View source for JSP-063-93, Forwards Supplemental Info to 910920 Application for Amend to License NPF-62,changing TS to Incorporate Reliability Based Improvements to Instrumentation Action Statements & Surveillance Test Intervals,Per 921124 Meeting W/Nrc

{{Adams
| number = ML20128M685
| issue date = 02/17/1993
| title = Forwards Supplemental Info to 910920 Application for Amend to License NPF-62,changing TS to Incorporate Reliability Based Improvements to Instrumentation Action Statements & Surveillance Test Intervals,Per 921124 Meeting W/Nrc
| author name = Perry J
| author affiliation = ILLINOIS POWER CO.
| addressee name = 
| addressee affiliation = NRC OFFICE OF INFORMATION RESOURCES MANAGEMENT (IRM)
| docket = 05000461
| license number = 
| contact person = 
| document report number = JSP-063-93, JSP-63-93, U-602078, NUDOCS 9302220249
| package number = ML20128M691
| document type = CORRESPONDENCE-LETTERS, INCOMING CORRESPONDENCE
| page count = 14
| project = 
| stage = Supplement
}}

=Text=
{{#Wiki_filter:_ _ _ _ - _ _ _ _ _ _ _ - _ _ _
n-lihnom Power Company Chnton Power Station P_O Box 678 Chnton. IL 61727 Tel 217 93E6226 J. Stephen Perry Vce Presdent ELLIN915 PGMR                                    JS P- 0 6 3 -- 9 3                             1$7 (02-17)LP February 17, 1993 8E.100a 10CFR50.90 Docket No. 50 461 Document Control Desk Nuclear Regulatory Commission Washington, D.C. 20555

==Subject:==
Clinton Power Station Revision to Previously Submitted Proposed Amendment of Facility Operatint License No. NPP-62

==Dear Sir:==

By {{letter dated|date=September 20, 1991|text=letter dated September 20, 1991}} (reference U 601871), Illinois Power (IP) applied for amendment of Facility Operating License No. NPF-62, Appendix A - Technical Specifications, for Clinton Power Station (CPS). That request consisted of proposed changes to_the CPS Technical Specifications to incorporate reliability-based improvements to instrumentation Action Statements and surveillance test intervals based on Topical Reports which were previously submitted to the NRC by the Boiling Water Reactor Owners' croup (BVROG). However, as a recult of questions / comments received from the NRC during their review of IP's request, additional clarifications / revisions became necessary. Those additional clarifications / revisions were submitted to the NRC via IP letter U-602025 dated August 17, 1992.
During a meeting with the NRC Staff on November 24, 1992, IP received additional comments from the NRC regarding the September 20, 1991 amendment request. These comments involve additional justification for the proposed repair time limit for inoperable main steam line isolation instruments, resolution of a conflict with a previously submitted Technical Specification change to simplify control rod block instramentation surveillance triggers, and resolution of " loss-of-function" issues to be consistent with the Improved Standard Technical Specifications (NUREC-1434).       In order to resolve these comments, further clarifications / revisions to IP's September 20, 1991' amendment request are required.
Attachment 2 to this letter contains the requested additional
,          justification for the September 20, 1991 amendment request as well as a description and justification for the additional changes proposed by this supplement. Attachment 3 to this letter contains replacement pages for the affected marked-up pages for Technical Specification (TS) 3/4.3.3, " Emergency Core Cooling System Actuation Instrumentation," TS                                      7 190181 9302220249 930217 PDR P       ADOCK 05000461                                                                                     '   'l PDR

t
           .                                                                                  Page 2 of 2
 .                                                                                            to U-602078 1
i                                                                                                                  1 3/4.3.5, " Reactor Core Isolation Cooling System Actuation
',                     Instrumentation," and TS 3/4.3.6, " Control Rod Block Instrumentation,"
~
contained in IP's September 20, 1991 request (i.e., pages 15, 16, 27, 30, 31, and 32 of Attachment 3 to U-601871).       The additional changes being proposed by this supplement are identified by double change bars.
Further, an affidavit supporting the facts set forth in this letter and
.                      its attachments is provided in Attachment'1.
IP has reviewed the Basis for No Significant Hazards Consideration contained in IP's September 20, 1991 amendment request and has concluded that the additional changes contained in this supplement do not alter the bases or conclusions provided in those assessments. Additionally, the changes contained in this supplement do not alter IP's determination that the proposed changes meet the criteria given in 10CFR51.22(c)(9) for a categorical exclusion from the requirement for an Environmental Impact Statement.
4 I
Sincerely yours, J    S. Per Senior Vice President l                      DAS/mfm Attachments 4
cc:     NRC Clinton Licensing Project Manager NRC Resident Office, V-690 i
Regional Administrator, Region III, USNRC Illinois Department of Nuclear Safety k
4 i
e h
t
     - - -     ----e .         -m,   eevw: - - - -      .,
m  --    -----p~.       .,-      w ~ r ,-t+

   .. . -              .  . . . . . . . . . .                   ..__. . ~ . . . . - _- -     . .      . .-                       .          . -              . - ..                        - -
8' i                                                                                                                                                                          Attochment 1-                                     ,
to U 602078 f.
t i                                                                                                                                                                                                                            ,
i                                                                                                                                                                                                                         _ .
j
:.                               STATE OF ILLINOIS j                                COUNTY OF DEWITT 1
4                                                                                                                                                                                                                           T J. Stephen Perry, being first duly sworn, deposes and says: That he is-Senior Vice President of Illinois PowerLCompany; that the application l                             - for. amendment of Facility Operating License NPF 62'has been prepared-under his supervision and direction; that he knows the: contents thereof;
;                                and that to the best of his. knowledge and' belief said' application and the facts contained therein are true and correct.
i t
DATE:    This- ( ~)                     day of February,-1993, 4
t 0
Signed:                                                                                       _
StphenPerry
;                                 Subscribed and sworn to before me this /7/[ day;of' February,1993; J'
                                                                                                      /
Notary Public-i-
                                                                                                            =1
[                   WFICIAL SEE -
Linda S. French -
                                                                                                                                                                                     . ll.
h
: l. ' Notary Public, State of IWnsk                                     ;l
                                                                                                            ; ll My Commission Ex
                                                                                                            - Ll _ : _ _ _-_ _ _ _pires
_ _ _ ; _j 9/1/98 - j a
L r-*'+                            --e w a                                                                     e                                                                  w~N= r as e- r- e- -v,-
e    v        w   n,mzw          s t v~         e'rP       -                  - %     e -r t s
* o r r#<nete   -v          m ie e w r v y - w-       c %mer v tan -Y v-         e m---

     . t-
 ;                                                                                                  Attachment 2                             )
                                                                                                    ~to U 602078                             !
i-                                                                                                Page 1 of 11
 ,                    Backcround 4                    By {{letter dated|date=September 20, 1991|text=letter dated September 20, 1991}} (reference U-601871), Illinois Power (IP) requested amendment of the Technical Specifications (TS) for Clinton Power i                     Station (CPS). Specifically, the {{letter dated|date=September 20, 1991|text=September 20, 1991 letter}} was written to request changes to the allowable outage time (A0T)-limits for repairs and surveillances and changes to the frequency for performing Channel Functional 4
Tests (CFTs) and analog trip module (ATM) calibration checks;for various instruments contained in the CPS TS. .The affected TS include TS 3/4.3.1, 4
                      " Reactor Protection System Instrumentation"; TS 3/4.3.2, " Containment and Reactor Vessel Isolation Control System"; TS 3/4.3.3, " Emergency Core Cooling
}                     System Actuation Instrumentation"; TS 3/4.3.4.1, "ATWS Recirculation Pump Trip i                     System Instrumentation"; TS 3/4.3.4.2, "End-of-Cycle Recirculation Pump Trip
!                     System Instrumentation"; TS 3/4.3.5, " Reactor Core Isolation Cooling System Actuation Instrumentation"; TS 3/4.3.6, " Control Rod Block Instrumentation";
TS 3/4.3.9, " Plant Systems Actuation Instrumentation"; TS 3/4.4.2.1, .
;                     " Safety / Relief Valves"; and TS 3/4.4.2.2, " Safety / Relief Valves .lew Low Set i
Function". In general, the repair AOTs for these instruments will be
;                     increased from one hour to six hours for the Reactor Protection System and to 2                  - 24 hours for other instrumentation; the surveillance A0Ts will be increased from two hours to six hours; and the CFT and ATM calibration check surveillance frequencies will be increased 'from monthly to quarterly.                     These 7                    proposed changes are supported by Topical Reports prepared by the-Boiling l                     Water Reactor Owner's Group (BVROG) which have been approved by the NRC for -
individual plant use.
]
3 As a result of comments received during the NRC's review of IP's September 20, i                     1991 amendment request, IP provided a supplement to that request (reference IP
,                     letter U-602025 dated August 17, 1992), That supplement proposed additional changes to TS 3/4.3.7.1, " Radiation Monitoring Instrumentation," and TS'
;                     3/4.3.9, " Plant Systems Actuation Instrumentation," Further, the August-17, 1992 supplement provided additional justification / clarification for the
,                     changes to TS 3/4.3.5, " Reactor Core-Isolation-Cooling System Actuation i
Instrumentation," and TS 3/4.3.6, " Control Rod Block Instrumentation,"-
contained in the September 20, 1991 request.
During a meeting with the NRC on November 24, 1992, IP received additional comments-from the NRC which necessitate the submittal of this additional'
,                     supplement. The NRC comments relate to three general areas: (1) to provide
:                     additional justification for the proposed repair A07- change from one hour to six hours applicable when two of the four Containment and Reactor Vessel
;-                    Isolation Control System (CRVICS) Main Steam Line Isolation Trip Function channels are inoperable (TS 3/4.3.2, Action b.2); . (2) to resolve the conflict between TS Table 4.3.6-1, " Control Rod Block Instrumentation Surveillance Requirements," footnote (d) and the proposed change to the channel Functional-Test frequency.for the associated Trip Function; and (3)'to provide revisions to the proposed repair AOT limits to address " loss-of-function"11ssues as recently resolved during NRC review of the Improved Standard Technical Specifications (NUREG-1434). Each of these areas is discussed separately as
:                     follows.
4 y    , . , , , , - , . . -        , , +- -w  +     ~
c       gnu - - - , ,   ,.,v, ,,w   e     w  v en,-   re e-w e - n r - m n

        -      .. _              .         . . . -- .     ~ --. .                              .       . .       --     . .-. -
4                                                                                                           Attachment 2 to U 602078 Page 2 of 11 l                CRVICS Main Steam Line Isolation Repair A0T TS 3/4.3.2 provides operability and surveillance requirements for CRVICS instrumentation, includir,              ose instruments which initiate isolation of.the main steam lines and mai                am drain lines.                    The instrumentation logic for isolatiot,of the main st -. tines and drains is arranged in a two out-of-four
,                 configuration. The Action Statements for the main steam line isolation
{                 instruments are currently consistent with those for the Reactor Protection System (RPS) contained in TS 3/4.3.1 since the RPS logic is also arranged in a j                 two out-of-four configuration.            IP's September 20, 1991 amendment request
:                 proposed, in part, to change the repair A0T for two inoperable RPS channels from one hour to six hours. Those proposed changes to the RPS repair A0T are
{                 specifically evaluated and addressed in BWROG Topical Report NEDC-30851P, i                 " Technical Specification Improvement Analyses for BWR Reactor Protection l               ' System."
IP's September 20. 1991 amendment reque                           also proposed, in part, similar changes to the CRVICS main steam line isolation instrumentation repair A0T limits. Although mark ups for the proposed repair A0T changes for CPS were -
7 not specifically provided in the BWROC Topical Report applicable to main steam line isolation Trip Functions (NEDC-30851P, Supplement 2 " Technical 4
Specification Improvement Analysis for BWR Isolation' Instrumentation Common to
;                 RPS and ECCS Instrumentation"), their qualitative evaluation is documented in j                 the Topical Report. Section 3,1 of NEDC 30851P, Supplement 2 documents the i                 evaluation of changes to the surveillance test intervals for main steam line
,                 isolation Trip Functions common to RPS for'the BWh 6 solid state plant (i.e.,
i                 C75). Section 3.5 documents _ the generic evaluation of A0T changes for all j                 product lines. NEDC-30851P, Supplement 2 concluded that, for a bounding case, an A0T of 24 hours for tests and repairs has less than 2% effect on the 2
probability of failure of the isolation function given a demand.                                  Since the frequency of demand is very low, the Topical Report. concluded that an A0T of 24 hours was justified. However, the NRC Safety Evaluation of NEDC-30851P,
;                 Supplement 2 concluded that the repair A0Ts for instruments common to RPS
:                 sh'uld be limited to the times allowed for the RPS-instruments, rather than-24 i
houls.
t i
Because TS 3/4.3.2, Action Statement b 2 only addresses two inoperable
{                 channels for e main Steam line isolation Trip Function, the capability.to L                 isolate the main steam lines in response to each of the associated-Trip-i                 Function parameters would not be lost while in this configuration due to the two-out-of-four logic configurttion.                    In addition, the proposed repair A0T of i
six hours is less than 24 hours (as evaluated in NEDC-30851P, Supplement 2),
and the proposed repair A0T is equal to the time allowed ~for RPS instruments
                                                                                                ~
(consistent with the NRC's Safety Evaluation of NEDC-30851P, Supplement 2).
Further, the proposed repair A0T is not longer than allowed by the proposed surveillance A0T. Notwithstanding, as stated in NEDC-30851, Supplement 2,.
individual valve failure probabilities dominate overall isolation failure probabilities. As a result, IP has concluded that the proposed six-hour
                                                                                                                 ~
:                 repair A0T for TS 3/4.3.2, Action Statement b.2 does not significantly-l increase the isolation failure probabilities associated with these instruments and, therefore, is acceptable.
4
                                                                                                                                    ~
3

;                a
  \
Attachment 2 to U 602078               l j                                                                                       Page 3 of 11              l 4
Control Rod Block Footnote (d)
As its name implies, CPS TS Table 4.3.6-1, " Control Rod Block Instrumentation Surveillance Requirements," provides the surveillance testing requirements for the control rod block instrumentation.
i                                                                IP's {{letter dated|date=September 20, 1991|text=September 20, 1991 letter}}
.                    requested, in part, increasing the Channel Functional Test (CFT) frequency for the instruments associated with the Rod Pattern Control System (RPCS) low ..
power setpoint and Rod Withdrawal Limiter (RWL) high power setpoint (Items 1.a and 1.b) from monthly (M) to quarterly (Q). The monthly frequency notation j
for each of these two Trip Functions on Table 4.3.6-1 has two_ footnotes attached to it, fcotnote (d) and footnote (e).      Footnote (e) identifies that the CPT must include the reactor manual control multiplexing system input and
;                    footnote (d) identifies that the CFT must be performed at least once per 31
,                    days while operation continues within a given power range above_the.RPCS low
;                    power setpoint. IP's September 20, 1991 amendment request noted (see page 12 of Attachment 2 to U-601871) that IP had previously proposed to deleto 3                    foott.ote (d) per an earlier request. At the time, it was anticipated-that NRC
 !                   review of the earlier amendment request would be completed prior to review of
:                    the September 20,-1991 request. However, the earlier request is still under I                    review by the NRC. As a result, approval of IP's September 20, 1991 amendment request at this time will result in a conflict with footnote (d).
IP is now requesting that footnote (d) be deleted as part of this request in order to resolve the conflict between the frequency proposed in the CFT column of Table 4.3.6-1 (quarterly) and the frequency contained in-footnote (d) (at least once per 31 days). Deletion of footnote (d) is reflected in Attachment
;                    3 (as denoted by double change bars) and the justification is provided below.
,                    IP proposes to delete footnote (d) primarily for-the purpose of simplifying the surveillance requirements. Without footnote (d) attachad to the frequency 1
notation, the CFT is required to be performed at least once during the required test interval while the plant is in the specified modes. The' plant modes specified for these Trip Functions encompass the more specific i
conditions of " operation... within a given power range of the RPCS low-power setpoint" identified in footnote (d). Although deleting the footnote could require the CPTs to be performed more often than required with_the footnote attached (if the plant, for example, was in operation for an extended period 1                    of time in Mode 1 or 2 but at a power level below that corresponding to the low power setpoint), Operations personnel feel that simpilfying the CFT i-                   requirements is more important. The possibility of additional CFTs being i
required as a result of removing footnote (d) would be even more' remote after the CPT frequency is reduced to quarterly. It should also be noted that
;                    footnote (d) has already been removed from the Technical Specifications for the other three BWR-6 plants.
~
Resolution of " Loss-of-Function" Issues The changes to repair A0Ts_as provided in the BWROG Topical R3 ports (and as generically approved by the NRC) would allow, with certain instrument channels inoperable, a plant configuration which does not have the capability to-automatically actuate the respective system / valve (s)1to exist for up to 24 hours. During review of proposed changes to individual. plants' TS to

        .     - - = . . .                              - -- -                   .- -    - -              .         ~.      -    . - - --       . -
t   .
Attachment 2 i                                                                                                                to U-602078 Page 4 of 11 i               implement the BWROG Topical Reports, the NRC identified the potential _for a loss of scram capability for certain events to exist for up to 12 hours based on the changes proposed to the Action Statements for RPS by the BWROG. The NRC concluded that permitting such a " loss of-function" condition to exist for such a period of time was unacceptable and that this issue must be resolved 3
prior to further approval of proposed changes to RPS repair A0Ts on individual plants' dockets. As identified in IP's September 20, 1991 amendment request (reference page 4 of Attachment 2 to U 601871),. this RPS loss-of function issue is not applicable to CPS since the RPS logic at CPS is arranged in a two-out-of-four configuration and the Action Statements do not allow continued
!               operation when any parameter is unable to provide a reactor scram (i.e., more than two channels inoperable).
i
;               As noted previously, IP submitted a supplement to the September 20, 1991
;               amendment request (IP letter U 602025) on August 17, 1992. That supplement
!               was written, in part, to eliminate a loss of function concern in the proposed 3               Action Statements for TS 3/4.3.9, " Plant Systems Actuation Instrumentation."
j               However, those changes were necessary to conform with the limitations provided in BWROG Topical Report CENE 770 06 1, " Bases for Changes to Surveillance Test Intervals and Allowed Out-of-Service Times for Selected Instrumentation
}i              Technical Specifications." The allowance provided in GENE-770 06 1 to change i
4 repair A0Ts for the instruments listed in TS 3/4.3.9 only applies in those cases where "taking out the channel does not cause loss of the trip function."
a The changea to TS 3/4.3.9 provided in IP's August 17, 1992 supplement conform to this limitation and preclude a loss of function condition existing for these instruments for greater than one hour.
I t
During the development of the Improved Standard Technical Specifications (ITS)
}                (NUREG-1434), loss-of function and support system operability were issues that I
were specifically addressed. As a result, the Action Statements in NUREG-1434 i                for instrumentation that provides an automatic actuation function contain checks to ensure that a loss-of-function condition does not exist. -NUREG 1434
:               was issued by the NRC for implementation by utilities on September 29, 1992, During a meeting with IP on November 24, 1992, the NRC stated that the repair i               A0T changes proposed by IP are.not acceptable because the associated Action Statements do not contain checks (as contained in NUREG 1434) to ensure that a loss-of-function condition does not exist.for more than one hour. As a j               result, IP has completed a review of each of the repair A0T changes proposed                                                           l j-               in IP's September 20, 1991 amendment request to identify and eliminate'where                                                          j j               loss-of function conditions may be permitted to exist for more than one hour.                                                          l 1
The results of that review and t.he necessary changes to IP's September 20,                                                            '
l                1991 amendment request are described below.
Resolution of the loss-of-function issue requires no further. changes to the Action Statements previously proposed for much of the instrumentation addressed by the CPS TS. As noted previously, no further changes are required for TS 3/4.3.1, " Reactor Protection System Instrumentation," because the RPS logic is arranged in a two-out-of four configuration and the Action Statements 4
              'do not allow continued operation when any parameter is unable to provide a reactor scram. Because identical logic.and Action Statements are provided for the end-of-cycle recirculation pump trip actuation instrumentation (TS
              .3/4.3.4.2) and main steam line isolation Trip Functions of CRVICS (TS
                          , . - , .,wv.-.,. ,7,-w.,--.        -..,,w ., .~i+..,      4r     --
                                                                                               ,...--..,---r,. -,.     -,%    e          - y- .,y  e -

_-                                   -           . .        .                          ~                        . - .                                             .                     .
l
     *          *                                                                                                                                                                                      \
4 l
                                                                                                                                          -Attachment 2                                                !
to U-602078 Page 5 of 11 3/4.3.2) .no further changes to these TS are likewise required.                                                                        The proposed 1                     changes to the remainder of the A<-ion Statements-of TS 3/4,3.2 apply only to one trip system and preclude conti.ued operation if the ability _to isolate a containment penetration has_been lost. As a result, no further changes to TS
!                     3/4.3.2 are required. No further changes are required to TS 3/4.3.4.1, "ATWS-j-                    Recirculation Pump Trip System Instrumentation," TS 3/4.4.2.1, ' " Safe ty/ Relief -
l                     Valves," or TS 3/4.4.2.2, " Safety / Relief Valves Low-Low Set Function," because
^
IP did not propose any changes to the repair A0Ts for the instruments
;                     addressed by these TS. No further changes to TS-3/4.3.9, " Plant Systems Actuation Instrumentation," are required because, as stated above, IP's_ August 17, 1992 supplement provided changes to this TS to. eliminate loss-of-function conditions. Finally, no further changes to TS 3/4.3.7.1, " Radiation j                     Monitoring Instrumentation," are required since the affected Action Statement addresses having only one channel inoperable. -This configuration would not.
;                     create a loss-of-function _ condition since the associated logic is arranged in
,                     a one-out-of-two- twice configuration.
,                     IP has determined that additional changes are' required to the Action 1
Statements for TS 3/4.3.3, " Emergency Core Cooling System Actuation Instrumentation"; TS 3/4.3.5, " Reactor Core Isolation Cooling System Actuation-j                     Instrumentation"; and TS 3/4.3.6, " Control Rod Block Instrumentation." The j
necessary changes are reflected in Attachment 3 (as denoted by double change -
bars). The Action Statements for each of these TS are discussed below.
4 TS 3/4.3.3. "Emerrency Core Cooling System Actuation Instrumentation"
;                                     The Action Statements provided for ECCS Actuation Instrumentation in NUREG-1434 (LCO 3.3.5.1) consist of the following general requirements:
}                                      For the Division I and Division II ECCS [i.e., low pressura core _ spray j                                      (LPCS) and low pressure coolant inj ec tion _ (LPCI) loops A,                                                     B, and C], a
:                                      check is required to ensure that automatic initiation capability has not-been lost for both divisions of ECCS when an automatic initiation instrument becomes inoperable.                                 (This applies to the reactor water level-low low low level 1, drywell pressure high, pump start time delay, j                                      injection valve permissive. reactor vessel pressure-low (Modes 1, 2, and-l                                      3 only) and pump discharge flow low Trip Functions.} If a loss-of-function condition does not exist, then at least 24 hours is allowed to l
restore the channel to operable status or place it in the tripped condition. NUREG-1434 does not require a loss-of-function check to be performed for the injection valve permissive reactor _ vessel pressure-low l                                     Trip Functions while the reactor is in Mode 4 or 5 or for the low
_ pressure ECCS manual initiation Trip Functions.
l For the Division III ECCS [high pressure core spray (HPCS)' system), a check is required to ensure that automatic initiation capability has not been lost for the HPCS system when an automatic initiation instrument becomes inoperable.                  (This applies to the reactor water level-low. low a
'                                      level 2, drywell pressure high, RCIC storage tank level-low, and
_ suppression pool-hiS h. Trip Functions.) If_a loss-of-function condition
;                                      does not exist, then at least 24 hours is allowed to restore the_ channel l                                      to operable status or place it in the tripped condition.                                                          NUREC-1434 does not require a loss-of-function check to be performed for the HPCS 1
I 4

                  -            -         -               ..     -           -       .                                   ~- .       .- .    .
1 Attachment 2-
$                                                                                                       to U-602078-Page 6 of 11 manual initiation, HPCS pump flow, HPCS pump pressure, or reactor water                       ~
level-high level 8 Trip. Functions.
For-the automatic-depressurization system (ADS), a check is required to                            _
!                   ensure that automatic initiation capability has not;been lost for both
{                   ADS Trip Systems when an automatic initiation instrument becomes
:                   inoperable. (This applies to the reactor water level-low low low level i
1, drywell pressure high, reactor water level ~-low level 3 permissive,
;                   ADS timer, low pressure ECCS pump pressure permissive, and drywell j                   pressure bypass timer Trip Functions.) If a loss-of function condition a                   does not exist, then at least four days are allowed to restore the i                   channel to operable status or place the channel in the tripped condition.          NUREG-1434 does not require a loss-of-function check to be i                   performed for the ADS manual initiation Trip Function.
                                                                                                                               ~
5                   In light of the above, IP is proposing the following changes to the Action Statements of TS Table 3.3.3-1 to be consistent with NUREG 1434:
Action 30 currently applies to the low pressure ECCS and ADS reactor water level low low low level 1 and drywell pressure-high Trip Functions
!                   (Items A.l.a, A.l.b, A.2.a              A.2.b, B.1.a. B.1.b, B.2.a, and B.2.b) and j                   the ADS drywell pressure bypass timer Trip Functions (Items A.2.g and
;                   B.2.f). This Action Statement has been revised to require, within one j                   hour, a verification that a sufficient number of channels remain i                   operable or are in the tripped condition to maintain automatic actuation capability of either Division I or Division II ECCS and either ADS Trip
;                   System 1 or Trip System 2.              This will ensure that a loss-of-function condition does not exist. The revised Action 30 will require the i                   inoperable channel (s) to be placed in the tripped condition within 24 hours.       If a loss-of-function condition exists or it is not desirable to place the inoperable channel (s) in the tripped condition,= the associated i                   system (s) must be declared inoperable.
It should be noted that it . is not appropriate to place the ADS drywell pressure bypass timer (Items A.2.g and B.2.f)-in the tripped condition 4 i
This would result in starting the ADS timer immediately on a low reactor water level (level 1) condition.- Currently, a concurrent high drywell pressure signal is required to start the' ADS timer within the first six minutes of obtaining a low reactor sater level signal. As-a result, the reference-Action for this Trip Function is being changed to Action 32,
,                   (See the following discussion regarding Action 32.) Revised Action _32 will require the timer to be restored to operable status within 24 hours or the associated ADS trip system to be' declared inoperable.
With further respect to Action 32, the ADS reactor water level-low level' e
3' permissive Trip Functions (Items'A.2.d and B.2.d) currently reference this Action. Action 32, however, does not provide the option of placing i
the inoperable' channel in the tripped condition. This should be an acceptable alternative to declaring the associated ADS. trip' system inoperable.. The level 3 signal is provided only-as a confirmatory signal to ensure that a low reactor water level condition actually
                                               ~
exists.         Placing the inoperable; channel in the tripped condition would still require receipt of a level 1 signal to initiate ADS, and placing 4
1
     . _ _ _ ..   .        _ . -      .   -m .   .  . . -           ,__       - , . - . - ~ . - . _ , _ ~ . ,- . . . . _ . . _ .        .,

Attachment 2 to U 602078 Page 7 of 11 the channel in the. tripped condition is allowed by NUREC 1434. As a-result, the reference Action for-the reactor water level-low leval 3 Trip Function (s) is being changed from Action 32 to Action 30.
Action 32 currently applies to the low pressure ECCS injection valve permissive reactor vessel pressure low (during Modes 1, 2, and-3 only) and LPCI 'A' and LPCI 'B' pump start time delay Trip Functions (Items A.1.c, A.1.d, B.1.c, and B.1.d); ADS timer, reactor vessel water level-low level 3 permissive, and low pressure ECCS pump pressure permissive Trip Functions (Items A.2.c, A.2.d, A.2.e      A.2.f, B.2.c, B.2.d, and B.2.e); and the HPCS reactor vessel water level-high level 8 Trip Function (Item C.1.c) . This Action Statement-has been revised to require, within one hour, a verification that a sufficient number-of channels remain operable or are in a tripped condition to maintain automatic trip capability of either Division I or Division 11 ECCS and either ADS Trip System 1 or Trip System 2. This will ensure that a loss of function condition does not exist. The revised Action 32 will require the inoperable channel (s) to be restored to operable status within 24 hours. If a loss of-function condition exists or the inoperable channel (s) cannot be restored to operable status, the associated system (s) must be declared inoperable.
As identified above, Action 32 currently' applies to'ene HPCS reactor water level-high level 8 Trip Function (Item C.1.c). However, NUREG-1434 does not require a loss-of-function check to be performed for this               1 Trip Function. . As a result, the reference Action for this Trip Function is being changed to revised Action 35 which is consistent with Action 32 with the exception that it does not require a loss-of-function check.
(Action 35 is further discussed below.)
hallon 33 currently applies to - the low pressure .ECCS injection _ valve permissive reactor vessel pressure-low Trip Functions during Modes 4 and 5 (Items A.l.c and B.1.c). _Since NUREG-1434 does not require.a loss of-function check to be performed when this Trip Function _becomes inoperable, the revision to Action 33 proposed-in IP's September 20, 1991 amendment request requires no changes.
Action 35 currently applies to the low pressure ECCS manual initiation-Trip Functions-(Items A.1.g and B.l.g); !.0; canual inhibit switch and ADS manual initiation Trip Functions (Items A.E.h, A.2.1, B.2.g, and-B.2.h); and HPCS manual initiation Trip Function (Item C.1.h). Since NUREG-1434 does not require a loss-of-function check to be; performed when these Trip Functions become inoperable, the revision to Action 35-proposed in IP's September 20, 1991 amendment request-requires no changes. In addition, as_noted above, NUREG-1434 does not require a loss-of-function check to be performed when- the HPCS reactor water level-high level 8 Trip Function (Item C.1.c) becomes inoperable. As a result, the reference Action for this Trip Function has been changed
             -from Action 32 to Action 35. Action 35 will require the inoperable channel (s) to be restored to operable status within 24 hours or the_HPCS system declared inoperable. Therefore, this change is acceptable.

l     .
i Attachment 2
                                                                                                      -to U-602078 Page 8 of 11 i
Action 36 currently applies to the HPCS reactor water level-low low level 2-and drywell pressure-high Trip: Functions (Items C.1.a and i
C.l.b). This Action Statement has been revised to require, within one hour, a verification that a sufficient number of channels remain -
i                operable or are in the tripped condition to maintain automatic HPCS j                actuation capability. This will ensure that a loss of function i                condition does'not exist. The revised Action 36 will require the inoperable channel (s) to be placed in the tripped condition within 24 i'               hours. If a loss of function condition exists or it is not desirable to place the inoperable channel (s) in the tripped condition, the HPCS-
!                 system must be declared inoperable, 1
l                Action 37 currently applies to the RCIC storage tank level-low and
.                 suppression pool water level high Trip Functions for-HPCS'(Items C.1.d
!                and C.1.e). This Action Statement has been revised to require, within j                 one hour, a verification that-the HPCS pump suction is either aligned or
;                 capable of automatically realigning to the suppression pool. This will  -
ensure that a loss of-function condition does not exist. The revised l                Action 37 will require at least one inoperable channel-to be placed in
!                 the tripped condition (which will automatically realign the HPCS pump j                 suction to the suppression pool) within 24 hours. If a loss-of-function condition exists or it is not desirable to place an inoparable channel
:                 in the tripped condition (or realign the HPCS pump suction to the suppression pool),.the HPCS system must be declared inoperable.
1' Action 40 currently applies to low pressure ECCS pump discharge flow
:                Trip Functions (Items A l.e, A.l.f. B.l.e, and B.l.f) and HPCS pump discharge pressure and system flow rate Trip Functions (Items C.1.f and
                                                                                        ~
C.1.g). This Action Statement has been revised to require, within one j                hour, a verification that a sufficient number of channels remain operable or are in the tripped condition to maintain automatic actuation 1                 capcbility of either Division I or Division II ECCS. This will ensure that a loss-of-function condicion does not exist. Dae revised Action 40 will require the inoperable channel (s) to be restored to operable status within seven days (the current time limit).                                 If a loss of-function condition exists or the inoperabic channel (s) cannot be' restored to operable status, _the associated system mustlbe declared inoperable.
                . However, NUREG-1434 does not -require a loss-of-function check to be 4
performed for-the HPCS pump discharge pressure and system flow rate _ Trip Functions (Items C.1.f. and C.1.g). As a rasult.fa new Action is being i                 applied to these. Trip Functions. New Action 41,-as. described below, is consistent with Action 40 with the exception that it does not require a
;                 loss-of-function check.
4 As describe'd above, pew Action Statement 41 is being proposed to apply-to the HPCS pump discharge pressure and system flow rate Trip Functions                                               I (Items C.1.f and C.l.g). This new Action Statement requires the inoperable channel (s) to be restored to operable status.within seven days (the_ current time limit)'.                              If the inoperable channel (s) cannot be
;                 restored to operable status, the HPCS must'be declared inoperable ~. (As
:                 noted above, NUREG-1434 ' does .not require a loss-of-function _ check for these Trip Functions.)
1
_,       ,       _. _       . . .   , . , _ . . - _ . _ , - , _ - . - _ .                           - . _ . .       _ _ _ - . _ .J

_                 _  .                      - - ~    _.         _        __              __         _ . _                 ..
!                                                                                                            Attachment 2 to U 602078 Page 9 of 11                    ;
T                       In addition to the proposed changes to the above Action Statements,-two additional changes of an editorial nature are being proposed. First, footnotes (e) and (f) to Table 3.3.3 1 are being deleted. These footnotes clarify the trip system boundary for-the four reactor water level (Item C.1.a) and high drywell pressure (Item C.1.b) inputs to the HPCS actuation logic. These footnotes were added to the CPS TS via Amendment No. 48. As stated in the NRC's Safety Evaluation accompanying
]                      Amendment No. 48 (dated September 25, 1990), these footnotes were added to ensure that the correspondir.g Action Statements are implemented properly when one or more channels are declared inoperable. These footnotes were necessary because the corresponding Action Statement
;                       (Ac. tion 36) currently prescribes the action to be taken-based on the number of trip systems affected. However, the revised Action 36
,                      proposed in this supplement eliminates the dependence of the action to j                      be taken on the number of trip systems affected. As a result, footnotes (e) and (f) are no longer necessa ry and therefore, IP proposes to delete j                       them,
,                       Secondly, the changes to the Action Statements proposed in this supplement involve the addition of a new requirement to verify that a sufficient number of channels remain operable or are in the tripped i                       condition to maintain automatic actuation capability of the associated i                       ECCS systems.          However, consistent with NUREG 1434, this verification is not required for a number of ECCS Trip Functions.                                 Therefore, a new
,                       footnote (e) is.being added to identify those Trip Functions which are
!                       subj ect to loss-of-function checks.                This will provide the clarification needed to ensure that these new requirements are implemented as intended. New footnote (e) would be applied under the Minimum Operable
<                       Channels per Trip Function column of Table 3.3.3-1 and would be applicable to Items A.l.a. A.1.b, A.1.c (during Modes 1, 2, and 3 only),
A.1.d, A.l.e. A.1.f A.2.a. A.2.b, A.2.c, A.2.d, A.2.e, A.2.f                                  A.2.g.
,                       B.1.a. B.1.b, B.1.c (during Modes 1, 2, and 3 only), B.1.d, B.1.e, B.1.f. B.2.a, B.2.b, B.2.c,-B.2.d, B.2.e, B.2.f, c'.1.a. and C.1.b.                                         The
'                       remaining Trip Functions listed on Table 3.3.3-1 are not subject to loss-of-function checks.
f              TS 3/4.3.5. " Reactor Core Isolation Cooline System Actuation Instrumentation"
,                       The Action Statements provided for RCIC Actuation Instrumentation in-NUREG-1434 (LCO 3.3.5.2) require a-loss-of-function check to be
;                       performed when a RCIC automatic initiation instrument becomes inoperable.        (This applies to the reactor water level low low level 2, RCIC storage tank level-low, and suppression pool level-high Trip i-                      Functions.) If a loss-of-function condition does not exist, then 24
+
hours is allowed to restore the channel to operable status or place it in the tripped condition. NUREG-1434 does not require a loss-of-function check to be performed for RCIC manual initiation-or reactor water level-high level 8 Trip Functions.
IP is proposing the following changes to the Action Statements of TS Table 3.3.5-1 to be consistent with NUREG-1434:
__      - _ _ . , - -      . . ._ -, .-              --    _- ._     . - . . . ~ . - _ . ,.               . _ , , .       _.    .

Attachment 2 to U.602078 PaSe-10 of 11 Action 50 currently applies to the reactor water icvel. low low level 2 Trip Function (Item a). This Action Statement has been revised to g
require, within one hour, a verification that a sufficient number of low-reactor vessel water level channals remain operable or are in the tripped condition to maintain automatic RCIC actuation capability.                                               This will ensure that a loss of function condition does not exist. The revised Action 50 will require the inoperable channel (s) to be . aced in the tripped condition within 24 hours. If a loss of function                                         -41 tion exists or it is not desirable to place the inoperable channe16.                                             n the tripped condition, the RCIC system must be declared inoperable.
Action 51 currently applies to the reactor water level +hi&h Trip t' unction (item b). Since NUREC 1434 does not require a loss of. function-check to be performed when this Trip Function becomes inoperable, the revision to Action $1 proposed in IP's September 20, 1991 amendment request requires no changes.
Agtion $2 currently applies to thn RCIC storage tank level. low and the suppression pool level.hi,h                           t Trip Functions (Items c_and d).        This Action Statement has been revised to require, wichin one hour, a vcrification that the RCIC pump suction is either aligned or capable of automatically realigning to the suppression pool. This will ensure that a lor if-
                    < unction condition does not exist. The revised Action 52 will reqaire at least one inoperable channel to be placed in the tripped condition (which will automatically realign the RCIC pump suction to the suppression pool) within 24 hours. If a loss of. function condition exists or it is not desirable to place an inoperable channel in the tripped condition (or realign the RCIC pump suction to the suppression                                                 3 pool), the RCIC system must be declared inoperable,                                                                     n AsMon 53 currentif applies, to the RCIC manual initiation Trip Function (1 tem e),             Since NUREC-1434 does not require a loss of function check to be performed when this Trip function becomes inoperable, the revision to tion 53 proposed in IP'c September 20, 1991 amendment request requires changes.
TS 3/4.3.6 " Control Rod )],ock Instrumentation" NUREC 1434 does not provide any specific Action Statements for the individual inputs to the Rod Withdrawal Limiter. The only Action Statement of TS 3/4.3.6 which was impacted by IP's September 20, 1991 amendment request was.the addition of a-new Action Statement (Action 64) for the scram discharge volume water level.high and reactor coolant system recirculation flow upscale Trip. Functions. Proposed Aation Statement 64 has been revised to require, within one hour, a .
verification that a sufficient ' number of channels remain operable to-initiate.'a rod block by the' associated Trip Function. This will ensure that a loss of-function condition does not exist.- The revised Action 64
                . will requt*e at least one inoperable channel to be placed in the tripped condition within 24 hours. If a loss.of function condition exists or-it is not. desirable to place an inoperable channel inlthe tripped condition, a rod block must be -initiated.
O

           . - - - _ - - -- . - - - - - -                                                                                                                              -.--------a.-.                                                                  -
                                                                                                                                                                                                                                                                 =~
q                            -.
t
}                                                                                                                                                                                                        Attacturient 2
}                                                                                                                                                                                                         to U 602078-Page 11 of 11
$                                    Stunmarv
!                                    In summary, IP has reviewed the changes proposed in the September 20, 1991
 ;                                   amendment request, as modified by letter dated August- 17, 1992. For each of
;                                    thoso Action Statements which could apply to a loss of function configuration, i                                    IP has modified the Action Statement to include a loss.of function check l                                    consistent with NUREG 1434                                                           As a result, IP har concluded that this submittal j                                    adequately addresses the loss.of. function concerns for instrtunents at_ CPS j                                    within the scope of the BVR00 rsliability based instrumentation analyses.
1 j                                    Basis for No Sicnificant 11arards Consideration i
f                                     IP has reviewed the Basis for No Significant Hazards Consideration provided in i                                    IP's September 20,_1991 amendment request and has concluded'that the additional changes contained in this supplement'do not alter the bases or a                                    conclusions provided in those assessments. As a result, IP has concluded that i                                     these proposed changes do.not involve a significant hazards consideration, 2
i                                                                                                                                                                                                                                                                     i i
T f
t 1
i T
1 I
1 i
i 4
i 4
4 4
i i
e-
* w,- ww w -r-m t c      w w m vee m w = -t- wev
* v v=,w e '= ~ O Tv ir -+vev v ev ate vw -* w w r *-=> 9r t-
* v f =* P= - v e r y- -mtes-- -=--g9-ve-,go n,-,-ee- w eg wyr , --vv-+-- fy-,-ey-y,-,-g 'rf rs"<*M*-r*R SP'T F W 1 -'-4r***f4**-9CP'Y~    F}}