Text

Response to Request for Additional Information Regarding Section 3.3, Instrumentation, of the Improved Technical Specification (ITS)
	ML031010219
Person / Time
Site:	Indian Point
Issue date:	04/08/2003
From:	Dacimo F; Entergy Nuclear Northeast
To:	; Document Control Desk, Office of Nuclear Reactor Regulation
References
	NL-03-052
	Download: ML031010219 (96)
	v • d • e

Entergy Nuclear Northeast Indian Point Energy Center 295 Broadway, Suite 1 PO Box 249

' Enntergy Buchanan, NY 10511-0249 Tel 914 734 5340 Fax 914 734 5718 Fred Dacimo Vice President, Operations April 8, 2003 Re: Indian Point Unit No. 2 Docket No. 50-247 NL-03-052 U.S. Nuclear Regulatory Commission ATTN: Document Control Desk Mail Station O-P1-17 Washington, DC 20555-0001

Subject:

Response to Request for Additional Information Regarding Section 3.3, Instrumentation, of the Improved Technical Specifications (ITS)

(TAC No. MB4739)

Reference:

1) Entergy letter (NL-02-016) to NRC, "License Amendment Request (LAR 02-005) Conversion to Improved Standard Technical Specifications," dated March 27, 2002

2) Entergy letter (NL-02-092) to NRC, "Supplement 1 to the Indian Point 2 License Amendment Request for Conversion to Improved Standard Technical Specifications," dated July 10, 2002

3) Entergy letter (NL-03-035) to NRC, "Supplement 2 to the Indian Point 2 License Amendment Request for Conversion to Improved Standard Technical Specifications," dated February 26, 2003

4) NUREG 1431, "Standard Technical Specifications Westinghouse Plants," Revision 2, dated April 2001

5) 10 CFR 50.36, 'Technical Specifications," as amended

6) NRC letter to Entergy Nuclear Operations, Inc., "Request for Additional Information (RAI) Regarding Improved Technical Specification (ITS) Sections: 3.3.2, Engineered Safety Feature Actuation System (ESFAS) Instrumentation; ITS 3.3.3, Post Accident Monitoring Instrumentation; 3.3.4, Remote Shutdown Instrumentation; 3.3.5, Loss of Power Diesel Generator (LOP-DG)

Start Instrumentation; 3.3.6, Containment Purge and Exhaust Isolation Instrumentation; 3.3.7 Control Room Ventilation System (CRVS) Actuation Instrumentation (TAC No. MB4739)," dated January 22, 2003

7) Entergy letter (NL-02-160) to NRC, "Response to Request for Additional Information Regarding Sections 1.0, 2.0, 3.0, 3.1, 3.2, 3.3, 3.4, 3.5, 3.6, 3.7, 3.9, 4.0, and 5.0 of the Improved Technical Specifications (ITS)," dated December 18, 2002

NL-03-052 Page 2 of 3

Dear Sir:

By letter dated March 27, 2002 (Reference 1), as supplemented by letters dated July 10, 2002 (Reference 2) and February 26, 2003 (Reference 3), Entergy Nuclear Operations, Inc. (ENO) requested to amend the Indian Point 2 (IP2) Plant Operating License, Appendices A and B, "Technical Specifications." The proposed amendment converts the IP2 Current Technical Specifications (CTS) to Improved Technical Specifications (ITS) in accordance with NUREG 1431, "Standard Technical Specifications Westinghouse Plants," (Reference 4), and the Code of Federal Regulations (CFR) (Reference 5).

The U.S. Nuclear Regulatory Commission (NRC) staff reviewing the request has determined that additional information is required to complete its review. The request for additional information is dated January 22, 2003 (Reference 6). A list of acronyms that may have been used in this submittal has been provided as Attachment 1 to this letter. Attachment 2 to this letter, "Response to Request for Additional Information Regarding Section 3.3 of the Improved Technical Specifications (ITS)," provides ENO's response to the subject request for additional information. The IP2 Actions described in will be incorporated in a future supplement to the ITS submittal packages.

As indicated in ENO's letter dated December 18, 2002 (Reference 7), our planned implementation date for the ITS amendment is September 30, 2003. Therefore, ENO respectfully requests an approved Safety Evaluation Report (SER) in time to support the indicated implementation date.

There are no commitments contained in this letter.

Should you or your staff have any questions regarding this matter, please contact the IP2 ITS Project Manager, Mr. William Blair at (914) 734-5336.

I declare under penalty of perjury that the foregoing is true and correct.

Sincerely, Executed on B 03 -_ __l_ __

d R. Dacimo Vice President, Operations Attachments cc: See page 3

NL-03-052 Page 3 of 3 cc:

Mr. Hubert J. Miller Regional Administrator-Region I U.S. Nuclear Regulatory Commission 475 Allendale Road King of Prussia, PA 19406 Mr. Patrick D. Milano, Senior Project Manager, Section 1 Project Directorate I Division of Licensing Project Management U.S. Nuclear Regulatory Commission Mail Stop 0-8-2C Washington, DC 20555 Senior Resident Inspector U.S. Nuclear Regulatory Commission P.O. Box 38 Buchanan, NY 10511 Mayor, Village of Buchanan 236 Tate Avenue Buchanan, NY 10511 Mr. Paul Eddy NYS Department of Public Service 3 Empire State Plaza Albany, NY 12223-1350 Mr. William Flynn NYS ERDA Corporate Plaza West 286 Washington Ave. Extension Albany, NY 12203

ATTACHMENT 1 TO NL-03-052 List of Acronyms That May Be Used In This Submittal Entergy Nuclear Operations, Inc.

Indian Point Unit No. 2 Docket No. 50-247

NL-03-052 Attachment 1 Page 1 of 2 List of Acronyms That May Be Used In This Submittal AC Air Conditioning or Alternating Current AOT Allowed Outage Time ASME American Society of Mechanical Engineers ASTM American Society for Testing and Materials ATWS Anticipated Transient Without Scram BIT Boron Injection Tank CFR Code of Federal Regulations CLB Current License Basis COLR Core Operating Limits Report COT Channel Operational Test CST Condensate Storage Tank CTS Current Technical Specification DB Design-Basis DBA Design-Basis Accident DC Direct Current DG Diesel Generator DOC Discussion of Change (from the CTS)

ECCS Emergency Core Cooling System EDG Emergency Diesel Generator ESF Engineered Safeguard Feature FR Federal Register GDC General Design Criteria HEPA High Efficiency Particulate Air Hz Hertz IRM Intermediate Range Monitor ISI Inservice Inspection ITS Improved (converted) Technical Specifications JFD Justification For Difference kV Kilovolt kW Kilowatt LAR Licence Amendment Request LCO Limiting Condition for Operation LOCA Loss of Coolant Accident LOOP Loss of Offsite Power LOP Loss of Power MSIV Main Steam Isolation Valve MSLB Main Steam Line Break NUMAC Nclear Measurement Analysis and Control PAM Post-Accident Monitoring P/T Pressure/Temperature QA Quality Assurance RAI Request for Additional Information

NL-03-052 Attachment 1 Page 2 of 2 RCS Reactor Coolant System RG Regulatory Guide RHR Residual Heat Removal RPS Reactor Protection System RPV Reactor Pressure Vessel RTP Rated Thermal Power SDC Shutdown Cooling SDM Shutdown Margin SE Safety Evaluation SER Safety Evaluation Report SR Surveillance Requirement SRM Source Range Monitor STS Improved Standard Technical Specification(s), NUREG-1431, Rev. 2 SW Service Water TRM Technical Requirements Manual TS Technical Specifications TSTF Technical Specifications Task Force (re: generic changes to the STS)

ATTACHMENT 2 TO NL-03-052 Response to Request for Additional Information Regarding Section 3.3 of the Improved Technical Specifications (ITS)

Entergy Nuclear Operations, Inc.

Indian Point Unit No. 2 Docket No. 50-247

NL-03-052 Attachment 2 Page 1 of 89 Response to Request for Additional Information The NRC Staff reviewing information provided in the March 27, 2002 license amendment request, as supplemented by letters dated July 10, 2002 and February 26, 2003, has determined that additional information is required to complete its review. The following are the specific requests from the NRC staff and ENO's response to those requests.

NL-03-052 Attachment 1 Page 2 of 89 3.3.2: Engineered Safety Feature Actuation System (ESFAS)

Instrumentation NRC RAI Number TAC Number:

3.3.2 - 1 MB4739 NRC Request for Additional Information (RAI):

RAI 3.3.2.01 (Item 1)

CTS: 3.5.1 DOC A.33 CTS require that during specified operations the initiation instrumentation settings limits shall be as stated in Table 3.5-1. In the ITS, this CTS requirement is deleted. DOC A.33 discusses the change in the context of establishing applicability requirements for each ESFAS function in ITS 3.3.2, Table 3.3.2-

1. Revise justification A.33 to include discussion regarding initiation instrumentation settings.

Entergy (IP2) Response:

CTS 3.5.1 specifies that "When the plant is not in the cold shutdown condition, the Engineered Safety Features initiation instrumentation setting limits shall be as stated in Table 3.5-1."

ITS DOC A.33 was intended to explain that in addition to the global statement in CTS 3.5.1 that ESFAS functions must be Operable when the plant is not in cold shutdown condition, CTS also provides an explicitly stated or inferred Applicability requirement for each of the ESFAS functions. It is the function specific or inferred Applicability for each ESFAS function that is maintained in ITS 3.3.2, Table 3.3.2-1.,

or addressed in the DOCs. The markup of CTS 3.5.1 and the discussion in DOC A.33 were not intended to show any change to the fact that the Engineered Safety Features initiation instrumentation setting limits are listed in CTS Table 3.5-1. In fact, ITS 3.3.2 will maintain instrumentation setting limits in an equivalent ITS Table (i.e., ITS Table 3.3.2-1.)

IP2 revised markup of CTS 3.5.1 to show that DOC A.33 applies only to the phrase "When the plant is not in the cold shutdown condition" and that settings currently maintained in CTS Table 3.5-1 will be maintained in ITS Table 3.3.2-1 except as modified by the changes described and justified in DOC L.1 (i.e., conversion to allowable values based on an approved methodology). IP2 also revised DOC A.33 to clarify discussion consistent with the changes to the markup.

Entergy (1P2) Action:

Revised markup of CTS 3.5.1 to show that DOC A.33 applies only to the phrase "When the plant is not in the cold shutdown condition" and that settings currently maintained in CTS Table 3.5-1 will be maintained in ITS Table 3.3.2-1 except as modified by the changes described and justified in DOC L.1 (i.e., conversion to allowable values based on an approved methodology). Revised DOC A.33 to clarify discussion consistent with the changes to the markup.

Questions regarding this response should be directed to Dick Bense at (914) 734-5895 (RBENS90@Entergy.Com) or Bill Blair at (914) 737-4167 (WBlair@Entergy.Com).

NL-03-052 Attachment 1 Page 3 of 89 3.3.2: Engineered Safety Feature Actuation System (ESFAS)

Instrumentation NRC RAI Number TAC Number:

3.3.2 - 2 MB4739 NRC Request for Additional Information (RAI):

RAI 3.3.2.02 (Item 3)

CTS: 3.5.2 DOC L.2 This DOC write-up includes CTS changes for A.34, that during specified operations the initiation instrumentation settings limits shall be as stated in Table 3.5-1. and for L.2, that by definition, an instrument channel failure shall not be regarded as a channel being tested. Explain their connection/dependency. Also, DOC L.2 doesn't evaluate the proposed CTS 3.5.2 deletion.

Entergv (1P2) Response:

CTS 3.5.2 specifies that "plant operation shall be permitted to continue in accordance with Tables 3.5-2 through 3.5-4. No more than one channel of a particular protection channel set shall be tested at the same time. By definition, an instrumentation channel failure shall not be regarded as a channel being tested."

The first sentence, "plant operation shall be permitted to continue in accordance with Tables 3.5-2 through 3.5-4," refers to requirements to maintain both a minimum number of operable channels and a minimum degree of redundancy as defined in CTS 1.5, Degree of Redundancy. Basically, this means that operation may continue with up to one inoperable channel if the inoperable channel is placed in trip within the allowable out of service time. This is explained in ITS 3.3.2, DOC A.37. ITS 3.3.2, Required Actions, maintain identical requirements which are explained in detail in DOCs A.03.c and A.03.d through A.31.c and A.31.d. Any differences between the CTS and the ITS for a specific function are identified in these DOCs and justified in an associated M DOC or L DOC.

The second sentence, "No more than one channel of a particular protection channel set shall be tested at the same time," is intended to ensure that a channel being tested is treated as inoperable. As explained above and in ITS 3.3.2, DOC A.34, CTS Tables 3.5-2 through 3.5-4 permit no more than one channel to be inoperable at one time except as allowed in CTS 3.5.4. CTS 3.5.4 allows an inoperable channel that is in trip to be bypassed to permit testing of the remaining operable channels without causing a reactor trip. ITS 3.3.2, Required Actions and associated Notes, maintain identical requirements which are explained in detail in DOCs A.03.c and A.03.d through A.31.c and A.31.d. Any differences between the CTS and the ITS for a specific function are identified in these DOCS and justified in an associated M DOC or L DOC.

The third sentence, "By definition, an instrumentation channel failure shall not be regarded as a channel being tested," is intended to prevent the assumption that operators can delay or avoid taking the actions for an inoperable channel by treating the failed channel as a channel being tested. ITS 3.3.2, Required Actions and associated Notes, in combination with the ITS definition of Operability will prevent treating an inoperable channel as a channel in test.

Questions regarding this response should be directed to Dick Bense at (914) 734-5895 (RBENS90@Entergy.Com) or Bill Blair at (914) 737-4167 (WBlair@Entergy.Com).

NL-03-052 Attachment 1 Page 4 of 89 Based on the above, deletion of CTS 3.5.2 is an administrative change because ITS will maintain equivalent restrictions preventing "more than one channel of a particular protection channel set shall be tested at the same time" and ensuring that a "channel failure shall not be regarded as a channel being tested."

Entergy (1P2) Action:

IP2 will revise ITS 3.3.2, DOC A.34 to include the discussion above and will mark DOC L.2 as "Not Used."

Questions regarding this response should be directed to Dick Bense at (914) 734-5895 (RBENS90@Entergy.Com) or Bill Blair at (914) 737-4167 (WBlair@Entergy.Com).

NL-03-052 Attachment 1 Page 5 of 89 3.3.2: Engineered Safety Feature Actuation System (ESFAS)

Instrumentation NRC RAI Number TAC Number:

3.3.2 - 3 MB4739 NRC Request for Additional Information (RAI):

RAI 3.3.2.03 (Item 4)

CTS: 3.5.2 and 3.5.3 ITS: Required Action A.1 Both CTS 3.5.2 and 3.5.3 are marked up to show they represent ITS Required Action A.1. One, not both CTS requirements can be Required Action A.1.

Entergy (IP2) Response:

ITS LCO 3.3.2, Condition A, reads: "One or more Functions with one or more required channels or trains inoperable." Required Action A.1 reads: "Enter the Condition referenced in Table 3.3.2-1 for the channel(s) or train(s)." Condition A and Required Action A.1 are essentially a pointer that directs entry into the Actions listed on Table 3.3.2-1 when a channel or train is inoperable.

CTS 3.5.2 reads: "For instrumentation channels, plant operation at rated power shall be permitted to continue in accordance with Tables 3.5-2 through 3.5-4." The phrase "plant operation ... shall be permitted to continue" indicates that CTS 3.5.2 is essentially a pointer that directs entry into the Actions listed on Tables 3.5-2 through 3.5-4 when a channel or train is inoperable.

CTS 3.5.3 reads: "In the event the number of channels of a particular function in service falls below the limits given in the column entitled Minimum Operable Channels, or Minimum Degree of Redundancy cannot be achieved, operation shall be limited according to the requirements shown in Column 5 or 6 of Tables 3.5-2 through 3.5-4." The phrase "operation shall be limited according to the requirements shown in Column 5 or 6 of Tables 3.5-2 through 3.5-4" indicates that CTS 3.5.3 is essentially another pointer that directs entry into the Actions listed on Tables 3.5-2 through 3.5-4 when a channel or train is inoperable.

IP2 believes that both CTS 3.5.2 and CTS 3.5.3 duplicate the function performed in ITS LCO 3.3.2, Condition A.

Entergy (IP2) Action:

None.

Questions regarding this response should be directed to Dick Bense at (914) 734-5895 (RBENS90@Entergy.Com) or Bill Blair at (914) 737-4167 (WBlair@Entergy.Com).

NL-03-052 Attachment 1 Page 6 of 89 3.3.2: Engineered Safety Feature Actuation System (ESFAS)

Instrumentation NRC RAI Number TAC Number:

3.3.2 - 4 MB4739 NRC Request for Additional Information (RAI):

RAI 3.3.2.04 (Item 5)

CTS: Table 3.5-3, Item 4.a.i (Start Motor Driven Pumps),

Table 3.5-3,Item 4.a.ii (Start Turbine Driven Pumps)

ITS: Table 3.3.2, Function 6.b (Auxiliary Feedwater - SG Water Level - low low)

ITS proposes to represent two CTS items with one ITS function, however, the pump start logics in column 2 of Table 3.5-3 are different, in addition the logics start different pumps, thus it is unclear how a single ITS function can represent two CTS items. Revise Table 3.3.2-1, Function 6.b into two functions per CTS Table 3.5-3, items 4.a.i and 4.a.ii showing 4.a.i logic is 2 out of 3 in any steam generator and 4.a.ii is 2 out of 3 in each of two steam generators.

Entergy (IP2) Response:

CTS Table 3.5-3, Item 4.a.i (Start Motor Pumps) specifies that the SG Water Level Low-Low Trip must have a minimum of 2 operable channels per generator with a minimum degree of redundancy of 1 channel per generator (i.e., 3 channels must be Operable or 2 channels must be Operable with the third channel in trip in each of the 4 SGs). If two out of three channels in any one SG are in trip, the Automatic Actuation Logic and Actuation Relays associated with this function will start the motor driven AFW pumps.

CTS Table 3.5-3, Item 4.a.ii (Start Turbine Driven Pump) specifies that the SG Water Level Low-Low Trip must have a minimum of 2 operable channels per generator with a minimum degree of redundancy of 1 channel per generator (i.e., 3 channels must be Operable or 2 channels must be Operable with the third channel in trip in each of the 4 SGs). If two out of three channels in any two SGs are tripped, the Automatic Actuation Logic and Actuation Relays associated with this function will start the turbine driven AFW pump.

Under both CTS and ITS, if a SG Water Level Low-Low channel becomes inoperable, that channel is placed in trip. Placing that one channel in trip satisfies the Actions for both CTS Table 3.5-3, Item 4.a.i and CTS Table 3.5-3, Item 4.a.ii. Therefore, at the channel level, CTS Table 3.5-3, Item 4.a.i and CTS Table 3.5-3, Item 4.a.ii, are the same Function. (Note that the same placing the channel in trip also satisfies Required Actions for ITS 3.3.1, Function 14, the reactor trip on SG Water Level Low-Low.)

Therefore, ITS 3.3.2, Function 6.b, SG Water level Low-Low, addresses both CTS line items. (See UFSAR Figure 7.2-10).

Up to the point where the SG Water Level Low-Low channels combine into the two out of three logic, the Functions have channel identity. At the point that SG Water Level Low-Low channels combine into the two out of three logic, the Function assumes train identity and the differences implied by separate line entries for CTS Table 3.5-3, Item 4.a.i and CTS Table 3.5-3, Item 4.a.ii is addressed by ITS 3.3.2, Function 6.a, Automatic Actuation Logic and Actuation Relays. (See UFSAR Figure 7.2-8)

Questions regarding this response should be directed to Dick Bense at (914) 734-5895 (RBENS90@Entergy.Com) or Bill Blair at (914) 737-4167 (WBlair@Entergy.Com).

NL-03-052 Attachment 1 Page 7 of 89 Therefore, the failure of any SG Water Level Low-Low channel would require entry in a Condition for both ITS 3.3.1, Function 14, and ITS 3.3.2, Function 6.b. However, the failure of any combination of channels to start the motor driven AFW pumps and / or turbine driven AFW pump as described in the Bases would result in entry into ITS 3.3.2, Condition G, for an inoperable train of ITS 3.3.2, Function 6.a, Automatic Actuation Logic and Actuation Relays.

Entergy (IP2) Action:

None Questions regarding this response should be directed to Dick Bense at (914) 734-5895 (RBENS90@Entergy.Com) or Bill Blair at (914) 737-4167 (WBlair@Entergy.Com).

NL-03-052 Attachment 1 Page 8 of 89 3.3.2: Engineered Safety Feature Actuation System (ESFAS)

Instrumentation NRC RAI Number TAC Number:

3.3.2 - 5 MB4739 NRC Request for Additional Information (RAI):

RAI 3.3.2.05 (Item 6)

DOC A.30 CTS: Table 3.5-3, Item 4.c, Station Blackout Start Motor-Driven and Turbine Driven Pumps ITS: Table 3.3.2-1, Function 6.d CTS nomenclature for AFW start of Motor-Driven and Turbine Driven Pumps on Station Blackout is revised in the ITS to Undervoltage (Emergency Bus 5A or 6A). This nomenclature change is not explained. It appears that the change loses the identity of the trip functions which are better preserved with the NUREG nomenclature, "Loss of Offsite Power Start of AFW Pumps". Provide appropriate change discussion, or cite existing plant documents which generated this proposed change.

Entergy (IP2) Response:

IP2 will revise the name of CTS Table 3.5-3, Item 4.c, Station Blackout Start Motor-Driven and Turbine Driven Pumps, to ITS 3.3.2, Function 6.d, Station Blackout (SBO) (Undervoltage Bus 5A or Bus 6A).

This nomenclature was selected because it is consistent with plant nomenclature. The same name will be used in ITS 3.3.5 where this function is being added to LCO 3.3.5, Loss of Power (LOP) Diesel Generator (DG) Start Instrumentation" as described in the response to RAI 3.3.5-1. The suggested term, "Loss of Offsite Power Start of AFW Pumps," is not appropriate because IP2 480 V buses 2A/3A are supplied by the main generator. Therefore, plant trip is also needed to get the actuation.

This change in nomenclature will be described in DOC A.30. ITS 3.3.2 Bases also needs to be revised to explain the role of the Station Blackout (SBO) (Undervoltage Bus 5A or Bus 6A) relays on DG start sequence.

Entergy (IP2) Action:

IP2 will revise the name of CTS Table 3.5-3, Item 4.c, Station Blackout Start Motor-Driven and Turbine Driven Pumps, to ITS 3.3.2, Function 6.d, Station Blackout (SBO) (Undervoltage Bus 5A or Bus 6A).

This change in nomenclature will be described in DOC A.30. ITS 3.3.2 Bases also needs to be revised to explain the role of the Station Blackout (SBO) (Undervoltage Bus 5A or Bus 6A) relays on DG start sequence.

Questions regarding this response should be directed to Dick Bense at (914) 734-5895 (RBENS90@Entergy.Com) or Bill Blair at (914) 737-4167 (WBlair@Entergy.Com).

NL-03-052 Attachment 1 Page 9 of 89 3.3.2: Engineered Safety Feature Actuation System (ESFAS)

Instrumentation NRC RAI Number TAC Number:

3.3.2 - 6 MB4739 NRC Request for Additional Information (RAI):

RAI 3.3.2.06 (Item 7)

DOC M.1 CTS: 3.5.3, 3.5.4 ITS C.1, D.1, E.1, G.1 In the event of a subsystem instrumentation channel failure, the CTS state that the requirements of Tables 3.5-2 through 3.5-4 (Instrumentation Operating Conditions for Engineered Safety Features) need not be observed "'short period of time". In the ITS a "short period of time" becomes the bypass allowed outage times (AOTs) in ITS Required Actions C.1, D.1, E.1 and G.1. The bypass AOTs contained in the NUREG are based on the staff SE for topical reports WCAP-10271 and WCAP-14333. Provide a SE citation that show these bypass allowances are approved for use at IP2 or submit information required for plant specific use of topical report allowances.

Entergy (IP2) ResDonse:

The SER associated with IP2 CTS Amendment 212, dated November 30, 2000, approved adoption of allowable out of service times (AOTs) consistent with WCAP-14333-P-A, Rev.1, 'Probabilistic Risk Analysis of the RPS and ESFAS Test Times and Completion Times.' Conformance with the requirements of WCAP-10271 is a prerequisite for adopting WCAP-14333.

The SER associated with IP2 CTS Amendment 154, dated November 30, 2000, approved adoption of testing in bypass for those functions that have installed bypass capability. Additionally, this SER approved extending surveillance test intervals for channel functional tests from monthly to 92 days based on the verification that IP2 instrumentation systems conformed to WCAP-10271. A copy of CTS Amendment 154 including the associated SER was provided to the NRC on July 16, 2002.

CTS 3.5.3 provides the allowance for testing and maintenance in bypass without restricting IP2 to the time limits specified in WCAP-14333 and CTS 3.5.4 allows bypassing an inoperable channel in trip for testing of other channels using the term 'a short period of time' instead of the time limits specified in WCAP-14333. However, the CTS Bases (Page 3.5-6) provide the clarification that time in Bypass is limited to the times in WCAP-14333. Administrative controls enforce these time limits. The Applicable excerpt from the CTS Bases follow:

"The Functional Units having risk informed AOTs are identified with either (1) or (2) in column 6 of Tables 3.5-2 through 3.5-4. Risk informed AOTs for analog channels (72 hours8.333333e-4 days 0.02 hours 1.190476e-4 weeks 2.7396e-5 months ) and logic channels (24 hours2.777778e-4 days 0.00667 hours 3.968254e-5 weeks 9.132e-6 months ) are based on the analysis provided in Reference 5. Specification 3.5.3 allows the minimum degree of redundancy to be reduced by one for on-line testing (and corrective maintenance for inoperable instrumentation discovered during the surveillance testing) of instruments with installed bypass capability. For analog channels, this test bypass allowance is limited to 12 hours1.388889e-4 days 0.00333 hours 1.984127e-5 weeks 4.566e-6 months consistent with Reference 5. For logic channels, this test bypass allowance is limited to eight hours as provided in Note

of Tables 3.5-2 and 3.5-3 and consistent with Reference 5. At the end of this test bypass allowance, Questions regarding this response should be directed to Dick Bense at (914) 734-5895 (RBENS9OQEntergy.Com) or Bill Blair at (914) 737-4167 (WBlair@Entergy.Com).

NL-03-052 Attachment 1 Page 10 of 89 the requirements of Tables 3.5-2 through 3.5-4 and associated notes must be complied with. The test bypass allowance does not apply to the performance of preventative maintenance or performance of maintenance for inoperable instrumentation discovered by other means than the performance of a surveillance test." Note that Reference 5 is WCAP-14333, "Probabilistic Risk Analysis of the RPS and ESFAS Test Times and Completion Times" IP2 will revise ITS 3.3.1, DOC M.01, and ITS 3.3.2, DOC M.01, to further clarify that the ITS adoption of the allowable out of service times (AOTs) from WCAP-1433 in the Technical Specifications (rather than the Bases as is done in CTS) is a more restrictive change because it creates explicit Technical Specification limits for instrumentation AOTs that were approved by IP2 CTS Amendment 212.

Entergy (I1P2) Action:

IP2 will revise ITS 3.3.1, DOC M.01, and ITS 3.3.2, DOC M.1, to further clarify that the ITS adoption of the allowable out of service times (AOTs) from WCAP-1433 in the Technical Specifications (rather than the Bases) is a more restrictive change because it creates explicit Technical Specification limits for instrumentation AOTs that were approved by IP2 CTS Amendment 212 but only specified in the Bases.

Questions regarding this response should be directed to Dick Bense at (914) 734-5895 (RBENS90@Entergy.Com) or Bill Blair at (914) 737-4167 (WBIair@Entergy.Com).

NL-03-052 Attachment 1 Page 11 of 89 3.3.2: Engineered Safety Feature Actuation System (ESFAS)

Instrumentation NRC RAI Number TAC Number:

3.3.2 - 7 MB4739 NRC Request for Additional Information (RAI):

RAI 3.3.2.07 (Item 8)

ITS: Table 3.3.2-1, insert 3.3.2-14-01 (Auxiliary Feedwater)

The insert proposes note (f), a notation that limits the applicability of AFW start on Trip of Main Boiler Feedwater Pumps to "not required if AFW pump is not required to be Operable" in Modes 1 and 2.

These proposed notes deviate from the NUREG presentation for AFW actuation functions. This information is related to design detail and rules for TS usage and therefore represent information that belong in procedures or other owner controlled documents.

Entergv (IP2) Response:

IP2 will delete Note (f) to Table 3.3.2-1 and relocate this information to the Bases.

Entergy (IP2) Action:

IP2 will delete Note (f) to Table 3.3.2-1 and relocate this information to the Bases.

Questions regarding this response should be directed to Dick Bense at (914) 734-5895 (RBENS90@Entergy.Com) or Bill Blair at (914) 737-4167 (WBlair@Entergy.Com).

NL-03-052 Attachment 1 Page 12 of 89 3.3.2: Engineered Safety Feature Actuation System (ESFAS)

Instrumentation NRC RAI Number TAC Number:

3.3.2 - 8 MB4739 NRC Request for Additional Information (RAI):

RAI 3.3.2.08 (Item 9)

CTS Table 3.5-3, item 6, Engineered Safety Feature (SI) Logic Provide an L-DOC discussion for deleting this CTS functional unit.

Entergy (IP2) Response:

IP2 Amendment 212 revised the IP2 CTS to incorporate allowances justified in WCAP-14333-P-A, Rev.1, Probabilistic Risk Analysis of the RPS and ESFAS Test Times and Completion Times. Specifically, Amendment 212 authorized a Completion Time of 72 hours8.333333e-4 days 0.02 hours 1.190476e-4 weeks 2.7396e-5 months for restoring an inoperable channel or placing it in trip, a Completion Time of 24 hours2.777778e-4 days 0.00667 hours 3.968254e-5 weeks 9.132e-6 months for restoring an inoperable logic or relay train, an allowance of 12 hours1.388889e-4 days 0.00333 hours 1.984127e-5 weeks 4.566e-6 months for in bypass for testing channels, and an allowance of 8 hours9.259259e-5 days 0.00222 hours 1.322751e-5 weeks 3.044e-6 months for testing logic and relay trains. Note that some allowances apply to individual channels and other allowances apply to trains of logic or trains of actuation relays.

CTS Tables 3.5-3 and 3.5-4 identify ESFAS channels; however, prior to Amendment 212, CTS Tables 3.5-2 through 3.5-4 did not identify any requirements equivalent to the STS (NUREG-1431) line items identified as "Automatic Actuation Logic and Actuation Relays" (i.e., logic trains). This omission didn't matter prior to Amendment 212 because the allowable out of service time (i.e., time to restore or trip an inoperable channel and time to restore an inoperable train) was not explicitly stated and was assumed to be "within one hour" for both inoperable channels and trains. However, when WCAP-14333 justified different Completion Times for channels and trains, CTS Tables 3.5-3 and 3.5-4 did not provide a line item for the logic and relay trains that could be modified.

CTS should have added a line item for "Automatic Actuation Logic and Actuation Relays" (i.e., logic trains) for each safety function shown as a major heading in CTS Tables 3.5-3 and 3.5-4 (i.e., Safety Injection, Containment Spray, Auxiliary Feedwater, Containment Isolation (Phase A and Phase B),

Steam Line Isolation, and Feedwater Isolation). These new line items would each require 1 operable train with a minimum degree of redundancy of 1 train and include an allowance permitting a reduction in the required degree of redundancy for 8 hours9.259259e-5 days 0.00222 hours 1.322751e-5 weeks 3.044e-6 months for testing and 24 hours2.777778e-4 days 0.00667 hours 3.968254e-5 weeks 9.132e-6 months while restoring an inoperable train.

CTS Amendment 212, instead of adding line items for logic trains, moved CTS Table 3.5-2, Item 18.a, Engineered Safety Features (SI) Logic (i.e., requirement that an SI signal must initiate a reactor trip), to CTS Table 3.5-3, as Item 6, as a requirement for two trains of SI actuation logic and relays. CTS Table 3.5-3, Note #, was added to incorporate the WCAP-14333 allowance of 24 hours2.777778e-4 days 0.00667 hours 3.968254e-5 weeks 9.132e-6 months for restoration and 8 hours9.259259e-5 days 0.00222 hours 1.322751e-5 weeks 3.044e-6 months for bypassing a logic train. No similar line item for "Automatic Actuation Logic and Actuation Relays" was added to CTS Table 3.5-3 for Containment Spray or Auxiliary Feedwater because the CTS Table 3.5-3, Item 6, (SI) Logic, was intended to apply to all three types of ESFAS functions.

Similarly, instead of adding line items for "Automatic Actuation Logic and Actuation Relays" for Questions regarding this response should be directed to Dick Bense at (914) 734-5895 (RBENS9O@Entergy.Com) or Bill Blair at (914) 737-4167 (WBlair@Entergy.Com).

NL-03-052 Attachment 1 Page 13 of 89 Containment Isolation (Phase A and Phase B), Steam Line Isolation, and Feedwater Isolation to CTS Table 3.5-4, CTS Amendment 212 conservatively added Note (1) which assigned a Completion Time of 24 hours2.777778e-4 days 0.00667 hours 3.968254e-5 weeks 9.132e-6 months (versus 72 hours8.333333e-4 days 0.02 hours 1.190476e-4 weeks 2.7396e-5 months allowed by WCAP-14333) and a bypass time of 8 hours9.259259e-5 days 0.00222 hours 1.322751e-5 weeks 3.044e-6 months (versus 72 hours8.333333e-4 days 0.02 hours 1.190476e-4 weeks 2.7396e-5 months allowed by WCAP-14333) to the following CTS Functions: 1.a, Automatic Safety Injection (Phase A)

(i.e., an SI signal must initiate a Phase A isolation); 1.b, Containment Pressure (phase B), 2.a High Steam Flow coincident with Low Tave or Steam Line Pressure; and 2.b, High Containment Pressure (Hi-Hi Level).

ITS Conversion Package 3.3.2 incorporated the allowances that were already justified in WCAP-14333 and approved by the staff in the SER for Amendment 212 as follows:

ITS DOCs added line items for "Automatic Actuation Logic and Actuation Relays" for ITS 3.3.2, Function 1.b. Safety Injection, in DOC A.04; ITS 3.3.2, Function 2.b, Containment Spray, as described in DOC A.11; ITS 3.3.2, Function 3.a.(2), Containment Phase A Isolation, as described in DOC A.14; ITS 3.3.2, Function 3.b.(2) Containment Phase B Isolation, as described in DOC A.17; ITS 3.3.2, Function 4.b, Steam Line Isolation, as described in DOC A.20; ITS 3.3.2, Function 5.a, Feedwater Isolation, as described in DOC A.24; and ITS 3.3.2, Function 6.a, Auxiliary Feedwater, as described in DOC A.27.

DOC L.3 and the various A DOCS explained that these functions were assigned a Completion Time of 24 hours2.777778e-4 days 0.00667 hours 3.968254e-5 weeks 9.132e-6 months for restoring an inoperable logic or relay train and an allowance of 8 hours9.259259e-5 days 0.00222 hours 1.322751e-5 weeks 3.044e-6 months for testing logic and relay trains which was already justified in WCAP-14333 and approved by the staff in the SER for Amendment 212.

For consistency, the "Automatic Actuation Logic and Actuation Relays" for ITS 3.3.2, Function 1.b, Safety Injection, was treated as if it was a new line item and not related to CTS Table 3.5-3, Item 6.

CTS Table 3.5-3, Item 6, was restored to ITS 3.3.1, as Function 16 in ITS 3.3.1, DOC M.13. ITS 3.3.2, DOC A.39, explains that CTS Table 3.5-3, Item 6, was intended to represent requirements for "Automatic Actuation Logic and Actuation Relays" and is addressed in DOCS A.04 and DOC L.3.

IP2 will revise ITS 3.3.2, DOC A.04, DOC A.39 and DOC L.3 to provide additional clarification of the issues described above.

Entergy (IP2) Action:

IP2 will revise ITS 3.3.2, DOC A.04, DOC A.39 and DOC L.3 to provide additional clarification of the issues described above.

Questions regarding this response should be directed to Dick Bense at (914) 734-5895 (RBENS90@Entergy.Com) or Bill Blair at (914) 737-4167 (WBlair@Entergy.Com).

NL-03-052 Attachment 1 Page 14 of 89 3.3.2: Engineered Safety Feature Actuation System (ESFAS)

Instrumentation NRC RAI Number TAC Number:

3.3.2 - 9 MB4739 NRC Request for Additional Information (RAI):

RAI 3.3.2.09 (Item 10)

DOC M.5 DOC A.37 CTS: Table 3.5-3, item 4.J (sic)( Item 4.c)

ITS: Table 3.3.2-1, F6.d Revise the ITS applicability per CTS mark up (Table 3.5-3, item 4.i) to "3 per bus" Entercly (IP2) Response:

IP2 will revise ITS 3.3.2, Function 6.d, Auxiliary Feedwater-Station Blackout (SBO) (Undervoltage Bus 5A or Bus 6A) (See Response to RAI 3.3.2-5 for name change) to require 3 channels per bus. In conjunction with this change, ITS 3.3.2 will be revised to include new Conditions J, K and L to address inoperable channels and/or trains of the SBO function. As described in the response to RAI 3.3.5-1, ITS 3.3.5 will also be revised to include 3 channels per bus of the Station Blackout (SBO) (Undervoltage Bus 5A or Bus 6A) with parallel requirements for the Loss of Power (LOP) Diesel Generator (DG) Start Instrumentation. ITS 3.3.2, DOCs A.30 and M.5 will be revised accordingly.

CTS Table 3.5-3, Function 4.c, Auxiliary Feedwater-Station Blackout (Start Motor Driven and Turbine Driven Pumps), requires 1 operable channel with a minimum degree of redundancy of zero. This is interpreted as requiring that the Function be Operable for either bus 5A or 6A. This is consistent with drawing 9321-LL-3117, Sheets 3, 3A and 3B, Schematic Diagram 480 VAC Interlocking Relays, which show that the SBO 480 V bus undervoltage Function has three relays on bus 5A and three relays on bus 6A. For bus 5A, the relays are 27-51 (Phase A-B), 27-52 (Phase B-C), and 27-53 (Phase C-A). For bus 6A, the relays are (27-61 (Phase A-B), 27-62 (Phase B-C), and 27-63 (Phase C-A). The SBO function actuates on two of three channels on either bus 5A or Bus 6A. The setpoints, approximately 46 percent of nominal, are designed to provide a fast trip response under complete loss-of-power ("dead bus")

conditions of either of the two buses that provide all offsite power to the plant safety systems.

Therefore, the CTS Table 3.5-3, Function 4.c, meets requirements for redundancy using only one of the two buses equipped with this function. Therefore, Required Actions for the inoperable Auxiliary Feedwater-SBO (Undervoltage Bus 5A or Bus 6A) will be as follows:

Condition J: One SBO Undervoltage channel inoperable.

Req. Action: Place channel in trip within 14 days. (Note that Separate Condition entry is allowed for each bus.) (Bases will justify 14 day Completion Time based on fact that SBO Function still has redundancy even with one channel from each bus inoperable because two channels from either bus will initiate the SBO function for both AFW pumps and DG starting.)

Condition K: One SBO train with two or more channels inoperable. (Bases will explain that this Condition applies even if one of the channels is already in trip as required by Condition J).

Req. Action: Restore SBO train to OPERABLE status within 48 hours5.555556e-4 days 0.0133 hours 7.936508e-5 weeks 1.8264e-5 months (Bases will define an Operable Questions regarding this response should be directed to Dick Bense at (914) 734-5895 (RBENS90@Entergy.Com) or Bill Blair at (914) 737-4167 (WBIair@Entergy.Com).

NL-03-052 Attachment 1 Page 15 of 89 SBO train as having either three Operable channels or two Operable channels with the third channel in trip.) (Bases will justify 48 hour5.555556e-4 days 0.0133 hours 7.936508e-5 weeks 1.8264e-5 months Completion Time based on fact that SBO Function still has redundancy even with one channel from each bus inoperable because two channels from either bus will initiate the SBO function.)

Condition L: Required Action and Completion Time of Condition J or Knot met.

Req. Action: Be in Mode 3 within 6 hours6.944444e-5 days 0.00167 hours 9.920635e-6 weeks 2.283e-6 months and Mode 4 within 18 hours2.083333e-4 days 0.005 hours 2.97619e-5 weeks 6.849e-6 months . (Note that this is consistent with inoperable AFW pumps.) If the inoperable SBO train also affects DG Operability, ITS 3.3.5 will require that the plant proceed to Mode 5 within 36 hours4.166667e-4 days 0.01 hours 5.952381e-5 weeks 1.3698e-5 months .

Entergy (IP2) Action:

IP2 will revise ITS 3.3.2, Function 6.d, Auxiliary Feedwater-Station Blackout (SBO) (Undervoltage Bus 5A or Bus 6A) (See Response to RAI 3.3.2-5 for name change) to require 3 channels per bus. In conjunction with this change, ITS 3.3.2 will be revised to include new Conditions J, K and L to address inoperable channels and/or trains of the SBO function. As described in the response to RAI 3.3.5-1, ITS 3.3.5 will also be revised to include 3 channels per bus of the Station Blackout (SBO) (Undervoltage Bus 5A or Bus 6A) with parallel requirements for the Loss of Power (LOP) Diesel Generator (DG) Start Instrumentation. ITS 3.3.2, DOCs A.30 and M.5 will be revised accordingly.

Questions regarding this response should be directed to Dick Bense at (914) 734-5895 (RBENS90@Entergy.Com) or Bill Blair at (914) 737-4167 (WBlair@ Entergy.Com).

NL-03-052 Attachment 1 Page 16 of 89 3.3.2: Engineered Safety Feature Actuation System (ESFAS)

Instrumentation NRC RAI Number TAC Number:

3.3.2- 10 MB4739 NRC Reguest for Additional Information (RAI):

RAI 3.3.2.11 (Item 12)

CTS: Table 3.5-4, item 3 ITS: Table 3.3.2-1, Function 5.a Provide an M-DOC for new function 5.a (Feedwater Isolation on SG Water Level - High, High) Include a design basis discussion for MODES, Required Channels, Conditions, Surveillance Requirements and Allowable Values.

Entergy (IP2) Response:

ITS 3.3.2, DOCs A.25.a through A.25.f, adds the requirement for Operability and Surveillance testing of ITS 3.3.2, Function 5.b, Feedwater Isolation - SG Water Level (High-High), because this Function is assumed to terminate an excessive heat removal due to feedwater system malfunction event in conjunction with reactor protection which is provided by overpower and overtemperature protection (high neutron flux, overtemperature delta T and overpower delta T trips). This requirement is justified in DOC M.8.

ITS 3.3.2, DOCs A.25.a through A.25.f, provide the detailed description and justification of the new requirements as follows:

A.25.a describes changes in Applicability requirements; A.25.b describes changes in requirements for number of Operable channels; A.25.c describes changes to Required Actions for one inoperable channel; A.25.d describes changes for Required Actions for loss of function or extended loss of redundancy; A.25.e describes changes for Surveillance requirements; and, A.25.f describes changes for Allowable Values and Setpoints.

These descriptions reference discussions of change that justify any more or less restrictive changes that are described.

IP2 will add a reference to ITS 3.3.2, Function 5.b, Feedwater Isolation - SG Water Level (High-High) and DOC A.25 and DOC M.8 to the CTS markup on CTS Table 3.5-1.

Entergy (IP2) Action:

IP2 will add a reference to ITS 3.3.2, Function 5.b, Feedwater Isolation - SG Water Level (High-High) and DOC A.25 and DOC M.8 to the CTS markup on cTS Table 3.5-1. DOC M.8 will be revised to specify that requirements and allowances for SR Frequency and completion Times are based on WCAPs 10272 and 14333. Use of this justification is appropriate because the design is consistent with configurations evaluated in the WCAPs and requirements being incorporated into the ITS (e.g.,

allowable values, SR intervals, etc.) are consistent with similar Functions also governed by WCAPs 10272 and 14333.

Questions regarding this response should be directed to Dick Bense at (914) 734-5895 (RBENS90@Entergy.Com) or Bill Blair at (914) 737-4167 (WBlalr@Entergy.Com).

NL-03-052 Attachment 1 Page 17 of 89 3.3.2: Engineered Safety Feature Actuation System (ESFAS)

Instrumentation NRC RAI Number TAC Number:

3.3.2 - 11 MB4739 NRC Request for Additional Information (RAI):

RAI 3.3.2.14 (Item 15)

ITS 3.3.2, Function L.a, Safety Injection, Manual Initiation DOC M.2, DOC A.3.b Explain the need to discuss actions and CTS when justifying the new 2 channel requirement.

Entergy (IP2) Response:

CTS Table 3.5-3, Item L.a. (Safety Injection) Manual, requires that only one of the two manual initiation channels is Operable. Because only one of the two (Safety Injection) Manual initiation channels is ever required to be Operable, CTS does not specify any actions if one of the two (Safety Injection) Manual channels is inoperable.

ITS 3.3.2, Function l.a., Safety Injection-Manual Initiation, requires that both of the manual initiation channels are Operable. If one of the two channels is inoperable, ITS 3.3.2 includes a new requirement that it be restored to Operable within 48 hours5.555556e-4 days 0.0133 hours 7.936508e-5 weeks 1.8264e-5 months . Therefore, both the addition of a requirement for a second channel and the actions to be taken if that second channel is inoperable are both part of the same more restrictive change.

ITS 3.3.2, DOC A.03, explains the change as follows with additional detail provided in ITS 3.3.2, DOC M.2:

CTS Table 3.5-3, Function 1.a, requires 1 operable channel with a minimum degree of redundancy of zero for the manual initiation function for safety injection.

ITS 3.3.2. Function l.a, Safety Injection-Manual Initiation, requires 2 operable channels for the manual initiation function. This is a more restrictive change. In conjunction with this change, ITS LCO 3.3.2, Required Action B.1, will allow 48 hours5.555556e-4 days 0.0133 hours 7.936508e-5 weeks 1.8264e-5 months to restore an inoperable channel when one of the two channels now required is inoperable.

For a loss of redundancy for the manual trip capability, CTS does not specify any actions because CTS Table 3.5-3 only requires 1 operable channel with a minimum degree of redundancy of zero for the manual initiation function. Under the same conditions, ITS LCO 3.3.2, Action B.1, will require that if one of the two required channels is inoperable (i.e., loss of redundancy but no loss of function) then both channels must be made Operable within 48 hours5.555556e-4 days 0.0133 hours 7.936508e-5 weeks 1.8264e-5 months . This AOT was justified in WCAP-10271-P-A, Supplement 2, Rev. 1, June 1990.

Entergv (IP2) Action:

None.

Questions regarding this response should be directed to Dick Bense at (914) 734-5895 (RBENS90@Entergy.Com) or Bill Blair at (914) 737-4167 (WBlair@Entergy.Com).

NL-03-052 Attachment 1 Page 18 of 89 3.3.2: Engineered Safety Feature Actuation System (ESFAS)

Instrumentation NRC RAI Number TAC Number:

3.3.2 - 12 MB4739 NRC Request for Additional Information (RAI):

RAI 3.3.2.15 (Item 16)

DOCs A.3.c, A.4.c, A.5.c, A.11.c, A.14.c, A.17.c, A.20.c, A.24.c, A.27.c and L.5 These DOCs discuss topical report allowances that are included in the ITS Conditions and SRs but which are not in CTS. Provide an SE citation or submit information required for plant specific use of topical report allowances.

Entergy (IP2) Response:

Issue 1) IP2's adoption of WCAP-14333 allowances for ITS 3.3.2. Function l.a, Safety Injection-Manual Initiation in DOC A.3.c; Issue 2) IP2's adoption of WCAP-14333 allowances for ITS 3.3.2, Function 1.c, Safety Injection-Containment Pressure-High in DOC A.5.c; and Issue 3) IP2's adoption of WCAP-14333 allowances for all of the ESFAS "Automatic Actuation Logic and Actuation Relays" in the following:

--DOC A.4.c, ITS 3.3.2, Function 1.b, Safety Injection-Automatic Actuation Logic and Actuation Relays,

--DOC A.11.c, ITS 3.3.2, Function 2.b, Containment Spray - Automatic Actuation Logic and Actuation

Relays,

--DOC A.14.c, ITS 3.3.2, Function 3.DOC A.(2), Containment Phase A Isolation-Automatic Actuation Logic and Actuation Relays,

--DOC A.17.c, ITS 3.3.2, Function 3.b.(2) Containment Phase B Isolation-Automatic Actuation Logic and Actuation Relays.

Issue 1:

IP2's adoption of WCAP-14333 allowances for ITS 3.3.2. Function 1.a, Safety Injection-Manual Initiation in DOC A.3.c.

DOC A.3.c and DOC M.2 explain that CTS Table 3.5-3 requires only 1 operable channel with a minimum degree of redundancy of zero for the manual initiation function (i.e., only one of the two manual initiation channels must be Operable). Therefore, there are no Actions and no Completion Time for restoration if one of the two channels is inoperable. ITS 3.3.2 will require that both channels of manual initiation are Operable. However, if one of the manual initiation channels is inoperable, ITS 3.3.2 will allow 48 hours5.555556e-4 days 0.0133 hours 7.936508e-5 weeks 1.8264e-5 months for restoration before reactor shutdown is required. The Completion Time of 48 hours5.555556e-4 days 0.0133 hours 7.936508e-5 weeks 1.8264e-5 months for restoration of redundancy for manual initiation Functions for Westinghouse plants was justified in WCAP-10271-P-A, Supplement 2, Rev. 1, June 1990. The addition of a requirement for a second channel and the actions to be taken if that second channel is inoperable are both part of the same more restrictive change justified in DOC M.2. The IP2 design for manual initiation is addressed in WCAP-10271 and, with manual initiation, there are no issues related to drift during the calibration interval or allowable value.

Questions regarding this response should be directed to Dick Bense at (914) 734-5895 (RBENS90@Entergy.Com) or Bill Blair at (914) 737-4167 (WBlair@Entergy.Com).

NL-03-052 Attachment 1 Page 19 of 89 Issue 2:

IP2's adoption of WCAP-14333 allowance for testing in bypass for ITS 3.3.2, Function 1.c, Safety Injection-Containment Pressure-High in DOC A.5.c. (This issue is addressed in detail in the responses to RAI 3.3.2-6)

DOC A.5.c explains that CTS 3.5.3 allows the required minimum degree of redundancy to be reduced by one to permit testing or corrective maintenance of a channel in bypass for on-line testing or corrective maintenance of instruments with installed bypass capability. CTS 3.5.4 allows an inoperable channel that has been placed in trip to be bypassed "for a short period of time" for testing of the remaining Operable channels. iTS LCO 3.3.2, Note to Required Action D.1, maintains this allowance for surveillance testing; however, ITS limits the amount of time that a channel may be bypassed to 12 hours1.388889e-4 days 0.00333 hours 1.984127e-5 weeks 4.566e-6 months consistent with the analysis provided in WCAP-14333-P-A, Rev.1, Probabilistic Risk Analysis of the RPS and ESFAS Test Times and Completion Times.

As explained in the response to RAI 3.3.2-6, CTS 3.5.3 provides the allowance for testing and maintenance in bypass without restricting IP2 to the time limits specified in WCAP-14333 and CTS 3.5.4 allows bypassing an inoperable channel in trip for testing of other channels using the term 'a short period of time' instead of the time limits specified in WCAP-14333. However, the CTS Bases (Page 3.5-

6) provide the clarification that time in Bypass is limited to the times in WCAP-14333. Administrative controls that enforce these time limits. As explained in the response to RAI 3.3.2-6, IP2 will revise ITS 3.3.1, DOC M.01, and ITS 3.3.2, DOC M.1, to further clarify that the ITS adoption of the allowable out of service times (AOTs) from WCAP-14333.

Issue 3:

DOCs A.4.c, A.11.c, A.14.c, A.17.c, A.20.c, A.24.c, A.27.c all address the following:

a) Extending the allowable out of service time for one inoperable train of various ESFAS "Automatic Actuation Logic and Actuation Relays" to 24 hours2.777778e-4 days 0.00667 hours 3.968254e-5 weeks 9.132e-6 months is a less restrictive change which is justified in WCAP-14333-P-A, Rev.1, Probabilistic Risk Analysis of the RPS and ESFAS Test Times and Completion Times (See 3.3.2, DOC L.3); and b) Limiting the amount of time that various ESFAS "Automatic Actuation Logic and Actuation Relays" trains may be bypassed to 8 hours9.259259e-5 days 0.00222 hours 1.322751e-5 weeks 3.044e-6 months is a more restrictive change needed to conform to WCAP-14333-P-A, Rev.1, Probabilistic Risk Analysis of the RPS and ESFAS Test Times and Completion Times (See ITS 3.3.2, DOC M.01).

Although the ITS conversion packages show these changes as a new allowance of 24 hours2.777778e-4 days 0.00667 hours 3.968254e-5 weeks 9.132e-6 months to restore an inoperable train of various ESFAS "Automatic Actuation Logic and Actuation Relays" and a new restriction that ESFAS "Automatic Actuation Logic and Actuation Relays" trains may be bypassed to 8 hours9.259259e-5 days 0.00222 hours 1.322751e-5 weeks 3.044e-6 months , these changes were evaluated and approved in CTS Amendment 212 which adopted the allowances justified in WCAP-14333. CTS Bases Page 3.5-6, added by Amendment 212, and the associated SER clarify that intent of CTS Amendment 212 was to provide "Risk informed AOTs for analog channels (72 hours8.333333e-4 days 0.02 hours 1.190476e-4 weeks 2.7396e-5 months ) and logic channels (24 hours2.777778e-4 days 0.00667 hours 3.968254e-5 weeks 9.132e-6 months ) ... based on the analysis provided in" WCAP-14333.

However, the way that these allowances were incorporated into CTS Table 3.5-3, Engineered Safety Questions regarding this response should be directed to Dick Bense at (914) 734-5895 (RBENS90@Entergy.Com) or Bill Blair at (914) 737-4167 (WBlair@Entergy.Com).

NL-03-052 Attachment 1 Page 20 of 89 Features, and CTS Table 3.5-4, Isolation Functions, resulted in allowances that were more conservative than the allowances justified by WCAP-14333 and approved in the SER. This is because STS (NUREG-1431) and WCAP-14333 divide ESFAS into two distinct parts: a) sensor "channels" and b) "automatic actuation logic and actuation relays" (i.e., logic train). CTS Table 3.5-3, Engineered Safety Features, and CTS Table 3.5-4, Isolation Functions, did not make this distinction. These CTS tables listed only "channels" and requirements and allowances for relays were inferred. This was appropriate when there was no explicit time specified for placing an inoperable channel in trip or restoring an inoperable logic train to Operable because there was an implied requirement that these actions be completed in one hour.

In order to incorporate the WCAP-14333 allowance of 24 hours2.777778e-4 days 0.00667 hours 3.968254e-5 weeks 9.132e-6 months for restoration and 8 hours9.259259e-5 days 0.00222 hours 1.322751e-5 weeks 3.044e-6 months for bypassing a logic train into CTS Table 3.5-3, CTS Amendment 212 moved CTS Table 3.5-2, Item 18.a, Engineered Safety Features (SI) Logic (i.e., requirement that an SI signal is required to cause a reactor trip), to CTS Table 3.5-3, as Item 6, as the SI actuation logic and added CTS Table 3.5-3, Note #,

which provided the WCAP-14333 allowance of 24 hours2.777778e-4 days 0.00667 hours 3.968254e-5 weeks 9.132e-6 months for restoration and 8 hours9.259259e-5 days 0.00222 hours 1.322751e-5 weeks 3.044e-6 months for bypassing a logic train. No similar line item for "Automatic Actuation Logic and Actuation Relays" was added for Containment Spray or Auxiliary Feedwater because the CTS Table 3.5-3, Item 6, was intended to apply to all three types of ESFAS functions. The ITS conversion package corrected this by deleting CTS Table 3.5-3, Item 6, as explained in DOC A.39 and adding requirements for "Automatic Actuation Logic and Actuation Relays" for Safety Injection (DOC A.04.c), Containment Spray (DOC A.11.c), and Auxiliary Feedwater (DOC A.27.c). The allowances justified in CTS Amendment 212 as described in CTS Bases Page 3.5-6 were now explicitly included in ITS (versus being in the CTS Bases) so these changes were justified in DOCs L.3 and M.2 as described in DOC A.04.c, DOC A.11.c, and DOC A.27.c.

Similarly, CTS Table 3.5-4, Isolation Functions, does not make a distinction between sensor "channels" and "automatic actuation logic and actuation relays" (i.e., logic train). Instead of adding new line items for "automatic actuation logic and actuation relays" for Containment Phase A Isolation, Containment Phase B Isolation, Steamline Isolation, and Feedwater Isolation so that a 24 hour2.777778e-4 days 0.00667 hours 3.968254e-5 weeks 9.132e-6 months restoration Completion Time for logic, CTS Amendment 212 conservatively assigned a 24 hour2.777778e-4 days 0.00667 hours 3.968254e-5 weeks 9.132e-6 months restoration Completion Time to the individual channels by adding Note (1) to CTS Table 3.5-4. The ITS conversion package reversed this unnecessary conservatism in DOC L.5 which changed the 24 hour2.777778e-4 days 0.00667 hours 3.968254e-5 weeks 9.132e-6 months Completion Time for the channels in Note (1) to CTS Table 3.5-4 to the 72 hours8.333333e-4 days 0.02 hours 1.190476e-4 weeks 2.7396e-5 months as justified in the SER for CTS Amendment 212 as explained in CTS Bases Page 3.5-6. To enhance clarity, the ITS conversion package added new line items for "automatic actuation logic and actuation relays" for Containment Phase A Isolation, Containment Phase B Isolation, Steamline Isolation, and Feedwater Isolation as described in DOCs A.4.c, A.11.c, A.14.c, A.17.c, A.20.c, A.24.c, A.27.c and justified in DOC L.3 and DOC M.01.

Entergy (IP2) Action:

IP2 will revise ITS 3.3.2, DOCs M.1 and M.2, to provide additional explanation of the changes.

Questions regarding this response should be directed to Dick Bense at (914) 734-5895 (RBENS90Entergy.Com) or Bill Blair at (914) 737-4167 (WBlair@Entergy.Com).

NL-03-052 Attachment 1 Page 21 of 89 3.3.2: Engineered Safety Feature Actuation System (ESFAS)

Instrumentation NRC RAI Number TAC Number:

3.3.2 - 13 MB4739 NRC Request for Additional Information (RAI):

RAI 3.3.2.16 (Item 17)

CTS Table 3.5-3 Provide a new M-DOC to justify the change to ITS Condition "Be in Mode 3 in 6 hours6.944444e-5 days 0.00167 hours 9.920635e-6 weeks 2.283e-6 months " from CTS Table 3.5-3, be in Shutdown per LCO 3.0.1 in 7 hours8.101852e-5 days 0.00194 hours 1.157407e-5 weeks 2.6635e-6 months .

Entergy (IP2) Response:

CTS Table 3.5-3, footnotes (1) and (2) and CTS Table 3.5-4, footnote (1) both specify that if requirements for minimum number of channels or minimum degree of redundancy are not met within the specified time or there is a loss of a safety function, either "proceed to cold shutdown" or, for some cases in CTS Table 3.5-3, "reduce Tavg to < 350 F" (i.e., exit the applicable Mode). However, no Completion Time is specified. Therefore, requirements and completion times specified in CTS 3.0.1 would govern and the shutdown requirement would be interpreted as requiring that the plant is in hot shutdown (i.e., Mode 3) within the following 7 hours8.101852e-5 days 0.00194 hours 1.157407e-5 weeks 2.6635e-6 months and cold shutdown within 37 hours4.282407e-4 days 0.0103 hours 6.117725e-5 weeks 1.40785e-5 months .

Under some conditions (i.e., complete loss of safety function), ITS LCO 3.3.2 defaults to ITS LCO 3.0.3 which requires that the plant be placed in Mode 3 within 7 hours8.101852e-5 days 0.00194 hours 1.157407e-5 weeks 2.6635e-6 months and Mode 5 within 37 hours4.282407e-4 days 0.0103 hours 6.117725e-5 weeks 1.40785e-5 months . In these cases, there is no change to the existing requirements. However, if the problem is that redundancy is not restored within the specified Completion Time but safety Function is not lost, ITS 3.3.2 established a Completion Time to be in Mode 3 in following 6 hours6.944444e-5 days 0.00167 hours 9.920635e-6 weeks 2.283e-6 months (versus 7 hours8.101852e-5 days 0.00194 hours 1.157407e-5 weeks 2.6635e-6 months allowed by STS 3.0.1) and Mode 5 in the following 36 hours4.166667e-4 days 0.01 hours 5.952381e-5 weeks 1.3698e-5 months (versus 37 hours4.282407e-4 days 0.0103 hours 6.117725e-5 weeks 1.40785e-5 months allowed by STS 3.0.1). IP2 ITS 3.3.2, DOCs A.X.d, identified this difference as an Administrative Change because CTS Table 3.5-3 and CTS Table 3.5-4 do not explicitly identify Completion Times and the explicit ITS 3.3.2 Completion Times to be in Mode 3 in following 6 hours6.944444e-5 days 0.00167 hours 9.920635e-6 weeks 2.283e-6 months (versus 7 hours8.101852e-5 days 0.00194 hours 1.157407e-5 weeks 2.6635e-6 months allowed by STS 3.0.1) and Mode 5 in the following 36 hours4.166667e-4 days 0.01 hours 5.952381e-5 weeks 1.3698e-5 months (versus 7 hours8.101852e-5 days 0.00194 hours 1.157407e-5 weeks 2.6635e-6 months allowed by STS 3.0.1) were considered reasonable interpretations of the existing requirements.

IP2 will revise the CTS markup of CTS Table 3.5-3, footnotes (1) and (2) and CTS Table 3.5-4, footnote (1) to include DOC M.10 which will identify and justify the explicit ITS 3.3.2 Completion Times to be in Mode 3 in following 6 hours6.944444e-5 days 0.00167 hours 9.920635e-6 weeks 2.283e-6 months (versus 7 hours8.101852e-5 days 0.00194 hours 1.157407e-5 weeks 2.6635e-6 months allowed by STS 3.0.1) and Mode 5 in the following 36 hours4.166667e-4 days 0.01 hours 5.952381e-5 weeks 1.3698e-5 months (versus 37 hours4.282407e-4 days 0.0103 hours 6.117725e-5 weeks 1.40785e-5 months allowed by STS 3.0.1) as a more restrictive change.

Entergy (IP2) Action:

IP2 will revise the CTS markup of CTS Table 3.5-3, footnotes (1) and (2) and CTS Table 3.5-4, footnote (1) to include DOC M.10 which will identify and justify the explicit ITS 3.3.2 Completion Times to be in Mode 3 in following 6 hours6.944444e-5 days 0.00167 hours 9.920635e-6 weeks 2.283e-6 months (versus 7 hours8.101852e-5 days 0.00194 hours 1.157407e-5 weeks 2.6635e-6 months allowed by STS 3.0.1) and Mode 5 in the following 36 hours4.166667e-4 days 0.01 hours 5.952381e-5 weeks 1.3698e-5 months (versus 37 hours4.282407e-4 days 0.0103 hours 6.117725e-5 weeks 1.40785e-5 months allowed by STS 3.0.1) as a more restrictive change.

Questions regarding this response should be directed to Dick Bense at (914) 734-5895 (RBENS90@Entergy.Com) or Bill Blair at (914) 737-4167 (WBlair@Entergy.Com).

NL-03-052 Attachment 1 Page 22 of 89 3.3.2: Engineered Safety Feature Actuation System (ESFAS)

Instrumentation NRC RAI Number TAC Number:

3.3.2- 14 MB4739 NRC Request for Additional Information (RAI):

RAI 3.3.2.17 (Item 18)

DOC A.39 Provide further explanation of the CTS markup which deletes Table 3.5-3, Note # which allows a 24 hour2.777778e-4 days 0.00667 hours 3.968254e-5 weeks 9.132e-6 months bypass time and replaces it with an 8 hour9.259259e-5 days 0.00222 hours 1.322751e-5 weeks 3.044e-6 months test allowed outage time per Amendment 212 . This appears to be unjustified since ITS retains these allowances.

Entergy (1P2) Response:

ITS 3.3.2, DOC A.39, reads as follows:

"CTS Table 3.5-3, Note #, (added by CTS Amendment 212, dated November 30, 2000) provided the allowance that "An Engineered Safety Feature (SI) logic channel may be bypassed for corrective maintenance for up to 24 hours2.777778e-4 days 0.00667 hours 3.968254e-5 weeks 9.132e-6 months or surveillance testing for up to eight hours provided the redundant logic channel is operable."

ITS 3.3.2, Required Actions C.1 and G.1 and associated Notes, maintain these allowances in that an inoperable ESFAS train must be restored to Operable within 24 hours2.777778e-4 days 0.00667 hours 3.968254e-5 weeks 9.132e-6 months and an ESFAS train may be bypassed for 8 hours9.259259e-5 days 0.00222 hours 1.322751e-5 weeks 3.044e-6 months for surveillance testing. This change is described in DOCS for the following:

ITS 3.3.2, Function 1.b, Safety Injection-Automatic Actuation Logic (See DOC A.4);

ITS 3.3.2, Function 2.b, Containment Spray - Automatic Actuation Logic (See DOC A.11);

ITS 3.3.2, Function 3.a.(2), Cont. Phase A Isolation-Automatic Actuation Logic (See DOC A.14);

ITS 3.3.2, Function 3.b.(2) Cont. Phase B Isolation-Automatic Actuation Logic (See DOC A.17);.

ITS 3.3.2, Function 4.b, Steam Line Isolation-Automatic Actuation Logic (See DOC A.20);

ITS 3.3.2, Function 5.a, Feedwater Isolation-Automatic Actuation Logic (See DOC A.24);

ITS 3.3.2, Function 6.a, Auxiliary Feedwater-Automatic Actuation Logic (See DOC A.27)."

IP2 will revise the markup of CTS Table 3.5-3, Note #, to show that the allowance is maintained in the ITS.

Entergy (IP2) Action:

IP2 will revise the markup of CTS Table 3.5-3, Note #, to show that the allowance is maintained in the ITS.

Questions regarding this response should be directed to Dick Bense at (914) 734-5895 (RBENS90@Entergy.Com) or Bill Blair at (914) 737-4167 (WBlair@Entergy.Com).

NL-03-052 Attachment 1 Page 23 of 89 3.3.2: Engineered Safety Feature Actuation System (ESFAS)

Instrumentation NRC RAI Number TAC Number:

3.3.2 - 15 MB4739 NRC Request for Additional Information (RAI):

RAI 3.3.2.18 (Item 19)

ITS Table 3.3.2-1, Function 2.a, Containment Spray - Manual Initiation DOC A.10.b DOC A.10.b and the Bases for Containment Spray - Manual Initiation state 2 channels (pushbuttons) are required like SI manual. Revise ITS to "1 per train, 2 trains."

Entergy (IP2) Response:

For ITS Table 3.3.2-1, Function 2.a, Containment Spray - Manual Initiation, the Indian Point 2 design differs from the Indian Point 3 design and both plants differ from the design described in STS (NUREG-1431). IP2 believes that the unique IP2 design warrants the difference in the presentation of requirements for ITS 3.3.2, Function 2.a, Manual Initiation of Containment Spray. The design differences are as follows:

Indian Point 3 ITS 3.3.2, Function 2.a, Manual Initiation of Containment Spray, specifies the requirement as "2 per train/2 trains." This specification supports the following design which is described in the IP3 ITS Bases:

"Manual initiation of containment spray (CS) requires that two pushbuttons in the control room be depressed simultaneously which will actuate both trains of CS. Two pushbuttons must be depressed simultaneously to minimize the potential for an inadvertent actuation of CS which could have serious consequences. Each CS pushbutton closes one of the two contacts required to start CS train A and one of the two contacts required to start CS train B; depressing both pushbuttons (closes both of the contacts required to start CS train A and both of the contacts required to start CS train B. Two channels (contacts) are required to be Operable for CS train A and two channels (contacts) are required to be Operable for CS train B. Failure of one manual pushbutton will result in one inoperable channel in both trains."

Indian Point 2 ITS 3.3.2, Function 2.a, Manual Initiation of Containment Spray, specifies the requirement as "2 trains." This difference is necessary because of the significant difference in the IP2 design. Of particular importance is the fact that each IP2 containment spray pushbutton initiates only one train of CS (i.e., each button starts only one pump). This is the reason that the function is specified as "2 trains" versus "2 channels." The IP2 ITS Bases provide the following description of the IP2 design:

"Manual initiation of containment spray (CS) requires that either of two pushbuttons in the control room be depressed. Each pushbutton will actuate one logic train and the associated CS train. Two trains are required to be Operable (one pushbutton associated with each logic train)."

IP2 believes that the unique IP2 design warrants the difference in the presentation of requirements for Questions regarding this response should be directed to Dick Bense at (914) 734-5895 (RBENS90@Entergy.Com) or Bill Blair at (914) 737-4167 (WBlair@Entergy.Com).

NL-03-052 Attachment 1 Page 24 of 89 ITS 3.3.2, Function 2.a, Manual Initiation of Containment Spray.

Entergy (IP2) Action:

None.

Questions regarding this response should be directed to Dick Bense at (914) 734-5895 (RBENS90@Entergy.Com) or Bill Blair at (914) 737-4167 (WBiair@Entergy.Com).

NL-03-052 Attachment 1 Page 25 of 89 3.3.2: Engineered Safety Feature Actuation System (ESFAS)

Instrumentation NRC RAI Number TAC Number:

3.3.2- 16 MB4739 NRC Request for Additional Information (RAI):

RAI 3.3.2.19 (Item 20)

CTS 4.7 ITS SR 3.3.2.6 DOC A.19.e, Manual Main Steam Line Isolation Provide additional justification to show that CTS 4.7 required testing of main steam stop valves is equivalent to ITS SR 3.3.2.6 TADOT test requirement of the instrument loop.

Entercy (IP2) Response:

CTS 4.7 requires that "The main steam stop valves shall be tested at least once every Refueling Interval. Closure time of five seconds or less shall be verified."

ITS 3.3.2, DOC A.19.e, states that "CTS Table 4.1-1 does not establish a specific requirement to test the Steam Line Isolation-Manual Initiation Function; however, CTS 4.7 establishes requirements for testing the MSIV closing Function every 24 months. ITS SR 3.3.2.6 maintains the same requirement to verify Operability of the manual initiation function by the performance of a Trip Actuating Device Operational Test (TADOT) every 24 months. The SR is modified by a Note that excludes verification of setpoints during the TADOT for manual initiation Functions because these Functions have no associated setpoints."

STS (NUREG-1431) defines a TADOT as a test that "shall consist of operating the trip actuating device and verifying the Operability of all devices in the channel required for trip actuating device Operability.

The TADOT shall include adjustment, as necessary, of the trip actuating device so that it actuates at the required setpoint within the necessary accuracy. The TADOT may be performed by means of any series of sequential, overlapping, or total channel steps."

IP2 already tests the Steam Line Isolation-Manual Initiation Function every 24 months. ITS SR 3.3.2.6 and ITS SR 3.7.2.2 will ensure that this function continues to be fully tested every 24 months.

Entercy (IP2) Action:

None.

Questions regarding this response should be directed to Dick Bense at (914) 734-5895 (RBENS90@Entergy.Com) or Bill Blair at (914) 737-4167 (WBlair@Entergy.Com).

NL-03-052 Attachment 1 Page 26 of 89 3.3.2 : Engineered Safety Feature Actuation System (ESFAS)

Instrumentation NRC RAI Number TAC Number:

3.3.2 - 17 MB4739 NRC Request for Additional Information (RAI):

RAI 3.3.2.21 (Item 23)

DOC A.35 CTS 3.5.3 DOC A.35 does not discuss deleting the CTS 3.5.3 allowance to reduce the minimum degree of redundancy. Provide additional justification.

Entergv (IP2) Response:

CTS 3.5.3 includes the statement that "For on-line testing or corrective maintenance of instruments with installed bypass capability, the required minimum degree of redundancy may be reduced by one to permit testing or corrective maintenance of a channel in bypass." This statement is shown in the CTS markup as cross referenced to "Notes to Required Actions C.1 D.1, E.1, and G.1" and shows the statement being deleted by ITS 3.3.2, DOC A.35, which reads as follows:

'TS 3.5.3 specifies that for on-line testing of instruments with installed bypass capability, the required minimum degree of redundancy may be reduced by one to permit testing of a channel in bypass. This statement clarifies that a channel in bypass, even for testing, is inoperable and is treated as an inoperable channel. Since there is no explicit time limit in the CTS for placing an inoperable channel in trip, this statement allows testing that makes a channel inoperable to be performed without immediately placing the channel in trip as is required by the first sentence of CTS 3.5.3."

"This is an administrative change with no impact on safety because there is no change to the existing requirement that a channel bypassed for testing is treated as an inoperable channel. See DOC M.1 for new explicit limits for the amount of time that a channel may be bypassed."

IP2 will revise DOC A.35 to clarify that this statement can be deleted because ITS LCO 3.3.2, Required Actions C.1 D.1, E.1, and G.1 maintain the allowance that a channel or train may be bypassed for surveillance testing.

Entergy (MP2) Action:

IP2 will revise DOC A.35 to clarify that this statement can be deleted because ITS LCO 3.3.2, Required Actions D.1, E.1, and G.1 maintain the allowance that a channel or train may be bypassed for surveillance testing.

Questions regarding this response should be directed to Dick Bense at (914) 734-5895 (RBENS9OQEntergy.Com) or Bill Blair at (914) 737-4167 (WBlair@Entergy.Com).

NL-03-052 Attachment 1 Page 27 of 89 3.3.2: Engineered Safety Feature Actuation System (ESFAS)

Instrumentation NRC RAI Number TAC Number:

3.3.2 - 18 MB4739 NRC Request for Additional Information (RAI):

RAI 3.3.2.23 (Item 26) - BSI CTS Table 3.5-1, Instrument Setting Changes to instrument settings require further staff review and comment on proposed limits and supporting documentation for the Allowable Values in Table 3.3.2-1.

Entergy (IP2) Response:

This RAI is a duplicate of an RAI that was previously identified as a beyond scope issue. This response duplicates the response provided in Letter NL 02-04 on November 26, 2002.

The IP2 setpoint methodology is documented in IP2 Specification No. FIX-95-A-001, "Guidelines For Preparation Of Instrument Loop Accuracy And Setpoint Determination Calculations," Revision 1. The calculations supporting allowable values for ITS LCO 3.3.1, Reactor Protection System (RPS)

Instrumentation, ITS 3.3.2, Engineered Safety Feature Actuation System (ESFAS) Instrumentation, and ITS 3.3.5, Loss of Power (LOP) Diesel Generator (DG) Start Instrumentation, are currently being developed. The results of these calculations and sample calculations will be provided to the NRC in a separate submittal.

Entergy (IP2) Action:

IP2 has submitted a copy of IP2 Specification No. FIX-95-A-001, "Guidelines For Preparation Of Instrument Loop Accuracy And Setpoint Determination Calculations," Revision 1, as part of this response provided in Letter NL 02-04 on November 26, 2002.

Questions regarding this response should be directed to Dick Bense at (914) 734-5895 (RBENS90@Entergy.Com) or Bill Blair at (914) 737-4167 (WBlair@Entergy.Com).

NL-03-052 Attachment 1 Page 28 of 89 3.3.2: Engineered Safety Feature Actuation System (ESFAS)

Instrumentation NRC RAI Number TAC Number:

3.3.2 - 19 MB4739 NRC Request for Additional Information (RAI):

RAI 3.3.2.24 (Item 27)

CTS Table 3.5-3, SI High Steam Flow ITS Table 3.3.2-1, Function 1.f, Function 1.g DOC M.3 Provide SE references for the DOC M.3 citation of the 72 hour8.333333e-4 days 0.02 hours 1.190476e-4 weeks 2.7396e-5 months repair AOT per WCAP-14333 and 92 day STI per WCAP-10271.

Entergy (IP2) Response:

CTS Amendment 154, dated July 29, 1991, extended the surveillance interval for ESFAS analog channel tests, including CTS Table 3.5-3, SI High Steam Flow, from monthly to quarterly based on the analysis in WCAP-10271.

CTS Amendment 212, dated November 30, 2000, extended the allowable out of service time for an inoperable channel from immediately (interpreted as within one hour) to 72 hours8.333333e-4 days 0.02 hours 1.190476e-4 weeks 2.7396e-5 months based on the analysis in WCAP-14333.

DOC M.3 explains that ITS requires Operability of 2 channels of high steam flow per steam line on all 4 steam lines (versus the CTS requirement of 2 channels of high steam flow per steam line on only 3 of 4 steam lines). The CTS requirement for High Steam Flow channels in only 3 of the 4 steam lines satisfies IEEE-279 requirements for redundancy because this Function provides protection against a steam line break event. This configuration (high steam flow channels in only 3 of the 4 steam lines) maintains single failure tolerance because a steam line break will cause the steam flow in the remaining intact steam lines to increase to levels above the trip setpoint in order to maintain turbine load.

Therefore, even with a single failure of the Function in one steam line and the steam break in a second steam line, steam flow in the remaining two steam lines will increase sufficiently to cause an actuation.

Based on a review performed for the IP3 conversion, WCAP-10271 did not include a configuration of 3 of 4 steam lines in the list of configurations that were analyzed. Therefore, ITS requires Operable channels in all 4 steam lines to ensure that the IP2 configuration conforms to the assumptions of WCAP-10271. Additionally, as explained in DOCs A.08.b and A.09.b, CTS Table 3.5-3, 1.e, includes a typographical error and should read 1 channel per steam line in each of three steam lines with a minimum degree of redundancy of 1 (not 2 as shown in the CTS) channel per steam line in each of three steam lines which would establish a requirement for two Operable channels in each steam line with an inoperable channel placed in trip.

Enterav (1P2) Action:

None Questions regarding this response should be directed to Dick Bense at (914) 734-5895 (RBENS90@Entergy.Com) or Bill Blair at (914) 737-4167 (WBlair@Entergy.Com).

NL-03-052 Attachment 1 Page 29 of 89 3.3.2: Engineered Safety Feature Actuation System (ESFAS)

Instrumentation NRC RAI Number TAC Number:

3.3.2- 20 MB4739 NRC Request for Additional Information (RAI):

RAI 3.3.2.26 (Item 29)

DOC A.9.b Editorial changes to the Description of Change, last paragraph. Revise 'Tave Low" to "Steam Line Pressure" and "ITS 3.3.2, Function I.f " to "ITS 3.3.2, Function 1.g" Entergv (IP2) Response:

IP2 corrected typographical errors in ITS 3.3.2, DOC A.09.b.

Entergv (IP2) Action:

IP2 corrected typographical errors in ITS 3.3.2, DOC A.09.b.

Questions regarding this response should be directed to Dick Bense at (914) 734-5895 (RBENS90@Entergy.Com) or Bill Blair at (914) 737-4167 (WBlair@Entergy.Com).

NL-03-052 Attachment 1 Page 30 of 89 3.3.2: Engineered Safety Feature Actuation System (ESFAS)

Instrumentation NRC RAI Number TAC Number:

3.3.2 - 21 MB4739 NRC Request for Additional Information (RAI):

RAI 3.3.2.27 (Item 30)

The referenced DOCs below contain CTS mark up errors or there is a DOC discussion mismatch with DOC Summary.

DOC A.3.b, A.13.b, A.16.b, A.19.b: "In conjunction with this change...

DOC A.6.d, A.7d, A.8d, A.9.d, A.12.d, A.18.d, A.21.d, A.22.d, A.23.d: ... Completion Time "or complete loss of manual initiation function", CTS Table ...

DOC A.15 - Justification for Change is not applicable to the DOC.

DOC A.20.d, A.24.d, A.27.d: "CTS 3.5.3, in conjunction with" is not applicable to Automatic Actuation Logic.

Entergv (IP2) Response:

Issue 1:

ITS 3.3.2, DOCs A.03.b, A.13.b, A.16.b, A.19.b address ESFAS Manual Initiation Functions (i.e., ITS 3.3.2. Function 1.a, Safety Injection-Manual Initiation, ITS 3.3.2, Function 3.a.(1), Containment Phase A Isolation-Manual Initiation, ITS 3.3.2, Function 3.b.(1) Containment Phase B Isolation-Manual Initiation, and ITS 3.3.2, Function 4.a Steam Line Isolation-Manual Initiation). All of these DOCs are structured as follows:

CTS Table 3.5-3, Function 1.a, requires 1 operable channel with a minimum degree of redundancy of zero (See ITS 3.3.2, DOC A.37) for the manual initiation function for safety injection.

ITS 3.3.2 requires 2 operable channels for the manual initiation function. This is a more restrictive change (See 3.3.2, DOC M.2). In conjunction with this change, ITS LCO 3.3.2, Required Action B.1, will allow 48 hours5.555556e-4 days 0.0133 hours 7.936508e-5 weeks 1.8264e-5 months to restore an inoperable channel when one of the two channels now required is inoperable (see 3.3.2, DOC M.2).

This issue is addressed in the response to RAI 3.3.2 - 11 as follows:

CTS Table 3.5-3, Item 1.a. (Safety Injection) Manual, requires that only one of the two manual initiation channels is Operable. Because only one of the two (Safety Injection) Manual initiation channels is ever required to be Operable, CTS does not specify any actions if one of the two (Safety Injection) Manual channels is inoperable.

ITS 3.3.2, Function l.a., Safety Injection-Manual Initiation, requires that both of the manual initiation channels are Operable. If one of the two channels is inoperable, ITS 3.3.2 includes a new requirement that it be restored to Operable within 48 hours5.555556e-4 days 0.0133 hours 7.936508e-5 weeks 1.8264e-5 months . Therefore, both the addition of a requirements for a second channel and the actions to be taken if that second channel is inoperable are both part of the same more restrictive change.

Questions regarding this response should be directed to Dick Bense at (914) 734-5895 (RBENS90@Entergy.Com) or Bill Blair at (914) 7374167 (WBlairQEntergy.Com).

NL-03-052 Attachment 1 Page 31 of 89 Issue 2:

IP2 will revise ITS 3.3.2, DOCs A.06.d, A.07d, A.08d, A.09.d, A.12.d, A.18.d, A.21.d, A.22.d and A.23.d to delete the Phrase "or complete loss of manual initiation function" from the first sentence.

Issue 3:

IP2 will revise the justification for DOC A.15 to read as follows:

These are administrative changes with no impact on safety except for the change extending the amount of time allowed to place an inoperable Containment Phase A Isolation - Safety Injection channel in trip from 24 to 72 hours8.333333e-4 days 0.02 hours 1.190476e-4 weeks 2.7396e-5 months . This change is consistent with WCAP-14333-P-A, Rev.1, Probabilistic Risk Analysis of the RPS and ESFAS Test Times and Completion Times and is described and justified in ITS 3.3.2, DOC L.5.

Issue 4:

DOC A.20.d, A.24.d, A.27.d: "CTS 3.5.3, in conjunction with" is not applicable to Automatic Actuation Logic.

IP2 will revise DOCs A.04.d, A.11.d, A.14.d, A.17.d, A.20.d, A.24.d, and A.27.d to eliminate the phrase "in conjunction with CTS 1.5."

Entergv (IP2) Action:

IP2 will revise ITS 3.3.2, DOCs A.06.d, A.07d, A.08d, A.09.d, A.12.d, A.18.d, A.21.d, A.22.d and A.23.d to delete the Phrase "or complete loss of manual initiation function" from the first sentence.

IP2 will revise the justification for DOC A.15 to read as described above.

IP2 will revise DOCs A.04.d, A.11.d, A.14.d, A.17.d, A.20.d, A.24.d, and A.27.d to eliminate the phrase "in conjunction with CTS 1.5."

Questions regarding this response should be directed to Dick Bense at (914) 734-5895 (RBENS90@Entergy.Com) or Bill Blair at (914) 737-4167 (WBlair@Entergy.Com).

NL-03-052 Attachment 1 Page 32 of 89 3.3.2: Engineered Safety Feature Actuation System (ESFAS)

Instrumentation NRC RAI Number TAC Number:

3.3.2 - 22 MB4739 NRC Request for Additional Information (RAI):

RAI 3.3.2.28 (Item 31)

DOC A.5.e, Safety Injection - Containment Pressure High Provide a DOC for adopting the ITS SR 3.3.2.7 Note.

Entergy (MP2) Response:

STS (NUREG-1431) SR 3.3.2.9 (IP2 ITS SR 3.3.2.7) includes a Note that 'The Surveillance shall include verification that the time constants are adjusted to the prescribed value." This Note should not have been included in the IP2 ITS because the IP2 design does not include any ESFAS Functions that include a lead/lag time constant that is part of the allowable value for the Function. Therefore, IP2 will revise IP2 iTS to delete the Note to SR 3.3.2.7.

Entervy (IP2) Action:

IP2 will revise IP2 ITS to delete the Note to SR 3.3.2.7.

Questions regarding this response should be directed to Dick Bense at (914) 734-5895 (RBENS90@Entergy.Com) or Bill Blair at (914) 737-4167 (WBlair@Entergy.Com).

NL-03-052 Attachment 1 Page 33 of 89 3.3.2: Engineered Safety Feature Actuation System (ESFAS)

Instrumentation NRC RAI Number TAC Number:

3.3.2 - 23 MB4739 NRC Request for Additional Information (RAI):

RAI 3.3.2.29 (Item 32)

DOC A.3.e, Safety Injection - Manual Provide a DOC for adopting the ITS SR 3.3.2.6 Note.

Enteray (IP2) Response:

SR 3.3.2.6 requires performance of a Trip Actuating Device Operational Test (TADOT) for Functions for each of the various ESFAS manual initiation functions. The ITS definition of a TADOT includes the requirement that "The TADOT shall include adjustment, as necessary, of the trip actuating device so that it actuates at the required setpoint within the necessary accuracy." Therefore, SR 3.3.2.6 is modified by a note that clarifies that "Verification of setpoint is not required for manual initiation functions.

ITS 3.3.2, DOCs A.03.e, A.10.e, A.13.e, A.16.e and A.19.2 discuss surveillance requirements for the ESFAS manual initiation functions. All of these DOCs include a discussion similar to DOC A.03.e which is repeated below.

CTS Table 4.1-1 does not establish a specific requirement to test the Safety Injection Manual Initiation Function: however, CTS 4.5.A.1.a establishes requirements for testing the Safety Injection Function every 24 months. ITS SR 3.3.2.6 maintains the same requirement to verify Operability of the manual initiation function by the performance of a Trip Actuating Device Operational Test (TADOT) every 24 months. The SR is modified by a Note that excludes verification of setpoints during the TADOT for manual initiation Functions because these Functions have no associated setpoints.

Entergy (IP2) Action:

None Questions regarding this response should be directed to Dick Bense at (914) 734-5895 (RBENS90@Entergy.Com) or Bill Blair at (914) 737-4167 (WBlair@lEntergy.Com).

NL-03-052 Attachment 1 Page 34 of 89 3.3.2: Engineered Safety Feature Actuation System (ESFAS)

Instrumentation NRC RAI Number TAC Number:

3.3.2- 24 MB4739 NRC Request for Additional Information (RAI):

RAI 3.3.2.32 (Item 35)

DOC A.8 DOC A.9 CTS Surveillance Table 4.1-1, item 24 (Turbine 1st Stage Pressure) is translated in the ITS as Table 3.3.2-1, footnote (b) which is an allowable value trip setpoint for High Steam Flow in Two Steam Lines (Table 3.3.2-1 functions 1.f and 1.g). This discussion is unclear. CTS Table 4.1-1 does not contain instrument trip setpoints or allowable values.

Entergy (IP2) Response:

IP2 will revise the markup of CTS Table 4.1-1, item 24 (Turbine 1st Stage Pressure) to delete the reference to "footnote (b)."

Entergy (IP2) Action:

IP2 will revise the markup of CTS Table 4.1-1, item 24 (Turbine 1st Stage Pressure) to delete the reference to "footnote (b)."

Questions regarding this response should be directed to Dick Bense at (914) 734-5895 (RBENS90@Entergy.Com) or Bill Blair at (914) 737 4167 (WBlair@Entergy.Com).

NL-03-052 Attachment 1 Page 35 of 89 3.3.2: Engineered Safety Feature Actuation System (ESFAS)

Instrumentation NRC RAI Number TAC Number:

3.3.2 - 25 MB4739 NRC Request for Additional Information (RAI):

RAI 3.3.2.33 (Item 36)

DOC A.8.e, A.9.e, A.22.e and A.23.e The DOC Summaries for these DOCs explain Surveillance Requirements for ITS 3.3.2, Function 1.f, Safety Injection - High Steam Flow in Two Steam Lines Coincident with Tave-Low. The Description of Change for these DOCs reference CTS Table 4.1-1, Item #4 (Reactor Coolant Temperature (i.e., Tave) and CTS Table 4.1-1, Item #23 (Steam Line Pressure) as requiring a channel check every shift. Explain how items #4 and #23 are channel inputs for the IP2 designed SI on High Steam Flow in Two Steam Lines Coincident with either Tave or Steam Line Pressure Low.

Entergy (IP2) Response:

IP2 will revise DOC A.08 and A.08.e to delete the incorrect reference to "CTS Table 4.1-1, Item 23, Steam line Pressure."

IP2 will revise DOC A.9.e to delete the incorrect reference to "CTS Table 4.1-1, Item 4, Reactor Coolant Temperature (i.e., Tave)."

IP2 will revise DOC A.22.e to delete the incorrect reference to "and CTS Table 4.1-1, Item 23, Steam line Pressure" IP2 will revise DOC A.23.e to delete the incorrect reference to "CTS Table 4.1-1, Item 4, Reactor Coolant Temperature (i.e., Tave)."

Entergy (IP2) Action:

IP2 will revise DOC A.08 and A.08.e to delete the incorrect reference to "CTS Table 4.1-1, Item 23, Steam line Pressure."

IP2 will revise DOC A.9.e to delete the incorrect reference to "CTS Table 4.1-1, Item 4, Reactor Coolant Temperature (i.e., Tave)."

IP2 will revise DOC A.22.e to delete the incorrect reference to "and CTS Table 4.1-1, Item 23, Steam line Pressure" IP2 will revise DOC A.23.e to delete the incorrect reference to "CTS Table 4.1-1, Item 4, Reactor Coolant Temperature (i.e., Tave)."

Cuestions regarding this response should be directed to Dick Bense at (914) 734-5895 (RBENS90@Entergy.Com) or Bill Blair at (914) 737-4167 (WBlrialEntergy.Com).

NL-03-052 Attachment 1 Page 36 of 89 3.332: Engineered Safety Feature Actuation System (ESFAS)

Instrumentation NRC RAI Number TAC Number:

3.3.2 - 26 MB4739 NRC Request for Additional Information (RAI):

RAI 3.3.2.34 (Item 37)

DOC A.8.e and DOC A.9.e DOC M.7 The DOC Summaries for these DOCs explain Surveillance Requirements for iTS 3.3.2, Function 1.f, Safety Injection - High Steam Flow in Two Steam Lines Coincident with Tave-Low. The Description of Change discussion states that CTS Table 4.1-1 does not identify any explicit requirement for testing the high steam flow function. ITS adds SRs for testing high steam flow. Explain why the proposed tests are appropriate. WCAP-10271 and WCAP-14333 citations for SR frequencies are not part of the current license basis and need to be established by analysis with a submittal from IP2 and approval by the staff.

Entergy (IP2) Response:

ITS 3.3.2, DOCs A.08 and A.08.e, provides the following description:

ITS 3.3.2, Function 1.f, Safety Injection-High Steam Flow in Two Steam Lines Coincident with Tave-Low, is equivalent to CTS Table 3.5-1, Item 5, CTS Table 3.5-3, Item 1.e, (Safety Injection) High Steam Flow in 2/4 Steam Lines Coincident with Low Tave, CTS Table 4.1-1, Item 4 (Reactor Coolant Temperature), and CTS Table 4.1-1, Item 24 (turbine first stage pressure (i.e., input to the Steam Flow Setpoint Adjustment)).

CTS Table 4.1-1 does not identify any explicit requirements for testing the high steam flow function.

ITS SR 3.3.2.1 is added to require a channel check of the steam flow function every 12 hours1.388889e-4 days 0.00333 hours 1.984127e-5 weeks 4.566e-6 months . ITS SR 3.3.2.4 is added to require a channel operational test (COT) of the steam flow function every 92 days.

ITS SR 3.3.2.7 is added to require a channel calibration of the steam flow function every 24 month.

Adding requirements for a steam flow function channel check every 12 hours1.388889e-4 days 0.00333 hours 1.984127e-5 weeks 4.566e-6 months , a channel operational test (COT) every 92 days, and a channel calibration every 24 months is a more restrictive change that is justified in DOC M.07.

ITS 3.3.2, DOCs A.09 and A.09.e, provides a parallel description for ITS 3.3.2, Function 1.g. Safety Injection - High Steam Flow in Two Steam Lines Coincident with Steam Line Pressure - Low.

As stated, CTS Table 4.1-1 does not identify any explicit requirements for testing the high steam flow function. Therefore, ITS 3.3.2 defined Surveillance requirements based on the following:

a) the proposed SR requirements and frequencies specified for this function are identical to those recommended in the STS (NUREG-1431);

b) the proposed SR requirements and frequencies specified for this function are consistent with those specified in WCAP-10271-P-A, Supplement 2, Rev. 1, June 1990, and WCAP-14333-P-A, Rev.1, Probabilistic Risk Analysis of the RPS and ESFAS Test Times and Completion Times.

c) the proposed SR requirements and frequencies specified for this function are consistent with current practice.

Questions regarding this response should be directed to Dick Bense at (914) 734-5895 (RBENS90@Entergy.Com) or Bill Blair at (914) 737-4167 (WBlair@Entergy.Com).

NL-03-052 Attachment 1 Page 37 of 89 Entergy (IP2) Action:

None Questions regarding this response should be directed to Dick Bense at (914) 734-5895 (RBENS90@Entergy.Com) or Bill Blair at (914) 737-4167 (WBlair@Entergy.Com).

NL-03-052 Attachment 1 Page 38 of 89 3.3.2: Engineered Safety Feature Actuation System (ESFAS)

Instrumentation NRC RAI Number TAC Number:

3.3.2- 27 MB4739 NRC Request for Additional Information (RAI):

RAI 3.3.2.35 (Item 38)

DOCs A.12, A.18 and A.21 DOC M.6 CTS requirements to perform a channel check every 24 hours2.777778e-4 days 0.00667 hours 3.968254e-5 weeks 9.132e-6 months is changed in the ITS to a 12 hour1.388889e-4 days 0.00333 hours 1.984127e-5 weeks 4.566e-6 months channel check for DOCs A.12, A.18 and A.21. The Justification for Change discussion states that the periodic verification of the Operability of the Containment Pressure (Wide Range) input to the ESFAS containment isolation functions are consistent with the assumptions in WCAP-10271 and WCAP-14333.

Explain the topical report assumptions for the 12 hour1.388889e-4 days 0.00333 hours 1.984127e-5 weeks 4.566e-6 months channel check frequency.

Entercy (IP2) Response:

IP2 will revise ITS 3.3.2, DOC M.6 to explain that the Frequency for the channel check required by CTS Table 4.1-1, Item 18.a, for Containment Pressure (Wide Range), is changed to require a channel check every 12 hours1.388889e-4 days 0.00333 hours 1.984127e-5 weeks 4.566e-6 months to establish consistent SR Frequency for channel checks for all ESFAS functions.

Entergy (IP2) Action:

IP2 will revise ITS 3.3.2, DOC M.6 as described above.

Ouestions regarding this response should be directed to Dick Bense at (914) 734-5895 (RBENS90@Entergy.Com) or Bill Blair at (914) 737-4167 (WBlair@Entergy.Com).

NL-03-052 Attachment 1 Page 39 of 89 3.3.2: Engineered Safety Feature Actuation System (ESFAS)

Instrumentation NRC RAI Number TAC Number:

3.3.2 - 28 MB4739 NRC Request for Additional Information (RAI):

RAI 3.3.2.36 (Item 39)

DOC A.28.e ITS 3.3.2, Function 6.b, Auxiliary Feedwater - Steam Generator Level - low-low Revising the channel test requirement to "monthly" from "refueling" requires a new M-DOC for this proposed change in the ITS submittal.

Entergy (1P2) Response:

IP2 will revise ITS 3.3.2, Function 6.b, Auxiliary Feedwater - Steam Generator Level - (low-low), and DOC A.28.e to delete the requirement for SR 3.3.2.4 (i.e., Perform COT every 92 days). The CTS requirements for this function, as defined in CTS Table 4.1-1, Item 30.a, Auxiliary Feedwater - Steam Generator Level (low-low), requires a channel calibration at interval R# (i.e., every 24 months). ITS SR 3.3.2.7 requires a channel calibration every 24 months which maintains the existing requirement and Frequency. Requiring only the channel calibration is acceptable because the definition of a channel calibration requires that "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."

Entergv (IP2) Action:

IP2 will revise ITS 332, Function 6.b, Auxiliary Feedwater - Steam Generator Level - low-low, and DOC A.28.e to delete the requirement for SR 3.3.2.4 (i.e., Perform COT every 92 days).

Questions regarding this response should be directed to Dick Bense at (914) 734-5895 (RBENS90@Entergy.Com) or Bill Blair at (914) 737-4167 (WBlair@Entergy.Com).

NL-03-052 Attachment 1 Page 40 of 89 3.3.2: Engineered Safety Feature Actuation System (ESFAS)

Instrumentation NRC RAI Number TAC Number:

3.3.2 - 29 MB4739 NRC Request for Additional Information (RAI):

RAI 3.3.2.37 (Item 40)

DOC M.5 The ITS Bases contains a mismatch on page B 3.3.2-29-03 with the text of DOC M.5 in describing the signal coincidence for starting the motor driven and turbine driven feedwater pumps.

Entergy (IP2) Response:

IP2 will revise DOC M.5 to describe the AFW start on Station Blackout using the description in Insert B 3.3.2 03 which reads as follows:

'The turbine driven AFW pump receives an automatic start signal when there is an undervoltage condition on safeguards power train 480 V bus 5A or 6A coincident with a unit trip with no safety injection signal present. The two motor driven pumps receive an automatic start signal when there is an undervoltage condition on safeguards power train 480 V bus 5A or 6A coincident with a unit trip."

Note that DOC M.5 will also be modified to require 3 channels per bus of the SBO function as described in the response to RAI 3.3.2-9.

Entergy (IP2) Action:

IP2 will revise DOC M.5 to describe the AFW start on Station Blackout using the description in Insert B 3.3.2 03 as described above.

Questions regarding this response should be directed to Dick Bense at (914) 734-5895 (RBENS9O@Entergy.Com) or Bill Blair at (914) 737-4167 (WBlair@Entergy.Com).

NL-03-052 Attachment 1 Page 41 of 89 3.3.2: Engineered Safety Feature Actuation System (ESFAS)

Instrumentation NRC RAI Number TAC Number:

3.3.2 - 30 MB4739 NRC Request for Additional Information (RAI):

RAI 3.3.2.38 (Item 41)

DOC A.30.c - Undervoltage AFW Pump Start For a loss of redundancy for the DOC A.30.c explains the Required Actions for one inoperable channel.

The Justification for Changes states the 48 hour5.555556e-4 days 0.0133 hours 7.936508e-5 weeks 1.8264e-5 months allowable out of service time to restore an inoperable channel is acceptable based on current licensing basis. The JFC also states that the IP2 plant design for this Function is not addressed in WCAP-10271, ever after requirement were revised to require 1 channel per bus and 2 busses. The JFC also states that the allowable out of service times and surveillance test intervals are more conservative than CTS requirements, and that accident scenarios are protected by functions addressed in WCAP-10271 and the requirements specified in ITS 3.3.2 are consistent with the plant design.

Discuss the JFC statement that a "48 hour5.555556e-4 days 0.0133 hours 7.936508e-5 weeks 1.8264e-5 months allowable out of service time to restore an inoperable channel is acceptable based on current licensing basis" The basis for the proposed use of the WCAP-10271 is not provided in DOC M.5.

Entergy (IP2) Response:

As discussed in the response to RAI 3.3.2-9, IP2 will revise ITS 3.3.2, Function 6.d, Auxiliary Feedwater-Station Blackout (SBO) (Undervoltage Bus 5A or Bus 6A) (See Response to RAI 3.3.2-5 for name change) to require 3 channels per bus. In conjunction with this change, ITS 3.3.2 will be revised to include new Conditions 3, K and L to address inoperable channels and/or trains of the SBO function.

Therefore, ITS 3.3.2, DOCs A.30.b through A.30.d will be completely re-written to reflect this change.

Entergy (IP2) Action:

ITS 3.3.2, DOCs A.30.b through A.30.d will be completely re-written to reflect that IP2 will revise ITS 3.3.2, Function 6.d, Auxiliary Feedwater-Station Blackout (SBO) (Undervoltage Bus 5A or Bus 6A) to require 3 channels per bus.

Questions regarding this response should be directed to Dick Bense at (914) 734-5895 (RBENS90@Entergy.Com) or Bill Blair at (914) 737-4167 (WBIalr@Entergy.Com).

NL-03-052 Attachment 1 Page 42 of 89 3.3.2: Engineered Safety Feature Actuation System (ESFAS)

Instrumentation NRC RAI Number TAC Number:

3.3.2 - 31 MB4739 NRC Request for Additional Information (RAI):

RAI 3.3.2.39 (Item 42)

DOC A.30.d - Undervoltage AFW Pump Start DOC A.30.d repeats DOC A.30.c discussion. DOC A.30.d does not discuss CTS requirements for failure to place a channel in trip. Nor is the 48-hour trip requirement evaluated. Provide the additional justification.

Entergy (IP2) Response:

As discussed in the response to RAI 3.3.2-9, IP2 will revise ITS 3.3.2, Function 6.d, Auxiliary Feedwater-Station Blackout (SBO) (Undervoltage Bus 5A or Bus 6A) (See Response to RAI 3.3.2-5 for name change) to require 3 channels per bus. In conjunction with this change, ITS 3.3.2 will be revised to include new Conditions J, Kand L to address inoperable channels and/or trains of the SBO function.

Therefore, ITS 3.3.2, DOCs A.30.b through A.30.d will be completely re-written to reflect this change.

Entergy (IP2) Action:

ITS 3.3.2, DOCs A.30.b through A.30.d will be completely re-written to reflect that IP2 will revise ITS 3.3.2, Function 6.d, Auxiliary Feedwater-Station Blackout (SBO) (Undervoltage Bus 5A or Bus 6A) to require 3 channels per bus.

Questions regarding this response should be directed to Dick Bense at (914) 734-5895 (RBENS9M@ Entergy.Com) or Bill Blair at (914) 737-4167 (WBlair@ Entergy.Com).

NL-03-052 Attachment 1 Page 43 of 89 3.3.2: Engineered Safety Feature Actuation System (ESFAS)

Instrumentation NRC RAI Number TAC Number:

3.3.2 - 32 MB4739 NRC Request for Additional Information (RAI):

RAI 3.3.2.42 (Item 45)

DOC A.31.c, one inoperable channel DOC A.31.d, two inoperable channels Revise proposed Condition H (one inoperable channel) to adopt the STS required actions for this condition. Provide a technical basis for a 48 hour5.555556e-4 days 0.0133 hours 7.936508e-5 weeks 1.8264e-5 months channel repair AOT. Adopt STS Actions 3.1 and J.2 for one Main Boiler Feedwater Pump trip channel inoperable because the 24 month TADOT is the only required surveillance and thus any need for actions other than for a random active failure during operation is moot.

Entergy (IP2) Response:

STS (NUREG-1431) LCO 3.3.2 is based on a design with two channels per Main Feedwater Pump (MFP). A trip of one of the two channels for each pump required to actuate AFW. This design provides single failure tolerance when either one or both MFPs are operating.

The IP2 design consists of a single channel associated with each Main Feedwater Pump (MFP). A trip of either channel will start AFW. CTS Table 3.5-3, Function 4.d, requires 1 operable channel with a minimum degree of redundancy of zero. Therefore, CTS requires only one Operable channel associated with only one MFP. CTS Table 3.5-3, Item 4.d, does not require any allowance for single failure. In fact, single failure tolerance is available only if both MFPs are operating and the AFW start channel associated with each MFP is Operable even if not required by CTS. This is acceptable because protection against a loss of heat sink is provided primarily by SG Water Level - Low Low. Signals from two-out-of-three channels from any one SG will start the motor driven AFW pumps. Signals from two-out-of-three channels from any two SGs will start the steam driven AFW pumps.

IP2 has voluntarily revised ITS Function 6.e to require 1 channel per operating MFP. This establishes a new requirement for redundancy for the AFW start function when two MFPs are Operable. In conjunction with this change, IP2 added ITS 3.3.2, Condition H, which will require that IP2 restore single failure tolerance within 48 hours5.555556e-4 days 0.0133 hours 7.936508e-5 weeks 1.8264e-5 months if two MFP are operating. Considering that AFW pumps are started by multiple other diverse functions which provide protection for a loss of heat sink and that IP2 currently has no current requirement for starting AFW on a loss of main feedwater, the new requirement to provide redundancy for this function provides an additional level of conservatism.

Therefore, allowing 48 hours5.555556e-4 days 0.0133 hours 7.936508e-5 weeks 1.8264e-5 months to restore redundancy for the AFW start on loss of feedwater provides a reasonable amount of time to correct a problem before a power reduction is required.

Enterav (I1P2) Action:

None Questions regarding this response should be directed to Dick Bense at (914) 734-5895 (RBENS90Entergy.Com) or Bill Blair at (914) 737-4167 (WBlair@Entergy.Com).

NL-03-052 Attachment 1 Page 44 of 89 3.3.2: Engineered Safety Feature Actuation System (ESFAS)

Instrumentation NRC RAI Number TAC Number:

3.3.2 - 33 MB4739 NRC Request for Additional Information (RAI):

RAI 3.3.2.43 (Item 4) Item 46 DOC A.31.f - Allowable Value for Trip of Main Boiler Feedwater Pump NUREG markup shows that the "AV" is "tbd". Explain the A.31.f write-up.

Entergy (1P2) Response:

IP2 will revise ITS DOC A.31.f to read as follows:

CTS does not identify a limiting safety system setting for this function. Each turbine driven MBFP is equipped with a pressure switch on the control oil line for the speed control system. A low pressure signal (i.e., essentially 0 psig) from this pressure switch indicates a trip of that pump.

ITS 3.3.2, Function 6.e. Auxiliary Feedwater - Trip of Main Boiler Feedwater Pump, will specify an "Allowable Value" (i.e., as-found setpoint) as the Limiting Safety System Setting for this function designed to ensure that calibration error and drift of the pressure switch do not allow the switch to be considered operable at 0 psig or below.

Indian Point 2 is currently in the process of developing an allowable value of this function using a methodology consistent with Part I of ISA-S67.04-1994, "Setpoints for Nuclear Safety-Related Instrumentation" and Regulatory Guide 1.105, "Setpoints for Safety-related Instrumentation." When completed, Indian Point 2 will submit to the NRC a copy of site specific methodology and the results.

Upon NRC approval, the allowable values will be incorporated into the Improved Technical Specification submittal.

Entergv (IP2) Action:

IP2 will revise ITS DOC A.31.f as described above.

Questions regarding this response should be directed to Dick Bense at (914) 734-5895 (RBENS90@Entergy.Com) or Bill Blair at (914) 737-4167 (WBlair@Entergy.Com).

NL-03-052 Attachment 1 Page 45 of 89 3.3.2: Engineered Safety Feature Actuation System (ESFAS)

Instrumentation NRC RAI Number TAC Number:

3.3.2 - 34 MB4739 NRC Request for Additional Information (RAI):

RAI 3.3.2.45 (Item 48)

CTS 4.8.A.1 ITS SR 3.3.2.5 & SR 3.3.2.6 The CTS requirements in CTS 4.8.A.1 are shown to be an instrument channel test, but it appears to be a ESF (AFW) system actuation test. Show where CTS 4.8.A.1 is referenced in CTS Table 4.1-1.

Entergy (IP2) Response:

CTS 4.8.A.1 is not referenced in CTS Table 4.1-1. The CTS requirements for testing AFW Automatic Actuation Logic and Actuation Relays are identified in CTS 4.8.A.1 and CTS Table 4.1-1, Item 30.b as follows:

CTS 4.8.A.1 requires "Verification of proper operation of auxiliary feedwater system components and initiating logic upon receipt of test signals for each mode of automatic initiation" at least once every refueling interval.

CTS Table 4.1-1, Item 30.b, requires a test of "low-low Level AFW Automatic Actuation Logic" at a Frequency specified as monthly with a "test of one logic channel per month on an alternating basis" (i.e., one train per month).

ITS 3.3.2, Function 6.a, AFW-Automatic Actuation Logic and Actuation Relays, requires three tests SR 3.3.2.2, SR 3.3.2.3, and SR 3.3.2.5.

ITS SR 3.3.2.2 requires "Perform ACTUATION LOGIC TEST" every 31 days on a staggered test basis.

ITS SR 3.3.2.5 requires "Perform SLAVE RELAY TEST" every 24 months.

ITS 3.3.2, DOC A.27.e, describes the relationship between the CTS and ITS as follows:

CTS Table 4.1-1, Item 30.b, requires a test of "low-low Level AFW Automatic Actuation Logic" at a Frequency specified as monthly with a "test of one logic channel per month on an alternating basis" (i.e., one train per month).

ITS SR 3.3.2.2, Actuation Logic Test, and ITS SR 3.3.2.3, Master Relay Test, maintain the requirement for testing the automatic actuation logic and actuation relays, respectively, at the same Frequency.

Slave relay operation causes equipment to actuate and CTS Table 4.1-1, Item 30.b is not interpreted as requiring testing of the slave relays. The slave relays (i.e., those associated with AFW Actuation) are currently tested every 24 months as required by CTS 4.8.a.1.

ITS SR 3.3.2.5, Slave Relay Test, establishes a requirement to verify operability of the slave relays Ouestions regarding this response should be directed to Dick Bense at (914) 734-5895 (RBENS90@Entergy.Com) or Bill Blair at (914) 737-4167 (WBlair@Entergy.Com).

NL-03-052 Attachment 1 Page 46 of 89 every 24 months, which is consistent with CrS 4.8.a.1 requirements to test the Steam Line Isolation.

Entergy (MP2) Action:

None Questions regarding this response should be directed to Dick Bense at (914) 734-5895 (RBENS90@Entergy.Com) or Bill Blair at (914) 737-4167 (WBlair@Entergy.Com).

NL-03-052 Attachment 1 Page 47 of 89 3.3.3 : Post Accident Monitoring (PAM) Instrumentation NRC RAI Number TAC Number:

3.3.3 - 1 MB4739 NRC Request for Additional Information (RAI):

RAI 3.3.3-01 CTS: Table 3.5-5 ITS : Table 3.3.3-1, Functions 1, 2, 13, 21, 22 DOC: A.3, A.4, A.19, A.20, A.24 PAM instrumentation functions in Table 3.3.3-1 for Core Exit Temperature (Functions 15,16, 17, and 18) specify 4 required channels. As proposed, the channel requirements do not account for monitoring the core radial temperature gradient. Revise the table entries for these functions to account for monitoring radial temperature gradients using qualified thermocouples by specifying each quadrant contain required channels as "2 trains (c)" with footnote (c) stating that a train consists of 2 core exit thermocouples.

Also, PAM instrumentation functions in Table 3.3.3-1 for Steam Generator Water Level (Wide Range)

(Function 13), Auxiliary Feedwater Flow (Function 19), RCS Subcooling Margin Monitor (Function 21),

and RWST Level (Function 22) instrumentation specify requirements for only 1 channel to be operable.

Provide TS for redundant channels of these functions including Conditions and Required Actions for the required redundant channels capability for these functions not met.

Entergy (IP2) Response:

Part 1:

IP2 will revise the requirement for ITS 3.3.3, Functions 15, 16, 17 and 18 (Core Exit Temperature),

from "4 channels" to "2 trains" with a footnote that clarifies that each train must include a minimum of 2 qualified channels.

The ITS Bases for the core exit temperature functions will provide required clarification as follows:

"Core exit temperature is monitored by the core exit thermocouples (CETs). A total of 65 thermocouples are installed at preselected core locations to provide core exit temperature data up to 2300 F. There are two trains of CETs, one to process data for 34 thermocouples and the other for the remaining 31. The two trains receive power from redundant instrument busses. Two display units (one for each train) are provided on the central control room accident assessment panels. Each presents a graphic core location map with an alphanumeric display of core exit temperatures. "

'This LCO is satisfied by having 2 trains, each with a minimum of 2 qualified CETS (i.e., 4 CETs total) in each of the four quadrants. Requiring 2 qualified CETs each train in each of the four quadrants provides assurance that sufficient CETs are available to support evaluation of core radial decay power distribution. Each pairing of 2 CETs from the same train in each quadrant is considered a separate function."

Part 2:

Questions regarding this response should be directed to Dick Bense at (914) 734-5895 (RBENS90@Entergy.Com) or Bill Blair at (914) 737-4167 (WBlair@Entergy.Com).

NL-03-052 Attachment 1 Page 48 of 89 Issues resulting from IP2's use of a diverse function as the required redundant channel are resolved as follows:

a) RCS Subcooling Margin Monitor:

IP2 will revise requirements for Function 21, RCS Subcooling Margin Monitor, to require two channels of this function as discussed in the Response to RAI 3.3.3 - 5.

b) RCS hot leg temperature (Function 2) and Core Exit Temperature (CET) (Functions 15 through 18).

IP2 will revise Condition C to include the following additional condition: "OR RCS Hot Leg Temperature (Wide Range) channel inoperable and no OPERABLE Core Exit Temperature (CET) trains in the associated quadrant."

Note that the required redundant channel for each of the four loops of RCS hot leg temperature channels is one qualified Core Exit Temperature train (i.e., two channels from the same power supply) in the quadrant associated with that loop. However, IP2 ITS requires 2 trains of CETs, each with 2 qualified CETS (i.e., 4 CETs total) in each of the four quadrants; therefore, RCS hot leg temperature is not required for redundancy for the CETs. The following explanation will be included in the ITS Bases:

"Only one channel per loop of hot leg temperature is required because redundancy is provided by a diverse Function (i.e., either of the two trains of Core Exit Temperature (CET) Function in the core quadrant associated with the loop). If a hot leg temperature channel is inoperable and at least one of the two required trains of CET in the associated quadrant is OPERABLE, entry into Condition A is appropriate. If a hot leg temperature channel is inoperable at the same time both required CET trains in the associated quadrant are inoperable, entry into Condition C is appropriate because there is a loss of function for hot leg temperature for that loop. Additionally, entry into Condition C is also required when both required CET trains in a quadrant are inoperable regardless of the status of the hot leg temperature function in the associated loop because the CETs provide a function for which the hot leg temperature function does not provide redundancy."

c) RCS cold leg temperature (Function 2) and Steam Generator Pressure (Function 20):

IP2 will revise Condition C to include the following additional condition: "OR RCS Cold Leg Temperature (Wide Range) channel inoperable and no OPERABLE SG Pressure channels for the associated SG."

Note that the required redundant channel for each of the four loops of RCS cold leg temperature channels is one Steam Generator Pressure channel in the associated SG. However, IP2 ITS requires 2 channels of Steam Generator Pressure for each SG; therefore, RCS cold leg temperature is not required for redundancy for the SG Pressure channel. The following explanation will be included in the ITS Bases:

"Only one channel per loop of RCS cold leg temperature is required because redundancy for the RCS cold leg temperature is provided by either of the two channels of SG Pressure (Function 20). If a cold leg temperature channel is inoperable and at least one of the two required channels of SG Pressure in the associated SG is OPERABLE, entry into Condition A is appropriate. If a cold leg temperature channel is inoperable at the same time both required SG Pressure channels in the associated SG are inoperable, entry into Condition C is appropriate because there is a loss of function for cold leg temperature for that loop. Additionally, entry into Condition C is required when both required SG Questions regarding this response should be directed to Dick Bense at (914) 734-5895 (RBENS90@Entergy.Com) or Bill Blair at (914) 737-4167 (WBlair@Entergy.Com).

NL-03-052 Attachment 1 Page 49 of 89 Pressure channels in a SG are inoperable regardless of the status of the cold leg temperature function in the associated loop because SG Pressure channels provide a function for which the cold leg temperature function does not provide redundancy."

d) RWST Level:

IP2 will revise ITS LCO 3.3.3, Function 22, RWST Level, to require 2 Operable channels consistent with IP2 commitments made in a letter dated 9/12/85. This is consistent with FSAR 7.5.2.1.4 which states that Refueling water storage tank level measurement is provided by 'Two separate, redundant transmitting channels, which provide level indication and level alarms in the central control room for the initiation of the changeover to the post accident recirculation phase." The requirement for RWST level indication will be met by LT 920 and LT 5751.

e) Steam Generator Water Level (Wide Range) and Auxiliary Feedwater Flow:

Steam Generator Water Level (Wide Range) (Function 13) does not use AFW flow indication (Function

19) as a redundant channel. AFW flow indication is a diverse method for independent verification of the SG wide range level function for confirmation that SG water inventory is sufficient to support post accident cooldown. Therefore, presentation of requirements for SG Water Level (Wide Range) and AFW Flow as "4" channels instead of "1 per steam generator" is necessary to ensure that ITS LCO 3.3.3 maintains both redundancy and diversity for the safety function provided by these instruments (i.e.,

verification that SG water inventory is sufficient to support post accident cooldown, in particular, for the ST tube rupture (SGTR) event). This approach recognizes that the SGTR analysis assumes that two SGs are available to support the cooldown following a SGTR event (i.e., one SG is rendered inoperable as a result of the event and one SG is unavailable due to either single failure or inoperability). If requirements for SG Water Level (Wide Range) are presented as "1 per steam generator," ITS 3.3.3, Condition A, in conjunction with the allowance for separate condition entry would allow all four channels of SG Level Wide Range to be inoperable at the same time for 30 days before any action is required and only AFW Flow (and SG Level (Narrow Range)) would be available.

Requiring 4 channels of SG Water Level (Wide Range) (versus 1 channel per SG) and 4 channels of AFW Flow (versus 1 channel per SG) will require that IP2 enter Condition A when any one SG or AFW Flow Channel is inoperable and will require that IP2 enter Condition C when more than one SG has an inoperable wide range level channel or more than one SG has an inoperable AFW flow channel. This presentation of requirements is consistent with the accident analysis and provides greater assurance that SG Water Level (Wide Range) and its diverse indicator (AFW Flow) will be available for a minimum of 2 SGs which will enable operators to verify that the SGs are capable of performing as a heat sink even when the required SG narrow range level indication is not on scale.

IP2 will revise requirements for Function 13, Steam Generator Water Level (Wide Range), from "1 per steam generator" to "4". This change will require that IP2 enter Condition A when any one SG has an inoperable wide range level channel and will require that IP2 enter Condition C when more than one SG has an inoperable wide range level channel. The ITS Bases for this Function will include the following explanation and justification for this approach using the same approach used for the Bases for AFW flow indication (Function 19). The explanation in the Bases will be as follows:

'The requirement for Steam Generator Water Level (Wide Range) is OPERABILITY of 4 channels of SG Water Level (Wide Range) (versus 1 channel per SG). This presentation of the requirement recognizes that two SGs are required to conduct a plant cooldown (i.e., one SG is unavailable as a result of the Questions regarding this response should be directed to Dick Bense at (914) 734-5895 (RBENS90@Entergy.Com) or Bill Blair at (914) 737-4167 (WBlalr@Entergy.Com).

NL-03-052 Attachment 1 Page 50 of 89 event and a second SG is assumed to be unavailable as a result of a single failure either before or after the event). Requiring one SG Water Level (Wide Range) instrument in each of the 4 SGs is conservative because, if the single failure is assumed to be a Steam Generator Water Level (Wide Range) instrument, the SG associated with the single failure will still be available because SG water inventory could be confirmed using Auxiliary Feedwater flow or either of the two Steam Generator Water Level (Narrow Range) instruments required for each SG. Therefore, entry into Condition A (one required channel inoperable) is required when one SG Water Level (Wide Range) channel is inoperable and entry into Condition C (two or more required channels inoperable) is required if the SG Water Level (Wide Range) channel is inoperable on more than one SG."

Enterav (IP2) Action:

IP2 will revise the requirement for ITS 3.3.3, Functions 15, 16, 17 and 18 (Core Exit Temperature),

from "4 channels" to "2 trains" with a footnote that clarifies that each train must include a minimum of 2 qualified channels. And revise the Bases and DOCs accordingly.

IP2 will revise requirements for Function 21, RCS Subcooling Margin Monitor, to require two channels of this function and revise the Bases and DOCs accordingly.

IP2 will revise Condition Cto include the following additional condition: "OR RCS Hot Leg Temperature (Wide Range) channel inoperable and no OPERABLE Core Exit Temperature (CET) trains in the associated quadrant." The ITS Bases and associated DOCs will be revised accordingly.

IP2 will revise Condition C to include the following additional condition: "OR RCS Cold Leg Temperature (Wide Range) channel inoperable and no OPERABLE SG Pressure channels for the associated SG." The ITS Bases and associated DOCs will be revised accordingly.

IP2 will revise requirements for Function 13, Steam Generator Water Level (Wide Range), from "1 per steam generator" to "4" and revise the Bases and DOCs accordingly.

Questions regarding this response should be directed to Dick Bense at (914) 734-5895 (RBENS90Entergy.Com) or Bill Blair at (914) 737-4167 (WBlalr@Entergy.Com).

NL-03-052 Attachment 1 Page 51 of 89 3.3.3: Post Accident Monitoring (PAM) Instrumentation NRC RAI Number TAC Number:

3.3.3 - 2 MB4739 NRC Request for Additional Information (RAI):

CTS: Table 4.1-1, Table 3.5-5 iTS: Table 3.3.3-1 DOC: M.1 The proposed changes to CTS will add requirements for 2 channels of Containment Pressure (wide range). If 2 or more channels are inoperable, the ITS proposes a 7-day AOT with an alternate monitoring method requirement if the channel is inoperable past 7 days. The STS provide alternate monitoring for loss of instrument function if at least one instrument channel cannot be restored to operable status if the instrument detectors are inaccessible during plant operation. Revise the DOC and proposed ITS to require a plant shutdown if 2 channels of ITS Function 8, Containment Pressure (wide range) are inoperable for more than 7 days.

Entergy (IP2) Response:

IP2 will revise ITS Table 3.3.3-1, Function 8, Containment Pressure (Wide Range), to reference Condition E and Required Actions E.1 and E.2 when two or more required channels are inoperable for more than 7 days. Required Actions E.1 and E.2 will require that the plant be in Mode 3 in 6 hours6.944444e-5 days 0.00167 hours 9.920635e-6 weeks 2.283e-6 months and Mode 4 in 12 hours1.388889e-4 days 0.00333 hours 1.984127e-5 weeks 4.566e-6 months . IP2 will revise DOC A.10 and add DOC M.7 to describe and justify this change.

Note IP2 will revise to change the name of ITS Table 3.3.3-1, Function 8, from "Containment Pressure (Wide Range)" (which is used in the CTS) to "Containment Pressure (High Range)." Additionally, IP2 will revise to change the name of ITS Table 3.3.3-1, Function 7, from "Containment Pressure (Narrow Range)" to "Containment Pressure." These changes are being made so that Technical Specification nomenclature more closely matches design documents and control room labeling.

Entergy (IP2) Action:

IP2 will revise ITS Table 3.3.3-1, Function 8, Containment Pressure (Wide Range), to reference Condition E. IP2 will revise DOC A.10 and add DOC M.7 to describe and justify this change.

IP2 will revise to change the name of ITS Table 3.3.3-1, Function 8, from "Containment Pressure (Wide Range)" to "Containment Pressure (High Range)." Additionally, IP2 will revise to change the name of ITS Table 3.3.3-1, Function 7, from "Containment Pressure (Narrow Range)" to "Containment Pressure."

Questions regarding this response should be directed to Dick Bense at (914) 734-5895 (RBENS90Entergy.Com) or Bill Blair at (914) 737-4167 (WBlair(@Entergy.Com).

NL-03-052 Attachment 1 Page 52 of 89 3.3.3: Post Accident Monitoring (PAM) Instrumentation NRC RAI Number TAC Number:

3.3.3 - 3 MB4739 NRC Request for Additional Information (RAI):

CTS: Table 4.1-1, Table 3.5-5 ITS: Table 3.3.3-1 DOC: N/A NUREG markup of Required Action C.1 adds the phrase "all but" to the requirement to "restore one channel to operable status." Delete this change to the ITS; it is unnecessary based on Note 2 to ITS Actions which permits separate condition entry for each Function.

Entergv (1P2) Response:

IP2 needs to maintain the phrase "all but one" in IP2 ITS 3.3.3, Condition C, because, as described in paragraph e of part 2 of the resposne to RAI 3.3.3-1, IP2 will require 4 channels of SG Water Level (Wide Range) (versus 1 channel per SG) and 4 channels of AFW Flow (versus 1 channel per SG). This will require that IP2 enter Condition A when any one SG or AFW Flow Channel is inoperable and will require that IP2 enter Condition Cwhen more than one SG has an inoperable wide range level channel or more than one SG has an inoperable AFW flow channel. The phrase "all but one" must be maintained in Requried Action C.1 to ensure that Condition C is not exited as allowed by ITS LCO 3.0.2 until only one channel of SG Level (wide range) or only one channel of AFW flow is left inoperable.

Without this phrase, Requried Action C.1 could be met when more than one channel remains inoperable.

Entergy (IP2) Action:

None Questions regarding this response should be directed to Dick Bense at (914) 734-5895 (RBENS90Entergy.Com) or Bill Blair at (914) 737-4167 (WBlair@Entergy.Com).

NL-03-052 Attachment 1 Page 53 of 89 3.3.3 : Post Accident Monitoring (PAM) Instrumentation NRC RAI Number TAC Number:

3.3.3 - 4 MB4739 NRC Request for Additional Information (RAI):

CTS: 3.3.A.l.k, Table 4.1-1 ITS: Table 3.3.3-1, LCO 3.5.4 DOC: L.4 The ITS proposes to decrease the required Calibration Frequency of the RWST Level indication from every 92 days to every 24 months, whereas the ITS SR 3.5.4.4 will retain existing TS for calibration of the RWST Level alarms every 92 days. Provide a technical basis for applying different test intervals to test of the level instrument channel components. Explain how the two tests can be distinct from one another.

Entergv (IP2) Response:

IP2 will revise DOC L.4 and ITS SR 3.3.3.2 to require that ITS LCO 3.3.3, Function 22, RWST Level, is calibrated once every 92 days consistent with CTS 4.1-1, Item 14. This Frequency is consistent with calibration procedures PC-Q2.

Entergy (IP2) Action:

IP2 will revise DOC L.4 and ITS SR 3.3.3.2 to requires that ITS LCO 3.3.3, Function 22, RWST Level, is calibrated once every 92 days.

Questions regarding this response should be directed to Dick Bense at (914) 734-5895 (RBENS90@Entergy.Com) or Bill Blair at (914) 737-4167 (WBlair@Entergy.Com).

NL-03-052 Attachment 1 Page 54 of 89 3.3.3: Post Accident Monitoring (PAM) Instrumentation NRC RAI Number TAC Number:

3.3.3 - 5 MB4739 NRC Reguest for Additional Information (RAI):

CTS: Table 3.5-5 iTS: Table 3.3.3-1 DOC: L.6, M.5 The ITS proposes only one Subcooling Margin Monitor instrument channel required to be operable: The staff notes the following current design basis for PAM subcooling margin instrumentation:

8/30/85: Licensee declared RCS Subcooling Margin monitor to be Type A, but Category 2 because the monitor is not seismically qualified and there is not a redundant monitor.

9/12/86: Licensee stated that the RCS Subcooling Margin monitor is a single readout and a second readout is provided by the SAS/Safety Parameter Display System. However, these are not seismically qualified. Inputs to existing RCS Subcooling Margin monitor and SAS/SPDS are redundant and qualified.

During and after seismic events qualified RCS pressure and temperature instrumentation can be used.

10/18/88: Upgrade to redundant SMM scheduled for 1990. Staff SER accepted monitor and computer not seismically qualified and use of RCS pressure and temperature used to calculate subcooling margin based on staff acceptance for NUREG-0737, Item ll.F.2.

Provide safety basis discussion to show that post-accident management objectives can be met as required by RG 1.97, without a redundant Subcooling Margin Monitor instrument channel required to be operable. Include discussion regarding any reduction in commitment that may result from proposed TS.

Entercy (IP2) Response:

IP2 will revise requirements for Function 21, RCS Subcooling Margin Monitor, to require two channels of this function. DOC A.19 will be revised and DOC M.8 will be added to describe and justify this change.

Entergy (IP2) Action:

IP2 will revise requirements for Function 21, RCS Subcooling Margin Monitor, to require two channels of this function. DOC A.19 will be revised and DOC M.8 will be added to describe and justify this change.

Ouestions regarding this response should be directed to Dick Bense at (914) 734-5895 (RBENS90@Entergy.Com) or Bill Blair at (914) 737-4167 (WBlalr@ Entergy.Com).

NL-03-052 Attachment 1 Page 55 of 89 3.3.3: Post Accident Monitoring (PAM) Instrumentation NRC RAI Number TAC Number:

3.3.3 - 6 MB4739 NRC Reauest for Additional Information (RAI):

CTS: n/a ITS: Table 3.3.3-1 DOC: M.5 The ITS proposes only one RWST Level instrument channel is required to be operable. The staff notes the following current design basis for PAM RWST instrumentation:

8/30/85: Licensee declared RWST Level to be Type A, but Category 2 because it was not redundant.

9/12/85: Licensee stated that upgrade is required to meet Category 1 requirements and that a second qualified channel will be installed.

Provide a safety basis evaluation to show that post-accident management objectives can be met as required by RG 1.97 without an operable redundant RWST level instrument channel.

Entergy (IP2) Response:

IP2 will revise ITS LCO 3.3.3, Function 22, RWST Level, to require 2 Operable channels consistent with IP2 commitments made in a letter dated 9/12/85. This is consistent with FSAR 7.5.2.1.4 which states that Refueling water storage tank level measurement is provided by "Two separate, redundant transmitting channels, which provide level indication and level alarms in the central control room for the initiation of the changeover to the post accident recirculation phase." This requirement will be met by LT 920 and LT 5751.

Entergy (IP2) Action:

IP2 will revise ITS LCO 3.3.3, Function 22, RWST Level, to require 2 Operable channels.

Questions regarding this response should be directed to Dick Bense at (914) 734-5895 (RBENS90CEntergy.Com) or Bill Blair at (914) 737-4167 (WBlair@Entergy.Com).

NL-03-052 Attachment 1 Page 56 of 89 3.3.4: Remote Shutdown NRC RAI Number TAC Number:

3.3.4 - 1 NRC Reauest for Additional Information (RAI):

Item 1 CTS: none DOC: M.4, M.5 ITS: SR 3.3.4.2, SR 3.3.4.3 DOC Summary M.4 states that requirements are added (SR 3.3.4.2) to verify every 24 months that each remote shutdown control circuit and transfer switch performs the intended function. DOC Summary M.5 states that requirements are added (SR 3.3.4.3) to perform a Channel Calibration every 24 months on each remote shutdown instrumentation channel with the exception of the neutron detectors. DOCs M.4 and M.5 justify the addition of requirements to perform the noted surveillances. Provide revised DOCs that include justification for the specified frequency since the CTS do not include these specific surveillance requirements.

CTS Table 4.1-1.

Entergv (IP2) Response:

ITS 3.3.4, Table B 3.3.4 - 1, Remote Shutdown Instrumentation and Controls, is based on requirements in IP2 procedures AOI 27.1.9, Control Room Inaccessibility Safe Shutdown Control, and SAO - 703, Fire Protection Impairment Criteria and Surveillance. The 24 month SR Frequency for testing and calibration is based on the existing requirements in SAO-703 which governs testing of equipment identified in these procedures.

Entergv (IP2) Action:

IP2 will revise ITS 3.3.4, DOCs M.4 and M.5, to explain that the SR Frequency is consistent with existing requirements.

Questions regarding this response should be directed to Dick Bense at (914) 734-5895 (RBENS90@Entergy.Com) or Bill Blair at (914) 737-4167 (WBlair@Entergy.Com).

NL-03-052 Attachment 1 Page 57 of 89 3.3.4: Remote Shutdown NRC RAI Number TAC Number:

3.3.4 - 2 NRC Request for Additional Information (RAI):

Item 2 CTS: none DOC: none ITS: none The ITS Bases Table 3.3.4-1 specifies that the Reactor Trip & Bypass Breaker Trip Switch; or 21 MG Set

& 22 MG Set Trip Switch remote shutdown Function (1.c) are required to be operable. The ITS proposes to delete surveillance SR 3.3.4.4, "Perform TADOT of the reactor trip breaker open/closed indication" which specifies an 18 month frequency. This proposed STS deviation is not evaluated.

Show that the proposed ITS Surveillance requirements for Bases Table 3.3.4-1, Function 1.c will verify operability of the reactor trip breakers open and closed indication to ensure plant remote shutdown requirements and capabilities are met.

Entergy (IP2) Response:

IP2 did not include STS (NUREG-1431) SR 3.3.4.4, "Perform TADOT of the reactor trip breaker open/closed indication" because, as explained in the STS Bases, this is verification of breaker position indication on the remote shutdown panel. IP2 does not have a remote shutdown panel and uses the indication on the Reactor Trip Breaker to satisfy ITS 3.3.4, Function 1.b, Reactor Trip and Bypass Breaker Position. IP2 verifies Reactor Trip and Bypass Breaker local indication as an integral part of the acceptance criteria of ITS SR 3.3.1.4, Perform TADOT every 31 days on a staggered test basis for both reactor trip breakers and RTB undervoltage and shunt trip mechanism. This test is currently performed every 31 days on a staggered test basis by procedure PT-2M 2 (and PT-2M 3), "Reactor Protection Logic Train A (and B) Functional Test."

IP2 will revise ITS 3.3.4 to include JFC X.1 which will explain the above.

Entergy (IP2) Action:

IP2 will revise ITS 3.3.4 to include JFC X.1 which will explain the above.

Questions regarding this response should be directed to Dick Bense at (914) 734-5895 (RBENS90@Entergy.Com) or Bill Blair at (914) 737-4167 (WBlair@Entergy.Com).

NL-03-052 Attachment 1 Page 58 of 89 3.3.4: Remote Shutdown NRC RAI Number TAC Number:

3.3.4 - 3 NRC Request for Additional Information (RAI):

Item 3 Revise the IP2 Bases to be consistent with IP3 Remote Shutdown Bases.

Entergy (IP2) Response:

IP2 will revise the Background Section of the Bases of ITS 3.3.4 to be more consistent with the description used in the IP3 Bases.

Entergv (IP2) Action:

IP2 will revise the Background Section of the Bases of ITS 3.3.4 to be more consistent with the description used in the IP3 Bases.

Questions regarding this response should be directed to Dick Bense at (914) 734-5895 (RBENS90@Entergy.Com) or Bill Blair at (914) 737-4167 (WBlair@Entergy.Com).

NL-03-052 Attachment 1 Page 59 of 89 3.3.4: Remote Shutdown NRC RAI Number TAC Number:

3.3.4 - 4 NRC Request for Additional Information (RAI):

Item 4 Revise Insert 3.3.4-1-01 to include "Reference 2" Entergy (IP2) Response:

IP2 will revise Insert 3.3.4-1-01 to include "Reference 2."

Entergy (IP2) Action:

IP2 will revise Insert 3.3.4-1-01 to include "Reference 2."

Questions regarding this response should be directed to Dick Bense at (914) 734-5895 (RBENS90@Entergy.Com) or Bill Blair at (914) 737-4167 (WBIair@ilEntergy.Com).

NL-03-052 Attachment 1 Page 60 of 89 3.3.4 : Remote Shutdown NRC RAI Number TAC Number:

3.3.4 - 5 NRC Reguest for Additional Information (RAI):

Item 5 Bases Table B 3.3.4-1, Remote Shutdown Instrumentation and Controls lists required GDC-19 Functions/Instruments or Control Parameters in the first column and the required number of Functions in the second column. The Reviewers Note to Bases Table B 3.3.4-1 permits a requirement of only one channel per a given Function if the unit has justified such a design, and the NRC's SER accepted the justification. Provide a citation of an NRC SER for IP2 approving only one channel of a given GDC 19 function for those Bases Table B 3.3.4-1 functions with one required channel, otherwise submit appropriate justification for staff review. Clarify the Bases references in Bases insert 3.3.4-1-01.

Entergy (IP2) Response:

10 CFR 50, Appendix A, Criterion 19, Control Room, includes the requirement that "Equipment at appropriate locations outside the control room shall be provided (1) with a design capability for prompt hot shutdown of the reactor, including necessary instrumentation and controls to maintain the unit in a safe condition during hot shutdown, and (2) with a potential capability for subsequent cold shutdown of the reactor through the use of suitable procedures."

IP2 requirements for meeting 10 CFR 50, Appendix A, Criterion 19, requirements for reactor shutdown outside the control room are specified in UFSAR 7.7.3, Emergency Shutdown Control, and implemented by IP2 procedures AOI 27.1.9, Control Room Inaccessibility Safe Shutdown Control, and SAO - 703, Fire Protection Impairment Criteria and Surveillance. Other than the SER associated with the original FSAR, no SER evaluating IP2 remote shutdown capability was identified. IP2 ITS 3.3.4 and the procedures it is based on do not require redundancy for any function other than reactor trip capability. This is identical to the requirements specified in STS (NUREG-1431). IP2 believes that 10 CFR 50, Appendix A, Criterion 19, requirements for remote shutdown do not specify any requirements for redundancy of instruments or controls.

Entergy (1P2) Action:

None.

Questions regarding this response should be directed to Dick Bense at (914) 734-5895 (RBENS90@Entergy.Com) or Bill Blair at (914) 737-4167 (WBlair@Entergy.Com).

NL-03-052 Attachment 1 Page 61 of 89 3.3.5: Loss of Power (LOP) Diesel Generator (DG) Start Instrumentation NRC RAI Number TAC Number:

3.3.5 - 1 MB4739 NRC Request for Additional Information (RAI):

Item 1 CTS: Table 3.5-3, Function 3.a, 480 V Emergency Bus Undervoltage ITS: Required Actions DOC: M.1, A.3.c, A.3.d The proposed LOP DG Start Instrumentation LCO requires one of two installed undervoltage channels to be operable. The proposed limits are consistent with current TS. However, the proposed ITS Actions are a relaxation of the CTS Actions and the actions represent an unapproved generic change to NUREG-1431 required actions for undervoltage instrumentation when the LCO is not met. The staff finds the proposed licensing basis changes unacceptable. For undervoltage instrumentation channels, the staff notes that the proposed ITS permit startup and operation with one of two undervoltage channels inoperable on all 480 volt buses. The ITS also relax current TS required actions to permit one hour to restore an inoperable channel (during which time no operable LOP DG start channel would be monitoring buss voltage) and add required actions to restore the required actions to declare the supported AC power source inoperable for the degraded conditions specified in proposed ITS Condition C. The DOC do not provide sufficient safety analysis for the proposed TS changes. Revise the ITS to require a plant shutdown for one Undervoltage Function channel inoperable, current TS Table 3.5-3 action, for Function 3.a.

Entergy (IP2) Response:

Based on reviews of ITS performed by IP2 Operations, IP2 determined that CFS Table 3.5-3, Function 4.c, Auxiliary Feedwater-Station Blackout (Start Motor Driven and Turbine Driven Pumps) should also have been included as a requirement in ITS 3.3.5, Loss of Power (LOP) Diesel Generator (DG) Start Instrumentation.

IP2 will revise ITS 3.3.5, to add requirements for 3 channels per bus of the Station Blackout (SBO)

(Undervoltage Bus 5A or Bus 6A), as described in the response to ITS 3.3.2 RAI-9. In conjunction with this change, ITS 3.3.2 will be revised to include new Conditions A, B and C to address inoperable channels and/or trains of the SBO function. This change is necessary because Operability of the SBO Function is required for the start of any of the three DGs. Requirements in ITS will parallel the new requirements in ITS 3.3.2, Function 6.d, Auxiliary Feedwater-Station Blackout (SBO) (Undervoltage Bus 5A or Bus 6A) (See Response to RAI 3.3.2-5 for name change).

This change is based on requirements currently in CTS Table 3.5-3, Function 4.c, Auxiliary Feedwater-Station Blackout (Start Motor Driven and Turbine Driven Pumps), which requires 1 operable channel with a minimum degree of redundancy of zero. This is interpreted as requiring that the Function be Operable for either bus 5A or 6A. This is consistent with drawing 9321-LL-3117, Sheets 3, 3A and 3B, Schematic Diagram 480 VAC Interlocking Relays, which show that the SBO 480 V bus undervoltage Function has three relays on bus 5A and three relays on bus 6A. For bus 5A, the relays are 27-51 Questions regarding this response should be directed to Dick Bense at (914) 734-5895 (RBENS90@Entergy.Com) or Bill Blair at (914) 737-4167 (WBlair@Entergy.Com).

NL-03-052 Attachment 1 Page 62 of 89 (Phase A-B), 27-52 (Phase B-C), and 27-53 (Phase C-A). For bus 6A, the relays are 27-61 (Phase A-B),

27-62 (Phase B-C), and 27-63 (Phase C-A). The SBO function actuates on two of three channels on either bus 5A or Bus 6A. The setpoints, approximately 46 percent of nominal, are designed to provide a fast trip response under complete loss-of-power ("dead bus") conditions of either of the two buses that provide all offsite power to the plant safety systems. Therefore, the CTS Table 3.5-3, Function 4.c, meets requirements for redundancy using only one of the two buses equipped with this function.

Therefore, Required Actions for the inoperable SBO (Undervoltage Bus 5A or Bus 6A) will be as follows:

Condition A: One SBO Undervoltage channel inoperable.

Req. Action: Place channel in trip within 14 days. (Note that Separate Condition entry is allowed for each bus.) (Bases will justify 14 day Completion Time based on fact that SBO Function still has redundancy even with one channel from each bus inoperable because two channels from either bus will initiate the SBO function for loading all three DGs and starting both AFW pumps.)

Condition B: One SBO train with two or more channels inoperable. (Bases will explain that this Condition applies even if one of the channels is already in trip as required by Condition B).

Req. Action: Restore SBO train to OPERABLE status within 48 hours5.555556e-4 days 0.0133 hours 7.936508e-5 weeks 1.8264e-5 months (Bases will define an Operable SBO train as having either three Operable channels or two Operable channels with the third channel in trip.) (Bases will justify 48 hour5.555556e-4 days 0.0133 hours 7.936508e-5 weeks 1.8264e-5 months Completion Time based on fact that SBO Function still has redundancy even with one channel from each bus inoperable because two channels from either bus will initiate the SBO function.)

Condition C: Required Action and Completion Time of A or B not met.

Req. Action: Be in Mode 3 and Be in Mode 5 in 36 hours4.166667e-4 days 0.01 hours 5.952381e-5 weeks 1.3698e-5 months .

Based on the changes described above, IP2 will maintain requirements for the Undervoltage channels and Degraded Voltage channels as proposed. IP2 will revise ITS 3.3.5, DOC A.3.d, and add ITS 3.3.5, DOC L.2, to explain and justify the change to the Required Action when the 480 V bus undervoltage trip function is lost on one 480 V bus for more than 1 hour1.157407e-5 days 2.777778e-4 hours 1.653439e-6 weeks 3.805e-7 months or if the 480 V bus undervoltage trip function is lost on more than one 480 V bus. This is a less restrictive change because when in this condition CTS Table 3.5-3, Function 3.a, requires an immediate reactor shutdown; whereas, ITS 3.3.5, Required Action C.1 will require only that the associated DG is declared inoperable.

Enteray (IP2) Action:

IP2 will revise ITS 3.3.5 to add requirements for 3 channels per bus of the Station Blackout (SBO)

(Undervoltage Bus 5A or Bus 6A), as described above.

IP2 will revise ITS 3.3.5, DOC A.3.d, and add ITS 3.3.5, DOC L.2, to explain and justify the change to the Required Action when the 480 V bus undervoltage trip function is lost on one 480 V bus for more than 1 hour1.157407e-5 days 2.777778e-4 hours 1.653439e-6 weeks 3.805e-7 months or if the 480 V bus undervoltage trip function is lost on more than one 480 V bus.

Questions regarding this response should be directed to Dick Bense at (914) 734-5895 (RBENS90@Entergy.Com) or Bill Blair at (914) 737-4167 (WBlair@iEntergy.Com).

NL-03-052 Attachment 1 Page 63 of 89 3.3.5: Loss of Power (LOP) Diesel Generator (DG) Start Instrumentation NRC RAI Number TAC Number:

3.3.5 - 2 MB4739 NRC Request for Additional Information (RAI):

Item 2 CTS: 3.5.1 ITS: Applicability requirements DOC: A.3.a This DOC Category is Administrative; no technical changes. This DOC should be revised to clearly discuss the administrative changes that are proposed by the submittal in order to retain CTS applicability requirements in the ITS. All other applicability requirements need to be discussed in separate DOCs.

Enterav (IP2) Response:

ITS 3.3.5, DOC A.3.a, is a road map that explains the changes to the Applicability requirements for CTS Table 3.5-1, Item 8.a, 480 V Emergency Bus Undervoltage (Loss of Voltage) and CTS Table 3.5-3, Item 3.a, 480 V Emergency Bus Undervoltage (Loss of Voltage). ITS 3.3.5, DOC M.1, provides justification for the more restrictive applicability requirements for the 480 V Emergency Bus Undervoltage function which is retained in ITS LCO 3.3.5.

IP2 will revise ITS 3.3.5, DOCs A.3.a and M.1, to provide the following improved description of the change to the Applicability:

CTS Table 3.5-1, Item 8.a, 480 V Emergency Bus Undervoltage (Loss of Voltage) and CTS Table 3.5-3, Item 3.a, 480 V Emergency Bus Undervoltage (Loss of Voltage) establish requirements for an automatic DG start on loss of voltage on any of the 480 V safeguards buses.

CTS 3.5.1 establishes the Applicability for Engineered Safety Features initiation instrumentation as whenever the plant is not in the cold shutdown condition. This is consistent with CTS Table 3.5-3 which establishes an implied Applicability by requiring that the plant be placed in cold shutdown (i.e., Mode 5) if requirements cannot be met. This is also consistent with the CTS requirement that DGs are required to be Operable only when above cold shutdown (i.e., Mode 5).

ITS LCO 3.3.5 maintains the requirement that LOP DG start instrumentation is Operable above cold shutdown (i.e., Modes 1, 2, 3 and 4); however, ITS 3.8.2 establishes a new requirement that DGs are Operable in Mode 5 and Mode 6 and when moving recently irradiated fuel (See ITS 3.8.2, DOC M.1).

Therefore, ITS LCO 3.3.5 is revised to require that LOP DG start instrumentation is Operable whenever a DG is required to be Operable. This means that ITS 3.3.5 adds a new requirement that LOP DG start instrumentation must be Operable in Modes 5 and 6 and during movement of recently irradiated fuel assemblies.

Entergy (IP2) Action:

IP2 will revise ITS 3.3.5, DOCs A.3.a and M.1, to include the additional description provided above.

Questions regarding this response should be directed to Dick Bense at (914) 734-5895 (RBENS90@Entergy.Com) or Bill Blair at (914) 737-4167 (WBlair@Entergy.Com).

NL-03-052 Attachment 1 Page 64 of 89 3.3.5: Loss of Power (LOP) Diesel Generator (DG) Start Instrumentation NRC RAI Number TAC Number:

3.3.5 - 3 MB4739 NRC Reauest for Additional Information (RAI):

Item 3 - BSI for staff review CTS: Table 3.5-1, Item 8.a, 480 V Emergency Bus Undervoltage (Loss of Voltage)

ITS: Allowable Values and Setpoints DOC: A.3.f, A.4.f, L.1 ITS proposed Allowable Value trip setpoint are under development by the licensee to be submitted in a future revision to ITS.

Entergv (IP2) Response:

The IP2 setpoint methodology is documented in IP2 Specification No. FIX-95-A-001, "Guidelines For Preparation Of Instrument Loop Accuracy And Setpoint Determination Calculations," Revision 1. The calculations supporting allowable values for ITS LCO 3.3.1, Reactor Protection System (RPS)

Instrumentation, ITS 3.3.2, Engineered Safety Feature Actuation System (ESFAS) Instrumentation, and ITS 3.3.5, Loss of Power (LOP) Diesel Generator (DG) Start Instrumentation, are currently being developed. The results of these calculations and sample calculations will be provided to the NRC in a separate submittal.

Entergy (IP2) Action:

IP2 will make a separate submittal for all of the allowable values for ITS 3.3.1, Reactor Protection System, ITS 3.3.2, Engineered Safety Feature Actuation System, and ITS 3.3.5, Loss of Power Diesel Generator Start Instrumentation.

Questions regarding this response should be directed to Dick Bense at (914) 734-5895 (RBENS90@Entergy.Com) or Bill Blair at (914) 737-4167 (WBlair@Entergy.Com).

NL-03-052 Attachment 1 Page 65 of 89 3.3.5: Loss of Power (LOP) Diesel Generator (DG) Start Instrumentation NRC RAI Number TAC Number:

3.3.5 - 4 MB4739 NRC Request for Additional Information (RAI):

Item 4 CTS: Table 3.5-3, Function 3.b ITS: 3.3.5, degraded voltage function DOC: A.4.b This DOC explains the requirements for the number of channels. There is a change to the number of required channels to 2 channels per trip logic from 1 channel per trip logic. The proposed TS is more restrictive than CTS requirements. Revise the submittal to provide appropriate discussion.

Entergy (IP2) Response:

ITS 3.3.5, DOC A.4.b, explains differences between CTS and ITS requirements for the number of channels of 480 V bus degraded voltage as follows:

CTS Table 3.5-3, Function 3.b, requires 1 operable channel per bus with a minimum degree of redundancy of zero (See ITS 3.3.5, DOC A.5). This requires that only one of the two installed channels is Operable; however, the IP2 design has 2 channels per bus and a signal from both channels is required to start the associated diesel generator (DG). Additionally, CTS Table 3.5-3, Note 3, specifies separate Actions for one inoperable channel and two inoperable channels. The intent of this presentation is to require two Operable channels or one Operable channel with the other channel in trip. This discrepancy was necessary because the IP2 use of the concept of degree of redundancy does not allow for proper presentation of a requirement of a two out of two trip logic.

ITS 3.3.5, 480 V bus degraded voltage function - LOP DG Start Instrumentation, corrects the presentation of requirements and maintains the existing requirement that two channels associated with each bus must be Operable.

IP2 will revise ITS 3.3.5, DOC A.4.b, to explain that this is a more restrictive change and provide appropriate justification in ITS 3.3.5, DOC M.3.

Entergy (IP2) Action:

IP2 will revise ITS 3.3.5, DOC A.4.b, to explain that differences between CTS and ITS requirements for the number of channels of 480 V bus degraded voltage is a more restrictive change and provide appropriate justification in ITS 3.3.5, DOC M.3.

Questions regarding this response should be directed to Dick Bense at (914) 734-5895 (RBENS90@ Entergy.Com) or Bill Blair at (914) 737-4167 (WBlair@Entergy.Com).

NL-03-052 Attachment 1 Page 66 of 89 3.3.5: Loss of Power (LOP) Diesel Generator (DG) Start Instrumentation NRC RAI Number TAC Number:

3.3.5 - 5 MB4739 NRC Request for Additional Information (RAI):

Item 5 CTS: Table 3.5-3, Function 3.b ITS: 3.3.5, degraded voltage function DOC: A.4.b This DOC makes a statement that a 480 V undervoltage channel and a 480 V degraded voltage channel will trip when an undervoltage signal from any two of the three 480 V bus phases exceeds the specified limits. The DOC also states that a channel is inoperable when the sub channel for any phase is inoperable. Explain the proposed ITS requirements for the 2 out-of 3 bus phase trips and the sub channel phase operability requirements. Explain how the trip logic design supports CTS action completion times.

Enteray (1P2) Response:

IP2 will revise the Bases for ITS 3.3.5 and DOC A.4.b to delete the statement that the undervoltage and degraded voltage function will detect loss of any one phase.

The IP2 design for DG start on undervoltage and degraded voltage both consist of two channels on each of the following busses: 480 V Buses 5A, 2A, 3A and 6A. The channels monitor voltage difference between two of the three phases (Phases A to B and Bto C). Therefore, in some cases, neither the undervoltage nor the degraded voltage function will start the DGs on the loss of a single phase.

Entergy (IP2) Action:

IP2 will revise the Bases for ITS 3.3.5 and DOC A.4.b to delete the statement that the undervoltage and degraded voltage function will detect loss of any one phase.

Questions regarding this response should be directed to Dick Bense at (914) 734-5895 (RBENS90Entergy.Com) or Bill Blair at (914) 737-4167 (WBlalr@Entergy.Com).

NL-03-052 Attachment 1 Page 67 of 89 3.3.5: Loss of Power (LOP) Diesel Generator (DG) Start Instrumentation NRC RAI Number TAC Number:

3.3.5 - 6 MB4739 NRC Request for Additional Information (RAI):

Item 6 CTS: Table 3.5-3, Function 3.b, Note (3)

ITS: 3.3.5, degraded voltage function DOC: A.4.c, A.4.d, M.2 This DOC explains the required actions for one inoperable channel. The description of change states that the Note (3) specified Actions can be interpreted to be consistent with ITS action to trip an inoperable channel within one hour and the action to declared the associated DG inoperable. Note (3)(a) and (3)(b) discuss actions if the 138kV sources of offsite power and the 13.8. kV source of offsite power are available. Clarify how the ITS proposed actions are based on CTS interpretations. Include discussions of which parts of Table 3.5-3, Note (3) are translated into ITS Actions B.1 and C.1.

Evaluate any parts of the CTS Table Note (3) that are deleted from ITS.

Entergy (IP2) Response:

IP2 will revise DOCs A.4.c and M.2 to explain how and why Note (3) to CTS Table 3.5-3, Function 3.b, requires Actions for an inoperable degraded voltage channel that are consistent with declaring the associated DG inoperable.

Entercv (IP2) Action:

IP2 will revise DOCs A.4.c and M.2 to explain how and why Note (3) to CTS Table 3.5-3, Function 3.b, requires Actions for an inoperable degraded voltage channel that are consistent with declaring the associated DG inoperable.

Questions regarding this response should be directed to Dick Bense at (914) 734-5895 (RBENS900Entergy.Com) or Bill Blair at (914) 737-4167 (WBlair@Entergy.Com).

NL-03-052 Attachment 1 Page 68 of 89 3.3.5: Loss of Power (LOP) Diesel Generator (DG) Start Instrumentation NRC RAI Number TAC Number:

3.3.5 - 7 MB4739 NRC Request for Additional Information (RAI):

Item 7 CTS: Table 4.1-1, No. 29.c ITS: none, relocated detail DOC: LA.2 Provide discussion in DOC LA.2 which states the safety basis for proposing the relocation of the affected CTS details.

Entergy (IP2) Response:

IP2 will revise ITS 3.3.5, DOC LA.2, to provide additional justification for relocation of the requirement for periodic testing of the 480 V emergency bus undervoltage alarm to a licensee document controlled by 10 CFR 50.59 (i.e., IP2 UFSAR 7.5.2.1.12).

Entergy (IP2) Action:

IP2 will revise ITS 3.3.5, DOC LA.2, to provide additional justification for relocation of the requirement for periodic testing of the 480 V emergency bus undervoltage alarm to a licensee document controlled by 10 CFR 50.59 (i.e., IP2 UFSAR 7.5.2.1.12).

Questions regarding this response should be directed to Dick Bense at (914) 734-5895 (RBENS90@Entergy.Com) or Bill Blair at (914) 737-4167 (WBlair@Entergy.Com).

NL-03-052 Attachment 1 Page 69 of 89 3.3.6: Containment Purge System and Pressure Relief Line Isolation Instrumentation NRC RAI Number TAC Number:

3.3.6 - 1 MB4739 NRC Request for Additional Information (RAI):

Item 1 CTS: CTS 3.8.A.1 and CTS 3.8.B.11 ITS: ITS 3.3.6 Applicability, Table 3.3.6-1 footnote (a),

DOC: L.1, A.3.a, A.4.a JFD: DB.1, X.1 This RAI is based on RAI 3.6-1. RAI 3.6-1 noted inconsistencies with approved TSTF-51 for operability requirements "during movement of recently irradiated fuel." The Entergy (IP2) response to RAI 3.6-1 dated 10/6/2002 committed to incorporate NUREG-1431 requirements that are applicable only during movement of "recently irradiated fuel." The response concluded IP2 ITS 3.3.6, Containment Purge System and Pressure Relief Line Isolation Instrumentation will be revised. Provide revised ITS 3.3.6 Applicability, Actions and Table 3.3.6-1 in response to RAI 3.6-1.

Entergy (IP2) Response:

IP2 will revise ITS 3.3.6 to require that Containment Purge System and Pressure Relief Line Isolation Instrumentation be Operable during movement of "recently irradiated fuel" in accordance with TSTF-51.

Revision 0 of the IP2 ITS 3.3.6 did not incorporate requirements that are applicable only during movement of "recently" irradiated fuel because the IP2 definition of 'recently' irradiated fuel is any fuel that has been part of a critical reactor in the previous 100 hours0.00116 days 0.0278 hours 1.653439e-4 weeks 3.805e-5 months and CTS 3.8.B.4 prohibits movement of fuel from the vessel until 100 hours0.00116 days 0.0278 hours 1.653439e-4 weeks 3.805e-5 months after reactor shutdown. Therefore, unless CTS 3.8.B.4 (which is being relocated to Technical Requirements Manual 3.9.A by Relocated Item R.24) is changed to allow movement of fuel from the reactor vessel in less than 100 hours0.00116 days 0.0278 hours 1.653439e-4 weeks 3.805e-5 months after reactor shutdown, IP2 ITS 3.3.6 will never be Applicable during movement of any irradiated fuel.

Enteray (1P2) Action:

IP2 will revise ITS 3.3.6 to require that Containment Purge System and Pressure Relief Line Isolation Instrumentation is required to be Operable during movement of "recently irradiated fuel" in accordance with TSTF-51. DOC L.1 will be revised to describe and justify this change.

Questions regarding this response should be directed to Dick Bense at (914) 734-5895 (RBENS90@Entergy.Com) or Bill Blair at (914) 737-4167 (WBlair@Entergy.Com).

NL-03-052 Attachment 1 Page 70 of 89 3.3.6: Containment Purge System and Pressure Relief Line Isolation Instrumentation NRC RAI Number TAC Number:

3.3.6 - 2 MB4739 NRC Request for Additional Information (RAI):

Item 2 CTS: 3.1.F.1.a(6)(a)

ITS: Table 3.3.6-1, Function 2.a, Gaseous monitors DOC: A.4.b FSAR Figure 7.2-12 shows that containment ventilation is isolated by radiation monitors R-41, R-42 and R44. FSAR Table 7.2-1, item 17, "Containment or plant ventilation activity" states that a one out of three (1/3) coincidence on High-High activity signal from the containment particulate or the plant ventilation radiogas detector directly actuate the containment purge supply and exhaust valves and the containment pressure relief valves. FSAR Sections 11.2.3.2.2 and 11.2.3.2.3 discuss the containment air monitor and plant vent air monitors, respectfully. FSAR 11.2.3.2.2 states that R-41 and R-42 isolate the containment purge vent and exhaust and pressure relief vales. FSAR 11.2.3.2.3 states that R-44 initiates a containment ventilation isolation as described in FSAR 11.2.3.2.2. The containment isolation on the gaseous R-44 monitor is not in the CTS and not in the ITS. Revise Table 3.3.6-1 to include R-

44. In addition, DOC A.4.b Justification for Change should be revised to provide applicable justification for the DOC Summary.

Entergy (1P2) Response:

IP2 ITS 3.3.6 Bases does state that "Although not required to satisfy Technical Specification requirements, containment purge and containment pressure relief are also isolated when high gas radiation levels are detected in the plant vent (R-44)."

Plant vent monitor R-44 was not included in CTS and will not be included in ITS because the IP2 accident analysis assumes that containment ventilation is isolated by an ESFAS Safety Injection signal (via the Containment Isolation - Phase A signal). Containment ventilation isolation on an ESFAS containment spray signal and on a high radiation signal from R41 and R42 was included in the CTS and will be included in ITS 3.3.6 to satisfy the requirements of Items (1) and (7) of Section II.E.4.2.7, Containment Isolation Dependability, of NUREG-0737, "Clarification of TMI Action Plan Requirements,"

which require that:

II.E.4.2.7(1) requires that containment isolation system designs shall comply with the recommendations of Standard Review Plan Section 6.2.4 (i.e., that there be diversity in the parameters sensed for the initiation of containment isolation). (SRP 6.2.4, Section 6.m, further clarifies II.E.4.2.7(1) in that "A high radiation signal should not be considered one of the diverse containment isolation parameters.")

This is satisfied by ITS 3.3.6, Function 4, ESFAS containment spray signal, which is diverse from ITS 3.3.6, Function 3, ESFAS Containment Isolation - Phase A.

II.E.4.2.7(7) requires that containment purge and vent isolation valves must close on a high radiation signal. This is satisfied by ITS 3.3.6, Functions 2.a (R-42) and 2.b (R-41).

Ouestions regarding this response should be directed to Dick Bense at (914) 734-5895 (RBENS90@Entergy.Com) or Bill Blair at (914) 737-4167 (WBlair@Entergy.Com).

NL-03-052 Attachment 1 Page 71 of 89 UFSAR 11.2.3.2.2, Containment Air Monitors, states that Monitors R41 and R42 have been "analyzed and credited for IP2 compliance with NUREG-0737, Item II.E.4.2.7."

Entergy (IP2) Action:

None Questions regarding this response should be directed to Dick Bense at (914) 734-5895 (RBENS90@Entergy.Com) or Bill Blair at (914) 737-4167 (WBIair@Entergy.Com).

NL-03-052 Attachment 1 Page 72 of 89 3.3.6: Containment Purge System and Pressure Relief Line Isolation Instrumentation NRC RAI Number TAC Number:

3.3.6 - 3 MB4739 NRC Request for Additional Information (RAI):

Item 3 CTS: 3.5.2 ITS: LCO 3.3.6 Applicability DOC: A.4.a The CTS markup shows CTS 3.5.1 as the basis for requiring Modes 1,2,3 and 4 applicability for ITS LCO 3.3.6 Function 4.a. However, it appears that CTS 3.5.2 and CTS 3.1.F.1.a govern the applicability for Table 3.5-4, Function 4.a. Revise the discussion in DOC A.4.a to reflect CTS applicability requirements for containment purge/pressure relief isolation.

Entergv (IP2) Response:

IP2 will revise the markup of CTS Page 3.5-1 and DOC A.4.a to delete references to CTS 3.5.1 and the bases for applicability requirements for ITS LCO 3.3.6, Containment Purge System and Pressure Relief Line Isolation Instrumentation.

EntergY (IP2) Action:

IP2 will revise the markup of CTS Page 3.5-1 and DOC A.4.a to delete references to CTS 3.5.1 and the bases for applicability requirements for ITS LCO 3.3.6, Containment Purge System and Pressure Relief Line Isolation Instrumentation.

Questions regarding this response should be directed to Dick Bense at (914) 734-5895 (RBENS90@Entergy.Com) or Bill Blair at (914) 737-4167 (WBIalr@PEntergy.Com).

NL-03-052 Attachment 1 Page 73 of 89 3.3.6: Containment Purge System and Pressure Relief Line Isolation Instrumentation NRC RAI Number TAC Number:

3.3.6 - 4 MB4739 NRC Request for Additional Information (RAI):

Item 4 CTS: 3.5.2 ITS: LCO 3.3.6 Applicability DOC: A.4.a Description of Change discussion regarding CTS 3.8.A.1 and CTS 3.8.B.11 (sic) should be moved to DOC L.1 Entergy (IP2) Response:

As discussed in the response to RAI 3.3.6-1, IP2 will revise ITS 3.3.6 to require that Containment Purge System and Pressure Relief Line Isolation Instrumentation be Operable during movement of "recently irradiated fuel" in accordance with TSTF-51.

In order to incorporate TSTF-51, IP2 will need to revise the CTS markup and DOCS associated with Applicability and requirements during movement of irradiated fuel. These revisions will include DOC A.04.e, DOC L.1 and markups of CTS 3.8.A.1 and CTS 3.8.B.8.

Entergy (IP2) Action:

IP2 will need to revise the CTS markup and DOCs associated with Applicability and requirements during movement of irradiated fuel in order to incorporate TSTF-51. These revisions will include DOC A.04.e, DOC L.1 and markups of CTS 3.8.A.1 and CTS 3.8.B.8.

Questions regarding this response should be directed to Dick Bense at (914) 734-5895 (RBENS90@Entergy.Com) or Bill Blair at (914) 737-4167 (WBlair@Entergy.Com).

NL-03-052 Attachment 1 Page 74 of 89 3.3.6: Containment Purge System and Pressure Relief Line Isolation Instrumentation NRC RAI Number TAC Number:

3.3.6 - 5 MB4739 NRC Reauest for Additional Information (RAI):

Item 7 CTS: Table 3.5-4 ITS: 3.3.6, Functions 2.a and 2.B (R-42/R-41)

DOC: A.4.f The description of change states that "isolation on a high radiation signal is a backup that is not directly credited in the accident analysis" and the DOC concludes that placing the allowable values for the Table 3.3.6-1 Functions in the IP2 Offsite Dose Calculation Manual is not change to the existing requirement and is administrative. The STS require allowable values in TS to ensure channel operability limits are met during the channel calibration. Placing the TS operability limit for a containment ventilation isolation signal in a licensee-controlled document is not consistent with the provisions of 50.36. TS operability limits such as Allowable Values that are cycle-specific may, however, be relocated to licensee-controlled documents when there is prior review and approval of changes to those limits. Revise Table 3.3.6-1 to include TS Allowable Values.

Entergy (IP2) ResDonse:

IP2 will revise ITS LCO 3.3.6 to include the Limiting Safety System Setting for Radiation Monitors R-41 and R-42 in ITS Table 3.3.6-1.

Entergy (IP2) Action:

IP2 will revise ITS LCO 3.3.6 to include the Limiting Safety System Setting for Radiation Monitors R-41 and R-42 in ITS Table 3.3.6-1.

Questions regarding this response should be directed to Dick Bense at (914) 734-5895 (RBENS90@Entergy.Com) or Bill Blair at (914) 737-4167 (WBlair@Entergy.Com).

NL-03-052 Attachment 1 Page 75 of 89 3.3.6: Containment Purge System and Pressure Relief Line Isolation Instrumentation NRC RAI Number TAC Number:

3.3.6 - 6 MB4739 NRC Request for Additional Information (RAI):

Item 8 CTS: LCO 3.3.2, Function 3.a, Phase A ESFAS signal ITS: LCO 3.3.6, Function 3, Purge and Pressure Relief Isolation on Phase A DOC: A.5, DB.1 DOC A.5 description of change states that the addition of the ESFAS actuation signal to LCO 3.3.6 is an administrative change with no impact on safety because this is an explicit statement of an existing requirement. Since the ITS surveillance requirements for ESFAS include Master Relay testing (SR 3.3.2.3) and Slave Relay Testing (SR 3.3.2.5) and addition of these requirements is also considered an administrative change to CTS, then it follows that current TS also require testing the master and slave relays for radiation monitoring functions in Table 3.3.6-1. Justify why the STS master and slave relay tests, ITS SR 3.3.6.3 and SR 3.3.6.5, respectfully, are not included in LCO 3.3.6.

Entergy (IP2) Response:

STS (NUREG-1431) SR 3.3.6.3, Perform Master Relay Test every 31 days on a staggered test basis, and STS (NUREG-1431) SR 3.3.6.5, Perform Slave Relay Test every 31 days, are not included in LCO 3.3.6 because of the following:

IP2 Procedure PT-M82, Process Radiation Monitor R-41/R-42 Functional Test, is performed monthly and satisfies CTS Table 4.1-1, Item 19, requirements for the Containment Purge System and Pressure Relief Line Isolation, for an operational test every month (i.e., 31 days). This test is maintained in the ITS as SR 3.3.6.3 which requires a Channel Operational Test of R-41 and R-42 every 31 days. This test verifies performance of containment ventilation isolation master relays Vi and V2 as initiated from R-41 and R-42. This tests the master relays every 31 days as opposed to every 31 days on a staggered test basis if the STS (NUREG-1431) SR 3.3.6.3 ere adopted. Because the R-41 and R-42 COT will test the master relays anyway, there is no benefit to adding a specific line item for master relay testing.

IP2 Procedures PT-2M 4 (and 5), Safety Injection System Train A (and B) Logic, is performed monthly on a staggered test basis, and includes an action logic test that includes the containment ventilation system isolation initiated by a Containment Phase A isolation, Containment Spray and R-41 and R-42 (i.e., it verifies Operability of the master relays VI and V2). This test is maintained in the ITS as SR 3.3.6.2 which requires an Actuation Logic Test every 31 days on a staggered test basis. This tests the master relays every 31 days on a staggered test basis exactly as required by STS (NUREG-1431) SR 3.3.6.3. Again, there is no benefit to a specific line item for testing the master relays.

IP2 Procedure PT-R141, Manual Phase A Testing, verifies that each logic train will close the associated containment isolation valves on a manual phase A isolation signal every 24 months. This test will verify that each train of slave relays will actuate the associated containment ventilation aIV. This test is performed every 24 months. IP2 uses the manual phase A isolation signal because Containment Ventilation Isolation (i.e., valves governed by ITS 3.3.6) do not have a dedicated manual channel. This Questions regarding this response should be directed to Dick Bense at (914) 734-5895 (RBENS90@Entergy.Com) or Bill Blair at (914) 737-4167 (WBlair@Entergy.Com).

NL-03-052 Attachment 1 Page 76 of 89 is why IP2 ITS SR 3.3.6.4, Perform TADOT, is maintained in ITS 3.3.6 as a requirement for Actuation Logic and Relay testing instead of a requirement for the manual initiation function.

IP2 will correct the misstatement in ITS 3.3.6, DOC A.03.e relating the TADOT to the calibration requirement. ITS SR 3.3.6.5 maintain the requirement for calibration of R-41 and R-42.

Entergy (IP2) Action:

IP2 will correct the misstatement in ITS 3.3.6, DOC A.03.e relating the TADOT to the calibration requirement. ITS SR 3.3.6.5 will maintain the requirement for calibration of R-41 and R-42.

Questions regarding this response should be directed to Dick Bense at (914) 734-5895 (RBENS90@Entergy.Com) or Bill Blair at (914) 737-4167 (WBlair@Entergy.Com).

NL-03-052 Attachment 1 Page 77 of 89 3.3.6: Containment Purge System and Pressure Relief Line Isolation Instrumentation NRC RAI Number TAC Number:

3.3.6 - 7 MB4739 NRC Reauest for Additional Information (RAI):

Item 9 CTS: Table 4.1-1, Item 19 ITS: SR 3.3.6.2 DOC: L.2, A.3.e Current TS require a monthly test of the Process Radiation Monitoring System. The CTS monthly test is translated as requiring a 31 day COT. DOC A.3.e infers that the CTS monthly test includes a requirement to perform a monthly actuation logic test and that this test is maintained in ITS as SR 3.3.6.2, however the test frequency is extended to 31 days on a staggered test basis as justified by DOC L.2. Provide documentation that current plant procedures require a monthly actuation logic test of both trains of logic that actuate containment purge and pressure relief isolation instrumentation. Revise DOC L.2 to support the conclusion that adopting a 31 day staggered test basis actuation logic test interval is based on instrument reliability documentation for IP2 instrumentation.

Entergy (IP2) Response:

IP2 Procedure PT-M82, Process Radiation Monitor R-41/R-42 Functional Test, is performed monthly and satisfies CTS Table 4.1-1, Item 19, requirements for the Containment Purge System and Pressure Relief Line Isolation, for an operational test every month (i.e., 31 days). This test is maintained in the ITS as SR 3.3.6.3 which requires a Channel Operational Test of R-41 and R-42 every 31 days.

IP2 Procedures PT-2M 4 (and 5), Safety Injection System Train A (and B) Logic, is performed monthly on a staggered test basis, includes an actuation logic test that includes the containment ventilation system isolation initiated by a Containment Phase A isolation, Containment Spray and R-41 and R-42.

This test is maintained in the ITS as SR 3.3.6.2 which requires an Actuation Logic Test every 31 days on a staggered test basis.

IP2 will revise ITS 3.3.6, DOC A.03.e and the associated CTS and NUREG markups to show that ITS SR 3.3.6.2 maintains the requirement in CTS Table 4.1-1, Item 26, Engineered Safety Features (SI) Logic Channel testing, which requires an actuation logic test every 31 days on a staggered test basis. DOC L.2 will be deleted.

Entergy (IP2) Action:

IP2 will revise ITS 3.3.6, DOC A.03.e and the associated CTS and NUREG markups to show that ITS SR 3.3.6.2 maintains the requirement in CTS Table 4.1-1, Item 26, Engineered Safety Features (SI) Logic Channel testing, which requires an actuation logic test every 31 days on a staggered test basis. DOC L.2 will be deleted.

Ouestions regarding this response should be directed to Dick Bense at (914) 734-5895 (RBENS90@Entergy.Com) or Bill Blair at (914) 737-4167 (WBIalr@Entergy.Com).

NL-03-052 Attachment 1 Page 78 of 89 3.3.7: Control Room Ventilation System (CRVS) Actuation Instrumentation NRC RAI Number TAC Number:

3.3.7 - 1 MB4739 NRC Request for Additional Information (RAI):

Item 1 CTS: CTS 3.8.A.1 and CTS 3.8.B.11 ITS: ITS 3.3.7 Applicability, Table 3.3.7-1 footnote (a),

STS: Condition D JFD: X.1 This RAI is based on RAI 3.6-1. RAI 3.6-1 noted inconsistencies with approved TSTF-51 for operability requirements "during movement of recently irradiated fuel." The Entergy (IP2) response to RAI 3.6-1 dated 10/6/2002 committed to incorporate NUREG-1431 requirements that are applicable only during movement of "recently irradiated fuel." The response concluded IP2 ITS 3.3.7, CRVS Actuation Instrumentation will be revised. Provide revised ITS 3.3.7 Applicability, Actions and Table 3.3.7-1 in response to RAI 3.6-1.

Entergy (IP2) Response:

IP2 will revise ITS 3.3.7 to require that Control Room Ventilation System (CRVS) Actuation Instrumentation is Operable during movement of "recently irradiated fuel" in accordance with TSTF-51.

Revision 0 of the IP2 ITS 3.3.7 did not incorporate requirements that are applicable only during movement of "recently" irradiated fuel because the IP2 definition of 'recently' irradiated fuel is any fuel that has been part of a critical reactor in the previous 100 hours0.00116 days 0.0278 hours 1.653439e-4 weeks 3.805e-5 months and CTS 3.8.B.4 prohibits movement of fuel from the vessel until 100 hours0.00116 days 0.0278 hours 1.653439e-4 weeks 3.805e-5 months after reactor shutdown. Therefore, unless CTS 3.8.B.4 (which is being relocated to Technical Requirements Manual 3.9.A by Relocated Item R.24) is changed to allow movement of fuel from the reactor vessel in less than 100 hour0.00116 days 0.0278 hours 1.653439e-4 weeks 3.805e-5 months after reactor shutdown, IP2 ITS 3.3.7 will never be Applicable during movement of any irradiated fuel.

Enteray (IP2) Action:

IP2 will revise ITS 3.3.7 to require that Control Room Ventilation System (CRVS) Actuation Instrumentation is required to be Operable during movement of "recently irradiated fuel" in accordance with TSTF-51. DOC L.1 will be revised to describe and justify this change.

Questions regarding this response should be directed to Dick Bense at (914) 734-5895 (RBENS90@Entergy.Com) or Bill Blair at (914) 737-4167 (WBlair@Entergy.Com).

NL-03-052 Attachment 1 Page 79 of 89 3.3.7: Control Room Ventilation System (CRVS) Actuation Instrumentation NRC RAI Number TAC Number:

3.3.7 - 2 MB4739 NRC Request for Additional Information (RAI):

Item 2 CTS: Table 4.1-1, Item 19a ITS: Table 3.3.7-1, Function 1 DOC: R.21 DOC R.21 proposes relocating CTS Table 4.1-1, Minimum Frequencies for Checks, Calibrations and Tests of Instrument Channels, Item No. 19a, Area Radiation Monitoring System to a licensee-controlled document because the CTS do not meet requirements for retention in improved TS. ITS Section 3.3.7 for CRVS Actuation Instrumentation uses the same Table 4.1-1 entry, Item No. 19a, to show that this CTS requirement is translated into ITS Table 3.3.7-1, Function 1, Control Room Air Intake Radiation (R-38-2). Reconcile the LAR request to both relocate and retain the same CTS requirement.

Enterav (1P2) Response: I CTS 3.3.H.1 requires that the control room ventilation system, including an implied requirement for actuation instrumentation, be operable. CTS 4.4.E.4.b, which is a surveillance that verifies that CTS 3.3.H.1 is met, requires periodic verification that the control room ventilation system actuates on a safety injection signal or a high radiation signal. However, there is no explicit requirement for a channel check, channel operational test or channel calibration of the 'high radiation signal' signal that actuates the control room ventilation system except for the generic requirement in CTS Table 4.1-1, Minimum Frequencies for Checks, Calibrations and Tests of Instrument Channels, Item 19.a, that applies to all instruments in the "Area Radiation Monitoring System." Therefore, CTS Table 4.1-1, Item 19.a, is interpreted to apply to both the control room ventilation system and numerous other radiation monitoring instruments that are being relocated.

This approach is confirmed by Procedure PT-M58, CCR Ventilation Area Radiation Monitors and Control, which verifies, every 31 days, that R-38-1 and R-38-2 will actuate all of the dampers and primary fans of the CCR ventilation system to the "Outside Air Filtered Pressurization Mode (Mode 2)." Note that the Frequency (monthly) is based on TS Table 4.1-1, Item 19.a, and not the 24 months specified in CTS 4.4.E.4.b. That is why IP2 Specified the Frequency for the Rad Monitor COT at 31 days.

Enteray (IP2) Action:

None Questions regarding this response should be directed to Dick Bense at (914) 734-5895 (RBENS90@Entergy.Com) or Bill Blair at (914) 737-4167 (WBlair@Entergy.Com).

NL-03-052 Attachment 1 Page 80 of 89 3.3.7: Control Room Ventilation System (CRVS) Actuation Instrumentation NRC RAI Number TAC Number:

3.3.7 - 3 MB4739 NRC Request for Additional Information (RAI):

Item 3 CTS: n/a ITS: Bases Background DOC: n/a The CRVS Actuation System is described in the Bases for LCO 3.7.10, "Control Room Ventilation System." LCO 3.7.10 Bases state that the original CRVS design was not required to meet single failure criteria but has been upgraded so that the pressurization mode (mode 2) meet the design basis single active failure criterion. To meet this criterion the CRVS is divided into two trains. SI is a proposed CRVS Actuation System function in table 3.3.7-1. This function is also divided into two trains. Provide discussion for not including Actuation logic and Actuation Relays and manual initiation TS requirement in Table 3.3.7-1 to support actuation of the trains of CRVS using SI or radiation monitor signals.

Additionally, the SI actuation signals are redundant and therefore protected from a single active failure.

Is there a radiation monitor which is redundant to R-38-2? The staff notes that the Bases for CRVS references control room monitor (RE-38-2) as required by LCO 3.3.7. Is RE-38-2 a redundant monitor to R-38-2?

Entergy (IP2) Response:

Issue 1:

Provide discussion for not including manual initiation TS requirement in Table 3.3.7-1 to support actuation of the trains of CRVS.

IP2 will revise ITS 3.3.7, Table 3.3.7-1, to include a requirement for "1 train" of manual initiation of control room ventilation to "Outside Air Filtered Pressurization Mode (Mode 2)." The requirement is for "1 train" because, as described below, control room ventilation actuation circuits are not redundant.

Testing requirements will be every 24 months which is consistent with CTS 4.5.E.4.b which currently requires verification of system actuation from an SI signal or radiation monitor every 24 months.

Issue 2:

Provide discussion for not including Actuation logic and Actuation Relays in Table 3.3.7-1 to support actuation of the trains of CRVS using SI or radiation monitor signals.

Response

Actuation logic and Actuation Relays were not included in Table 3.3.7-1 to support actuation of the trains of CRVS using SI or radiation monitor signals because control room ventilation actuation circuits are not redundant.

Note (1) to drawing A225105-10, Safeguards Actuation Signals (Sheet 12), explains that control room ventilation isolation "circuitry is not part of the safeguards system and is not redundant." Both train A Questions regarding this response should be directed to Dick Bense at (914) 734-5895 (RBENS90@Entergy.Com) or Bill Blair at (914) 737-4167 (WBlalr@Entergy.Com).

NL-03-052 Attachment 1 Page 81 of 89 and train B of ESFAS SI provide a signal that will actuate control room ventilation, however, the control room ventilation isolation portion of the circuitry is not redundant. Drawing A225105-10 is duplicated as UFSAR Figure 7.2-12, which shows a box around control room ventilation isolation with the notation "Not Redundant" but does not include the note.

Procedure PT-M58, CCR Ventilation Area Radiation Monitors and Control, verifies, every 31 days, that R-38-1 and R-38-2 will actuate required dampers and primary fans of the CCR ventilation system to the "Outside Air Filtered Pressurization Mode (Mode 2)."

Procedure PT-R13, Safety Injection System (Step 7.24), verifies, every 24 months, that a safety injection signal will actuate required dampers and primary fans of the CCR ventilation system to the "Outside Air Filtered Pressurization Mode (Mode 2)."

As explained in the Background Section of the Bases for ITS 3.7.10, an SI signal or radiation signal will start Filter booster fan (CCRBF-21) and Air conditioning unit fan (CCRF-21). If the filter booster fan (CCRBF-21) fails to start or trips, a flow switch will detect the failure and start the redundant filter booster fan (CCRBF-22) after a predetermined time delay. If the air conditioning unit fan (CCRF-21) fails to start or trips, a flow switch will detect the failure and a redundant fan (CCRCF-22) will start.

The actuation of the backup fans is tested as part of ITS 3.7.10, Verify each train actuates on an actual or simulated signal.

Procedure PT-M58 and Procedure PT-R13 provide complete verification that all of the dampers and primary fans of the CCR ventilation system to the "Outside Air Filtered Pressurization Mode (Mode 2)."

Considering that CCR actuation circuitry is not redundant and that the different trains of CCR ventilation fans are started only after a failure of the primary fan and not by actuation logic, addition of a separate line item for Actuation logic and Actuation Relays adds confusion and adds no value.

IP2 will revise IP2 ITS 3.7.10 Bases statement referenced above to replace the phrase "meet the design basis single active failure criterion" to more closely match the description in UFSAR 7.2.4.2 that 'The central control room ventilation system is designed to accommodate certain active or passive failures."

This is consistent with the ITS 3.7.10 Bases which provides a detailed description of the redundant mechanical components that provide this redundancy.

Issue 3:

Is there a radiation monitor which is redundant to R-38-2?

As explained in UFSAR 11.2.3.4.7, either radiation monitor R-38-1 or R-38-2 will provide a signal that places control room ventilation in the "Incident - Outside Air Filtered Pressurization Mode (Mode 2)."

However, only R-38-2 monitors air that is introduced into the control room. Monitor R-38-1 "is located on the intake air stream for the Unit 1 area of the Control Building excluding the Control Room."

IP2 will revise ITS 3.3.7 to include a requirement for the Operability of R-38-1 as separate function to allow separate Condition entry for R-38-1 and R-38-2. This is acceptable because the monitors are not redundant and ITS 3.7.10 and ITS 3.3.7 both already allow a loss of function based on current licensing basis. Additionally, CCR ventilation can be placed in "Outside Air Filtered Pressurization Mode (Mode 2)"

manually either using the control switch or tripping one of the radiation monitors.

Guestions regarding this response should be directed to Dick Bense at (914) 734-5895 (RBENS90@Entergy.Com) or Bill Blair at (914) 737-4167 (WBlair@Entergy.Com).

NL-03-052 Attachment 1 Page 82 of 89 Entergy (IP2) Action:

IP2 will revise ITS 3.3.7 to include a requirement for the Operability of R-38-1 as separate function to allow separate Condition entry for R-38-1 and R-38-2.

IP2 will revise ITS 3.3.7, Table 3.3.7-1, to include a requirement for "1 train" of manual initiation of control room ventilation to "Outside Air Filtered Pressurization Mode (Mode 2)." Testing requirements will be a COT every 24 months which is consistent with CTS 4.5.E.4.b which currently requires verification of system actuation from an SI signal or radiation monitor every 24 months.

Ouestions regarding this response should be directed to Dick Bense at (914) 734-5895 (RBENS90@Entergy.Com) or Bill Blair at (914) 737-4167 (WBlair@Entergy.Com).

NL-03-052 Attachment 1 Page 83 of 89 3.3.7: Control Room Ventilation System (CRVS) Actuation Instrumentation NRC RAI Number TAC Number:

3.3.7 - 4 MB4739 NRC Request for Additional Information (RAI):

Item 4 CTS: n/a ITS: n/a DOC: n/a The Bases state that a safety injection signal or a high radiation signal from the control room area monitor (RE-38-2) as required by LCO 3.3.7 will automatically place the CRVS in the pressurization mode (mode 2) . In the pressurization mode, either of the two filter booster fans (CCRBF-21 or CCRBF-

22) will maintain the control room at a slight positive pressure relative to adjacent areas. Identify any CRVS actuation instrumentation failures that could render one CRVS train inoperable.

Entergv (1P2) Response:

As explained in the response to RAI 3.3.7-3, control room ventilation isolation circuitry is not part of the safeguards system and is not redundant. Both R-38-1 and R-38-2 and both train A and train B of ESFAS SI will provide a signal that will actuate control room ventilation, however, the control room ventilation isolation portion of the circuitry is not redundant.

As explained in the Background Section of the Bases for ITS 3.7.10, an SI signal or radiation signal will start Filter booster fan (CCRBF-21) and Air conditioning unit fan (CCRF-21). If the filter booster fan (CCRBF-21) fails to start or trips, a flow switch will detect the failure and start the redundant filter booster fan (CCRBF-22) after a predetermined time delay. If the air conditioning unit fan (CCRF-21) fails to start or trips, a flow switch will detect the failure and a redundant fan (CCRCF-22) will start.

The actuation of the backup fans is tested as part of ITS 3.7.10, Verify each train actuates on an actual or simulated signal.

Entergy (IP2) Action:

None Questions regarding this response should be directed to Dick Bense at (914) 734-5895 (RBENS90@Entergy.Com) or Bill Blair at (914) 737-4167 (WBlalr@Entergy.Com).

NL-03-052 Attachment 1 Page 84 of 89 3.3.7 : Control Room Ventilation System (CRVS) Actuation Instrumentation NRC RAI Number TAC Number:

3.3.7 - 5 MB4739 NRC Request for Additional Information (RAI):

Item 5 CTS: Table 4.1-1, Item 19 ITS: SR 3.3.6.2 (DOC L.2, A.3.e)

DOC: n/a Current TS require a monthly test of the Process Radiation Monitoring System (item 19). In LCO 3.3.6, the CTS monthly test is translated as requiring a 31 day COT. LCO 3.3.6 DOC A.3.e infers that the CTS monthly test includes a requirement to perform a monthly actuation logic test and that this test is maintained in ITS as SR 3.3.6.2, however the same test frequency exists for LCO 3.3.7 without including a monthly actuation logic test for the CRVS Actuation Instrumentation. Provide documentation that current plant procedures do not require a monthly actuation logic test for CRVS Actuation Instrumentation Entergy (IP2) Response:

Procedure PT-M58, CCR Ventilation Area Radiation Monitors and Control, verifies, every 31 days, that R-38-1 and R-38-2 will actuate required dampers and primary fans of the CCR ventilation system to the Outside Air Filtered Pressurization Mode (Mode 2). This requirement implements CTS Table 4.1-1, Minimum Frequencies for Checks, Calibrations and Tests of Instrument Channels, Item 19.a. This requirement is maintained in ITS as SR 3.3.7.2 which requires a COT every 31 days.

Procedure PT-R13, Safety Injection System (Step 7.24), verifies, every 24 months, that a safety injection signal will actuate required dampers and primary fans of the CCR ventilation system to the "Outside Air Filtered Pressurization Mode (Mode 2). This requirement is maintained in ITS 3.3.2, SR 3.3.2.5, Slave Relay Test, every 24 months. A slave relay from both train A and train B of the SI actuation logic and relays actuates control room ventilation. This is consistent with the presentation of requirements in ITS 3.3.7 which references ITS 3.3.2.

Entergy (IP2) Action:

None Questions regarding this response should be directed to Dick Bense at (914) 734-5895 (RBENS90@Entergy.Com) or Bill Blair at (914) 737-4167 (WBIair@Entergy.Com).

NL-03-052 Attachment 1 Page 85 of 89 3.3.7: Control Room Ventilation System (CRVS) Actuation Instrumentation NRC RAI Number TAC Number:

3.3.7 - 6 MB4739 NRC Request for Additional Information (RAI):

Item 6 CTS: LCO 3.3.2, Function 1, SI ESFAS signal ITS: n/a DOC: n/a In ITS LCO 3.3.6 DOC A.5 describes the addition of Purge and Pressure Relief Isolation on Phase A as an administrative change with no impact on safety because this is an explicit statement of an existing requirement. In ITS LCO 3.3.7 an SI actuation of CRVS function is added to Table 3.3.7-1. Provide a DOC for this change to CTS. Additionally, since the ITS surveillance requirements for ESFAS include Master Relay testing (SR 3.3.2.3) and Slave Relay Testing (SR 3.3.2.5) and addition of these testing requirements is also considered an administrative change to CTS, then it follows that current TS would also require testing the master and slave relays for radiation monitoring functions in Table 3.3.7-1.

Justify why the STS master and slave relay tests, STS SR 3.3.7.4 and SR 3.3.7.5, respectively, are not included in LCO 3.3.7.

Entergy (IP2) Res~onse:

Issue 1:

IP2 will revise ITS 3.3.7 to add DOC A.6 which will explain that ITS LCO 3.3.7, Function 3, CRVS -

Safety Injection (LCO 3.3.2, Function 1), is added to clarify the existing requirement that the control room ventilation system is required to isolate on an LCO 3.3.2, Function 1, Safety Injection, ESFAS signal. This is an administrative change with no impact on safety because this is an explicit statement of an existing requirement.

Issue 2:

This item is addressed in the response to issue 2 of RAI 3.3.7 - 3 as follows:

Provide discussion for not including Actuation logic and Actuation Relays in Table 3.3.7-1 to support actuation of the trains of CRVS using SI or radiation monitor signals.

Response

Actuation logic and Actuation Relays were not included in Table 3.3.7-1 to support actuation of the trains of CRVS using SI or radiation monitor signals because control room ventilation actuation circuits are not redundant.

Note (1) to drawing A225105-10, Safeguards Actuation Signals (Sheet 12), explains that control room ventilation isolation "circuitry is not part of the safeguards system and is not redundant." Both train A and train B of ESFAS SI provide a signal that will actuate control room ventilation, however, the control room ventilation isolation portion of the circuitry is not redundant. Drawing A225105-10 is duplicated as UFSAR Figure 7.2-12. UFSAR Figure 7.2-12 shows a box around control room ventilation isolation with the notation "Not Redundant" but does not include the note.

Questions regarding this response should be directed to Dick Bense at (914) 734-5895 (RBENS90@Entergy.Com) or Bill Blair at (914) 737-4167 (WBIair@Entergy.Com).

NL-03-052 Attachment 1 Page 86 of 89 Procedure PT-M58, CCR Ventilation Area Radiation Monitors and Control, verifies, every 31 days, that R-38-1 and R-38-2 will actuate required dampers and primary fans of the CCR ventilation system to the "Outside Air Filtered Pressurization Mode (Mode 2)."

Procedure PT-R13, Safety Injection System (Step 7.24), verifies, every 24 months, that a safety injection signal will actuate required dampers and primary fans of the CCR ventilation system to the "Outside Air Filtered Pressurization Mode (Mode 2)."

As explained in the Background Section of the Bases for ITS 3.7.10, an SI signal or radiation signal will start Filter booster fan (CCRBF-21) and Air conditioning unit fan (CCRF-21). If the filter booster fan (CCRBF-21) fails to start or trips, a flow switch will detect the failure and start the redundant filter booster fan (CCRBF-22) after a predetermined time delay. If the air conditioning unit fan (CCRF-21) fails to start or trips, a flow switch will detect the failure and a redundant fan (CCRCF-22) will start.

The actuation of the backup fans is tested as part of ITS 3.7.10, Verify each train actuates on an actual or simulated signal.

Procedure PT-M58 and Procedure PT-R13 provide complete verification that all of the dampers and primary fans of the CCR ventilation system to the "Outside Air Filtered Pressurization Mode (Mode 2)."

Considering that CCR actuation circuitry is not redundant and that the different trains of CCR ventilation fans are started only after a failure of the primary fan and not by actuation logic, addition of a separate line item for Actuation logic and Actuation Relays adds confusion and adds no value.

IP2 will revise IP2 ITS 3.7.10 Bases statement referenced above to replace the phrase "meet the design basis single active failure criterion" to more closely match the description in UFSAR 7.2.4.2 that 'The central control room ventilation system is designed to accommodate certain active or passive failures."

This is consistent with the ITS 3.7.10 Bases which provides a detailed description of the redundant mechanical components that provide this redundancy.

Entergv (IP2) Action:

IP2 will revise ITS 3.3.7 to add DOC A.6 which will explain that ITS LCO 3.3.7, Function 3, CRVS -

Safety Injection (LCO 3.3.2, Function 1), is added to clarify the existing requirement that the control room ventilation system is required to isolate on a signal generated by LCO 3.3.2, Function 1, Safety Injection.

IP2 will revise IP2 ITS 3.7.10 Bases statement referenced above to replace the phrase "meet the design basis single active failure criterion" to more closely match the description in UFSAR 7.2.4.2 that 'The central control room ventilation system is designed to accommodate certain active or passive failures."

Questions regarding this response should be directed to Dick Bense at (914) 734-5895 (RBENS90Entergy.Com) or Bill Blair at (914) 737-4167 (WBlair@Entergy.Com).

NL-03-052 Attachment 1 Page 87 of 89 3.3.7: Control Room Ventilation System (CRVS) Actuation Instrumentation NRC RAI Number TAC Number:

3.3.7 - 7 MB4739 NRC Reguest for Additional Information (RAI):

Item 7 CTS: 3.3.H.2 ITS: Action A DOC: L.2, M.1 JFD: DB.1 CTS 3.3.H.2 requires that the control room ventilation system be operable. There are no specified instrumentation TS requirements for CRVS, therefore, the interpretation of CTS is that 3.3.H.2 also applies to the supporting instrumentation for CRVS actuation. According to CTS 3.3.H.2 the plant must be shutdown when the requirements are not met and not restored within the stated 3.5 day completion time. DOC L.2 proposes to eliminate the requirement to shutdown if the CRVS is placed in the filtered pressurization mode.

CTS 3.3.H.1 requires that control air filtration (CRVS), including actuation instrumentation, is operable.

The licensee states there is no requirement for redundancy for either the CRVS or the actuation instrumentation because CTS 3.3.H.2 establishes requirements when the CRVS is not operable but does not distinguish between a loss of CRVS redundancy and a loss of CRVS functions. Therefore, CTS 3.3.H.2 specifies no Required Actions for a loss of CRVS redundancy and provides an allowable out of service time (AOT) of 3.5 days for a loss of CRVS function.

DOC M.1 proposes changes to the STS for CRVS. STS specify a 7 day AOT to place a train in operation for loss of CRVS actuation instrumentation or actuation train redundancy. STS specify an immediate action to place CRVS in operation and enter the CRVS LCO for one train inoperable or place both CRVS trains in operation for loss of CRVS actuation instrumentation of actuation train function.

ITS LCO 3.7.10 requires that two CRVS trains are operable to provide redundant CRVS capability; however, ITS LCO 3.3.7, maintains the licensee's interpretation for a single train of CRVS actuation instrumentation inoperable. Thus, ITS LCO 3.3.7, specifies a new AOT of 72 hours8.333333e-4 days 0.02 hours 1.190476e-4 weeks 2.7396e-5 months when one or both CRVS actuation instrumentation functions are inoperable. Provide an FSAR citation to justify the DOC M.1 statement that the requirement for a single train of CRVS actuation instrumentation is consistent with the IP2 design.

Entergy (IP2) Response:

Issue:

Provide an FSAR citation to justify the DOC M.1 statement that the requirement for a single train of CRVS actuation instrumentation is consistent with the IP2 design.

Note (1) to drawing A225105-10, Safeguards Actuation Signals (Sheet 12), explains that control room ventilation isolation "circuitry is not part of the safeguards system and is not redundant." Both train A and train B of ESFAS SI provide a signal that will actuate control room ventilation, however, the control Questions regarding this response should be directed to Dick Bense at (914) 734-5895 (RBENS90@Entergy.Com) or Bill Blair at (914) 737-4167 (WBlair@Entergy.Com).

NL-03-052 Attachment 1 Page 88 of 89 room ventilation isolation portion of the circuitry is not redundant. Drawing A225105-10 is duplicated as UFSAR Figure 7.2-12. UFSAR Figure 7.2-12 shows a box around control room ventilation isolation with the notation "Not Redundant" but does not include the note.

IP2 will revise IP2 ITS 3.7.10 Bases statement referenced above to replace the phrase "meet the design basis single active failure criterion" to more closely match the description in UFSAR 7.2.4.2 that 'The central control room ventilation system is designed to accommodate certain active or passive failures."

This is consistent with the ITS 3.7.10 Bases which provides a detailed description of the redundant mechanical components that provide this redundancy.

Enterciy (IP2) Action:

IP2 will revise IP2 ITS 3.7.10 Bases statement referenced above to replace the phrase "meet the design basis single active failure criterion" to more closely match the description in UFSAR 7.2.4.2 that "The central control room ventilation system is designed to accommodate certain active or passive failures."

Questions regarding this response should be directed to Dick Bense at (914) 734.5895 (RBENS90Entergy.Com) or Bill Blair at (914) 737-4167 (WBIair@Entergy.Com).

NL-03-052 Attachment 1 Page 89 of 89 3.3.7: Control Room Ventilation System (CRVS) Actuation Instrumentation NRC RAI Number TAC Number:

3.3.7 - 8 MB4739 NRC Request for Additional Information (RAI):

Item 8 CTS: n/a ITS: 3.3.7, Function 1 (R-38-2)

DOC: none Provide a discussion of change for placing the Control Room Air Intake Radiation Monitor Allowable Value in the IP2 Offsite Dose Calculation Manual. The STS require allowable values in TS to ensure channel operability limits are met during the channel calibration. Placing the TS operability limit for a containment ventilation isolation signal in a licensee-controlled document is not consistent with the provisions of 50.36. TS operability limits such as Allowable Values that are cycle-specific may, however, be relocated to licensee-controlled documents when there is prior review and approval of changes to those limits. Revise Table 3.3.7-1 to include TS Allowable Values.

Entergy (IP2) Response:

IP2 will revise ITS LCO 3.3.7 to include the Limiting Safety System Setting for Control Room Ventilation System (CRVS) Actuation Instrumentation in ITS Table 3.3.7-1.

Entergy (IP2) Action:

IP2 will revise ITS LCO 3.3.7 to include the Limiting Safety System Setting for Control Room Ventilation System (CRVS) Actuation Instrumentation in ITS Table 3.3.7-1 instead of having the allowable value in the ODCM.

Questions regarding this response should be directed to Dick Bense at (914) 734-5895 (RBENS90@Entergy.Com) or Bill Blair at (914) 737-4167 (WBlair@Entergy.Com).

NL-03-052, Response to Request for Additional Information Regarding Section 3.3, Instrumentation, of the Improved Technical Specification (ITS)

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NL-03-052, Response to Request for Additional Information Regarding Section 3.3, Instrumentation, of the Improved Technical Specification (ITS)

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