View source for JSP-442-91, Application for Amend to License NPF-62,changing Tech Spec 3/4.3.2 Re Containment & Reactor Vessel Isolation Control Sys

{{Adams
| number = ML20082A173
| issue date = 07/01/1991
| title = Application for Amend to License NPF-62,changing Tech Spec 3/4.3.2 Re Containment & Reactor Vessel Isolation Control Sys
| author name = Cook 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-0442-91, JSP-442-91, U-601837, NUDOCS 9107100211
| package number = ML20082A177
| document type = OPERATING LICENSES-APPLIATION TO AMEND-RENEW EXISTING, TEXT-LICENSE APPLICATIONS &amp; PERMITS
| page count = 29
| project = 
| stage = Request
}}

=Text=
{{#Wiki_filter:o U-601837 4                                                                                                                                    L4 7-91(07-01)LP 8" 2 oa ILLill0IS POWEll CLINTON POWER STATION P.O. ISOX 678, CLINTON. ILLINOIS 61727 0G78. TELEPilONE (217) 935 8881 JSP-0442-91 July 1, 1991                                                                                    l l
Docket No. 50-461 Document Control Desk Nuclear Regulatory Commission Washington,        D.C.      20555

==Subject:==
Clinton Power Station Proposed Amendment of Facility                                                                                         i ODeratina License No. NPP-62                                                                                           I

==Dear Sir:==

Pursuant te 10CFR50.90, Illinois Power Co=pany (IP) hereby applies for amendment of Facility Operating License No. NPF-62, Appendix A - Technical Specifications, for Clinton Power Station (CPS). This request consists of proposed changes to Technical                                                                                      l Specification 3/4.3.2, " Containment and Reactor Vessel Isolation Control System." For each of these proposed Technical Specification changes, a description, the associated justification (including a Basis For No Significant Hazards Consideration), and marked-up copies of pages from the current Technical Specjfications are provided in Attachment 2. In addition, an affidavit supporting the facts set forth in this letter and its attachments is providc' in Attachment 1.
IP has reviewed the proposed changes against the criteria of 10CFR51.22 for categorical exclusion from environmental impact considerations. The proposed changes do not involve a significant hazards consideration, or significantly increase the amounts or change the types of effluents that may be released offsite, nor do they significantly increase individual or cumulative occupational radiation exposures.                                                                     Based on the foregoing, IP concludes the proposed changes meet the criteria given in 10CFR51.22 (c) (9) for a categorical exclusion fiom the requirement for an Environmental Impact Statement.
Sincerely yours, J.
                                                             'hD
                                                             . Cook Manager-Clinton Power Station lI
()0 0-9107100211 910701 PDR   ADOCK 05000461
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_~     - - __ - ___-- _ _ __--_--_ - -__ _ _ _ __________- - _ - - ____

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Attachments                                       '
l cc:  NRC Clinton Licensing Project Manager                                              l NRC Resident Office NRC Region III, Regional Administrator Illinois Department of Nuclear Safety i
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o                                                                                                                              Attachment 1
        '                                                                                                                          to U-601837 STATE OF ILLINOIS COUNTY OF DEWITT John G. Cook, being first duly sworn, deposes and says:
That he is Manager of Illinois Power Company's Clinton Power Station and has been duly authorized to submit this application for amendment of Facility Operating License NPF-62; that the application for amendment of Facility Operating License HPF-62 hos been prepared under his supervision and direction; that he knows the contents thereof; a:1d that to the best of his knowledge and belief said application and the facts contained therein are true arid correct.
DATED:          This        I   day of July 1991 Signed:          /                                  /                                   fh j                                                         John G. Cook Subscribed and sworn to before me this /Jd                                                                          day of July 1991.
c::: :::::::::::::::::: ;                     x/ 44; orricin sEn-               t 7
t   /seab Notary Public unda S. French Netary Public. State of lainois
                  ,  My Commission Espires 9/1/92 j t::::::::::::::::::::::::

Attachment 2 q                                                                                                                                                                                                                             U-601837 4                                                                                                                                                                              LS-89-007 Page 1 of 26 Dackaroynd In December 1987, Illinois Power (IP) identified that the setpoint calculations for instrumentation within the design scope of the Architect / Engineer (Sargent and Lundy) for Clinton Power Station (CPS) were performed assuming six-month calibration intervals.                                           IP noted that this was inconsistent with the CPS Technical Specifications and plant calibration procedures which allowed calibrations to be performed at 18-month intervals.*
As a result of the above finding, IP reviewed a random sample of the Sargent and Lundy (S&L) setpoint calculations to determine the impact of increasing the assumed cilibration interval f rom six months to 18 months, The IP review preliminarily determined that the additional drift allowance required to increase the assumed calibration interval from six months to 18 months resulted in a negligible impact on the random sample of setpoints due to the margin contained in those setpoint calculations.
However, IP's preliminary determination was based on a sample of setpoint calculations and was based on a methodology slightly different than the methodology S&L had utilized.
During 1988, IP directed S&L to recalculate the setpoints for those instruments within their scope of design utilizing
                                                                                         ' the S&L setpoint methodology and an assumed 18-month calibration / drift interval.                            These results determined that the setpoints and/or allowable values for 97 instrumenta were impacted.            As a result. i. hose instruments whose setpoints did not supporc 18-month calibration intervals were subsequently recalibrated during the first refueling outage and th'e calibration schedules for these instruments were revised to_ require future calibrations to be performed-on a six-month frequency.
During a planned plant outage in the Spring of 1990, the Shutdown Service Water system flow rates were rebalanced.
As a result of this rebalancing, the leak detection temperature calculations were revised.                                                                          The revised calculations utilized revised cooling water flow rates based upon the Jautdown Service Water system rebalancing and a more advanced, yet conservative, modeling of heat exchanger performance. The results of the revised calculations formed the basis for a subsequent revision to the leak detection setpoint calculations.             In those cases where sufficient margin was available between the revised temperature calculation results and the existing allowable value, the allowable value was increased.                                          In other cases,.only the
* IP verified that the setpoint calculations performed for instrumentation within the General Electric Company's scope of design were correctly based on 18-month calibration intervals.
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* Attachment 2 U-601837 3
LS-89-007 Page 2 of 26 trip setpoint or both the trip setpoint and allowable value were lowered in order to maintain sufficient margin and allow calibraulon on an 18-month interval, of the 97 instruments whose setpoints did not support an 18-month calibration interval, 82 are within the scopc of the CPS Technical Specifications; of these, 66 have setpoints specifically identifiad in the Technical Specifications.                                                    In particular, all of these instruments are addrossed in Technical specification 3/4.3.2, " Containment and Reactor Vessel Isolation Control System" (CRVICS).                                                   The remaining 15 instruments (of the 97) are not within the scope of the CPS Technical Specifications and are calibrated under the CPS preventive maintenance program.
Although IP continues to calibrate the 66 instruments whose setpoints are upocified in the Technical Specifications on a six-month interval, the proposed changes are requested to revise the trip setpoints and/or allowable values for these 66 instruments. Approval of this request will allow CPS to return the procedural calibration frequency to at least once per 18 months consistent with the frequency currently specified in the Technical Specifications. The remaining 31 instruments who a setpoints are not specified in the Technical Speci11 cations will continue to be calibrated in accordance with the CPS preventive maintenance program.
Das_qription of Proposed Chances In accordance with 10CFR50.90, the following changes to the trip setpoints and allowable values for the CRVICS instrumentation contained on Tr.chnical Specification Table 3.3.2-2, "CRVICS Instrumentat.on                            #
Setpoints," are being proposed:
: 1. Primary and Secondary Containment Isolation
: a. For Item 1.k, Containment Pressure - High, the trip sntpoint is decreased from $ 2.62 psid to s 2.36 psid.
: 2. Main steam Line Isolation
: a. For Item 2.f, Main Steam Line Tunnel Temp. - High, the trip setpoint is decreased from 5 165'F to 5 156*F, and the allowable value is decreased from 5 176 F to 5 171*F.
: b. For Item 2.g, Main Steam Line Tunnel Delta Temp.                                                -
High, the allowable value is increased from 5 60*F to 5 63*F.
: c. For Item 2.h(1), Main Steam Line Turbine Bldg.
Temp. - High, 1E31-M559A,B,C,D, 1E31-N560A,B,C,D, lE31-N561A,B,C,D, 1E31-N562A,B,C,D; the allowable value is increased from s 138'F to 5 142*F.
* Attachment 2
. q U-601837 i     ,
LS-89-007 Page 3 of 26
: d.      For Item 2.h(2), Main Steam Line Turbine Bldg.
Tamp. - High, 1E31-N563A,B,C,D; the trip setpoint is decreased from 5 143.2*F to s 139.5'F.
: 3. Reactor Water Cleanuo System Igolation
: a.      For Item 3.c.1,             Equipment Area Temp. - High, Fump Rooms - A,B,C; the allowable value is increased from s 197.1'F to 5 202'F.
: b.      For Item 3.c.2,               Equipment Area Temp. - High, Heat Exchanger Rooms - East, West; the trip setpoint is decreased from 1 201*F to 5 190*F, and the allowable value is decreased from 1 212*F to
                      $ 205'F.
: c.      For Item 3.d.1, Equipment Area Delta Temp. - High, Pump Rooms - A,B,C; the allowable value is increased from s 60*F to 5 63*F.
: d.      For Item 3.d.2, Equipment Area Delta Temp. - High, Heat Exchanger Rooms - East, West; the allowable value is increased from 5 60'F to 5 63'F.
: c.      For Item 3.f, Main Steam Line Tunnel Ambient Temp.
                       - Hight the trip setpoint is decreased from s 165'F to 1 156*F, and the allowable value is decreased from 5 176*F to 5 171*F.
: f.      For Item 3.g, Main Steam Line Tunnel Delta Temp.                -
High; the allowable value is increased from s 60*F to 5 63*F.
: 4. Reactor Core Isolation Coolina System Isolation
: a.      For Item 4.e, RCIC Equipment Room Ambient Temp.               -
High, the trip setpoint is decreased from 5 222.5*F to 5 192*F, and the allowable value is decreased from 5 233.1'F to 1 207'F.
: b.       For Item 4.f, RCIC Equipment Room Delta Temp.             -
High, the allowable value is increased from 5 40*F to 5 43*F.
: c.      For Item 4.g, Main Steam Line Tunnel Ambient Temp.
                         - High, the trip setpoint is decreased from i 165'F to 5 156*F, and the allowable value is decreased from s 176'F to 5 171'F.
: d.      For Item 4.h, Main Steam Line Tunnel Delta Temp.                 -
High, the allowable value is increased from 5 60'F to 5 63*F.
                    . For Item 4.m, RHR Heat Exchanger A, B, Ambient Temperature - High; the trip setpoint is increased from 5 130.5'F to 1 144.5'F, and the allowable value is increased from 1 149.6*F to 5 160*F.

            ~
Attachmsnt 2 g                                                                                                                              U-601837
          .                                                                                                                      LS-89-007 Fage 4 of 26
: f. For Item 4.n, RHR Heat Exchanger A, D, Delta Temp.
                                                                                          - Hight the trip setpoint is decreased from 5 74.2'T to 5 71.9'F.
: 5.                                   R}{R System IsolatioD
: a. For Item 5.a, RHR Heat Exchanger Rooms A, B, Ambient Temperature - Hight the trip setpoint is increased from $ 138.5'F to s 144.5'F, and the allowable value is increased from $ 149.6'F to 5 160*F.
: b. For Item 5.b, RHR Heat Exchanger Rooms A, B, Delta Temperature - Hight the trip setpoint is decreased from 5 74.2'F to 5 71.9'F.
All of these proposed changes are indicated on marked-up copies of CPS Technical Specification pages 3/4 3-21, -22, and -23 provided as pages 24, 25 and 26 of this submittal.
Justificaticn for Proposed Chances Except for one item, all of the Containment and Reactor vessel Isolation Control System (CRVICS) instrumentation channels affected by this proposed change are associated with the Icak detection system. As described in Section 7.6.1.4 of the CPS Updated Safety Analysis Report (USAR)**,
the purpose of the leak detection system instrumentation and controls is to monitor leakage from the reactor coolant pressure boundary and initiate alarms and/or an isolation function before predetermined (temperature) limits are exceeded. Pursuant to this purpose, this affected instrumentation is designed to detect and effect an automatic isolation in response to a 25-gpm equivalent steam leak in the particular area monitored by the associated leak detection instrumentation.
As described in CPS USAR Section 5.2.5, the equipment areas in the Auxiliary Building, the main steam tunnel and the Turbine Building are monitored for primary coolant leakage.
The process piping for each system monitored is located in compartments or rooms which are separate from other systems.
where feasible, so that leakage may be detected by area temperature indications. Ambient temperatures of the equipment areas are monitored by dual-element thermocouples.
Individual area differential temperatures are monitored from-temperature elements which sense the differential between
                                                 **                                  The leak detection instrumentation associated with the main steam lines, the Reactor Water Cleanup system, and the Residual Heat Removal system is also discussed in CPS USAR Sections 7.3.1.1.2.4.1.3, 7.3.1.1.2.4.1.10, and 7.3.1.1.2.4.1.11, respectively.

    '                                                           Attcchment 2 g
U-601837 LS-89-007 i
page 5 of 26 the cooling water inlet and outlet of the respective area coolers. These monitors have sensitivities suitable for detection of reactor coolant leakage into the monitored areas of 25 gpm (steam equivalent) or less. The actual temperature trip setpoints are a function of room size and the type of ventilation provided.
In addition to temperature monitoring, excess leakage external to the containment can be detected by low reactor water level, high process line flov, and high differential flow. The leakage detection methoas used at CPS are summarized on CPS USAR Tables 5.2-9a and 5.2-9b. As can be seen from these tables, two or more leakage detection systems are available for each system or area that is a potential source of leakage. Further, accessible areas          are inspected periodically, and the temperature and flow indications are monitored regularly. Any instrument indication of abnormal leakage is investigated.
Each of these proposed changes only affects the trip setpoint and/or allowable value for each of the associated instruments and does not physically modify the affected system's components, function, or redundancy. In determining the impact of the proposed Technical Specification changes, IP has evaluated the effect of changing the setpoints and/or allowable values on the continued capability of the instrumentation to detect and respond to a 25-gpm equivalent steam Icak condition. The proposed trip setpoint changes have also been reviewed to ensure that they do not result in spurious isolations during normal plant operation.         Additionally, the proposed allowable values have been verified to limit area temperatures such that the qualification of safe-shutdown equipment located in the associated areas is not adversely impacted by these proposed changes. Further, a 25-gpm equivalent steam leak is well within the makeup capability of any one of the emergency core cooling systems.
The proposed trip setpoints and allowable values have been established in accordance with the methodology of Regulatory Guido 1.105, " Instrument Setpoints." Accordingly, each proposed change is supported by calculations that include instrument accuracy, calibration uncertainties, and drift allowance during the 18-month calibration interval. This supports the intent for those intruments to automatically effect the associated isolations when the associated parameter exceeds a certain value or limit. In all cases, calculations demonstrate that a 25-gpm (equivalent) steam leak will be isolated within ten minutes.
: 1. Item 1.k. Primary and Secqndary Containment Isolation, Containment Pressure - Hiah Pressure instruments IPY-VG145 and 1PY-VG147 are provided for the purposes of monitoring primary to          ,
I secondary containment differential pressure and providing a permissive to open the containment

Attechmsnt 2 g                                                                                                                                                                              U-601837
                           -                                                                                                                                                      LS-89-007 Page 6 of 26 ventilation supp1*/ and exhaust isolation bypass valves (1VR002A,D and IVQOO6A,B) when the Standby Gas Treatment System (SGTS) is used as a backup to the drywell purge system in the post - Loss-of-Coolant-Accident (post-LOCA) containment purge mode. If these valves are open and tne setpoint is exceeded, the opening permissive for these valves would no longer be satisfied and, in this case,                             o high-pressure trip signal acts as an isolation s.gnal to close these valves. These valves are required to be locked closed                                                                         ;
during all plant operational modes per Technical                                                                             i specification 3.6.4, " Containment Isolation Valves."***
The setpoint for these pressure relays is based upon preventing opening of these valves when excessive differential kisssure could result in damage to the associated ductwork.                                                                                                         j The trip setpoint for these pressure relays has been lowered in the conservative direction from s 2.62 to s 2.56 psid.                 The allowable value                                        was unaffected and is                  l being maintained at 5 3.00 psid.                                                                                              1 This proposed change is in the conservative direction.
As a result, the affected pressure instrumentation will still provide the permissive only when allowed and will still ensure that the noted valves automatically close prior to containment pressure exceeding the design limits of the associated ductwork. Additionally, during normal plant operating conditions, primary ontainment to secondary containment differential pressure is required to be maintained between -0.25 psid and +0.25 paid per cps Technical Specification 3.6.1.6. This differential pressure is well below the proposed trip setpoint of 5 3.56 psid. Therefore, this proposed change will not result in spurious isolations                                                                      ,
from these instruments during normal plant operation.
(Notwithstanding, as previously statad, the noted valves are required te be maintair J in tne locked-closed position during plant operai 'on.)
With respect to any impact on use of the SGTS as a backup purge method during post-LOCA conditions, lowering the setpoint by 0.06 psid will not pose any significant restriction on use of the system in this manner.. Notwithstanding, use of this operating configuration is not required for maintaining the plant in a. safe shutdown condition as it is only intended to provide additional operating flexibility as a backup or optional means of purging.
                               ***                                    Except when opencd under administrative control to support or perform surveillance testing and during Mode 5 when no core alterations or operations with a potential to drain the reactor vessel are being performed and there is no handling of irradiated fuel within the secondary containment in progress.

1 Attachmont 2 U-601837 y
                                                    -                                                               LS-89-007 Page 7 of 26
: 2. Main Steam Line Isolation The CRVICS monitors tha following parameters in order to offect main steam line isolation:
: a. Reactor Vessel - Low Water Level,
: b. Main Steam Line - High Radiation,
: c. Main Turbine Inlet - Low Steam Pressure,
: d. Main Steam Line - High Flow,
: e. Main condenser - Vacuum Trip,
: f. Main Steam Line Pipe Tunnel Area - High Temperature and Differential Temperature,
: g. Turbine Building - Area Temperature, and
: h. Manual Initiation.
The proposed changes for the Main Steam Line Isolation i                                                          instruments only affect the trip setpoints and/or l                                                          allowable values of the Main Steam Line Pipe Tunnel i                                                          Area - High Temperature and Differential Temperature                                                         ,
and Turbine Building - Area Temperature CRVICS functions.             Each of the proposed changes to these Main Steam Line Isolation functions is discussed below,
: a. Item 2.f.           Main Steam Line Tunnel Tomo. - Hiah This function is provided for the purposes of detecting and isolating a 25-gpm equivalent steam leak in the main steam lines in the main steam tunnel. Trip units 1E31-N604A,B,C, and D monitor the ambient temperature in the main steam tunnel.
When the ambient temperature reaches a preset limit corresponding to a 25-gpm tequivalent) steam leak, these instruments initiate automatic closure of the main steam lines and drains.
The trip setpoint for these ambient temperature trip units has been lowered from i 165'F to 5 156*F. The allowable value has also been lowered from i 176*P to 5 171'F.
The proposed changes are in the conservative direction with respect to the leak detection design basis. The proposed trip setpoint of
                                                                $ 156*F is based on a design calculation which demonstrates-that the-proposed allowable value of 5 171'F is still less than or equal to the conservatively calculated main steam tunnel ambient temperature corresponding to a 25-gpm equivalent steam leak in the area with the ventilation system in operation. With respect to operating margin, the proposed trip setpoint of
                                                                $ 156*F remains above the maximum expected main steam tunnel ambient temperature of 148'F during normal operating conditions. As a result, these proposed changes will not result in spurious isolations from these instruments.

Attachmsnt 2 g                                                                      U-601837
               .                                                             LS-89-007 Page 8 of 26 Further, the worst case temperature for which safe-shutdown components located in these main steam tunnel areas are qualified is 275'F. The proposed allowable value of 5 171'F will still ensure that a .i.-gpm equivalent steam leak is isolated in sufficient time to ensure that the qualification of safe-shutdown components in these areas is not adversely affected.                                            I I
: b. Item 2.0. Main Steam Line Tunnel Delta Tenn.            -
J11ah Similar to item 2.f above, this function is also provided for the purposes of detecting and isolating a 25-gpm equivalent steam leak in the main steam lines in the main steam tunnel. Trip units lE11-N605A,B,C, and D monitor the temperature rise across the water side of the unin steam tunnel area cooling coils. When the differential temperature across the coils reaches a preset limit corresponding to a 25-gpm (equivalent) steam leak, these instruments initiate automatic closure of the main steam lines and drains.
The trip setpoint for these differential temperature trip units was unaffected and is being maintained at S 54.5'F. The allowable value has been increased from 5 60*F to n 63'F.
This proposed change is based on a design calculation which demonstrates that the proposed allowable value of 5 63'F is still less than or equal to the conservatively calculated main steam tunnel area cooling coil differential temperature corresponding to a 25-gpm equivalent steam leak in the area with the ventilation system in operation.
Additionally, because the trip setpoint of 5 54.5'F is unchanged and remains above the maximum expected main steam tunnel area cooling coil differential temperature of 20*F during normal-operating conditions, this proposed change will not increase the potential for spurious isolations from these instruments.
: c. Item 2.h (1) . Main Sigam Line Turbine Bldu. Temp.                   -
Hiah; 1E31-N559AtB.C.D. 1E31-N560A.B.C.D.
3E31-N561A.B.C.D. 1E31-N562A.B.C.D This function is provided for the purposes of detecting and isolating a 25-gpm equivalent steam leak in the main steam lines in the turbine building. Trip units 1E31-N559A,B,C,D; 1E31-N560A,B,C,D; 1E31-N561A,B,C,D; and lE31-N562A,B,C,D monitor the Turbine Building ambient' temperature in the vicinity of the main turbine. When the ambient temperature reaches a
* Attech::nt 2 g                                                                       U-601837 LS-89-007 Page 9 of 26 preset limit corresponding to a 25-gpm (equivalent) steam leak, these instruments initiate an automatic closure of the main steam lines and drains.
The trip setpoint for those ambient temperature trip units was unaffected and is being maintained
_                                    at 5 131.2'F. The allowable value has been            i increased from s 138'F to 5 142'F.
This proposed change is based on a design             I calculation which demonstrates that the proposed allowable value of 5 142'F is still less than the conservatively calculated turbine building ambient temperature corresponding to a 25-gpm equivalent I                                      steam leak in the area with the ventilation system in operation. Additionally, because the trip          l setpoint of 5 131.2'F is unchanged and remains        !
above the maximum expected local Turbine Building operating temperature which has been observed to      l be as high as 110*F during normal operating           1 conditions, this proposed change will not increase    i the potential for spurious isolations from these      !
instruments.
Further, the worst case temperature for which safe-shutdown components located in these Turbine Building areas are qualified is 250*F. The proposed allowable value of s 142*F will Lcill i
ensure that a 25-gpm equivalent steam leak is i
isolated in sufficient time to ensure that the qualification of safe-shutdown components in these areas is not adversely affected.
: d. Item 2.h(2). Main Steam Line Turbine Blda. Temp.    -
l                                      Hight 1E31-N563A.B.C.D Similar to item 2.h(1) above, this function is
;                                      also provided for the purposes of detecting and isolating a 25-gpm equivalent steam leak in the main steam lines in the Turbine Building. In this case, trip units 1E31-N563A,B,C, and D monitor the Turbine Building ambient temperature in the vicinity cf the main turbine near the main steam L                                      mixing header. When the ambient temperature I
reaches a preset limit corresponding to a 25-gpm (equivalent) steam leak, these instruments
                                      -initiate automatic closure of the main steam lines and drains.
The trip setpoint for these ambient temperature trip units has been lowered from S 143.2*F to
                                      $ 139.5'F. The allowable value was unaffected and is being maintained at 5 150*F.

Attechment 2 g                                                                                     U-601837
           -                                                                             LS-89-007 Page 10 of 26 This proposed change is in the conservativo direction with respect to the leak detection design basis. Since the allowable value of
                           $ 150*F for these instruments has not been changed, it remains below the conservatively calculated Turbine Building temperature corresponding to a 25-gpm equivalent main steam line leak in the Turbine Building with the ventilation system in operation. With respect to operating margin, the proposed trip setpoint of
                           $ 139.5'F remains above the local Turbine Duilding operating temperature which has been observed to be as high as 127'F. As a result, this proposed change will not result in spurious isolations from                                 ;
these instruments.
Further, the worst case temperature for which safe-shutdown components located in these Turbine Building areas are qualified is 250'F.                           The c.11owable value, which has been maintained at s 150*F, will still ensure that a 25-gpm equivalent steam leak is isolated in sufficient time to ensure that the qualification of safe-                                     ,
shutdown components in these areas is not adversely affected.
: 3. Reactor Water Cleanuo Evstem Isolation The CRVICS monitors the following parameters in order to effect Reactor Water Cleanup (RWCU) system isolation:
: a. RWCU System Differential Flow - High (and its associated timer),
: b. RWCU Equipment Area - High Temperature and
                           -Differential Temperature (Pump Rooms and Heat Exchanger Rooms),
c.-    Reactor Vessel - Low Water Level,
: d. Main Steam Line Pipe Tunnel Area - High Temperature and Differential Temperature,
: e.      Standby Liquid Control System Initiation, and
: f.      Manual Initiation.
The proposed changes for the_RWCU system isolation instruments only affect the trip setpoints and/or allowable values of the RWCU Equipment Area - High Temperature and Differential Temperature and the Main Steam ~Line Pipe Tunnel Area - High Temperature and Differential Temperature CRVICS functions. Each of the proposed changes to these RWCU system isolation                                            '
functions is discussed below.
l l'
l i                                                                                                      . . -

i                                                                                                                                                                            Attachmont 2 U-601837
(
                                                                      .                                                                                                                                                                LS-89-007 Page 11 of 26
: a. Item 3.c.1. Eauipment                              Area Temo. - Hicht Pump Rooms - A.B.C This function is provided for the purposes of detecting and isolating a 25-gpm equivalent steam leak in the RWCU system pump rooms. Trip units lE31-H621A,B,E,F and lE31-N622A and B monitor the ambient temperature in these rooms. When the ambient temperature reaches a preset limit corresponding to a 25-gpm (equivalent) steam Icak, these instruments initiate automatic closure of the RWCU suction and return line containment isolation valves.
The trip setpoint for these ambient temperature trip units was unaffected and is being maintained at 5 186.5'F.      The allowable value has been increased from 5 197.l'F to 5 202'F.
This proposed change is based on a design calculation which demonstrates that the proposed allowable value of 5 202*F is still less than the conservatively calculated RWCU pump room ambient temperature corresponding to a 25-gpm equivalent steam leak in the area with the ventilation system in operation.      Additionally, because the trip setpoint of 5 186.5'F is unchanged and remains above the maximum expected RWCU pump room ambient temperature of 104'F during normal operating conditions, this proposed change will not increase-the potential for spurious isolations from these instruments.
Further, the worst case temperature for which safe-shutdown components in the RWCU pump rooms are qualified is 212'F. The proposed allowable value of 5 202'F will still ensure that a 25-gpm equivalent steam leak is isolated in sufficient time to ensure that the qualification of safe-shutdown components in these areas is not adversely affected.
: b. Item 3.c.2. Eculement Area Temp. - Hiahr Heat Exchanner Rooms - East. West This function is provided for the-purposes of
                                                                                                       -detecting and isolating a 25-gpm equivalent steam leak in the RWCU heat exchanger rooms.                                                                                                Trip units 1E31-N620A,B, and 1E31-N626A and B monitor the ambient temperature in these rooms. When the ambient temperature reaches a preset limit corresponding to a 25-gpm (equivalent) steam leak, these instruments initiate automatic closure of the RWCU suction and return line containment isolation valves.
* Attcchm:nt 2 I
g U-601837
      .                                                                          LS-89-007 Page 12 of 26 The trip setpoint for these ambient temperaturo trip units has been lowered from 1 201*F to s 190'F. The allowable value has also been lowered from $ 212'F to s 205'F.
These proposed changes are in the conservativo direction with respect to the leak detection design basis. The proposed trip setpoint of 5 190'F is based on a design calculation which demonstrates that the propoced allowable value of 5 205'F is still less than or equal to the conservatively calculated RWCU heat exchanger room ambient temperature with a 25-gpm equivalent steam leak in the arua with the ventilation system in operation. With respect to operating margin, the proposed trip setpoint of 5 190*F remains above the maximum expected RWCU heat exchanger room ambient temperature of 122*F during normal operating conditions. Therefore, these proposed changes will not result in spurious isolations from these instruments.
Additionally, the worst case temperature for which safe-shutdown components in the RWCU heat exchanger rooms are qualified is 225'F. The proposed allowable value of 5 205'F will still ensure that a 25-gpm equivalent steam leak is isolated in sufficient time to ensure that the qualification of safe-shutdown components in those areas is not adversely affected.
: c. Item 3.d.1. Eauipment Area Delta Temo. - Hich; Pump Rooms - A.B.C Similar to item 3.c.1 above, this function is also provided for the purposes of detecting and isolating a 25-gpm equivalent steam leak in the RWCU pump rooms. Trip units 1E31-N613A,B,E,F, and 1E31-N614A and B monitor the temperature rise across the water side of the RWCU pump room area cooling coils. When the differential temperature across the coils reaches a preset limit corresponding to a 25-gpm equivalent steam leak, these instruments initiate automatic closure of the RWCU suction and return line containment isolation valves.
The trip setpoint for these differential temperature trip units was unaffected and is being maintained at 5 54.5'F. The allowable value has been increased from 5 60'F to $ 63'F.
This proposed change is based upon a design calculation which demonstrates that the proposed allowable value of 5 63*F is still less than or                             ,
equal to the conservatively calculated RWCU pump                            l room cooler differential temperature with a 25-gpm

a                                                                                Attachment 2 U-G01837 s
LS-89-007 Page 13 of 26 equivalent steam leak in the area and with the ventilation system in operation.                                    Additionally, because the trip setpoint of 1 54.5'F is unchanged and remains above the maximum expected RWCU pump room cooler differential temperature of 16*F during normal operating conditions, this proposed change will not increase the potential for spurious isolations from these instruments.
: d. Item 3.d.2. Ecuinment Area Delta TeID. - Hichi Heat Exchqnger Rooms - East. WeEt Similar to item 3.c.2 above, this function is also provided for the purposes of detecting and isolating a 25-gpm equivalent steam leak in the RWCU heat exchanger rooms.                                   Trip units lE31-N612A,B, and lE31-N618A and B monitor the temperature rise across the water side of the RWCU heat exchanger room area cooling coils. When the differential temperature across the coils reaches a preset limit corresponding to a 25-gpm (equivalent) steam leak, these instruments initiate automatic closure of the RWCU suction and return line containment isolation valves.                                            p The trip setpoint for these differential temperature trip units was unaffected and is being maintained at 5 54.5'F. The allowable value has been increased from 5 60*F to s 63*F.
This proposed change is based on a design calculation which demonstrates that the proposed allowable value of 5 63'P is still less than or equal to the conservatively calculated RWCU heat exchanger room cooler differential temperature with a 25-gpm equivalent steam leak in the area and with the ventilation system in operation.
Additionally, because the trip setpoint of 5 54.5'F is unchanged and remains above the maximum expected RWCU heat exchanger room cooler differential temperature of 23*F during normal operating conditions, this proposed change will not increase the potential for spurious isolations from these instruments.
Item 3.f. Main _ Steam Line Tunnel Ambient Temp.
e.
ll19h Similar to item 2.f above, this function is provided for the purposes of detecting and isolating a 25-gpm equivalent steam leak in the RWCU system piping in the main steam tunnel.                                   As described in item 2.f above, trip units lE31-N604A and B monitor the ambient temperature in the main steam tunne).                                 When the ambient temperature reaches a preset limit corresponding to a 25-gpm (equivalent) steam leak, these instruments also

     -                                                             Attcchment 2 g
U-601837 l
LS-89-007 l                                                                  page 14 of 26 initiate automatic closure of the RWCU suction and return line containment isolation valves.
As described in item 2.f above, the trip setpoint for these ambient temperature trip units has been lowered from s 165'F to 5 156'F. The allowable value has also been lowured from 5 176'F to 5 171*F.
These proposed changes are in the conservative direction with respect to the leak detection design basis. The proposed trip setpoint of s 156*F is based on a design calculation which demonstrates that the proposed allowable value of 5 171*F is still less than or equal to the conservatively calculated main steam tunnel ambient temperature with a 25-gpm equivalent steam leak in the area and with the ventilation system in operation. With respect to operating margin, the proposed trip setpoint of s 156*F remains above the maximum expected main steam tunnel ambient temperature of 148'F during normal operating conditions. as a result, these proposed changes will not result in spurious isolations from these instruments.
Further, the worst case temperature for W11ch safe-shutdown components in these main steam tunnel areas are qualified is 275'F.                    The proposed allowable value of s 171'F will still ensure that a 25-gpm equivalent steam leak is isolated in sufficient time to ensure that the qualification of safe-shutdown components in these areas is tut adversely affected,
: f. Item 3.0.               Main Steam Line Tunnel Delta Temn.  -
Hish Similar to items 2.g and 3.f above, this function is also provided for the purposes of detecting and isolating a 25-gpm equivalent steam leak in the RWCU system piping in the main steam tunnel. As described in item 2.g above, trip units 1E?l-605A and B monitor the temperature rise across the water side of the main steam tunnel area cooling coils.                When the differential temperature across the coils reaches a praset limit corresponding to a 25-gpm (equivalent) steam leak, these instruments also initiate automatic closure of the RWCU suction and return line containment isolation valves.
As described in item 2.g above, the trip setpoint for these differential temperature trip units was unaffected and is being maintained at 5 54.5*F.
The allowable value has been increased from 5 60*F                 I to 1 63*F.

e                                                            Attachment 2 z.
U-601837
  #-                                                              LS-89-007 Page 15 of 26 This proposed cnange is based on a design calculation which demonstrates that the proposed allowable valus cr s o3*P remains less than or equal to the conserv-*ively calculated main steam tunnel cooler offfoto..c231 temperature-with a 25-opm et uivalzat steam leak in the area and with the ventilation sy.t?m in operation.
Additionally, because the trip setpoint of r                            5 54.5'F is unchanged and remains above the expected main steam tunnel cooler differential temperature of 20'F during normal operating conditions, this proposed change will not increase the potential for spurioas isolations from these     ;
instruments.                                         l 1
: 4.  .Peactor Core. Isolation Joolina System Isolation The CRVICS monitors the following parameters in order to effect Reactor Core Isciation Cooling (RCIC) system isolation:                                                 j
: a. RCIC System flow - High (and its associated timer),
: b. RCIC Steam Supply Pressure - Low,
: c. RCIC Turbinc *:xhaust Diaphragm Pressure - High,
: d. ROIC Equipmv c Room - High Temperature and Differential Temperacure,                            1
: e. Main Steam Line Pipe Tunnel Area - High Temperature (and its associated timer) and Differential Temperature,
: f. Drywell Pressure - High,
: g. Manual Initiation, h.-   RHR/RCIC Steam Line Flow - High, and
: i. RHh Heat Exchanger Area - High Temperature and Differential Temperature.
The proposed changes for the RCIC system isolation instruments only affect the trip setpoints and/or allowable values of the RCIC Equipment Room, Main Steam Line Pipe Tunnel, and PHR Heat Exchanger - High
* Temperature and Differential Temperature CRVICS
                      -functions. Each of the proposed changes to these RCIC system isolation functions is discussed below,
: a. Itap_f.e. RCIC Equipment Room Ambient Temo. - Hiah This function is provided for the purposes of detecting and isolating a 25-gpm equivalent stram leak in the RCIC equipment rooms. Trip units 1E31-N602A and B nonitor the ambient temperature in these rooms. When the ambient temperature reaches a preset limit corresponding te a 25-gpm (equivalent) steam leak, these instruments initiate automatic closure of the RCIC suction and steem supply line containment isolation valves.
* Attechment 2 U-601837 i        .                                                                LS-89-007 Page 16 of 26 The trip setpoint for these ambient temperature trip units has been lowered from $ 222.5'F to 5 192'F. The allowable value has also been lowered from 5 233.1'F to 1 207'F.
These proposed changes are in the conservative direction with respect to the leak detection design basis. The proposed trip setpoint of 5 192*F is I sed on a design calculation which demonstrates that the proposed allcwable value of 5 207'F is still less than or equal to the conservatively calculated RCIC equipment room ambient temperature with a 25-gpm equivalent steam leak in the area and with the ventilation system in operation. With respect to operating margin, the proposed trip setpoint of 5 192*F remains above the maximum expected RCIC equipment room ambient temperature of 145'F during normal shutdown conditions (the maximum expected RCIC equipment room ambient tamperature during normal operating conditions is 108'F).                       As a result, these proposed changes will not result in spurious isolations frou these instruments.
Further, the worst case temperature for which safe-shutdown components in the RCIC equipment rooms are qualified is 250'F.                       The proposed allowable value of s 207'F will still ensure that a 25-gpm equivalent steam leak is_ isolated in sufficient time to ensure that the qualification of safe-shutdown components in these areas ir not adversely affected,
: b. Item 4.f. RCIC Eculoment Room Delta Temp. - Hioh Similar to item 4.e above, this function is also provided for the purposes of detecting and isolating a 25-gpm equivalent steam leak in the RCIC equipment rooms. Trip units 1E31-N603A and B monitor the temperature rise across the water side of the RCIC equipment room area cooling coils.
When the differential temperature across the coils reaches a preset limit corresponding.to a 25 gpm (equivalent) steam leak, these instruments initiate automatic closure of the RCIC suction and steam supply line containment isolation valves.
The trip setpoint ror these differential temperature trip units was unaffected and is being maintained at 5 34.5'F. The allowable value has been increased from 5 40*F to 5 43*F.
This proposed change is based on a design calculation which demonstrates that the proposed allowable value of 5 43*F is still less than or equal to the conservatively calculated RCIC equipment room cooler differential temperature
* Attachment 2
.s U-601837 LS-89-007 Page 17 of 26 with a 25-gpm equivalent steam leak in the area and with the ventilation system in operation.
Au.itionally, because the trip setpoint of s 34.5'F is unchanged and remains above the expected maximum RCIC equipment room cooler differential temperature of 12*F during normal operating conditions, this proposed change will not increase the potential for spurious isolations from these instruments.
Item 4.a. Main Steam Line Tunnel Ambient Temp.
c.
High                                                                 ,
Similar to items 2.f and 3.f above, this function is provided for the purposes of detecting and                      -
isolating a 25-gpm equivalent steam leak in the RCIC steam supply piping in the main steam tunnel.
Trip units 1E31-N604E and F also monitor the ambient temperature in this area. When the ambient temperature reaches a precet limit corresponding to a 25-gpm (equivalent) steam leak,             4 1
these instruments initiate automatic closure of                I)    "
the RCIC suction and steam supply line containment isolation valves.
As identified in items 2.f and 3.f above, the trip setpoint for these ambient temperature trip units has been lowered from i 165'F to $ 156*F. The allowable value has also been lowered from s 176*F              ,
to 5 171*F.                                                     .
These proposed changes are in the conservative direction with respect to the leak detection design basis. The proposed trip setpoint of                      -
5 156*F is based on a design calculation which demonstrates that the proposed allowable value of 5 171*F is still less than or equal to the conservatively calculated main steam tunnel ambient temperature with n 25-gpm equivalent steam leak in the area and with the ventilation system in operation. With respect to operating margin, the proposed trip setpoint of $ 156*F remains above the expected maximum main steam tunnel ambient temperature of 148'F during normal operating conditions. As a result, these proposed changes will not result in spurious isolations from these instruments.
Further, the worst case temperature for which safe-shutdown components in these main sta.am tunnel areas are qua.ified is 275'F. The proposed allowable value of 5 171*F will still ensure that a 25-gpm equivalent steam leak is isolated in sufficient time to ensure that the qualification of safe-shutdown components in these areas is not adversely affected.

o
       '                                               Attachment 2 U-601837
{        .
LS-89-007 Page 18 of 26
: d. Item 4.h    Main Steam 1,ine Tunnel Delta Tomo.   -
Hiqh Similar to item 4.g above, this function is also provided for the purposes of detecting and isolating a 25-gpm equivalent steam leak in the RCIC steam cupply piping in the main steam tunnel.
Trip units lE31-N605E and F monitor the temperature rise across the water side of the main steam tunnel area cooling coils. When the differential temperature across the coils reaches a preset limit corresponding to a 25-gpm (equivalent) steam leak, these instruments initiate automatic closure of the RCIC suction and steam supply line containment isolation valves.
The trip setpoint for these differential temperature trip units was unaffected and is being maintained at 5 54.5'F. The allowable value has been increased from 5 60*F to S 63*F.
This proposed change is based on a design calculation which demonstrates that the proposed allowable value of 5 63*F is still less than or egaal to the conservatively calculated main steam tunnel cooler differential temperature with a 25-gpm equivalent steam leak in the area and with the ventilation system in operation. Additionally, because the trip setpoint of 5 54.5*F is unchanged and remains above the maximum expected main steam tunnel cooler differential temperature of 20*F during normal operating conditions, this proposed change will not increase the potential for spurious isolations from these instruments.
: e. Item 4 m. kHR Heat Excbancer A. B. Ambient Temperature - Hiah This function is prosided for the purposes of detecting and isolating a 25-gpm equivalent steam leak in the RHR heat exchanger rooms. Trip units 1E31-N608A,B, and 1E31-N610A and B monitor the ambient temperature in these rooms. When the ambient temperature reaches a preset limit corresponding to a 25-gpm (equivalent) steam leak, these instruments initiate automatic closure of the RCIC suction and steam supply line containment isolation valves.
The trip setpoint for these ambient temperature trip units has been increased from s 138.5'F to s 144.5'F. The allowable value has also been increased from 5 149.6*F to s 160*F.
The proposed trip setpoint of $ 144.5'F is based on a design calculation which demonstrates that          j the proposed allowable value of s 160*F is still
* Attachment 2
        ~       '
U-601837 LS-89-007 page 19 of 26 less than the conservatis21y calculated RdR heat exchanger room ambient temperature with a 25-gpm equivalent steam leak ir. the area and with the
: 5)                     ventilation system in operation.                          With recpect        to operating margin, the proposed trip setpoint of
                       $ 144.5 is (             the maximum expected RER heat exchanger rc            abient temperature of 140
* F during normal shutdo.          conditions (the maximum expected RHR heat exchanger room ambient temperature during normal operating conditions is 104*F). Since the proposed trip setpoint is higher than the current setpoint, these proposed changes will reduce the potential for spurious isolations from these instruments.
Further, the worst case temperature for which safe-shutdown components in the RHR heat exchanger rooms are qualified is 250*F.                         The proposed allowable value of 5 160"F will still ensure that a 25-gpm equivalent steam leak is isolated in sufficient time to ensure that the qualification of safe-shutdown components in these areas is not adversely affected.
: f. Item 4.n. RHR Heat Exchancer A,                        B. Delta Temo. -
Hiqh Similar to item 4.m above, this function is also provided for the-purposes of detecting and isolating a 25-gpm equivalent steam leak in the RHR heat exchanger rooms. Trip units 1E31-N600A,B, and 1E31-N611A and B monitor the temperature rise across the water side of the RHR heat exchanger .Jom area cooling coils. When the differential temperature across the coils reaches a preset limit corresponding to a 25-gpm (equivalent) steam leak, these instruments initiate automatic closure of the RCIC suction and steam supply line containment isolation valves.
t The trip setpoint for these differential temperature trip units has been lowered from s 74.2*F to 5 71.9'F. The allowable value was unaffected and is being maintained at i 79.6*F.
This proposed change is in the conservative direction with respect to the leak detection cesign basis. The proposed trip setpoint or s 71.9'F is based on a design calculation which demonstrates that the unchanged allowable value of
                         $ 79.6*F remains less than or equal to the conservatively calculated RHR heat exchanger room cooler differential temperature with a 25-gpm equivalent steam leak in the area and with the ventilation system in operation.                         With respect to operating margin, the proposed trip setpoint of
                          $ 71.9'F remains above the maximum expected RHR

s
* Attachment 2 U-601837 LS-89-007 Page 20 of 26 heat-exchanger room cooler differential temperature of 13*F during normal operating conditions. As a result, this proposed change will not result in spurious isolations from these instruments.
: 5. BUR E Stem Isolat1QB The CRVICS monitors the following parameters in order to effect RUR system isolation:
: a. RHR Heat Exchanger Rooms - High Temperature and Differential Temperature,
: b. Reactor Vessel - Low Water Le"el,
: c. Reactor Vessel - High Pressure,
: d. Drywell - High Pressure, and
: c. Manual Initiation.
The proposed changes for the RHR system isolation instruments only affect the RHR Heat Exchanger Rooms -
High Temperature and Differential Temperature CRVICS functions. Each of the proposed changes to these RHR system isolation functions is discussed below,
: a. Item 5.a. RHR Heat Exchancer Rggms A.             B. Ambient Temnerature - lii.gh Identical to item 4.m above, this function is provided for the purposes of Octocting and isolating a 25-gpm equivalent steam leak in the RHR heat exchanger rooms.              As described in item 4.m above, trip units 1E31-N608A,B, and 1E31-N610A and B monitor the ambient temperature in these rooms. When the ambient temperature increases to a preset limit corresponding to a 25-gpm (equivalent) eteam leak, these instruments also initiate automatic closure of the RHR return-to-feedwater, shutdown cooling suction, fuel pool cooling assist, and reactor vessel head spray line containment isolation valves.
As described in item 4.m above, the trip setpoint for these ambient temperature trip units has been increased from 5 118.5*F to i 144.5'F. The allowable value has also been increased from
                         $ 149.6*F to 5 160*F.
The proposed trip setpoint of i 144.5'F s based on a design calculation which demonstrat s that the proposed allowable value of 5 1r6*F is still less than the conservatively calcalated RHR heat exchanger room ambient temperature with a 25-gpm equivalent steam leak in the aren and with the ventilation system in operat;.on.            Wite respect to operating margin, the proposed trip setpoint of
                          $ 144.5*F is above the maximum expected RHR heat exchanger room ambient temperature of 140*F during

Attcchment 2 v<                                                     U-601837
         .-                                              LS-89-007 Page 21 of 26 normal shutdown conditions (the maximum expected RHR heat exchanger room ambient temperature during nor. sal operating conditions is 104 'F) . Since the proposed trip setpoint is higher than the current setpoint, these proposed changes will reduce the potential for spurious isolations from these instruments.
Further, the worst case temperature for which           l safe-shutdown components in the RHR heat exchani,       j rooms are qualified is 250'F. The proposed              I allowable value of $ 160*F will still ensure that       !
a 25-gpm equivalent steam leak is isolated in           I sufficient time to ensure that the qualification of safe-shutdown components in these areas is not       ;
adversely affected.                                     !
i                                                                        !
: b. Item 5.b. RHR Heat Exchanner Rooms A,      B. Delta Temocrature - Hich Identical to item 4.n above and similar to item 5.a above, this function is also provided for the purposes of detecting and isolating a 25-gpm equivalent steam leak in the RHR heat exchanger rooms. As described in item 4.n above, trip units 1E31-N600A,B, and 1E31-N611A and B monitor the temperature rise across the water side of the RHR heat exchanger room area cooling coils.       When the differential-temperature across the coils reaches a preset limit corresponding to a 25-gpm (equivalent) steam leak, these instruments also initiate automatic closure of the RHR return-to-feedwater, shutdown cooling = suction, fuel pool cooling assist, and reactor vessel head spray line containment isolatien valves.
As described in item 4.n above, the trip setpoint for these differential temperature trip units has been lowered from 5 74.2'F to 5 71.9'F. The allowable value was unaffected and is being maintained at i 79.6**.
This proposed change is in the conservative direction with respect to the leak detection design basis. The proposed trip setpoint of
                 $ 71.9'F is based on a design calculttion which demonstrates that the unchanged allowable value of
                 $ 79.6*F remains less than or equal to the conservatively calculated RHR heat exchanger room cooler differential temperature with a 25-gpm equivalent steam leak in the area and with the          '
ventilation system in operation.      With respect    -
operating margin, the proposed trip setpoint of 1 71.9'F remains above the maximum expected RHR heat exchanger room cooler differential temperature of 13'F during normal operating conditions. As a result, this proposed change           !
i
* Attachment 2
.o
   #_
* U-601837 LS-89-007 Page 22 of 26 will not result in spurious isolations from these inctruments.
Basis For No Sinnificant Hazards Consideration
          -     In accordance with 10CFR50.92, a proposed change to the ope ating license (Technical Specifications) involves no significant hazards considerations if operation of the facility in accordance with the proposed change would not:
(1) involve a significant increase in the probability or consequences of any accident previously evaluated, or (2) creata the possibility of a new or different kind of accident from any accident previously evaluated, or (3) involve a significant reduction in a margin of safety. The proposed changes are evaluated against each of these criteria below.
: 1)    Although this request involves changes to the trip setpoint s and/or allowable values for certain CRVICS instruments, the safety bases for these setpoints have not been changed, and design calculations have been performed which demonstrate that the proposed setpoints still support the applicable safety bases. That is, for the proposed changes to allowable values, the design calculations demonstrate that the associated automatic isolations will still occur when required such that detection of and automatic isolation in response to a 25-gpn equivalent steam leak will occur as intended (and in all cases, within 10 minutes). The proposed setpoints will also continue to ensure that, in the event of a leak, temperatures do not exceed the environmental qualification temperature limits for safe-shutdown equipment located in the associated areas. Moreover, the proposed setpoints are supported by calculations which include instrument accuracy, calibration uncertainties and drift allowances during the time intervals between calibration. These proposed changes have also been reviewed to ensure that they do not result in spurious isolations during normal operating conditions. Therefore, these proposed changes will not increase the probability or the consequences of any accident previously evaluated.
: 2)    The proposed changes only involve changes to trip setpoints and/or allowable values for the affected instruments,   toese proposed changes do not physically modify any existing system components, do not change the functional requirements of any system's components, nor do tuey affect existing e stem redundancy or failure analysis. Consequen u.y , no new failure modes are introduced by the proposed changes. Therefore, these proposed changes cannot create the possibility of a new or different kind of accident from any accident previously evaluated.
: 3)    The proposed changes establish new instrument trip setpoints and/or allowable values to support an
* Attachment 2 U-601837 l         ,
:                                                                LS-89-007 I                                                                            Page 23 of 26 18-month (rather than a 6-month) calibration fruquency.-
While new instrument setpoints have been established which impact the automatic actuation points for affected instruments and equipment, these trip setpoints and allowable values have been established to account for the effects of increasing the calibration interval. The proposed trip setpoints and allowab3e values have been established in accordance with the methodology of Regulatory Guide 1.105. Accordingly, each proposed change is supported by calculations that include instrument accuracy, calibration uncertainties, and drift allowance during the 18-month calibration inte rval . By this methodology, trip setpoints and allowable values are established to ensure that an appropriate margin of safety is maintained and that the applicable automatic actions occur when intended or assumed by the applicable safety analyses.                 Further, the proposed changes have been reviewed to ensure that they will not result in spurious isolations and that they continue to limit area temperatures such that the qualification of safe-shutdown equipment located in the associated areas is not adversely impacted.                Therefore, theco proposed changes will not result in a significant reduction in the margin (s) of safety.
Based upon the foregoing, IP concludes that these proposed changes do not involve a significant hazards conrideration.
L
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