Temperature for Linde 80 Welds (1CNA031503) dated March 26, 2015.
- 8.
Deleted.
- 9.
10 CFR 50.36, Technical Specifications.
- 10. ANO-1 License Amendment Request (1CAN059008), dated May 22, 1990, and Operating License Amendment 138, (1CNA119002) dated November 1, 1990.
Insert:
Alternately, the Frequency for checking the calibration of pressure, level, and flow transmitters may be determined in accordance with the Online Monitoring Program implemented in accordance with AMS-TR-0720R2-A (Ref. 12) and TS 5.5.19, Online Monitoring Program.
Insert:
- 12. AMS-TR-0720R2-A, "Online Monitoring Technology to Extend Calibration Intervals of Nuclear Plant Pressure Transmitters."
RCS Leakage Detection Instrumentation B 3.4.15 ANO-1 B 3.4.15-5 Amendment No. 215 Rev. 22,24,44,50,67 ACTIONS (continued)
D.1 and D.2 (continued)
Required Action D.2 is modified by a second Note. Note 2 states that LCO 3.0.4.a is not applicable when entering MODE 4. This Note prohibits the use of LCO 3.0.4.a to enter MODE 4 during startup with the LCO not met. However, there is no restriction on the use of LCO 3.0.4.b, if applicable, because LCO 3.0.4.b requires performance of a risk assessment addressing inoperable systems and components, consideration of the results, determination of the acceptability of entering MODE 4, and establishment of risk management actions, if appropriate.
LCO 3.0.4 is not applicable to, and the Note does not preclude, changes in MODES or other specified conditions in the Applicability that are required to comply with ACTIONS or that are part of a shutdown of the unit.
E.1 With both required monitors inoperable, no indicated means of monitoring leakage are available, and immediate plant shutdown in accordance with LCO 3.0.3 is required.
SURVEILLANCE REQUIREMENTS SR 3.4.15.1 SR 3.4.15.1 requires the performance of a CHANNEL CHECK of the required reactor building atmosphere radioactivity monitor. The check gives reasonable confidence that each channel is operating properly. The Surveillance Frequency is controlled under the Surveillance Frequency Control Program.
SR 3.4.15.2 SR 3.4.15.2 requires the performance of a CHANNEL FUNCTIONAL TEST of the required reactor building atmosphere radioactivity monitor. The test ensures that the monitor can perform its function in the desired manner. The test verifies the alarm function and relative accuracy of the instrument string. The Surveillance Frequency is controlled under the Surveillance Frequency Control Program.
SR 3.4.15.3 and SR 3.4.15.4 These SRs require the performance of a CHANNEL CALIBRATION for each of the required RCS leakage detection instrumentation channels. The calibration verifies the accuracy of the instrument string, including the instruments located inside the reactor building. The Surveillance Frequencies are controlled under the Surveillance Frequency Control Program.
Insert:
Alternately, the Frequency for checking the calibration of pressure, level, and flow transmitters may be determined in accordance with the Online Monitoring Program implemented in accordance with AMS-TR-0720R2-A (Ref. 6) and TS 5.5.19, Online Monitoring Program.
RCS Leakage Detection Instrumentation B 3.4.15 ANO-1 B 3.4.15-6 Amendment No. 215 Rev. 22,24,44,50 REFERENCES
- 1.
- 2.
Regulatory Guide 1.45, Revision 0, Reactor Coolant Pressure Boundary Leakage Detection Systems, May 1973.
- 3.
SAR, Section 4.2.3.8.
- 4.
- 5.
BAW-2441-A, Revision 2, Risk Informed Justification for LCO End-State Changes, September 2006.
Insert:
- 6. AMS-TR-0720R2-A, "Online Monitoring Technology to Extend Calibration Intervals of Nuclear Plant Pressure Transmitters."
Enclosure, Attachment 12 CNRO2024-00002 Technical Specification Bases Mark-ups - ANO-2 (Information only)
(6 TS Bases Pages Follow)
ARKANSAS - UNIT 2 B 3/4 3-1 Amendment No. 33,79,186,189 Issued By NRC Letter Dated June 18, 1998 Rev. 40,44,73,77 3/4.3 INSTRUMENTATION BASES 3/4.3.1 and 3/4.3.2 PROTECTIVE AND ENGINEERED SAFETY FEATURES (ESF)
INSTRUMENTATION The OPERABILITY of the protective and ESF instrumentation systems and bypasses ensure that 1) the associated ESF action and/or reactor trip will be initiated when the parameter monitored by each channel or combination thereof reaches its setpoint, 2) the specified coincidence logic is maintained, 3) sufficient redundancy is maintained to permit a channel to be out of service for testing or maintenance, and 4) sufficient system functional capability is available for protective and ESF purposes from diverse parameters.
The OPERABILITY of these systems is required to provide the overall reliability, redundancy and diversity assumed available in the facility design for the protection and mitigation of accident and transient conditions. The integrated operation of each of these systems is consistent with the assumptions used in the accident analyses.
The surveillance requirements specified for these systems ensure that the overall system functional capability is maintained comparable to the original design standards. The periodic surveillance tests performed at the minimum frequencies are sufficient to demonstrate this capability. The CHANNEL FUNCTIONAL TEST frequency in controlled under the Surveillance Frequency Control Program.
The RPS Matrix Logic channels and the Initiation Logic channels are listed as separate functional units in Table 3.3-1 and are grouped together in the corresponding surveillance Table 4.3-1 as a single functional unit listed as Reactor Protection System (RPS) Logic. The RPS Logic contains six Matrix Logic channels and four Initiation Logic channels. The associated CHANNEL FUNCTIONAL TEST requirements are performed during the individual channel PPS test. The six RPS Matrix Logic channels are divided up for testing purposes as follows: Matrix AB is tested with Channel A, Matrices BC and BD are tested with Channel B, Matrices AC and CD are tested with Channel C, and Matrix AD is tested with Channel D.
Table 4.3-1 requires verification (in accordance with the Surveillance Frequency Control Program) that CPC indicated flow rate is less than or equal to the RCS total flow rate measured using either reactor coolant pump differential pressure instrumentation or calorimetric calculations (see Note 7). This calibration requirement ensures that the CPC calculation of DNBR uses a conservative value of RCS total flow rate. The calibration check is typically performed by comparing CPC and reactor coolant pump differential pressure based COLSS relative mass flows (in terms of the fraction of design flow rate). When COLSS is out of service, the calibration of CPC flow is performed by comparing to a manual calculation of the flow rate using calorimetric or pump differential pressure based (COLSS) methods. Appropriate flow measurement uncertainties for either method of determining the actual flow rate are included in the determination of CPC DNBR uncertainty addressable constant BERR1 (using methodology described in CEN-356(V)-P-A). The flow measurement uncertainty accounts for process and instrumentation uncertainties as well as uncertainties associated with calibration of the COLSS flow measurement algorithm based on pump casing curves, validated calorimetric flow measurements and detailed simulations of RCS flow.
Insert:
Alternately, the Frequency for checking the calibration of pressure, level, and flow transmitters may be determined in accordance with the Online Monitoring Program implemented in accordance with AMS-TR-0720R2-A and TS 6.5.20, Online Monitoring Program.
ARKANSAS - UNIT 2 B 3/4 3-1a Amendment No. 159,195,239 Issued by NRC Letter Dated June 18, 1998 Rev. 24,40,44,73,80 3/4.3 INSTRUMENTATION BASES Table 4.3-2 requires the Automatic Actuation Logic channels for each of the associated ESFAS functional units to have a CHANNEL FUNCTIONAL TEST performed in accordance with the Surveillance Frequency Control Program. These testing requirements also apply to the six ESFAS Matrix Logic channels and the four ESFAS Initiation Logic channels. The ESFAS Matrix Logic channels are divided up for testing purposes like the RPS Matrix Logic channels.
The measurement of response time at the specified frequencies provides assurance that the protective and ESF action function associated with each channel is completed within the time limit assumed in the accident analyses.
No credit was taken in the analyses for those channels with response times indicated as not applicable.
Response time may be demonstrated by any series of sequential, overlapping or total channel test measurements, provided that such tests demonstrate the total channel response time as defined. Sensor response time verification may be demonstrated by 1) in place, onsite or offsite test measurements or 2) utilizing replacement sensors with certified response times or
- 3) utilizing allocated response time for selected sensors. Topical Report CE NPSD-1167-A, 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 Topical Report. The response time may be verified for components that replace the components that were previously evaluated in CE NPSD-1167-A provided that the components have been evaluated in accordance with the NRC approved methodology as discussed in Attachment 1 to TSTF-569, "Methodology to Eliminate Pressure Sensor and Protection Channel (for Westinghouse Plants only) Response Time Testing." Response time verification for sensor types must be demonstrated by test. The allocation of sensor response times must be verified prior to placing a new component in operation and re-verified after maintenance that may adversely affect the sensor response time.
Plant Protective System (PPS) logic is designed for operation as a 2-out-of-3 logic, although normally it is operated in a 2-out-of-4 mode.
The RPS Logic consists of everything downstream of the bistable relays and upstream of the Reactor Trip Circuit Breakers. The RPS Logic is divided into two parts, Matrix Logic, and Initiation Logic. Failures of individual bistables and their relays are considered measurement channel failures.
The ESFAS Logic consists of everything downstream of the bistable relays and upstream of the subgroup relays. The ESFAS Logic is divided into three parts, Matrix Logic, Initiation Logic, and Actuation Logic. Failures of individual bistables and their relays are considered measurement channel failures.
Matrix Logic refers to the matrix power supplies, trip channel bypass contacts, and interconnecting matrix wiring between bistable relay cards, up to, but not including the matrix relays. Matrix contacts on the bistable relay cards are excluded from the Matrix Logic definition since they are addressed as part of the measurement channel.
Insert:
Alternately, the use of the allocated sensor RESPONSE TIME for transmitters in the Online Monitoring Program is supported using the 'noise analysis' technique implemented in accordance with AMS-TR-0720R2-A to detect dynamic failures modes that can affect transmitter response time.
ARKANSAS - UNIT 2 B 3/4 3-5 Amendment No. 22,29,60,123,132,191 Rev. 8,17,40,56,60,70,79,88 INSTRUMENTATION BASES 3/4.3.3.5 REMOTE SHUTDOWN INSTRUMENTATION (continued)
The following CHANNEL CHECKS and CHANNEL CALIBRATIONS are applicable to each required RSD instrument:
INSTRUMENT CHANNEL CHECK CHANNEL CALIBRATION
- 1.
Logarithmic Neutron Channel SFCP N.A.
- 2.
Startup Channel SFCP N.A.
- 3.
Reactor Trip Breaker Indication SFCP N.A.
- 4.
Reactor Coolant Cold Leg Temperature SFCP SFCP
- 5.
Pressurizer Pressure SFCP SFCP
- 6.
Pressurizer Level SFCP SFCP
- 7.
Steam Generator Pressure SFCP SFCP
- 8.
Steam Generator Level SFCP SFCP
- 9.
Shutdown Cooling Flow Rate SFCP SFCP
- 10.
Condensate Storage Tank Level SFCP SFCP 3/4.3.3.6 POST-ACCIDENT INSTRUMENTATION BACKGROUND The primary purpose of the Post Accident Monitoring (PAM) instrumentation is to display plant variables that provide information required by the Control Room Operators during accident situations. This information provides the necessary support for the Operator to take the manual actions, for which no automatic control is provided, that are required for safety systems to accomplish their safety functions for Design Basis Events. The OPERABILITY of the PAM instrumentation ensures that sufficient information is available on selected plant parameters to monitor and assess plant status and behavior following an accident. The availability of PAM instrumentation is important so that responses to corrective actions can be observed and the need for, and magnitude of, further actions can be determined. This capability is consistent with the recommendations of Regulatory Guide (RG) 1.97, "Instrumentation for Light-Water-Cooled Nuclear Plants to Assess Plant Conditions During and Following an Accident," December 1975 as required by Supplement 1 to NUREG-0737, "TMI Action Items," and NUREG-0578, "TMI-2 Lessons Learned Task Force Status Report and Short Term Recommendations."
Type A variables are included in this LCO because they provide the primary information required to permit the Control Room Operator to take specific manually controlled actions, for which no automatic control is provided, that are required for safety systems to accomplish their safety functions for Design Basis Accidents (DBAs).
Insert:
Alternately, the Frequency for checking the calibration of pressure, level, and flow transmitters may be determined in accordance with the Online Monitoring Program implemented in accordance with AMS-TR-0720R2-A and TS 6.5.20, Online Monitoring Program.
ARKANSAS - UNIT 2 B 3/4 3-14 Rev. 70,79 INSTRUMENTATION BASES 3/4.3.3.6 POST-ACCIDENT INSTRUMENTATION (continued)
ACTIONS (continued)
ACTION 3 When at least one inoperable RVLMS channel cannot be restored because repairs are not feasible, actions in accordance with Specification 6.6.4 must be initiated immediately, which requires a written report to be submitted to the NRC. With respect to this specification, an example of when repair is not feasible is a condition that would require access to the reactor vessel to effect repairs. An example that does not meet the intent of this ACTION is a failure in the associated Control Room cabinet which cannot be restored due to the unavailability of parts.
The required report discusses the results of the root cause evaluation of the inoperability and identifies proposed restorative actions. This ACTION is appropriate in lieu of a shutdown requirement, given the likelihood of plant conditions that would require information provided by this instrumentation. Also, alternative actions are identified before a loss of functional capability condition occurs.
SURVEILLANCE REQUIREMENTS Performance of the CHANNEL CHECK ensures that a gross failure of instrumentation has not occurred. A CHANNEL CHECK is normally a comparison of the parameter indicated on one channel to a similar parameter on other channels. It is based on the assumption that instrument channels monitoring the same parameter should read approximately the same value.
Significant deviations between the two instrument channels could be an indication of excessive instrument drift in one of the channels or of something even more serious. A CHANNEL CHECK will detect gross channel failure; thus, it is key to verifying the instrumentation continues to operate properly between each CHANNEL CALIBRATION.
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 sensor or the signal processing equipment has drifted outside its limit. If the channels are within the criteria, it is an indication that the channels are OPERABLE.
If the channels are normally off scale during times when surveillance is required, the CHANNEL CHECK will only verify that they are off scale in the same direction. Off scale low current loop channels are verified to be reading at the bottom of the range and not failed downscale.
The Frequency of 31 days is based upon plant operating experience with regard to channel OPERABILITY and drift, which demonstrates that failure of more than one channel of a given Function in any 31-day interval is a rare event. The CHANNEL CHECK supplements less formal, but more frequent, checks of channel during normal operational use of the displays associated with this LCO's required channels.
A CHANNEL CALIBRATION is a complete check of the instrument channel including the sensor. The Surveillance verifies the channel responds to the measured parameter within the necessary range and accuracy. A Note allows exclusion of the neutron detectors from the CHANNEL CALIBRATION.
Insert:
Alternately, the Frequency for checking the calibration of pressure, level, and flow transmitters may be determined in accordance with the Online Monitoring Program implemented in accordance with AMS-TR-0720R2-A (Ref. 11) and TS 6.5.20, Online Monitoring Program.
ARKANSAS - UNIT 2 B 3/4 3-15 Rev. 70,79,87 INSTRUMENTATION BASES 3/4.3.3.6 POST-ACCIDENT INSTRUMENTATION (continued)
SURVEILLANCE REQUIREMENTS (continued)
Whenever a sensing element is replaced, the next required CHANNEL CALIBRATION of the THOT resistance temperature detectors (RTD) sensors and the CET sensors is accomplished by an in-place cross calibration that compares the other sensing elements with the recently installed sensing element.
The Frequency is controlled by the Surveillance Frequency Control Program (SFCP) and is based upon operating experience and determination of the magnitude of equipment drift.
REFERENCES
- 1.
Systems Training Manual (STM) 2-03, Reactor Coolant System
- 2.
STM 2-08, Containment Spray System
- 3.
STM 2-13, Containment Building
- 4.
STM 2-15, Steam Generators and Main Steam System
- 5.
STM 2-19, Emergency Feedwater & Auxiliary Feedwater Systems
- 6.
STM 2-67, Excore Nuclear Instrumentation
- 7.
STM 2-75, Reactor Vessel Level Monitoring System
- 8.
OP-1903.010, Emergency Action Level Classification
- 9.
OP-2105.014, Safety Parameter Display System Operation
- 10.
ANO-2 SAR Table 7.5-3, R.G. 1.97 Post Accident Monitoring Variables Insert:
- 11. AMS-TR-0720R2-A, "Online Monitoring Technology to Extend Calibration Intervals of Nuclear Plant Pressure Transmitters."
ARKANSAS - UNIT 2 B 3/4 4-8 Amendment No. 184,231 Rev. 19,56,63 REACTOR COOLANT SYSTEM BASES 3/4.4.6 REACTOR COOLANT SYSTEM LEAKAGE 3/4.4.6.1 LEAKAGE DETECTION SYSTEMS GDC 30 of Appendix A to 10 CFR 50 requires means for detecting and, to the extent practical, identifying the location of the source of RCS LEAKAGE. The RCS leakage detection systems required by this specification are provided to monitor and detect leakage from the Reactor Coolant Pressure Boundary. These detection systems are consistent with the recommendations of Regulatory Guide (RG) 1.45, "Reactor Coolant Pressure Boundary Leakage Detection Systems" May 1973. Likewise, the actions implemented upon inoperability of a required leak detection instrument are sufficient in maintaining the diversity and accuracy needed to effectively detect RCS leaks.
Industry practice has shown that water flow changes of 0.5 gpm to 1.0 gpm can readily be detected in contained volumes by monitoring changes in water level, in flow rate, or in the operating frequency of a pump. In addition, the reactor coolant contains radioactivity that, when released to the containment, can be detected by radiation monitoring instrumentation.
Instrument sensitivities of 10 - 106 cpm for particulate and gaseous monitoring are practical for these leakage detection systems.
12 hours1.388889e-4 days <br />0.00333 hours <br />1.984127e-5 weeks <br />4.566e-6 months <br /> is provided by a footnote to allow for plant stabilization before performance of the required reactor coolant inventory balance. This provision is necessary to ensure an accurate measurement is obtained.
The Containment Atmosphere Monitoring System (CAMS) has been modified to permit adjustments in containment pressure and oxygen level. The modification does not interfere with the leak detection capability of the CAMS and is isolated automatically, along with the CAMS, upon receipt of a Containment Isolation Signal. The modification involves insignificant flow rates and is monitored through building exhaust paths; therefore, the modification does not constitute a PURGE.
The specification requires a CAMS unit to be OPERABLE, but not necessarily in operation. In this respect, it is not necessary to enter the Actions of this specification when swapping CAMS units. RG 1.45 recommendations are based on the ability of applicable systems to detect a 1 gpm increase in leakrate within 1 hour1.157407e-5 days <br />2.777778e-4 hours <br />1.653439e-6 weeks <br />3.805e-7 months <br />. Based on historical information, a CAMS unit generally requires 15-30 minutes to stabilize once placed in service. Because the actual stabilization time can vary based on actual leakage, the present RCS activity, and containment parameters, a 15-minute margin is added to the stabilization time resulting in an assumed 45-minute period to ensure the CAMS unit is capable of required detection. Therefore, to support swapping units to respond to inadvertent loss of the running CAMS unit or to perform minor maintenance activities, both CAMS units may be secured for up to 15 minutes without applying the actions of this specification. This ensures a CAMS unit can be started, reach stabilization, and otherwise be capable of detecting a 1 gpm change in leakrate within the time period assumed in the license basis.
Only the normal or emergency power source is required for OPERABILITY of the CAMS.
Because the CAMS is not required to mitigate an accident, single failure criteria is not applicable. In addition, the allowed outage time of an inoperable normal or emergency power source is much less (no more than 14 days) than that allowed by this specification when no CAMS is OPERABLE (30 days). Therefore, the CAMS may be considered OPERABLE provided at least its associated normal or emergency power source is OPERABLE.
Insert:
The Frequency for checking the calibration of pressure, level, and flow transmitters may be determined in accordance with the Online Monitoring Program implemented in accordance with AMS-TR-0720R2-A and TS 6.5.20, Online Monitoring Program.
Enclosure, Attachment 13 CNRO2024-00002 Technical Specification Bases Mark-ups - GGNS (Information only)
(27 TS Bases Pages Follow)
RPS Instrumentation B 3.3.1.1 BASES GRAND GULF B 3.3-7 LBDCR 10027 APPLICABLE Allowable Values for RPS instrumentation functions are specified for
- SAFETY, each RPS function specified in Table 3.3.1.1-1. Trip setpoints and the ANALYSES, methodologies for calculating the as-left and as-found tolerances are LCO, and described in the Technical Requirements Manual. The nominal setpoints APPLICABILITY are selected to ensure the actual setpoints remain conservative with (continued) respect to the as-found tolerance between successive CHANNEL CALIBRATIONS. After each calibration, the trip setpoint shall be left within the as-left band around the setpoint.
1.a. Intermediate Range Monitor (IRM) Neutron Flux - High The IRMs monitor neutron flux levels from the upper range of the source range monitors (SRMs) to the lower range of the average power range monitors (APRMs). The IRMs are capable of generating trip signals that can be used to prevent fuel damage resulting from abnormal operating transients in the intermediate power range. In this power range, the most significant source of reactivity change is due to control rod withdrawal.
The IRM provides diverse protection for the rod pattern controller (RPC),
which monitors and controls the movement of control rods at low power.
The RPC prevents the withdrawal of an out of sequence control rod during startup that could result in an unacceptable neutron flux excursion (Ref. 5). The IRM provides mitigation of the neutron flux excursion. To demonstrate the capability of the IRM System to mitigate control rod withdrawal events, generic analyses have been performed (Ref. 6) to evaluate the consequences of control rod withdrawal events during startup that are mitigated only by the IRM. This analysis, which assumes that one IRM channel in each trip system is bypassed, demonstrates that the IRMs provide protection against local control rod withdrawal errors and results in peak fuel energy depositions below the 170 cal/gm fuel failure threshold criterion.
The IRMs are also capable of limiting other reactivity excursions during startup, such as cold water injection events, although no credit is specifically assumed.
(continued)
Insert:
Alternately, the Frequency for checking the calibration of pressure, level, and flow transmitters may be determined in accordance with the Online Monitoring Program implemented in accordance with AMS-TR-0720R2-A (Ref. 18) and TS 5.5.15, Online Monitoring Program.
RPS Instrumentation B 3.3.1.1 BASES GRAND GULF B 3.3-36 LBDCR 18114 SURVEILLANCE SR 3.3.1.1.10, SR 3.3.1.1.12 and SR 3.3.1.1.17 REQUIREMENTS A CHANNEL CALIBRATION is a complete check of the instrument loop and the sensor. This test verifies the channel responds to the measured parameter within the necessary range and accuracy. CHANNEL CALIBRATION leaves the channel adjusted to account for instrument drifts between successive calibrations consistent with the plant specific setpoint methodology.
Note 1 states that neutron detectors are excluded from CHANNEL CALIBRATION because of the difficulty of simulating a meaningful signal.
Changes in neutron detector sensitivity are compensated for by performing the calorimetric calibration (SR 3.3.1.1.2) and the LPRM calibration against the TIPs (SR 3.3.1.1.7). A second Note is provided that requires the APRM and IRM SRs to be performed within 12 hours1.388889e-4 days <br />0.00333 hours <br />1.984127e-5 weeks <br />4.566e-6 months <br /> of entering MODE 2 from MODE 1. Testing of the MODE 2 APRM and IRM Functions cannot be performed in MODE 1 without utilizing jumpers, lifted leads or movable links. This Note allows entry into MODE 2 from MODE 1 if the associated Frequency is not met per SR 3.0.2. Twelve hours is based on operating experience and in consideration of providing a reasonable time in which to complete the SR.
Note 3 to SR 3.3.1.1.10 states that the APRM recirculation flow transmitters are excluded from CHANNEL CALIBRATION of Function 2.d, Average Power Range Monitor Flow Biased Simulated Thermal Power -
High.
SR 3.3.1.1.10 and SR 3.3.1.1.12 for the designated function is modified by two notes identified in Table 3.3.1.1-1. The first note requires evaluation of channel performance for the condition where the as-found setting for the channel setpoint is outside its as-found tolerance but conservative with respect to the Allowable Value. Evaluating channel performance will verify that the channel will continue to behave in accordance with safety analysis assumptions and the channel performance assumptions in the setpoint methodology. The purpose of the assessment is to ensure confidence in channel performance prior to returning the channel to service. Performance of these channels will be evaluated under the Corrective Action Program. Entry into the Corrective Action Program ensures required review and documentation of the condition to establish a reasonable expectation for continued OPERABILITY.
(continued)
Insert:
Alternately, the Frequency for checking the calibration of pressure, level, and flow transmitters may be determined in accordance with the Online Monitoring Program implemented in accordance with AMS-TR-0720R2-A (Ref. 18) and TS 5.5.15, Online Monitoring Program.
RPS Instrumentation B 3.3.1.1 BASES GRAND GULF B 3.3-39 LDC 97078 SURVEILLANCE SR 3.3.1.1.15 REQUIREMENTS (continued)
This SR ensures that the individual channel response times are less than or equal to the maximum values assumed in the accident analysis. The RPS RESPONSE TIME acceptance criteria are included in the applicable plant procedures.
As noted, neutron detectors are excluded from RPS RESPONSE TIME testing because the principles of detector operation virtually ensure an instantaneous response time. Note 2 allows the channel sensors of Functions 3, 4, and 5 to be excluded from specific RPS RESPONSE TIME testing. This allowance to not perform specific response time testing of the sensors is applicable when the alternate testing requirements and restrictions of Reference 10 are performed. As stated in Reference 10, analysis has demonstrated that other Technical Specification testing requirements (CHANNEL CALIBRATIONS, CHANNEL CHECKS, CHANNEL FUNCTIONAL TESTS, and LOGIC SYSTEM FUNCTIONAL TESTS) and actions taken in response to NRC Bulletin 90-01 Supplement 1 are sufficient to identify failure modes or degradation in instrument response times and assure operation of the analyzed instrument loops within acceptable limits.
Reference 10 also identifies that there are no known channel sensor failure modes identified that can be detected by response time testing that cannot also be detected by other Technical Specification required surveillances. Therefore, when the requirements, including sensor types, of Reference 10 are complied with, adequate assurance of the response time of the sensors is provided. This assurance of the response time of the sensors when combined with the response time testing of the remainder of the channel ensures that the individual channel response times are less than or equal to the maximum values assumed in the accident analysis. The calibration shall be performed such that fast ramp or step change to system components during calibrations is performed to verify that the response of the transmitter to the input change is prompt.
Technicians shall monitor for response time degradation during the performance of calibrations. Technicians shall be appropriately trained to ensure they are aware of the consequences of instrument response time degradation. These items are commitments made per Reference 11. If the alternate testing requirements of Reference 10 are not complied with, then the entire channel will be response time tested including the sensors.
(continued)
Insert:
Alternately, the use of the allocated RPS RESPONSE TIME for transmitters in the Online Monitoring Program is supported using the 'noise analysis' technique implemented in accordance with AMSTR-0720R2-A (Ref. 18) to detect dynamic failures modes that can affect transmitter response time.
RPS Instrumentation B 3.3.1.1 BASES (continued)
GRAND GULF B 3.3-42 LBDCR 16070 REFERENCES
- 1.
UFSAR, Figure 7.2-1.
- 2.
UFSAR, Section 5.2.2.
- 3.
UFSAR, Section 6.3.3.
- 4.
UFSAR, Chapter 15.
- 5.
UFSAR, Section 15.4.1.
- 6.
NEDO-23842, "Continuous Control Rod Withdrawal in the Startup Range," April 18, 1978.
- 7.
UFSAR, Section 15.4.9.
- 8.
Letter, P. Check (NRC) to G. Lainas (NRC), BWR Scram Discharge System Safety Evaluation, December 1, 1980, as attached to NRC Generic Letter dated December 9, 1980.
- 9.
NEDO-30851-P-A, Technical Specification Improvement Analyses for BWR Reactor Protection System, March 1988.
- 10.
NEDO-32291-A, System Analyses for Elimination of Selected Response Time Testing Requirements, October 1995.
- 11.
GNRI-97/00181, Amendment 133 to the Operating License.
- 12.
NEDC-33075P, General Electric Boiling Water Reactor Detect and Suppress Solution - Confirmation Density, Revision 7.
- 13.
NRC letter to Entergy Operations, Inc., Grand Gulf Nuclear Station, Unit 1 - Issuance of Amendment Re: Power Range Neutron Monitoring System Replacement (TAC No. ME2531),
March 28, 2012 (TS Amendment 188)
- 14.
Deleted
- 15.
NEDC-32410-P-A, Nuclear Measurement Analysis and Control -
Power Range Neutron Monitor (NUMAC PRNM) Retrofit Plus Option III Stability trip Function, Vols 1 and 2, and Supplement 1
- 16.
Deleted
- 17.
TSTF-493, Clarify Application of Setpoint Methodology for LSSS Functions Insert:
- 18. AMS-TR-0720R2-A, "Online Monitoring Technology to Extend Calibration Intervals of Nuclear Plant Pressure Transmitters."
PAM Instrumentation B 3.3.3.1 BASES GRAND GULF B 3.3-70 LBDCR 18127 SURVEILLANCE SR 3.3.3.1.1 (continued)
REQUIREMENTS Agreement criteria are determined by the plant staff based on a combination of the channel instrument uncertainties, including isolation, indication, and readability. If a channel is outside the criteria, it may be an indication that the sensor or the signal processing equipment has drifted outside its limit.
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 those displays associated with the required channels of this LCO.
SR 3.3.3.1.2 Deleted SR 3.3.3.1.3 CHANNEL CALIBRATION is a complete check of the instrument loop including the sensor. The test verifies that the channel responds to the measured parameter with the necessary range and accuracy. The Surveillance Frequency is controlled under the Surveillance Frequency Control Program.
For Functions 12 and 13 the CHANNEL CALIBRATION consists of an electronic calibration of the channel, not including the detector, for range decades above 10R/hr and a one point calibration check of the detector below 10R/hr with an installed or portable gamma source. The neutron detectors are excluded from the CHANNEL CALIBRATION because they cannot readily be adjusted. The detectors are fission chambers that are designed to have a relatively constant sensitivity over the range, and with an accuracy specified for a fixed useful life.
(continued)
Insert:
Alternately, the Frequency for checking the calibration of pressure, level, and flow transmitters may be determined in accordance with the Online Monitoring Program implemented in accordance with AMS-TR-0720R2-A (Ref. 5) and TS 5.5.15, Online Monitoring Program.
PAM Instrumentation B 3.3.3.1 BASES GRAND GULF B 3.3-71 LDC 03102 REFERENCES
- 1.
Regulatory Guide 1.97, "Instrumentation for Light-Water Cooled Nuclear Power Plants to Assess Plant and Environs Conditions During and Following an Accident," Revision 2, December 1980.
- 2.
NRC Safety Evaluation Report, "Conformance to regulatory Guide 1.97, Revision 2, Grand Gulf Nuclear Station, Unit 1," dated January 12, 1987.
- 3.
GNRO-93/00032, Grand Gulf Nuclear Station (GGNS) Plant Specific Design Evaluation for NEDO-31558, dated March 15, 1993.
- 4.
UFSAR, Section 7.5.
Insert:
- 5. AMS-TR-0720R2-A, "Online Monitoring Technology to Extend Calibration Intervals of Nuclear Plant Pressure Transmitters."
Remote Shutdown System B 3.3.3.2 BASES GRAND GULF B 3.3-76 LBDCR 18127 SURVEILLANCE SR 3.3.3.2.2 REQUIREMENTS SR 3.3.3.2.2 verifies each required Remote Shutdown System transfer switch and control circuit performs the intended function. This verification is performed from the remote shutdown panel and locally, as appropriate.
Operation of the equipment from the remote shutdown panel is not necessary. The Surveillance can be satisfied by performance of a continuity check. This will ensure that if the control room becomes inaccessible, the plant can be placed and maintained in MODE 3 from the remote shutdown panel and the local control stations. However, this Surveillance is not required to be performed only during a plant outage.
The Surveillance Frequency is controlled under the Surveillance Frequency Control Program.
SR 3.3.3.2.3 CHANNEL CALIBRATION is a complete check of the instrument loop and the sensor. The test verifies the channel responds to measured parameter values with the necessary range and accuracy.
The Surveillance Frequency is controlled under the Surveillance Frequency Control Program.
REFERENCES
- 1.
10 CFR 50, Appendix A, GDC 19.
Insert:
Alternately, the Frequency for checking the calibration of pressure, level, and flow transmitters may be determined in accordance with the Online Monitoring Program implemented in accordance with AMS-TR-0720R2-A (Ref. 2) and TS 5.5.15, Online Monitoring Program.
Insert:
- 2. AMS-TR-0720R2-A, "Online Monitoring Technology to Extend Calibration Intervals of Nuclear Plant Pressure Transmitters."
EOC-RPT Instrumentation B 3.3.4.1 BASES GRAND GULF B 3.3-87 LBDCR 18114 SR 3.3.4.1.2 (continued)
If the as-left channel setting cannot be returned to a setting within the as left tolerance of the NTSP, then the channel shall be declared inoperable.
The second Note also requires that NTSP and the methodologies for calculating the as-left and the as-found tolerances be in the Technical Requirements Manual.
The Surveillance Frequency is controlled under the Surveillance Frequency Control Program.
SR 3.3.4.1.3 CHANNEL CALIBRATION is a complete check of the instrument loop and the sensor. This test verifies the channel responds to the measured parameter within the necessary range and accuracy. CHANNEL CALIBRATION leaves the channel adjusted to account for instrument drifts between successive calibrations consistent with the plant specific setpoint methodology.
SR 3.3.4.1.3 is modified by two Notes in the SR table. The first Note requires evaluation of channel performance for the condition where the as-found setting for the channel setpoint is outside its as-found tolerance but conservative with respect to the Allowable Value. Evaluation of channel performance will verify that the channel will continue to behave in accordance with safety analysis assumptions and the channel performance assumptions in the setpoint methodology. The purpose of the assessment is to ensure confidence in the channel performance prior to returning the channel to service. For channels determined to be OPERABLE but degraded, after returning the channel to service the performance of these channels will be evaluated under the plant Corrective Action Program. Entry into the Corrective Action Program will ensure required review and documentation of the condition. The second Note requires that the as-left setting for the channel be within the as-left tolerance of the NTSP. Where a setpoint more conservative than the NTSP is used in the plant surveillance procedures, the as-left and as-found tolerances, as applicable, will be applied to the surveillance procedure setpoint. This will ensure that sufficient margin to the Safety Limit and/or Analytical Limit is maintained. If the as-left channel setting cannot be returned to a setting within the as left tolerance of the NTSP, then the channel shall be declared inoperable. The second Note also requires that NTSP and the methodologies for calculating the as-left and the as-found tolerances be in the Technical Requirements Manual.
The Surveillance Frequency is controlled under the Surveillance Frequency Control Program.
(continued)
Insert:
Alternately, the Frequency for checking the calibration of pressure, level, and flow transmitters may be determined in accordance with the Online Monitoring Program implemented in accordance with AMS-TR-0720R2-A (Ref. 6) and TS 5.5.15, Online Monitoring Program.
EOC-RPT Instrumentation B 3.3.4.1 BASES GRAND GULF B 3.3-89 LBDCR 18127 SURVEILLANCE SR 3.3.4.1.6 REQUIREMENTS (continued)
This SR ensures that the individual channel response times are less than or equal to the maximum values assumed in the accident analysis. The EOC-RPT SYSTEM RESPONSE TIME acceptance criteria are included in the applicable plant procedures.
A Note to the Surveillance states that breaker interruption time may be assumed from the most recent performance of SR 3.3.4.1.7. This is allowed since the time to open the contacts after energization of the trip coil and the arc suppression time are short and do not appreciably change, due to the design of the breaker opening device and the fact that the breaker is not routinely cycled.
Response times cannot be determined at power because operation of final actuated devices is required. The Surveillance Frequency is controlled under the Surveillance Frequency Control Program.
SR 3.3.4.1.7 This SR ensures that the RPT breaker interruption time is provided to the EOC-RPT SYSTEM RESPONSE TIME test. Breaker Interruption time is defined as Breaker Response time plus Arc Suppression time. Breaker Response is the time from application of voltage to the trip coil until the main contacts separate. Arc Suppression is the time from main contact separation until the complete suppression of the electrical arc across the open contacts. Breaker Response shall be verified by testing and added to the manufacturer's design Arc Suppression time of 12 ms to determine Breaker Interruption time. The breaker arc suppression time shall be validated by the performance of periodic contact gap measurements and high potential tests on the breaker vacuum interrupters in accordance with plant procedures. The Surveillance Frequency is controlled under the Surveillance Frequency Control Program.
REFERENCES
- 1.
UFSAR, Section 7.6.1.8.
- 2.
UFSAR, Section 5.2.2.
- 3.
UFSAR, Sections 15.1.2 and 15.1.3.
- 4.
UFSAR, Sections 15.2.2, 15.2.3 and 15.2.5.
- 5.
GENE-770-06-1, "Bases for Changes To Surveillance Test Intervals And Allowed Out-Of-Service Times For Selected Instrumentation Technical Specifications," February 1991.
(continued)
Insert:
Alternately, the use of the allocated EOC-RPT RESPONSE TIME for transmitters in the Online Monitoring Program is supported using the 'noise analysis' technique implemented in accordance with AMS-TR-0720R2-A (Ref. 6) to detect dynamic failures modes that can affect transmitter response time.
Insert:
- 6. AMS-TR-0720R2-A, "Online Monitoring Technology to Extend Calibration Intervals of Nuclear Plant Pressure Transmitters."
ATWS-RPT Instrumentation B 3.3.4.2 BASES GRAND GULF B 3.3-97 LBDCR 18127 SURVEILLANCE SR 3.3.4.2.3 REQUIREMENTS (continued)
Calibration of trip units provides a check of the actual trip setpoints. The channel must be declared inoperable if the trip setting is discovered to be less conservative than the Allowable Value specified in SR 3.3.4.2.4. If the trip setting is discovered to be less conservative than the setting accounted for in the appropriate setpoint methodology, but is not beyond the Allowable Value, the channel performance is still within the requirements of the plant safety analysis. Under these conditions, the setpoint must be readjusted to be equal to or more conservative than accounted for in the appropriate setpoint methodology.
The Surveillance Frequency is controlled under the Surveillance Frequency Control Program.
SR 3.3.4.2.4 A CHANNEL CALIBRATION is a complete check of the instrument loop and the sensor. This test verifies that the channel responds to the measured parameter within the necessary range and accuracy.
CHANNEL CALIBRATION leaves the channel adjusted to account for instrument drifts between successive calibrations consistent with the plant specific setpoint methodology.
The Surveillance Frequency is controlled under the Surveillance Frequency Control Program.
SR 3.3.4.2.5 The LOGIC SYSTEM FUNCTIONAL TEST demonstrates the OPERABILITY of the required trip logic for a specific channel. The system functional test of the pump breakers, included as part of this Surveillance, overlaps the LOGIC SYSTEM FUNCTIONAL TEST to provide complete testing of the assumed safety function. Therefore, if a breaker is incapable of operating, the associated instrument channel(s) would be inoperable.
The Surveillance Frequency is controlled under the Surveillance Frequency Control Program.
REFERENCES
- 1.
UFSAR, Section 5.4.1.7.10.
- 2.
NEDE-770-06-1, "Bases For Changes To Surveillance Test Intervals and Allowed Out-of-Service Times For Selected Instrumentation Technical Specifications," February 1991.
Insert:
Alternately, the Frequency for checking the calibration of pressure, level, and flow transmitters may be determined in accordance with the Online Monitoring Program implemented in accordance with AMS-TR-0720R2-A (Ref. 3) and TS 5.5.15, Online Monitoring Program Insert:
- 3. AMS-TR-0720R2-A, "Online Monitoring Technology to Extend Calibration Intervals of Nuclear Plant Pressure Transmitters."
ECCS Instrumentation B 3.3.5.1 BASES GRAND GULF B 3.3-135 LBDCR 18127 SURVEILLANCE SR 3.3.5.1.4 and SR 3.3.5.1.5 REQUIREMENTS A CHANNEL CALIBRATION is a complete check of the instrument loop and the sensor. This test verifies the channel responds to the measured parameter within the necessary range and accuracy. CHANNEL CALIBRATION leaves the channel adjusted to account for instrument drifts between successive calibrations consistent with the plant specific setpoint methodology.
The Surveillance Frequencies are controlled under the Surveillance Frequency Control Program.
SR 3.3.5.1.5 for Function 3.d, Condensate Storage Tank Level - Low, is modified by two Notes as identified in Table 3.3.5.1-1. The first Note requires evaluation of channel performance for the condition where the as-found setting for the channel setpoint is outside its as-found tolerance but conservative with respect to the Allowable Value. Evaluation of channel performance will verify that the channel will continue to behave in accordance with safety analysis assumptions and the channel performance assumptions in the setpoint methodology. The purpose of the assessment is to ensure confidence in the channel performance prior to returning the channel to service. For channels determined to be OPERABLE but degraded, after returning the channel to service the performance of these channels will be evaluated under the plant Corrective Action Program. Entry into the Corrective Action Program will ensure required review and documentation of the condition.
The second Note applied to SR 3.3.5.1.5 for Function 3.d, Condensate Storage Tank Level - Low, requires that the as-left setting for the channel be within the as-left tolerance of the NTSP. Where a setpoint more conservative than the NTSP is used in the plant surveillance procedures, the as-left and as-found tolerances, as applicable, will be applied to the surveillance procedure setpoint. This will ensure that sufficient margin to the Safety Limit and/or Analytical Limit is maintained.
If the as-left channel setting cannot be returned to a setting within the as-left tolerance of the NTSP, then the channel shall be declared inoperable.
The second Note also requires that NTSP and the methodologies for calculating the as-left and the as-found tolerances be in the TRM.
(continued)
Insert:
Alternately, the Frequency for checking the calibration of pressure, level, and flow transmitters may be determined in accordance with the Online Monitoring Program implemented in accordance with AMS-TR-0720R2-A (Ref. 6) and TS 5.5.15, Online Monitoring Program.
ECCS Instrumentation B 3.3.5.1 BASES GRAND GULF B 3.3-136 LBDCR 18127 SURVEILLANCE SR 3.3.5.1.6 REQUIREMENTS (continued)
The LOGIC SYSTEM FUNCTIONAL TEST demonstrates the OPERABILITY of the required initiation logic for a specific channel. The system functional testing performed in LCO 3.5.1, LCO 3.5.2, LCO 3.8.1, and LCO 3.8.2 overlaps this Surveillance to provide complete testing of the assumed safety function.
The Surveillance Frequency is controlled under the Surveillance Frequency Control Program.
REFERENCES
- 1.
UFSAR, Section 5.2.
- 2.
UFSAR, Section 6.3.
- 3.
UFSAR, Chapter 15.
- 4.
NEDC-30936-P-A, "BWR Owners' Group Technical Specification Improvement Analyses for ECCS Actuation Instrumentation, Part 2," December 1988.
- 5.
Regulatory Guide 1.105, Setpoints for Safety-Related Instrumentation, Revision 3.
Insert:
- 6. AMS-TR-0720R2-A, "Online Monitoring Technology to Extend Calibration Intervals of Nuclear Plant Pressure Transmitters."
RCIC System Instrumentation B 3.3.5.3 BASES GRAND GULF B 3.3-160 LBDCR 18128 LBDCR 18127 SURVEILLANCE SR 3.3.5.3.2 REQUIREMENTS (continued)
A CHANNEL FUNCTIONAL TEST is performed on each required channel to ensure that the entire channel will perform the intended function. Any setpoint adjustment shall be consistent with the assumptions of the current plant specific setpoint methodology.
The Surveillance Frequency is controlled under the Surveillance Frequency Control Program.
SR 3.3.5.3.3 The calibration of trip units provides a check of the actual trip setpoints.
The channel must be declared inoperable if the trip setting is discovered to be less conservative than the Allowable Value specified in Table 3.3.5.3-1. If the trip setting is discovered to be less conservative than accounted for in the appropriate setpoint methodology, but is not beyond the Allowable Value, the channel performance is still within the requirements of the plant safety analysis. Under these conditions, the setpoint must be re-adjusted to be equal to or more conservative than accounted for in the appropriate setpoint methodology.
The Surveillance Frequency is controlled under the Surveillance Frequency Control Program.
SR 3.3.5.3.4 CHANNEL CALIBRATION is a complete check of the instrument loop and the sensor. This test verifies the channel responds to the measured parameter with the necessary range and accuracy. CHANNEL CALIBRATION leaves the channel adjusted to account for instrument drifts between successive calibrations consistent with the plant specific setpoint methodology.
The Surveillance Frequency is controlled under the Surveillance Frequency Control Program.
SR 3.3.5.3.4 for Function 3, Condensate Storage Tank Level-Low, is modified by two Notes as identified in Table 3.3.5.3-1. The first Note require evaluation of channel performance for the condition where the as-found setting for the channel setpoint is outside its as-found tolerance but (continued)
Insert:
Alternately, the Frequency for checking the calibration of pressure, level, and flow transmitters may be determined in accordance with the Online Monitoring Program implemented in accordance with AMS-TR-0720R2-A (Ref. 3) and TS 5.5.15, Online Monitoring Program.
RCIC System Instrumentation B 3.3.5.3 BASES GRAND GULF B 3.3-161 LBDCR 18128 LBDCR 18127 SURVEILLANCE SR 3.3.5.3.4 (continued)
REQUIREMENTS conservative with respect to the Allowable Value. Evaluation of channel performance will verify that the channel will continue to behave in accordance with safety analysis assumptions and the channel performance assumptions in the setpoint methodology. The purpose of the assessment is to ensure confidence in the channel performance prior to returning the channel to service. For channels determined to be OPERABLE but degraded after returning the channel to service the performance of these channels will be evaluated under the plant Corrective Action Program. Entry into the Corrective Action Program will ensure required review and documentation of the condition.
The second Note applied to SR 3.3.5.3.4 for Function 3, Condensate Storage Tank Level-Low, requires that the as-left setting for the channel be within the as-left tolerance of the Nominal Trip Setpoint (NTSP).
Where a setpoint more conservative than the NTSP is used in the plant surveillance procedures, the as-left and as-found tolerances, as applicable, will be applied to the surveillance procedure setpoint. This will ensure that sufficient margin to the Safety Limit and/or Analytical Limit is maintained. If the as-left channel setting cannot be returned to a setting within the as-left tolerance of the NTSP, then the channel shall be declared inoperable. The second Note also requires that the NTSP and the methodologies for calculating the as-left and the as-found tolerances be in the TRM.
SR 3.3.5.3.5 The LOGIC SYSTEM FUNCTIONAL TEST demonstrates the OPERABILITY of the required initiation logic for a specific channel. The system functional testing performed in LCO 3.5.3 overlaps this Surveillance to provide complete testing of the safety function.
The Surveillance Frequency is controlled under the Surveillance Frequency Control Program.
REFERENCES
- 1.
NEDE-770-06-2, "Addendum to Bases for Changes to Surveillance Test Intervals and Allowed Out-of-Service Times for Selected Instrumentation Technical Specifications," February 1991.
- 2.
Regulatory Guide 1.105, Setpoints for Safety-Related Instrumentation, Revision 3.
Insert:
- 3. AMS-TR-0720R2-A, "Online Monitoring Technology to Extend Calibration Intervals of Nuclear Plant Pressure Transmitters."
Primary Containment and Drywell Isolation Instrumentation B 3.3.6.1 BASES GRAND GULF B 3.3-195 LBDCR 18127 SURVEILLANCE SR 3.3.6.1.3 REQUIREMENTS (continued)
A CHANNEL FUNCTIONAL TEST is performed on each required channel to ensure that the entire channel will perform the intended function.
The calibration of trip units consists of a test to provide a check of the actual trip setpoints. The channel must be declared inoperable if the trip setting is discovered to be less conservative than the Allowable Value specified in Table 3.3.6.1-1. For Function 1.c, Main Steam Line Flow High, there is a plant specific program which verifies the instrument channel functions by verifying the as-left and as-found settings are consistent with those established by the setpoint methodology. If the trip setting is discovered to be less conservative than accounted for in the appropriate setpoint methodology, but is not beyond the Allowable Value, the channel performance is still within the requirements of the plant safety analysis. Under these conditions, the setpoint must be readjusted to be equal to or more conservative than accounted for in the appropriate setpoint methodology.
The Surveillance Frequency is controlled under the Surveillance Frequency Control Program.
SR 3.3.6.1.4, SR 3.3.6.1.5, and SR 3.3.6.1.7 CHANNEL CALIBRATION is a complete check of the instrument loop and the sensor. This test verifies the channel responds to the measured parameter within the necessary range and accuracy. CHANNEL CALIBRATION leaves the channel adjusted to account for instrument drifts between successive calibrations consistent with the plant specific setpoint methodology.
The Surveillance Frequency is controlled under the Surveillance Frequency Control Program.
(continued)
Insert:
Alternately, the Frequency for checking the calibration of pressure, level, and flow transmitters may be determined in accordance with the Online Monitoring Program implemented in accordance with AMS-TR-0720R2-A (Ref. 9) and TS 5.5.15, Online Monitoring Program.
Primary Containment and Drywell Isolation Instrumentation B 3.3.6.1 BASES GRAND GULF B 3.3-196 LBDCR 18127 SURVEILLANCE SR 3.3.6.1.6 and SR 3.3.6.1.8 REQUIREMENTS (continued)
The LOGIC SYSTEM FUNCTIONAL TEST demonstrates the OPERABILITY of the required isolation logic for a specific channel. The system functional testing performed on isolation valves in LCO 3.6.1.3 and LCO 3.6.5.3 overlaps this Surveillance to provide complete testing of the assumed safety function.
The Surveillance Frequency is controlled under the Surveillance Frequency Control Program.
SR 3.3.6.1.9 This SR ensures that the individual channel response times are less than or equal to the maximum values assumed in the accident analysis.
Testing is performed only on channels where the assumed response time does not correspond to the diesel generator (DG) start time. For channels assumed to respond within the DG start time, sufficient margin exists in the 10 second start time when compared to the typical channel response time (milliseconds) so as to assure adequate response without a specific measurement test. Testing of the closure times of the MSIVs is not included in this Surveillance since the closure time of the MSIVs is tested by SR 3.6.1.3.6. ISOLATION SYSTEM RESPONSE TIME acceptance criteria for this instrumentation is included in the applicable plant procedures.
As Noted, the channel sensor may be excluded from response time testing. This allowance to not perform specific response time testing of the sensors is applicable when the alternate testing requirements and restrictions of Reference 7 are performed. As stated in Reference 7, analysis has demonstrated that other Technical Specification testing requirements (CHANNEL CALIBRATIONS, CHANNEL CHECKS, CHANNEL FUNCTIONAL TESTS, and LOGIC SYSTEM FUNCTIONAL TESTS) and actions taken in response to NRC Bulletin 90-01 Supplement 1 are sufficient to identify failure modes or degradation in instrument response times and assure operation of the analyzed instrument loops within acceptable limits. Reference 7 also identifies that there are no known channel sensor failure modes identified that can be detected by (continued)
Insert:
Alternately, the use of the allocated ISOLATION RESPONSE TIME for transmitters in the Online Monitoring Program is supported using the 'noise analysis' technique implemented in accordance with AMS-TR-0720R2-A (Ref. 9) to detect dynamic failures modes that can affect transmitter response time.
Primary Containment and Drywell Isolation Instrumentation B 3.3.6.1 BASES (continued)
GRAND GULF B 3.3-198 LDC 03039 REFERENCES
- 1.
UFSAR, Chapter 6.
- 2.
UFSAR, Chapter 15.
- 3.
NEDO-31466, "Technical Specification Screening Criteria Application and Risk Assessment," November 1987.
- 4.
UFSAR, Section 9.3.5.
- 5.
NEDC-31677-P-A, "Technical Specification Improvement Analysis for BWR Isolation Actuation Instrumentation," June 1989.
- 6.
NEDC-30851-P-A, Supplement 2, "Technical Specifications Improvement Analysis for BWR Isolation Instrumentation Common to RPS and ECCS Instrumentation," March 1989.
- 7.
NEDO-32291-A, "System Analyses for Elimination of Selected Response Time Testing Requirements," October 1995.
- 8.
GNRI-97/00181, Amendment 133 to the Operating License.
Insert:
- 9. AMS-TR-0720R2-A, "Online Monitoring Technology to Extend Calibration Intervals of Nuclear Plant Pressure Transmitters."
Secondary Containment Isolation Instrumentation B 3.3.6.2 BASES GRAND GULF B 3.3-208 LBDCR 18127 SURVEILLANCE SR 3.3.6.2.3 REQUIREMENTS (continued)
Calibration of trip units provides a check of the actual trip setpoints. The channel must be declared inoperable if the trip setting is discovered to be less conservative than the Allowable Value specified in Table 3.3.6.2-1. If the trip setting is discovered to be less conservative than accounted for in the appropriate setpoint methodology, but is not beyond the Allowable Value, performance is still within the requirements of the plant safety analysis. Under these conditions, the setpoint must be readjusted to be equal to or more conservative than accounted for in the appropriate setpoint methodology.
The Surveillance Frequency is controlled under the Surveillance Frequency Control Program.
SR 3.3.6.2.4 and SR 3.3.6.2.5 CHANNEL CALIBRATION is a complete check of the instrument loop and the sensor. This test verifies the channel responds to the measured parameter within the necessary range and accuracy. CHANNEL CALIBRATION leaves the channel adjusted to account for instrument drifts between successive calibrations consistent with the plant specific setpoint methodology.
The Surveillance Frequencies are controlled under the Surveillance Frequency Control Program.
SR 3.3.6.2.6 The LOGIC SYSTEM FUNCTIONAL TEST demonstrates the OPERABILITY of the required isolation logic for a specific channel. The system functional testing, performed on SCIVs and the SGT System in LCO 3.6.4.2 and LCO 3.6.4.3, respectively, overlaps this Surveillance to provide complete testing of the assumed safety function.
The Surveillance Frequency is controlled under the Surveillance Frequency Control Program.
(continued)
Insert:
Alternately, the Frequency for checking the calibration of pressure, level, and flow transmitters may be determined in accordance with the Online Monitoring Program implemented in accordance with AMS-TR-0720R2-A (Ref. 5) and TS 5.5.15, Online Monitoring Program.
Secondary Containment Isolation Instrumentation B 3.3.6.2 BASES GRAND GULF B 3.3-209 LBDCR 18127 SURVEILLANCE SR 3.3.6.2.7 REQUIREMENTS This SR ensures that the individual channel response times are less than or equal to the maximum values assumed in the accident analysis.
Testing is performed only on channels where the assumed response time does not correspond to the diesel generator (DG) start time. For channels assumed to respond within the DG start time, sufficient margin exists in the 10 second start time when compared to the typical channel response time (milliseconds) so as to assure adequate response without a specific measurement test. Testing of the closure times of the isolation dampers is not included in this Surveillance since the closure time of the isolation dampers is tested by SR 3.6.4.2.2. ISOLATION SYSTEM RESPONSE TIME acceptance criteria for this instrumentation is included in the applicable plant procedures.
A Note to the Surveillance states that the radiation detectors may be excluded from ISOLATION SYSTEM RESPONSE TIME testing. This Note is necessary because of the difficulty of generating an appropriate detector input signal and because the principles of detector operation virtually ensure an instantaneous response time. Response time for radiation detector channels shall be measured from detector output or the input of the first electronic component in the channel.
The Surveillance Frequency is controlled under the Surveillance Frequency Control Program.
REFERENCES
- 1.
UFSAR, Section 6.2.
- 2.
UFSAR, Chapter 15.
- 3.
NEDO-31677-P-A, "Technical Specification Improvement Analysis for BWR Isolation Actuation Instrumentation," July 1990.
- 4.
NEDC-30851-P-A Supplement 2, "Technical Specifications Improvement Analysis for BWR Isolation Instrumentations Common to RPS and ECCS Instrumentation," March 1989.
Insert:
Alternately, the use of the allocated ISOLATION RESPONSE TIME for transmitters in the Online Monitoring Program is supported using the 'noise analysis' technique implemented in accordance with AMS-TR-0720R2-A (Ref. 5) to detect dynamic failures modes that can affect transmitter response time.
Insert:
- 5. AMS-TR-0720R2-A, "Online Monitoring Technology to Extend Calibration Intervals of Nuclear Plant Pressure Transmitters."
RHR Containment Spray System Instrumentation B 3.3.6.3 BASES GRAND GULF B 3.3-218 LBDCR 23016 SURVEILLANCE SR 3.3.6.3.2 (continued)
REQUIREMENTS A CHANNEL FUNCTIONAL TEST is performed on each required channel to ensure the entire 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 applicable extensions.
Any setpoint adjustment shall be consistent with the assumptions of the current plant specific setpoint methodology.
The Surveillance Frequency is controlled under the Surveillance Frequency Control Program.
SR 3.3.6.3.3 The calibration of trip units provides a check of the actual trip setpoints.
The channel must be declared inoperable if the trip setting is discovered to be less conservative than the Allowable Value specified in Table 3.3.6.3-1. If the trip setting is discovered to be less conservative than accounted for in the appropriate setpoint methodology, but is not beyond the Allowable Value, the channel performance is still within the requirements of the plant safety analysis. Under these conditions, the setpoint must be readjusted to be equal to or more conservative than accounted for in the appropriate setpoint methodology.
The Surveillance Frequency is controlled under the Surveillance Frequency Control Program.
SR 3.3.6.3.4 and SR 3.3.6.3.5 A CHANNEL CALIBRATION is a complete check of the instrument loop and the sensor. This test verifies that the channel responds to the measured parameter within the necessary range and accuracy.
CHANNEL CALIBRATION leaves the channel adjusted to account for instrument drifts between successive calibrations consistent with the plant specific setpoint methodology.
The Surveillance Frequencies are controlled under the Surveillance Frequency Control Program.
(continued)
Insert:
Alternately, the Frequency for checking the calibration of pressure, level, and flow transmitters may be determined in accordance with the Online Monitoring Program implemented in accordance with AMS-TR-0720R2-A (Ref. 4) and TS 5.5.15, Online Monitoring Program.
RHR Containment Spray System Instrumentation B 3.3.6.3 BASES GRAND GULF B 3.3-219 LBDCR 18127 SURVEILLANCE SR 3.3.6.3.6 (continued)
REQUIREMENTS The LOGIC SYSTEM FUNCTIONAL TEST demonstrates the OPERABILITY of the required initiation logic for a specific channel. The system functional testing performed in LCO 3.6.1.7, "Residual Heat Removal (RHR) Containment Spray," overlaps this Surveillance to provide complete testing of the assumed safety function.
The Surveillance Frequency is controlled under the Surveillance Frequency Control Program.
REFERENCES
- 1.
UFSAR, Section 7.3.1.1.4.
- 2.
UFSAR, Section 6.2.1.1.5.
- 3.
GENE-770-06-1, "Bases for Changes to Surveillance Test Intervals and Allowed Out-of-Service Times for Selected Instrumentation Technical Specifications," February 1991.
(continued)
Insert:
- 4. AMS-TR-0720R2-A, "Online Monitoring Technology to Extend Calibration Intervals of Nuclear Plant Pressure Transmitters."
SPMU System Instrumentation B 3.3.6.4 BASES GRAND GULF B 3.3-231 LBDCR 18127 SURVEILLANCE SR 3.3.6.4.4 and SR 3.3.6.4.5 REQUIREMENTS (continued)
A CHANNEL CALIBRATION is a complete check of the instrument loop and the sensor. This test verifies that the channel responds to the measured parameter within the necessary range and accuracy.
CHANNEL CALIBRATION leaves the channel adjusted to account for instrument drifts between successive calibrations consistent with the plant specific setpoint methodology.
The Surveillance Frequencies are controlled under the Surveillance Frequency Control Program.
SR 3.3.6.4.6 The LOGIC SYSTEM FUNCTIONAL TEST demonstrates the OPERABILITY of the required initiation logic for a specific channel. The system functional testing performed in LCO 3.6.2.4, "Suppression Pool Makeup (SPMU) System," overlaps this Surveillance to provide complete testing of the assumed safety function.
The Surveillance Frequency is controlled under the Surveillance Frequency Control Program.
REFERENCES
- 1.
UFSAR, Section 7.3.1.1.9.
- 2.
UFSAR, Section 6.2.7.3.
- 3.
GENE-770-06-1, "Bases for Changes to Surveillance Test Intervals and Allowed Out-of-Service Times for Selected Instrumentation Technical Specifications," February 1991.
Insert:
- 4. AMS-TR-0720R2-A, "Online Monitoring Technology to Extend Calibration Intervals of Nuclear Plant Pressure Transmitters."
Insert:
Alternately, the Frequency for checking the calibration of pressure, level, and flow transmitters may be determined in accordance with the Online Monitoring Program implemented in accordance with AMS-TR-0720R2-A (Ref. 4) and TS 5.5.15, Online Monitoring Program.
Relief and LLS Instrumentation B 3.3.6.5 BASES GRAND GULF B 3.3-237 LBDCR 18127 SURVEILLANCE SR 3.3.6.5.3 REQUIREMENTS A CHANNEL CALIBRATION is a complete check of the instrument loop and the sensor. This test verifies the channel responds to the measured parameter within the necessary range and accuracy. CHANNEL CALIBRATION leaves the channel adjusted to account for instrument drifts between successive calibrations consistent with the plant specific setpoint methodology.
The Surveillance Frequency is controlled under the Surveillance Frequency Control Program.
SR 3.3.6.5.4 The LOGIC SYSTEM FUNCTIONAL TEST demonstrates the OPERABILITY of the required actuation logic for a specific channel. The system functional testing performed for S/RVs in LCO 3.4.4 and LCO 3.6.1.6 overlaps this Surveillance to provide complete testing of the assumed safety function.
The Surveillance Frequency is controlled under the Surveillance Frequency Control Program.
REFERENCES
- 1.
UFSAR, Section 5.2.2.
- 2.
GENE-770-06-1, "Bases for Changes to Surveillance Test Intervals and Allowed Out-of-Service Times for Selected Instrumentation Technical Specifications," February 1991.
Insert:
Alternately, the Frequency for checking the calibration of pressure, level, and flow transmitters may be determined in accordance with the Online Monitoring Program implemented in accordance with AMS-TR-0720R2-A (Ref. 3) and TS 5.5.15, Online Monitoring Program.
Insert:
- 3. AMS-TR-0720R2-A, "Online Monitoring Technology to Extend Calibration Intervals of Nuclear Plant Pressure Transmitters."
ECCS Operating B 3.5.1 GRAND GULF B 3.5-17 LBDCR 18127 BASES SURVEILLANCE SR 3.5.1.8 REQUIREMENTS This SR ensures that the HPCS System response time is less than or equal to the maximum value assumed in the accident analysis. Specific testing of the ECCS actuation instrumentation inputs into the HPCS System ECCS SYSTEM RESPONSE TIME is not required by this SR.
Specific response time testing of this instrumentation is not required since these actuation channels are only assumed to respond within the diesel generator start time; therefore, sufficient margin exists in the diesel generator 10 second start time when compared to the typical channel response time (milliseconds) so as to assure adequate response without a specific measurement test (Ref. 17). The diesel generator starting and any sequence loading delays along with the Reactor Vessel Water Level -
Low Low, Level 2 confirmation delay permissive must be added to the HPCS System equipment response times to obtain the HPCS System ECCS SYSTEM RESPONSE TIME. The acceptance criterion for the HPCS System ECCS SYSTEM RESPONSE TIME is d 32 seconds.
The Surveillance Frequency is controlled under the Surveillance Frequency Control Program.
(continued)
Insert:
Alternately, the use of the allocated ISOLATION RESPONSE TIME for transmitters in the Online Monitoring Program is supported using the 'noise analysis' technique implemented in accordance with AMS-TR-0720R2-A (Ref. 21) to detect dynamic failures modes that can affect transmitter response time.
ECCS Operating B 3.5.1 GRAND GULF B 3.5-18 LBDCR 18085 BASES REFERENCES
- 1.
FSAR, Section 6.3.2.2.3.
- 2.
FSAR, Section 6.3.2.2.4.
- 3.
FSAR, Section 6.3.2.2.1.
- 4.
FSAR, Section 6.3.2.2.2.
- 5.
FSAR, Section 15.2.8.
- 6.
FSAR, Section 15.6.4.
- 7.
FSAR, Section 15.6.5.
- 8.
- 9.
FSAR, Section 6.3.3.
- 10.
- 11.
FSAR, Section 6.3.3.3.
- 12.
Memorandum from R.L. Baer (NRC) to V. Stello, Jr. (NRC),
"Recommended Interim Revisions to LCO's for ECCS Components," December 1, 1975.
- 13.
NEDC-32988-A, Revision 2, Technical Justification to Support Risk-Informed Modification to Selected Required End States for BWR Plants, December 2002.
- 14.
FSAR, Section 6.3.3.7.8
- 15.
FSAR, Section 7.3.1.1.1.4.2.
- 16.
GNRI-96/00229, Amendment 130 to the Operating License.
- 17.
NEDO-32291-A, "System Analyses for Elimination of Selected Response Time Testing Requirements," October 1995.
- 18.
GNRI-97/00181, Amendment 133 to the Operating License.
- 19.
ASME/ANSI OM-1987, Operation and Maintenance of Nuclear Pumps in Light Water Reactor Power Plants.
- 20.
Deleted (continued)
Insert:
- 21. AMS-TR-0720R2-A, "Online Monitoring Technology to Extend Calibration Intervals of Nuclear Plant Pressure Transmitters."
Drywell Purge System B 3.6.3.3 BASES GRAND GULF B 3.6-79 LBDCR 18127 SURVEILLANCE SR 3.6.3.3.4 REQUIREMENTS This SR verifies that the pressure differential required to open the vacuum breakers is < 1.0 psid and that the isolation valve differential pressure actuation instrumentation opens the valve at 0.0 to 1.0 psid (drywell minus containment). This SR includes a CHANNEL CALIBRATION of the isolation valve differential pressure actuation instrumentation. The Surveillance Frequency is controlled under the Surveillance Frequency Control Program.
REFERENCES
- 1.
Regulatory Guide 1.7, Revision 1.
- 2.
UFSAR, Section 6.2.5.
- 3.
Technical Specification Amendment 145 to GGNS Operating License.
Insert:
Alternately, the Frequency for checking the calibration of pressure, level, and flow transmitters may be determined in accordance with the Online Monitoring Program implemented in accordance with AMS-TR-0720R2-A (Ref. 4) and TS 5.5.15, Online Monitoring Program.
Insert:
- 4. AMS-TR-0720R2-A, "Online Monitoring Technology to Extend Calibration Intervals of Nuclear Plant Pressure Transmitters."
GRAND GULF B 3.6-131 LBDCR 18127 SURVEILLANCE SR 3.6.5.6.3 REQUIREMENTS Verification of the opening pressure differential is necessary to ensure that the safety analysis assumption that the vacuum breaker or isolation valve will open fully at a differential pressure of 1.0 psid is valid. This SR verifies that the pressure differential required to open the vacuum breakers is < 1.0 psid and that the isolation valve differential pressure actuation instrumentation opens the valve at 0.0 to 1.0 psid for the drywell purge vacuum relief subsystem and -1.0 to 0.0 psid for the post-LOCA vacuum relief subsystems (drywell minus containment). This SR includes a CHANNEL CALIBRATION of the isolation valve differential pressure actuation instrumentation. This Surveillance includes a calibration of the position indication as necessary. The Surveillance Frequency is controlled under the Surveillance Frequency Control Program.
REFERENCES
- 1.
UFSAR, Section 6.2.
- 2.
NEDC-32988-A, Revision 2, Technical Justification to Support Risk Informed Modification to Selected Required End States for BWR Plants, December 2002.
Insert:
Alternately, the Frequency for checking the calibration of pressure, level, and flow transmitters may be determined in accordance with the Online Monitoring Program implemented in accordance with AMS-TR-0720R2-A (Ref. 3) and TS 5.5.15, Online Monitoring Program.
Insert:
- 3. AMS-TR-0720R2-A, "Online Monitoring Technology to Extend Calibration Intervals of Nuclear Plant Pressure Transmitters."
Drywell Vacuum Relief System B 3.6.5.6
Enclosure, Attachment 14 CNRO2024-00002 Technical Specification Bases Mark-ups - RBS (Information only)
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Insert:
The Frequency for checking the calibration of pressure, level, and flow transmitters may be determined in accordance with the Online Monitoring Program implemented in accordance with AMS-TR-0720R2-A (Ref. 12) and TS 5.5.1, Online Monitoring Program.
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Insert:
Alternately, the use of the allocated RPS RESPONSE TIME for transmitters in the Online Monitoring Program is supported using the 'noise analysis' technique implemented in accordance with AMS-TR-0720R2-A (Ref. 12) to detect dynamic failures modes that can affect transmitter response time.
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- 12. AMS-TR-0720R2-A, "Online Monitoring Technology to Extend Calibration Intervals of Nuclear Plant Pressure Transmitters."
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Insert:
The Frequency for checking the calibration of pressure, level, and flow transmitters may be determined in accordance with the Online Monitoring Program implemented in accordance with AMS-TR-0720R2-A (Ref. 5) and TS 5.5.17, Online Monitoring Program.
Insert:
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The Frequency for checking the calibration of pressure, level, and flow transmitters may be determined in accordance with the Online Monitoring Program implemented in accordance with AMS-TR-0720R2-A (Ref. 3) and TS 5.5.17, Online Monitoring Program.
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The Frequency for checking the calibration of pressure, level, and flow transmitters may be determined in accordance with the Online Monitoring Program implemented in accordance with AMS-TR-0720R2-A (Ref. 7) and TS 5.5.17, Online Monitoring Program.
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Alternately, the use of the allocated EOC-RPT RESPONSE TIME for transmitters in the Online Monitoring Program is supported using the 'noise analysis' technique implemented in accordance with AMS-TR-0720R2-A (Ref. 7) to detect dynamic failures modes that can affect transmitter response time.
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The Frequency for checking the calibration of pressure, level, and flow transmitters may be determined in accordance with the Online Monitoring Program implemented in accordance with AMS-TR-0720R2-A (Ref. 3) and TS 5.5.17, Online Monitoring Program.
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The Frequency for checking the calibration of pressure, level, and flow transmitters may be determined in accordance with the Online Monitoring Program implemented in accordance with AMS-TR-0720R2-A (Ref. 6) and TS 5.5.17, Online Monitoring Program.
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- 6. AMS-TR-0720R2-A, "Online Monitoring Technology to Extend Calibration Intervals of Nuclear Plant Pressure Transmitters."
RCIC System Instrumentation B 3.3.5.3 RIVER BEND B 3.3-133 Amendment No. 215 BASES SURVEILLANCE SR 3.3.5.3.4 (continued)
REQUIREMENTS CHANNEL CALIBRATION leaves the channel adjusted to account for instrument drifts between successive calibrations consistent with the plant specific setpoint methodology.
The Surveillance Frequency is controlled under the Surveillance Frequency Control Program.
SR 3.3.5.3.5 The LOGIC SYSTEM FUNCTIONAL TEST demonstrates the OPERABILITY of the required initiation logic for a specific channel. The system functional testing performed in LCO 3.5.3 overlaps this Surveillance to provide complete testing of the safety function.
The Surveillance Frequencies are controlled under the Surveillance Frequency Control Program.
REFERENCES
- 1.
NEDE-770-06-2, "Addendum to Bases for Changes to Surveillance Test Intervals and Allowed Out-of-Service Times for Selected Instrumentation Technical Specifications," February 1991.
Insert:
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- 2. AMS-TR-0720R2-A, "Online Monitoring Technology to Extend Calibration Intervals of Nuclear Plant Pressure Transmitters."
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The Frequency for checking the calibration of pressure, level, and flow transmitters may be determined in accordance with the Online Monitoring Program implemented in accordance with AMS-TR-0720R2-A (Ref. 5) and TS 5.5.17, Online Monitoring Program.
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- 5. AMS-TR-0720R2-A, "Online Monitoring Technology to Extend Calibration Intervals of Nuclear Plant Pressure Transmitters."
Containment Unit Cooler System Instrumentation B 3.3.6.3 RIVER BEND B 3.3-189 Amendment No. 215 BASES SURVEILLANCE SR 3.3.6.3.2 REQUIREMENTS (continued)
A CHANNEL FUNCTIONAL TEST is performed on each required channel to ensure the entire 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 applicable extensions.
Any setpoint adjustment shall be consistent with the assumptions of the current plant specific setpoint methodology.
The Surveillance Frequency is controlled under the Surveillance Frequency Control Program.
SR 3.3.6.3.3 The calibration of trip units provides a check of the actual trip setpoints.
The channel must be declared inoperable if the trip setting is discovered to be less conservative than the Allowable Value specified in Table 3.3.6.3-1. If the trip setting is discovered to be less conservative than accounted for in the appropriate setpoint methodology, but is not beyond the Allowable Value, the channel performance is still within the requirements of the plant safety analysis. Under these conditions, the setpoint must be readjusted to be equal to or more conservative than accounted for in the appropriate setpoint methodology.
The Surveillance Frequency is controlled under the Surveillance Frequency Control Program.
SR 3.3.6.3.4 A CHANNEL CALIBRATION is a complete check of the instrument loop and the sensor. This test verifies that the channel responds to the measured parameter within the necessary range and accuracy.
CHANNEL CALIBRATION leaves the channel adjusted to account for instrument drifts between successive calibrations consistent with the plant specific setpoint methodology.
The Surveillance Frequency is controlled under the Surveillance Frequency Control Program.
(continued)
Insert:
The Frequency for checking the calibration of pressure, level, and flow transmitters may be determined in accordance with the Online Monitoring Program implemented in accordance with AMS-TR-0720R2-A (Ref. 4) and TS 5.5.17, Online Monitoring Program.
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- 4. AMS-TR-0720R2-A, "Online Monitoring Technology to Extend Calibration Intervals of Nuclear Plant Pressure Transmitters."
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The Frequency for checking the calibration of pressure, level, and flow transmitters may be determined in accordance with the Online Monitoring Program implemented in accordance with AMS-TR-0720R2-A (Ref. 4) and TS 5.5.17, Online Monitoring Program.
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- 4. AMS-TR-0720R2-A, "Online Monitoring Technology to Extend Calibration Intervals of Nuclear Plant Pressure Transmitters."
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The Frequency for checking the calibration of pressure, level, and flow transmitters may be determined in accordance with the Online Monitoring Program implemented in accordance with AMS-TR-0720R2-A (Ref. 7) and TS 5.5.17, Online Monitoring Program.
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- 7. AMS-TR-0720R2-A, "Online Monitoring Technology to Extend Calibration Intervals of Nuclear Plant Pressure Transmitters."
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Alternately, the use of the allocated ECCS RESPONSE TIME for transmitters in the Online Monitoring Program is supported using the 'noise analysis' technique implemented in accordance with AMS-TR-0720R2-A (Ref. 18) to detect dynamic failures modes that can affect transmitter response time.
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- 18. AMS-TR-0720R2-A, "Online Monitoring Technology to Extend Calibration Intervals of Nuclear Plant Pressure Transmitters."
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Alternately, the use of the allocated TURBINE BYPASS SYSTEM RESPONSE TIME for transmitters in the Online Monitoring Program is supported using the 'noise analysis' technique implemented in accordance with AMS-TR-0720R2-A (Ref. 3) to detect dynamic failures modes that can affect transmitter response time.
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- 3. AMS-TR-0720R2-A, "Online Monitoring Technology to Extend Calibration Intervals of Nuclear Plant Pressure Transmitters."
Enclosure, Attachment 15 CNRO2024-00002 Technical Specification Bases Mark-ups - WF3 (Information only)
(4 TS Bases Pages Follow)
WATERFORD - UNIT 3 B 3/4 3-1c AMENDMENT NO. 154 TSCR 99-14 CHANGE NO. 4, 9, 27, 57, 63, 67, 86, 99 3/4.3 INSTRUMENTATION BASES 3/4.3.1 and 3/4.3.2 REACTOR PROTECTIVE AND ENGINEERED SAFETY FEATURES ACTUATION SYSTEMS INSTRUMENTATION (Continued)
When one of the inoperable channels is restored to OPERABLE status, subsequent operation in the applicable MODE(S) may continue in accordance with the provisions of ACTION 19.
Because of the interaction between process measurement circuits and associated functional units as listed in the ACTIONS 19 and 20, placement of an inoperable channel of Steam Generator Level in the bypass or trip condition results in corresponding placements of Steam Generator P (EFAS) instrumentation. Depending on the number of applicable inoperable channels, the provisions of ACTIONS 19 and 20 and the aforesaid scenarios for Steam Generator P (EFAS) would govern.
(LBDCR 16-046, Ch. 86)
The Surveillance Requirements specified for these systems ensure that the overall system functional capability is maintained comparable to the original design standards. The periodic surveillance tests performed at the frequencies in the Surveillance Frequency Control Program are sufficient to demonstrate this capability. The frequency for the channel functional tests for these systems is controlled by the Surveillance Frequency Control Program.
(LBDCR 16-046, Ch. 86)
(LBDCR 21-010, Ch. 99)
The CPC testing features are designed to allow for complete testing by using a combination of system self-checking and manual tests. Successful testing consists of verifying that the capability of the system to perform the safety function has not failed or degraded. For hardware functions this would involve verifying that the hardware components and connections have not failed or degraded. Software testing involves verifying that the software code has not changed and that the software code is executing. To the extent possible, CPC system testing will be accomplished with continuous system self-checking features in lieu of manual surveillance tests.
Self-checking features include on-line diagnostics for the computer system and the hardware and communications tests. Faults detected by the self-checking features are alarmed in the main control room. These self-checking tests do not interfere with normal system operation. The performance of channel checks validates that the self-diagnostics are continuing to perform their self-checking functions.
(LBDCR 21-010, Ch. 99)
(LBDCR 16-046, Ch. 86)
Testing frequency for the Reactor Trip Breakers (RTBs) is controlled by the Surveillance Frequency Control Program. The RTB channel functional test and RPS logic channel functional test are scheduled and performed such that RTBs are verified OPERABLE in accordance with the Surveillance Frequency Control Program.
(LBDCR 16-046, Ch. 86)
RPS/ESFAS Trip Setpoints values are determined by means of an explicit setpoint calculation analysis. A Total Loop Uncertainty (TLU) is calculated for each RPS/ESFAS instrument channel. The Trip Setpoint is then determined by adding or subtracting the TLU from the Analytical Limit (add TLU for decreasing process value; subtract TLU for increasing process value). The Allowable Value is determined by adding an allowance between the Trip Setpoint and the Analytical Limit to account for RPS/ESFAS cabinet Periodic Test Errors (PTE) which are present during a CHANNEL FUNCTIONAL TEST. PTE combines the RPS/ESFAS Insert:
Alternately, the Frequency for checking the calibration of pressure, level, and flow transmitters may be determined in accordance with the Online Monitoring Program implemented in accordance with AMS-TR-0720R2-A and TS 6.5.20, Online Monitoring Program.
WATERFORD - UNIT 3 B 3/4 3-1d CHANGE NO. 57, 63, 67, 86, 99, 104, 111 3/4.3 INSTRUMENTATION BASES 3/4.3.1 and 3/4.3.2 REACTOR PROTECTIVE AND ENGINEERED SAFETY FEATURES ACTUATION SYSTEMS INSTRUMENTATION (Continued) cabinet reference accuracy, calibration equipment errors (M&TE), and RPS/ESFAS cabinet bistable Drift. Periodic testing assures that actual setpoints are within their Allowable Values. A channel is inoperable if its actual setpoint is not within its Allowable Value and corrective action must be taken. Operation with a trip set less conservative than its setpoint, but within its specified ALLOWABLE VALUE is acceptable on the basis that the difference between each trip Setpoint and the ALLOWABLE VALUE is equal to or less than the Periodic Test Error allowance assumed for each trip in the safety analyses.
(EC-26338, Ch. 67)
The Core Protection Calculator, High Logarithmic Power (HLP), and Reactor Coolant System Flow use a single bistable to initiate both the permissive and automatic operating bypass removal functions. A single bistable cannot both energize and de-energize at a single, discrete value due to hysteresis. The CPC automatic bypass removal and permissive for the HLP trip bypass occur at the bistable setpoint (nominally 10-4% power). However, the HLP automatic bypass removal and permissive for CPC trip bypass occur at the reset value of the bistable. Also note if the bistable setpoint is changed as part of the Special Test Exception 3.10.3, the same dead band transition is applicable.
(EC-26338, Ch. 67; (LBDCR 23-016, Ch. 111)
The measurement of response time provides assurance that the protective and ESF action function associated with each channel is completed within the time limit assumed in the safety analyses. No credit was taken in the analyses for those channels with response times indicated as not applicable.
(LBDCR 23-016, Ch. 111)
(LBDCR 22-034, Ch. 104)
Response time may be verified by any series of sequential, overlapping, or total channel measurements, including allocated sensor response time, such that the response time is verified.
Allocations for sensor response times may be obtained from records of test results, vendor test data, or vendor engineering specifications. Topical Report CE NPSD-1167-A, "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 Topical Report. The response time may be verified for components that replace the components that were previously evaluated in CE NPSD-1167-A provided that the components have been evaluated in accordance with the NRC approved methodology as discussed in Attachment 1 to TSTF-569, "Methodology to Eliminate Pressure Sensor and Protection Channel (for Westinghouse plants only) Response Time Testing."
Response time verification for other sensor types must be demonstrated by test. The allocation of sensor response times must be verified prior to placing a new component in operation and reverified after maintenance that may adversely affect the sensor response time.
(LBDCR 22-034, Ch. 104)
Insert:
Alternately, the use of the allocated RPS/ESFAS RESPONSE TIME for transmitters in the Online Monitoring Program is supported using the 'noise analysis' technique implemented in accordance with AMS-TR-0720R2-A to detect dynamic failures modes that can affect transmitter response time.
WATERFORD - UNIT 3 B 3/4 3-3 AMENDMENT NO. 14, 29, 49, 122 CHANGE NO. 24,71 86 INSTRUMENTATION BASES 3/4.3.3.5 REMOTE SHUTDOWN INSTRUMENTATION The OPERABILITY of the remote shutdown instrumentation ensures that sufficient capability is available to permit shutdown and maintenance of HOT STANDBY of the facility from locations outside of the control room. This capability is required in the event control room habitability is lost and is consistent with General Design Criterion 19 of 10 CFR Part 50.
(LBDCR 16-046, Ch. 86)
The Surveillance Frequency is controlled under the Surveillance Frequency Control Program.
(LBDCR 16-046, Ch. 86) 3/4.3.3.6 ACCIDENT MONITORING INSTRUMENTATION The OPERABILITY of the accident monitoring instrumentation ensures that sufficient information is available on selected plant parameters to monitor and assess these variables following an accident. The availability of accident monitoring instrumentation is important so that responses to corrective actions can be observed and the need for, and magnitude of, further actions can be determined. These essential instruments are identified by plant specific documents addressing the recommendations of Regulatory Guide 1.97, as required by Supplement 1 to NUREG-0737, "TMI Action Items." Table 3.3.10 includes most of the plant's RG 1.97 Type A and Category 1 variables. The remaining Type A/Category 1 variables are included in their respective specifications. Type A variables are included in this LCO because they provide the primary information required to permit the control room operator to take specific manually controlled actions, for which no automatic control is provided, that are required for safety systems to accomplish their safety functions for Design Basis Accidents (DBAs).
Category 1 variables are the key variables deemed risk significant because they are needed to:
(1) Determine whether other systems important to safety are performing their intended functions; (2) Provide information to the operators that will enable them to determine the potential for causing a gross breach of the barriers to radioactivity release; and (3) Provide information regarding the release of radioactive materials to allow for early indication of the need to initiate action necessary to protect the public as well as to obtain an estimate of the magnitude of any impending threat.
>(DRN 03-656, Ch. 24)
With the number of OPERABLE accident monitoring channels less than the Required Number of Channels shown in Table 3.3-10, the inoperable channel should be restored to OPERABLE status within 30 days. The 30 day Completion Time is based on operating experience and takes into account the remaining OPERABLE channel (or in the case of a Function that has only one required channel, other non-Regulatory Guide 1.97 instrument channels to monitor the Function), the passive nature of the instrument (no critical automatic action is assumed to occur from these instruments), and the low probability of an event requiring accident monitoring instrumentation during this interval. If the 30 day AOT is not met, a Special Report approved by OSRC is required to be submitted to the NRC within the following 14 days. This report discusses the results of the root cause evaluation of the inoperability and identifies proposed restorative Actions. This Action is appropriate in lieu of a shutdown requirement, given the likelihood of plant conditions that would require information provided by this instrumentation. Also, alternative Actions are identified before a loss of functional capability condition occurs.
<(DRN 03-656, Ch. 24)
With the number of OPERABLE accident monitoring channels less than the Minimum Channels OPERABLE requirements of Table 3.3-10; at least one of the inoperable channels should be restored to OPERABLE status within 7 days. The Completion Time of 7 days is based on the relatively low probability of an event requiring PAM instrumentation operation and the availability of alternate means to obtain the required information.
Insert:
Alternately, the Frequency for checking the calibration of pressure, level, and flow transmitters may be determined in accordance with the Online Monitoring Program implemented in accordance with AMS-TR-0720R2-A and TS 6.5.20, Online Monitoring Program.
WATERFORD - UNIT 3 B 3/4 3-3a AMENDMENT NO. 14,20,50,104, 122,133,135, 151 CHANGE NO. 86, 100 INSTRUMENTATION BASES 3/4.3.3.6 ACCIDENT MONITORING INSTRUMENTATION (CONTINUED)
Continuous operation with less than Minimum Channels OPERABLE requirements is not acceptable because the alternate indications may not fully meet all performance qualification requirements applied to the accident monitoring instrumentation. Therefore, requiring restoration of one inoperable channel limits the risk that the variable will be in a degraded condition should an accident occur. If the 7 day requirement is not met, the plant must be brought to a MODE in which the LCO does not apply. To achieve this status, the plant must be brought to at least MODE 4 within 12 hours1.388889e-4 days <br />0.00333 hours <br />1.984127e-5 weeks <br />4.566e-6 months <br />. The completion time is reasonable, based on operating experience, to reach the required plant conditions from full power conditions in an orderly manner and without challenging plant systems.
TS 3/4.3.3.6 applies to the following instrumentation:
ESFIPI6750 A, ESFIPR6750 B, ESFIPR6755 A&B, RC ITI0122 HA, RC ITI0112 HB, RC ITI0122 CA, RC ITI0112 CB, RC IPI0102 A,B,C,&D, RC ILI0110 X&Y, SG ILI1113 A,B,C,&D, SG ILI1123 A,B,C,&D, SG ILI1115 A2&B2, SG ILI1125 A2&B2, SI ILI7145 A, SI ILR7145 B, all CET's, all Category 1 Containment Isolation Valve Position Indicators, EFWILI9013 A&B, HJTC's, and ENIIJI0001 C&D.
J(LBDCR 16-046, Ch. 86)
The Surveillance Frequency is controlled under the Surveillance Frequency Control Program.
I(LBDCR 16-046, Ch. 86)
J(LBDCR 22-019, Ch. 100) 3/4.3.3.7 This section deleted I(LBDCR 22-019, Ch. 100)
Insert:
Alternately, the Frequency for checking the calibration of pressure, level, and flow transmitters may be determined in accordance with the Online Monitoring Program implemented in accordance with AMS-TR-0720R2-A and TS 6.5.20, Online Monitoring Program.