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Proposed Conversion to ITSs for Chapter 3.3
	ML20207D642
Person / Time
Site:	Farley
Issue date:	05/31/1999
From:	; SOUTHERN NUCLEAR OPERATING CO.
To:	;
Shared Package
ML20207D618	List: L-99-021, Forwards Response to RAI Re Conversion to ITSs for Chapter 3.3.Attachment II Includes Proposed Revs to Previously Submitted LAR Re Rais,Grouped by RAI number.Clean-typed Copies of Affected ITS Pages Not Included; ML20207D642;
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{{#Wiki_filter:FNP TS Conversion Enclosure 3 - Significant Hazards Evaluations Chapter 3.3 - Instrumentation III. SPECIFIC SIGNIFICANT HAZARDS EVALUATIONS CTS 2.2 LIMITING SAFETY SYSTEM SETTINGS 37 CTS 3/4.3.1 REACTOR TRIP SYSTEM INSTRUMENTATION FNP ITS 3.3.1 REACTOR TRIP SYSTEM (RTS) INSTRUMENTATION l proposed change does not reduce the margin of safety. 1 9906040040 990528 PDR ADOCK 05000348 P PDR , Chapter 3.3 E3-2-A May,1999 L

l h[b RTS Instrumentation 3.3.1 Table 3.3.1-1 (page 7 of 8) Reactor Trip System Instrumentation 1 Note in Overt - rature AT The Overteeperature AT Fu tjon Allowable Value shall not exceed the following Trip

setpoint by more than g t of At span. A m W I AT *

    .                                  SAT o    K-K i

T - T' + K (P-P/ )- f g(A O 2. Where At is sensured . g; g g ArO is the indicat at RTPf 'F. ' 9_ e is the Laplace tran rm operator, sec' .

T,is the measur verage temperature, 'F. - l T is the @omina1JT,,, ht RTP, n {58Sf F.

7*7,'t,'

hk&ded

Nre.ftreht.tj ; P,is the measurea pres e pressur0 si

i P is the nom 1 o oa rating pressure,q s b2235 peig.

_x hmi .09

        ~ r a:

D x2 0. iss 11/ *F x3 = do.0006711Tfpsi[ a see r2 5 3 **c 6s[ 2 sec W r4 see r5 5 **c re sg 2 i see 3 fj(AI) = .26 + (q - qb)) when(qt - Q S - . RTP I

      = 2,q g         0% of RTP                          when -      % RTP <
                      -1.0       ( qt - Gb ) -           whenfqt        > 7 tRTP
                                                                                     ~ h5        7   RTP Where qt and qb are                  cent RT b

the upper and lower halves of ' the core, respectively, and qt + 9b is the total THERMAL POWER in percent RTP. OTE 16 & totessor ] The Greek Lt.NV N l Skould bt Ube d.tn p d oF'T* in the Terms 71-T=le . J ((4'1C so b e.Nm of4he,bAl#M Afe<m.t WSwe 4cf b.b Athc.h of ke yv qe nor.\tw e c.Meoj wA "5 4o be seleM based m mos.wyeA shent ceqw$c 34 M$ M SMup he swa-Ad-: WOG STS 3.3-21 Rev 1, 04/07/95

E 937 RTS Instrumentation 3.3.1 Table 3.3.1-1 (page 8 of 8) Reactor Trip system Instrumentation Note 2: Overnower &r O' Y The overpower Ar Funci 'ro Allowable Value shall not exceed the following Trip setpoint by more than 3 of AT span. M 6 U 3 (1+ f cy 1 3'g (1* 'as, 1+ 1 1

                                                                                              ~        ~
                                                                 ,1 +fes,         1 + fes l

Where: At is measured F. Arg is the indicat e is the Laplace t at RTFf *F. gghTg rm operator, sec . - l T,is the measured verage t rature, *F. O' ~ is the prominag_T,y, at RTP, s ses * . 577,2.

    $_-                     n-                                                                       -              P            .
          - K M f) O % 0]y.0 tl.09 C              O          /
                                                        ]7*F for increasing
                                             /*F for decreasing T,yg avg                           T 0.0012sl/*F when,T > T

Of/*F when T 5 T fi 2: fel see T 5 (3) sec l M T3 sec

         ,fT6 5(         sec 1r[E(10]secf 7                                    4; d

f 2(AI) = Ot RTF for all Ar. '

                                                                 . kS:                   -       1        -

T5 ibE 4 b ._ h %e(, NdTE reek ToLetferYd wodPM } 1 sha,M,be.used.,m p(E4. sF"T"In $$)e Termb TE~ \

   <                                    )                                                                                            ll I

WOG STS 3.3-22 Rev 1, 04/07/95

FNP TS Conversion Enclosure 5 - JD from STS Chapter 3.3 -Instrumentation STS 3.3.1 REACTOR TRIP SYSTEM (RTS) INSTRUMENTATION FNP ITS 3.3.1 REACTOR TRIP SYSTEM (RTS) INSTRUMENTATION JD NUMBER JUSTIFICATION , specified in the CTS. 21 The STS note (f) (FNP ITS note e) is revised consistent with the FNP design and CTS. The STS note (f) includes a reference to a Boron Dilution Protection System I

               .(BDPS). This reference is deleted in the corresponding FNP ITS note (e). The FNP design does not include the automatic detection and mitigation features of the BDPS and the STS LCO 3.3.9 for this system is not applicable to FNP. Plants             l utilizing this automated system to detect and mitigate boron dilution events typically require two channels of source range instrumentation operable to support the BDPS. 'As FNP does not have a BDPS, only one channel of source range instrumentation is required operable for indication purposes only in Modes 3,4, and 5 when the RTBs are open.

22 The STS RTS function SG Water level-Iow Coincident with Steam - l Flow /Feedwater Flow Mismatch is not part of the FNP design or CTS and is deleted. Subsequent RTS function numbers are revised accortiingly. l 23 Not used. 24 The FNP ITS Condition V for two RTS trains inoperable, which requires that LCO 3.0.3 be entered immediately, is assigned to the RTS RTB and Automatic trip logic functions. The STS Rev 1 included this Condition in the Actions but did not assign this Condition to any RTS functions. If the Condition is not assigned a function it will not become applicable according to Condition A of the RTS LCO. Therefore, the omission of this information in the STS is an error. According to the original change initiated by the NRC (NRC-02-01) which added Condition V to revision 0 of NUREG-1431, the new Condition was assigned to the RTB and automatic trip logic functions. Therefore, consistent with the intent of the original NRC change yI document, this Condition is assigned to the RTS RTB and Automatic trip logic functions in the FNP ITS. 25 STS Table 3.3.1-1 Notes 1 and 2, which provide the OTAT & OPAT setpoint equations, are revised based on FNP design basis. The equation revisions, including the defined terms, static and dynamic constants and associated values, reflect Farley-specific hardware, accident analyses modeling and assumptions, setpoint uncertainty calculations, scaling calculations, and calibration and periodic surveillance practices. The Farley-specific approach provides assurance that the OTAT & OPAT reactor trip functions will always respond conservatively with respect to the safety analyses that credit these trip functions. A summary of the STS Chapter 3.3 ES-13 A May,1999 e ]

FNP TS Conversion Enclosure 5 - JD from STS Chapter 3.3 - Instrumentation STS 3.3.1 REACTOR TRIP SYSTEM (RTS) INSTRUMENTATION FNP ITS 3.3.1 REACTOR TRIP SYSTEM (RTS) INSTRUMENTATION JD NUMBER JUSTIFICATION deviations follows. The OTAT & OPAT dynamic compensation term changes reflect the as-built hardware configuration as approved in Technical Specifications Amandment Nos. 87 (Unit 1) and 85 (Unit 2), FNP RTD Bypass Manifold Elimination. The equalities, inequalities and values associated with the static and dynamic constants and allowable values were approved in Technical Specifications Amendment Nos. 121 (Unit 1) and 113 (Unit 2), Revision to Cort Limits and OTAT & OPAT gA Setpoints. Use of equalities for the static constants is required because these are explicit scaling calculation inputs that must be implemented within the hardware calibration tolerances. The requirement to set T' and T" to equal the full power operating reference temperature (Tw) was also approved in these amendments,- , along with the clarification that ATomust be normalized at the full power operating reference temperature. The tenn descriptions for AT, T, and AToc larify that these tenns for each protection system channel are associated with specific RCS " loops." The term description for P' clarifies that the process control parameter is the

               " pressurizer" pressure reference setpoint (i.e., Pw). The use of an equality for the nominal operating pressurizer pressure value reflects the transient and accident analyses modeling of a nominal setpoint with a plus/minus uncertainty. Inclusion of the fi(AI) term description clarifies that it is an " indicated" function which must be calibrated (i.e., normalized) based on cycle-specific test data following each refueling.

These Farley-specific deviations from STS provide assurance that FNP is operated and the OTAT & OPAT reactor trip functions are maintained consistent with applicable FNP transient and accident analyses, safety analysis limits, and setpoint uncertainty and scaling calculations. These STS deviations also reflect the current FNP licensing design basis. 26 The surveillance requirements for FNP ITS Table 3.3.1-1, Function 17.b, Permissive P-7, will be specified as N/A. The STS specifies SR 3.3.1.10, Channel Calibration, and SR 3.3.1.11, Channel Operability Test, for the P-7 interlock. The P-7 interlock receives input from the P-10 and P-13 interlocks and, as such, does not have individual channels. Without individual channels P-7 is purely train-oriented logic, and the channel calibration and channel operability are not ! appropriate. The P-10 and P-13 channel calibrations are covered by their respective l Channel Calibration and Channel Operability Tests, and specifying a Channel l Calibration or Channel Operability Tests for P-7 would be redundant. Therefore, the Channel Calibration SR 3.3.1.10 and Channel Operability Test 3.3.1.11 are not Ch=*ar 3.3 ES-14-A May,1999 C.

l Nd) RTS Instrumentation

B.3.3.1 BASES In MODE 3, 4, or 5 with the reactor shut down, the ! Source Range Neutron Flux trip Function must also be { OPERABLE. If the CRD System is capable of rod withdrawal, the Source Range Neutron Flux trip must be APPLICABLE 5. Source Ranae Neutron Flux (continued) SAFETY ANALYSES, LCO, and OPERABLE to provide core protection against a rod APPLICABILITY withdrawal accident. If the CRD System is not capable of rod withdrawal, the source range detectors are not required to trip the reactor. However, their monitoring Function must be OPERABLE to monitor core neutron levels and provide indication of reactivity 3 3y\ chanpas that may occur as a result of events like a , . borca ilution. Uhese inputs are provided to tha l -- g QDT The requirements for tne NIS source range F de ectors in MODE 6 are addressed in LCO 3.9.3, D " Nuclear Instrumentation." ) g gg 6. Overtemperature AT f MO

O The Overtemperature AT trip Function is provided to rt e re ensure that the design limit DNBR is met. This trip @$C 4(tA<.

Whor y%pa Function also limits the range over which the Overpower AT trip Function must provide protection. he inputs to the Overtemperature AT trip include all pr coolant temperature, axial power distribu , reactor power as indicated by loop AT assuming full r coolant flow. Protection The eort Nrmal from violating the DNBR s assured for those power ns concelo.te{ the transients that are slow with re et to delays from S ihe M fcysntish core to the measurement syste E he Function i

                              ' monitors botn varianon in power and flow since a Q    M IO

8DS ihe.VPS$2.-ll0 decrease in flow has the same effect on AT as a nowe Lincrease.1TheOvertemperatureATtripFunctionuses measu m p # acn loop's AT as a measure of reactor power and is l P g4g# g compared with a setpoint that is automatically varied with the following parameters: l g regityyde Qj py g,
reactor coolant average temperature - the Trip Setpoint is varied to correct for changes in MbCOM#98 coolant density and specific heat capacity with changes in coolant temperature;

      %e.vohM oh Me a p h h C y lc-S po' N g n p r' G k ro ne.4 itmph e.

(continued) WOG STS B 3.3-15 Rev 1, 04/07/95

[2-[ / RTS Instrume t BASES

pressurizer pressure - the Trip Setpoint is varied to correct for changes in system pressure; and 3,

e axial power distribution - f(AI), the Trip Setpoint is varied to account for imbalances in the axial power distribution as detected by the APPLICABLE 6. Overtemoerature AT (continued) aj SAFETY ANALYSES, LCO, and NIS upper and lower power range detector f APPLICABILITY , raxial peans are greater snan tne oesign limit, its

                                                    -       indicated by the difference between the upper and N, f, d$

AT" lower NIS power range detectors, the Trip Setpoint is reduced in accordance with Note 1 off'

/-

egua.b er exceeds. ITable 3.3.1-15 , 06 M*

Dynamic compensat n included for system piping delays from the a re in na _ + === = = + "r= = = = n - -,t stem

{e eletdaQ 4 ' The Over erature AT trip Functio s calcula1=d far w eachd oop as scribed in Note 1 of able 3.G Tri A curs i vert _emperature AT m u m cates'in two

fi uoo >syyt some units 1 the pressure and temperature _a . igiais are_ used for other control functionsc Forr l pC' g,WM (those un1Yd the actuation logic must be able to g witnstand an input failure to the control system, I*1 *n-

                           -1
            '                                                                                                       P ConYm 9
                                           / actuation. and a single failure in the other ciannels                 IM'

[s siem%pNg3 which may then requir iffe d *. 6 rege/ rem 898* that this prov' ding t' protection function actuationifioteM ction also provides aKsignal toraeneratf@6)r Va. turbine runDaclD Dr'or to reachina the Trip Setpoi

                                                                                                                            - f'.

Y pg 'p b kreactor turbine ' runback wi'I reduce turo power. A reduction in power newill I power anarm lly *g I M AT 44 alleviate the Overta=nerature AT conditio n a M dJft dl 64- . prevent a reactor trip. " # h M ieF3AP.

~~~

The LC0 requires all four channels of the

                                                                                                            }) ' tenta    M         i
      -c,g7er 7,L.

g ( Overtemperature AT trip Fujiction to bo OPERARI F fnr ] ; i m c, dwo and four loop units GUhe Lco requ' res all three The cleadS channels on the overtemperaturqL AT trip Function to be gg 61-8d-* b3 gn .j OPERABLECror thren loon units q ' Note that Overtemperature A Function-reqqives pu channels shared with ener xTy unct s. Failures rom g (conismiird over p 4 % prus w w r WOG STS ~ F****'* e d ES B 3.3-16 Rev 1, 04/07/95

    .                   P'"* W RMANt$

u_._

E l+8 RTS Instrumentation B 3.3.1 tM BASES ? - toe, N L desien basts is that affect multiple Functions require entry into the l y Conditions applicable to all affected Functions. In MO M 1 or.2, the Ov sperature AT trip must be OPERAi,.E toTrevent DNF. In MODE 3, 4, 5, or 6, this trip Function aoes not have to be OPERABLE because the reactor is not operating and there is insufficient heat production to be concerned about DNB. APPLICABLE 7. Overnower AT for de on kaud[i. tan $ienYs I an The Overp_ AT trip Functionenr sures tia(ifrotectiori APPLICABILITY hsprovidet o ensure the integrity of tie fuel (i.e., _ ~~ g-(c nued) no fuel pe'let melting and less than 1% cladding g g- strain) under all possible overpower conditions. This m - - trip Function also limits the required range of the

       %s tre a fods'en as                 Overtemperature AT trip Function and provides a backup 9t,c,g.       gte4in                to the Power Range Neutron Flux - High Setpoint trip.                   l g               %m                   The Overpower AT trip Function ensures that the 9

I ' g, ,4,,g gg,o < allowable heat generation rate (kW/ft) of the fuel is {

 /                g ,p. g                  not exceeded.4 It uses the AT of each loop as a measure of reactor power with a setpoint that is gg g               automatically varied with the following parameters:
              " ^

reactor coolant average temperature - the Trip Setpoint is varied to correct for changes in coolant density and specific heat capacity with y/ changes in coolant temperature;.and Og g ; 4A lor) rate of change of reactor coolant average temperature - including dynamic compensation for py g e .the delays between the core and the temperature og a c4cobteA -measureme a:ggncM ];

1p Function is calculated for each 'T The loop asOverpower per Note 2,nr t(pf Tab],s 3.3.1-1.rip occurs if verpowgr AT qs mc icateg'in two lo Gt somje O fifYf Wit Ale temperatura sianals ar ed'for other - con rol functions; [At th~ose units.)the actuation 95 M- logic must be able to withstand an input failure to d the control system,'which may then require the fy&ICm N#-Q Control MpM;e/ i protection the remaining channels function actuation providing the protection _ _b and a b function actuationArnote Inat Inis runction also " ghrtM eulftm90h peacOg l p gmM4n e f- (lto reaching the Allowable Valum-providesasignaltogenera A turhine runhack ] _

                'O' 9gg,       g'ggg'p,ggggg g nt,g                      j I
          ' wn                     $

rs=

fN. .* r . m

                                                      /[MsqWpree@ @gcontinf*d)
                                                        ,r ,My'        ^ '""% f .a/95                          ,   i w0s STS Q'QS C    ,*"1            2 7 He           _

5V1 RTS Instrumentation B 3.3.1 BASES Iwill reduce turbine power and reactor power. A reduction in power will normally alleviate the E , j grpowerATconditionandmaypreventareactortrip.) Tho LC0 requires (6g channels for two and C ht i,) ON ts Shree channe'sUor three 1an units 3 of the 5 uverpower AT trip Function to be PERABLE Fa"- No laa hat h the Overpower AT trip Functio ive p rom _ l APPLICABLE 7. Overnower AT Len , ce Th c M is h m oa,***-

SAFETY ANALYSES, W3r4pAM _ ep yy., I LCO, and chainhell snared ~with RTS Functio . Tailu,6 - APPLICABILITY that affect multiple Functions require entry into the Conditions applicable to all affected Functions. -

In NODE 1 or 2, the Overpower AT trip Function must be

             %               OPERABLE. These are the only times that enough heat is generated in the fuel to be concerned about the 9p                 heat generation rates and overheating of the fuel. In g, MODE 3, 4, 5, or 6, this trip Function does not have to be OPERABLE because the reactor is not operating and there is insufficient heat production to be concerned about fuel overheating and fuel dama a-                       Q-N#I              asdneE8FRST ON     ,

8. Pressurizer \ Pressure

                                          +    y

(%

                                                                                                 .u in
                                                                                                          $2, p)      g D, Q      :

The same GRA&gy provi Pressure - High and L _ inpu he Pressurizer ps and the =g c

                         -   Overtemperature AT t         Unt some units,.the] P ressurizerPressure,hanneysrealsousedto) provide inout to the
                                                                 ~                    ,

PressurizerPrussureCont*olSystembfFor L

                            'the suuuuon ' og' c must a able to witTs, those units,tand an inp failure to the control system, which may then requi,re the protection function actuation, and a. single
!d-      --                  failure in the other channels providing the protection                l 4      gg              (Enction actuation.                                                >

M B0 NY Pressurizer Pressure - Low 4 citdecOc

   '                  nnd          The Pressurizer Pressure - Low trip Function                                  l I'   '   t            ensures that protection is provided against                                  '
        *-                         violating the DN8R limit d_ue to low pressure.yp
                                      ==       +=                         w          - r                        .
$e$5'""g            -

h hh*YaWpWh O' .. g* @ % # 4 (continuedw, ,, ' x ans LL k BMA. - - . WOG STS y 1, 04/07/95

1 Associated Package Changes for RAI-3.3.1-2 i l l 1 1 l l l 1 1 l l 1 l l l l l l l l i 1 1 1 l L..

FNP TS Conversion Enclosure 2 - Discussion of Changes to CTS Chapter 3.3 - Instrumentation CTS 2.2 LIMITING SAFETY SYSTEM SETTINGS CTS 3/4.3.1 REACTOR TRIP SYSTEM INSTRUMENTATION FNP ITS 3.3.1 REACTOR TRIP SYSTEM (RTS) INSTRUMENTATION DOC N_Q SHE DISCUSSION 1 A The CTS 2.2 requirement for Limiting Safety System Settings is moved into the Reactor Trip System (RTS) Instrumentation LCO, 3.3.1, consistent with the organization of the STS. CTS 2.2 contains the RTS trip setpoints and allowable values for the reactor trip instmment functions. This change retains the CTS 2.2 setpoints and allowable values but organizes all the RTS requirements into a single TS. The re-organization of these requirements consistent with the STS format does not introduce a technical change. Therefore, this change is considered admmistrative. la LC The CTS requirements are revised consistent with the STS. In the STS, l I Conditions are normally provided with a default action in the event that the primary action is not accomplished within the allowed time. The purpose of the default Action is to remove the plant from the applicable Modes for the affected function. Once the plant is removed from the applicable Modes for an inoperable function, that function is no longer relied on to mitigate 8 the applicable design basis accidents described in the FSAR and safe 3I operation of the plant may continue without the protection provided by that tunction. The conversion to the STS incorporates several new Actions - Conditions which are derived from the CTS Action statements but include specific default Actions for specific functions. These changes provide for equivalent, or in some cases more stringent, shutdown requirements as compared to LCO 3.0.3 entry. This type of change is considered less restrictive as it provides an attemate to LCO 3.0.3 entry thus avoiding the wyodag requirements of 10 CFR 50.73 associated with an LCO 3.0.3 entry. 2 LA The CTS 2.2.1 Safety Limit statement for the RTS instrumentation is effectively replaced by the STS 3.3.1 LCO statement and associated bases. Since the 2.2 safety limit requirements are moved into the RTS ) Instrumentation, LCO 3.3.1, consistent with the STS, the LCO 3.3.1 j statement requiring the RTS instrumentation operable is applicable. ! Consistent with the format and presentation of STS LCO statements, the operability details (interlock and setpoint setting requirements) are discussed in the associated bases. The STS LCO simply requires the instrument function to be operable. The STS RTS bases contains extensive i discussions pertaining to the required trip setpoints and allowable values in ;

Chapter 3.3 E2-1-A May,1999 l

FNP TS Conversion Enclosure 2 - Discussion of Changes to CTS Chapter 3.3 - Instrumentation CTS 2.2 LIMITING SAFETY SYSTEM SETTINGS CTS 3/4.3.1 REACTOR TRIP SYSTEM INSTRUMENTATION FNP ITS 3.3.1 REACTOR TRIP SYSTEM (RTS) INSTRUMENTATION DOC HQ~ SHE DISCUSSION the QPTR verification per Specification 4.2.4.2 is required only when the ; inoperable power range channel results in the input from that channel to QPTR being inoperable. A power range neutron flux channel consists of an upper and lower excore detector from the nuclear instrumentation system in addition to the associated relays, bistables, amplifiers and contacts from the RTS. Inputs to the QPTR calculator are derived from the currents of the upper and lower excore detectors. Each current maintains its own identity up to the process computer where QPTR is calculated. This enables core tilt to be calculated for both the top half and bottom half of the core. Power range neutron flux however, is obtained by summing the currents from the upper and lower excore detectors to obtain a total current which represents a given percent of rated thermal power. Therefore, if an excore detector becomes inoperable, the entire power range neutron flux chanr.el becomes inoperable since the excore detectors generate the input signals to the RTS. However, if the excore detectors are operable and a downstream portion of the RTS channel is inoperable (c. g., a trip bistable), then the ability to monitor QPTR may not be affected. Performing incott measurements - every 12 hours requires considerable plant staff support and operator involvement.' Ifit can be determined that the failure of a power range , neutron flux channel does not affect the excore detector signals to the QPTR calculator, then reliance on the excore instrumentation to monitor QPTR should not be precluded. If the input from the affected power range instrument channel is intact, QPTR may be monitored normally without the undue use of resources or the potential distraction to the operating staff resulting from the requirement to perform incore measurements every 12 hours. Therefore, the addition of the STS Note is acceptable and does not eliminate the requirement or diminish the capability to monitor changes in radial power distributions when one power range neutron flux channel is inoperable. 62 M CTS Action 2 for a single inoperable power range instrument channel on CTS Table 3.3-1 is revised by the addition of a new Action consistent with the STS. The STS default Action "or be in Mode 3 in 12 hours"is added to CTS Action statement 2 consistent with the corrWing STS Condition D. The addition of this STS Action represents a new TS requirement that . was not previously specified in the CTS. As this requirement is only

                   . Chapter 3.3-                                 E2-38-A                                 . March,1998 be.i. sms.-mimm. M&

7 FNP TS Conversion Enclosure 2 - Discussion of Changes to CTS Chapter 3.3 - Instrumentation CTS 2.2 LIMITING SAFIiTY SYSTEM SETTINGS CTS 3/4.3.1 REACTOR TRIP SYSTEM INSTRUMENTATION FNP ITS 3.3.1 REACTOR TRIP SYSTEM (RTS) INSTRUMENTATION DOC HQ Sjig DISCUSSION applicable if the other Actions are not met and meeting this new' Action removes the plant from the applicable Mode for the associated RTS function, the addition of this Action is applicable to FNP. The proposed c p addition ofITS Condition D.3 is equivalent to the existing default action for pf CTS Action 2, which requires entry into LCO 3.0.3 when Action 2 conditions are not met. However, since the total CTS action time to reach Mode 3 is 13 hours, versus the STS time of 12 hours, this addition is considered a more restrictive change. 63 -A CTS Action statement 6 applies to inoperable turbine throttle valve closure turbine trip channels and is revised into the STS format in FNP ITS _ Condition Q. CTS Action statement 6 provides for multiple channels to be inoperable by simply stating "With the number of Operable channels less than the total number ..." The allowance for multiple channels to be - inoperable in this particular function is reasonable considering that the trip logic requires 4-out-of-4 throttle valves to be closed (tripped) in order to actuate a reactor trip. Therefore, as many as three channels of this function may be tripped and the resulting condition of the actuation logic would be similar to a 2-out-of-3 function with one channel in trip (one additional channel tripped will cause a reactor trip).- It should also be noted that the turbine trip - reactor trip function is anticipatory and not credited by any design basis accident analyses described in FSAR Chapter 15. In the STS, this Action would translate into a Condition which specified "One or more Turbine Throttle Valve Turbine Trip channels inoperable". However, the STS does not contain an Action Condition that corresponds with the requirements contained in CTS Action Statement 6. Therefore, an FNP ITS specific RTS Condition P is introduced to contain Actions equivalent to - CTS Action statement 6. Although not consistent with a specific STS Action Condition, this change is consistent with the CTS requirements for this function and is therefore considered an administrative change to the CTS in order to conform with the STS format and presentation. 54- M CTS Action statement 6 applies to inoperable turbine throttle valve closure turbine trip channels and is revised into the STS format in FNP ITS Condition P. This CTS Action is further revised by the addition of a default Action that is applicable if the other Actions can not be met. The new 1 Chapter 3.3 E2-39-A May,1999

FNP TS Conversion Enclosure 2 - Discussion of Changes to CTS Chapter 3.3 - Instrumentation CTS 2.2 LIMITING SAFETY SYSTEM SETTINGS CTS 3/4.3.1 REACTOR TRIP SYSTEM INSTRUMENTATION FNP ITS 3.3.1 REACTOR TRIP SYSTEM (RTS) INSTRUMENTATION DOC NQ SHE DISCUSSION channel requirement, The CTS minimum channels requirement is always met while the STS Action Condition is applicable. Therefore, the CTS Action statement regarding meeting the minimum channels operable I requirement is no longer necessary. In addition, the CTS bypass allowance in Action 7b is also revised by deletion of the specific reference to CTS surveillance 4.3.1.1. As the STS does not contain a single generic RTS surveillance to reference (each test listed in 4.3.1.1 is a separate surveillance in the STS), the specific reference is replaced by a simple reference to surveillance testing. The changes discussed above are necessary to present the CTS Action 7b bypass allowance in the STS Condition note format and do not change the technical intent of the CTS allowance. Therefore, these changes are considered administrative. 66a M CTS Action 7 for a single inoperable instrument channel on CTS Table 3.3-1 is revised by the addition of a new Action consistent with the corresponding STS Condition E. The STS default Action "or be in Mode 3 in 12 hours" is added to CTS Action statement 7 consistent with the l correcponding STS Condition E. The addition of this STS Action ! represents a new TS requirement that was not previously specified in the CTS. As this requirement is only applicable if the other Acticns are not met G and meeting this new Action removes the plant from the applicable Mode N 3, V - for the associated RTS function, the addition of this Action is applicable to 33 FNP. The proposed addition ofITS Condition E.2 is equivalent to the existing default action for CTS Action 7, which requires entry into LCO 4 3.0.3 when Action 7 conditions are not met. However, since the total CTS l action time to reach Mode 3 is 13 hours, versus the STS time of 12 hours, j this addition is considered a more restrictive change. l 67 L The CTS Action statement 10 is revised consistent with the corresponding STS Condition. The CTS Action allows 6 hours to restore the inoperable channel to operable status or power must be reduced below the P-8 interlock setpoint within the next 2 hours. The conesponding STS : Condition allows 4 hours to reduce power to less than the P-8 interlock ; setpoint after the initial 6 hours allows for restoration. The additional 2 hours allowed by the STS provides a more reasonable time to prepare and j initiate a power reduction from full power while providing adequate ! Chapter 3.3 E2-41-A May,1999

7 .. FNP TS Conversion Enclosure 3 - Significant Hazards Evaluations Chapter 3.3 - Instrumentation SIGNIFICANT HAZARDS EVALUATIONS CONTENTS

1. Organization...........................................................................................................................2 II. Generic Evaluations "A" - Administrative ... .. .. . .. .... .. . . ... . .. .. .. . ... . . . . . .. . . .. .. . . ... ... . .... .. ... ... . .. . .. . . .. ..... . ..... .. . ... . .... ... . . . . . .... 3 "R" - Relocation of Technical Specifications ......................................................................... 5 "M" - M ore Restrictive .. .. .. ... ...... .. . . . .. .... .. .... ... ... . . .... .. ... .. . ........... ... .. . . . .. . ... ... . .. . ... .. ...... .. ... .. .. .. . 8 "LA" - Removal of Requirements from Retained TS ......................... ...................... ......... 10 "LB" - Use of Simulated or Actual Test Signal .............................................. ..... .............. 12 "LC" - Replacement of 3.0.3 Entry Requirement Within TS ....................................... ......14 l

III. Specific Evaluations "L" - Less Restrictive .. .. . . . . .... . . ... . . ... . . . . . .... .. ... . . .... . . ... . . .... . . . . ... ... . . . .... . . . . .. . . . ... . .. . . .. . . . . . . . .. . . .. . . 1 6 l i 3fD i l 1

i i i 1 l

    . Chapter 3.3                                                                     E31                                                                                       May,1999                          '

FNP TS Conversion Enclosure 3 - Significant Hazards Evaluations Chapter 3.3 - Instrumentation II. GENERIC SIGNIFICANT HAZARDS EVALUATION 10 CFR 50.92 EVALUATION l i[ FOR j REPLACEMENT OF 3.0.3 ENTRY REQUIREMENT WITHIN TS (changes labeled"LC") 1 This generic category applies to those changes that provide for equivalent, or in some cases more stringent, shutdown requirements as compared to LCO 3.0.3 entry, to be contained within the individual TS. This type of change is considered less restrictive as it provides an alternate to LCO 3.0.3 entry thus avoiding the reporting requirements of 10 CFR 50.73 associated with an LCO 3.0.3 entry. The shutdown requirements contained within the TS are equivalent to, ot in some cases more stringent than, the shutdown requirements contained in LCO 3.0.3. Therefore, action is taken within the appropriate time to place the unit in a safe condition. Changes to the CTS requirements that fall within this category (Less Restrictive - Generic) are l annotated with an "LC" in the Enclosure 1 markup and Enclosure 2 DOC. SNC has evaluated each of the proposed TS changes identified as Less Restrictive - Generic in accordance with the criteria set forth in 10 CFR 50.92 and has determmed that the proposed changes do not involve a significant hazards consideration. These changes are considered j l generic and each change identified as Less Restrictive - Generic will not be specifically discussed l in this SHE. This evaluation will be applicable to each of the changes identified with an "LC" in the Enclosure 1 markup of the CTS and the associated Enclosure 2 DOC. The bases for the determination that the proposed changes do not involve a significant hazards - l consideration is an evaluation of these changes against each of the criteria in 10 CFR 50.92(c). The criteria and conclusions of the evaluation are presented below. i l l l 1 Chapter 3.3 E3-14 May,1999 l

I-FNP TS Conversion Enclosure 3 - Significant Hazards Evaluations Chapter 3.3 - Instrumentation I l l II. GENERIC SIGNIFICANT HAZARDS EVALUATION l

     ,r g.

f ',y 10 CFR 50.92 EVALUATION FOR i i REPLACEMENT OF 3.0.3 ENTRY REQUIREMENT WITHIN TS l (changes labeled "LC") (continued)

1. Does the change involve a significant increase in the probability or consequences of an accident previously evaluated?

The proposed changes provide for equivalent, or in some cases more stringent, shutdown requirements as compared to LCO 3.0.3 entry, to be contained within the individual TS. By i including the shutdown requirements within the individual TS, the reporting requirements associated with an LCO 3.0.3 entry are avoided. The proposed changes will continue to ensure that action is taken within the appropriate time to place the unit in a safe condition. l The deletion of the requirement to report the shutdown has no impact on the probability or the consequences of an accident previously evaluated. Therefore, these changes do not involve a significant increase in the probability or consequences of an accident previously evaluated. l 2. Does the change create the possibility of a new or different kind of accident from any l accident previously evaluated? The proposed changes do not introduce a new mode of plant operation or necessitate a physical alteration of the plant (no new or different type of equipment will be installed) or l changes in parameters governing normal plant operation. Thus, these changes do not create the possibility of a new or different kind of accident from any accident previously evaluated

3. Does this change involve a significant reduction in a margin of safety?

l The allowance to provide for equivalent, or in some cases more stringent, shutdown ! requirements as compared to LCO 3.0.3 entry to be contained within the individual TS l continues to ensure that action is taken within the appropriate time to place the unit in a safe condition. Therefore, these changes do not involve a significant reduction in a margin of safety. 1 1 i l l l Chapter 3.3 E3-15 'Eay,1999 j l

1 i I Associated Package Changes for RAIs - 3.3.1-3 and 3.3.1 10 1

i

l 1 i i l

FNP TS Conversion Enclosure 2 - Discussion of Changes to CTS Chapter 3.3 - Instrumentation CTS 2.2 LIMITING SAFETY SYSTEM SETTINGS CTS 3/4.3.1 REACTOR TRIP SYSTEM INSTRUMENTATION FNP ITS 3.3.1 REACTOR TRIP SYSTEM (RTS) INSTRUMENTATION DOC N_Q SHE DISCUSSION channels for both the one loop and two loop trip functions. As the associated STS Action and applicability for the single Loss of Flow Function serve to address the full range of operating conditions where the Loss of Flow instrument channels are required operable, the STS presentation of this information simplifies but does not reduce the requirements for this RTS function (except as noted in DOC 34-L). The placement of the CTS information describing the design of this function (the two types of Low Flow trips) in the bases is consistent with the philosophy of the STS regarding descriptive information. The placement of s 3 design and operating descriptions in the STS bases is acceptable since ye changes to the information in the bases is controlled by the Bases Control f4f9 Y Program specified in the administrative controls section of the TS. 37 L The applicabilities and Actions associated with the RTS Turbine Trip functions (auto stop oil pressure and turbine throttle valve position) on CTS ! Table 3.3-1 are revised consistent with the FNP RTS design and, where I applicable, the STS. The Mode 1 applicability of these functions is ! modified by the addition of an STS footnote. The footnote modifying these functions limits the applicability in Mode 1 to "above the P-9 interlock." I The addition of this STS footnote is consistent with the RTS Turbine Trip design which provides for automatically blocking the associated reactor trip ! functions below the P-9 interlock. This design feature is acceptable because the turbine trip / reactor trip is an anticipatory trip and is not assumed to operate in any design basis accident analyses described in FSAR Chapter

15. In addition, the NSSS Control System design capability includes the capacity to absorb a load rejection below P-9 without incurring a reactor trip. As this is a standard design feature of Westinghouse PWRs and the STS incorporates this limit in the Mode 1 applicability for these functions, it is also applicable to FNP as well. In addition to the revision of the applicability for these functions, the STS introduces a separate Actions Condition to specifically address the applicability of these functions. The STS assigns Condition O to turbine trip functions. Condition O provides the appropriate default action "or reduce power below P-9" for these RTS functions. Below P-9 these functions are no longer required. However, the STS Condition O for the turbine trip functions only allows for a single inoperable channel in each function. This STS Condition corresponds to Chapter 3.3 E2-23-A May,1999

FNP TS Conversion Enclosure 2 - Discussion of Changes to CTS Chapter 3.3 - Instrumentation CTS 2.2 LIMITING SAFETY SYSTEM SETTINGS h ff CTS 3/4.3.1 REACTOR TRIP SYSTEM INSTRUMENTATION FNP ITS 3.3.1 REACTOR TRIP SYSTEM (RTS) INSTRUMENTATION f, 9 **' N_Q SHE DISCUSSION the FNP Action statement 7 which applies only to the low auto stop oil pressure turbine trip RTS function. The FNP Action Statement which is applicable to the turbine trip throttle valve closure RTS function (Action 6) allows for more than one inoperable channel of this function. This allowance is reasonable considermg that inoperable channels are placed in trip and the logic for this trip function requires 4 out of 4 throttle valves to 4 be closed (tripped) in order for a reactor trip signal to be generated. l Therefore, an FNP specific ITS Condition P has been added to the FNP ITS to incorporate the CTS Action allowance for more than one inoperable channel in the turbine trip throttle valve closure RTS function. The proposed FNP specific Condition P contains the CTS Action requirement (6) which is revised in format and presentation to be consistent with similar requirements in the ITS (with the exclusion of the note that allows an inoperable channel to be bypassed for up to 4 hours). The FNP ITS specific Condition P also provides a default Action consistent with the applicability of this function (or reduce power below P-9), which is the same as the STS l Condition O. Below P-9 this function is no longer required. Therefore, FNP ITS Conditions O and P are used in place of CTS Action statement 6 and 7 for the turbine trip RTS functions. CTS Action statement 7 is marked up in Enclosure 1 to illustrate a default Action for functions with an applicability of Modes 1 and 2. Since a different default Action is j applicable for the turbine trip RTS functions discussed above, Condition O is included separately as an insert in Enclosure I to illustrate the applicable default Actions. Other changes to CTS Action statement 7 are discussed in the DOCS associated with those changes and with the exception of the

                          " default actions" described above those DOCS are applicable to the conversion of CTS Action 7 to Condition O. The FNP specific CTS Action statement 6 is marked up to show the changes required to convert to the FNP ITS specific Condition P, including the addition of the STS type default Action "or reduce power below P-9." The changes to CTS Action j               statement 6 are discussed in the DOCS associated with those changes. The changes to the applicability and Actions for these RTS functions reduce the CTS requirements for these functions consistent with the FNP RTS design and the guidance provided in the STS and are therefore considered less restrictive changes.
 .      Chapter 3.3                                  E2-24-A                                       May,1999  l

FNP TS Conversion Enclosure 2 - Discussion of Changes to CTS Chapter 3.3 - Instrumentation CTS 2.2 LIMITING SAFETY SYSTEM SETTINGS CTS 3/4.3.1 REACTOR TRIP SYSTEM INSTRUMENTATION FNP ITS 3.3.1 REACTOR TRIP SYSTEM (RTS) INSTRUMENTATION DOC HQ SHE DISCUSSION considered a more restrictive change.

       -63        A-    CTS Action statement 6 applies to inoperable turbine throttle valve closure reactor trip channels and is revised, where applicable, into the STS format in FNP ITS Condition P. CTS Action statement 6 provides for multiple gb 40                    channels to be inoperable by simply stating, "With the number of Operable channels less than the total number . . . ." The allowance for multiple
$-3                     channels to be inoperable in this particular function is reasonable considering that the trip logic requires 4-out-of-4 throttle valves to be          .

closed (tripped) in order to actuate a reactor trip. Therefore, as many as three channels of this function may be tripped and the resulting condition of the actuation logic would be similar to a 2-out-of-3 function with one i channel in trip (i.e., one additional channel tripped will cause a reactor trip). I It should also be noted that the turbine trip / reactor trip function is anticipatory and not credited by any design basis accident analyses described in FSAR Chapter 15. In the STS, this Action would translate into a Condition which specified, "One or more Turbine Throttle Valve Turbine Trip channels inoperable." However, the STS does not contain an Action Condition that corresponds with the requirements contained in CTS Action Statement 6. Therefore, an FNP ITS specific RTS Condition P is introduced to contain Actions equivalent to CTS Action statement 6. Although not consistent with a specific STS Action Condition, this change is consistent with the CTS requirements for this function and is therefore considered an administrative change to the CTS in order to conform with

                       ~.the STS format and presentation.

64 M CTS Action statement 6 applies to inoperable turbine throttle valve closure g reactor trip channels and, with the exception of the note that allows an inoperable channel to be bypassed for up to 4 hours for surveillance testing

? g,3                  ~of other channels, is revised into the STS format in FNP ITS Condition P.

3r jo 3 9 CTS action statement 7 applies to an inoperable auto stop oil low pressure reactor trip channel and is revised into the STS format in FNP ITS Condition O. These CTS Actions are further revised by the addition of a default Action that is applicable if the other Actions can not be met. The new default Action is consistent with the default Actions provided by the ; STS in all other STS Conditions. The default Action "or reduce power to < ! Chapter 3.3 E2-40-A May,1999 !

i 7 FNP TS Conversion Enclosure 2 - Discussion of Changes to CTS Chapter 3.3 - Instrumentation

                                                                                                                'l CTS 2.2 LIMITING SAFETY SYSTEM SETTINGS CTS 3/4.3.1 REACTOR TRIP SYSTEM INSTRUMENTATION FNP ITS 3.3.1 REACTOR TRIP SYSTEM (RTS) INSTRUMENTATION DOC NQ       SHE                                       DISCUSSION P-9" effectively removes the plant from the applicable Mode for the turbine l                  trip / reactor trip function. As this Action presents a reasonable alternative if the other Action can not be performed, this STS type Action is applicable

[g 3 and appropriate for FNP as well. Thejustification for this less restrictive foj change, i.e., reducing power to < P-9 versus placing the unit in Mode 3, is i))J 1 provided by DOC 37-L. With regard to the Completion Times for Required Actions O.1 and P.1, which place the inoperable channel (s) in trip, the CTS and the STS requirements are identical. With regard to the Completion Times for the new default Required Actions O.2 and P.2, which require - power reduction below P-9, the STS time of 10 hours is more restrictive than the CTS time of 13 hours.~ The STS default action time provides 4 additional hours to reduce power below the level of the RTS function applicability if the channel is not placed in trip. This allowance is reasonable based on operating experience. The CTS default action time in LCO 3.0.3 provides 7 additional hours to reduce power below the level of

                           - the RTS function applicability if the channel is not placed in trip.

Therefore, incorporation of the STS completion time for Acdons O.2 and P.2 is considered a more restrictive change. 65 A CTS Action statement 7 is converted into Condition E consistent with the STS. The total number of channels requirement referred to in CTS Action 7 is revised to " Required Channels" consistent with the STS format and presentation of the number of required channels. The actual number of channels that the Action refers to is not changed. Therefore, this change is made for format reasons only. In addition, the CTS Action 7 allowance for "Startup and Power Operation to proceed provided the following - Conditions are satisfied"is no longer necessary and is deleted. The format of the corresponding Condition in the STS (E) and the general rules of TS in the STS (LCO 3.0.4) automatically allow for continued operation (including Mode changes) when the Actions Condition does not limit the

                            ' time the Condition is applicable once the Action has been performed. Since the STS Condition E does not limit plant operation in the applicable Mode once the affected instrument channel has been placed in trip, Startup and Power Operation may proceed in accordance with the provisions of STS LCO 3.0.4. The changes discussed above are made solely to conform with the presentation and format of this information in the STS and no technical Chapter 3.3                                    E2-41-A -                                   May,1999

272 RTS instrument. tion

                                                                                         , 3.3.1 ACTIONS (continued)

CONDITION REQUIRED ACTION COMPLETION TIME c- -

[1.ow Auto step 0/4 t'reasure P. One % bine Trip h ------------NOTE------------- channel inoperable. The inoperable channel may be bypassed for up to 4 hours for surveillance testing of other channels. O ----------------------------- T&TF-il3 P.1 Place channel in 6 hours trip. E C./ P.2 Reduc TH L POWER 10 hours to < -9 . Q. One train inoperable. 9)

                                                       -NOTE-------------                       -

One tr4in may be bypassed for up to (4 hours for surveillance testing provided the other train is OPERABLE.

Q.1 Restore train to 6 hours OPERABLE status. E Q.2 Be in MODE 3. 12 hours

                               ~     '             -       -       '       '

inued) p, one, tg .c hw TAime N {9' Throtti.e.wJve closur* enel(s)inohb. p., pue e_wnelopep. 4 hour s ge M THEttrlAL D R /# $#"#S (o to sP-9. t

                                    -_           __- ~

WOG STS 3.3-7 Rev 1, 04/07/95 1 l

FNP TS Conversion Enclosure 5 - JD from STS Chapter 3.3 - Instrumentation STS 3.3.1 REACTOR TRIP SYSTEM (RTS) INSTRUMENTATION FNP ITS 3.3.1 REACTOR TRIP SYSTEM (RTS) INSTRUMENTATION JD NUMBER JUSTIFICATION impact on the ability to measure QPTR. In addition, this change maintains the current FNP licensing basis as documented in the CTS. 3 The STS Condition D Note which is intended to modify the requirement to perform Required Action D.2.2 is moved into Required Action D.2.2. This editorial change to the STS enhances clarity and understanding and does not change the technical intent of the STS note. The current position of the STS note (above both Required Actions D.2.2 and D.3) could imply that the note pertains to Required Action D.3 as well as D.2.2. The proposed change makes it clear that the note only applies to D.2.2. Required Action D.3 pmvides the default action in this STS Condition to reduce power and must always remam an option to be exercised if the other Actions in this Condition are not met. The application of Required Action D.3 is independent of whether or not the input to QPTR is affected by the inoperable power range instrument channel. 4 STS Condition L is revised consistent with the CTS requirements for the source range instrumentation in shutdown Modes with the RTBs open. In shutdown Modes with the RTBs open, only one channel of source range indication is required for monitoring functions. As STS Condition L is intended to address this situation, it has been revised to refer to a single inoperable channel instead of channel (s). This change maintains consistency with the FNP current licensing basis as specified in the CTS. 5 STS Condition N (revised by TSTF-169 to N from O) applicable to the RCP breaker position trip function (single loop), is revised by the deletion of the STS note in this Condition. The STS note provides the allowance to bypass a single inoperable channel to allow surveillance testing of the remaining channels. This allowance does not exist in the corresponding CTS Action statement number 10 and it is not required for FNP. The single loop RCP breaker position trip function logic at FNP is 1/1 per train. If an RCP breaker opens, the reactor trip is initiated. There is no option or design feature to place a channel in trip and one channel cannot be bypassed while another channel is tested in trip. Since testing this function would require the actuation of the breaker position contacts, testing of the RCP breaker position trip (single loop) function must be performed during plant shutdowns. Therefore, this STS note is unnecessary and is deleted consistent with the FNP design and CTS requirements. 6 The STS Condition O (TSTF-169 revised STS Condition P to O) is further revised to be FNP specific and new FNP specific ITS Condition P is added consistent with Chapter 3.3 ES-2 A March,1998 7

1 FNP TS Conversion Enclosure 5 - JD from STS Chapter 3.3 - Instrumentation STS 3.3.1 REACTOR TRIP SYSTEM (RTS) INSTRUMENTATION FNP ITS 3.3.1 REACTOR TRIP SYSTEM (RTS) INSTRUMENTATION JD NUMBER JUSTIFICATION the corresponding Action requirements of the CTS for the turbine trip RTS . functions. The STS Conditions following the new FNP ITS Condition P are re-lettered accordingly to account for the addition of the new FNP specific Condition (note that TSTF-169 deleted Condition N and re-lettered all subsequent y Conditions). The STS Condition O is revised to apply only to the FNP low auto stop oil pressure turbine trip and is effectively consistent with the corresponding [y CTS Action statement 7. A new Condition is required for the FNP throttle valve l closure RTS function as the STS Condition O assigned to this function does not allow for more than one inoperable channel. The CTS Action statement number 6, l applicable to the throttle valve closure RTS function, effectively allows for multiple inoperable channels in this function. The FNP throttle valve closure trip function requires 4-out-of-4 throttle valves to be closed to initiate a reactor trip. Therefore, if most than one channel (throttle valve position) becomes inoperable the CTS allows the inoperable channels to be placed in trip. In addition, the turbine trip / reactor trip is an anticipatory trip and is not assumed to operate in any design basis accident analyses described in FSAR Chapter 15. Therefore, an FNP specific ITS Condition P has been added to the FNP ITS to incorporate the CTS Action allowance for more than one inoperable channel in the turbine trip throttle valve l closure RTS function. The proposed FNP specific Condition P contains the CTS Action requirement (6) which is revised in format and presentation to be consistent l with the corresponding STS Condition for the turbine trip / reactor trip functions. The FNP ITS specific Condition P also provides a default Action consistent with the applicability of this function (or reduce power below P-9) the same as the l correspondmg STS Condition for the turbine trip / reactor trip functions. Below P-9 this function is no longer required. The Completion Times provided in the proposed FNP ITS Condition are consistent with the Completion Times of the corresponding STS Condition for the turbine trip / reactor trip functions. In addition, the proposed FNP specific Condition P does not contain a note that would provide an allowance to bypass an inoperable channel for testing. The exclusion of this note in the proposed FNP ITS Condition is based on the exclusion of this allowance in

                         - the wiwniisg CTS Condition and in WCAP-10271. Therefore, FNP ITS Conditions O and P are used in place of CTS Action statement 6 and 7 for the turbine trip RTS functions. These changes are made to maintain consistency with the FNP current licensing basis as specified in the CTS and with the provisions and l           format of the corresponding STS Condition for the turbine trip / reactor trip functions.

7 Note 2 in the STS Condition for the RTBs ( Condition R) is revised consistent with the corresponding guidance provided in the last sentence of CTS Action statement Chapter 3.3 E5-3 A May,1999

1

                                                      %Q RTS Instrumentation B 3.3.1 BASES he       difference in flow rates.       There are two SG level
                       /

channels and two Steam Flow /Feedwater Flow Mismatch FNP channels per SG. One narrow range level channel nsing a low level coincident with one Steam F1 / Op F dwater Flow Mismatch channel sensing flow mi atch (st react flow greater than feed flow) will actu ea trip. The LC0 quires two channels of SG Wate Level - Low coincident ith Steam Flow /Feedwater F Mismatch. In MODE 1 or when the reactor r ires a heat sink, the SG Water Le 1 - Low coincide with Steam Flow / Feedwater Flow Mi tch trip nu be OPERA 8LE. The normal source of wa r for th s is the MFW System (not safety related). The System is only in operation in MODE 1 or . he AFW System is the safety related backup so ce of water to ensure that the SGs remain the hea si for the reactor. During - normal startups and td the AFW System provides. feedwater to mainta SG 1 eve In MODE 3, 4, 5, APPLICABLE 15. Steam Generator ater Level - L Coincident With SAFETY ANALYSES, han / Flow /Feedwatee Flow Mismatch (conti ed) LCO, and APPLICA81LITY or 6, th G Water u vel - Low coinciden with Steam Flow /F ater Flow Mismatch Function' doe at have to be OP BLE because the MFW System is not i operation and e reactor is not operating or even crit al. D ay heat removal is accomplished by the AFW tem MODE 3 and by the RHR System in MODE 4, 5. or . The MFW System is in operation only in MODE 1 or 2 and, therefore, this trip Function need only be OPERA 8LE in these MODES. __ 15 i. Turbine Trio Qfofag @ '

a. Turbine Trio - Low Fluid OiY Pressure The Turbine Trip - L lui 011 Pressure trip

      .,                                      Function anticipates the ss of heat removal y3 0                            capabilities of the secondary system following a p                   ,\                   turbine trip. This trip Function acts to minimize
         %Q the pressure / temperature transient on the reacto Any turbine trip from a power level below the P-m=                          -

[M 4. p%,, C eM 5;sb MM ( M y c m pcm e ,Jes ' (continued) WOG STS B 3.3-27 Rev 1, 04/0//95

5 A RTS Instrumentation v' B 3.3.1 BASES $ c RCS i setpoint, ately ower, will not actuate a reactor trip. Three pressure switches moniuor thodontrol oilleressured n ".he urbin

                                            &lactronvarauite cantrol svstan. 1A 'ow pressure v

condition sensed by two-out-of-three pressure 3 switches will actuate a reactor trip. These d AT OverkMwel pressure switches do not provide any input to the 5 (controlsystem. a complete lossThe unitand of load is designed not sust to ore Njamage or challengdthe RCS pres limitations. n

                                             ; ore protectuorgy provided b         e fressurizor ressure - Hig Ptrip Functio ndfRm inteor< ty is) %L nsuredJby the pressurizer safety va' ves.

The LTlh hree channels of Turbine y- Trip-Lo$ w ui 011 Pressure to be OPERABLE in i ' The do.rwels MODE I above - Jg Cambinetin A. 1 2.g.. p.3 trlO Below the P-9 setpoint, a turbine trip does not actuate a reactor trip. In MODE 2, 3, 4, 5, or

              %. 8"                         there is no potenti A for a turbinalria 8    8b.

g ICABLE a. Turbine Trio - Low Fluid Oi[ Pressu (continued SAFETY ANALYSES,,-- h / LCO, and and the Turbine Trip - Low W il Pressure trip APPLICABILITY l Function does not need to be OPERA 8LE. == h roTle,

b. Turbine Trio - Turbine Valve Closurej -- -

The Turbine Trip - Turbine alve Closure trip Function anticipates the loss of heat removal cap 3bilities of the secondary est_em fc41owing a V6 - turbine trip from a power ' eve rats,1_opthe P-9 sennoint, approximately 50% power.f ghis action

'g_

96lmd wi'l not actuate a reactor trip. ihe trip Function anticipates the loss of secondary he

                   % 6e Pd tg               removal capability that occurs when the(tojpp    o valves close. Tripping the reactor in anticipation of loss of secondary heat removal acts to minimize the nressure and temperature oA -h pea                        ranstant on the reac"ont This trip Function will r_o.\.A ghm hswet not and is not required to operate in the presence DA                  of a single channel failure. The unit is designed 1

to withstand a complete loss of load and not (continued) WOG STS 8 3.3-28 Rev I, 04/07/95

3b RTS Instrumentation B 3.3.1 I r(6 P ar,d R cs infecrW BASES M I V

        .n.nd. Overkerrfettkbre sustain core damage or challe e the RCS pressurd.C.

i dT _ limitations. Core nrotection provided by-tfi PressurizerPressure-HigMTtrpFunctionFand C Mntegrity is ensureIn by the pressurizer safety % 5 Thistripjunction diverse to the h[y y f [fo u f [gg valves. IurDine Trip - Lo W Function. Each tura ne il o ressure trin a ve is eauioned ho H(t,

ith one limit switch that inputs to the RTSf I all four limit switches indicate that the

                       . @5        valves are all closed, a reactor trip _ it __
                                                                                                /

Tners kTo w h LSSS for this runctfoniis serto

             %m
             % g n, WA             channel trip occurs when the associate is completely closed.

to valve The LC0 requires four Turbine Trip - Turbine to Valve Closure channels, one per valve, to be OPERABLE in MODE 1 above P-9. Al ur channel must trip to cause reactor trip. ,n & JM A oA %s <.m%\ syder , Below the P-9 setpoint, a load reject o an e accommodated by the Steam Dump Syste . In MODE 2, - 3, 4, 5, or 6, there is no potential for C-t -- (. . -

b. Turbine Trio - Turbine Ston Valve Closure APPLICABLE SAFETY ANALYSES, i LCO, and (continued) Nh '-

(APPLICABILIT V a load rejection, and the Turbine Trip - Sto Valve Closure trip Function does not need be OPERABLE. Safety Iniection Inout from Enaineered Safety Feature l (p. 1 Actuation System The SI Input from ESFAS ensures that if a reactor trip has not already been generated by the RTS, the ESFAS automatic actuation logic will initiate a reactor trip upon any signal that initiates SI. This is a condition of acceptability for the LOCA. However, other transients and accidents take credit for varying levels of ESF performance and rely upon rod insartion, except for the most reactive rod that is assumed to be fully withdrawn, to ensure reactor shutdown. Therefore, a reactor trip is initiated every time an SI signal is present. (continued) WOG STS B 3.3-29 Rev 1, 04/07/95

767 RTS Instrumentation B 3.3.1 BASES

d. Power Ranae Neutron Flux. P-9 kyt, St The Power Range Neutron Flux, 9 interlock is ~

actuated at approximately 50% ower as determined by two-out-of-four NIS power ange detectors. The LCO requirement for this uutis&Whsures that the Turbine Trip L 0011 Pressure and Turbine Trip - Turbi k(Elu' toA alve closure Tkreitb reactor trips are enabled above ';he P-9 setpoint.U = Above the P-9 setpoint, a turbine trip will cause 3 4g a load rejection beyond the capacity of the Steam

                                                   \        ** M                         Dump System. A reactor trip is automatically M#g           _

initianed o'n a turbine trip when it is above the 9 y\ Tt ecM hp P-9 setpoint, to mi imi the t ns e reacto La3d um The LCO requ res

                                                                                                                    ?"L % >          -
                                                                                                                                           =

enanWeTs W Power Range Neutron Flux, P-9 interlock to be OPERABLE in MODE 1. In MODE 1, a turbine trip could cause a load e act on beyond the capacity of the Steam Dump Sys , so the Power Range Neutron Flux interlock must be OPERA 8LE. In MODE 2, 3, 4, 5, or 6, this Function does not have to be OPERABLE because the reactor is not at a power level sufficient to have a load rejection beyond the capacity of the SteamDumpSystp APPLICABLE e. Power Ranae Neutron Flux. P-10 SAFETY ANALYSES, LCO, and The Power Range Neutron Flux, P-10 interlock is APPLICABILITY actuated at approximately 10% power, as (continued) determined by two-out-of-four NIS power range detectors. If power level falls below 10% RTP on 3 of 4 channels, the nuclear instrument trips will be automatically unblocked. The LCO requirement for the P-10 interlock ensures that the following Functions are performed:

on increasing power, the P-10 interlock allows the operator to manually block the Intermediate Range Neutron Flux reactor trip. Note that blocking the reactor trip also blocks the signal to prevent automatic and manual rod withdrawal; (continued)

WG STS B 3.3-34 R*V le 04/07/95 g _. . - _ - . - . . - - . - - , _ - _ - - - - . - - - - - - - - - ---

                   ,,,q                  , --

is ca eco4re-bl6 be, be ((- f[ RTS Instrume t on

frw fut\ goace aM eMQ n Q M 's 9denne. ~7. i BASES P%4% v b the P-8 setpoint because other RTS Functions provide core p tion below the P-8 setpoint. T e 6 hours allowed to restore- channel to OPERABLE status ana trey h 4 additional the P-8 setpoin h rs allowed to inreduce re : usttriad THERMALpER to below metrar==ca 3

                     /       ~he Required Actions have been modified by a Note that
                                                                                                           )

g/ g y allows placing the ino erable channel in the bypassed S}d[' y FNp condition for up to 4 ours while performing routine surveillance testing of the other channels. The 4 hour time S limit is justified in Reference 7. _ g, T&TF-Efl (8 h

                ,            Condi      n S a > plies      Turbine Trip on Low lui 011

T Pressure er o s juresne ston valve uosure) inoperable, tTe ' noperapie enannel must be placed in the one channel trip condition within 6 hours. If placed in the tripped Tns. AAM condition, this results in a partial trip condition 4 % S,e requiring only one additional channel to initiate a reactor:

4,D y trip. If the channel cannot be restored to OPERABLE status

      * ""gg or placed in the trip conditica, then power must be reduced below the P-9 setpoint within the next 4 hours. The 6 hours j

M "" allowed to place the inoperable channel in the tripped f condition mna sne s haue< a r - -- -, == ----- arau h; . 8P**%'f

f- '

justified'nReference7.g C~b TY The Required Actions have been modified by a Note that allows placing the inoperable channel in the bypassed condition for up to 4 hours while performing routine

 .-                           surveillance testing of the other channels. The 4 hour time TS$ EAT G                 limit is justified in Reference 7.

HEW MM 0.1 and 0.2 P Condition Q applies to the SI Input from ESFAS reactor trip and the RTS Automatic Trip Logic in MODES I and 2. These actions address the train orientation of the RTS for these Functions. With one train inoperable, 6 hours are allowed to restore the train to OPERABLE status (Required Action Q.1) or the unit must be placed in MODE 3 within the ACTIONS 0.1 and 0.2 (continued) next 6 hours. The Completion Time of 6 hours (Required Action Q.1) is reasonable considering that in this (continued) WOG STS B 3.3-48 Rev 1, 04/07/95 l

l

                                                ~2.XL CHAPTER 3.3 INSERT G
                                 .TO STS BASES PAGE B 3.3-48 NEW FNP ITS RTS CONDITION P FOR TURBINE TRIP THROTTLE VALVE CLOSURE FUNCTION P.1 and P.2 Condition P applies to the Turbine Trip on Throttle Valve Closure Function. With one or more channels inoperable, each inoperable channel must be placed in the trip condition within 6 hours.

Since all the valves must be tripped in order for the reactor trip signal to be generated, it is acceptable to place more than one Turbine Throttle Valve Closure channel in the tripped condition. If a channel cannot be restored to OPERABLE status or placed in the trip condition, ' then power must be reduced below the P-9 setpoint within the next 4 hours. The 6 hours allowed to place each inoperable channel in the tripped condition is justified in Reference 7. The additional 4 hours for reducing power is reasonable based on operating experience. 1 3' O Q-I i Chapter 3.3 Insert Page

i h7 flTS Instrumentation B 3.3.1 BASES

      " $ 5 'ed>        s.      io crR so. . 6 O

6. 4 RTS/ESFAS Setpoint Methodology Study. h F5ANTA\e 7. CEAP-lo271-P-A, Supplement 2,Rev.1. June 199

*'I

s. i e 6chnical Requirements Manual, Section is, nespons t

9. Rn %c4dnd 5 54sm 3 beu.ci)b (Path- A-@oo7 to. wcAP tagss, mea;.m sied sew 4.c cass) 11 WCAP L390 7/i1ses s.t A k W of. Fed m4er h Plow MgvA M bm4.M.w4 mss it.

T.ceph M. F.Aty Hudear Pow.c Pl.~4 un4 US WeuWs, LiAiMeins +~4 Setp.irls - - Vy 5 jP , 0 2f*hl*YT (u-no9ez.). v +r S' l VJCAP-loMI, " Ew.lv.h of Surveiliw F$veMes 4 od 4 Sphe %es L 4he Reub Pr.b4,hn InskmenMean %54em J' wA supple 4s to4kd <er v4 as appv.,ved W % . Net. - A doc e edsJ in 4be sc o

                               & SSER. (ls#ers 4a xx skepp ,.J %

Cec;l o, h as aded Februvy 2i,1935,- Agte A, NcM. A ck des E. Roa; 4 4.J 5,bn,q r.2.,193'i; 4 6 ward T: 6occl$

                                .py c,wh er, Rossi J.Aed y.) 30, I990).

cts 8*M5 f*$' O D (. WOG STS 8 3.3-60 Rev 1, 04/07/95 ! . I

1 Associated Package Changes for RAI- 3.3.1-4 1

o 1-FNP TS Conversion Enclosure 2 - Discussion of Changes to CTS Chapter 3.3 - Instrumentation CTS 2.2 LIMITING SAFETY SYSTEM SETTINGS CTS 3/4.3.1 REACTOR TRIP SYSTEM INSTRUMENTATION FNP ITS 3.3.1 REACTOR TRIP SYSTEM (RTS) INSTRUMENTATION DOC NQ SHE DISCUSSION The deletion of this CTS Action statement guidance is made to conform with the rules of usage and the format and presentation of this information in the STS and does not introduce a technical change. Therefore, this change is considered administrative. 69 A CTS Action statement 11 applies to the low RCS flow RCP breaker trip RTS function. The CTS Action is revised consistent with the corresponding STS Condition. The CTS reference to the Minimum number of channels is replaced with the STS term " Required Channels". In the STS RTS LCO, all Actions Conditions refer to the Required Channels. Since the number of Required Channels in the STS is the same as the FNP minimum number of channels (1 per RCP or RCP breaker) this change does not introduce a technical change. Therefore, this change is considered administrative. 70 L CTS Action statement 11 applies to the low RCS flow RCP breaker trip RTS function and is applicable when one channel is inoperable. The CTS Action is revised consistent with the corresponding STS Condition by the addition of a note which allows the inoperable channel to be bypassed for up to 4 hours for surveillance testing the other required channels. The allowance to bypass an inoperable channel for up to 4 hours is currently applicable to' most RTS functions. The addition of this allowance for the RCP breaker trip function is reasonable considering that this function is only one of 4 diverse RTS functions for initiating a reactor trip on low RCS l flow. In addition, the RCP breaker position trip function like the diverse l RCP bus undervoltage and underfrequency trip functions is an anticipatory l trip. The actual RCS flow provides yet another trip function which is not l anticipatory and is based on the measured RCS flow. Therefore, the addition of the STS allowance to bypass an inoperable channel is acceptable based on the number of diverse functions providing low flow protection, the relatively brief period of time the channel is allowed to be bypassed, and the i low likelihood of an event occurring within this time that would require this particular low flow trip. 71 .M CTS Action 11 for a single inoperable RCP breaker position trip instrument channel on CTS Table 3.3-1 is revised by the addition of a new Action i Chapter 3.3 E2-43-A March,1998

E FNP TS Conversion Enclosure 2 - Discussion of Chanm to CTS , Chapter 3.3 - Instrumemation l i CTS 2.2 LIMITING SAFETY SYSTEM SETTINGS CTS 3/4.3.1 REACTOR TRIP SYSTEM INSTRUMENTATION FNP ITS 3.3.1 REACTOR TRIP SYSTEM (RTS) INSTRUMENTATION DOC N_Q SHE DISCUSSION consistent with the STS. The STS default Action "or reduce power to less than P-7 in 12 houn" (meaning in the following 6 hours in CTS time) is added to CTS Action statement 11 consistent with the corresponding STS Condition. The addition ~of thir STS Action represents a new TS requirement that was not previously specified in the CTS. As this requirement is only applicable if the other Actions are not met and meeting this new Action removes the plant from the applicable Mode for the associated RTS function, the addition of this Action is applicable to FNP. l Thejustification for the less restrictive change associated with reducing ! power to < P-7 versus placing the unit in Mode 3 is provided in DOC 41-L. a With regard to the Completion Time for Required Action M.1, the CTS y1 and STS requirements are identical. With regard to the Completion Time

 'by              for new default Required Action M.2, the STS time of 12 hours is more restrictive than the CTS time of 13 hours. The STS default action time i                  provides 6 hours to reduce power below the level of the RTS function I

applicability if the channel is not placed in trip in the first 6 hours (total time in the Condition - 12 hours). This allowance is reasonable based on l operating experience and taking into consideration the redundant capability I provided by the mmaining OPERABLE channel and the low probability of occurrence of an event during this pc-iod. As such, the proposed addition ofITS Condition M.2 for RCS Bream Position is equivalent to the existing default action for CTS Table 3.3-1 Action 11, which requires entry into i LCO 3.0.3 when Action 11 is not completed within the required time i j period. However, since the total CTS action time to reduce power below ; I the level of the RTS function applicability is 13 hours, versus the STS time of 12 hours, this time duration addition is considered a more restrictive change. l 72 A CTS Action statement 12, applicable to the manual reactor trip function, is revised consistent with the corresponding STS Condition B with the l exception of the Condition B Action to open the RTBs. The STS Action to open the RTBs is part of CTS Action statement 13 which corresponds to STS Condition C and is applicable after Mode 3 is entered. In addition, the ; reference to the minimum channels operable requirement is deleted. The ! number of channels in the minimum and total columns for this function in the CTS is the same. The STS only uses the Required Channels to Chapter 3.3 E2-44-A May,1999 , i 1 1

O RTS Instrumentation B 3.3.1 p93'p,4 _ _ W.& Aee*F6' ~ 4 BASES Rcp % pf,4.g es N RPbeh/ The Required Actions have been modified by a e that P,5A% h,4hw allows placing the inoperable e.annel in the l bypassed gga condition for up tc 4 hours while performing ou ne surveillance testing of the other channels. 4 hour time l

     "*iO N *"               limit is justified in Reference 7.$
     %s tweber oF
     % A%

Y f previa,3 6 FW N. and N.2 F* "e Condit N applies to the Reactor Coolant Flow- L M'vd 1 W (Single L reactor trip Function. With one ci nel p o.k 4 G we 4 e o' inoperable, inoperable channel must be pla in trip Cyg ;, gg within 6 hours. If the channel cannot be ri ored to OPERABLE status o he channel placed in p within the

      -h be, byPM            6 hours, o,4 Ae, tow           then THERMAL POWER aus            reduced          the P-8 setpoint g.ggy g,              within the next 4 hours.          his pl     s the unit in a MODE where the LC0 is no longer            1    ble. This trip Function
      '8M    ett M$

sb % .We does not have to be OPERABLE other RTS trip Functions p ide ow the P-8 setpoint because re protection below the

 '     g         g           P-8 setpoint. The 6 ho            allowed      restore the channel to OPERABLE statu: or p1           in trip and        4 additional hours rugh N'              allowed to reduce              L POWER to bel        e P-8 setpoint ybAv W               are justified in eference 7.

The Requir ctions have been modified by a No that allows p ing the inoperable channel in the bypas condi n for up to 4 hours while performfag routine

          'W F lQ g          su       11ance testing of the other channels. The 4 hour              me 1

it is justgied in Reference 7. 14 TSTP-l(,9 Condition 0 applies to the RCP Breaker Position (Single Loop) ry c or trip Function. There is one breaker position )

                          ; m yer RCP breaker. With one channel inoperable, the                          ,

inoperable channel must be restored to OPERABLE status - i within 6 hours. If the channel cannot be restored to OPERABLE status within the 6 hours, then THERMAL POWER aust be reduced below the P-8 setpoint within the next 4 hours. ! ACTIONS 1a (continued) This places the unit in a MODE where the LC0 is no longer applicable. This Function does not have to be OPERABLE (continued) W0G STS B 3.3-47 Rev 1, 04/07/95

is a res4ene. It, be, be an ops <*Aq t.xPh

       , e    otAeM g N.t. k k/

power d W RTS Instrumentation fre ,wer B 3.3.1 BASES T-C bel the P-8 setpoint because other RTS Functions provide h3'h core p to restore tion below the P-8 setpoint. T e 6 hours allowed channel to OPERABLE status ana tre1 h 4 additional h rs allowed "he P-8 setpoin', toinreduce re : ustifian marme==e* THERMALpER to i>elow g// g y "he Required Ac" ions liave been modified by a Note that allows placing the inoperable channel in the bypassed FNP condition for up to 4 hours while perfoming routine surveillance testing of the other channels. The 4 hour time ! limit is justified in Reference 7. { g _, Ts>TV-Ut *5 Condi n B a > plies Turbine Trip on Low lui 011

      . {T3(,,-       Pressure er v i mreine ston valve uosure)                 one chan'nel inoperable, t te ' noperapie enannel must be placed in the trip condition within 6 hours.          If placed in the tripped condition, this results in a partial trip condition requiring onlyl one additional channel to initiate a reactor trip. If the channel cannot be restored to OPERABLE status or placed in the trip condition, then power must be reduced below the P-g setpoint within the next 4 hours. The 6 hours allowed to place the inoperable channel in the tripped condition and the 4 hours allowed for reducing power are justified in Reference 7.

The Required Actions have been modified by a Note that l C73C~b allows placing the inoperable channel in the bypassed ) condition for up to 4 tours while performing routine i surveillance testing of the other channels. The 4 hour time IS$E#J G limit is justified in Reference 7. hW h 0.1 and 0.2 P Condition Q applies.to the SI Input from ESFAS reactor trip and the RTS Automatic Trip Logic in MODES 1 and 2. These actions address the train orientation of the RTS for these. Functions. With one train inoperable, 6 hours are allowed to restore the train to OPERABLE status (Required A: tion Q.1) or the unit must be placed in MODE 3 within the ACTIONS- 0.1 and'0.2 (continued) next 6 hours. The Completion Time of 6 hours (Required Action Q.1) is reasonable considering that in this (continued) WOG STS B 3.3-48 Revi,04/07/95

I i Associated Package Changes for RAls - 3.3.1-5,3.3.1-6, and 3.3.1-7

I i l

FNP TS Conversion - Enclosure 2 - Discussion of Changes to CTS Chapter 3.3 - Instrumentation 1 CTS 2.2 LIMITING SAFETY SYSTEM SETTINGS L CTS 3/4.3.1 REACTOR TRIP SYSTEM INSTRUMENTATION 1 1 FNP ITS 3.3.1 REACTOR TRIP SYSTEM (RTS) INSTRUMENTATION l DOC L NA SHE DISCUSSION 3.3-1 and the reassignment of Action 14 to this new function are made only to facilitate the separation of the RTBs fmm the trip mechanisms for l impmved clarity and are considered administrative changes. 47 M The RTB and Automatic Trip Logic functions on CTS Table 3.3-1 are revised by the addition of a new Action Condition (V) consistent with the STS. The STS Condition "Two RTS trains inoperable, enter LCO 3.0.3 immediately" is added to the RTS LCO due to the conventions of Actions ! Condition entry used in the STS. In the STS, multiple conditions of an LCO may be entered separately and result in a plant degradation or loss of function that is beyond what the individual Actions Condition were intended to address. In STS LCOs where the entry into multiple Conditions creates a degradation or loss of function that is not adequately addressed by l the individual Conditions, a separate Condition requiring entry into LCO l 3.0.3 is used to specify the appropriate Action. In the RTS, two functions ) l exist that address the reactor trip actuation trains and each function has a different Condition that may be applicable at the same time. These functions have been identified in the STS as having a potential problem ! concerning multiple condition entry. Ifmultiple entries into these reactor trip actuation train Conditions results in inoperabilities in both RTS trains at the same time, the immediate Action, which would be appropriate and should be required, is not included in any of the individual reactor trip actuation component Conditions that may be applicable. Since the RTS l LCO contains an Action for each potential inoperability, LCO 3.0.3 may 1 technically not be applicable even though a critical function may be lost. ; Therefore, the STS has included a specific Condition (V) requiring immediate LCO 3.0.3 entry in the event both RTS trams become inoperable for any reason. This Condition is associated with the reactor trip actuation i train functions listed on Table 3.3.1-1. Although the introduction of this i additional STS Action is reasonable and appropriate for FNP, it represents a new technical specification requirement that was not present in the CTS and is therefore considered a more restrictive change. i 48 A The RTB RTS function on CTS Table 3.3-1 is revised by the addition of a footnote consistent with the STS. - An STS footnote is added to modify the RTB function itself. The footnote which states that the RTB function

     *   , Chapter 3.3                                 E2-30-A                                    March,1998 i

FNP TS Conversion Enclosure 2 - Discussion of Changes to CTS Chapter 3.3 - Instrumentation CTS 2.2 LIMITING SAFETY SYSTEM SETTINGS CTS 3/4.3.1 REACTOR TRIP SYSTEM INSTRUMENTATION FNP ITS 3.3.1 REACTOR TRIP SYSTEM (RTS) INSTRUMENTATION DOC NQ SHE DISCUSSION l includes "any reactor trip bypass breaker that is racked in and closed for bypassing an RTB" is intended to ensure that the RTB function and y4 therefore the RTS LCO clearly includes the bypass breaker when it is in i use. As the bypass leesker is not an individual function on the Table the addition of this note t.s necessary to avoid potential confusion regarding the RTS LCO requirements for two tmins of RTB function when operating with a RTB bypass breaker racked in. Although this is a change to the CTS, it represents a clarification that is consistent with the intent of the CTS. The addition of this note incorporates a basic interpretation that allows the use of the bypass breakers in the CTS into the RTS LCO reqmrement for the RTBs. As this interpretation is necessary to meet the LCO requirement for , the RTDs and is used with or without the STS note, this change is considered administrative.

      ~49        A    The CTS Table 3.3-1 Table Notation is revised by the addition of various STS Notes which modify the functions listed on the CTS Table. The notes modify the function itself, or the applicability or Actions listed on CTS Table 3.3-1 for each function. As each new note may affect more than one function, applicability, or Action, the application of each note 'and the affected function (s) is detailed in the Enclosure 1 markup of the RTS functions on CTS Table 3.3 1. The addition of the new STS notes and their technical impact are discussed in the DOCS associated with the changes made to each affected RTS function, applicability or Action on CTS Table 3.3-1. Therefore, the listing of the new STS notes in the LCO is considered an administrative change made to conform with the presentation and format of the STS.

50 A The

footnote used in CTS Table 3.3-1 is revised consistent with the corresponding note in the STS. The CTS footnote is applied to various function applicabilities and modifies the applicability to include the l condition with the RTBs closed, the control rod drive system capable of rod l

                     - withdrawal, and fuel in the reactor vessel. The STS note is effectively the      i same but does not include the phrase "and fuel in the reactor vessel". In the STS, this note is used to modify Modes 3,4, and 5 for certain functions. As the STS includes " fuel in the vessel" as part of the definition of~ MODE, the inclusion of this phrase in the STS note, which serves only to modify a Chapter 3.3                                 E2-31-A                                      May,1999 j

W

n FNP TS Conversion Enclosure 2 - Discussion of Changes to CTS Chapter 3.3 - Instrumentation CTS 2.2 LIMITING SAFETY SYSTEM SETTINGS CTS 3/4.3.1 REACTOR TRIP SYSTEM INSTRUMENTATION FNP ITS 3.3.1 REACTOR TRIP SYSTEM (RTS) INSTRUMENTATION DOC NQ SHE DISCUSSION operating experience and taking into consideration the r*adant capability provided by the remaining OPERABLE channel and the low probability of occurrence of an event during this period. As such, the proposed addition- 1 ofITS Condition M.2 for RCS Breaker Position is equivalent to the existing default action for CTS Table 3.3-1 Action 11, which requires entry into LCO 3.0.3 when Action 11 is not completed within the required time period. However, since the total CTS action time to reduce power below the level of the RTS function applicability is 13 houn, versus the STS time of 12 hours, this time duration addition is considetui a more restrictive change. 72 A CTS Action statement 12, applicable to the manual reactor trip function, is revised consistent with the corresponding STS Condition B with the exception of the Condition B Action to open the RTBs. The STS Action to open the RTBs is part of CTS Action statement 13 which corresponds to STS Condition C and is applicable after Mode 3 is entered. In addition, the reference to the minimum channels operable requirement is deleted. The number of channels in the minimum and total columns for this function in the CTS is the same. The STS only uses the Required Channels to determiue when the Action is applicable and the STS Required Channel is derived from the CTS total number of channels. Therefore, there is no difference between the use of the STS Required Channels (CTS total channels) and the Action statement 12 reference to the minimum channels operable. The deletion of the reference to the minimum channels operable requirement does not change the technical requirements of this Action, and is made to conform with the presec.tation and format of this information in I the STS. Therefore, this change is considered administrative. 73 A CTS Action statement 13, applicable to reactor trip actuation trains (manual , and automatic) and trip breakers, including the diverse trip mechanisms, is l revised consistent with the corresponding STS Condition C. The Action : l 0 /\ statement is revised to address trains as well as channels as the actuation h,Y logic addressed by the Action is commonly referred to as trains. This change is made to more accurately reflect commonly used terminology and I j is not intended to be technical. In addition, the reference to the minimum channels operable requirement is deleted. The number of channels in the Chapter 3.3 E2-45-A Mey,1999 i

FNP TS Conversion Enclosure 2 - Discussion of Changes to CTS Chapter 3.3 - Instrumentation CTS 2.2 LIMITING SAFETY SYSTEM SETTINGS CTS 3/4.3.1 REACTOR TRIP SYSTEM INSTRUMENTATION FNP ITS 3.3.1 REACTOR TRIP SYSTEM (RTS) INSTRUMENTATION i DOC

N_Q SHli DISCUSSION: minimum and total columns for the functions associated with this Action in the CTS is the same. The STS only uses the Required Channels to determine when the Action is applicable and the STS Required Channel is derived from the CTS total number of channels. Therefore, there is no difference between the use of the STS Required Channels (CTS total channels) and the Action statement 13 reference to the minimum channels l operable. The deletion of the reference to minimum channels operable {

requirement does not change the technical requirements of this Action, and is made to confomt with the presentation and format of this information in the STS. Therefore, the changes discussed above are considered administrative. 74 A CTS Action statement 14, applicable to the undervoltage and shunt trip mechanisms, is revised consistent with the STS. The statement in this CTS Action, "the breaker may be considered operable..." is deleted consistent with the STS. In the CTS, this Action is associated with the RTB RTS function and this statement is a necessary clarification. In the STS, this Action is associated with a separate individual RTS function for the diverse trip mechanisms. As a separate line item RTS function, the operability of l the diverse trip mechanisms may be considered separately from the RTBs. ' Therefore, in the STS the clarification provided by the CTS statement is not required. Additionally, the CTS requirement in Action 14 to declare the ! RTB inoperable and apply Action 1 is replaced with the STS requirement to be in Mode 3 in the following 6 hours. The STS requirement to be in Mode 3 in 6 hours is effectively the same as declaring the RTB inoperable and ! applying Action statement 1. Action statement I simply requires the plant to be placed in Mode 3 in 6 hours. As such the changes discussed above are made to conform with the format and presentation of this information in the STS and do not introduce a technical change. Therefore, these changes are considered administrative. 75 A CTS Action statement 14, applicable to the undervoltage and shunt trip { mechanisms, is revised, where appropriate, to be consistent with the STS. l The last sentence of this Action statement contains an allowance to bypass an RTB for maintenance on an inoperable undervoltage or shunt trip l gYg/7 mechanism. This allowance is revised into the typical STS Note form and chapter 3.3 E2-46-A May,1999

FNP TS Conversion Enclosure 2 - Discussion of Changes to CTS Chapter 3.3 - Instrumentation CTS 2.2 LIMITING SAFETY SYSTEM SETTINGS CTS 3/4.3.1 REACTOR TRIP SYSTEM INSTRUMENTATION FNP ITS 3.3.1 REACTOR TRIP SYSTEM (RTS) INSTRUMENTATION l DOC L N.Q SHE DISCUSSION l placed as a Note in the Condition U Actions. The CTS bypass allowance is revised editorially to conform with the presentation of this type of note in the STS. The placement of this bypass allowance in the Actions Condition which addresses the undervoltage or shunt trip mechanism function being f bypassed is consistent with CTS Table 3.3-1 Action 14 and the organization L 4($ of these notes in other STS Conditions. The technical intent of the CTS bypass allowance is not changed, and the revisions discussed above are l made to conform, where appropriate, with the organization and presentation of this information in the STS. Therefore, these changes are considered admmistrative. 76 M The RTB bypass provision of CTS Action statement 14, applicable to the undervoltage and shunt trip mechanisms, is revised consistent with the STS. The allowance to bypass an RTB for maintenance on the undervoltage and shunt trip mechanisms is revised by the addition of the STS requirement I I that stipulates "provided the other train (RTB) is operable". This additional requirement provides assurance that one RTB train remains operable when the provision to bypass an RTB train is used. Although this STS requirement is a reasonable and pmdent precaution, that is obviously applicable to FNP, it represents a new TS requirement not present in'the CTS. Therefore, the addition of this STS requirement is considered more restrictive. 77 A CTS Action statement 15, applicable to the SI input and automatic actuation logic functions, is revised consistent with the STS. The use of the word ! " channel" is replaced by the STS term " train". The use of train instead of , channel more accurately describes the design of the affected RTS functions (two trains of SI and two trains of RTS automatic actuation logic). The use of the STS term for these functions does not introduce a change to the technical intent of the CTS. The reference to the minimum channels operable requirement is revised to the STS Required Channels. Since the number of channels specified remains unchanged, this change is made only to conform with the STS terminology for the RTS function requirements. l ! Additionally, the provision of CTS Action 15 to bypass one channel (train) is revised into a note form in the applicable Condition consistent with all , l such bypass pmvisions in the STS. The conversion of this CTS provision Chapter 3.3 E2-47-A May,1999 ; l l l

e 27J aTS Instrumentation 3.3.1 ACTIONS (continued) CONDITION REQUIRED ACTION COMPLETION TIME R. One RTB train --

                                ---------NOTE           -----------

inoperable. . One train may be bypassed for up to 2 hours for surveillance testing, provided the other train is OPERABLE. keRTBmay ypass dc (for up to z nours for govs 4* p\ maintenance on undervoltage o unt

                                                                      . -      4 CMMM trip mechanis               provided     ,

the other trai is ) (OPERABLE.

R.1 Restore train to I hour OPERABLE status, h g g[{ R.2 Be in MODE 3. 7 hours f S. One# channels S.1 Verify interlock is I hour inoperable, in required state for existing unit conditions. E S.2 Be in MODE 3. 7 hours (continued) I

WOG STS 3.3-8 Rev 1, 04/07/95

h RTS Instrumentation 3.3.1

ACTIONS (continued) CONDITION f orenorE REQUIRED ACTION COMPLETION TIME T. One channels T.1 Verify interlock is I hour inoperable. in required state for existing unit conditions. E 9 I T.2 Be in MODE 2. 7 hours G - he U. One trip mechanism U.1 Restore inoperable 48 hours C.,44,3 inoperable for one trip mechanism to RTB. OPERABLE status. E U.2 Be in MODE 3. 54 hours

                                ?hND
                                  . 2.2   Open RTB. N          h5 hour V. Two RTS trains         V.1       Enter LCO 3.0.3.       Immediately inoperable.

WOG STS 3.3-9 Rev 1, 04/07/95

I RTS Instrumentation 3.3.1 Table 3.3.1 1 (pose 6 of 8)

         $                              g}         Reactor Trip System Instrumentation 1                                     APPL!bLEMODES OR OTHER jg i

g*} SPECIFIED REQUIRED SURVEILLANCE ALLOWABL TRIP bOlb FUNCTION CONDITIONS CHANNELS CONDITIONS REQUIREMENTS VALUE SE IN (Q,,) l D 19. Reactor 1,2 2 trains R,V 3.3.1.6 NA NA l g Breakers

      @                              3 b,4       ,5        2 treins         C, V      SR 3.3.             NA           NA

20. Reactor Trip ,2 1 each U SR 3.3.1.4 NA NA Brooker per RTB l Undervottese and Sh et Trip 3 ,4 ,5 1 each C SR .4 NA NA Mechanisms per RTB 10 M 21 Automatic Trip 1,2 2 trains e,Y 3.3.1.5 NA NA Logic g

           ,h                        3   ,     b,5         2 trains         CVj       SR 3.3.1.5          NA           NA
                                                                                                                           - i a) Reviewer's Notes unit spectric taptementations may contain only Allowable Vetue depending on Setpoint ] Study methadology used by the mit.

h ith RTBs closed and Red Controt System ca Q)hncludineanyreactortripbypassbre.ke[pableofrodwithdrawet. h.t

                                                                     . eked in and closed for bypassine en RTs.        I7

[ h@

1 WOG STS 3.3-20 Rev 1, 04/07/95

1 FNP TS Conve sion Enclosure 5 - JD from STS Chapter 3.3 - Instrumentation STS 3.3.1 REACTOR TRIP SYSTEM (RTS) INSTRUMENTATION i FNP ITS 3.3.1 REACTOR TRIP SYSTEM (RTS) INSTRUMENTATION JD NUMBER JUSTIFICATION the correspondmg Action requirements of the CTS for the turbine trip RTS i functions. The STS Conditions following the new FNP ITS Condition P are re-lettered accodrigly to account for the addition of the new FNP specific Condition (note that TSTF-169 deleted Condition N and re-lettered all subsequent Conditions). The STS Condition O is revised to apply only to the FNP low auto j stop oil pressure turbine trip and is effectively consistent with the corresponding CTS Action statement 7. A new Condition is required for the FNP throttle valve closure RTS function as the STS Condition O assigned to this function does not allow for more than one inoperable channel. The CTS Action statement number 6, applicable to the throttle valve closure RTS function, effectively allows for multiple inoperable channels in this function. The FNP throttle valve closure trip function requires 4-out-of-4 throttle valves to be closed to initiate a reactor trip. Therefore, if more than one channel (throttle valve position) becomes inoperable the CTS

         ' allows the inoperable channels to be placed in trip. In addition, the turbine trip / reactor trip is an anticipatory trip and is not assumed to operate in any design basis accident analyses described in FSAR Chapter 15. Therefore, an FNP specific ITS Condition P has been added to the FNP ITS to incorporate the CTS Action              :

allowance for more than one inoperable channel in the turbine trip throttle valve closure RTS function. The proposed FNP specific Condition P contains the CTS Action requirement (6) which is revised in format and presentation to be consistent with the corresponding STS Condition for the turbine trip / reactor trip functions. The FNP ITS specific Condition P also provides a default Action consistent with the applicability of this function (or reduce power below P-9) the same as the corresponding STS Condition for the turbine trip / reactor trip functions. Below P-9 this function is no longer required. The Completion Times provided in the proposed FNP ITS Condition are consistent with the Completion Times of the corresponding STS Condition for the turbine trip / reactor trip functions. In addition, the proposed FNP specific Condition P does not contain a note that would provide an allowance to bypass an inoperable channel for testing. The exclusion of this note in the proposed FNP ITS Condition is based on the exclusion of this allowance in the corresponding CTS Condition and in WCAP-10271. Therefore, FNP ITS Conditions O and P are used in place of CTS Action statement 6 and 7 for the turbine trip RTS functions. These changes are made to maintain consistency with the FNP current licensing basis as specified in the CTS and with the provisions and y/) format of the ev.w+nding STS Condition for the turbine trip / reactor trip

  *y        functions.

7 STS Condition R, which applies to the RTB Trains, contains two notes. Note 2 allows a given RTB to be bypassed for maintenance on an inoperable undervoltage N=e 3.3 E5-3-A May,1999 i

i FNP TS Conversion Enclosure 5 - JD from STS Chapter 3.3 - Instrumentation STS 3.3.1 REACTOR TRIP SYSTEM (RTS) INSTRUMENTATION FNP ITS 3.3.1 REACTOR TRIP SYSTEM (RTS) INSTRUMENTATION JD NUMBER JUSTIFICATION or shunt trip mechanism for up to 2 hours if the other RTB train is operable. The proposed ITS deviations from STS revise and relocate Note 2 to be consistent with the current Farley design and licensing basis as reflected in the last sentence of CTS Table 3.3-1 Action 14. First, Note 2 is revised by deleting the explicit time duration for bypass because CTS Table 3.3-1 Action 14 includes no specific time duration. The unrestricted bypass allowance is provided to give sufficient time to accomplish corrective maintenance. However, the expectation is that such maintenance would be accomplished in a timely manner, and the explicit CTS requirement is that affected r RTB would only be bypassed during actual maintenance activities. The technical f[ 4 basis for this allowance is found in NRC Generic Letter 85-09," Technical I Specifications For Generic Letter 83-28, Item 4.3." Based on the current licensing j basis as approved in Technical Specifications Amendment Nos. 67 (U1) and 59 (U2), the exclusion of the 2 hour bypass allowance is acceptable. Second, minor editorial changes are incorporated in STS Condition R Note 2. These changes clarify that the bypass allowance applies only to one of two diverse trip mechanisms associated with a given RTB when the other RTB Train is Operable. Third, STS Condition R Note 2 is relocated to ITS Condition U based on the following. STS Condition R pertains to the RTB Trains. However, Note 2 is directly applicable to the undervoltage and shunt trip mechanisms, which are the portions of the RTB Trains excluded from STS Function No.18. The diverse trip mechanisms are listed as STS Function No.19, which utilizes STS Condition U. Because Farley listed the undervoltage and shunt trip mechanisms as a new ITS Functional Unit to conform to STS and CTS Action 14 applies directly to these diverse trip mechanisms, Note 2 must be relocated to ITS Condition U. These ITS deviations from the STS assure that the Farley licensing basis for CTS Table 3.3-1 Action 14 is retained consistent with the Farley design. 7a The FNP ITS Conditions S and T for the RTS interlocks are revised consistent with the allowance of the corresponding CTS Action statement 8. The CTS Action , identified several instrument functions associated with each interlock function and did not limit the inoperability addressed by the interlock Action to a single channel. The CTS Action simply addressed an inoperable interlock function. The CTS Action would address more than one inoperable channel identified for each l

    < Chapter 3.3                                 E5-4-A -                                      May,1999    i L                                                                                                            i

i FNP TS Conversion Enclosure 5 - JD from STS Chapter 3.3 - Instrumentation STS 3.3.1 REACTOR TRIP SYSTEM (RTS) INSTRUMENTATION FNP ITS 3.3.1 REACTOR TRIP SYSTEM (RTS) INSTRUMENTATION JD NUMBER JUSTIFICATION interlock if multiple inoperable channels resulted in an inoperable interlock function. Therefore, the STS interlock Conditions are revised consistent with the intent of CTS Action statement 8 to address "one or more inoperable channels". The STS interlock Conditions contain Required Actions which are intended to address an inoperable interlock function and which have a sufficiently short Completion Time (1 hour) to address more than a single inoperable channel. The relatively short Completion Time of the STS Action corresponds to the intent of the CTS Actions for an inoperable interlock which is to address an interlock that is inoperable to the extent that a reactor trip which should not be blocked in the current Mode is blocked. In a condition where a reactor trip is blocked which should not be blocked, the number ofinoperable channels involved with the affected interlock is not as significant as the requirement for quick action to restore the affected reactor trip function. The STS Condition for an inoperable interlock contains a sufficiently short Completion Time (1 hour) that provides an adequate restriction on plant operation when a reactor trip is blocked which should not be blocked. Therefore, this change maintains the FNP current licensing basis as specified in the CTS Action and implements the STS format for that Action. 7b STS footnote (k) for RTS Table 3.3.1-1, which is ITS footnote 0), is revised based j on FNP design. The RTS Reactor Trip Breaker (RTB) configuration employs two j trip breakers connected in series; each RTB, including its associated trip j mechanisms, is assigned to a specific protection system train (i.e., Train A and , Train B). Each trip breaker can be electrically bypassed using a Bypass Trip ! Breaker. The bypass breaker trip mechanisms are assigned to the opposite _ protection system train. Two diverse design features prevent bypassing both P protection system trains. First, the bypass breakers are provided with intemal 4\ electrical interlocks that will trip both bypass breakers "open" via their shunt trip T mechanisms should an operator inadvertently close the second bypass breaker with j both bypass breakers " racked in" to the " connect" position. Second, the SSPS General Warning Alarm circuits will initiate a trip signal via the undervoltage trip i mechanisms for each trip and bypass breaker should both bypass breakers be

                    " racked-in" to the " connect" position and " closed." Therefore, by design the RTS Bypass Trip Breakers can not be simultaneously " racked-in" and " closed." As such, Farley ITS Table 3.3.1-1, footnote 0) is revised to reflect the Farley design feature   ;

that only allows a single bypass breaker to be bypassed and closed. 8' The FNP ITS Condition U addressing the Required Actions for one RTB trip mechanism (undervoltage or shunt) inoperable is revised consistent with the CTS. This STS Condition requires restoration of the function in 48 hours or be in Mode 3 . Chapter 3.3 ES-5-A May,1999 l

FNP TS Conversion Enclosure 5 - JD from STS Chapter 3.3 - Instrumentation STS 3.3.1 REACTOR TRIP SYSTEM (RTS) INSTRUMENTATION FNP ITS 3.3.1 REACTOR TRIP SYSTEM (RTS) INSTRUMENTATION JD NUMBER JUSTIFICATION in the following 6 hours (54) and open the RTBs in the following hour (55). STS Required Action which specifies that the RTBs be opened in 55 hours is deleted. Condition U is applicable to the Reactor Trip Breakers in Modes 1 and 2. Once Mode 3 is entered, the Modes of applicability are exited. The corresponding CTS Action statement number 14 allows 48 houn to restore the inoperable trip p mechanism or declare the RTB inoperable and apply Action 1, which results in h,\,1 being in Mode 3 in the next 6 hours. CTS Action 14 does not contain the T requirement to open the RTBs. Once in Mode 3, CTS Action statement number 13 is applicable rand allows an additional 48 hours to restore the inoperable channel to operable status or requires that the RTBs be opened in the following hour. The Mode 3 CTS Action statement 13 cormsponds to STS Condition C. The proposed change to the STS Condition for the RTB trip mechanisms allows the STS . Conditions for the RTB trip mechanisms (Modes 1 and 2) and (Mode 3) to work togetherin the same manner as CTS Actions 14 and 13. The additional 48 hours allowed by CTS Action 13 (and STS Condition C) once the plant is in Mode 3 is reasonable considering the remaining operable trip mechanism on the affected RTB, the other fully operable RTB, and the fact that the plant is shutdown. Therefore, this change to the STS is justified and maintains consistency with the current FNP licensing bases as documented in the CTS. Sa STS SR 3.3.1.1 is revised by the addition of a note consistent with the FNP specific CTS note 7 on Table 4.3-1 for the source range instrumentation channel check surveillance requirement. STS SR 3.3.1.1 requires a channel check be performed every 12 hours and is the corresponding surveillance in the ITS for which CTS note

             ' 7 is' applicable. The FNP CTS note added to STS SR 3.3.1.1 is revised to be more consistent with the standard STS format for such notes. The CTS note provides a 1 hour allowance for performing this surveillance on the source range instrumentation sAer power is reduced below the P-6 interlock. The note provides a reasonable time to perform this surveillance on the source range instrumentation after entering the applicable Mode (< P-6) and after a shutdown transient, such as a reactor trip, which places the plant in Mode 3 without time to perform this SR prior to entering    ,

the applicability. Therefore, this Note provides an allowance necessary to prevent i immediate noncompliance with the source range channel check SR requirement after a transient such as a reactor trip. Considering the brief time provided by the note and the fact it would ensure compliance with the channel check surveillance in i the event of an unplanned transient, the addition of this CTS note is acceptable. In addition, the inclusion of this note in the FNP ITS maintains the FNP current ; licensing basis as specified in the CTS. j i Chapter 3.3 E5-6-A May,1999 l I

R 770 RTS Instrumentation B 3.3.1 SASES declared inoperable under Function above. OPERABILITY of both trip mechanisms n each breaker ensures that no single trip mechanism failure will prevent opening any breaker on a valid signal. YTiesetripFunctionsmustbeOPERABLEinMODE1or2. E Union the reactor is critica Q In MODE 3, 4, or 5, these RT rip tunctions must be OPERABLE when the of RTB ssociated bypass breakers are closed, and p the C System is capable of rod withdrawal.

21. Automatic Trio looic The LCO requirement for the RTBs ( ions nd and Automatic Trip Logic (Function nsures that means are provided to interrupt the power to allow the rods to fall into the reactor core. Each RTB is equipped with an undervoltage coil and a shunt trip coil to trip the breaker open when needed. Each RTB is equipped with a bypass breaker to allow testing of the trip breaker while the unit is at power. The reactor trip signals generated by the RTS Automatic Trip Logic cause the RTBs and associated bypass l breakers to open and shut down the reactor. %

A The LCO requires two trains of RTS Automatic Trip f Logic to be OPERABLE. Having two OPERABLE cnanne 5 9\ f\ y ,Y ensures that random failure of a single logic 4;Fannep" will not prevent reactor trip. 1 ! APPLICABLE Automatic Trio Loaic (continued) SAFETY ANALYSES V LCO, and These trip Functions must bpm PERABLE in MODE 1 or 2 APPLICABILITY h timen the raetor is critica] In MODE 3, 4, or 5, Theso RTSW rip Functions must be OPERABLE when the RTBsramp associated bypass breakers are closed, and the CRD System is capable of rod withdrawal. The RTS instrumentation satisfies Criterion 3 of the NRC Policy Statement.

ACTIONS A Note has been added to the ACTIONS to clarify the application of Completion Time rules. The Conditions of (continued) WOG STS B 3.3-37 Rev 1, 04/07/95

373 RTS Instrumentation B'3.3.1 BASES 1 Condition, the remaining OPERABLE train is adequate to I perform the safety function and given the low probability of an event during this interval. The Completion Time of 6 hours (Required Action Q.2) is reasonable, based on operating experience, to reach MODE 3 from full power in-an orderly manner and without challenging unit systems. The Required Actions have been so f d by a Note that allows bypassing one train up to 4 hours for surveillance g testing, provided the other trai is OPERABL j fq Amh46 presalsA 'a W Jeve n* 7 a 7 W & c fied. [ R.1 and R.2 * +4P Condition R applies to the Bs in MODES 1 and 2. These - actions' address the train rientation of the RTS for the l RTBs. With one train in erable, I hour is allowed to restore the train to OPE BLE status or the unit must be placed in MODE 3 within he next 6 hours. The Completion Time of 6 hours is reas nable, based on operating i experience, to reach E 3 from full power in an orderly manner and without cha'lenging unit systems. The 1 hour and 6 hour Completion Time i are equal to the time allowed by LCO 3.0.3 for shutdown actions in the event of a complete loss of RTS Function.VPlacing the unit in MODE 3 removes f; .the requ nt for this particular Function

              .              .                                   w                        /

The Regui Actions have been dified by Note #.' Note 7 al ows one channel to bypassed for up to 2 hour f for surve(11ance fsting, pr ided the other channel is A T&-71 OP ERABLE.pote g aiiv o nin to De oypassea Mb G! nurM gf maintenance on ndervoltage or shunt 4 l Fnecian t4ma l im if the other RTB train is OPFRARI F.I Th (1u s ti' en in unrar maca s.- - NO (TQ Qteis e when the inM)i

         ,   +

DC en oig

                       ,m : w'

Condition m

                                                         .6Ur__

a applies v sne r-v anu r-w interiocu, uusw I_s M *- onex hanne inoperable for one-out-of-two'or two-out four ' colncidenc logic, the associated interlock must be verified to be in its required state for the existing unit condition ACTIONS S.1 and S.2 (continued) / PSE c/rs MILON 8 (continued)

    - WOG STS                                 B 3.3-49                             Rev 1, 04/07/95 L.

l I 375_mm A 3 , RTS Instrumentation P

                                                                         **                                                 AYe . E.#

a/ h /; m ner o m f .

                                                                                                                    / / +W cenA. R With theGtTBs open and the unit in M0)E L Ehis/ friol                                                    %ew, CEC.-b              unction is no io icer rec uired to be OP EMB .EM                                             ~

ecte 4 t us snali not be )ypassec while one of use diverse eatures ( is inoperable except for the time required to )erform b

 %y                      maintenance to one of the diverse features. ITie allowable' 0 ,,      (time for perforumg memtenance or Ine a1 verse features isL L2 hours for the reasons stated under Condition R.                                                _

j e Completion Time of 48 hours for Required Action U.1 is Q%h a[Q;4 gA reasonable considering that in this condition there is one ybg aining diverse feature for the affected RTB, and one BLE RTB capable of performing the safety function and

 "{e.,EY N                g      0 given             e low probabili of an vent occurrin durin th s interval.             gy             g,9 g         g , g g y ,p na y4lk 4 4hc, a&er Merest M mebW 4

g ,J @

l We L g With two w.m u aum.4 4 es Artu*c 4c e u. m. , =

                                                                  +  Ah  iaeMe S trains inopera5Te, na automatic capability is g

gb'* P *g'M available to shut down the reactor, and immediate plant shutdown in accordance with LCO ').0.3 is required.

    & onownt.

SURVEILLANCE The SRs for each RTS Function are identified by the SRs REQUIREMENTS column of Table 3.3.1-1 for that Function. A Note has been added to the SR Table stating that Table 3.3.1-1 determines which SRs apply to which RTS Functions. Note that each channel of process protection supplies both trains of the RTS. When testing Channel I, Train A and Train B must be examined. Similarly, Train A and Train B must be examined when testing Channel II, Channel III, and Channel IV (if applicable). The CHANNEL CALIBRATION and COTS are performed in a manner that is consistent with the assumptions used in analytically calculating the required V channel accuracies. > No Topd r- -

                                                                                                                                  -T Report                Reviewer's Note: Certain Frequencies are based on approval                                                    1
 %vered,               topical reports. In order for a licensee to use these 9yp                   times, the licensee must justify the Frequencies as required by the staff SER for the topical report.                                                                     ;

ZTS ' -)

 @versiOO (continued)

WOG STS B 3.3-51 Rev 1, 04/07/95 l

Sh RTS Instrumentation 8 3.3.1 BASES SURVEILLANCE SR 3.3.1.4 REQUIREMENTS

               -(continued)         SR 3.3.1.4 is the performance of a TADOT every 31 days on a c.Ts r 4la u -l    STAGGERED TEST BASIS. This test shall verify OPERABILITY by
          @ W **                    actuation of the end devices.

[I/Vdhpy) fThe RTB test shall include separate verification of the undervoltagelandsshunt trip mechanisms. Independent MN verification of RTB undervoltage and shunt trip Function is not required for the bypass breakers. No capability is provided for performing such a test at power. The

                                  ' independent test for bypass breakers is included in SR
               %,$gMe 1 pot 6         3.3.1.14. The bypass breaker. test shall include a local' .f 81               shunt trip,. A Note has been added to indicate that this test must be performed on the bypass breaker prior to placing it in service.

The Frequency of every 31 days on a STAGGERED TEST BASIS is 6 adequate. It is based on industry operating experience, y,ha considering instrument iabilit and o erating history V data. g 7g SR 3.3.1.5 SR 3.3.1.5 is the performance of an ACTUATION LOGIC TEST. The SSPS is tested every 31 days on a STAGGERED TEST BASIS, using the semiautomatic tester. The train being tested is placed in the bypass condition, thus preventing inadvertent actuation. Through the semiautomatic tester, all possible logic combinations, with and without applicable permissives, are tested for each protection function. The Frequency of v'gq every 31 days on a STAGGERED TEST BASIS is adequate. It is g '5 y based on inaustry operating expertence, consiaenngy

                      ,y          anstri= ant reliability and oneratina history datV.

g[ sed fAswE To ' SR 3.3.1

e. fret + _

Nmend i SR 3.3.1 s a calibration of the excore channels to the Losedior) incore channels. If the measurements do not agree, the excore channels are not declared 1.ioperable but must be calibrated to agree with the incore detector measurements.

 /                                 If.the excore channels cannot be adjusted, the channels are        i declared inoperable. This Surveillance is performed to verify the f(AI) input to the overtemperature AT Function.

(continued) WOG STS B 3.3-54 Rev 1, 04/07/95 L __..

[7 RTS Instrumentation B 3.3.1 BASES n ed) 5. 10 CFR 50.49. F5AA,Tae

6. 4 RTS/ESFAS Setpoint Methodology Study, h 7, QcAp.iO271-P-A, Supplement 2,Rev.1, June 72.5 8.

echnical Requirements Manual, Section 15, "Responsej [

f . k, R?s McAdnd 's354em besccQb 05th- A-12\m to. wcAP tzatts, reek.m std sekc.be (mss) li WCAP t690 r/r53os e.1,/n k.b of,Feedaler h NW M via.P MbnenfaMow of M55 11. Toceph M. Fu\ey Hudear Power Pl=4- (Mf \ (@ Weqbs, LA.'4 bs M SchoMs - - T p U 2/.Mf7 (u-:rsoqiz.), SE. s/W

                                      \fJCAP- 10271 j     E-vdMM of Surve'ibwd F$vemies 4 OA 4 %<4a Tme6 4 4he                             I i

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                                       % % net. A boe.~eaJ in 4He sez, od SSER.(le#tys 4o II Shepp M b Cec.t o, h s d 4ed Feby 2's1935)

Agu- A. NeM b c.karles fE'. Ross; A 4ed

                                         $~.bev yr /t; 1939 M 6euo.ed T Goerig
                                         .Qrom L % h e.s G

Re SSi N h}t\ N) ,

1990). cT5 6585 f*$8 6 #4 '~ # WOG STS B 3.3-60 Rev 1, 04/07/95 1

l 3N 9 , CHAPTER 3.3 3 ' '13' A INSERT WW 30 TO STS BASES PAGE B 3.3-60 REFERENCES SECTION

13. Westinghouse Technical Bulletin, ESBU-TB-92-14-R1,"Decalibration Effects Of Calorimetric Power Level Measurements On The NIS High Power Reactor Tdp At Power Levels Less Than 70% RTP."

l

14. NRC Generic Letter 85-09, " Technical Specifications For Generic Letter 83-28 [ Required Actions Based On Generic Implications Of Salem ATWS Events), Item 43."

[ Note to Reviewer: Reference 13 was added in SNC Technical Specification Amendment Request transmitted via SNC letter to NRC dated November 6,1998. Reference number may need to be revised ifITS is approved prior to the above amendment request.] i l I i I Chapter 3.3 Insert Page

r- ) i l l 1 Associated Package Changes for RAI- 3.3.1-8 i i i 1 I i

FNP TS Conversion Enclosure 5 - JD from STS Chapter 3.3 - Instrumentation STS 3.3.1 REACTOR TRIP SYSTEM (RTS) INSTRUMENTATION FNP ITS 3.3.1 REACTOR TRIP SYSTEM (RTS) INSTRUMENTATION JD NUMBER JUSTIFICATION 9 Note 2 of STS surveillance SR 3.3.1.2 is revised from the bracketed 12 hours to 24 hours. The cow ponding CTS requirement in note 2 on CTS Table 4.3-1 does not contain a time limit for the performance of this surveillance after 15% power is reached. Therefore, the proposed FNP ITS 24 hour restriction for perfomdng this g[ SR after 15% power is reached provides adequate assurance that the surveillance will be performM in a timely manner while providing a reasonable time in which to complete the surveillance. For a given Farley unit startup at BOL, the initial NIS PR calibration is performed dunng a power ascension hold at about 30% RTP. This practice and the allowance of 24 hours to achieve this power level are acceptable based on the following. Calorimetric calculation results at low power levels can include large uncertainties; therefore, it is desirable to raise power to higher levels where the calorimetric calculations will be more accurate. There are also potential calibration uncertainty effects attributed to the core design; therefore, plant procedures provide preliminary BOL PR calibmtion data for initial startup based on cycle-specific core designs and test data. Performance of the initial NIS calibration must also be coordinated with other unit startup activities, and the power ascension rate is limited when raising power above 20% RTP to ensure pmper fuel preconditioning for new cores and following extended shutdown periods. Based on these Farley-specific controls, the proposed 24-hour time allowance is reasonable and necessary to perform this surveillance, in conjunction with other startup activities, without placing the plant in an unsafe condition. 10 Note 3 is added to ITS surveillance SR 3.3.1.3. The note clarifies that surveillance SR 3.3.1.9 satisfies the surveillance requirements of SR 3.3.1.3. This provision is acceptable. Surveillance SR 3.3.1.3 periodically compares the results ofincore flux map measurements to the actual excore M indications. If the absolute difference is

            >3%, then the affected excore channels must be adjusted (i.e., re-nor==H=d). This surveillance pmvides for periodic calibration checks that will, if necessary, compensate for the potential M de-calibration affects due to slowly changing core flux distributions during the operating cycle. For a given cycle, the results of the incore/excore calibration at BOL are used as the basis for the initial excore channel M calibration adjustments (i.e., the cycle-speci6c M normaliratian) under surveillance SR 3.3.1.9. This calibration data is based on analysis of multiple flux maps over a range of core flux distributions. The initial normalization ensures that excore M indications and the inputs to f(M) for the OTAT reactor trip are matched to the cycle-specific power distributions. In that SR 3.3.1.9 calibration data is based on a more detailed data analysis and that the surveillance requires excore channel adjustments, performance of SR 3.3.1.9, in lieu of the comparisons required by SR Chapta 3.3                                ES-7-A                                          May,1999

1 I J77 RTS Instrumentation 8 3.3.1 BASES , l SURVEILLANCE SR 3.3.1.2 (continued) REQUIRENENTS allowed for performing the first Surveillance after reaching 15% RTP. At lower power levels, calorimetric data ar - - inaccurate. p.we d - EXp The Frequency of every 24 hours is adequate. T asehn unit operating experience, considering instrument F_f.

          '33 *lA reliability and =erauna ni==rv aata ror insur            .t < rife Together these factors demonstt;te the change un the absolute difference between NIS and heat balance calculated poweri rarely exceeds 2% in any 24 hour period.

In addition, control room operators periodically monitor ~ redundant indications and alarms to detect deviations in channel outputs.

                                                                                &Sc -lO]

SR 3.3.1.3 M. O SR 3.3.1.3 compares the incore system t th NIS annel output every 31 EFPD. If the absolute iffe :e is a 3%, the NIS channel is still 0PERABLE, but st be reaaausted) If the NIS channel cannot be properly 6 adjusted, the channel is declared inoperable. This survetHance is performed to verify the f(AI) input in +ha e-temperature AT Function. (ca1JIora. M ] @SC-10) Two Notes modify SR 3.3.1.3. NoteINdicatesthatthe excore NIS channel shall be adiustadif f the absolute difference between t e i re and excore AFD is a 3%. Not 2 clarifies tha th Surveillance is required only if t powerisa4 15 RTP and that 24 hours is allowed r forming the irst Surveillance after reaching 5 RTP. The Frequency of every 31 EFPD is adequate. It is based on unit operating experience, considering instrument , reliability and operating history data for instrument drift. 1 Also, the slow changes in neutron flux during the fuel cycle i can be detected during this interval. l l (continued) idOG STS 8 3.3-53' Rev 1, 04/07/95 l j

Associated Package Changes for RAI-3.3.19 l

l l

FNP TS Conversion Enclosure 2 - Discussion of Changes to CTS Chapter 3.3 - Instrumentation CTS 2.2 LIMITING SAFETY SYSTEM SETTINGS CTS 3/4.3.1 REACTOR TRIP SYSTEM INSTRUMENTATION FNP ITS 3.3.1 REACTOR TRIP SYSTEM (RTS) INSTRUMENTATION doc N_Q SHE DISCUSSION incorporated into the single STS surveillance SR 3.3.1.14. However, the STS surveillance requirements for this function eliminate the CTS requirement to perform a CFT prior to startup. In the STS, all required ' testing of this RTS function is accomplished during one test performed every 18 months. The STS reduces the frequency of the required testing not the type of testing required. The elianination of the requirernent to re-perform the CFT prior to each startup is @le based on the remaining requirement to perform this testing every 18 months which provides adequate assurance of operability and the known reliability and simplicity of manually actuated functions. In addition, the elimination of this surveillance requirement which must be repeated prior to each startup reduces the number of RTB and bypass breaker cycles (wear) while having a negligible impact on safety. 83 LA ne CTS surveillances on Table 4.3-1 for the manual reactor trip function are revised consistent with the STS. The CTS surveillances contain notes which provide test requirement details. CTS note 11 requires that the undervoltage and shunt trip mechanisms be i=A=ndently verified for the manual reactor trip function. CTS note 12 requires that both the RTB and bypass breakers be tested. These CTS notes are effectively addressed in the STS bases for the cmiesprr 4ing surveillance which contains the detail of

                                           ' the required testing. The STS surveillance is required to be performed every 18 months for each required channel of the manual reactor trip RTS function. The placement of the infonnation from the CTS notes in the bases of the STS surveillance is consistent with the general philosophy of the STS to place descriptive or explanatory information in the bases. Reliance on the information contained in the bases for guidance in performing surveillance testing is acceptable since changes to the information in the bases is controlled by the Bases Control Program specified in the administrative controls section of the TS.

84 A The CTS monthly and quarterly Channel Calibrations for the power range neutron flux high setpoint are replaced by an 18-month channel calibration surveillance (STS SR 3.3.1.10) consistent with the STS. He CTS monthly channel calibration surveillance is moved to the

         .               Chapter 3.3                                   E2-51-A                                 March,1998 m_ _ _ . . _ . - . __.

FNP TS Conversion Enclosure 2 - Discussion of Changes to CTS Chapter 3.3 -Instrumentation CTS 2.2 LIMITING SAFETY SYSTEM SETTINGS CTS 3/4.3.1 REACTOR TRIP SYSTEM INSTRUMENTATION FNP ITS 3.3.1 REACTOR TRIP SYSTEM (RTS) INSTRUMENTATION DOC NQ SHE DISCUSSION overtemperature delta T RTS function and renumbered to SR 3.3.1.3 consistent with the location and presentation of this SR in the STS. The actual performance requirements of this surveillance remain unchanged and this revision of this CTS surveillance is one of presentation and format. i I This CTS monthly surveillance may affect all power range instrument p[ functions and appropriate action must still be taken for any function affected. However, the STS organization of the surveillances attempts to group the surveillances with the most appropnate function for operability l

concems. The STS organization of this monthly surveillance clarifies the relationship of the monthly surveillances to excore channel AI and the overtemperature delta T RTS function. This relationship is appropriate in that the OTAT setpoint must comra

for changes in axial flux difference to ensure core safety limits are not exceeded during postulated events which credit the OTAT reactor trip. Therefore, the f(AI) calibration must be periodically verified. The surveillance is primarily intended to periodically verify the correct excore channel f(AI) input to the overtemperature delta T function and is not a channel calibration required to verify the power range neutron flux high trip setpoint.

The CTS quarterly channel calibration requirement for the power range 1 neutron flux high trip function is effectively replaced by the addition of STS SR 3.3.1.10 and the quarterly COT (SR 3.3.1.7) which replaces the CTS l quarterly Channel Functional Test. The CTS Channel Functional Test ! I definition does not explicitly allow for channel adjustment, if necessary, as ! does the new ITS COT definition. Therefore, the CTS required an additional quarterly channel calibration of the high flux high setpoint l bistable and, when applicable, the high flux low setpoint bistable. The l remaining power range reactor trip circuits are calibrated on an 18-month frequency and functionally tested on a quarterly basis. The new COT requirement is effectively the same as the high flux high setpoint verification and adjustment, ifnecessary, of the power range channels. The i adoption of the new COT definition in the FNP ITS and the quarterly requirement to perform that COT (SR 3.3.1.7) for the power range high trip function now pmvides the same level of setpoint verification and 4 1 calibration as the CTS quarterly calibration and functional test requirements for this function. The performance of the new quarterly COT (SR 3.3.1.7) Chapter 3.3 _ E2-52-A May,1999 i

FNP TS Conversion Enclosure 2 - Discussion of Changes to CTS Chapter 3.3 - Instrumentation CTS 2.2 LIMITING SAFETY SYSTEM SETTINGS

              . CTS 3/4.3.1 REACTOR TRIP SYSTEM INSTRUMENTATION FNP ITS 3.3.1 REACTOR TRIP SYSTEM (RTS) INSTRUMENTATION DOC N_Q       SHE                                     DISCUSSION on the power range high trip function, combined with the addition of SR 3.3.1.10 (18 month channel calibration) effectively provides the same level g[g F

4 f of assurance that the power range high trip function is maintained within the required setpoint tolerance. These proposed changes are consistent with existing plant practices and the supporting setpoint uncertainty calculations, including rack drift allowances. The changes discussed above affect the organization and presentation of the surveillances related to the power range high flux high setpoint reactor trip function but do not reduce the CTS requirements, which remain effectively the same, but re-orpaid within the RTS LCO. The CTS power mage neutron flux high setpoint is still adequately verified and maintained quarterly and every 18 months by the appropriate surveillance requirements for this function consistent with the surveillances specified for other RTS and ESFAS functions and Farley-specific power range setpoint uncertainty calculations. Therefore, this change is made to conform with the format and presentation of this surveillance information in the STS and is considered administrative. 85 A The CTS daily and monthly, channel calibration requirements associated with the power range neutron flux low trip setpoint are replaced by an 18 month channel calibration surveillance consistent with the STS. The CTS daily and monthly surveillances being replaced do not verify the power range neutron flux low trip setpoint. These surveillances adjust or calibrate the excore detectors using the incore instrumentation (monthly surveillance) or a calorimetric heat balance calculation (daily surveillance). The daily CTS surveillance is retained (SR 3.3.1.2) and continues to be performed in association with the power range neutron flux high trip setpoint function where it is required in Modes 1 and 2. The specification of this daily requirement in association with the power range neutron flux high trip setpoint function bounds the Mode 2 requirement associated with the power range neutron flux low trip setpoint function and does not introduce a change in the way the power range channels are verified operable by this surveillance. The association of the daily surveillance with the power range high trip function conforms with the presentation and format of this J information in the STS. The monthly surveillance requirement is also 1 i May,1999 l: Chapter 3.3 E2-53-A

0 FNP TS Conversion Enclosure 2 - Discussion of Changes to CTS Chapter 3.3 - Instrumentation CTS 2.2 LIMITING SAFETY SYSTEM SETTINGS CTS 3/4.3.1 REACTOR TRIP SYSTEM INSTRUMENTATION FNP ITS 3.3.1 REACTOR TRIP SYSTEM (RTS) INSTRUMENTATION DOC HQ SHE DISCUSSION cowyosding STS SR 3.3.1.8. The surveillance is revised to be an STS COT and the 31 day allowance provided by CTS note 10 is revised to 92 days consistent with the frequency of the corresponding STS surveillance SR 3.3.1.8. The COT must be performed prior to each reactor startup (Mode 2) to verify the neutron flux trip setpoints are operable during power ascension (to 10% RTP) when the affected neutron flux trip functions are relied on to provide the required protection. The type of testing required remains unchanged, and any differences between the CTS CFT and the STS COT are discussed in the DOCS associated with STS section 1.0,

                   " Definitions". The proposed allowance (92 days) fori forming this surveillance prior to reactor startup is consistent with the required frequency
                 ' for most other COTS performed on the RTS functions. Since most RTS and ESFAS functions are considered operable between the required quarterly COTS, including the power range neutron flux channels in Mode 1, the allowance of 92 days for the performance of a COT prior to startup is also acceptable for the power, intermediate, and murce range neutron flux trip instrument functions affected by this change. Once the required COT has been performed within 92 days of startup, the neutron flux trip functions may be considered operable dunng the startup just as other RTS and ESFAS instrumentation functions are considered operable between quarterly COTS during operation in Mode 1.

86a L The CTS quarterly channel calibration surveillance requirement associated with the power range neutron flux low trip function is revised consistent with the STS. This CTS surveillance is replaced with the corresponding l STS COT SR 3.3.1.8. The CTS Channel Functional Test definition does ! l not explicitly allow for channel adjustment, if necessary, as does the new ! ITS COT definition. Therefore, the CTS required an additional quarterly l 9ff channel calibration of the high flux high setpoint bistable and, when applicable, the high flux low setpoint bistable. The reinaining power range reactor trip circuits are calibrated on an 18-month frequency and functionally tested on a quarterly basis. The new COT requirement is ! effectively the same as the high flux low setpoint verification and j adjustment, if necessary, of the power range channels. The adoption of the ! new COT definition in the FNP ITS and the quarterly requirement to j l perform that COT (SR 3.3.1.8) for the power range high neutron flux low l

1 Chapter 3.3 E2-55-A May,1999 1

FNP TS Conversion Enclosure 2 - Discussion of Changes to CTS Chapter 3.3 - Instrumentation CTS 2.2 LIMITING SAFETY SYSTEM SETTINGS CTS 3/4.3.1 REACTOR TRIP SYSTEM INSTR.UMENTATION FNP ITS 3.3.1 REACTOR TRIP SYSTEM (RTS) INSTRUMENTATION DOC NQ SHE DISCUSSION trip function now provides the same level of setpoint verification and l calibration as the CTS quarterly calibration and functional test requirements fcr this function. The performance of the new quarterly COT (SR 3.3.1.8) . l on the power range high neutron flux low trip function, combined with the ; addition of SR 3.3.1.10 (18 month channel calibration) effectively provides the same level of assurance that the power range high neutron flux low trip function is maintained within the required setpoint tolerance. These

               /    proposed changes are consistent with plant practices and the supporting p\g      setpoint uncertainty calculations, including the rack drift allowance. The changes discussed above are considered to be administrative. However, the STS SR 3.3.1.8 contains a provision in the frequency that allows a 4 hour delay in the performance of this SR after reducing power below P-10 (the applicable Mode for the power range low trip function as revised and              I documented on CTS Table 3.3-1). The CTS does not contain a cosWing allowance to delay performing this surveillance after entry into the applicable Mode. Therefore, to avoid noncompliance, the NIS power range detector cables must be determi=W to facilitate on-line testing of the high flux low setpoint bistable when operatirg above the trip setpoint (s 25% RTP). The STS allowance is reasonable considering the short duration of the delay, the fact that there is no reason to believe the required instrumentation is inoperable (the most probable result of performing a surveillance is that the equipment is found operable), and the fact the delay is only applicable upon reducing power which will eventually place the plant in a condition (shutdown) where :he affected RTS function will no longer be required. If the surveillance was performed and the RTS function found inoperable, the required action would result in the same plant condition (shutdown). If the plant is not shutdown and is maintained i

within the applicable Mode (Mode I below P-10 or Mode 2) for greater than 4 hours, the surveillance must be kept current with the 92 day frequency. Therefore, the delay in r= forming this SR upon reducing power into the applicable Mode provides a reasonable allowance for a plant which is being placed in shutdown anyway and does not significantly impact the level of protection provided by this instrumentation. This allowarse will also obviate the need to determinate the power range detector cables to facilitate periodic on-line calibration checks at power. This change conforms with the applicable requirements of the STS and reflects the NIS Chapter 3.3 E2-56-A May,1999

FNP TS Conversion Enclosure 2 - Discussion of Changes to CTS Chapter 3.3 - Instrumentation CTS 2.2 LIMITING SAFETY SYSTEM SETTINGS 3 CTS 3/4.3.1 REACTOR TRIP SYSTEM INSTRUMENTATION FNP ITS 3.3.1 REACTOR TRIP SYSTEM (RTS) INSTRUMENTATION eec Q SHE DISCUSSION l H. hardware design capabilities. 86b M The CTS CFT specified for the intermediate range neutron flux trip instmment function is revised consistent with the STS. In the CTS, a Channel Functional Test (CFT) is required prior to reactor startup. In the conversion to the ITS, the CFT becomes a COT (SR 3.3.1.8). In addition to the existing frequency, two frequencies are added for the intermediate range neutron flux trip instrument fhartian; four hours aAer reducing power below P-10 and every 92 days thereafter. If the plant is not shutdown and is maintained within the applicable Mode < P-10 for greater than 4 hours, the surveillance must be kept current with the 92 day frequency. The Frequency of"4 hours after reducing power below P-10" allows a normal shutdown to be completed and the unit removed from the MODE of Applicability for this surveillance without a delay to gifvis the testing required by this surveillance. The Frequency of every 92 days thereafter applies if the plant remaias in the MODE of Applicability after the initial performances of prior to reactor startup and four hours after reducing power below P-10. The MODE of Applicability for this surveillance is < P-10 for the intermediate range channels. Once the unit is in MODE 3, this surveillance is no longer required. If power is to be maintained < P-10 for more than 4 hours, then the testing required by this surveillance must be performed prior to the expiration of the 4 hour limit. Four hours is a reasonable time to complete the required testing or place the unit in a MODE where this surveillance is no longer required. This test ensures that the NIS intermediate range channels are OPERABLE prior to taking the reactor critical and after reducing power into the applicable MODE (< P-10) for periods > 4 hours. Since the IR reactor trip is credited for diversity for subcritical events in the safety analyses, these frequencies are applicable to Farley and the trip should be verified operable when the Unit is operated in conditions where such diverse protection may be needed. While it is highly unlikely that the Unit would ever be operated for any extended time period in Modes applicable to this surveillance during Unit ramp down and reactor shut down, the addition of these frequencies adds new requirements not currently in the CTS and this is therefore seen as a more restrictive change. 87 M The CTS CFT specified for the power, intermediate, and source range . Chapter 3.3 E2-57-A May,1999

FNP TS Conversion Enclosure 2 - Discussion of Changes to CTS Chapter 3.3 -Instrumentation CTS 2.2 LIMITING SAFETY SYSTEM SETTINGS CTS 3/4.3.1 REACTOR TRIP SYSTEM INSTRUMENTATION FNP ITS 3.3.1 REACTOR TRIP SYSTEM (RTS) INSTRUMENTATION DOC NQ SHE DISCUSSION perfonned or the plant removed from the applicable Mode within this time,

2) 'Ibe most probable consequence of performing any surveillance is that the equipment tested will be found operable, and 3) The fact that the allowance only applies when the plant is being shutdown which is consistent with the TS action ultimately required for a failed surveillance test and inoperable equipment. Therefore, the delay in performing the SRs upon reducing power into the applicable Mode pmvides a reasonable allowance for a plant which is being placed in shutdown anyway and does not significantly impact the level of protection provided by the soume range j instrumentation. !

88a M Consistent with the STS surveillance requirements and considering FNP current practices a new surveillance is added to the CTS Overtemperature Delta T function. FNP ITS SR 3.3.1.9 (STS SR 3.3.1.6) requires an incore/excore cross calibration be performed every 18 months and requires g[g F i the calibration be completed within 7 days of exceeding 50% power. Although the CTS does not contain a corresponding surveillance requimrnent, an equivalent procedure is routinely performed by FNP every 18 months at BOL. The proposed FNP ITS SR 3.3.1.9 conforms to the STS requimment for this type of SR, but the frequency is revised consistent with the way this surveillance is currently performed at FNP. As the FNP ITS version of this surveillance requirement conforms to current FNP - procedures for cross calibrating the excore instrumentation to the incore instrumentation, the addition of this SR does not impact the availability or reliability of this instrumentation. The inclusion of this new surveillance requirement in the TS provides additional assurance that the calibration of .j the excore channel AI indications and f(AI) input to the OTAT reactor trip I will be established at BOL on a cycle-specific basis. However, the addition ! of this SR represents a new TS requirement and is therefore considered a more restrictive change. ! 89 A 'Ibe CTS surveillance note 7 which modifies the source range neutron flux channel check requirement contains 2 provisions. The first provision of the note effectively establishes the applicability of the source range instrumentation channel check surveillance as below the P-6 interlock. This provision is consistent with the Mode of applicability requirement for the Chapter 3.3 E2-60-A May,1999

975 RTS Instrumentation Ndre - - -NOTE erecLto be.p-r formeck for 3~3*i 4eure.c nse inMrurnen SURVEILLANCE REQU EME_ peg ___ g,is_4 , Hong.u nbi L ____________~.__-----NOTE---------------------- -------------- Refer to Table .3.1-1 to determine which SRs apply for each RTS Function. SURVEILLANCE FREQUENCY SR 3.3.1.1 Perform CHANNEL CHECK. 12 hours SR 3.3.1.2 -------------------NOTES-------------------

1. Adjust NIS channel if absolute difference is > 2%.

2. equired to be performed until g 2 12] hours after THERMAL POWER is RTP.

9 Compare results of calorimetric heat 24 hours balance calculation to Nuclear Instrumentation System (NIS) channel output. SR 3.3.1.3 -------------------NOTES-------------------

1. Adjust NIS channel if absolute f 3,b I q difference is a 3%.

2. to be performed until d Notrequir[afterTHERMALPOWERis 4; nours) dq3 q 15 % RTP.

_______9______________________ ompare results of the incore detector 31 effective measurements to NIS AFD. full power days (EFPD) (continued)

3. Padu-(!c 4 SR 3.3,i.q sdd6s *

                      +% SR.                                                                go WOG STS                                                           3.3-10                         Rev 1, 04/07/95

67(o RTs instrumentation 3.3.1 SURVEILLANCE REQUIREMENTS (continued) SURVEILLANCE FREQUENCY SR 3.3.1.4 -------------------NOTE-------------------- This Surveillance must be performed on the reactor trip bypass breaker prior to placing the bypass breaker in service. Perform TADOT. 31 days on a STAGGERED TEST BASIS

A T

*/

9 SR 3.3.1.5 Perform ACTUATION LOGIC TEST. 31 days on a f \ n 's ' STAGGERED TEST BASIS 12 12A If}

                %         1." efron de,techr3 o-re                  -,

y' dd I h e. ibw e
SR 3.3.1 6 --- ---- -- - ---- - --- - N OT ER-- -- - - -- -- --- --- -- - _ _ _ _

g 2.Not reouired to be performed until ;

                                                                                                                   '3 g,                       24:     aournafter THERMAL POWER is                                       18 fnonT 5 2: 50% RTP.

79 ------------------------------------------- Calibrate excore channels to agree with incore detector measurements. (92)EFPh gl SR 3.3.1.7 -------------------NOTE-------------------- , Not required to be performed for source ! range instrumentation prior to entering MODE 3 from MODE 2 until 4 hours after entry into MODE 3. ; ___-___-_---- .---_----__-----__--___.----_ 1 Perform COT. 92 days (continued) WOG STS 3.3-11 Rev 1, 04/07/95

FNP TS Conversion Enclosure 5 - JD from STS Chapter 3.3 - Instrumentation STS 3.3.1 REACTOR TRIP SYSTEM (RTS) INSTRUMENTATION FNP ITS 3.3.1 REACTOR TRIP SYSTEM (RTS) INSTRUMENTATION JD NUMBER JUSTIFICATION 9 Note 2 of STS surveillance SR 3.3.1.2 is revised from the bracketed 12 hours to 24 hours. The cowyonding CTS requirement in note 2 on CTS Table 4.3-1 does not contain a time limit for the performance of this surveillance after 15% power is reached. Therefore, the proposed FNP ITS 24 hour restriction for performing this SR aAer 15% power is reached provides adequate assurance that the surveillance will be performed in a timely manner while providing a reasonable time in which to complete the surveillance. For a given Farley unit startup at BOL, the initial NIS PR calibration is performed during a power ascension hold at about 30% RTP. This practice and the allowance of 24 hours to achieve this power level are acceptable based on the following. Calorimetric calculation results at low power levels can include large uncertainties; therefore, it is desirable to raise power to higher levels where the calorimetric calculations will be more accurate. There are also potential calibration uncertainty effects attributed to the core design; therefore, plant procedures provide preliminary BOL PR calibration data for initial stattup based on cycle-specific core designs and test data. Furthermore, the plant administrative controls ensure that the NIS PR High Flux High reactor trip setpoint is reduced to s 85% RTP, until the NIS PR channels can be calibrated based on calorimetric data obtained at or above 50% RTP. Performance of the initial NIS calibration must also be coordiseted with other unit startup activities, and power ascension is limited to 3% per hour above 20% RTP to ensure proper fuel ymconditioning for new cores and following extended shutdown periods. Based on these Farley-specific controls and limitations, the proposed 24-hour time allowance is reasonable and necessary to y[ perform this surveillance, in conjunction with other startup activities, without placing the plant in an unsafe condition. 10 Note 3 is added to ITS surveillance SR 3.3.1.3. The note clarifies that surveillance SR 3.3.1.9 satisfies the surveillance requirements of SR 3.3.1.3. This provision is acceptable. Surveillance SR 3.3.1.3 periodically compares the results ofincore flux map measurements to the actual excore M indications. If the absolute difference is

             >3%, then the affected excore channels must be adjusted (i.e., re-normmHM). This surveillance provides for periodic calibration checks that will, if necessary, compensate for the potential M de-calibration affects due to slowly changing core flux distributions during the operating cycle. For a given cycle, the results of the incore/excore caliisration at BOL are used as the basis for the initial excore channel M calibration adjustments (i.e., the cycle-specific M normalization) under surveillance SR 3.3.1.9. This calibration data is based on analysis of multiple flux maps over a range ofcore flux distributions. The initial normalization ensures that excore M indications and the inputs to f(M) for the OTAT reactor trip are matched Chapter 3.3                                E5-7-A                                          May,1999 L

i FNP TS Conversion Enclosure 5 - JD from STS Chapter 3.3 - Instrumentation STS 3.3.1 REACTOR TRIP SYSTEM (RTS) INSTRUMENTATION FNP ITS 3.3.1 REACTOR TRIP SYSTEM (RTS) INSTRUMENTATION JD 3 NUMBER JUSTIFICATION to the cycle-specific power distributions. In that SR 3.3.1.9 calibration data is based ' on a more detailed data analysis and that the surveillcnce requires excore channel adjustments, performance of SR 3.3.1.9, in lieu of the comparisons required by SR 3.3.1.3, is acceptable. 11 The " bracketed" time and power level in STS surveillance SR 3.3.L3 Note 2 are changed based on Farley-specific operating experience, plant practices, and licensing basis. The " bracketed" time in STS surveillance SR 3.3.1.6 Note (FNP ITS SR 3.3.1.9 Note 2) is changed based on Farley-specific operating experience l' and plant practices. ITS SR 3.3.1.3 requires periodic excore channel AI adjustment (i.e., normalization), if necessary, based on incore flux map surveillance data. ITS SR 3.3.1.9 requires excore channel Al calibration (i.e., adjustments to norrnalire), based on multiple flux maps over a range of core power distributions. Both [g 1 i g surveillmacan ensure that the excore channel AI indications and f(AI) inputs to the OTAT reactor trip are maintained and calibrated consistent with the incore/excore calibration and periodic surveillance uncertainty allowances in the OTAT setpoint

calculation. Since these Notes place time and power limitations on performance of the associated surveillances, the time and power level in these Notes must be identical to prevent timing and applicability inconsistencies. The " bracketed" time of 24 hours in surveillances SR 3.3.1.3 and SR 3.3.1.9 is changed to 7 days. This time is reasonable based on the actual time required to: perfonn a full core flux map at full power or multiple flux maps over a range of power distributions at part-power; analyze the resultant data and calculate new excore detector calibration currents; revise NIS excore power range calibration procedures; and implement the new calibration data in each power range and OTAT protection channel. In addition, SR 3.3.1.9 must be coordinated with other BOL power ascension testing and plant chemistry activities with consideration for fuel limitations, such as power ramp and rod withdrawal rates. A time allowance of 7 days is also consistent with the time allowance for performance of AFD 1 surveillance in SR 3.2.3.1, which requires calibrated excore channel AI indications j based on the cycle-specific core power distributions. The 7-day allowance provides ! sufficient time for surveillance performance, including excore channel j normalization if necessary, and the subsequent performance of the AFD surveillance, without placing unwarranted duress on the plant operating maintenance and/or engineering staffs. ; The " bracketed" power level in STS surveillance SR 3.3.1.3 of 215% RTP is changed to 2 50% RTP. 'Ihis is identical to the power level in STS surveillance Chapter 3.3 ES-8-A May,1999 l l I

FNP TS Conversion Enclosure 5 - JD from STS Chapter 3.3 - Instrumentation STS 3.3.1 REACTOR TRIP SYSTEM (RTS) INSTRUMENTATION FNP ITS 3.3.1 REACTOR TRIP SYSTEM (RTS) INSTRUMENTATION JD NUMBER JUSTIFICATION 3.3.1.6 (ITS 3.3.1.9). A power level of 2 50% RTP corresponds .to the power level required for the surveillance of AFD specified in SR 3.2.3.1 for plants that are licensed to operate with a relaxed axial offset control (RAOC) strategy. Whereas, 15% RTP corresponds to the power level required for AFD surveillance for plants tiat are licensed to operate with a constant axial offset control (CAOC) strategy. Since Farley is licensed to operate with a RAOC strategy (reference Amendment Nos.121 (Ul) and 113 (U2)),2 50% RTP is an appropriate power level for requiring performance of surveillance SR 3.3.1.3. 12 STS surveillance SR 3.3.1.6 (FNP ITS SR 3.3.1.9) for the power range neutron flux channels is revised consistent with similar corresponding CTS surveillances. The other CTS power, intermediate, and source range instrument calibration surveillances refer to CTS note 6 on Table 4.3-1. CTS note 6 specifies that neutron g f[ detectors are excluded from the Ch X same purpose as the corresponding note used in other STS surveillances. This CTS note is added to the STS surveillance SR 3.3.1.6 (FNP ITS SR 3.3.1.9) as Note 1.

     .p         This change is made to maintain the clarification provided by CTS note 6 for the other CTS power, intermediate and source range instrument calibration surveillances and to maintain consistency with the FNP current licensing basis as documented in the CTS.

12a The frequency of STS SR 3.3.1.6 (FNP ITS SR 3.3.1.9) is revised consistent with the current practice at FNP for perfonning this surveillance. The STS surveillance requires the excore power range instrumentation to be calibrated (i.e., adjusted / normalized) to the incore instmmentation readings. This STS surveillance does not correspond to any existing CTS RTS surveillance requirements. However, the STS surveillance has been adopted in the FNP ITS and the STS " bracketed" 92 EFPD frequency is revised to 18 months based on the current practice at FNP for performing an incore/excore cross calibration. In addition, the STS SR number is revised to SR 3.3.1.9 (STS SR 3.3.1.9 is likewise revised to SR 3.3.1.6) in the FNP ITS to preserve the STS format of the longer SR intervals being presented later in the numerical order. Operating experience at FNP has proven this 18 month frequency to be adequate for performing the incore/excore cross calibration and for establishing the BOL cycle-specific power range channel AI calibration. Because variations in core design and fuel assembly manufacturing influence core power distributions, Farley performs a rigorous incore/excore calibration at the beginning of each operating cycle. The excore channel AI calibration data is based on analysis of multiple incore flux maps over a range of power distributions. In addition, the digital power range meter design at FNP allows for in> proved Chapter 3.3 E5-9-A May,1999 e

FNP TS Conversion Enclosure 5 - JD from STS Chapter 3.3 -Instrumentation STS 3.3.1 REACTOR TRIP SYSTEM (RTS) INSTRUMENTATION FNP ITS 3.3.1 REACTOR TRIP SYSTEM (RTS) INSTRUMENTATION JD NUMBER JUSTIFICATION incore/excore calibration accuracy. As a result, the BOL incore/excore cross-calibration normalizes the excore channel AI indications and f(AI) input for OTAT to match the cycle-specific core power distributions. The FNP monthly calibration checks and re-normalization, if necessary, of the power range AI channels, required by SR 3.3.1.3, address the affects of flux re-distribution with bumup. Therefore, the STS SR 3.3.1.6 frequency change from 92 EFPD to 18 months is appropriate for

       .g    Farley and will maintain consistency with the current Farley pmetices and licensing basis regarding the incore/excore calibration of the power range instrumentation.

13 The frequency terminology of the STS surveillance SR 3.3.1.8 is revised consistent with the CTS. The CTS uses the terms " power range %d " intermediate range" neutron flux instrumentation. This change maintains the CTS terminology and makes the statement of these instrument names consistent wlth the " source range" currer.dylisted in the STS. 13a The STS SR 3.3.1.9 (FNP ITS SR 3.3.1.6) is renumbered to a: count for changes made to the frequency of STS SR 3.3.1.6 (FNP ITS 3.3.1.9). Due to the extension of the frequency of STS SR 3.3.1.6 to 18 months (discussed in another JD) it was necessary to exchange numerical order with STS SR 3.3.1.9 to preserve the STS format oflonger surveillances intervals being presented later in the numerical order. This change is only intended to affect the numerical order in which this SR appears. No other change is made to STS SR 3.3.1.9. 13b STS Surveillance Requirement SR 3.3.1.9 (FNP ITS SR 3.3.1.6) requires performance of a TADOT every 92 days. The surveillance applies to the RCP Bus UV & UF instrument channels. STS SR 3.3.1.9 includes a pmvision for "not" verifying the UV/UF relay setpoint. This provision is not applicable to FNP. At > Farley, these relays can be tested and, if necessary, adjusted in situ. The supporting setpoint uncertainty calculations include a rack drift uncertainty allowance that bounds the expected rack drift for a healthy instrument channel. The allowance is based on quarterly surveillance to verify that the relay trip setpoint is within the established calibration tolerance. The quarterly surveillance is also in agreement J with the analysis frequency modeled in WCAP-10271, Supplement 1-P-A. Therefore, consistent with the CTS quarterly functional test requirements for the

             = RCP Bus UV functions for the RTS and ESFAS, the RCP Bus UF function for the RTS, and the supporting setpoint uncertainty calculations, the RCP UV & UF relays setpoints must be verified on a quarterly basis. As such, the Note associated with STS SR 3.3.1.9 is deleted in ITS SR 3.3.1.6.
                                                                                                     )

Chapter 3.3 E5-10-A May,1999 I l

.g TT7 RTS Instrume t BASES SURVEILLANCE SR 3.3.1.2 (continued) REQUIREMENTS allowed for performing the first Surveillance after reaching

                                 '15% RTP. At lower power levels, calorimetric data ar              _ - - _

inaccurate. p. s 4 ' Lg-cWg _ The Frequency of every 24 hours is adequate. t isla~sej,hn unit-operating experience, considering instrument F __ f-reliability.and operatina a m arv aata ror instr = nt c rif tr Together these factors demonstrate the change in the. absolute difference between NIS and heat balance calculated powers rarely exceeds 2% in any 24 hour period. 9 y/\ In addition, control room operators periodically monitor redundant indications and alarms to detect deviations in M -b cham 6l channel outputs. I hovWA* b 3% m oba*(4 *% SR 3.3.1.3 l h M MN U ! uMerM%cA9W8% SR 3.3.1.3 compares the incore system to the NIS channel ! 4g c 6 nal mod be output every 31 EFPD. If the absolute differencefTs a 3%, I

g. g, g, the NIS channel is still 0PERABLE, butWu be @ adjusted. i 6*MM) bad If the NIS channel cannot be properly djusted,the on m uce L channel is declared inoperable. This Surveillance is

       - Su n cill e cJ O '       performed to ver             f(AI) input to the overtemperature-AT Function.         euM \             ,gg           qg, p P" g,,) ,p -                   Notes modify SR 3.3.1. _.. Note 1 indi        es that the excore NIS channel shall e adjusted if           a absolute                       ;

h % M iS difference between the re and excore AFD is a 3%. c nsidt h ui A Note 2 clarifies tha" Surveillance, requ p only if g geweds reactor power is a L% P and that us nours is allowed j g 3, , ,q , f orming the G urveillan e,a_fter reachin ! Ms3s% W' N A 'Y"I k**Wd %' sg 3 3M +. requency of every 31 EFPD is adequate. It is based on uni ating experience, considering instrument gP4,4 y relia [11 and moerating history anta for instrument drif " Utu of 5818'I'$ Oso m ha ow changes in neutron flux during the fuel cycTe, i <. Sme.c SR 3 3.14 ) can be date ted during this interval C o \ % <* h U .C.j roy% pg gg ope q c3,.44, inM c6-wwl chnnel AK)odmed) 48- pab.6 b pt. bod unk SR 3 3 l'1.

h oeb +. gg ,g,;.J,jn a .

(; *Se m, eat chneh

            'd 'tevtbpS6 hem 4A((

e F 5R 3 3.f.3 (continued) w'

            ^WOG STS.                                  B 3.3-53'                      Rev 1, 04/07/95

Sh RTS Instrumentation B 3.3.1 BASES SURVEILLANCE SR 3.3.1.4 REQUIREMENTS (continued) 'SR 3.3.1.4 is the performance of a TADOT every 31 days on a

             . c,Ts reWa4.Pl    ' STAGGERED TEST BASIS. This test shall verify OPERABILITY by
      @ e sa w                    actuation of the end devices.

IThe RTB test shall include separate verification of the [JINdhALT) NM undervoltagelandsshunt trip mechanisms. Independent verification of RTB undervoltage and shunt trip Function is not required for the bypass breakers. No capability is provided for performing such a test at. power. The independent test for bypass breakers is included in SR

        . %,$a.r.k\e nN8tt'          3.3.1.14. The bypass breaker. test shall include a local' shunt trip,. A Note has been added to indicate that this test must be performed on the bypass breaker prior to placing it in service.

The Frequency of every 31 days on a STAGGERED TEST BASIS is adequate. It is based on industry operating experience, considering instrument iabilit and o erating history ;

          .                       data.                                7g                                 i SR 3.3.1.5 SR 3.3.1.5 is the performance of.an ACTUATION LOGIC TEST.

The SSPS is tested every 31 days on a STAGGERED TEST BASIS, , using the semiautomatic tester. The train being tested is i

placed in the bypass condition, thus preventing inadvertent actuation. Through the semiautomatic tester, all possible logic combinations, with and without applicable permissives, are tested for each protection function. The Frequency of every 31 days on a STAGGERED TEST BASIS is ade_quate. It is ! A based on inaustry operating experience, consiaering y f anstrn==nt relishility and coeratina history data.r fM T8 ' SR 3.3.1

                                                           .[TM-nQ                                        '

correc + -

     . NmeM.t              l      SR 3.3.'1     s aLcalibration of the excore channels to the Locedior)                    ncore   channelst  If the measurements do not agree, the
                             . exco're chanpts are not declared inoperable but must be          ok bot '

W . A m M n6'S G11bratasto agree with the incore detector measurements dAr%gf fif the excorj channels cannot be adjusted, the channel re declared ipperable. This Surveillance is performed o C nrity tha7T(AI). input to the overt erature TFunction[ b' Jer ep opw ' cyle. j w _- - u-

"[h

[Q gg g,4 4 (continued) WOG STS B 3.3-54 Rev 1, 04/07/95 t

390 RTS Instrumentation

Mr@ M b @bN BASES M m Oe.CoLb d'" ,No - 2 A . e __ w -- -Y 90 q (q.h_q) Note states that ), b SURVEILLANCE SR 3.3.1. co ued) .I REQUIREMENTS s W A Note m dif S 3.3.1. s urveillance is equired only if reactor power 'is TP nour ; is) allowed for eerforminalthe__ its ( 6Crl1) and that 124 surveillanceart reaching 5 RTP. The Frequency ofA2 EFPD is adeauate. ::tlis based on_ 7 4 mustro operaterta_ experience sconsider ng instrument m i e' ia m- Qaragna nistory data for instrument drift.)

               %        i

{- (.rse ngSR jtB"*g_D 1 Nh 64 Lipicin suffident de eshhK+M 3.5.I. @ocmkw anM(ac,fFech. cdbesMn e F de 4 ^ SR 3.3.1.7 is Weperformanceofa~COTevery}9pdays. W M TS A CQT is nerfoianed on each required channel to ensure the hl core '8s ntire channeH wlll perform the intended Function. Setpoints must be within the Allowable Values _specified_ in M. G. , Table 3.3.1-1. y g[,g,,' bounded,bf)} M to efisure, The 61fference between the current)"as found" vaTues Grfd th3 tenstste.rcy revious test "as W ;" values must De consintentJWith$ttle w crift allowance uset in the setpoint methodo'ogy M The setpoint shall be left set consistent with the assumptions of the current unit specific setpoint methodology. A _. NoT MNtsb " The "as found" and "as left" values must also be recordedl j P and reviewed for consistency with the assumptions of J LReference 7. ; SR 3.3.1.7 is modified by a Note that provides a 4 hour delay in the requirement to perform this Surveillance for a source range instrumentation when entering MODE 3 from MODE i 9 2. This Note allows a normal shutdown to proceed without a ! I)g/ \ delay for testing in MODE 2 and for a short time in MODE 3 until the RTBs are open and SR 3.3.1.7 is no longer required to be performed. If the unit is to be in MODE 3 with the i RTBs closed for > 4 hours this Surveillance must be ! performed prior to 4 hours after entry into MODE 3. ] The Frequency of ays is justified in Reference 7.

                           %g1 e                aw 4tsk pc<bvec.e, &peAenc/,    m\                o +Jne cd cWB d 7 dw is $8c.iedr. A power tevel                c%A9cwa 4 ). seg              M vmd Mpbenh cemspands                  j
                           % h power \tNed 4-N AED sehtlwc.t, f (continued)                             ]

cse s.2.3 4 w<>. e ea, wha ==.m WOG STS .-5 M d *- % . Rev 1, 04/07/95 L_

RTS Instrumentation B 3.3.1 BASES . 60 ~I3 SURVEILLANCE SR 3.3.1. continued) REQUIREMENTS The sR 1s moairied by a Note that excludes verification of wA. setpoints from the TADOT.. Since thts SR applies to RCP

p. undervoltage and underfrequency relays, setpoint verification requires elaborate bench calibration and is gg, accomplished during the CHANNEL CALIBRATION. f SR 3.3.1.10 A CHANNEL CALIBRATION is performed every 18( months, or r gg approximately at every refueling. CHANNE ChlIBRATION is a L complete check of the instrument loop, including the sensor From B3.1.)t The test verifies that the channel responds to a measur %

m , parameter within the necessary range and accuracy 4 ' oyck Oe need . NN 1 N PEf M ' CHANNEL CAL J.BTIONS must be performed consistent with it M assum>tions) the unit s >ecific setpoint methodology.1 cT Surv el h t. Lgirro ence netween tne cu rent)"as found" valises una t h Undt COS IgFrev'oustest as Iert" vafues munt be ennr s Ef-1 COM , larif :enT withphe allowance useo,.1.n tne setpo'nt methodo'ogy. oo , / The Frequency of 18 months is based on the assumptTon or ann-Omernfin ' 18 month calibration interval in the determination of the m. E. sJyeri haL / magnitude of equipment drift.in the setpoint methodolqq. 1 bh u p5 FIR 3.3.1.10ismodifiedbyaNotestatingthatthistest'bg.g shall include. verification that the time constants are The.6 cW.e adjusted to the prescribed values where applicable, j r whengerllrmai i i g (T6C-lq]. botqh6Sw [SR 3.3.1.11 /o SR 3.3.1.11 fL.the per nce of a CHANNEL CALIBRATION. as.] ! q

described in TR 3.3. [181 monthsJ This SR is __- modifiedbydNote tat at neutron detectors are excluded from the CHANN N'v$ go NoICS' CALIBRATION for the power range ne IBRATIO The CHANNEL

                                                                                  $ndetectorscon        ts of a normalization of thegetecto          b ased onra nnwe n iori- r.c === riu1 malnperforme

[", y h'N ($g 3,3A A), y _ CiANN CALIBRATION for'.he sour bove 15% RTP. idThe r nge ami me-m ateJ(~~ neutron detectors consist of obtaining etec or

      $h.g h c.w*L              2AUB9xneA U+he a                               phm .9pt;gg O '"'

y cw*j ntAm A*kechoe Q , Mddes noren.b.4.A e b c6wel '1hs ChalEL C.hbFWm & he M,MMg o u p b 4e d, o n p. w e r c ,A o r A s b L eq dmdcW*M W5 (s,g 3.3.i, q y norMh.a. bin d abe hgonTinuedF

                                                                **. WhAAc based, m a. pause
    .        WOG STS-                                     B 3.3-57 *I* 8N                ev  ,   4/07/95

RTS Instrumentation fq B 3.3.1 N BASES SURVEILLANCE hR 3.3.1.11 (continuedj w---% REQUIREMENTS plateau preampdiscriminatorcurves/e,,valuatingthos [oTE[$tdes Arrves, and comparing the curves to the manufacturer's d i gg This survetilance is not required for the NIS power range i 6M iM detectors for entry into MODE 2 or 1, and is not required .[, ver: M ien8 I for the NIS intermediate range detectors for entry into I 4he.hme MODE 2, because the unit must be in at least MODE 2 to L% " i perform the test for the intermediate range detectors and M

      %t]g($

i MODE 1 for the power range detectors. [The [18] mont r 1 N Trequen y is base ~on the ne'a'to perform this Surve 11anc "ff under e condit ons that a ly during a plant outa e and OTAT,oPAT,osd Llthe p ential f an unpla ed transien if the Su eilla I the powerra.Mt were erformed ith the r ctor at pow Operat g W'**hM ~ mxpe ience has shown thes components sually par the en perfo d on the [1 ] month Fr quency Q %h (Eur__eillance , co m im.nts.- SR 3.3.1.1f [f l carnbane 88.N SR 3.3.1 2 is the erformance f a CHANN CALIB ION, as describ a in SR 3 .1.10, ever [15] mon s. Thi SR is Tib>h by a No- stating t t this te t shall nelude lmodifi verif ation of.he RCS res stance tem erature etector (RTD bypass 1 p flow rat . Th test wi 1 verify th rate lag ompensati n for f w f a the co e to the RT . he Frequ cy is justi ied by the assumpti of an 8 month CTS Ekle 4.3-1 calibrati n interval n the dete ination f the m nitude ( NOTE S of equip nt drift i the setpo' t analys s. j SR 3.3.1.13 iI 3 gg g / SR 3.3 fl. 3 is the performance of a COT of RTS interlocks t every018gnths. ( Ig g ( The Frequency is based on the known reliability 6f the

               .            )          interlocks and the multichannel redundancy available, and ic of

l has been shown to be acceptable through operating

( , experience. (continued) WOG STS B 3.3-58 Rev 1, 04/07/95

i Associated Package Changes for RAI- 3.3.1-12 i l l l

FNP TS Conversion Enclosure 2 - Discussion of Changes to CTS Chapter 3.3 - Instrumentation CTS 2.2 LIMITING SAFETY SYSTEM SETTINGS CTS 3/4.3.1 REACTOR TRIP SYSTEM INSTRUMENTATION FNP ITS 3.3.1 REACTOR TRIP SYSTEM (RTS) INSTRUMENTATION DOC HQ SHE DISCUSSION fact that there is no reason to believe the required instrumentation is inoperable (the most probable result of performing a surveillance is that the

                  . equipment is found operable), and the fact the delay is only applicable upon reducing power which will eventually place the plant in a condition (shutdown) where the affected RTS function will no longer be required. If the surveillance was performed and the RTS function found inoperable, the required action would result in the same plant condition (shutdown). If the plant is not shutdown and is maintained within the applicable Mode < P-10 for greater than 4 hours, the surveillance must be kept current with the 92 day frequency. 'Iberefore, the delay in performing this SR upon reducing power into the applicable Mode pmvides a reasonable allowance for a plant which is being placed in shutdown anyway and does not significantly impact the level of protection provided by this instmmentation. This change conforms with the applicable requirements of the STS.

86b M The CTS CFT specified for the intermediate range neutron flux trip instrument function is revised consistent with the STS. In the CTS, a Channel Functi_onal Test (CFT) is required prior to reactor startup. In the conversion to the ITS, the CFT becomes a COT (SR 3.3.1.8). In addition to the existing frequency, two frequencies are added for the intermediate range neutron flux trip instrument function; four hours aAer reducing power below P-10 and every 92 days thereaAer. If the plant is not shutdown and is 8 maintained within the applicable Mode < P-10 for greater than 4 hours, the surveillance must be kept current with the 92 day frequency. The

    .$M Frequency of"4 hours aner reducing power below P-10" allows a normal shutdown to be completed and the unit removed from the MODE of Applicability for this surveillance without a delay to perform the testing required by this surveillance. The Frequency of every 92 days thereafter applies if the plant remains in the MODE of Applicability after the initial performances of prior to reactor startup and four hours aAer reducing power below P-10. The MODE of Applicability for this surveillance is < P-10 for the intermediate range channels. Once the unit is in MODE 3, this surveillance is no longer required. If power is to be maintained < P-10 for more than 4 hours, then the testing required by this surveillance must be performed prior to the expiration of the 4 hour limit. Four hours is a reasonable time to complete the required testing or place the unit in a Chapter 3.3                                   E2-56-A                                     May,1999 L                                                                                                     l

i FNP TS Conversion Enclosure 2 - Discussion of Changes to CTS Chapter 3.3 - Instrumentation CTS 2.2 LIMITING SAFETY SYSTEM SETTINGS CTS 3/4.3.1 REACTOR TRIP SYSTEM INSTRUMENTATION FNP ITS 3.3.1 REACTOR TRIP SYSTEM (RTS) INSTRUMENTATION DOC NQ Eg DISCUSSION MODE where this surveillance is no longer required. This test ensures that the NIS intermediate range channels are OPERABLE prior to taking the reactor critical and after reducing power into the applicable MODE (< P-10) for periods > 4 hours. Since the IR reactor trip is credited for diversity for g r

            'g l

subcritical events in the safety analyses, these frequencies are applicable to Farley and the trip should be verified operable when the Unit is operated in Yp conditions where such diverse protection may be needed. While it is highly unlikely that the Unit would ever be operated for any extmieri time period in Modes applicable to this surveillance durmg Unit ramp down and reactor shut down, the addition of these frequencies adds new requirements not currently in the CTS and this is therefore seen as a more restrictive change. 87 M The CTS CFT specified for the power, intermediate, and source range neutron flux trip instrument functions is revised by the addition of a note modifying the required surveillance consistent with the cwieronding STS surveillance. The cwisponding STS COT surveillance for these RTS functions contains a note that specifies the surveillance shall include verification that the P-6 and P-10 interlocks are in the required state for the existing unit conditions. The STS surveillance note represents an additional requirement not specifically included in the CTS for this surveillance. The STS requirement to verify interlock status is reasonable and appropriate for surveillances performed prior to the time during which the interlock is relied on to provide the required RTS functions. Therefore, the note modifying the STS COT is applicable to FNP. However, the addition of this note represents a new TS requirement, and it is therefore considered a more restrictive change. 88 L The CTS quarterly CFT surveillance requirement for the source range instrumentation is revised consistent with the corresponding STS SR 3.3.1.7 and SR 3.3.1.8. The CTS requires the quarterly performance of this surveillance in Modes 2,3,4,5, and with the RTBs closed and the rod control system capable of rod withdrawal (RTBs closed). In addition the CTS requires this surveillance be performed prior to startup. The STS provides a more detailed breakdown of the Modes in which the source range instrument is required operable. The following discussions address each source range instrumentation applicability as defined in the STS Chapter 3.3 E2-57-A May,1999

e 977 RTS Instrumeritation 3.3.1 SURVEILLANCE REQUIREMENTS (continued) SURVEILLANCE FREQUENCY SR 3.3.1.8 -------------------NOTE-------------------- This Surveillance shall include verification that interlocks P-6 and P-10 are in their required state for existing unit conditions. Perform COT. -----NOTE----- Only required when not pirjo d wfthi previous (92 days Prior to reactor startup t AND Four hours after reducin g e

r3 _ -10 for powe

                                                                         ,anu CA 6
                                                                         ' intermediate /

instrumentation V g.3'y 88Q i lgP Four hours after. reducing power below P-6 for source range instrumentation AN.D Every 92 days thereafter I (continued)

 . WOG STS                                    3.3-12                          Rev 1, 04/07/95

y FNP TS Conversion Enclosure 5 - JD from STS Chapter 3.3 - Instrumentation STS 3.3.1 REACTOR TRIP SYSTEM (RTS) INSTRUMENTATION FNP ITS 3.3.1 REACTOR TRIP SYSTEM (RTS) INSTRUMENTATION JD NUMBER JUSTIFICATION experience at FNP has proven this 18 month frequency to be adequate for performing the incore/excore cross calibration and maintaining the power range instmmentation calibrated. The digital power range meter design at FNP allows for improved incore/excore calibration accuracy and the FNP specific monthly calibration checks and re-normalization of the power range instrumentation required by SR 3.3.1.3 address the adjustments required for flux re-distribution with bumup. He FNP specific SR 3.3.1.3 is different than the STS in that it requires a monthly calibration and not an adjustment. Therefore, the revision of the STS SR 3.3.1.6 frequency frorn 92 EFPD to 18 months maintains consistency with the current FNP

       # practice and licensing basis regardmg the incore/excore calibration of the power M          range instrumentation.

13 De frequency terminology of the STS surveillance SR 3.3.1.8 is revised consistent with the CTS. The CTS uses the terms " power range" and " intermediate range" neutron flux instrumentation. This change maintains the CTS terminology and makes the statement of these instrument names consistent with the " source range" currentlylisted in the STS. 13a The STS SR 3.3.1.9 (FNP ITS SR 3.3.1.6) is renumbered to account for changes

made to the frequency of STS SR 3.3.1.6 (FNP ITS 3.3.1.9). Due to the extension of the frequency of STS SR 3.3.1.6 to 18 months (discussed in another JD) it was necessary to exchange numerical order with STS SR 3.3.1.9 to preserve the STS format oflonger surveillances intervals being presented later in the numerical order. This change is only intended to affect the numerical order in which this SR appears. No other change is made to STS SR 3.3.1.9. 13b STS Surveillance Requirement SR 3.3.1.9 (FNP ITS SR 3.3.1.6) requires performance of a TADOT every 92 days. The surveillance applies to the RCP Bus UV & UF instrument channels. STS SR 3.3.1.9 includes a provision for "not" verifying the UV/UF relay setpoint. This provision is not applicable to FNP. At Farley, these relays can be tested and, if necessary. adjusted in situ. The supporting setpoint uncertainty calculations include a rack drift uncertainty allowance that bounds the expected rack drift for a healthy instrument channel. The allowance is 4 based on quarterly surveillance to verify that the relay trip serpoint is within the established calibration tolerance. The quarterly surveillance is also in agreement

             - with the analysis frequency modeled in WCAP-10271, Supplement 1-P-A.

Therefore, consistent with the CTS quarterly functional test requirements for the i RCP Bus UV functions for the RTS and ESFAS, the RCP Bus UF function for the i RTS, and the supporting setpoint uncertainty calculations, the RCP UV & UF relays j Chapter 3.3 E5-9-A May,1999

l RTS Instrumentation B 3.3.1 BASES SURVEILLANCE SR 3.3.1.8 :

          -REQUIREMENTS                                        .

(continued) SR 3.3.1.8 is the performance of a COT as described in SR 3.3.1.7, except it is modified by a Note that this test shall include verification that the P-6 and P-10 interlocks are in their required state for the existing unit condition. he. quency is modified by a Note that allows this y sur lance to be satisfied if it has been performed within y p (92 days of the Frequencies prior to reactor startup.and four hours after reducing power below P-10 and P-6. Frequency of " prior to startup" ansures this surveillance i The performed prior to critical operations and applies to the fk source, intermediate and power range low instrument. W g. ene. E - channels. The Frequency of "4 hours after reducina oower below P-10" (applicable tofintermediate and power rance low n U 41d'"4 M u"** *h channels) (applicableand "4 hours to source after reducing range channels) pbwer allows a normal ro. Delow

        ., time.c6 for       shutdown to be completed and the unit removed from the MODE g M,pt. 'm%e of Applicability for this surveillance without a delay to
                   *Q.       perform the testing required by this surveillance.' The N                   l Frequency of every 92 days thereafter applies if the plant               l CebM5 %d* O remains in the MODE of Applicability after the initial M%, s'obredb4 performances of prior to reactor _ startup and four hours
            ,9 qs            after reducing Jower below P-LO or P-6. A The MODE of Applicab<11ty rar Inis surve1' lance is < P-10 for the power

( @ ;. range low and intermediate range channels and < P-6 for the source range channels. Once the unit is in MODE 3, this surveillance is no longer required. If power is to be maintained < P-10 or < P-6 for more than 4 hours, then the testing required by this surveillance muv be performed prior to the expiration of the 4 hour limit. Four hours is a reasonable time to complete the required testing or place the unit in a MODE where this surveillance is no longer i required. This test ensures that the NIS source, l intermediate, and power range low channels are OPERABLE l prior to taking the reactor critical,and after reducing l power into the applicable MODE (< P-10 or < ~ P-6) for periods :

                            > 4 hours.                                                     ,

l (, T,5c.-/3al. MOVE To SR 3? g- ! h[g gg , SR 3.3.1. the performance of a TADOT and*is performed every 92 days, as justified in Refere e/7. 34g d[op 4. +be sse.s 1.jc. cdc.v 58fr**A5 ' mg. g gy,g hA &w 44 MM8 V%5P't(continued) { WOG STS- B 3.3-56 Rev 1, 04/07/95 l L

l

I l Associated Package Changes for RAI- 3.3.1-13 4

d RTS Instrumentation 1 B 3.3.1 l BASES k00'I3 SURVEILLANCE SR 3.3.1. continued) REQUIREMENTS The SR is modified by a Note that excludes verification of setpoints from the TADOT. Since this SR applies to RCP undervoltage and underfrequency relays, setpoint verification requires elaborate bench calibration and is accomplished during the CHANNEL CALIBRATION. SR 3.3.1.10 A CHANNEL CALIBRATION is performed every 8f) months, or r- 3 approximately at every refueling. CHANN ChLIBRATION is a ~ LMIi> complete check of the instrument loop, including the sensor 9E Fro m B.B.l.H The test verifies that the channel responds to a measur

                          ,     parameter within the necessary range and accuracy                    4 d 0 4 B e ech.                                                                        ON CHANNEL CALLBBATIONS must be performed consistent with the - -
 -l     NF               M      assumptionsp the unit specific setpoint methodology.1               eT I SurvelMC t- l girrorence netween Ine currenu "as found"                   values cana r h wrd       er n e COMichS          N jyrev ous test as lef t vagues muut na cano               n :enT with     he   M I                           larifyallowance usec in Ine setpo'                                .

nt methodo' ogy.[i.e..A.undeAb p planAQ, 9pLwno t .

                      / The Frequency of 18 months is based on the assumpnon or an l

t h erafine ' 18 month calibration interval in the determination of the m.E. ytridhg / magnitude of equipment drift in the setpoint methodolog. I fh us 5R 3.3.1.10 is modified by a Note stating that this testl shall include verification that the time constants are ' b . gJ [ms gjusted to the prescribed values where applicable. s' f The.5 ll cut t wherjer6d. g I ornbin

                                                                                      / oF bothg6s.

ttd {SR-3.3.1.1[I (T6C-lQ SR 3.3.1.11 thepei nce of a CHANNEL C

                             <  described in . 3.._3.   . ,     .very__181

[ mont_ht.J.ALIB. This SR is RATION, modified b Note ta hat neutron detectors are excluded from the CHANNE IBRATION The CHANNEL g, bloIe5 CALIBRATION for the power range neutrIndetectorsconsists of a normalization of the detectors b ased on a power calorimetric and flux map performed bove 15% RTP. The CHANNEL CALIBRATION for the source r nge and intermediate range neutron detectors consists of obtainin e detector g p e n e. p % N C

                   ,i M-(continued)

WOG STS- B 3.3-57 Rev 1, 04/07/95

1

                                            \
                                            \
                                             \

I Associated Package Changes for RAI-3.31-14 k 4 4 l I i l 6

7 l 1 FNP TS Conversion Enclosure 2 - Discussion of Changes to CTS Chapter 3.3 nstrumentation CTS 2.2 LIMITING SAFETY SYSTEM SETTINGS CTS 3/4.3.1 REACTOR TRIP SYSTEM INSTRUMENTATION FNP ITS 3.3.1 ' REACTOR TRIP SYSTEM (RTS) INSTRUMENTATION DOC N_Q SHE . DISCUSSION as modified by note 9. CTS note 9 defines the testing required for this RTS function and does not include verification of the setpoints. CTS note 9 requires that the status of the channels be verified (tripped or not). Both the CTS and STS rely on the 18 month channel calibration to verify the correct l setpoints of this function. Therefore, the addition of the STS note regarding no setpoint verification required is consistent with the CTS method for l performing this test as described in CTS note 9 on Table 4.3-1. Therefore, l the changes described above are made to conform with the STS and are l considered administrative. 1 LA The CTS note 9 to Table 4.3-1, which is applicable to the CFT for the 93 turbine trip RTS functions, is moved into the Bases for the corresponding STS TADOT surveillance. CTS note 9 contains descriptive detail regarding l the performance of the required surveillance and modifies the CTS ! frequency of S/U (prior to startup). CTS note 9 specifies that the testing be performed prior to P-9 (approximately 50% RTP). By design, the RTS l d turbine trip signals can be functionally tested before and/or after reactor

           ,            startup prior to P-9. The test requires the turbine to be unlatched to verify a i[            valid trip signal and to be latched to verify reset of the trip signal. As the turbine trip RTS functions are only required above the P-9 interlock, the CTS note provides accurate guidance for performing this surveillance, l                  which is consistent with the Farley safety analyses and the STS applicable Modes for the turbine trip function. Therefore, the intent of the CTS note l                  which effectively requires the testing be performed " prior to P-9" is incorpeided into the STS frequency for this surveillance. The resulting l)- ,

L frequency for this surveillance (Prior to exceeding the P-9 interlock whenever the unit has been in Mode 3, if not performed in the previous 31 days) is consistent with the applicable Mode for the turbine trip RTS l function and consistent with the CTS method for performing this surveillance, which may be performed either before or after reactor startup. In addition, the entire CTS note 9 is moved into the Bases of the co-yorniing STS TADOT surveillance. The placement of the details for performing this surveillance in the Bases effectively retains the exact CTS l l requirements for this surveillance and is consistent with the level of detail l l in existing STS bases discussions for each surveillance requirement and i ; also consistent with the general philosophy of the STS concerning the ;

                                                                                                         -l Chapter 3.3                                  E2-62-A .                                     May,1999   :

l l s !

FNP TS Conversion j Enclosure 2 - Discussion of Changes to CTS Chapter 3.3 - Instrumentation CTS 2.2 LIMITING SAFETY SYSTEM SETTINGS CTS 3/4.3.1 REACTOR TRIP SYSTEM INSTRUMENTATION I-FNP ITS 3.3.1 REACTOR TRIP SYSTEM (RTS) INSTRUMENTATION DOC l MQ SHE DISCUSSION l l location of such detail. Reliance on the information contained in the Bases for guidance in performing surveillance testing is acceptable since changes l to the information in the Bases is controlled by the Bases Control Program specified in the administrative controls section of the TS. 94 A The CTS CFT on Table 4.3-1 applicable to the safety injection (SI) irput from ESF RTS function is revised to a TADOT and formatted consistent with the STS. The TADOT is an STS defined test (STS section 1.0) that is l one of the surveillances used to replace the CTS CFT surveillance. The introduction of the different STS surveillance tests and the differences from the CTS surveillances are identified and discussed in the markups and DOCS associated with Section 1.0. The conversion of this CTS CFT into

l. the STS TADOT does not reduce the CTS surveillance requirements for this function. The TADOT surveillance continues to verify the operability of the SI input to the RTS. The change to a TADOT surveillance is made to conform with the presentation and format of this information in the STS and does not result in a technical change to the required testing for this l

function. In addition, the corresponding STS TADOT surveillance is modified by a note which states that verification of setpoint is not required. The inclusion of this note is consistent with the design of the SI actuation of reactor trip in that there is no setpoint associated with this actuation circuitry. The individual SI actuation channels have setpoints associated with them and these channels and setpoints are specified in the ESFAS TS. The inclusion of the STS note, which states no setpoint verification is required, is consistent with the way this surveillance is currently I implemented at FNP which is dictated by the system design. Therefore, the . addition of this STS note does not result in a technical change to the CTS l requirements. As such, the changes discussed above are considered ; administrative. l 95 L The CTS CFT on Table 4.3-1 applicable to the safety injection (SI) input from ESF RTS function is revised by deletion of note 4 consistent with the STS. CTS note 4 defines this CFT as pertaining to the manual ESF j l functional input to RTS. However, the STS bases describes the SI input i function as initiating a reactor trip signal by "the ESFAS automatic ! I actuation logic" and does not relate this function to any manual operation. Chapter 3.3 E2-63-A May,1999 E ,

979 RTS Instrumentation 3.3.1 SURVEILLANCE REQUIREMENTS (continued) SURVEILLANCE FREQUENCY SR 3.3.1. L

                -------------------NOTE--------------------

Verification of setpoint is not required. Perform TADOT. I months n i -- 3.3.1. P SR -------------------NOTE-------------------- -----NOTE------ Verification of setpoint is not required. Only required

               -------------------------------------------             when not performed within previous 31 days Perform TADOT.                                         Prior to reactor startup

(

           &                                                                               W WJ SR  3.3.1.   -------------------NOTE--------------------                                    I Neutron detectors are excluded from response time testing.

Verify RTS RESPONSE TIME is within limits. 18i months on a S"AGGERED TEST BASIS Pr ior- h c.vceed b i P-9 g hvlac.k i.Jkene W 4h, v M M S e L b' ,1 McIE 3, "if nof

                            ,                                ywGn mek d>W
                                                             -the previoos 31 h5 WOG STS                                       3.3-14                    Rev 1, 04/07/95

FNP TS Conversion Enclosure 5 - JD from STS Chapter 3.3 - Instrumentation STS 3.3.1 REACTOR TRIP SYSTEM (RTS) INSTRUMENTATION FNP ITS 3.3.1 REACTOR TRIP SYSTEM (RTS) INSTRUMENTATION JD NllMBER JUSTIFICATION 14 STS SR 3.3.1.10 which requims the performance of a Channel Calibration every 18 months and is modified by a note that specifies the surveillance shall include verification that the time constants are adjusted to the prescribed values is effectively combined with STS SR 3.3.1.11 (also a Channel Calibration surveillance with a note that excludes neutron detectors) into a single Channel Calibration surveillance requirement (FNP ITS SR 3.3.1.10 modified by two notes). The combination of these two STS surveillances into a single FNP Channel Calibration surveillance does not introduce a technical change to the intent of the STS surveillances. Both Notes which modify the performance of this surveillance continue to be applicable as before. The specification of time constants and their requimd values is clearly identified for each affected RTS function (OPdeltaT and OTdeltaT) within the RTS LCO list of seapoints. The association of neutron detectors with specific RTS functions is also clearly identified by the design of those channels (power, intermediate and source range instrumentation). Therefore, there is no need for duplicate Channel Calibration requirements based on different notes. In addition, the STS bases text describing these two SRs is combined accordingly. 15 STS SR 3.3.1.12 which requires a channel calibration every 18 months and is modified by a note which specifies the surveillance shall include verification of RCS resistance temperature detector bypass loop flow rate is deleted consistent with the CTS. This STS Channel Calibration surveillance is one of three 18 month channel calibration requirements in the STS. This particular Channel Calibration surveillance requirement is distinguished only by the modifying note described above. There are no corresponding Channel Calibration requirements in the CTS modified by a similar note. The RCS RTD bypass loop has been eliminated from

        \k   the FNP design. Therefore, this STS surveillance, which is intended to ensure the RCS RTD bypass loop flow is verified is not required at FNP and is deleted from i[         the FNP ITS.

16 Not Used. 17 The STS Table 3.3.1-1 is revised by the deletion of Reviewers Note (a). This STS note is intended to provide information to assist in developing a plant specific implementation of the STS. The note serves no other purpose and could result in confusion ifleR in place after a plant specific implementation has been developed. Therefore, this note is deleted and all subsequent notes are re-lettered accordingly. This change results in numerous changes to superscript notations throughout the Chapter 3.3 E5-II-A May,1999

                                                                 %h                    RTSInstrumegt gi B'SES A

h ,

            = SURVEILLANCE               SR  3.3.1.   '
                                                            '1 REQUIREMENTS                        .

(continued): SR 3.3.1. is the performance of a TADO of he Manual Reactor Trip, RCP Breaker Position, and h SI Input from ESFAS. This TADOT is performed every 1 months. The test shall independently verify the OPERABILITY of the undervoltage and shunt trip mechanisms for the Manual Reactor Trip Function for the Reactor Trip Breakers and ag n,2. Reactor Trip Bypass Breakers. The Reactor Trip Bypass J3,o Breaker test shall include testing of.the automatic 7s.1 undervoltage trip. 38 3 g The Frequency is based on the known reliability of the

         .V                             Functions and the multichannel redundancy-available, and has been shown to be acceptable through operating experience.
        ?       '

The SR is modified by a Note that excludes verification of (%s TADoT setpoints from the TADOT. The Functions affected have no setpoints ssociated with them. fc.n9ds oFveri in b t each 3 p lochtAf85 CTur 'sg 3,3,1, ei-FeC MN M i

    $hf befort
                                                     ~

y the/srt$ AC M , R 3.3.1. f e->erformance of a TADOT of Turbine-Trio J4 jd/ca.fes AO Yurht linctionsori nrs TAX)T 1s as described in 3R 3.3.1.4, exM h:

jD A7 & forb6Mihat tnic test is nerformed orior to reactor startup.fA r4 Note states that this Surveillance 1s not required ff it has li I" ( w 'i48 been performed within the previous 31 days. Verification of C M .3-1 g; 6 the Trip'Setpoint does not have to'be performed for this ' WI w her o m r k Surveillance. Performance of this test will ensure that the turbine trip Functjon is OPERABLE prior todating tv-If,, ud W teactor crmcas.T This test emittbe performe_d;s4th th been ie reactor at power nd =un t=rero . ne narrorme Crior to 3ll pose S. reactor startup. gg P-9 WoA Q SR 3.3.1. 6- g TIw-3tl

                                  '     SR 3.3.1.       verifies that the individual channel / train FSA% Tkble.               3actuation response times are less than or equal to the 7, 2,,5          .

maximum values assumed in the accident analysis. Responso ; , time testing acceptance criteria $ffe included in Technica:f~ maauir-- nts rianual . Section W (Ref. 8)'. _ Individual component response times are not modeled in the analyses. l (continued) WOG.STS B 3.3-59 Rev 1, 04/07/95

Associated Package Changes for RAls - 3.3.2-1 and 3.3.2-6 i I

}<

FNP TS Conversion Enclosure 2 - Discussion of Changes to CTS Chapter 3.3 - Instrumentation CTS 2.2 LIMITING SAFETY SYSTEM SETTINGS CTS 3/4.3.1 REACTOR TRIP SYSTEM INSTRUMENTATION i FNP ITS 3.3.1 REACTOR TRIP SYSTEM (RTS) INSTRUMENTATION DOC NQ SHE DISCUSSION , i and the guidance provided in the STS and are therefore considered less restrictive changes.' 38 A The CTS instrument channels identified in the Total Channels Column of - CTS Table 3.3-1 are revised consistent with the terminology used in the STS. In some cases the word " trains"is used to identify the two actuation

          -               trains associated with the function. In addition, various terms used to           ;

I identify or quantify specific channels listed in the Total Channels Column of CTS Table 3.3-1 are revised solely to be consistent with the equivalent terms used in the STS These changes are not intended to introduce technical changes to the CTS and are considered to be administrative. l 39 A The total number of channels for the RCP undervoltage and underfrequency functions specified in the Total Channels Column of CTS Table 3.3-1 are revised consistent with the intent of the STS. Two UV sensors and two UF sensor; are associated with each bus (with'one UV and one UF sensor for e each actuelen logic train). Each RCP bus is assigned to a protection channel. By the design for 3-loop Westinghouse PWRs, the RCP UV/UF p actuation logic is two-out-of-three channels. The CTS Total Channels Column of Table 3.3-1 contained the total number of RCP buses (3) as well as the sensors per bus requirement (2) for these functions. As the TS requirement is based on the number of channels (i.e., buses) and the total number of RCP buses is fixed by design, the elimination of the total number of RCP buses and the sensors per bus from the CTS does not impact the fundamental requirement for two operable UV/UF sensors per channel. Specifying the total number of channels as three (3) reflects the as-built l design. This change also ensures that ITS Condition M and Required Actions M.1 and M.2 are in concert with the Required Channels for RCP UV & UF. The ITS Bases revision clarifies that for RCP UV & UF, both a sensors associated with a given channel must be tripped (or, if applicable,

  ,       9gg A           bypassed) to satisfy the requirements of Action M.l. This change is made to conform with the STS presentation of this information and eliminates Y              nonessential information from the technical specification. Therefore, this S 34 change is considered to be administrative.

40 A The Total Channels column on CTS Table 3.3-1 for the P-7 interlock i Chapter 3.3 E2-25-A May,1999 l s

FNP TS Conversion Enclosure 2 - Discussion of Changes to CTS Chapter 3.3 - Instrumentation CTS 2.2 LIMITING SAFETY SYSTEM SETTINGS CTS 3/4.3.1 REACTOR TRIP SYSTEM INSTRUMENTATION FNP ITS 3.3.1 REACTOR TRIP SYSTEM (RTS) INSTRUMENTATION DOC NQ SHE DISCUSSION addition of this surveillance requirement for the CTS loss of flow two loop function maintains consistency of presentation with the STS and does not i mean that an additional redundant surveillance test must be performed on the same loss of flow instrument channels. One surveillance test (COT) performed on the loss of flow channels will continue to meet the TS j requirements for both the one and two loop functions. This change is made to be consistent with the presentation of this information in the STS and does not represent a technical change to the CTS. Therefore, this change is considered administrative. 91 A The CTS quarterly CFT for the undervoltage and underfrequency RTS functions is retained in the FNP ITS as a quarterly Trip Actuating Device Operational Test (TADOT) consistent with the STS. The TADOT is an STS defined test (STS section 1.0) that is one of the surveillances used to replace the CTS CFT surveillance. The introduction of the diferent STS surveillance tests and the diferences from the CTS surveillances are identified and discussed in the markups and DOCS associated with Section 1.0. The corresponding STS TADOT for the undervoltage and [s/ underfrequency RTS functions contains a Note that states "setpoint verification is not required". As the CTS Channel Functional Test

 - $,t$,@h       implicitly requires setpoint verification, this note is removed from the FNP ITS. This is consistent with the CTS quarterly test requirements for these RTS functions and the supporting setpoint uncertainty calculation                 i allowances for rack drift. The TADOT ensures that the RTS functions actuate and that the setpoint remains within the required tolerance. As this change does not introduce a technical change to the CTS quarterly test            i I

requirements for these RTS functions, this change is considered administrative. 92 A The CTS CFT and associated note 10 on Table 4.3-1 applicable to the turbine trip RTS functions are revised to a TADOT and formatted consistent with the STS. The TADOT is an STS defined test (STS section 1.0) that is one of the surveillances used to replace the CTS CFT surveillance. The introduction of the diNerent STS surveillance tests and the diNerences from the CTS surveillances are identified and discussed in the : markups and DOCS associated with Section 1.0. The conversion of this Chapter 3.3 E2-61-A May,1999 i

FNP TS Conversion Enclosure 2 - Discussion of Changes to CTS Chapter 3.3 - Instrumentation CTS 3/4.3.2 ENGINEERED SAFETY FEATURE ACTUATION SYSTEM INSTRUMENTATION FNP ITS 3.3.2 ENGINEERED SAFETY FEATURE ACTUATION SYSTEM INSTRUMENTATION (ESFAS) FNP ITS 3.3.5 LOSS OF POWER (LOP) DIESEL GENERATOR (DG) START INSTRUMENTATION FNP ITS 3.3.6 CONTAINMENT PURGE AND EXHAUST ISOLATION INSTRUMENTATION DOC HQ SHE- DISCUSSION FNP ITS SR 3.3.2.9 do not introduce a technical change to the response time testing requirements of the CTS. Reliance on the information contained in the STS bases for system operability requirements and guidance for performing surveillance requirements is acceptable since changes to the information in the bases is controlled by the Bases Control Program specified in the administrative controls section of the TS. 4d A CTS surveillance 4.3.2.3 is revised consistent with the intent of the STS and the applicable FNP specific procedures. The CTS surveillance 4.3.2.3 contains the requirement for response time testing of the ESFAS functions. The corresponding STS response time surveillance (FNP ITS SR 3.3.2.9) includes a note that allows testing of the turbine-driven auxiliary feedwater pump to be delayed until sufficient steam pressure exists to support the required testing of this pump. The addition of this STS note is consistent S with the CTS and STS ESF Response Time definition which includes the pump reaching its required discharge pressure. The proposed STS note is l g*S[A revised to reflect the SG pressure (21005 psig) at RCS no-load T.v. to be consistent with existing FNP inservice test procedure for this pump, which 3,r is based on Tavg being 2 547 *F. However, valid response time tests can be , performed at lower SG pressures. The time allowed to test the pump (24 hours) is consistent with the time allowed in the STS, and FNP experience demonstrates that the test can be completed within this time frame. The addition of this note to the response time test requirement is considered a clarification necessary to meet the ESF Response Time Test defmition for pump testing and which incorporates requirements based on the existing FNP practice and experience for testing this pump. Therefore, the addition l of this STS note is considered to be an administrative change. 5 A The CTS 3/4.3.2 Actions are revised by the addition of a note which affects all Actions consistent with the STS. The STS note states that " Separate . Chapter 3.3 E2-4-B May,1999

1 FNP TS Conversion Enclosure 2 - Discussion of Changes to CTS Chapter 3.3 - Instrumentation CTS 3/4.3.2 ENGINEERED SAFETY FEATURE ACTUATION SYSTEM INSTRUMENTATION FNP ITS 3.3.2 ENGINEERED SAFETY FEATURE ACTUATION SYSTEM INSTRUMENTATION (ESFAS) FNP ITS 3.3.5 LOSS OF POWER (LOP) DIESEL GENERATOR (DG) START INSTRUMENTATION FNP ITS 3.3.6 CONTAINMENT PURGE AND EXHAUST ISOLATION ; INSTRUMENTATION DOC , N_Q SHE DISCUSSION auxiliary feodwater system is normally in operation during plant startups (Mode 2), the STS requirement that the RCP bus undervoltage start function be operable in Mode 2 is appropriate for FNP. During low power operation in Mode 2 (< 5% RTP), similar conditions are present as in normal power operation in Mode 1 (>5% RTP) and the same design basis accident analyses are applicable. The inclusion of the reqmrement for this function to be operable in Mode 2 provides additional assurance that the auxiliary feedwater system will be available automatically when required due to a loss of RCP power. Due to the transitory nature of Mode 2 and the fact that most testing required for Mode 1 entry is done in Mode 3, the addition of Mode 2 to the applicability of this function does not place undue testing or operational requirements on the plant. However, this change does increase the requirements for the RCP bus undervoltage auxiliary feedwater pump start function and is therefore considered a more restrictive change. 32 A The CTS ESFAS requirement for the number of channels of the RCP bus undervoltage start of the turbine-driven auxiliary feedwater pump is revised consistent with the intent of the STS. The CTS specifies 2/ bus on 3 busses. The references to 2/ bus and 3 busses are deleted and the Required channels are specified on a per channel (i.e., one per bus) basis consistent with the g/ r STS presentation of this information for other ESF functions. FNP is a three loop plant with 3 RCPs and consequently 3 electrical supply busses 9Y (one associated with each RCP). Two sensors are associated with each bus 3,y'g (one for each actuation logic train). Each RCP bus is assigrted to a protection channel. The design information regarding the number of RCPs or total number of associated busses or UV sensors is not required or necessary to be specified in the instrumentation TS. The number of RCPs required operable, and consequently the number of electrical supply busses required, is fixed by plant design and the RCS TS which specify the number of operable RCS loops (RCPs) required in any given Mode of operation. Chapter 3.3 E2-18-B May,1999

FNP TS Conversion j Enclosure 2 - Discussion of Changes to CTS Chapter 3.3 -Instmmentation l CTS 3/4.3.2 ENGINEERED SAFETY FEATURE ACTUATION SYSTEM INSTRUMENTATION FNP ITS 3.3.2 ENGINEERED SAFETY FEATURE ACTUATION SYSTEM i' INSTRUMENTATION (ESFAS) FNP ITS 3.3.5 LOSS OF POWER (LOP) DIESEL GENERATOR (DG) START INSTRUMENTATION FNP ITS 3.3.6 CONTAINMENT PURGE AND EXHAUST ISOLATION j INSTRUMENTATION ' DOC HQ SEE DISCUSSION The deletion of this information from the instrumentation TS does not reduce the requirements placed on the number of operable RCPs or the RCP

        $           electrical supply busses or the undervoltage instrumentation on those k ,i             busses. Specifying the total number of channels as 3 reflects the as-built design. 'Diis change also ensures that ITS Condition I and Required
     @P\Aa 3             Actions I.I and I.2 are in concert with the Required Channels for RCP UV.

The ITS Bases revision clarifies that for RCP UV, both sensors associated with a given channel must be tripped (or, if applicable, bypassed) to satisfy the requirements of Action I.l. This change does not introduce a technical change to the CTS and only alters the presentation of this requirement to conform with the STS. Therefore, this change is considered administrative. 33 LA The CTS ESFAS auxiliary feedwater auto start on SI and trip of main feedwater pump functions are revised consistent with the STS. The CTS functions include descriptive information regarding the specific auxiliary feedwater pumps that are started. The infonnation describing the start of the motor-driven auxiliary feedwater pumps is moved to the bases for both these functions consistent with the presentation of this information in the ! STS. The requirements for this instrumentation to be operable remain in the TS. Only the description of the pumps actuated is moved to the bases. , I This change does not introduce a technical change to the CTS requiremer ts for this instrumentation. The placement of descriptive details in the bases is consistent with the philosophy of the STS, and in this case, also conforns with the presentation of this information in the STS. Reliance on the information contained in the STS bases for system operability requirements and design information is acceptable (ince changes to the information in the bases is controlled by the Bases Control Program specified in the administrative controls section of the TS. 34 M The CTS auxiliary feedwater start requirement on trip of the main feedwater Chapter 3.3 E2-19-B May,1999 s

978 RTS Instrumentation 3.3.1 SURVEILLANCE REQUIREMENTS (continued) SURVEILLANCE FREQUENCY I

 $e                                                                                     /                            4 df gg +SR 3.3.1.

g C----------------NOTE------------------A Verification of set Q -.------_-------point is not required. [I'yi

3. g,4 4 9 --------------

                                                                              -------J                            z,3 4                                                           %

gy Perform TADOT. 9 days W (SR 3.3.1.1p -is Surveillance -------------NnTE-------------------- shall include i Z,Th -1 verification that the time constants are s I adjulted to theJrescribed values. M

..=-- ----- ------------ ------ ---------

erform CHANNEL CALIBRATION. [18] mon I SR kl.- 3.3.1. W -------------------NOTE--------------------

l. Neutron detectors are excluded from CHANNEL sCALIBRATION.

Perform CHANNEL CALIBRATION. 1 months SR 3.3.1. -------------------NOTE-------------------- Th eillance shall include verificat Reactor Coola em 16 resistance temper or bypass loop I flow rate. ! l erform CHANNEL CALIBRATION. months II . SR 3.3.1. Perform COT. 18 months l (continued) WOG STS 3.3-13 Rev 1, 04/07/95 ; a

Qg RTS Instrument on Tebte 3.3.1 1 (poes 4 of 8) Reactor Trip system Instrumentation APPLICAkEMIBEs OR OTHER , IO SPECIF150 REQUIREO SURVEILLANCE ALLOWAsl TRIP FUNCTION e CONDITIONS CHANNELS CONDIT10Ns REGUIREMENTs VALUE sE IN

11. Aeector Cootent Ptap (RCP) srooker Positten

e. Single Loop 1 1 per sk 3.3.1. NA NA g> RCP

b. Two Loope 1C 1 per M sa 3.3.1.

f RCP ggg g g 2{, go

12. Undervettese 1 3 pe N sa 3.3. V t 4830 V RCPs bue at 3.3.1.' !13e f 3 que 3.3.1. ' ! 5

13. Underfregaancy RCPs 1 1 per M st 3.3.h sa : .3. ' JGA

[ t BR : .3. ' 6J

14. steen 1,2 per E 88 3.3.1.1 t .4 m(

Generator (sG) sG $a 3.3.1.7 Water Level-Low 1 st 3.3.1.10 Low st 3.3.1. [ b5.'sGWetr 1,2 per-sG E st 3.3.1.1 t (30.43% t (32.31% Level Low SR 3.3.1.7 1 sa 3.3.1.10 sa 3.3.1.16 Cof ident Nith 1,2 2 per SG st 3.3.1. s (42.51 5 (401 st Flow / st 3.3.1. full ste futt st am F ter Flow SR 3.3.1 0 flow at TP flow e RTP Q M ematch sa 3.3. 16

(continued) (e) Reviewer's Note: Unit specific laplementations may conteln only Attowable Vetue depending on setpoint st methodology used by the unit. Above the P 7 (Low Power Reactor Tripe stock) Interlock, q l (.j)((AbovetheP-8(PowerRangeNeutronFlum) (h) Above the P 7 (Low. Power Reactor Tripe stock) Interlock and below the P-8 (Power Renee WoutronInterlock. Flux) Interlock. l WOG STS 3.3-18 Rev 1, 04/07/95 3

1 295 ESFAS Instrumentation 3.3.2 SURVEILLANCE REQUIREMENTS (continued) SURVEILLANCE FREQUENCY p 5 ) SR 3.3.2. [ % Veri-fication of relay setpoints not--------------NOTE---- r Q.equired. g

           .T
           .i,,5 Perform TADOT.             p                               92 days SR 3.3.2          -------------------NOTE--------------------           L Verification of setpoint not , required, 7                    CIOC*          '

(manual initiation funcuan&

                                                                                 ) l Perform TADOT.                                          [18 months SR     3.3.2.[7-------------------NOTE--------------------

This Surveillance shall include v-verification that the time constants are adjusted to the prescribed values. Perform CHANNEL CALIBRATION. 18 months 0 SR 3.3.2.[9-------------------NOTE-------- Not required to be performed f t e turbine driven AFW pump i 24([ hours

                 @       after SG pressure is 2: a00 y,psig.
                                         .Id'   .       I. l#0$

Verify ESFAS RESPONSE TIMES a within 18 months on limit. a STAGGERED TEST BASIS l

                             -      v         -       -

N o nued) e t 5 A 3.3.2.8 Perform SL AVE RELAY TEST IB toonths i N 5 WOG STS 3.3-30 Rev 1, 04/07/r,5

ESFAS Instrumentation 3.3.2 l Table 3.3.2 1 (page 6 of 8) Engineered safety Feature Actuation system Instrumentation APP 10 i O n.LICABLE Es OR OTHER ll i SPECIFIED REQUIRED SURVEILLANCE ALLOWABLE TRIP FUNCTION CONDITIONS CHANNELS CONDITIONS REQUIREMENTS VALUE SETPOINT

5. Turbine Trip and Feedwater Isolation gg lJ

e. Automatic 1, I 2 traine G) sa 3.3.2. NA NA Actuation Logic 3gj; st 3.3.2 Actuation sa 3.3.2 7g,g

b. SG Water 1, I I 1 st 3.3.2.1 5 84.2 s [82.4 Level-Nigh Nigh [3](j) SG st 3.3.2 4 (P-14) st 3.3.2 7 st 3.3.2.

c. SafetyInjection Refer to F metion 1 (sefety injection) for att initiation functione and requirements.

6. Aunf tlery Feedwater

a. Automatic 1,2,3 2 trains G st 3.3.2.2 NA NA Actuation Logic SR 3.3.2 g end Actuation SR 3.3.2 g *{

C isystem) r for

b. tomati 1 ,3 tral st .3.2.3 NA NA Actunt Logi and A unti Ret (s e of Pt t EsF g g b, SG Water 1,2,3 3[per D st 3.3.2 t (30.4$1 t (32.2 Level - Low Low SG SR 3.3.2 sa 3.3.2 Q, 2g S

g (sa 3.3.2 9*

      .N < $#                                    6                                         g         (b}
       $ j-                                                                                                        (continued)
                                                      \

__ M

     ) Reviewer's Note: Unit specific implementations may conteln only Attowable Vetuo depending on setpoint stu]dy l
        =thodotoev used by the unit.

! j) Except when ett NFIVs, MFRys, [and associated bypass valvesa are closed and (de activated] [or isolated by eLosed menueI'vetve]. , \ / b 00 yew w -ww r~e W m -- z (,b ; 1 l WOG STS 3.3-37 Rev 1, 04/07/95 l l j

                                                     }6[                                        ESFAS Instrument o}

Table 3.3.2 1 (page 7 of 8) Engineered Safety Feature Actuation System Instrumentation FUNCTION

                                    @ ^= 2SPECIFIED REQUIRED CONDITIONS CHANNELS SURVEILLANCE CONDITIONS REQUIRENENTS ALLOWABLE VALUE TRIP SETPOINT l

6. Auxiliary Feechseter (continued) f SafetyInjection Refer to function 1 (Safety injection) for all initiation f mettone and requirements. j g e. Los of Offalte 1,2,3 ) per F SR 3.3.2.7 t (29123 V t (29751 V

   \             P r                                       bus                    SR 3.3.2.9               th 5 0.8      with 5 0.8 h                                                                      @            3.3.2.10          see time delay see time delay f Undervoltage                    1,2       [33 per         I

_ _As M SR 3.3.2 t L693X bue' t 703% bus Reactor Coolant bus 3.3.2 . voltane J volt P"'P 2D . M ". 3 3 2- 4 pvolts Trip of all Main y , ~L w 12 27,per J SR 3.3.2 Feechseter Pumps puup (su 3.3.z.y I a(t I 1 palp u ( ) psFej, , ya 3.3.2.10J -, N, 8.

h. A fliary 1,2,3 (23 $ 3.3.2.1 t (20.53 et 2 ter P 3.3.2.7 (psis I fel tion T for 3.3.2. #

on Sucti

          ,      Preneur -Low
     ' 7. Automatic itchover to Conta         t Stmp

a. Au omstic 1,2,3 .2 tral SR .3.2.2 NA NA A tuetion L c SR 3.3.2.4 Actuati 3.3.2.

elsys Refuell Water ,2,3,4 4 K SR 3.3 .1 t 151% and ti1a Storage ank SR 3. 2.5 5 [ IX s[ (RWST) evel - Low SR 3. 2.9 Low SR 3 .2.10 i Col ident with Refer to F tion 1 afetyInj tion) f all int ation Sa ty injection functions and requi ts. (continued) A f(a) Reviewer's Note: Unit specific Isplementations muy contain only Allowable Value depending on Setpoint Study q methodology used by the mit. i 8 WOG STS 3.3-38 Rev 1, 04/07/95

1 FNP TS Conversion ) Enclosure 5 - JD from STS Chapter 3.3 - Instrumentation STS 3.3.1 REACTOR TRIP SYSTEM (RTS) INSTRUMENTATION FNP ITS 3.3.1 REACTOR TRIP SYSTEM (RTS) INSTRUMENTATION JD NUMBER JUSTIFICATION surveillances during a shutdown transient does not serve any useful purpose. Therefore, considenng the protection provided by the intermediate range instrumentation as described in the FSAR and the fact that plant operation below P-10 (10% RTP) is normally limited to startup and shutdown transients, the CTS surveillance and proposed FNP ITS SR (performed prior to reactor startup) provide adequate assurance of the operability of the intermediate range instrumentation. This change is made to maintain the FNP current licensing basis as specified in the CTS. 13a The STS SR 3.3.1.9 (FNP ITS SR 3.3.1.6) is renumbered to account for changes made to the frequency of STS SR 3.3.1.6 (FNP ITS 3.3.1.9). Due to the extension of the frequency of STS SR 3.3.1.6 to 18 months (discussed in another JD) it was necessary to exchange numerical order with STS SR 3.3.1.9 to preserve the STS J format oflonger surveillances intervals being presented later in the numerical order. e },\ This change is only intended to affect the numerical order in which this SR ft S , appears. No other change is made to STS SR 3.3.1.9. 13b STS Surveillance Requirement SR 3.3.1.9 (FNP ITS SR 3.3.1.6) requires performance of a TADOT every 92 days. The surveillance applies to the RCP Bus UV & UF instrument channels. STS SR 3.3.1.9 includes a provision for "not" verifying the UV/UF relay setpoint. This provision is not applicable to FNP. At Farley, these relays can be tested and, if necessary, adjusted in situ. The supporting setpoint uncertainty calculations include a rack drift uncertainty allowance that bounds the expected rack drift for a healthy instrument channel. The allowance is based on quarterly surveillance to verify that the relay trip setpoint is within the established calibration tolerance. The quarterly surveillance is also in agreement with the analysis frequency modeled in WCAP-10271, Supplement 1-P-A. Therefore, consistent with the CTS quarterly functional test requirements for the RCP Bus UV functions for the RTS a:2d ESFAS, the RCP Bus UF function for the RTS, and the supporting setpoint uncertainty calculations, the RCP UV & UF relays setpoints must be verified on a quarterly basis. As such, the Note associated with STS SR 3.3.1.9 is deleted in ITS SR 3.3.1.6. ; 14 STS SR 3.3.1.10 which requires the performance of a Channel Calibration every 18 l months and is modified by a note that specifies the surveillance shall include verification that the time constants are adjusted to the prescribed values is ! effectively combined with STS SR 3.3.1.11 (also a Channel Calibration surveillance with a note that excludes neutron detectors) into a single Channel Calibration surveillance requirement (FNP ITS SR 3.3.1.10 modified by two notes). Chapter 3.3; E5-10-A May,1999

FNP TS Conversion i Enclosure 5 - JD from STS Chapter 3.3 - Instrumentation STS 3.3.2 ENGINEERED SAFETY FEATURE ACTUATION SYSTEM (ESFAS) INSTRUMENTATION j FNP ITS 3.3.2 ENGINEERED SAFETY FEATURE ACTUATION SYSTEM (ESFAS) INSTRUMENTATION JD NUMBER JUSTIFICATION effectively maintains the FNP current licensing basis as specified in the CTS. 4- STS surveillance 3.3.2.3 does not apply to FNP and is deleted. STS surveillance 3.3.2.3 requires performance of an Actuation logic Test and contains a note stating that the continuity check may be excluded. This STS surveillance is associated solely with the auxiliary feedwater system balance of plant actuation logic and actuation relays function. This STS function and associated surveillance SR 3.3.2.3 are intended to address an auxiliary feedwater system design that includes additional actuation logic located outside of the SSPS. Balance of plant auxiliary feedwater actuation logic is a plant specific design that is included in some Westinghouse plants. The continuity check that may be performed as part of the SSPS Actuation Logic Testing, can not be accomplished for the balance of plant actuation logic systems. The balance of plant actuation logic systems do not have the same test circuits as the SSPS for checking continuity and so a note containing an exception to the definition of Actuation Logic Test for the continuity check is required in the SR. The auxiliary feedwater system design that this STS surveillance is intended to address is not part of the FNP design. Therefore, this surveillance is deleted. 5 ' The STS 92 day slave relay surveillance SR 3.3.2.6 is replaced with the FNP ITS 18 month slave relay surveillance SR 3.3.2.8. The FNP CTS do not contain this surveillance requirement. However, the FNP FSAR section 7.3 contains requirements for slave relay testing to be performed every 18 months. The STS slave relay testing is specified to be performed every 92 days (bracketed frequency) s g which is replaced by the current FSAR licensing basis test frequency of every 18 months. Therefore, this change to the STS is made in order to conform with the t[y i, current FNP licensing basis as discussed in the FSAR. Y I 6 The STS response time test surveillance SR 3.3.2.10 (FNP ITS SR 3.3.2.9) contains a note which provides an allowance for testing the turbine driven AFW pump. The STS note allows 24 hours after SG pressure is 21000 psig. The intent of the note is to allow the SG pressure to increase sufficiently to ensure the AFW pump is tested at an adequate steam header pressure. Although the FNP CTS do not contain similar provisions, FNP inservice and response time test procedures for the turbine-driven AFW pump contain provisions to ensure the pump is tested at appropriate steam supply pressures. Based on plant operating and testing experience, the time duration of 24 hours for performance of turbine driven auxiliary feedwater Chapter 3.3 ES-2-B May,1999

u-FNP TS Conversion Enclosure 5 - JD from STS Chapter 3.3 - Instrumentation STS 3.3.2 ENGINEERED SAFETY FEATURE ACTUATION SYSTEM (ESFAS) 4 INSTRUMENTATION FNP ITS 3.3.2 ENGINEERED SAFETY FEATURE ACTUATION SYSTEM (ESFAS) INSTRUMENTATION l JD NUMBER JUSTIFICATION (TDAFW) pump response time testing is acceptable. Therefore, the ITS time I duration allowance is maintained consistent with the STS. The ITS steam pressure requirement is revised consistent with the FNP design basis and inservice testing practices for the TDAFW pump.. The proposed steam generator pressure g requirement of;t 1005 psig corresponds to the Reactor Coolant System no-load, hot standby, Mode 2 operating T.,, of $47 'F. This Mode 2 requirement is consistent i y,bLOCA by(SBLOCA) RCP undervoltage analyses. No other Farley safety analyses ascreditatheprimary TDAFW e T pump as a primary enginal safety feature. In that the SBLOCA analyses only require automatic ESFAS response in Modes 1 and 2, automatic TDAFW pump start by RCP undervoltage is only required in Modes 1 and 2. The no-load RCS temperature is also consistent with the safety analyses initial condition assumption for 0 % RTP. Since the no-load RCS T. , correlates directly to the no-load steam generator pressure,1005 psig is an appropriate reference condition for TDAFW response time testing. The revision of the allowance contained in the STS note for this surveillance conforms to the current FNP Mode 2 no-load steam pressure and provides adequate assurance the pump is tested in a timely manner and at the required turbine steam pressure. 6a STS Surveillance Requirement SR 3.3.2.7 (FNP ITS SR 3.3.2.5) requires performance of a TADOT every 92 days. The surveillance applies to the RCP Bus UV instmment channels. STS SR 3.3.2.7 includes a provision for "not" verifying the UV relay setpoint. This pmvision is not applicable to FNP. At Farley, these relays can be tested and, if necessary, adjusted in situ. The supporting setpoint uncertainty calculations include a rack driA uncertainty allowance that bounds the expected rack driA for a healthy instrument channel. The allowance is based on quarterly surveillance to verify that the relay trip setpoint is within the established calibration tolerance. The quarterly surveillance is also in agreement with the analysis frequency modeled in WCAP-10271, Supplement 2-P-A. Therefore, consistent with the CTS quarterly functional test requirements for the RCP Bus UV functions for the RTS and ESFAS and the supporting setpoint uncertainty calculations, the RCP UV relays setpoint must be verified on a quarterly basis. As such, the Note associated with STS SR 3.3.2.7 is deleted in ITS SR 3.3.2.5. 6b STS Surveillance Requirement SR 3.3.2.10 (FNP ITS SR 3.3.2.9) is the performance of periodic response time testing (RTT). The surveillance applies to Chapter 3.3 E5-3-B May,1999

FNP TS Conversion Enclosure 5 - JD from STS Chapter 3.3 - Instiumentation STS 3.3.2 ENGINEERED SAFETY FEATURE ACTUATION SYSTEM (ESFAS) INSTRUMENTATION FNP ITS 3.3.2 ENGINEERED SAFETY FEATURE ACTUATION SYSTEM (ESFAS) INSTRUMENTATION JD NUMBER JUSTIFICATION the RCP Bus UV instrument channels, ESF actuation logic, relays, and the TDAFW pump, because the RCP UV signal is credited in the FNP Small Break LOCA gg analysis as a pnmary ESFAS signal (FNP FSAR Chapter 15.3). The surveillance does not apply to the automatic startup of the TDAFW pump by steam generator lp'g,1b ow-low l water level in two-out-of-three steam generators, because this function 3g provides backup protection in the safety analyses. Therefore, the RTT surveillance requirements for Function No. 6.b and Function No. 6.d on ITS Table 3.3.2-1 are revised to clearly indicate the .yropdate RTT surveillance for the TDAFW pump ESF actuation signals. Specifically, SR 3.3.2.9 for Function No. 6.b is footnoted to indicate that the test applies only to the MDAFW pump start on steam generator low-low level. SR 3.3.2.9 is added to Function No. 6.d. These RTT requirements are consistent with Farley FSAR Table 7.3-16 response time acceptance criteria and the Chapter 15 safety analyses modeling assumptions. Therefore, these STS deviations are acceptable. 7 The STS surveillance SR 3.3.2.11 is replaced with FNP ITS SR 3.3.2.10. The STS surveillance SR 3.3.2.11 was applicable to the P-4 interlock. The FNP ITS SR 3.3.2.10 is applicable to the trip of all main feedwater pumps auto start of the AFW system motor-driven pumps function. The proposed FNP ITS 3.3.2.10 corresponds to the surveillance requirements for this function as specified in CTS Table 4.3-2 (S/U) and includes the applicable CTS note #5 (if not performed within the previous 92 days). Therefore, FNP ITS SR 3.3.2.10 effectively retains the current licensing basis requirements for testing the trip of all main feedwater pumps function in a fonnat and presentation compatible with the STS. 1 The required P-4 interlock testing previously addressed by STS SR (3.3.2.11) is l replaced with FNP ITS SR 3.3.2.6. FNP ITS SR 3.3.2.6 requires a TADOT be performed every 18 months for manual initiation functions and is consistent with I the CTS P-4 testing frequency specified on Table 4.3-2 for the ESFAS interlocks (R). By assigning FNP ITS SR 3.3.2.6 to the P-4 interlock instead of STS SR 3.3.2.11, the STS frequency of testing the P-4 interlock 'Once per reactor trip breaker cycle" is revised to be consistent with the FNP CTS 18 month test frequeccy. Additionally, the "setpoint verification not required" note which modifies STS SR 3.3.2.8 (FNP ITS SR 3.3.2.6) is revised to include the P-4 interlock consistent with the P-4 STS surveillance SR 3.3.2.11 (the reference to manual initiation functions is deleted from the note). STS SR 3.3.2.11 includes the "setpoint verification not required" note for the P-4 intedock and is applicable to Chapter 3.3 ES-4-B May,1999

355 RTS Instrumentation B 3.3.1 BASES

ua _ - PS In MODE I above the P-7 setpoint and below the Mthi* DnB denn beis) i P-8 setpoint, the RCP Breaker Position (Two Loops) trip must be OPERABLE. Below the P-7 V ^ setpoint, all reactor trips on loss of flow are automatically blocked since no conceivable oower o _

                     , - _ - _ .                           distriby,tions could occur that would o use a DNB) ~

vioQin Se B l oncernm this low power level. Above the P-7 setpoint, the reactor trip on loss of flow in two DES p b SlS* RCS loops is automatically enabled. Above the P-8 setpoint, a loss of flow in any one loop will actuate a reactor trip because of the higher cfs 5 k82 6 p wer level and the reduced margin to the design IFde,.vndarvethqhhe 'lau esiM bemus' Ae tiie lassair af . roosfhtA.(Lt;ec'eath I RT83 6)lowm tirmu er re RC.9bu6FS 8 M h*t M i seconcla (an culdita'erathe deLs.e ss eEMFc}ecq,

                                                          ,s             --    -

2 _ m APPLICABLE 2. Undervaltaam Reactoc_raa' ant Pn= 'ggder te

            'FETY ANALYSES ME. SE Q                     W                        -

L and $tr The ndervo age RC s r or trip Fu tion ensures APPL BILIT TP that protect 1 on is provi ed against v lating the DNBR (con ued) limit due to p loss of ow in two more RCS loops. he voltage @ each RC s monitore Above the P-7 mrvM-h6 $ an a,ritic.: setpoint, a oss of voitage aetected on(Cw) or more M & tW for reaL+or kr%( -RCP buses will initiate a reactor trip.intiis trip .% pe, ec$ ion et gg, 4 c Function will generate a reactor trip before the Rt.p bu I gE Orb tri a Reactor Coolant Flow- Low (Two Loops) Trip Setpoint is Ic65 g reached.' Time delays are incorporated into the provided (Undervoltage.RCPs channels to prevent reactor trip oF 6 w hr.1 , No Gfd due to momentary electrical power transients.

   ' A .L b .k ari tri O c are4 9 % g 3e$ { (OThe tco reouires three Undervoltage C                                           channels                 's brNfMQ                                   ; Qer phase) per bus] to be OPERABLE.               ,

056 h. SweVeQ { thefuncMnah In MODE I above the P-7 setpoint, the Undervoltage RCP trip must be OPERABLE. Below the P-7 setpoint, all E l 9bilit 4.r. en a feWi6 %e, reactor trips on loss of flo blocked since no conceivabl automatically er distributions coul og r-g o g g pe g ,t; occur that would Eause a DNB concernlat this low er .e, t 4 e feat.kor ) level. Above ' P-7 setpoint, t.1e r a tor tr on a rr.ui+ loss 'of flow two or more RCS loops s au atically

 % L f o tec % o5 n 5s 4 M                          'l enabled.       T s Function uses the same ela             as the L'          _                          ESFAS Fun        ion 6.f, "Undervoltage Reactor oolant Pugip (RCP)" s rt of thegiary feedwa                         FW) pump y ses inp&                        C DT'        UB                       ..

S5 (con . WOG STS B 3.3-24 *f[n Driven

                                                                                        .           Rev1,04/07/95ce J

1 34 CHAPTER 3.3 INSERT PP TO STS PAGE B 3.3-24 l l FNP SPECIFIC UNDERVOLTAGE TRIP LOGIC BASES DESCRIPTION Two UV sensors (relays) are associated with each bus (one for each logic train). Each RCP bus is assigned to a protection channel. The actuation logic is two-out-of-three channels (i.e., buses) with loss of voltage. The RCP UV reactor trip logic is interlocked by permissive P-7. 1 W

3.%

  ,.       +'Y i

l l 1 i l Chapter 3.3 Insert Page l

[k U-/ L47.3fI ud,epen We Rc.P RTS Instrumentation E6b (fem)% M'4 brea.ke.r to pree_Lud.E B 3.3.1 vieL2.t I t [e b Ob desiinks,

IC f*d"Ai500 tel.DWh o f thelo AC Ih* Es.

                               ;                                         =,

S 71 Underfrecuency Reactor Coolant Pumos

  'p       *LTc h              M*              The Underfrequency RCPs reactor trip Function ensures h he priw tri               %p to that protection is provided against violating the DNBR

, fg,ged,, e /e j limit due to a loss of flow in two or more RCS loops

                         , Mo  et      ,f \fr'.,m a major network frequency disturbance. An l fp flow fr, gEw-- ,4 junderfrequency condition will slow down the pumps, L                                             thereby reducing their coastdown time following a pump M             3                       e4   trip. The proper coastdown time is required so that L

b.OrHowevtg M t f#tb /) 8 N . d y O il W 1 0f(} reactor trip. The frequency heat of eachcanRCPbe bus removed is monitored.pimmediat

                                                                                                            ,    Ps I %i$ fr/P SO46Le$ Th6                       Above    the  P-7  setpoint, a loss of frequency    detected mqig(jdilj]                                on two or more RCP buses will initiate a reactor tr ip. %# I g,g fgho 'nf                     ,         This trip Function will generate a reactor trip bef re the Reactor Coolant Flow - Low (Two Loops) Trip W       !'

k6M - E g.68

                                           ~ Setpoint is reached.& Time delays are incorporated into the Underfrequency RCPs channels to prevent spf              reactor trips due to momentary electrical power transients.
      \

APPLICABLE 13. Underfrecuency Reactor Coolant Pumos (continued) ' SAFETY ANALYSES, INSERT' l LCO, and The LCO equires three Underfrequency P channels 00 y A L BILI r to be OPERABLE.- cgges 7 % b d 'm elso the B 2-(. , In MODE 1 above the P-7 setpoint, the Underfrequency RcP g n ,pt>1 RCPs trip must be OPERABLE. Below the P-7 setpoint, .

               "t M8't'* *p                    all reactor trips on loss of 1           are automatically P"d 690d       h'b'** NI blocked since no conceivable r distributions could fecdvd is n Y inhAuN) Joccur that wouldCcause a DNB concerDat this low power CunW 9-1        uA Ad d ',"     h
                           *66"     "d        ' level. Above the P-       setpoint, the reactor trip on 5"'

loss of flow in two more pS loons is automatically C. 5 enabled f eQe e b/iBcle6tg y 14. Eteam Generator Water level - Low low The kilode Velve. The SG Water Level - Low Low trip Function ensures that ( gy;., Se.t int he protection is provided against a loss of heat sink and actuates the AFW System prior to uncovering the SG I' t b s Fu tio h"I* kte tubes. The SGs are the heat sink for the reactor. In p . % 3 e FiecL order to act as a heat sink, the SGs must contain a i i m d' f mtre p minimum amount of water. A narrow range low low level 4 C' W gg in any SG is indicative of a loss of heat sink for the (3D 80 J reactor?l The level transmitters provide input to the Q/^ "- SG Level Control System. Therefore, the actuation / logic must be able to withstand an input failure to the control system, which may then require the (continued) WOG STS B 3.3-25 Rev 1, 04/07/95

357 CHAPTER 3.3 4 INSERT XX Y,4'\b TO STS PAGE B 3.3-25 3 D,y FNP SPECIFIC UNDERFREQUENCY TRIP LOGIC BASES DESCRIPTION l Two UF sensors (relays) are associated with each bus (one for each logic train). Each RCP bus is assigned to a protection channel. The actuation logic is two-out-of-three channels (i.e., buses) with an underfrequency condition. The RCP UF reactor trip logic is interlocked by permissive P-7. INSERT 00 TO STS PAGE B 3.3-25 FNP SPECIFIC UNDERFREQUENCY TRIP BASES DESCRIPTION For underfrequency, the delay is set so that the time required for a signal to reach the reactor trip breakers after the underfrequency trip setpoint is reached shall not exceed 0.6 seconds. 1 - Chapter 3.3 Insen Page

3 79 RTS Instrumentation Nf',o F, RcP UV -& 94P OF, bee sensors assmM ' en t BASES whk hfN'M)-

                                           > @Yo Sesh %e regvwmis of Ah M. Lc % sof u               i is adequate. The Completion Times of within I hour and once per 12 hours are based on operating-experience in performing

! the Required Actions and the knowledge that unit conditions

g. will change slowly.

vn p Re:etordda.nY j M.1 and M.2 A.w-1.ma(Saff o j

i. ,p); Condition M applies to the following reactor trip Functions:

Pressurizer Pressure - Low;
Pressurizer Water Level - High; M
Reactor Coolant Flow- Low (Two Loops);
RCP Breaker Position (Two Loops);
Undervoltage RCPs; and i I eh fnp preistfion TSTF-ilo9 provideck is no
Underfrequency RCPs. STE.g Lon er rquired.

p.g G

'(

g\,Jr With one channel inoperable, the ino rable c nnel must'be I 9 placed in the tripped condition withi 6 hours. Placing the ) channel in the tripped condition resul f\ W@ # (9 ) i ** in a partial trip condition r quiring only one additional hannel t> initjat rip above the P-7 setpoint aind below t ie '- 8 T5TF h (asetpoint reacto These Funct ns _do not have'to be OPERABL E below J (* L ta tno P-7 setooint becaus 1ere are nu soss of tiow trms ow the P-7 setpoint) T1e 6 hours allowed to place Te The. Reudor Co$lut.W ciannel in the tripped condition is justified in Flow-Low (Si le Reference 7. An additional 6 hours is allowed to reduce LFunehd i

         % Ni*"       esneh 0       THERMAL POWER to below P-7 if the inoperable channel cannot a restored to OPERABLE status or placed in trip within the s

ha.ve.to belowthebe P4orsanets. setp:i.n t lectfied Completion Time. A howeve the R vireed owance of this time interval takes into consideration the

                     !tt         Oc r undant capability provided by the remaining redundant MS                M      and M.2 (continued)

WoferaA ofthek7 BLE channel, and the low probability of occurrence of M n ent during this period that may require the protection W8, af rded by the Functions associated with Condition M. in (o hour $ b dhe.ted.coengonerifs' , between % b , i w c L k R a u k &e r <

                                                       *M                                       (continued) w e                     r                                                                       l WOG STS                                       B 3.3-46                        Rev 1, 04/07/95
                                                                                                            ]

t.

3H RTS Instrumentation

                                                          .                                                   B 3.3.1 BASES SURVEILLANCE                SR 3.3.1.8                          !                                                ,

REQUIREMENTS . . !' (continued) SR 3.3.1.8 is the performance of a COT as described in SR 3.3.1.7, except it is modified by a Note that this test shall include verification that the P-6 and P-10 interlocks are in their requir.ed state for the existing unit condition. he. quency-is modified by a Note that allows this

                                         ;ur      lance to be satisfied if it has been performed within l92 days of the Frequencies prior to reactor startup.and four hours after reducing power below P-10 a11d P-6.               The E                    Frequency of " prior to startup" ensures this surveillance i performed prior to critical operations and applies to the f4e source, intermediate and power range low instrument.

A4ed erv. E channels. The Frequency of "4 hours aft.er reducing power t below P-10" (applicable tofintermediate 'nd >ower range low D A'"15 * " >elow P-6" M& M Mh channels) and "4tohours (applicable sourceafter rangereducing channels)pallows wer a normal Eb.wwia!64er- shutdown to be completed and the unit renNnied from the MODE g M,pt- hk perform of Applicability ~ for this surveillance without gy4 the test'ing required by this 's'urvefilan.a _ delay to ce.' The

       /. N                           IFrequency of every 92 days thereafter applies if the lant CMwNat M O                   remains in the MODE of Applicability after the initia Q%,'sbNcM performances of prior to reactor startup and four hours Ash after reducing power below P-10 or P-6.A The MODE of Applicability ror Inis , surveillance 1s < P-10 for the power
                  ?A    1.             range low.and intermediate range channels and < P-6 for the source rangii channels. Once the unit issin MODE 3, this surveillance is no. longer' required. If power is to be maintained < P-10 or < P-6 for more than 4 todrs, then the testing required by this surveillance must be performed prior to the expiration of the 4 hour limit. Four hours is a reasonable time to complete the required testing or place the unit in a MODE where this surveillance is no longer required. This test ensures that the NIS source, intermediate, and power range low channels are OPERABLE                               !

prior to taking the reactor critical.and after reducing 1 power into the applicable MODE (< P-10 or < P-6),for periods. .i

                                      > 4 hours.                                                       ,       ,

(, Tl$C.-/3a.,] MOVE To SR 3.3.1 . gg

              $h                      SR 3.3.1.          the performance of a TAD 0T and is performed every 92 days, as/ justified in Refere e 7.                                        ,j
            %e.s  9

__n u, nwa w+ stay (continued) a r:ye 333 7 WOG STS B 3.3-56 Rev 1, 04/07/95 L, . ., . .

S RTS Instrumentation B 3.3.1 BASES 60'I3 SURVEILLANCE SR 3.3.1. continued) REQUIREMENTS- - The 5R 15 moolried by a Note that excludes verification of rM setpoints from the TADOT. Since thts SR applies to RCP yy undervoltage and underfrequency relays, setpoint verification requires elaborate bench calibration and is gg, accomplished during the CHANNEL CALIBRATION. j i y,3.Y g SR 3.3.1.10

            $.3.V ACHANNELCALIBRATIONisperformedevery( 8( months, or r       3                approximately at-every refueling. CHANNE'. ChlIBRATION is a LE-NJ complete check of the instrument loop, including the sensor EE From 3.'5.l.it            The. test verifies that the channel responds to a measur
               =          ,      parameter within the necessary range and accuracy            4 o,,nck ne need,                                                                  NN the - -

j b pt.rb M CHANNEL CALL.BPTIONS must be performed consistent eT witha Survet M f t Lgittorence netween Ine cu renu "as found" values cana t b Wrdf N S Igrrev ous test as lert" vafues munt be ennr n :enT) with he N I t CDMMS ypLdunn N 6 lar1rk' allowance usea,in tne setpo' ogy.[i.e .A.orde nt methodo' plankb , / The Frequency of 18 months is based on the assumptTon or an lj dine 1 18 month calibration interval in the determination of the m. E. oheridhaa / magnitude of equipment drift.in the setpoint methodolog. 5R 3.3.1.10 is modified by a Note stating that this test' as shall include verification that the time constants are bc.; US The.6 llc$ry:.e adjusted to the prescribed values where applicable, j t wheqerwf. 1 I g OO8 n [SR 3.3.1.11 (T6C-ID /8

SR 3.3.1.11 14,the per nceofaCHANNELCALIBRATION.as) i descr eed in TR 3.3. 10. [181_ months.1 This SR is e t neutron detectors are

_- modifiedbn@Noteltat excluded from the CHANN IBRATION The CHANNEL pg, NoICS. CALIBRATION for the power range neutf5ndetectorsconsists , of a normalization of the detectors b ased on a power ! calorimetric and flux map performed bove 15% RTP. The l CHANNEL CALIBRATION for the source r nge and intermediate j range neutron detectors consists of obtainin t e detector ;

                                                                        & e. p % N C u

(continued) ! WOG STS B 3.3-57 Rev 1, 04/07/95

392x CHAPTER 3.3 INSERT YY TO STS PAGE B 3.3-57 FNP SPECIFIC ITS SR 3.3.1.6 BASES DESCRIPTION The test includes the undervoltage and unde-frequency sensing devices that provide actuation signals directly to the SSPS. The test functionally demonstrates channel OPERABILITY including verification of the trip setpoint. If necessary, the undervoltage/underfrequency setpoint is restored to within calibration tolerance. The frequency is based on instrument reliability and operating history. In addition, it is consistent with setpoint uncenainty calculation allowances for rack drift in Reference 6 and analysis modeled in Reference 7. A 332Y 33 Chapter 3.3 Insert Page

RTS Instrumentation B 3.3.1 BASES' SURVEILLANCE- SR'3.3.1.(6 ' continued)

           ' REQUIREMENTS The analyses model the overall or total elapsed time, from g

p the point at which the parameter. exceeds the trip setpoint

       %                         value at the sensor to the point at which the equipment p'g        reaches the required functional state (i.e., control and

[j shutdown rods fully inserted in'the reactor core). l 40 p edy For channels that include dynamic transfer Functions (e.g., l M,NA lag, lead / lag, rate / lag, etc.), the response time test may o r-ocuytect (be performed with the transfer Function set to onef witn thir crMr.a., ~ Jresulting measured response time compared to tne lppropriate

                               ,FSAR response time. Alternate 1v. the resnonsa time test card with the time constants set to their nominal W      erforme {a 6ne requirea response time is analyticall vaijegy,v,,

realculated assuming the time constants are set at their nominal values. ThTresponse time may be measured by a l M series' of ovevlipping' tests such that the entire resnonsa !- 11mm it mammured.f IN6ERT g C.TS BASES pr te, each channel's response must be verified i discusskn As every app 8/ months on a STAGGERED TEST BASIS.V Testing of the h For Res final actuation devices is included in the testing. l , Response times cannot be determined during unit operation ! M M. "p'becauseequipmentoperationisrequiredtomeasureresponse l times. Experience has shown that these components usually , pass this surveillance when performed at the 18 month I i Frequency. Therefore, the Frequency was concluded to be i l acceptable from a reliability standpoint, i SR 3.3.1 modified by a Note stating that neutron detectors are excluded from RTS RESPONSE TIME testing. This Note is necessary because of the difficulty in generating an appropriate detector input signal. Excluding the detectors is acceptable because the principles of detector operation I ensure.a virtually instantaneous response. PS E 9/ REFERENCES 1. FSAR, Chapter {7 M8 4'3'I'3 v l

2. FSAR, Chapter Euh ve.cht.'on ska.u ,

Jt./ tnr Lucle, cJMewb onS & !

      ,-                       3.      FSAR, Chapter [15 .-               tra m s4 %.t, b              A.

l l t tralnnevenbe,en cd.> M

4. IEEE-279-1971. I ome.per36mooY$5 (continued) l i

WOG STS B 3.3-60 Rev 1, 04/07/95

                                                  !             ESFAS Instrumentation B 3.3.2 BASES these Functions are the same as the requirements for their SI function. 'Therefore, the requirements are not repeated in Table 3.3.2-1.

Instead Function 1, SI, is referenced for all initiating functions and requirements. Turbine Trip and Feedwater Isolation Functions must be OPERABLE in M00ES I and 2f[and 3] except wnen ai NFIVs, MFRVs, ;and associated bypass valves) are closed and [de-activated] [or isolated by a closed manual valve] when the MFW System is in operation an the turbirie annerator may be in operationJ En 4 MODES W 13, b, 5, and 6, the MFW System and the turbine APPLICABLE c. Turbine Trio and Feedwater Isolation - Safety SAFETY ANALYSES, Iniection (continued) l LCO, and l APPLICABILITY generator are not in service and this Function is not required to be OPERABLE. d'

        't[\,d

6. Auxiliary Feedwater yy p - The AFW System is designed to provide a secondary side J

heat sink for the reactor in the event that the MFW 5ed M

'~

System is not available. The system has two motor

            *^           driven pumps and a turbine driven ump, making it available during normal unit o ation, d h'"#

oss l AC power. a loss of MFW, n uring a eedwater i System pipe breal* The norma source of water for the g AFW System is the condensate storage tank JCSTh r( ly afe y at A low level in th CS I NA aut a all lig pump /sucti to e gp , dnti S vi W er I . ':vetd (saf v rel ed J 7ht AFW System is aligned so that_ upon a pump start, flow is initiated to the respective]SGs immediately. 1

a. Auxiliary Feedwater - Auenmtic Ac':ua'; ion loQic and Ae"uation Relays ((So' id State Pro':ection3-4 ,

TE Automatic actuation logic and actuation relays h consist of the same features and operate in the same manner as described for ESFAS Function 1. JP *bt (continued) l l WOG STS B 3.3-93 Rev 1, 04/07/95 1

ESFAS Instrumentation B 3.3.2 BASES

b. Au[iliaryFe[dwater-A[tomaticIctuationidaic a6d Actuati4n Relays Malance of Plant ESFAS)

N/e pyg Automati actuation ogic an actuation elay consist f the sa features and operat in e same a ner as de ribed fo ESFAS Func ion .b. W"y RSE b,[ Auxil'iary Feedwater - Steam Generator Water

                                                  ~
                                                        "   "                                      [w g The, SC, uahr t.evel                                                                     h e+ M nts h 5 N N SG Water Level - Low Low                    vides protection        N
         /   In e. InSivumenf
                    .Frenew                against    a loss  of heat sin A  A feed line break, inside or outside of containment, or a loss of 5     on enc.h SG,           MFW, would result in a loss of SG water level.

SG Water Level - Low Low provides input to the SG APPLICABLE h Auxiliary Feedwater - Steam Generator Water 1 SAFETY ANALYSES, Level - Low Low (continued) LCO, and APPLICABILITY Level Control System. Therefore, the actuation logic must be able to withstand both an input R A5 FSD 2.82.5 failure to the control system which may then require a protection function actuation and a 3 ** 0" " single failure in the other channels >rovidinq__ b the protection function actuation. JTius, four l neis, m O4 3PERABLE channels are required to satisfy the 1 On 6 d requirements with two-out-of-four logic. For delador /6 ' units that have dedicated protection and control for use M*4 channels, only three protection channels are i tua.fer level do necessary to satisfy the protective requirements.

    / d uo i e rn, T A e @ /2         [    Forotherunitsthathaveonlythreechannels,af f-    g         o g fjof) g,4         hedian     signal selector is provided or l

g gg Justification is provided in Reference 7. J e f YEEE 279 /5 With the transmitters (d/p cells) located inside g/s[M th c. containment and thus possibly experiencing

         #            #     g              adverse environmental conditions (feed line break), the Trip Setpoint reflects the inclusion l

_g g/ecIbf g of both steady state and adverse environmental i ggg/re, instrument uncertainties. l f.o e/)6ure N 0. * . Auxiliary'Feedwater - Safety In_iection W I$ del,tt.$Ed

_O An signal starts the motor driven (nd turbine)

PSC. rive AFW pumps. The AFW initiation functions ! 1e same as the requirements for their SI are (continued) WOG STS B 3.3-94 Rev 1, 04/07/95

w -- ESFAS Instrumentation B 3.3.2 BASES function. Therefore, the requirements are not repeated in Table 3.3.2-1. Instead, Function 1, y'[gf g SI, is referenced for all initiating functions y , and requirements. ISC l Auxiliary Feedwater - Loss of Offsite Power g

        -        5
                    ]we 2 pg oss of offsite power to the service be a ompanied by a loss of reactor es will lant pumping    wer and the subsequent       ed for some h "M M                   method of      ay heat removal.      e loss of N     *.9* T"A A < alt b Aeblend offsite power

detected each service bus. Loss a voltage drop on power to either i

4 he sc,5 4 M service bus will sta the turbine driven AFW 3 podv\M w4 pumps to ensure t a east one SG contains j enough water t erve as t heat sink for APPLICABLE e. Auxiliar eedwater - Loss of 0 te Power SAFETY ANALYSES, (con ued) LCO, and APPLICABILITY eactor decay heat and sensible heat remov

)'

following the reactor trip.

     '***I    6Y*I 'n MM             Functions 6.athrough6hstbeOPERABLEinMODES1, NES         2, and 3 to ensure that the SGs remain the heat sink
    $a.s.d6A peaw  Ok=*E5F 3              tor tne reacto7:=j SG Water Level - Low Low in any 6%       4 tos of bt g & eved3,peno44, operating SG will cause the motor driven AFW pumps to start. The system is alioned so that upon a start of the pump, water immediately begin to flow to the SGs.U-
     .resiem bb ksM SG Water Level - Low Low in an         wo operating SGs will       l

Yy' F _ cause the turbine driven pum to start These l

Functions do not have to be 0 ERABLE i DES 5 and 6

                             -       because there is not encuah heat be          generated in S*t *.6 bAug yobb{r

h. e reactor to require the SGs as a heat sink. In MODE 4, AFW actuation does not need to be OPERABLE tog g. w t s&k eveJ9 because either AFW or residual heat removal (RHR) will

            -                        already be in operation to remove decay heat or
       ?* *

b. T *' p
sufficient time is available to manually place either '

h,5% ,u not M system in operation. cl. [ Auxiliary Feedwater - Undervoltace Reactor

                   /                                              /

A loss of power on the buses that provide power to the RCPs provides indication of a pending loss (continued) WOG STS B 3.3-95 Rev 1, 04/07/95

                                                                              ~_                ESFAS Instrumentation Tk SBLoc BASES
                                                                                           ]            5h          *p oj.5% twg*                       % Esms spal.

of RCP forced flow in the RCS. he Undervolta e

                   )#       g                                RCP Funi: tion seitses the voltag        ownstream of Y fach RCP breaker / M loss of powerI or an open]
           $[?               dWNN8-                       MCP hreakerJ o@ ormoreRCF(Lwillstartthe                             buse5 SGs CCM                         turb- ne driverVKFW pump to ensurT thatQt leas gneSGcontainjsse)ughwatertoserveasInenea Two            OV m 4
                                                             'ina for roact decay heat and sensible heat auc hth A es, V                                    removal fo' lowing the reactor trip.

b5 (one. %c exk \o31c Auxiliary Feedwater - Trin of All Main Feedwater M4 Eub RW M . . U owyelb pAu.4 } C

l A Trip of all MFW pumps is an indication of a M

W N OU D D W """

                        "' O ^^                            loss of MFW and the subsequent need for some method of decay heat and sensible heat removal to uv rew.W                MM                          bring the react w hack to no load temperature and M
         ~B W PM                  'N'                        pressure. JA t      *bine driven FW pump s equ1 pea w       two pres   ure switche on the c trol            r/ oil APPLICABLE                        g.         .

xiliary edwater-Tr of All in Fe water SAFETY ANALYSES, NEDI ( ntinued) LCO, and APPLICABILITY line f the spee control s tem. low l l press re signal om either of the pressur l PSC. 1 swi has indic es a trip f tha pump. No or

                           -                    Q          dr en MFW p           s are eq pped w h a brea r TMSEeJN                         /\              sition se ing devic . An o en supply reaker g pgpppg                            3 ndicates hat.the p ..is n running. Two
                                                          !0PERABL channels p r pump            tisfy re DESchfcN                                 requir , nts with ne-out f4Wo tak               ndancy twie       j{

logi . A trip all MF pumps st ts the otor

                                                          'dr en and tur ne driv n AFW pum to en re at at leas one SG - availabl with ter t                    the
                                                        , =t a s       :he   at sink for the r ctor.                     M^

6 E and 6.o st be OPERABLE in 1

and 2. This iFnsures that gt least one 5: LID provided dC~20 with water to serve as the heat sink to reniove reactor decay heat and sensible heat in the event of a- >-

accident. In MODES 3, 4, and 5, the RCPs (nd J FWT ' may be normally shut down, and thuscnenner pump 3

                   .Q n        ,

3 AFW n tiati indicative of a condition re utrin automatic e .u.

                                                                                                   ,g,3,
                                                                                                    " **f , W9g% ses

. ZNSEA.T O ~ FHPSjoecibb ---)> R,ne.+,on e

              / dA5cft)7/0/>                                                                                (continued)

W WOG STS B 3.3-96 Rev 1, 04/07/95 u . _

45 4 ESFAS Instrumentation B 3.3.2 BASES.

Undervoltage Reactor Coolant Pump.

If one channel is inoperable, 6 hours are allowed to restore 5/y one channel to OPERABLE status or to place it in the tripped TV f -canattion.WIf placed in the tripped condi'ilon, the Functi n Tg' ( Qis than in a partial trip condition where one-out-of-two C (6ne-out-of-threOlogic will result in actuation. The 6 hour completion 11me is justified in Reference 8. Failure to F c RcP UV b.4 restore the inoperable channel to OPERABLE status or place

       %3 ggg                  it in the tripped condition within 6 hours requires the unit I-                       to be placed in MODE 3 within the following 6 hours. The 1

[ {g . allowed Completion Time of 6 hours is reasonable, based on operating experience, to reach MODE 3 from full power i

      >8tPh h,ff@84 (80systems.     'phM conditions In MODE 3, these  in Functions an orderlyare nomanner        and withou longer required 4o so b M              OPERABLE.

ca y em E k W L \e ACTIONS I.1 and I.2 (continued) The Required Actions are modified by a Note tha allows the inoperable channel to be bypassed for up to 4 hours for surveillance testing of other channels. The 6 hours allowed to place the inoperable channel in the tripped condition, and the 4 hours allowed for a second channel to be in the bypassed condition for testing, are justified in-Reference 8. O J.1 hd J.2] , Condition J applies to the AFW pump start on trip of all MFW pumps. , If/6fRTp This act n address thetrainhientationo the SSP for gp i the auto art funct n of the AF' System on 1 s of al MFW I umps. The OPERABILI of the AFW ystem must assure by ! SPEdFlo lowing aut atic star of the AFW stem pumps. If a i ch nnel is in erable, 4 hours are a lowed to ret n it to i an ERABLE st us. If t function c not be retu ed to ' an 0 RABLE stat s, 6 hour are allowed :o place the nit in T6C.- 1 MODE 3 The allo d Complet on Time of I hours is reasona e, based operatin experience, to reach MOD 3 from ful ower con tions in orderly ma ner and witho t ! challengin unit syst ms. In E 3, the un t does not ha e s . , (continued) l WOG.STS- B 3.3-112 Rev 1, 04/07/95 u- -.J

M/ g S strumentation 912 A % o B 3.3.2 Q .Q ~~Mt anwe Wkle fw "h h% fhe Est%6 acabuAc&+ S BASES g3 4 n rwg o pgLW y M . L@%u based on Gndustry) operating ience, expei considerlnM 6 e @. instrument reliability and operating history data. l

      %e Mkbc.kl\                                                      N-                                     ~l le=ndwksc.dl             SR    3.3.2 f G

N8T ' SR 3.3.2 is the performi nc Lof a TADOT everv 92 WD *W 'D This test is a check of that.oss of Offsite Power,' days. A M se@d. P d Q Undervoltage RC M nd AFW Eumo Suction Transfer on Suction 3 m a m , the o'ressure - Low f unction 574ach>Funct' on is tested up to t,he, ss ! veksdg' @nd ncruaing, the master transfer re' ay coils 24 c.c M , l g,,4 ,, ta_Adenvo%e' 5'inW *M M The test includes deVITeYInm irovice actuation be , d4

       $6 A^O signals d        tly to the S PS. fThe SR 's socirled by a Noti at excluaes veruication or s'etpoints for relays. RelafAbasS6 )          %'o h l        Meruc.c                setpoints require elaborate bench calibratian and are / %\oes verified durina CHANNEL CALIBRA" ION.I Ine Freauency-is                               W l

Mb, .4 'S adequate. It is based on en1uary operatina ernariance,J

                                                                                                         / 5et*M      (

T 4 3.12-I. c m;.4s.3r +/,'4 unnsiaeringlinstrument relia 11' sty and operating history 3 Se% werb.h cAwh ob=w.s at in anu G d M $' t m , W w w erew.4 s. - - - a,ncLthe.FW l UR E LL C E~ ~ SR 3.3.2 F6 triterloc.K Fsedien c.y REQUIREMENTS 7# - '= (continued) SR 3.3.2 is the performance of a TADOT. his test is a J2 -

                          @ _c_ heck of he Manual Actuation Functions (andIAFW pump start)

PSC. von trin nr ali- new ma as/. It is performed every i Tn8LE 43-2. M 18flifonths. Each Manual Actuation Function is tested up l We to, and including, the master relay coils. In some instances, the test includes actuation of the end device l MM88tJS (i.e., pump starts, valve cycles, etc.). The Frequency is Teshy to be. / adeauate, based on industry operating experience and is berf,yycL., 3 consistent with the typical refueling cyclet ThdRis og,j g modified by a Note that excludes verification of)Fetpoints Iduring the TA00T.Yor manual initiation runctic nsa. The dufly> Whe.r ne@e.465 . manual initiation Functions have no associatec setpoints.

7 CncI P. 0 derloc.k] QSC- 7) ~ SR 3.3.25)

                                           =r                                         /

SR 3.3.2 8 is the performance of a CHANNd CAL RATION. ACHANNELCALIBRATIONisperformedevery[18 months, or approximately at every refueling. CHANNEL CALIBRATION is a i complete check of the instrument loop, including the sensor. l l (continued) WOG STS B 3.3-118 Rev 1, 04/07/95

Nk ESFAS Instrumentation B 3.3.2 BASES The test verifies that the channel responds to measured parameter within the necessary range and accuracy. CHANNEL CALIBRATIONS must be performed consistent with

      ""h,Q                kansumotions of the unit specific setpoint methodolou.s;         he i
                             @ fference between the curren") "as found" values en( the]
   '  b        "               >revioun test as iert vaiueo must De constutenn with4the          I drift a'lowance used in the setpoint methodo' Q.e.2bo TheTFre ency of 18 months is based on the a>>umpt10n
                                                                                        ^

Tr M h) an ",18 month calibration interval in the determination of the magnitude of equipment drift in the setpoint methodology. This SR is modified by a Note stating that this test should include verification that the time constants are adjusted to the prescribed values where applicable. SR 3.3.2 This SR ensures the individual channel ESF RESPONSE TIMES are less than or equal to the maximum values assumed in the SURVEILLANCE SR 3.3.2. (continued) REQUIREMENTS accident analysis. Response Time testina necentanea N 9 criteria are included in the Eec inical Reiuirements ManuaD FSAR i Tojele, ecti n IU(Ref. 9). Individual componen; response times are not modeled in the analyses. The analyses model the 7.3 -/6 ov.erall or total elapsed time, from the point at which the , parameter exceeds the Trip Setpoint value at the sensor, to

 \g        g                 the point at which the equipment in both trains reaches the 3,                          required functional state (e.g., pumps at rated discharge pressure, valves in full open or closed position).

d5 For channels that include dynamic transfer functions (e.g., M h c#TM lag, lead / lag, rate / lag, etc.), the response time test ma:r . be performed with the transfer functions set to oneJwith "hel

     % ree*4j t

d#nheA att %d : esulting measurea response time compared to Ine appropriate SAR response ti ne. Alternately. the resnonse time test ca) Cri ia- . e performe Fwit1 the time constants set to their nor.1nal val , rovicea Ine requirea response time is anaiyticall a cu ated assumino the time constants are set at the nominal values /Qhe response time may De measurea Dyg IN66&T - J CTS BASES Discusbion (C "ti""'d) WOG -119 Rev 1, 04/07/95

I ESFAS Instrumentation B 3.3.2 BASES cts 4 3 Iseries of overlapping tests such that the entire response time is measured. r h Eu.h veriGiahen . ESF RFKPONSE TIME tests are conducted on an nth htLiM F ' STAGGERED T EST BASIS.* Testing of the final actuation Leastene lop

1 devices, which make up the bulk of the response time, is t'rdn sue.h t'.M T included in the testing of each channel. The final both Lepc tr5W actuation device in one train is tes l

h each channel.

o. M L. v e # M e d . M re ore, staggered testing results sponse time 1 L.ea.donca.ptr4 ri ation of these devices every months. The i twonths. 18 month Frequency is consistent wit the typical refueling cycle and is based on unit operating experience, which shows that random failures of instrumentation M an op** h, components causing serious response time degradation, but l

89er4m6 2.4 h wsis el failure a infrequent occurrences.

1 s %Woue s 1 5 :

[ 4.eb d%ht. is modi edbyaNotethatclarifienthat'thE --4.. 0.<- - ' T pa d .v. = d M 8 turbine dri i pump is tested within!24! hours after. D N) g re M jreaching 000 sig in the'SGs. m --

     % +ssh A 6 W                                IO                         AFU.) pump $Uen$hf 0f f SR          3.3.2            (TSC.-7) '             A4& purnp       ur<.fi on
           ^*

3 SR 3.3.2.6 is the performance of a TADOT as described A r SR 3.3 2j, except that it is performed for theQ-4 Reacto.r) (SURVEIILANCE SR '. i

                                                                                 ''.< F
                                        -3.3.2fDE (continued)(!II JE@IREMENTS                                                 Ji     o-

Lrip T InterlockJ and the Frequency isConce per RTB cycls7 f{cmise yd<M inis7 requency is based on operating experience. I

 ,   ok h w          C.- 7    'demonstraung Inat_unaeteuco rauure of the P-4 Interloctr samathnes occurs when the RTB is cycled)

S P'4was. The SR is modified by a Note that excludes verification of

        $                        setpoints during the TAD 0T. The Function tested has no 73;t-l                   associated setpoint.

9 31,b REFERENCES 1. FSAR, Chapter 6 (mtor MuP

2. FSAR, Chapter 7 ffnoffe d rm e b ' b *

                            ' 3.          FSAR, Chapter     15

f"#

4. IEEE-279-1971. SC-7 (continued) 4 WOG STS B 3.3-120 Rev 1, 04/07/95 4

II i i l l I i Associated Package Changes for RAI-3.3.2-2 i 1 1 i l l l

c

                                                                                                       )
                                                    %o                  ESFAS Instrumentation B 3.3.2 BASES I

STAGGERED TEST BASIS. The time allowed for the testing (4 hours) and the surveillance interval are justified in Reference 8.

                                     't SR 3.3.2 g                  SR3.3.2[stheperformanceofaCOT.,

Yp A COT is nerf d on each required channel to ensure the ntire channel will pe the intended Function. g ,g setpoints must be found ithin the Allowable Vilume --- aAa. specif in Table 3.3 1. g , g ) bemsum Therattterance between tne curreni"as rounP vaTuesUma th@

       "                  >revious test "as ' ef :" y uuss sus ne c msmenuwiti e ar m all.owance used <n tie satpoinu mettodo ogy.t The setpoint shall be left set consistent with the assumptions of the current unit specific setpoint methodology.
               @      lhe "as found" and "as left" values must also be recorded) N/A pd reviewed for consistency with the assumptions of-thd FNP I

SURVEILLANCE SR 3.3.2 continued) o" REQUIREMENTS O [tapplicable. surveillance intervalixtension analysis (Ref The Frequency of 92 days is justified in Reference 8. _ _ M04 TO B or m M when WI I bt dortecy 4 SR 3.3.2 no adverat,tmp64 ten ne %i-SR 3.3.2 s the performance of a I5bVE RELAY ST. The 8A 8 SLAVE RELAY TEST is the energizing of the slave elays. 4j g ggg Contact operation is verified in one of two ways. Actuation ( p g b".4 equipment that may be operated in the design siti pation MODE is either allowed to function, or is placed in a :ondition where the relay contact operation can be verifie without I operation of the equipment. Actuation equipment that may S.3g/2- not be operated in the design mitigation MODE i prevented f t from oneration by the SLAVE RELAY TEST circui latter case,t' contact operatio For this verified by a continuity check of the circuit contai g the slave relay. This test is perfomed every([92) days} The Frequency is adequate, j [7kh

                                              -5                                 (continued)            ;
 .       WOG STS                               8 3.3-117                     Rev 1, 04/07/95

M/ dh h E,$rg hI [ h BASES fw# ~.g ~%@%g b nom ga- M .*y.m g_ggc=AwkJ wy s M - Aks%ne~p 4= M ey&et. ' basedonfindustry]operatingexpeiiince,considerlngl instrument reliability and operating history data. ( 5 i (TX~I2 y he -j > SR 3.3.2 m SR 3.3.2 s the perfo Mnct of a TADDT everv 92 This test is a check of tw.oss of Offsite Power > days. 1

          %C.      4 Undervoltage RC V'Ind AFW Bumo Suction Transfer on Suction 3 ;

Trressure - Low runctionpEach7Funct< on is tested up to the., _ ay coilsJC-4nd ' ncruaing, the master transfer re' 45P5 The test neludes trip devices that provide actuation signkls d'rectly to the SSPS The SR is modified by a Note - Cmk that aveludes verificatio setpoints for relays. Relay INi setpoints4equire relaborat p bench calibration and are U verified during CHANNtL CA.IBRATION. The Frequency is adequate. It is based on industry operating experience, considering instrument reliability and operating history data. b a,ncL the. P SURVEILLANCE SR 3.3.2 trduicc K Endon (,4 REQUIREMENTS (# -

(continued) SR 3.3.2 is the performance of a TAD 0T. his test is a A - check of he Manual Actuation Functions indIAFW pump start) M n tria af all m v o - s4 It is performed every MTatLE *M-1. A tl8 % nths. Each Manual Actuation Function is tested up go 1 *- to, and including, the master relay coils. In some 7 instances, the test includes actuation of the end device MMS I (i.e., pump starts, valve cycles, etc.). The Frequency is adeocate, based on industry operatina exoorience and is "fkabrNJfahe. / [ pfymec[,,, 3 cons < stent with the typica'. refueling cyc'et Th0R is modified by a Note that excludes verification ofAetpoints dUDOS8hddeWh5 Idurin the TAD 0T,for manual initiation i unctic n n. The (gherfmetAW manua initiation Functions have no associatet setpoints.

               -- v                   7              eM P4eder% Q5C.-7)   -

SR 3.3.2M

                                     'T SR3.3.2$istheperformanceofaCHANN CAL RATION.

A CHANNEL CALIBRATION is performed every 18 months, or approximately at every refueling. CHANNEL CALIBRATION is a complete check of the instrument loop, including the sensor. (continued) WOG STS B 3.3-118 Rev 1, 04/07/95

s Associated Package Changes for RAI-3.3.2-3 l l 1 1 i l l l l l I I l l 1 4 l l l l l l l l i l l l l l l l I l r i l

FNP TS Conversion Enclosure 2 - Discussion of Changes to CTS Chapter 3.3 - Instrumentation CTS 3/4.3.2 ENGINEERED SAFETY FEATURE ACTUATION SYSTEM INSTRUMENTATION FNP ITS 3.3.2 ENGINEERED SAFETY FEATURE ACTUATION SYSTEM INSTRUMENTATION'(ESFAS) FNP ITS 3.3.5 LOSS OF POWER (LOP) DIESEL GENERATOR (DG) START INSTRUMENTATION FNP ITS 3.3.6 CONTAINMENT PURGE AND EXHAUST ISOLATION , INSTRUMENTATION l DOC HQ SHE DISCUSSION 27 A The CTS turbine trip and feedwater isolation function is revised by the addition of safety injection to the initiating functions consistent with the STS. The addition of a separate line item for the safety injection initiation of turbine trip and feedwater isolation is consistent with the FNP design and provides a more complete list ofinitiating functions. The addition of safety injection as an initiating function serves only to provide a complete list of , initiating functions and to clarify the relationship of safety injection to the ! automatic actuation of the turbine trip and feedwater isolation function. The applicable requirements for safety injection are all addressed under the safety injection function and no additional or new requirements are implied or expressed by the inclusion of safety injection under the turbine trip and , 4j feedwater isolation function. Therefore, the addition of this function to the ;

   $,I             initiating functions is considered administrative and is made to conform t                with the presentation and format of this infonnation in the STS.

l 28 Not Used. l 29 LA The SG water level low-low auxiliary feedwater initiation function is revised consistent with the STS. The details describing the initiation J functions performed by this ESFAS function are moved to the bases. The l

                  . SG water level low-low instrumentation functions to start both the motor and turbine-driven auxiliary feedwater pumps. The CTS contains separate line items (functions) for each type of auxiliary feedwater pump. However, the SG level channels required operable to perform either of these start          l functions are the same 3 channels. Although the CTS may imply 6 channels per SG exist, this is not the case. FNP is designed with only 3 ESFAS level channels per SG. The CTS simply lists the same channels twice. In addition, if one of the required channels becomes inoperable, the CTS Action for either pump start function is the same. As such, the details regarding what pumps are started and how they are started by this function 4

Chapter 3.3 - E2-16-B May,1999

y I FNP TS Conversion Enclosure 3 - Significant Hazards Evaluations Chapter 3.3 - Instrumentation 1

III. SPECIFIC SIGNIFICANT HAZARDS EVALUATIONS CTS 3/4.3.2 ENGINEERED SAFETY FEATURE ACTUATION SYSTEM INSTRUMENTATION l FNP ITS 3.3.2 ENGINEERED SAFETY FEATURE ACTUATION SYSTEM INSTRUMENTATION (ESFAS) FNP ITS 3.3.5 LOSS OF POWER (LOP) DESEL GENERATOR (DG) START j INSTRUMENTATION FNP ITS 3.3.6 CONTAINMENT PURGE AND EXHAUST ISOLATION l INSTRUMENTATION f l 1 2.B:L l l (deleted) I l l l 9< l l i i i Chapter 3.3 E3-1-B May,1999

ESFAS Instrumentation 3.3.2 Table 3.3.2-1 (page 6 of 8) Engineered Safety Feature Actuation System Instrumentation MDDES OR

                                   @ APPLICABLE OTHER ll                                                  10 SPECIFIED      REQUIRED                  SURVEILLANCE    ALLOWA8LE          TRIP FUNCTION                CONDITIONS     CHANNELS    CONDITIONS REQUIREMENTS          VALUE       SETPolNT

5. Turbine Trip and Feedwater Isolation gg l7

a. Automatic 1, ) 2 trains SR 3.3.2.2 NA NA Actuation Logic SR 3.3.2 Actuation I33gj3 SR 3.3.2 gg

b. SG Water 1, ) SR 3.3.2 1 [D1 5 84.2 % 5 [82.4 Level-High High SG SR 3.3.2

[33gy) (P 14) SR 3.3.2 SR 3.3.2. i

c. SafetyInjection Refer to Fmetion 1 (Safety injection) for att initiation functions and requirements.

6. Auxiliary feedwater

a. Automatic 1,2,3 2 trains G SR 3.3.2.2 NA NA Actuation Logle SR 3.3.2 and Actuation SR 3.3.2 g I{

Retava R$olid ( " State Protection Ust_en)

b. toesti 1 ,3 tral SR .3.2.3 NA NA Actuet Log!

and A unti Ret s (Bal e of FL t ESFA b, SG Water 1,2,3 3[per D SR 3.3.2. t {[30.4$C t [32.2 Level-Low Low SG SR 3.3.2 4 l SR 3.3.2 7 Q, gg (SR 3.3.2 9' 6 g Gd

j (continued)

                                                     \                                                                    .

P Reviewer's Note: Unit specific laptementations may contain only Allowable Value depending on Setpoint Study h) -thodotoav used by the unit. j j) Except when all MFIVs, MfRVs, .[and associated bypass valvesJ are closed and [de-activated] tor Isolated by a closed manual ~ valve 3 D ,

                                              't s

i9 (h) Agid Mc % m%Fw yep M* y WOG STS 3.3-37 Rev 1, 04/07/95

l FNP TS Conversion Enclosure 5 - JD from STS l Chapter 3.3 - Instrumentation l STS 3.3.2 ENGINEERED SAFETY FEATURE ACTUATION SYSTEM (ESFAS) INSTRUMENTATION FNP ITS 3.3.2 ENGINEERED SAFETY FEATURE ACTUATION SYSTEM (ESFAS) INSTRUMENTATION JD NUMBER JUSTIFICATION the CTS. 18 The STS ESFAS function 6.a, automatic actuation logic and actuation relays for the auxiliary feedwater function is revised consistent with the FNP design and the CTS. The STS function contains descriptive information which identifies this function as part of the solid state protection system (SSPS). The reference to the SSPS is deleted. In the STS auxiliary feedwater function, two automatic actuation logic and actuation relay functions are provided for plants that are designed with both a balance of plant and SSPS automatic actuation logic system. The FNP auxiliary feedwater system design does not include a separate balance of plant actuation logic system. Therefore, the descriptive information to distinguish between actuation logic systems is not required for FNP and has been deleted. This change maintains consistency with the FNP design, CTS requirements, and intemally within the FNP 4 f$ 9 ITS ESFAS Table 3.3.2-1 list of functions which will avoid potential confusion. 19 STS Table 3.3.2-1 footnote (j) is deleted. This footnote is not consistent with the CTS and FNP design and operation and will not be incorporated into the FNP ITS. The function of P-14 (steam generator high-high level in any one steam generator) is to initiate Feedwater Isolation (FWI) and Turbine Generator trip and Steam Generator Feed Pump (SGFP) trip. By design, P-14 provides equipment protection. In addition, based on NRC Generic Letter 89-19 " Request for Action Related to Resolution of Unresolved Safety Issue A-47 ' Safety Implication of Control Systems in LWR Nuclear Power Plants' Pursuant To 10 CFR 50.54(f)," and consistent with j

the Farley FSAR Chapter 15.2 safety analyses, it is required to mitigate potential consequences of steam generator (SG) overfill events. As such, the system operability requirements should be consistent with the design basis functional system requirements and the overfill analysis. The proposed STS deviation satisfies i these objectives. Deletion of note (j) in STS Table 3.3.2-1 is also warranted because the exception l provides no viable benefit. The note is only applicable to FWI and Turbine & SOFP Trip by SG HI HI Level in Mode 2. The following examples illustrate why I note (j) does not provide any relief for almost any postulated fault.

1. A loss of any SG HI-HI Level logic circuit would mean that one ESFAS train I

has a failure, which requires the affected train to be " bypassed" for trouble shooting. SSPS automatic logic is required to be operable in Modes 1,2,3, and Chapter 3.3 E5-8-B May,1999

FNP TS Conversion Enclosure 5 - JD from STS Chapter 3.3 - Instrumentation STS 3.3.2 ENGINEERED SAFETY FEATURE ACTUATION SYSTEM (ESFAS) INSTRUMENTATION FNP ITS 3.3.2 ENGINEERED SAFETY FEATURE ACTUATION SYSTEM (ESFAS) INSTRUMENTATION i JD NUMBER JUSTIFICATION sometimes 4 and 5. Therefore, other LCO) would be more limiting.

2. A failure of any master relays or slave relays for FWI and Turbine & SGFP Trip by SG HI HI Level or any ofits logic circuits that are shared by the Safety Injection (SI) signal that seals-in FWI with P-4 would also impact the automatic initiation function associated with SI. Since the automatic SI circuits are

[y$ required to be operable in Modes 1,2 and 3, a more limiting LCO would over-ride any relief provided by the P-14 Mode 2 notation (j).

3. I.oss of two SG HI HI Level channels or bistables on any one SG will require two failures and very likely affect the ESFAS SG LO LO Level function to automatically start the AFW System which is required in Modes 1,2, and 3.

Based on these examples, it is highly unlikely that FNP could ever encounter a situation where STS note (j) would ever provide any relief to FNP. Therefore the note will not be included in the FNP ITS. 20 The Mode of applicability on ESFAS Table 3.3.2-1 for the trip of all main feedwater pumps function which auto-starts the auxiliary feedwater pumps is

           -evised consistent with the CTS requirements for this ESFAS function. The STS requires this function operable in Modes 1 and 2. In the CTS, the ESFAS trip of all main feedwater pumps is required operable in Mode 1 only. This function actuates when all the turbine-driven main feedwater pumps are shutdown (turbine stop valves closed). The FNP auxiliary feedwater pumps supply SG feedwater during startup (Mode 2). The main feedwater pumps are put into service supplying feedwater to the SGs just prior to Mode 1 entry. The STS applicability of Mode 2 for this trip is not appropriate for FNP as the auxiliary feedwater system is already in operation supplying the SGs in Mode 2 (no auto start required) and the main feedwater pumps are not put in service untiljust prior to Mode 1 entry. As such, the retention of the CTS applicability requirement of Mode 1 for this function is reasonable and maintains the current FNP licensing basis as specified in the CTS for this ESFAS function.

21 The STS surveillances assigned to the ESFAS trip of all main feedwater pumps function are revised consistent with the CTS requirements for this function. The Chapter 3.3 ES-9-B May,1999

ESFAS Instrumentation B 3.3.2

BASES APPLICABLE 1. Safety In.iection (continued) SAFETY ANALYSES, LCO, and 2. Boration to ensure recovery and maintenance of APPLICABILITY SDM (k,,, < 1.0) . pt. These functions are necessary to mitigate the effects of high energy line breaks (HELBs) both inside and outside of containment. The SI signal is also used to e Stad oM** initiate other Functions such as: mese.L Gt2%

Phase A Isolation, 1 I

e Containment Purge Isolation,

,s

Reactor Trip; lation; o p C P-loge the
Start of motor driven auxiliary eedwater (AFW) 2

  -[9y$                                  pumps; &
                                                                       .A-

gontrol room ventilation {solatioV, and p Enabling automatic switchover of Emergency Core O$F5R.*7,U'['*

Cooling Systems (ECCS) suction to containment NOTFMP E$FAs L sump. {~~Theseotherfunctionsensure:

$y

[to n a-

Isolation of nonessential systems throug containment penetrations; M gm W

                                                                                         %m med-I   operalen (I cmg             reviM     M                                                       6s &% peuw pouser6

Trip of the turbine and reactor t ower M

       ~ou,ut su%d d generation;                           sc,FPtrip    , ; ';P y 7

Isolation of main feedwater (MFW)fto limit k secondary side mass losses;

                                  *-     Start of AFW to ensure secondary side cooling capability;                                                     '

l-h of t Isolatio}lity; habitabi ontrol room to ensure and

                                                       -     A              N

[ - (continued) WOG STS B 3.3-67 Rev1,04/07/95 l

hb ESFAS Instrumentation B 3.3.2 BASES S Na.T.FHP E.SFA$ APPLICABLE 1. Safety Injection (continued) FSAR 7J. l.l.2 SAFETY ANALYSES, LCO, and . Enabling ECCS suction from the refueling wateh APPLICABILITY - storage tank (RWST) switchover on low low RWST level to ensure continued cooling via use of the

-{

_ containment sumo. 8,Ps a. Safety Iniection - Manual Initiation .>

                                                                  /C Fso 2,z/-/                                                                    T u-/% 23 g                           The LCO re u res n channey mer trais to be OPERABLE. The operator can initiate SI at any ip                time by using either of two switches in the         SA control room. This action         cause actuation m              of all componentsTin the        manner as any of the     tomatic actuation s    1s.g M,[

(# (The LCO for the Manual Initiation Function ensures the proper amount of redundancy is 96C-maintained in the manual ESFAS actuation ES circuitry to ensure the operator has man initiation capability. 1ege NR<M l / Each channel consists of dush buttoDand the

              ' *h D              .interconnectingwiringtabeactuationinaic 6'6 d b      .

cabinet. Each gush cutton3 ctuates both trains. NbAd M*- This configuration aoes not allow testing at

               & RTE               Power.

Shmt

               .y             b. Safety Injection - Automatic Actuation Loaic and g wg,              Actuation Relays This LCO requires two trains to be OPERABLE.

Actuation logic consists of all circuitry housed within the actuation subsystems, including the initiating relay contacts responsible for actuating the ESF equipment. Manual and automatic initiation of SI must be m OPERABLE in MODES 1, 2, and 3. In these MODES, highanfrom there is sufficient energy in the primary and strondary systems to warrant automatic initiation h w iers of ESF systems. Manual Initiation is also

                ,  geir re. quired in MODE 4 even though automatic W tuatiop is i not required. In this MODE, de@/                      adequate time is available to manually actuate required components in~the event of a DBA, but (continued)

WOG STS- B 3.3-68 Rev1,04/07/95

ESFAS Instrumentation ' B 3.3.2 4 BASES APPLICABLE (1) Steam Line Pressure - Low (continued) SAFETY ANALYSES, LCO, and reouirements with a two-out-of-thre Imaic. - APPLICABILITY Pff Con each steam lineK_ ./wreorn) With transmi ters(typicallyll_ocated b LTt5 EnsidO th stea tunnels,,it ~is possible l Tor them to experience adverse environmental conditionsJurina a secondary OXAP 34rfa hraa W herefore. Ehe Trip Setpoin IMSI e lu reflect _siotlDsteady stale and advers SETFcthT ' C M onma taw,n instrument ' uncertainties. 3rvey A)wmA St 4Pts 3 Ws cam #k 6sch 16.I.l. A3 This Function _ ticipatory in nature and ad/ lag ratio of 50/ A&g has a([ypica; ys%M % Steam Line ure - Low mus BLE

   / cowb Mmd                  RPS pg                   in MODES 1, 2, and 3 (above P          when a
      ,  IN~Y I               2,72.5 secondary side break or stuck open valve i

W# 4

         'Diffimb         $l P 12.

12 could result in the rapid depressurization of the steam lines.' This signal may be M5tE i l pm kn L anua]yblockedbytheroperatorbelowthe Q l P- netpoint. JBe' ow P-lh teea itne brea10 3 Asnotaconcern.fInsidecontain-- will be terminated by automatic ato O.) actuation via Con}adnment Hi h ou.)in

                                        "          rressGre      Higtrgy and outsid co ainmen        M 2

SLB will e termi_nated by the tea Tressure - Negative Rato - HialD s'igna o in kyne3 p'C-3,3.'l'S - steam line isosation. "his function 1's no wi tow.. required to be OPERABLE in MODE 4, 5, or 6 Low. because there is insufficient energy in the secondary side of the unit to cause an accident. (2) Steam Line Pressure - Hiah Differential Pressure Between Steam lines Steam Line Pressure - High Differential Pressure Between Steam Lines provides protection against the following accidents:

SLB; t-
Feed line break; and (continued)

          'WOG STS                                   B 3.3-72                        Rev 1, 04/07/95

hh ESFAS Instrumentation B 3.3.2 l BASES ; APPLICABLE (2) Steam line Pressure - Hiah Differential SAFETY ANALYSES, Pressure Between Steam Lines LCO, and (continued) APPLICABILITY

Inadvertent opening of an SG relief or an SG safety valve.

[6l % $teamLinePressure-HighDifferentia5 g gp % ['

                                    .PressureBetweenSteamLinesprovidesn)oi sinut    to any control functions. Thus,
      .$                            #1'ree OPERABLt channels on eacn steam line mph,v*.            in         are sufficient to satisfy the requirements, Ce M       cj               with a two-out-of-thre# logic on each steam 4W                      line.      g        gskekm]p Wit      he   ansmi tte # fypically)1ocated M g$p.y                    -

nsideathe teanibunne si, Jit is possible 1 rfor them to exper ence aaverse environmental conditions during an SLB ; Levent._ Them fpre,[the Trip setpoint _ o , eady state gna aaygg) - reflectsJbo; environmental strument uncertain;1es. -!

                     < pgl     '

Steam line nigh differential pressure must j be OPERABLE in MODES 1, 2, and 3 when a secondary side break or stuck open valve could result in the rapid depressurization of the steam line(s). This Function is not required to be OPERABLE in MODE 4, 5, or 6 because there is not sufficient energy in the secondary side of the unit to cause an accident.

                                   ! In.iection h-lh               f, g. Safetv                   dich Steam Flod in Two Stea Line's Coincident W4th T.,_ - Low 1/ow or Coincid(ent gg                        With Steam Line P/ essure'- Low FnP                           ese Functions (1.f and 1 9) rovide prote tion gainst the fo owing acciden s:

SLB; a
the i advertent open ng of an SG r lief or an S safety valve.

Two stea line flow cha els per stea line a e require OPERABLE for t ese Functions The team line f1 channels are combined in a one-ou -of-(co'ntinued) WOG STS B 3.3-73 Rev 1, 04/07/95

Fop pgipe uA ge,,g[n 46 M '"8 inf >A 6 Isd&n d dC sinds M t, 0c 4d' Rg NN l

            '**U"> Pod-Mp cwt. g mer exe w sm uA e&& 6,,w0 BASES     pmsva, %A gy,Ac 4 g g gg                                -

3k m W ww - y referen d for all in iating fun ions and g//g requi ments. FNP T s Function m t be OPERA in MODES , 2, i nd 3 when a condary si break or s ek open l

           -Q                        valve could esult in ra d depressur zation o                   '

the steam ines unless 11 MSIVs ar closed d [de-act ated). Thi unction is ot requi d to be OP BLE in MOD 4, 5, and ecause ere is ins ficient ener in the se dary si of the u t to have an ccident. ! APPLICABLE 5. Turb'ine Trio and Feedwater Isolation SAFETY ANALYSES, LCO, and gprimary functions of the Turbine Trip and APPLICABILITY j Feedwater Isolation signals are to prevent damage to (continued the turbine due to water in the steam lines, and to stop the excessive flow of feedwater into the SGs. F.At %k These Functions are necessary to mitigate the effects YnshcMrn txed of a high water level in the SGs, which could result ; I $% in carryover of water into the steam lines and ' (i m.e.,4 excessive cooldown of the primary system. The SG high 4 g water level is due to excessive feedwater flows. 2 The Function is actuated when the level in any SG exceeds the high high setpoint, and performs the following functions: 1 lr3

Trips the main turbine; t
Trips the MFW pumps;4
Initiates feedwater isolation;) and
Shuts the MFW regulating valves and the bypass feedwater regulating valves.

Oi'6c-

              .-             This Functien i$ actuated by SG Water Level - High cwtcrrekicadDy            High, cr by an SI signal. The RTS also initiates a I        turbine trip signal whenever a. reactor trip (P-4) i s- ; ,

47, @ 4' 4 cenerated. In the event of SI. the unit is qaken of ine and the turbine cenerator must be tr1Dped2 The em is also taken out of,5 operation and the AFW , MFW System Sys}is automatically started. The SI signal was TD d scussed reviousi . 3Mkdede P-Y 5eabJn ihe Fwn seg .h ensure <nedo tA N (cf in*49v S6*3 % AM% saJ4A

                     -thtSGFP% a sc,cWe.6  -&hs,nge resdwhss4M    4%g M AMc coM         '

(continued) eba mar # h A.he w ,s lnw w <_uelensah W 2r- ev 1, 04/07/95

E~ ] l g 430 ESFAS Instrumentation B .3.2 l l3.V [Porb d h, AA<mdh. A<MM Lope og aa % Ach u pe% mc.~m<n%b.m BASES (SC, W& Leve - W 5 k Nik (P-@ 4 5.&b y hjeSni, er Isolati - Automatic 1 Actuation Loaic and Actuation Relan Automatic Actuation Logic and Actuation Relays consist of the same features and operate in the E same manner as described for ESFAS Function 1.b --

b. Turbine Trio and Feedwater Isolation - Steam Generator Water Level - Hiah Hiah (P-14)

N l This signal provides protection against excessive feedwater flow. The ESFAS SG water level APPLICABLE b. Turbine Trio and Feedwater Isolation - Steam l SAFETY ANALYSES, Generator Water level - Hioh Hiah (P-14) l LCO, and (continued) l APPLICABILITY instruments provi.de input to the SG Water Level g Control System. Therefore, the actuation logic must be able to withstand both an input failure RP6FSD 2./2.5 to the control system (which may then require the protection function actuation) and a single failure in the other channels providino the N Since onL nree protection function actuation. IThus, four DPERABLE channels are required to satisfy the ] ' O.hcLhnEls requirements with a two-out-of-four logic. For

        /AS/6//ecb o.,rn d.M j               units that have dedicated protection and control Sig ho16etector 15                 channels, only three protection channels are                  l In3 h M RUSE                     I necessarytosatisfytheprotectiverequirement For other units that have only three channels, a L0ib YE O WM I                                           median signal selector is provided or

Le.veLContro( 6 6M.k ) justification is provided in NUREG-1218 (Ref. 7).j b E D hYICI The transmitters (d/p cells) are located inside I

protection gstem ( containment. However, the events that this Function protects against cannot cause a severe ! thie.rorMors dder'to l environment in containment. Therefore, the Trip oF IEEE 2.79 is Setpoint reflects only steady state instrument gfMd.g f$e. uncertainties. l

c. Turbine Trio and Feedwater Isolation - Safety Md/d-O Mar Mc$g[od , In.iection MinisfrbdWe Ci>hYICIS Turbine Trip alid Feedwater Isolation is also I ( b Ensure c.ha.nnej W initiated by all Functions that initiate SI. The l l 15 selecfecL., Feedwater Isolation Function requirements for (continued)

WOG STS B 3.3-92 Rev 1, 04/07/95 l

r i.

                                                    !             ESFAS Instrumentation 1

B 3.3.2 BASES these Functions are the same as the requirements for their SI function. Therefore, the requirements are not repeated in Table 3.3.2-1. Instead Function 1, SI, is referenced for all initiating functions and requirements. Turbine Trip and Feedwater Isclation Functions must be OPERABL! in MMS I and 21[anC3] except. wnen ai Y ,3 M:IVs, llFRVs, :and associated bypass valves) are closed and [de-activated) (or isolated by a closed 33 manual valve) when the MFW System is in operation an tra turbiria annaratar may be in anarationJ En - M: DES 4 W'3, %, 5, and 6, the MFW System and the turbine APPLICABLE c. Turbine Trio and Feedwater Isolation - Safety SAFETY ANALYSES, In.iection (continued) LC0, and APPLICA8ILITY generator are not in service and this Function is not required to be OPERABLE.

6. Auxiliary Feedwater The AFW System is designed to provide a secondary side ,

heat sink for the reactor in tte event that the MFW l System is not available. The system has two motor driven pumps and a turbine driven pump, making it available during normal unit operation, during a loss . of AC power, a loss of MFW, and during a Feedwater i System pipe break. The normal source of water for the Q J g AFW System is the condensate storace tank l' CST). at r( ru)s11 are A low levei in thW CS NA 'f au a all lig pump /suctio s to t)le gp , enti S vi a er ( _ we+ a tsaf v reldted a 7ht AFM System is n'igned so that upon a pump start, j flow is initiated to the respectiveJSGs immediately. >

a. Auxiliary Feedwater - Anta==He Ac<:ua' ion Loaic and Ac".uation Re' avs f(Solid State Pro' ectionx TE Automatic actuation logic and actuation relays h

consist of the same features and operate in the-same manner as described for ESFAS Function 1. i

                                                                             ) f"bf L (continued)

W0G STS B 3.3-93 Rev 1, 04/07/95 I

I I l I l i 1 Associated Package Changes for RAI-3.3.2-4 l i

CHAPTER 3.3 INSERT N TO STS ESFAS BASES PAGE B 3.3-96 FNP SPECIFIC TRIP OF ALL MAIN FEEDWATER PUMPS k g Each MFW pump has two steam stop valves (HP and LP) for the turbine driver. Each MFW 4 pump turbine stop valve is equipped with a limit switch that actuates when the valve is closed. When both MFW pumps are shutdown (all four turbine stop valve limit switches are actuated), a start of the motor-driven AFW pumps is initiated. The four-out-of-four logic of this function is not single failure proof but is acceptable due to ihe backup nature of this AFW pump start function. This ESF function is not credited for diversity, and its electrical circuits are not

 -      required to be safety-grade. This function is not relied on in any safety analyses as the primary actuation signal to initiate the AFW pumps but is part of the licensing basis of the ESFAS.

Therefore, two channels per pump are required OPERABLE to ensure this function is available if needed. The automatic start of the AFW pumps ensures that the available SGs are supplied with water to act as the heat sink for the reactor. INSERT O TO STS ESFAS BASES PAGE B 3.3-96 FNP SPECIFIC TRIP OF ALL MAIN FEEDWATER PUMPS APPLICABLE MODES Function 6.e must be OPERABLE in Mode 1 to provide the automatic start of the motor-driven AFW pumps if needed. The .nutomatic start of the AFW pumps ensures that the available SGs are supplied with water to act as the heat sink for the reactor in the event of an accident. In Modes 2, - 3,4, and 5, the MFW pumps may be normally shutdown and thus the pump trip is not indicative of a condition requiring automatic AFW initiation, i Chapter 3.3 Insert Page

Associated Package Changes for RAI-3.3.2-5 l

FNP TS Conversion Enclosure 2 - Discussion of Changes to CTS Chapter 3.3 - Instrumentation CTS 3/4.3.2 ENGINEERED SAFETY FEATURE ACTUATION SYSTEM INSTRUMENTATION FNP ITS 3.3.2 ENGINEERED SAFETY FEATURE ACTUATION SYSTEM INSTRUMENTATION (ESFAS) FNP ITS 3.3.5 LOSS OF POWER (LOP) DIESEL GENERATOR (DG) START

                                        -INSTRUMENTATION FNP ITS 3.3.6 CONTAINMENT PURGE AND EXHAUST ISOLATION INSTRUMENTATION DOC HQ       SHE                                   DISCUSSION CTS Table 3.3-3 to be applied. These CTS Actions are replaced by the STS 3.3.2 Condition A Required Action and associated Completion Time for           ;

one or more inoperable instrument channel (s). In the context of the STS format and rules for LCOs and Actions and considering that the STS bases contain the operability requirements (which includes setpoint within the allowable value), the STS LCO 3.3.2 Condition A eNectively replaces the CTS 3.3.2 Action statements without changing the technical intent of the actions. The re-organization of the CTS 3.3.2 Action requirements into the STS 3.3.2 Actions is made to conform with the passentation and format of this information in the STS. As the STS 3.3.2 Actions Condition provides efectively the same requirements, this change is considered administrative. 4a A The CTS 3/4.3.2 generic requirement to perform all applicable surveillance requirements (CTS 4.3.2.1) is deleted consistent with the STS. The corresponding required surveillances in the STS LCO 3.3.2 are individually identified for each ESFAS function on the integrated STS Table 3.3.2-1 and each surveillance requirement is further described in the surveillance section of the STS LCO. Although the actual presentation of these requirements diners greatly from the CTS, the information contained within the CTS surveillance requirements (type of testing required and frequency) is eKoctively retained within the individually specified corresponding STS surveillance requirements. Any technical diferences in surveillance requirements resulting from the conversion to the ITS will be discussed in other DOCS applicable to the individual instrument function (s) and surveillances afected. As this change to the generic CTS surveillance g requirement is made solely to conform with the STS format and bp . v.Jon of this information and is not intended to introduce a technical change to the CTS, it is considered an administrative change. A CTS surveillance 4.3.2.2 is revised as appropriate to conform to the STS. l4b

    - Chapter 3.3                                 E2-2-B                                    May,1999

,i

I FNP TS Conversion l Enclosure 2 - Discussion of Changes to CTS u Chapter 3.3 -Instrumentation L CTS 3/4.3.2 ENGINEERED SAFETY FEATURE ACTUATION SYSTEM INSTRUMENTATION FNP ITS 3.3.2 ENGINEERED SAFETY FEATURE ACTUATION SYSTEM ' E ( INSTRUMENTATION (ESFAS)-. ; 1 L - FNP ITS 3.3.5 LOSS OF POWER (LOP) DIESEL GENERATOR (DG) START I INSTRUMENTATION L FNP ITS 3.3.6 CONTAINMENT PURGE AND EXHAUST ISOLATION l- INSTRUMENTATION DOC NQ SHE DISCUSSION This CTS surveillance addresses testing ofinterlock functions, including the this CTS surveillance was added to STS Table 3.3.2-1. A new line item for - l-I g 'g,3},.S actuation logic and relays and the Automatic Actuation Logic and Actuation Relays was added to the ESFAS Interlocks Function to capture the Automatic Actuation Logic Test

                           . specified in the CTS. The STS and FNP ITS SR 3.3.2.2 will test the                 l Automatic Actuation Logic consistent with the requirements of the CTS.             l The remainder of CTS 4.3.2.2 surveillance requirement tests the total             j interlock function and this will be covered by the STS and FNP ITS with         'I the COT (SR 3.3.2.4), Master (SR 3.3.2.3) and Slave (SR 3.3.2.8) Relay L                             Tests, TADOT (SR 3.3.2.6) and Channel Calibration (SR 3.3.2.7). This l                             change is made to conform with the presentation and fonnat of the surveillance requirements in the STS and does not introduce a technical change to the CTS testing requirements. Therefore, this change is considered administrative.

4c LA CTS surveillance requirement 4.3.2.3 is revised consistent with the STS. l This CTS surveillance contains the ESF Response Time Testing requirements for the ESFAS functions. CTS 4.3.2.3 requires that each ESFAS function be tested on a Staggered Test Basis. The requirement to apply the Staggered Test Basis and the associated 18 month frequency is i explained in detail within the CTS surveillance. The corresponding STS surveillance simply specifies Response Time Testing be performed every 18 months on a Staggered Test Basis. The detailed explanation within the CTS surveillance is effectively included in the bases of the corresponding STS surveillance. This CTS surveillance corresponds to the FNP ITS surveillance SR 3.3.2.9. The STS bases explains the required testing in terms of the channels and end actuating devices (train related equipment) required to be tested. This STS bases explanation encompasses the j description of the required testing contained in CTS 4.3.2.3. The STS and i Chapter 3.3 : E2-3-B May,1999 p 1

FNP TS Conversion Enclosure 2 - Discussion of Changes to CTS Chapter 3.3 - Instrumentation CTS 3/4.3.2 ENGINEERED SAFETY FEATURE ACTUATION SYSTEM INSTRUMENTATION FNP ITS 3.3.2 ENGINEERED SAFETY FEATURE ACTUATION SYSTEM INSTRUMENTATION (ESFAS) FNP ITS 3.3.5 LOSS OF POWER (LOP) DIESEL GENERATOR (DG) STAR.T INSTRUMENTATION FNP ITS 3.3.6 CONTAINMENT PURGE AND EXHAUST ISOLATION INSTRUMENTATION DOC i

N.Q SHE DISCUSSION associated with the ESFAS functions addressed by this Action and the surveillances are applicable and must be perfonned whether specifically referenced or not. Therefore, the general reference to surveillance testin2,in the STS effectively accomplishes the same purpose (allow the applicable l surveillances to be performed) as the specific CTS reference. The changes discussed above are all made to conform with the presentation and format of this information in the STS and do not introduce a technical change to the CTS. Therefore, these changes are considered administrative. 49 A CTS Action statement 19b is revised consistent with the STS. CTS Action statement 19b provides an allowance to bypass an inoperable channel for up to 4 hours for surveillance testing other channels. In the STS, this same ! allowance is expressed in the standani STS note format. The revision of this CTS Action into a note format does not introduce a technical change to the CTS requirement The CTS Action is revised only to conform with the format and pasentation of this requirement in the STS. Therefore, this change is considered administrative. , 1 50 M The CTS Action Statement 20 for the ESFAS P-ll and P-12 interlock ) functions on CTS Table 3.3-3 is replaced with the STS Condition L l applicable to the same interlock functions. The STS Condition is modified l l to account for the specific requirements in the CTS Action. An interlock ;

                         ' function may be affected by more than one ESFAS function as specified in the CTS Action statement 20. The CTS Action statement effectively                l addmsses any number ofinoperable channels that may cause an interlock t'g      function to be inoperable. The CTS Action statement 20 for an inoperable interlock function refers to the applicable Actions for each instrument function associated with the affected interlock. The CTS require no action       j for loss of one channel. A loss of two channels or one train requires verification of the interlock states and its associated safeguards function. A   l J

l

 . Chapter 3.3                                      E2-36-B                                     May,1999 l

(

L FNP TS Conversion. l Enclosure 2 - Discussion of Changes to CTS ! Chapter 3.3 - Instrumentation CTS 3/4.3.2 ENGINEERED SAFETY FEATURE ACTUATION SYSTEM INSTRUMENTATION FNP ITS 3.3.2 ENGINEERED SAFETY FEATURE ACTUATION SYSTEM INSTRUMENTATION (ESFAS) l l FNP ITS 3.3.5 LOSS OF POWER (LOP) DIESEL GENERATOR (DG) START l INSTRUMENTATION FNP ITS 3.3.6 CONTAINMENT PURGE AND EXHAUST ISOLATION INSTRUMENTATION 1 DOC HQ SHE DISCUSSION loss of two channels defaults to CTS Action #19 and LCO 3.0.3, which is l equivalent to STS Required Action L.2. To ensure consistency with CTS, ITS Condition K is modified to specify"two channels inoperable" with action times equivalent to STS Condition L and CTS LCO 3.0.3. The failure of P-11 or P-12 logic in one train defaults to CTS Action #13. To maintain consistency with CTS, ITS Condition L is added to specify "one train inoperable" with action timo derived fmm STS Condition L and CTS I Action #13. An inoperable interlock function could result in a loss (block) . of a required ESFAS function which is equivalent to two or more l inoperable instrument channels in the same function. Therefore, the STS l provides a uniform I hour time in which to manually verify the status of the j affected interlock channels before requiring that action be taken to place the l g.t[ plant in a Mode in which that interlock function (blocked ESFAS function) is no longer required. As such, the STS Actions are generally more conservative than the corresponding CTS Actions but arejustified and applicable to FNP in the case where a required ESFAS function, relied on in l the safety analyses to mitigate design basis accidents, is unavailable due to I an inoperable interlock function. The Farley CTS have no explicit time limitations to verify the state of P-11 and P-12 interlocks. Therefore, this change is considered to be a more restrictive change. 51 A CTS Action statement 21 is revised consistent with the corresponding STS ; Condition G format and presentation. The CTS reference to the minimum number of channels is replaced with the STS " required channels". The STS I does not use minimum or total channels and simply refers to the required channels which is the number of channels upon which the CTS and STS Actions are based. This change is also one of terminology and presentation, the number of channels upon which the Action is based remains unchanged. The use of required channels in the STS effectively replaces the CTS use of minimum channels without introducing a technical change to CTS Action i ch-ee 3.3 E2-37-B May,1999

o I FNP TS Conversion j Enclosurc 2 - Discussion of Changes to CTS Chapter 3.3 -Instrumentation l CTS 3/4.3.2 ENGINEERED SAFETY FEATURE ACTUATION SYSTEM INSTRUMENTATION I FNP ITS 3.3.2 ENGINEERED SAFETY FEATURE ACTUATION SYSTEM ! INSTRUMENTATION (ESFAS) FNP ITS 3.3.5 LOSS OF POWER (LOP) DIESEL GENERATOR (DG) START INSTRUMENTATION l l FNP ITS 3.3.6 CONTAINMENT PURGE AND EXHAUST ISOLATION INSTRUMENTATION DOC NQ SHE DISCUSSION the appmpriate surveillance (FNP ITS SR 3.3.5.3) in the standard STS note l format. The CTS requirement for the performance of this testing during l response time testing is effectively retained in the FNP ITS without change. Therefore, this change is considered administrative and is made to more closely conform with the STS format and presentation of similar information. 98 A CTS Surveillance Requirement 4.3.2.2 for the ESFAS Permissives / Interlocks P-4, P-11 and P-12 is retained in the ITS by adding a new line l item to Table 3.3.2-1 under Function No. 8,"ESFAS Interlocks." The addition of a new function item is necessary to retain the explicit CTS testing requirements in Farley ITS. The function number is "8.a" with a f6 description of" Automatic Actuation Logic and Actuation Relays." . CTS SR y 4.3.2.2 specifies that the total interlock function must be tested every 18 i months and that the interlock logic must be tested "during the automatic logic test." Therefore, the new function will facilitate the STS to ITS l conversion by including ITS surveillances for the automatic actuation logic i- (SR 3.3.2.2), master relays (SR 3.3.2.3), and slave relays (SR 3.3.2.8). i l Consistent with the CTS, the Farley ITS provide explicit testing requirements for the P-4, P-11 and P-12 logic circuits and the P-11 and P-12 l ESF actuation relays. This is also consistent with the format for surveillance and conditions for all other ESFAS functions in STS Table 3.3.2-1 that utilize the SSPS ESF logic and safeguards actuation circuits and relays. As such, this change is made to conform to the presentation and I format of the surveillance requirement in the STS and does not introduce a l technical change to the CTS testing requirements. Therefore, this change is ; considered administrative. 99 M Consistent with the STS, SR 3.3.2.5 is added to the Farley ITS as new l surveillance SR 3.3.2.4. This surveillance provides for periodic testing of l Chapter 3.3: E2-68-B May,1999 [

FNP TS Conversion Enclosure 2 - Discussion of Changes to CTS Chapter 3.3 - Instrumentation CTS 3/4.3.2 ENGINEERED SAFETY FEATURE ACTUATION SYSTEM INSTRUMENTATION FNP ITS 3.3.2 ENGINEERED SAFETY FEATURE ACTUATION SYSTEM INSTRUMENTATION (ESFAS) FNP ITS 3.3.5 LOSS OF POWER (LOP) DIESEL GENERATOR (DG) START INSTRUMENTATION FNP ITS 3.3.6 CONTAINMENT PURGE AND EXHAUST ISOLATION INSTRUMENTATION DOC NQ SHE DISCUSSION the instrument channels for P-11 and P-12 between calibrations. The COT demonstrates the operability of the channel certs in the instrument racks, including verification of the bistable setpoint and reset values. This new requirement is consistent with the current plant operating practice to ) verify the P-11 and P-12 bistable setpoints in conjunction with functional testing of the associated pressurizer pressure and RCS temperature protection channels. This requirement is also consistent with the rack drift allowances in the supporting setpoint uncertainty calculations. This change is considered to be more restrictive than the CTS, because the CTS have no requirements for periodic functional testing of the P 11 and P-12 ESF interlocks. y i I i I Chapter 3.3 E2-69-B May,1999

h ESFAS Instrumentation 3.3.2 ACTIONS CONDITION REQUIRED ACTION COMPLETION TIME K. (continue K.2.1 Be lnMODE3. 12 . urs

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ESFAS Instrumentation 3.3.2 Tablo 3.1.2 1 (page 8 of 8) Engineered safety Feature Actuation System Instrumentation h FUNCTION

                              @~2 @ sPECIFIED COWITIONS CHANNELS REQUIRED SURVEILLANCE CONDITIONS REGUIREMENTs ALLOWABLE VALUE Ak        TRIP SETPOINT

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                                                    - toop L       faa LLtti SR 3.3.2 t     50.6 'F     1 [553 F   h gceym                                        SR 3.3.2                                        )

urew 7 sys'.yY f {i_E_ l m --=. p (a) Reviewer's Note: Unit specific laptementations may contain only Attowable Value depending on setpoint St methodology used by the mit. j 1 A. AvM<. AMJa i, z, 3 z + ,;ns L 5A 3 3 t 1. t4A NA top 4 Min SA "5 3.2 3 b Sit. 3 3.t.1 WOG STS 3.3-39 Rev 1, 04/07/95

L FNP TS Conversion Enclosure 5 - JD from STS Chapter 3.3 - Instrumentation l STS 3.3.2 ENGINEERED SAFETY FEATURE ACTUATION SYSTEM (ESFAS) INSTRUMENTATION FNP ITS 3.3.2 ENGINEERED SAFETY FEATURE ACTUATION SYSTEM (ESFAS) INSTRUMENTATION JD NUMBER JUSTIFICATION 1 The STS Condition J is revised to be consistent with the corresponding CTS requirements in ESFAS Action statement #23 (as modified by associated changes made to conform with the STS format and presentation) on CTS Table 3.3-3. This STS-Action applies to the auxiliary feedwater (AFW) pump start on trip of all main i feedwater pumps. This FNP ESFAS function is an anticipatory backup start of the AFW motor-driven pumps and is not relied on or assumed operable in any design basis accident analysis. The CTS effectively requires that this function be operable prior to reactor start up, but does not require the plant to shut down (as does the STS) if the function is lost during operation. Considering the anticipatory backup nature of this function, the CTS requirements are acceptable and have been incorporated into the FNP ITS. Therefore, this change to the STS maintains the current FNP licensing basis as specified in the CTS. 2 The STS Condition K is deleted consistent with the CTS ESFAS requirements. The STS Condition K is applicable to instrument channels associated with the automatic switch over to containment sump ESFAS function in the STS. This STS ESFAS 4 function is not part of the CTS. As such, the deletion of this STS Action maintains 4y - consistency with the FNP current licensing basis as specified in the CTS. 3 STS Condition L (FNP ITS Conditions K and L) is revised consistent with the corresponding CTS Action #20, and, as applicable, Actions #19 and #13. This STS Condition addresses an inoperable ESFAS interlock function (P-11 or P-12). The P-11 and P-12 interlock functions are comprised of three instrument channels and two actuation logic trams, each with a two-out-of-three logic circuit and associated master and slave relays. The P-4 interlock function is comprised of two trains of cell switches and auxiliary contacts, which sense reactor trip and bypass breaker i position, and the corresponding logic circuits in each SSPS train. In addition, the P-4 circuits in the Reactor Trip switchgear provide direct actuation signals (e.g., turbine trip). The corresponding CTS Actions address multiple inoperable l instmment channels and an inoperable logic circuit in one SSPS train. The CTS Actions were more clearly designed to address an inoperable interlock function, which may have resulted from more than one inoperable instrument channel or an inoperable train oflogic. CTS Action #20 requires no action for one inoperable channel.' Therefore, ITS Condition K will apply when two channels are inoperable, and ITS Condition L will apply when one train is inoperable. This STS deviation maintains consistency with CTS Actions #20, #19 and #13 for an inoperable P-4, P-Chapter 3.3 - E5-1-B May,1999

FNP TS Conversion Enclosure 5 - JD from STS Chapter 3.3 - Instrumentation STS 3.3.2 ENGINEERED SAFETY FEATURE ACTUATION SYSTEM (ESFAS) INSTRUMENTATION FNP ITS 3.3.2 ENGINEERED SAFETY FEATURE ACTUATION SYSTEM (ESFAS) INSTRUMENTATION h JD MBER JUSTIFICATION 11 or P-12 interlock function. This change results in FNP ITS Conditions which more closely couspand to the CTS Actions and allowances in the STS format. As such, this change effectively maintains the FNP current licensing basis as specified in the CTS. 4 - STS surveillance 3.3.2.3 does not apply to FNP and is deleted. STS surveillance 3.3.2.3 tequires performance of an Actuation Logic Test and contains a note stating that the continuity check may be excluded. This STS surveillance is associated solely with the auxiliary feedwater system balance of plant actuation logic and actuation relays function. This STS function and associated surveillance SR 3.3.2.3 are intended to address an auxiliary feedwater system design that includes additional actuation logic located outside of the SSPS. Balance of plant auxiliary feedwater actuation logic is a plant specific design that is included in some Westinghouse plants. The continuity check that may be performed as part of the ; SSPS Actuation Logic Testing, can not be accomplished for the balance of plant actuation logic systems. The balance ofplant actuation logic systems do not have the same test circuits as the SSPS for checking continuity and so a note containing an exception to the definition of Actuation Logic Test for the continuity check is i I required in the SR. The auxiliary feedwater system design that this STS surveillance is intended to address is not part of the FNP design. Therefore, this surveillance is deleted. 5 The STS 92 day slave relay surveillance SR 3.3.2.6 is replaced with the FNP ITS 18 month slave relay surveillance SR 3.3.2.8. The FNP CTS do not contain this surveillance requirement. However, the FNP FSAR section 7.3 contains l requirements for slave relay testing to be performed every 18 months. The STS slave relay testing is specified to be performed every 92 days (bracketed frequency) which is replaced by the current FSAR licensing basis test frequency of every 18 months. Therefore, this change to the STS is made in order to conform with the current FNP licensing basis as discussed in the FSAR. 6 The STS response time test surveillance SR 3.3.2.10 (FNP ITS SR 3.3.2.9) contains a note which provides an allowance for testing the turbine driven AFW pump. The

            . STS note allows 24 hours after SG pressure is 21000 psig. The intent of the note is to allow the SG pressure to increase sufficiently to ensure the AFW pump is tested at an adequate steam header pressure. Although the FNP CTS do not contain similar provisions, FNP inservice and response time test procedures for the turbine-Chapter 3.3                                   ES-2-B                                       May,1999

FNP TS Conversion l Enclosure 5 - JD from STS Chapter 3.3 - Instrumentation STS 3.3.2 ENGINEERED SAFETY FEATURE ACTUATION SYSTEM (ESFAS) INSTRUMENTATION FNP ITS 3.3.2 ENGINEERED SAFETY FEATURE ACTUATION SYSTEM (ESFAS) INSTRUMENTATION JD NUMBER JUSTIFICATION such, the Note associated with STS SR 3.3.2.7 is deleted in ITS SR 3.3.2.5. 6b STS Surveillance Requirement SR 3.3.2.10 (FNP ITS SR 3.3.2.9) is the performance ofperiodic response time testing (R'IT). The surveillance applies to the RCP Bus UV instrument channels, ESF actuation logic, relays, and the TDAFW pump, because the RCP UV signal is credited in the FNP Small Break LOCA analysis as a primary ESFAS signal (FNP FSAR Chapter 15.3). The surveillance does not apply to the automatic startup of the TDAFW pump by steam generator low-low water level in two-out-of-three steam generators, because this function provides backup protection in the safety analyses. Therefore, the RTT surveillance requirements for Function No. 6.b and Function No. 6.d on ITS Table 3.3.2-1 are revised to clearly indicate the appropriate R'IT surveillance for the TDAFW pump ESF actuation signals. Specifically, SR 3.3.2.9 for Function No. 6.b is footnoted to indicate that the test applies only to the MDAFW pump start on steam generator low-low level. SR 3.3.2.9 is added to Function No. 6.d. These RTT requirements are consistent with Farley FSAR Table 7.3-16 response time acceptance criteria and the Chapter 15 safety analyses modeling assumptions. Therefore, these STS deviations are acceptable. 7 The STS surveillance SR 3.3.2.11 is replaced with FNP ITS SR 3.3.2.10. The STS surveillance SR 3.3.2.1I was applicable to the P-4 interlock. The FNP ITS SR 3.3.2.10 is applicable to the trip of all main feedwater pumps auto start of the AFW

system motor driven pumps function. The proposed FNP ITS 3.3.2.10 corresponds to the surveillance requirements for this function as specified in CTS Table 4.3-2 (S/U) and includes the applicable CTS note #5 (if not performed within the > previous 92 days). Therefore, FNP ITS SR 3.3.2.10 effectively retains the current licensing basis requirements for testing the trip of all main feedwater pumps function in a format and presentation compatible with the STS. The required P-4 interlock testing previously addressed by STS SR (3.3.2.11) is replaced with FNP ITS SR 3.3.2.6. FNP ITS SR 3.3.2.6 requires a TADOT be performed every 18 months for manual initiation functions and is consistent with the CTS P-4 testing frequency specified on Table 4.3-2 for the ESFAS interlocks (R). By assigning FNP ITS SR 3.3.2.6 to the P-4 interlock instead of STS SR [ [ 3.3.2.11, the STS frequency of testing the P-4 interlock "Once per reactor trip breaker cycle" is revised to be consistent with the FNP CTS 18 month test lp frequency. 'Ibe P-4 testing requirements associated with ITS SR 3.3.2.6 are also ,. Chapter 3.3 ES-4-B May,1999

FNP TS Conversion Enclosure 5 - JD.from STS Chapter 3.3 - Instrumentation STS 3.3.2 ENGINEERED SAFETY FEATURE ACTUATION SYSTEM (ESFAS) INSTRUMENTATION FNP ITS 3.3.2 ENGINEERED SAFETY FEATURE ACTUATION SYSTEM (ESFAS) INSTRUMENTATION JD NUMBER JUSTIFICATION consistent with CTS surveillance 4.3.2.2, which requires that the total interlock function be demonstrated operable every 18 months. Therefore, consistent with current plant practices and licensing basis, the P-4 inputs to the SSPS logic circuits and P-4 actuation signals (e.g., turbine trip) will be tested under this ITS TADOT. Additionally, the "setpoint verification not required" note which modifies STS SR [A 3.3.2.8 (FNP ITS SR 3.3.2.6) is revised to include the P-4 interlock consistent with 9 the P-4 STS surveillance SR 3.3.2.11 (the reference to manual initiation functions is deleted from the note). STS SR 3.3.2.11 includes the "setpoint verification not required" note for the P-4 interlock and is applicable to FNP. Therefore, the applicable STS surveillance that matches the specific FNP P-4 interlock test requirements most closely is STS SR 3.3.2.8 (FNP ITS SR 3.3.2.6) with the revised setpoint verification exception note. The application of the proposed FNP ITS SR 3.3.2.6 for the P-4 interlock testing effectively retains the current licensing basis requirements for testing this function (as specified in CTS Table 4.3-2) in a format and presentation compatible with the STS. 8 The STS Table 3.3.2-1 is revised by the deletion of Reviewers Note (a). This STS note is intended to provide information to assist in developing a plant specific implementation of the STS. The note serves no other purpose and could result in confusion ifleft in place after a plant specific implementation has been developed. Therefore, this note is deleted and all subsequent notes are re-lettered accordingly. This change results in numerous changes to superscript notations throughout the Applicable Modes column of STS Table 3.3.2 1. 9 The STS surveillance requirements listed on Table 3.3.2-1 are renumbered consistent with the deletion of STS SR 3.3.2.3 and SR 3.3.2.6 and the addition of FNP ITS SR 3.3.2.8. The deletions and addition of surveillance requirements was addressed in previous JDs. The renumbering of subsequent surveillance requirements affects numerous STS surveillances on Table 3.3.2-1. In addition, STS SR 3.3.2.10, response time testing, is deleted from FNP ESFAS functions which do not have response times identified in FNP FSAR section 7.3. If no response time is identified in the FSAR for an ESFAS function, a response time is ! not assumed in any DBA analysis for that function and response time testing is not currently required for that function. The deletion of STS SR 3.3.2.10 for those functions without corresponding FSAR response times maintains the FNP current , licensing basis as implemented by the CTS and FSAR. Chapter 3.3 E5-5-B May,1999

FNP TS Conversion Enclosure 5 - JD from STS Chapter 3.3 - Instrumentation STS 3.3.2 ENGINEERED SAFETY FEATURE ACTUATION SYSTEM (ESFAS) INSTRUMENTATION FNP ITS 3.3.2 ENGINEERED SAFETY FEATURE ACTUATION SYSTEM (ESFAS) INSTRUMENTATION JD NUMBER JUSTIFICATION two channels per pump of this function consist of the turbine driver steam stop valve limit switches. The limit switch actuation is currently verified prior to reactor startup if not performed within the previous 92 days. The CTS surveillance requirement for these limit switches is retained in the FNP ITS SR 3.3.2.10. The STS surveillance requirements for a channel calibration and response time testing are deleted. The single CTS surveillance described above is adequate for this function and is proven through operating experience to ensure the operability of the function. The STS channel calibration requirement is unnecessary for a limit switch actuated function and has not been included in the FNP ITS. Additionally, no response time is associated with this function as documented in FSAR section 7.3. His change maintains the current FNP licensing basis for this function as specified in the CTS. 22 The STS surveillances associated with the P-ll and P-12 ESFAS interlock functions are revised consistent with the CTS surveillance requirements for these functions. Separate surveillance requirements will be provided for the instrument channel and the actuation logic. The STS 12 hour channel check surveillance requirement for these functions is deleted, since no CTS requirement exists, and it would be redundant to channel checks performed for the other pressurizer pressure and RCS 44are ESF functions. This approach is also consistent with the RTS Permissive / interlock channel check surveillance (i.e., no channel check is specified when the channel check is performed for other RTS functions). The CTS Surveillance SR 4.3.2.2 and Table 4.3-2 require that the interlock logic be tested with the Automatic Actuation Logic test and that the total interlock function be tested and the individual channels be calibrated every 18 months. To make the y4 change from the CTS to the STS format, the Automatic Actuation Logic and p Actuation Relays function for the interlocks was broken out and listed separately. This approach / format is consistent with all other ESF functions. The logic for generating each permissive / interlock signal will be tested for each interlock function as described in JFD 22a to meet the logic circuit testing requirements of CTS SR 4.3.2.2. The total interlock function will be tested with ITS SR 3.3.2.7 Channel Calibration, ITS SR 3.3.2.2 Actuation I.ogic Test, ITS SR 3.3.2.3 Master Relay Test, and ITS 3.3.2.8 Slave Relay Test. The ITS SR 3.3.2.4 COT for P-11 and P-12 will be performed on a 92 day interval in conjunction with the associated ESFAS pressure and temperature channel COT. This frequency is consistent with the setpoint uncertainty calculation allowances for rack driR. The 18-month calibration for P-ll and P-12 will complete the total interlock functional check and ! l i Chapter 3.3 E5-11-B May,1999

l

FNP TS Conversion Enclosure 5 - JD from STS Chapter 3.3 - Instrumentation STS 3.3.2 ENGINEERED SAFETY FEATURE ACTUATION SYSTEM (ESFAS) INSTRUMENTATION FNP ITS 3.3.2 ENGINEERED SAFETY FEATURE ACTUATION SYSTEM (ESFAS) INSTRUMENTATION

         -JD NUMBER                                          JUSTIFICATION coincide with the refueling outage channel calibration requirement from the CTS 4.3.2.2 and Table 4.3-2. The ITS changes also ensure that the Logic Test, Master and Slave Relay Tests, COT and Channel Calibration requirements for P-12 are identical to the surveillance requirements for the RCS T. , Low-Low input for MSLI. The use ofidentical surveillances for the same channels and logic circuits is f             appropriate and consistent with the FNP CTS and plant practices. This STS g'1             deviation maintains the current Farley licensing basis by continuing the explicit off               testing requirements of CTS Surveillance Requirement 4.3.2.2 in the FNP ITS.

22a The STS Automatic Actuation Logic and Actuation Relay function associated with the P-4, P-il and P-12 interlock functions was added to be consistent with the CTS surveillance requirement for these functions. The CTS requirement 4.3.2.2 required that the logic for the interlock be demonstrated operable during the automatic actuation logic test. This new line item under the function provides for the explicit testing of the SSPS automatic actuation logic associated with P-4, P-Il and P-12. Additionally, this line item will contain the surveillance requirements for testing the l Master and Slave relays associated with the P-11 function ofinterlocking closed the PORVs and the P-12 function ofinterlocking closed the Steam Dump Control System valves. This change maintains the current FNP licensing basis for these functions a specified in the CTS LCO 3.3.2 and SR 4.3.2.2 and allows assignment of a separate Condition for the interlock function and the interlock channels. The change also provides consistency with all other ESFAS functions that utilize the SSPS logic circuits and safeguards actuation circuits and relays. 23 The STS Actions Condition "L" for the P-11 and P-12 interlock functions is re-labeled as FNP ITS Condition "K". The STS Action Condition is re-labeled due to i the deletion of STS Condition K. STS Condition K is associated with an ESFAS l l function that is deleted from the FNP ITS ESFAS LCO and discussed in another JD. As such, this revision is necessary due to other changes made to the STS l ESFAS LCO to conform with the current FNP licensing basis as'specified in the CTS. l 24 The STS P-12 Tavg low low ESFAS interlock function is revised consistent with the CTS. The CTS requirement for this function contains both increasing and ; decreasing setpoints. The CTS increasing setpoints are added to the STS function in the FNP ITS ESFAS LCO. In addition to its main steam isolation function on the decreasing setpoint (coincident with high steam flow in two lines), the FNP P-Chapter 3.3 E5-12-B May,1999

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R*M od *pw.hs l>'f'At. sms mmdat s.sun a %e %e BASES hesa,\,cs

ESF% Kme.h I,b , p pp\ I, >

if SI hoS ac Gns froT6cSFFfng, anrcause other actions to occ.urrecL, rese.h occur. The interlock Functions back up manual actions 1 oF%e Sr is to ensure bypassable functions are in operation under cWowg the conditions assumed in the safety analyses. Enaineered Safety Feature Actuation System Interlocks - Reactor Trio. P-4 4 $,Y g Th P- interlock is enabled when a reactor trip br er (RTB) and its associated by ass breaker i open. Once the P-4 in_terloc_k _1 abled, [ (o D - cru"omatic SI initiation is blockedJ after a (s7Tecond time delay. This function allows operators to takennual control of SI systems aft _er the 111tialMiiase of injection is complete. unce*SI iL31ockedL automatic actuation of SI cannot occir until the RTBs have been manually closed. The f i of the P-4 interlock are: APPLICABLE SAFETY ANALYSES, k Enaineered Sa e ure Actuation System Interlocks - Reactor Trio. P-4 (continued) LCO, and .___ APPLICABILITY (* Trip the main turbine; p 3 I Isolate MFW w incidentlowT,.,[~ Reset high 5 '

revent reactTiaT1on of SI after a manual I flS setphnNo l reset of SI; C
i Transferthesteamdumpfromtheload]

h . rejection controller to the unit trip controller; andy

Prevent opening of the MFW isolation valves b% sb b cM if they were closed on SI or SG Water h \*d %p. E" g g"9 Level - High High.

f

Arm 6 d**P N#I Each of the above Functions is interlocked with b- 4c'it y M /or P-4 to avert or reduce the continued cooldown of g M m f-Aug the RCS following a reactor trip. An excessive gg 4 que cooldown of the RCS following a reactor trip could cause an insertion of positive reactivity g, O'P C#^ - 'S **d with a subsequent increase in generated power. ,

        /                                         To avoid such a situation, the noted Functions 44 g g .},ab have beendesign                    interlocked         with P-4 as part of the of the unit control and protection system.

pg gas g4,, Swt.Me o<~ Csebt.he beek &A ruvMg oc4%ko CM M1}FE55m. (continued) WOG STS B 3.3-101 Rev1,04/07/95

( ESFAS Instrumentation B 3.3.2 BASES Q (n Se LacA sJekg' mgeg Yone of the noted Functions serves a mitigatio function in the unit lirancina basis safety bnalyses. Only.thafturbine trip Function is O56 explicitly assumedgince it is an immediate St.J<. d e.e ,ob ' LD consecuence of the reactor trip Function. spy 6 Y#J 4 Neither turbine trip, nor any or tne otner reur Functions associated with the reactor trip N NW kb 5 signal, is required to show that the unit VM O F5NCA tw M dn9o44 licensing basis safety analysis acceptance triteria are not exceeded. r The RTB position switches that provide input to the P-4 interlock only function to energize or de-energize or open or close contacts. Therefore, this Function has no adjustable trip setpoint with which to associate a Trip Setpoint and Allowable Value. p .i St APPLICABLE @f'EnaineeredSafetyFeatureActuationSystem f* SAFETY ANALYSES, Interlocks - Reactor Trio. P-4 (continued) w a, g LCO, and APPLICABILITY This function must be OPERABLE in MODES 1, 2, and 3 when the reactor may be critical or i approaching criticality. This function does not , have to be OPERABLFj n MODE 4. 5, or_6 >ecause O

                        ._         the main turbin ( N MFW Systemn @ )e Steaml ump systaqpar    ot li. operation %.

Enaineered Safety Feature Actuation System Interlocks - Pressurizer Pressure. P-11 from oreburkte.t The P-11 interlock permits a normal unit cooldown Low p m.ssure, and depressurization without actuation of SI or

                       'X 6@S                         ymain steam line isolation) Mith two-out-of-three pressurizer pressure channels (discussed y f.tl th\oJ:.              previously) less than the P-11 setpoint, the g operator can manually blo k the Pressurizer 7 i

Pggg, .(;,tl,J,3 hoo Pressur Lowland steam !.ine Pressure - low SI J. - Oh bg signal the eam L1R rressur - low fream T 11 1so tion gnal (p viously discuss @ ). Wh th Steam ine Pre ure - L w steam ine l is man ally bl ked, a ain g/k.f. v4 I 1: lati n sign heam solati signal n Sten Line Press re #- Ne ative R e - Hig is ena ed. his I prov des nro ection f r at SL by clo;ure of the MSI . fWith two-out-of-tiree pressuruzer

(continued) ; i WOG STS B 3.3-102 Rev 1, 04/07/95 i

i g b k SFAS Instrume t 3 g;-- M 4e orchmtahl)5$b WAoaq c\.5,cJ -G%me w . .Apuun'ur $*y3 BASES u n % . A /- b ge ck c,y,g ,,4,) ets g 9.n g g pressure channels above the P-11 setpoint, the F" - ' f SIa&diaMoh l5 l Pressurizer Pressure - Lowiand 5 eam L1 e Sten Line

    >M ihSYM.. gg[h- {                            jLPre      ure - ow si s1 nals nd t Pr sure Low stea line isola ion s gnal                   e au matic ly enabl d.            e op rator an a o
        = _ -                                           er ble t se trips by u          of fie re ecti
                                                .      mI,nual r set buttc s.         hen    te Ste    Li essur - Low stfam 1         e is latio sig 1 it abled    the mair           iso ation nS am1/r ressu    - Neaat:f   ve ste R te - ich i die h1.d/ f ie S                                                                                                                      I

o. pressurit.eI IoW Trip 56tpoint instrument re" lect's bIsteady sta'te uncertaintie 39 i# This Funct on must bo OPERABLE in MODES 1, 2, and 3 tofallow an orcerly cooldown ano depressurization of the unit without the 3 g ac';uation oMSI er main steam i io atto . This Function does not have to be primBLE in MODE 4 APPLICABLE b Enainoered Safety Feature Actuation System g' 44g SAFETY ANALYSES, Inter' ocks - Pressurizer Pressure. P-11 gg LCO, and APPLICABILITY (continued) _ ]I <

                                                                                                                -.y 5, or 6 because system pressure must alrea                      a           ;

below the P-11 setpoint for the requirements of the heatup and cooldown curves to be met. Pse b*

                  -                          c.        Enaineered Safety Feature Actuation System                                 I a,rd,puunsieom                                    Interlocks - T x - Low Low. P-12                                           l
                                                                     '         ~
                                                                                                                '; bah gs,ew_ Mon
                                       # ~~-~i x                      nc _

On increas ctor co temperature, hef 4 6 ,ndsw d*Msio q , , , P_-12 1_nterl ockereinstat on ti1ch stearflow Toincloent witn15 team Li e Pressure - Lowfor . SQ, i PSE .n . . , ,, i . Coincident..Mth, - Low Low and provia

                                                     .irming signal'To Ee Steam Dump System. ton                       3     g 1 ~-

a,A rnain - aecreasing reactor coolant teve ature,fthe P-121 S interlock allows the o>eratorKo man Jally block uG C 4% gsog4gg SITonfHicn Meam tiow ,,01ncident Wit 19 Steam Line .tasun,, _ h _Prgssure - Lowtr Coincid=+ with L - Low LoWL z,grK (Dra decreatina temperaturerhe P nterloc a-Et tiso eemoves t se armina siana- w sne asam uumo 6 Gystemno prevent an excessTve cooiaown or tne - RC5 dud %tra malfunctioning Steam Du stem. mferlocks Since T,,, is used as ah indication u k RCS /

                 %e Sten.m Dump require           i temperature,       this  Function meets    redundancy gg                                                        BLE chan_nel in each
                                                         %s Mp seWM M Md sb@

sh k W h ed- #66 4

M (continued)

WOG STS B 3.3-103 Rev1,04/07/95

I W2% CHAPTER 3.3 Y g INSERT ZZ pt TO STS PAGE B 3.3-103

t l FNP SPECIFIC ITS BASES DESCRIPTION FOR P-12 INTERLOCK On decreasing temperature with two-out-of-three T.v channels below the setpoint, the P-12 interlock safety function is to provide main steam isolation on high steam flow in two steam lines coincident with T. -I.ow Low. Another P-12 safety function on Chapter 3.3 Insert Page r

ESFAS Instrumentation B 3.3.2 BASES Q/

                                            /            -

g loop. (In three loca unitd [hese channeln are b F,g.'l,4 gc used in two-out-of-;hree loaic. An Ecur ' oop y 1 (units. thav are used in two-out-of-four loQic.]

       'N                     This Function must be OPERABLE in MODES 1, 2,-

i J

       +M sr.h     4          and 3Fwhen a secondary side break or stuck open valve could result in the rapid depressurization N"                    of the steam lines. This Function does not have line Pnwe- W          to be OPERABLE in MODE 4, 5, or 6 because there M 4. off rd.          is insufficient eneeny in the secondary side        pfc yokh                  the unit to have a ccident.                   .

The ESFAS instrumentation satisfies Criter1orrs of the NRC Policy Statement. ACTIONS A Note has been added in the ACTIONS to clarify the application of Completion Time rules. The Conditions of this Specification may be entered independently for each Function listed on Table 3.3.2-1. In the event a channel's Trip Setpoint is found nonconservative with respect to the Allowable Vale.e, or the transmitter, instrument Loop, signal processing ulectronics, or bistable is found inoperable, then all affected Functions provided by that channel must be declared inoperable and the LCO Condition (s) entered for the protection Function (s) affected. When the Required Channels in Table 3.3.2-1 are specified (e.g., on a per steam line, per loop, per SG, etc., basis), then the Condition may be entered separately for each steam line, loop, SG, etc., as appropriate. When the number of inoperable channels in a trip function 1 exceed those specified in one or other related Conditions associated with a trip function, then the unit is outside the safety analysis. Therefore, LCO 3.0.3 should be immediately entered if applicable in the current MODE of operation.

FAIP hLS , Note: .Certain LCO Completion Times on WPNb tecAP approved top these times, the licen

                                               . In order -

censee to use a Completion Times 107.73 as require aff Safety Eva u u 1 (continued) WOG STS B 3.3-104 Rev 1, 04/07/95 4

445 ESFAS Instrumentation B 3.3.2 BASES C.I. C.2.1 and C.2.2 Condition C applies to the automatic actuation logic and y-4 actuation relays for the following functions:

S F y L:i 2nkrlo& *
contTT5bHc . y;
Phase A Isolation; ACTIONS C.I. C.2.1 and C.2.2 (contnued)

Phasa B Isolation [ n , Q Automatic Switchover to Containment Sump.] @S L

!NSERTQ  This action addresses the train orientation of the SSPS and the master and slave relays. If one train is inoperable, 6 hours are allowed to restore the train to OPERABLE status.

The specified' Completion Time is reasonable considering that there is another train OPERABLE, and the low probability of an event occurring during this interval. If the train cannot be restored to OPERABLE status, the unit must be placed in a MODE in which the LCO does not apply. This is done by placing the unit in at least MODE 3 within an additional 6 hours (12 hours total time) and in MODE 5 within an additional 30 hours (42 hours total time). The Completion Times are reasonable, based on operating experience, to reach the required unit conditions from full power conditions in an orderly manner and without challenging unit systems. g The Required Actions are modifi< d y a Note that allows one train to be bypassed for up to ;4 hours for surveillance testing, provided the other train is OPERABLE. This allowance is based on the reliability analysis assumption of WCAP-10271-P-A (Ref. 8) that 4 hours is the average time required to perform channel surveillance. l

(continued) WOG STS B 3.3-106 Rev 1, 04/07/95

ESFAS Instrumentation B 3.3.2 BASES placing the inoperable channel in the bypass condition within 6 hours, is sufficient to assure that the Function remains OPERABLE and minimizes the time that the Function may be in a partial trip condition (assuming the inoperable channel has failed high). The Completion Time is further justified based on the low probability of an event occurring during this interval. Failure to restore the inoperable channel to OPERABLE status, or place it in the bypassed condition within 6 hours, requires the unit be placed in MODE 3 within the following 6 hours and MODE 4 within the next 6 hours. The allowed Completion Times are reasonable, based on operating experience, to reach the required unit conditions from full power conditions in an orderly manner and without challenging unit systems. In MODE 4, these Functions are no longer required OPERABLE. ACTIONS E.1. E.2.1. and E.2.2 (continued) / The Required Actions are modified by a Note lha allows one additional channel to be bypassed for up to ;4 hours for surveillance testing. Placing a second channe' in the bypass condition for up to 4 hours for testing purposes is acceptable based on the results of Reference 8. F.1. F.2.1. and F.2.2 3 Condition F applies to [ Manual Initiation of Steam Line Isolation (76C.-12,o] [ Loss of Offsite Power; ) g jp 3 [* Auxiliary Feedwater Pump Suction Transfer on Suction ( Pressure - Low; and

             @       P-4 Interlock [

For the Manual Initiation Snd the P-4 InterloclD Functio this action addres.ces the train orientation of the SSPS. (For trie Loss of Offsite Power tunction, Ints action Og recognizes the lack of manual trip provision for a failed lchannelf For the AFW System pump suction transfer channels, (thisactionrecognizesthatplacingafailedchannelintr l { i

l (continued) t WOG STS B 3.3-109 Rev 1, 04/07/95 l

Mo ESFAS Instrumentation S 3.3.2 BASES Y g dur goperdionisnotnecesarilya onserva ve actio Sp foustfpof is funct< n could lign th AFW Syst to source that h at immed %te'y ca him of innartina n=n J L_uction.IIf a train or channe' is inoperab1'e, 48 hours is anowed to return it to OPERABLE status. The specified j Completion Time is reasonable considering the nature of { these Functions, the available redundancy, and the low 4 probability of an event occurring during this interval. If the Function cannot be returned to OPERABLE status, the unit must be placed in MODE 3 within the next 6 hours and MODE 4 within tie following 6 hours. The allowed Completion Times are reasonable, based on operating experience, to reach the required unit conditions from full power in an orderly manner and without challenging unit systems. In MODE 4, the unit does not have any analyzed transients or conditions f that require the explicit use of the protection functiongP noted above. ACTIONS G.I. G.2.1 and G.2.2 (continued) Condition G applies to the automatic actuation logic and Y actuaticn relave for the _ Steam Line Isolation u.Iurbine Trio) 76C, Cand Feetwater Isolation,]and AFW actuation Functions. The action addresses the train orientation of the SSPS and the master and slave relays for these functions. If one

 ,lNSERT          train is inoperable, 6 hours are allowed to restore the I

train to OPERABLE status. The Completion Time for restoring ! a train to OPERABLE status is reasonable considering that there is another train OPERABLE, and the low probability of an event occurring during this interval. If the train cannot be returned to OPERABLE status, the unit must be brought to MODE 3 within the next 6 hours and MODE 4 within bge the following 6 hours. The allowed Completion Times are ) reasonaDie, based on%perating experience, to reach the

      @e#ag required unit conditions from full power conditions in an 4           orderly manner and without challenging unit systems.

Placing the unit in MODE 4 removes all requirements for OPERABILITY of the protection channels and actuation functions. In this MODE, the unit does not have analyzed

 %' $$            transients or conditions that require the explicit use of I

the protection functions noted above. The Required Actions are modified a Note that allows one train to be bypassed for up 4 hours for surveillance (continued) WOG STS B 3.3-110 Rev 1, 04/07/95

957 ESFAS Instrumentation B 3.3.2 BASES req he explicit use of the protection funct above. The Required Actions are y a Note that allows placing a second chan te s condition for up to [4] hours for i lance testing. tal of 12 hours to rea E 3 and 4 hours for a second cha be sed is acceptable based on the results of Refe . Ns Co Mon 5 .1. .2.1 and .2.2 Lcale,944.0)<l k -- A ggi Conditio 5 liestotheP-11andP-12kndP-14)) g e, f interlocks

                  *O                    hanne inoperable, the operator must verify that G5FAS                 I)With the interlock is in the required state for the existing unit 4>hich shoulelo*         condition. This action manually accomplishes the function 6e. bloc.keclinee-        of the interlock. Determinatior, must be made within I hour.

I c.utrent. McDE s l The I hour Completion Time is equal to the time allowed by i

                          }.1.L.2.1andL.2.2            (continue 4 , g g                 LCO 3.0.3 to initiate shutdown actions in the event of a complete loss of ESFAS function.      If the interlock is not in WPkk I

the required state (or placed in the required state) for the

 / op<d-or i$ N ]           existing unit condition, the unit must be placed in MODE 3 n,pnA 4. Mc            within the next 6 hours and MODE 4 within the following eh,               6 hours. The allowed Completion Times are reasonable, based on operating experience, to reach the required unit conditions from full power conditions in an orderly manner T5C ~            and without challenging unit systems. Placing the unit in MODE 4 removes all requirements for OPERABILITY of these nterlocks.

SURVEILLANCE The SRs for each ESFAS Function are identified by the SRs REQUIREMENTS column of Table 3.3.2-1. A Note has been added to the SR Table to clarify that 1 lt'b Table 3.3.2-1 determines which SRs apply to which ESFAS Functions. , Note that each channel of process protection supplies both trains of the ESFAS. When testing channel I, train A and (continued) WOG STS B 3.3-114 Rev 1, 04/07/95

Mik

     -gk .T g CHAPTER 3.3 l

P INSERT AAA TO STS PAGE B 3.3-114 M ~3 FNP SPECIFIC ITS BASES DISCUSSION FOR ACTIONS L1, L.2, L.3.1, AND L.3.2 L.1. L.2. L.3.1. and L.3.2 Condition L applies to the automatic actuation logic and actuation relays for the P-4, P-11 and P-12 interlocks. This Condition is applicable when the interlock is inoperable to the extent that an ESFAS function which should not be blocked in the current MODE is blocked.

      ' With one train inoperable, the operator must verify that the interlock is in the required state for the existing unit condition.' This action manually accomplishes the function of the interlock.

Detennination must be made within I hour. If the interlock is not in the required state (or placed in the required state) for the existing unit condition, the interlock must be restored to OPERABLE status within 6 hours, or the unit must be placed in MODE 3 within the next 6 hours and MODE 5 within the following 30 houn. The allowed Completion Times are reasonable,- based on operating experience, to reach the required unit conditions from full power conditions in an orderly manner and without challenging unit systems. Placing the unit in MODE 5 removes all requirements for OPERABILITY of these interlocks and the automatic actuation logic, SI actuation relays and interlock actuation relays. This Condition is intended to address an inoperability of the actuation logic or relays associated with a given train which affects the integrated ESFAS response to a pressurizer low pressure SI j (P. I1), steam line low pressure SI/MSLI (P-12), or any auto SI (P-4) actuation signal. The ! relatively short Completion Time of this action (6 hours) is based on the fact that multiple ESF l components (systems or equipment) within a train are affected by the failure of the actuation

      . logic or relays. This Condition is applicable whenever more than one ESF system is affected by       ,

the inoperable train oflogic or relays. However, if one or more inoperable actuation relay (s) in a train affect only a single ESF system, then the ACTIONS Condition of the LCO applicable to the affected ESF component or system should be entered and this Condition is not applicable. This action addresses the train orientation of the SSPS and the master and slave relays. If one

      . train is inoperable,6 hours are allowed to restore the train to OPERABLE status. The specified
      . Completion Time is reasonable considering that there is another train OPERABLE, and the low          ,

probability of an event occurring during this interval. If the train cannot be restored to ! 1 OPERABLE status, the unit must be placed in a MODE in which the LCO does not apply. This is done by placing the unit in at least MODE 3 within an additional 6 hours (12 hours total time) , and in MODE 5 within an additional 30 hours (42 houn total time). The Completion Times are reasonable, based on operating experience, to reach the required unit conditions from full power conditions in an orderly manner and without challenging unit systems. j The Required Actions are modified by a Note that allows one train to be bypassed for up to 4 hours for surveillance testing, provided the other train is OPERABLE. This allowance is based on the reliability analysis assumption that 4 hours is the average time required to perform .:hannel surveillance (Ref. 8). Chapter 3.3 Insert Page

IO7

                     /                                                      ESFAS Instrumentation 7                                                                      B 3.3.2 3,T BASES SR   3.3.2.2                              M W*hikt f

SR 3.3.2.2 is the performance of an ACTUATION LOGIC TEST. C{3rasuE43-1 The SSPS is tested every 31 days on a STAGGERED TEST BASIS, using the semiautomatic testers The train being tested is placed in the bypass condition,I thus preventing inadvertent l ggn(Oe, ouAI M . actuation. Through the semiautomatic tester, all possible logic combinations, with and without applicable permissives, are tested for each protectionWunction, In addition, the [' for actua:boh Oe.tri of T* maaster inlay cois is puise testea for continuity. This au, mn verifies that the logic modules are OPERABLE and that there pumps is an intact voltage signal path to the master relay coils. The Frequency of every 31 days on a STAGGERED TEST BASIS is adequate. It is based o industry operating experience, considering instrument re iabi it and operating history data. g 9g

h 3.2.3 SR.3. . . the performance of an ACTUATION LO . EST as describe

                                                  .3.2.2, except that the semi         atic SURVEILLANCE    SR 3.3.2.3       (con    u REQUIREMENTS tester is not used and            o      ity check does not have to be performed, as            ined            te. This SR is applied        i to the bala            plant     untio          and relays that do not h          e SSPS t      circuits inst           utilize the automatic t        r or perform the cont % : heck. This test is also rformed every 31 days on a S M                  T BASIS.          Frequency is adequate based on indus h _EST g experience, considering instrument reliabR it oper                                                                  d o    ating history data.

3 SR 3 . 3. 2.[ SR 3.3.2. the performance of a MASTER RELAY TEST. The MASTER RELAY TEST is the energizing of the master relay, verifying contact operation and a low voltage continuity check of the slave relay coil. Upon master relay contact ' operation, a low voltage is injected to the slave relay ;

                           ' coil. This voltage is insufficient to pick up the slave                  i relay, but large enough to demonstrate signal path                        4 continuity. This test is performed every 31 days on a (continued)

WOG STS B 3.3-116 Rev 1, 04/07/95 , 1 l

nea l'** W & Q w A ge emph 4 7_i g 4 , c ,7 g s , c g ESFAS Instrumentation 4ke c h e) bprh&W,4 a mj %, B 3.3.2

             %e P-h kp4 on +cs4cd ,w - it. m                  6is BASES v46{ 5
          /            STAGGERED TEST BASIS.        The time allowed for the testing (4 hours) and the surveillance interval are justified in Reference 8.

Y SR 3.3.2 SR3.3.2.[stheperformanceofaCOT., mPp. comf4 A COT is perf d on each required channel to ensure the

                   -       ntire channel will per        the intended Function.               g   ,4 Setpoints must be found ithin the Allowable _Value<

specified in Table 3.3 1 1. gg 6 )

 " E" g7 Omum                  Theid         rence between the currenD "asYo^uN"TaItiesW the)
  "                    ~ revious test "as left" values must)De consisteni]with e                     ,

l critt allowance used in the setpoint methodology.Y_The setpoint shall be left set consistent with the assumptions of the current unit specific setpoint methodology. ; 3he "as found" and "as left" values must also be recordedl N/A j pd reviewed for consistency with the assumptions of thed FNP SURVEILLANCE SR 3.3.2 continued) p" REQUIREMENTS - l nce interval extension analysis (Ref. 8) wh The Frequency of 92 days is justified in Referenc move To o or us eskL when tkue wil bb Correef SR 3.3.2 nc> o.ck+vuse,imPo4f'en n my, 4 ,g. 0 =-__ SR 3.3.2(6/is the performance of a SLAVE RELAY ST. The

-)

MN " SLAVE RELAY TEST is the energizing of the slave elays. "y "'. ggg Contact operation is verified in one of two ways. Actuation

           . ,         equipment that may be operated in the design miti gation MODE DM}T C           >      is either allowed to function, or is placed in a.:ondition where the relay contact operation can be verifie without operation of the equipment. Actuation equipment that may not be operated in the design mitigation MODE i          prevented t rom f       operation by the SLAVE RELAY TEST circuit        For this latter case # contact operatiogJs verified by a continuity check of the circuit contain)Fg the slave relay. This test is performed every([92) daysJ The Frequency is adequate, (continued)

WOG STS B 3.3-117 Rev 1, 04/07/95

g i 4GI S strumentation _= VWe fhe, EFAS is Ac$,% +o B 3.3.2 OR5c. fg Ac'*-' 's@ ontme d:,kg on M .~,5 sue BASES gg"3 b noMg pi2A ceuu Mg c.hd g My M . J _. Q g w p 4. w+e v Wea. ' basedonQndustry)operatingexperience,considering p3g instrument reliability and operating history data.

                   -                                  5                    ;
                                                                                                                'IE ~l2, tee kdfuu.bil hememhnds.3 c.

N8'T ' I SR SR 3.3.2 A

3. 3. 2 In

[M is the performi nee _of a TADOT everv 92 C-/ VCO M

8 D days. 1 M Psd fod.d (This test is a check Undervoltage RC Fof andtMI.oss AFW Pomo of Suction OffsiteTransfer Power,' on Suction) m.e 3< wressure - LowJFunction6F-Each) Function is tested up to t,ht, 55 .s o g t , the (nd ' ncitaing, the master transfer relay coil A c. cih#,

y The test neludes e to ctuation be I WQ'^ g,g Qsignals d rectly to the S PS.fThe SR is moairled by a Noti An %4 That excluaes vermcation or setpoints for relays. Relayd AbaMc fo\erace - setpoints require elaborate bench calibration and are > S%es tarified durina CHANNEL CALIERA" ION.I The Freauency is t* M k. 4' *. adequate. It is based on 5nc ustry operatina evnerience,)g 5ftM TsS,3.7.2-1. l ,. cowebk.A. sconsider1nclinstrument reliabil' ty and operating history

rn, AdeA b kfereue,

                                            .n a,nci, the, P-4          h UR E LL C              SR 3.3.2       -(pF6                         mterloc.K Fore 4enf'edvAi REQUIREMENTS                                                                      ivrbJne M6 NMc SR 3.3.2        is the performance of a TADOT. This les~t is a              '52 We      '

[g,'Vg(continued)to check of he Manual Actuation Functions ({ndIAFW pump sta i' 95C, Ynn trin af all Mtw on=ns/. It is performed every Seelo CT5Tatt.E 4 3-2. Af18flifonths. Each Manual Actuation Function is tested up cf Nt go to, and including, the master relay coils. In some hj sr. instances, the test includes actuation of the end device Ghd., M S ! Techrx, to be. ) a(deauate, based on industry operating experience and *.d isi.e., pum pe g med T consistent with the typical refueling cyclet Th d R is Of 1' I dVMQdWWF)$j' modified during the TADOT.Yor by a tunctions. manual initiation

NoteThe__that .N ex

When DedWh* . manual initiation Functions _have _no_ associated setpoints. gj"

                       %M                              7            ea. PSeettoe.q qsc-1) us, wes% M 558SR 3.3.2.6) ibpv4-  5
                                                                                            ~

j schuuMen \oit " h SR 3.3.28 is 4 / gg W qach the performance of a CHANNEL CAL 3 RATION. MMN ACHANNELCALIBRATIONisperformedevery[18 months, or

          - uvk SR 3 3.l.            approximately at every refueling. CHAN)iEL CALIBRATION is a en x 31 y                  complete check of the instrument loop, including the sensor.

sTN4EAED mEs (continued) WOG STS B 3.3-118 Rev 1, 04/07/95 i

i r l l 1 1 l Associated Package Changes for RAI-3.3.4-2 l l l l l l l i I 1 i I J 1 l L,

I1 G i CHAPTER 3.3 l INSERT T TO CTS PAGE 3/4.3-50 AND TO STS PAGE 3.3-46 FNP SPECIFIC REMOTE SHUTDOWN INSTRUMENTATION AND CONTROLS j i Table 3.3.4-1 (page 1 of1) Remote Shutdown System Instrumentation and Controls FUNCTION / INSTRUMENT OR CONTROL REQUIRED NUMBER OF CHANNELS PARAMETER i MONITORING INSTRUMENTATION

1. Steam Generator Wide Range Level 1/SG 2 Steam Generator Pressee 1/SG

3. Pressuriaer Waterlevel 1

4. Pressunzer Pressure 1 :

l 1 l

5. RCS HotI4g Temperature (IAop A) 1

6. RCS Cold Leg Temperature (IAop A) 1

7. Source Range Neutron Flux (Gammamatncs) I 1 l l l 8. CWS Storage Tank Level 1 TRANSFER AND CONTROL CIRCUITS

1. Reactivity Control l Boric Acid Transfer System I l 2. RCS Pressure i i

i l Pressunzer Hester control 1

3. RCS Inventory Charsmg System 1 l

Letdown OrificeIsolation Valves I i

4. Decay Heat Removal Auxiliary Feedwater System 1 SG Atmospheric Relief Valves 1

5. Safety Grade Support Systems Required For 1 Functmas Listed Above.

3$ Chapter 3.3 Insen Page L

i Associated Package Changes for RAI-3.3.5-1 l l l l 1

/U

_ LOP DG Start Instrumentation

                                           %s LOPtnstrumer)sh he eu.h km.f,$

3.3 INSTRlhlENTATION C 3.3.F-/ .5W/ 8e OBEMBLE. 3.3.5 Loss of Power (LOP) Diesel Generator (DG) Start Instrumentation L LCO 3.3.5 kThree] channels per bus of the loss of voltage Function and [three] channels per bus of the degraded voltage Function pall be OPERABLE. APPLICABILITY: MODES 1,2,3,and4F When associated DG is required to be OPERABLE by LC0 3.8.2, m J Q C Sources - Shutdown." ACTIONS Y ,

     -------------------------------------NOTE-------------------------------------

Separate Condition entry is allowed for each Function. 9 h CONDITION REQUIRED ACTION COMPLETION TIME I A. One or more Functions A.1 --------NOTE--------- with ne channel per The inoperable u noperable. channel may be g., bypassed for up to 4 hours for

                        .                                  surveillance testing                    ,

of other channels. 2- Place channel in 6 hours , trip. ( , B. One or more Functions B.1 Restore all but one 1 hour l with two or more channel to OPERABLE i channels per u status. 1 inoperable. (aer bm ; f m'n u j 7 / (continued) ___- g _.______.._ 1 Only Apb Nl6 4 b. M I ed 2. 3 . WOG STS 3.3-47 Rev 1, 04/07/95

[ M> l CHAPTER 3.3 i INSERT I

        \                            TO STS LCO 3.3.5 PAGE 3.3-48
     $Y                           FNP SPECIFIC LOP ALARM ACTIONS T

CONDITION REQUIRED ACTION COMPLETION TIME f D. ---------NOTE- - D.1 Verify voltage on associated Once per 4 hours Only applicable to Function 3. bus is 2 3850 volts. One Alarm Function channel inoperable on one or more trains. E. Required Action and E.1 Restore bus voltage to 2 1 hour associated Completion Time 3850 volts. of Condition D not met. F. Required Action and F.1 Be in MODE 3. 6 hours associated Completion Time of Condition E not met. AND F.2 Be in MODE 5. 36 hours l l l Chapter 3.3 Insen Page

FNP TS Conversion Enclosure 5 - JD from STS Chapter 3.3 - Instrumentation STS 3.3.5 LOSS OF POWER (LOP) DIESEL GENERATOR (DG) START INSTRUMENTATION FNP ITS 3.3.5 LOSS OF POWER (LOP) DIESEL GENERATOR (DG) START INSTRUMENTATION l JD NUMBER JUSTIFICATION 1 - The STS 3.3.5 LCO and Applicability sections are revised to accommodate FNP specific changes to STS 3.3.5. STS 3.3.5 addresses the loss of voltage and degraded grid voltage instrument functions. The FNP specific version of this LCO includes a different kind ofinstrument function which is required in different Modes of applicability and has different Required Actions, required channels, and surveillances. The FNP specific LCO 3.3.5, contains requirements for a degraded grid alarm which provides notification of degradmg 4160 volt bus voltage on the class IE busses. The addition of this TS requirement in the FNP ITS is consistent with commitment 4.0(a) in the NRC SER associated with the FNP design for degraded grid protection dated 8/9/95 and transmitted via NRC letter dated 11/21/95. The addition of this alarm instrument function to STS 3.3.5 includes changes to the LCO, Actions, Applicability, setpoints, and surveillances. Therefore, a separate Table containmg a list of the Loss of Power instrument functions with the associated Required Channels, Applicable Modes, Surveillance Requirements, and setpoints is included in the FNP ITS 3.3.5. The FNP specific Table 3.3.5-1 allows the requirements for the different Loss of Power instrument functions to be organized and presented in a manner similar to other STS instrumentation LCOs which contain different functions. The proposed changes to STS 3.3.5 are necessary to allow a clear presentation of the FNP specific Loss of Power requirements consistent with the presentation of this information in other STS LCOs. 2 The STS Conditions A and B and associated Actions are revised consistent with the addition of the FNP specific degraded grid alann function and consistent with the train-oriented design of this function. These STS Conditions are applicable to the 9y loss of voltage and degraded grid voltage functions only. The proposed new FNP .hF specific alarm funcdon has separate applicable Actions. Therefore, the FNP specific implementation of these Conditions references the applicable functions 1 l and 2 accontingly in a note to Conditions A and B. Function 1 and Function 2 on FNP ITS Table 3.3.5-1 are the loss of voltage and degraded grid voltage functions I for which the STS Condition A and B are intended to apply. The note is added to , accommodate clearly referencing the specific loss of power Functions. The l l addition of the note is not intended to introduce a technical change to the STS ; Conditions or Actions. In addition, the STS "per bus" basis of these Conditions is ; changed to the FNP specific design of"per train". The FNP design includes more than one ESF bus in a train. However, the FNP LOP protection for each train of Chapter 3.3 ES-1-E May,1999

FNP TS Conversion Enclosure 5 - JD from STS Chapter 3.3 - Instrumentation

STS 3.3.5 LOSS OF POWER (LOP) DIESEL GENERATOR (DG) START INSTRUMENTATION j FNP ITS 3.3.5 LOSS OF POWER (LOP) DIESEL GENERATOR (DG) START INSTRUMENTATION JD NUMBER JUSTIFICATION ESF buses is only installed on a single bus within that train. The LOP protection instrumentation is installed on buses F and G. Therefore, the specification of l protection channels required on a "per bus" basis is inaccurate and misleading for the FNP design. The proposed FNP ITS Conditions A and B implement the FNP specific requirements for this LCO while maintaining consistency with the intent of the STS. 3 STS Condition C is also revised consistent with the addition of new Actions for the FNP specific degraded grid voltage alarm function. STS Condition C provides the default Action for the loss of voltage and degraded grid voltage DG start functions. STS Condition C does not contain an Action applicable to an inoperable FNP degraded grid voltage alarm. Therefore, the Condition is revised to clearly reference Conditions A and B which address the loss of voltage and degraded grid voltage DG start functions. Specific Actions appropriate for an inoperable FNP degraded grid voltage alarm are included in the FNP ITS 3.3.5. 4 FNP ITS 3.3.5 Conditions D, E, and F are intended to address the FNP specific degraded grid alarm function. The proposed FNP ITS 3.3.5 Actions Conditions are consistent with the current non-TS actions taken to meet commitment 4.0(a) in the l NRC SER associated with the FNP design for degraded grid protection dated 8/9/95 and transmitted via NRC letter dated 11/21/95. If the required alarm function is inoperable, the associated ESF bus voltage (s) must be verified frequently by operations (every 4 hours). If bus voltage falls below the specified voltage (3850V), it must be restored within I hour or action taken to place the unit in a Mode where the degraded grid voltage condition does not present a problem for equipment required to mitigate a design basis LOCA accident (Mode 5). As such, the proposed Conditions D, E, and F are consistent with the current FNP licensing basis reganiing this alarm function. ; 5 STS bracketed surveillance SR 3.3.5.1 is deleted consistent with the CTS requirements for this instrumentation. STS SR 3.3.5.1 requires a channel check of the loss of power functions every 12 hours. This surveillance is not part of the CTS l and considering that FNP has a specific alarm function included in this LCO which automatically provides notification of a degraded grid condition, the STS 12 hour channel checks are unnecessary. Therefore, this STS SR is deleted consistent with the FNP current licensing basis specified in the CTS. i Chapter 3.3 ES-2-E March,1998

973 LOP DG Start Instrumentation B 3.3.5 BASES ACTIONS this Specification may be entered independently for each (continued) Function listed in the LCO. The Completion Time (s) of the inoperable channel (s) of a Function will be tracked separately for each Function starting from the time the Condition was entered for that Function. L.1 s (Funchn5 I iMb l Condition A applies to the LOP DG start Functio wit one loss of voltage or degraded voltage channel per u inoperable. gn 4 g ., g g l yhA If one channel is inoperable, Required Action A.1 requires that channel to be placed in trip within 6 hours. With a

       '"A,i 49 y4 l         .

channel in trip, the LOP DG start instrumentation channels is 4 g. Ale l are configured to provide a one-out-of-three logic to itiate a trip of the incoming offsite power. g g. g g 2, A Note is added to allow bypassing an inoperable channel for up to 4 hours for surveillance testing of other channels. I This allowance is made where bypassing the channel does not ) cause an actuation and where at least two other channels are i monitoring that parame - g.g The specified Com etion anaTime allowed for bypassing [f one channel are r sonable ransidering the Function remains fully OPERABLE oncevery >us Ed the low probability of an event occurring djrino tsese_ intervals. g l

          -              Q@y@"M, e,                                        y Condition B/appliesNwhen more than onil loss of vol wm e or Atide'is oAbd 4o           inore Inan onis degraded voltage channe' on a single u C.,uldido 6                 inoperable.

I 4 Qad1

      .W % \bal'h^f? g' Required Action B.1 requires restoring all but one channel to OPERABLE status. The 1 hour Completion Time should allow y gyg g M 2. ample time to rep r most failures and takes into account the low probabil y of an event requiring an LOP start l                                 occurring durin this interval.                                           .l l                                                      1~      m    ,W~                          on
                                         %4 a Sinf l e inoMe Ch00EI                   ,        tru.'i n I
                        ?SE         r    remainin o% o. + rein, ConMYian A t

l N 'ff _M- +- (continued) l WOG STS B 3.3-147 Rev 1, 04/07/95

2W CHAPTER 3.3 INSERT BB TO STS PAGE B 3.3-148 FNP SPECIFIC BASES FOR ACTIONS D.1, E.1, F.1 AND F.2 FOR STS 3.3.5 LOP INSTRUMENTATION f3 a1 Condition D applies when the required degraded grid voltage alarm function is inoperable on one or both trains of emergency buses. The affected bus voltage associated with each inoperable alarm function must be verified 2 3850 volts every 4 hours. Frequent bus voltage verifications in lieu of an OPERABLE alarm effectively accomplish the same function as the alarm and allow operation to continue without the required alarm (s). A Note is added to Condition D indicating that it is only applicable to Function 3. El Condition E is applicable when the Required Action and associated Completion Time of Condition D is not met. If the voltage being verified per Required Action D.1 is < 3850 volts action must be taken to restore the voltage to 2 3850 volts within one hour. The Completion Time of one hour is reasonable to ensure prompt action is taken to restore adequate voltage to the affected er vgency bus (es). F.1 and F.2 Condition F becomes applicable when the Required Action and associated Completion Time of Condition E is not met. If the emergency bus voltage can not be restored to 2 3850 volts within the Completion Time of Condition E, action must be taken to place the unit in a MODE where the LCO requirement for the Alarm function is not applicable. To achieve this status, the unit must be brought to MODE 3 within 6 hours and MODE 5 within 36 hours. The allowed Completion Times are reasonable, based on operating experience, to reach the required unit conditions from full power conditions in an orderly manner and without challenging unit systems. l Chapter 3.3 Insert Page l 1

t I ATTACHMENTIII j i SNC Identified Changes Associated Package Changes I l i 1 4 1

1. During review and evaluation ofNRC comments on ITS Chapter 3.3.1," Reactor Trip System Instrumentation," SNC identified two issues associated with the proposed CTS to STS conversion.

First, the surveillance requirements for Table 3.3.1-1 Item 17.b, " Low Power Reactor Trips . l Block, P-7," which are based on STS, are not consistent with the FNP design. The proposed ITS surveillances SR 3.3.1.10 and SR 3.3.1.11 require performance of channel calibration and COT. Permissive P-7 is generated in the RTS logic circuits based on P-10 and/or P-13 logic. Dere are no P-7 instrument channels; therefore, there is no basis for specifying channel calibration or periodic operational tests. Each train of P-7 logic is tested under SR 3.3.1.5 (see Table 3.3.1-1 Function No. 20," Automatic Trip Logic"). As such, SNC has revised the ITS submittal to reflect that the surveillance requirements for P-7 on Table 3.3.1-1

are "NA" (i.e., not applicable). In addition, the ITS Bases and DOC NO.15b are revised. j New JD-26 provides the justification for this STS deviation. i Second, ITS COT surveillance requirement SR 3.3.1.11 for Permissives P-6, P-8, P-9, P-10 and P-13 on Table 3.3.1-1, which is based on STS, provides no benefit as specified and is ne consistent with the CTS. The RTS Permissive surveillance requirements proposed for ITS are channel calibration and COT every 18 months. The channel calibration encompasses all the requirements of the COT. With a COT test frequency of 18 months, the channel j calibration obviates the need for a COT. However, the STS and CTS intent of specifying a COT for the RTS permissives is to ensure that the permissives are functionally tested periodically and/or prior to startup and power ascension. Therefore, the COT test frequency should include a specific requirement such as " prior to reactor startup." As such, SNC has revised the ITS submittal to reflect a test frequency for the RTS Permissives P-6, P-8, P-9, P-10 and P-13 of"18 months and prior to reactor startup,"if"not performed within previous 92 days." This frequency is consistent with the RTS permissive surveillance frequency specified in CTS Table 4.3-1 Note 8. He additional frequency provides assurance that the instrument channels are functionally tested, including verification of the bistable setpoints, within 92 days of reactor startup. This frequ'ency is consistent with the Farley-specific setpoint uncertainty calculations allowance for rack drift and also the test frequency for the associated reactor trip instrument channels. In addition, existing plant surveillance procedures already include periodic functional testing provisions for the RTS permissives. In conjunction with the actuation logic test, which is performed in each train every 62 days, the additional test frequency ensures that the total interlock function is tested within 92 days of each reactor startup. The logic test and channel calibration requirements also ensure that the total interlock function is tested every 18 months. Rese comprehensive test results are consistent with CTS Surveillance Requirement 4.3.1.2, which will be deleted by the STS. To ensure consistency with the CTS and to meet the intent of STS and CTS, SNC has revised the ITS submittal to reflect an additional RTS Permissive surveillance test frequency for SR 3.3.1.11 of prior to startup if not performed within the previous 92 days. In addition, the ITS Bases is revised; DOC NOS. 97-LA and 98-L are revised to 97-M and 98-M, respectively; SHE 98-L is deleted; and new JD-27 is added tojustify the STS deviation. - 2. Enclosure 2, CTS 3/4.3.3.1 - DOC 22-LA referenced the wrong radiation monitor (R24A, B instead of R-27A, B). This change is attached. i l I

E i l 1 1 l l I i 1 1 l 4 l l I i Associated Package Changes for SNC Identified Item 1 l l I i 1 1 I l I i 1 1 i

FNP TS Conversion Enclosure 2 - Discussion of Changes to CTS Chapter 3.3 - Instrumentation CTS 2.2 LIMITING SAFETY SYSTEM SETTINGS CTS 3/4.3.1 REACTOR TRIP SYSTEM INSTRUMENTATION FNP ITS 3.3.1 REACTOR TRIP SYSTEM (RTS) INSTRUMENTATION DOC 1 MQ SHE DISCUSSION technical change to the CTS, it is considered an administrative change. 15b M CTS RTS surveillance 4.3.1.2 is deleted consistent with the STS. This CTS surveillance required the logic for the interlock functions to be demonstrated operable prior to each startup unless performed during the prding 92 days. In the STS, the interlock logic is required to be tested during performance of the Actuation Logic Test. 7"ne addition of the new

 #' \                 STS Actuation Logic Test definition is described in more detail in the changes to the definition section of the TS (1.0). This STS test specifically 1               includes the requirement to verify each trip in combination with each possible interlock logic state and is performed every 31 days on a staggered test basis. The STS Actuation Logic Test (SR 3.3.1.5) is assigned to the l               RTS Automatic Trip Logic functions and also the RTS interlocks to ensure the interlock logic is tested with the RTS automatic trip logic. The frequency of this STS surveillance every 31 days on a Staggered Test Basis is mom frequent than the CTS requirement prior to each reactor startup.

Since the SSPS semi-automatic logic test panel used to perform the Actuation Logic Test includes provisions for testing the logic associated with interlock functions, the addition of the requirement to test interlock functions does not impose any undue demands on the RTS system or the test personnel involved. Performance ofpermissive/ interlock logic circuit testing in conjunction with the trip logic circuits is consistent with current plant practices. Additionally, the inclusion of the interlock verification in the Actuation Logic Test performed every 31 days on a staggered test basis is consistent with the STS test requirements for Westinghouse plants. The CTS surveillance 4.3.1.2 also included the requirement to demonstrate the total interlock function operable every 18 months. The STS and FNP ITS (SR 3.3.1.10) specify a Channel Calibration Test be performed on each interlock function every 18 months, which tests the individual instrument I channel components including the channel bistable setpoints and the channel inputs to the SSPS logic circuits in each train. Along with the STS Actuation Logic Test, this STS surveillance effectively addresses the CTS requirement to demonstrate the total interlock function operable every 18 months' As such, the CTS surveillance 4.3.1.2 is no longer required to ensure the RTS interlock functions are adequately tested and is deleted consistent with the STS. However, as the new STS Actuation Logic Test . Chapter 3.3 E2-8-A May,1999

o l FNP TS Conversion Enclosure 2 - Discussion of Changes to CTS l Chapter 3.3 - Instrumentation CTS 2.2 LIMITING SAFETY SYSTEM SETTINGS 1 l CTS 3/4.3.1 REACTOR TRIP SYSTEM INSTRUMENTATION j FNP ITS 3.3.1 REACTOR TRIP SYSTEM (RTS) INSTRUMENTATION l DOC l HQ SHE DISCUSSION requirement increases the frequency specified in the TS for verifying the interlock logic, this change is considered more restrictive. l 15c LA CTS surveillance requirement 4.3.1.3 is revised consistent with the STS. l This CTS surveillance contains the RTS Response Time Testing requirements for the RTS functions. CTS 4.3.1.3 requires that each RTS function be tested on a Staggered Test Basis. The requirement to apply the Staggered Test Basis and the associated 18 month frequency is explained in detail within the CTS surveillance. The corresponding STS surveillance simply specifies Response Time Testing be performed every 18 months on a Staggered Test Basis. The detailed explanation within the CTS surveillance is effectively included in the bases of the corresponding STS surveillance. This CTS surveillance corresponds to the FNP ITS surveillance SR 3.3.1.14. The STS bases explains the required testing in terms 'of the channels and end actuating devices (RTBs or trains) required to be tested. This STS bases explanation encompasses the description of the l required testing contained in CTS 4.3.1.3. The STS and FNP ITS SR 3.3.1.14 do not introduce a technical change to the response time testing l requirements of the CTS. Reliance on the information contained in the STS bases for system operability requirements and guidance for performing surveillance requirements is acceptable since changes to the infonnation in the bases is controlled by the Bases Control Program specified in the administrative controls section of the TS. 16 A The title of the " Total Number of Channels" column in CTS Table 3.3-1 is revised to be " Required Channels" consistent with the columns of the conesponding STS Table 3.3.1-1. This change conforms to the STS and is intended to be an administrative change. The new ITS Conditions assigned to each Instrument Function will specify the appropriate action when one or more " Required"instmment channels are inoperable. Any technical differences between the CTS Actions and the STS Actions are discussed in the changes to the Actions of the CTS. Therefore, this change is considered administrative and is made to conform with the STS. 17 A CTS Table 3.3-1 is revised to incorporate a clarification to the Applicable - Modes column. The phrase "or other specified conditions" is added to the Chapter 3.3 E2-9-A March,1998 i l

FNP TS Conversion Enclosure 2 - Discussion of Changes to CTS Chapter 3.3 - Instiumentation CTS 2.2 LIMITING SAFETY SYSTEM SETTINGS CTS 3/4.3.1 REACTOR TRIP SYSTEM INSTRUMENTATION FNP ITS 3.3.1 REACTOR TRIP SYSTEM (RTS) INSTRUMENTATION DOC HQ SHE DISCUSSION TS. 'Ihe deletion of CTS note 4 and adoption of the STS bases redefines the RTS SI input function for FNP to be consistent with the automatic actuation logic described in the STS and with the assumptions of the FNP design basis accident analyses. Therefore, although this change eliminates the TS requirements for manual SI input to the RTS, it is applicable to and acceptable for FNP. 96 A The CTS refueling CFT for the RCP breaker position trip is revised to a TADOT and formatted consistent with the STS. The TADOT is an STS defined test (STS section 1.0) that is one of the surveillances used to replace the CTS CFT surveillance. The introduction of the different STS surveillance tests and the differences from the CTS surveillances are identified and discussed in the markups and DOCS associated with Section 1.0. The conversion of this CTS CFT into the STS TADOT does not reduce the CTS surveillance requirements for this function. The TADOT surveillance continues to verify the operability of the RCP breaker position reactor trip. The change to a TADOT surveillance is made to conform with the presentation and format of this information in the STS and does not result in a Whnical change to the required testing for this function. In addition, the corresponding STS TADOT surveillance is modified by a note which states that verification of setpoint is not required. The inclusion of this note is consistent with the design of the RCP breaker position actuation of reactor trip in that there is no setpoint associated with this actuation circuitry. The RCP breakers simply actuate contacts open or closed. The inclusion of the STS note, which states no setpoint verification is required, is consistent with the way this surveillance is currently implemented at FNP which is dictated by the system design. Therefore, the addition of this STS

           \      note does not result in a technical change to the CTS requirements. As l((               such, the changes discussed above are considered administrative.

97 M The S/U functional test requirement for the RTS Interlocks in CTS Surveillance 4.3.1.2 and Table 4.3 1 will be included in the Actuation Logic Test STS SR 3.3.1.5, performed under ITS Function No. 20, Reactor Trip

                ' Logic. CTS Table 4.3-1 Note 8, states that this functional test is " logic only." Since the CTS Actuation Logic Test already functionally tests all logic associated with the reactor trip interlocks, the startup test requirement Chapter 3.3                                    E2-66-A                                     May,1999

FNP TS Conversion Enclosure 2 - Discussion of Changes to CTS Chapter 3.3 - Instrumentation CTS 2.2 LIMITING SAFETY SYSTEM SETTINGS CTS 3/4.3.1 REACTOR TRIP SYSTEM INSTRUMENTATION FNP ITS 3.3.1 REACTOR TRIP SYSTEM (RTS) INSTRUMENTATION DOC NQ SHE DISCUSSION of Note 8 is redundant. The periodicity required by the CTS is at start-up unless performed in the previous 92 days. The periodicity of the Actuation Logic Test is every 31 days on a staggered test basis, or 62 days per train. The Actuation Logic Test is required to be performed in Modes 1-5 (( \ whenever the RTB's are closed and the Rod Control System is capable of rod withdrawal and so would be required at Startup. This periodicity exceeds the original periodicity of S/U or 92 days and, therefore, is more conservative and more restrictive. Since the Actuation logic Test SR 3.3.1.5 is included under the separate function of automatic trip logic, ITS ! Function No. 20, it is not necessary to repost the CTS Table 4.3-1 Note 8 requirement in the ITS. The ITS Bases revision clarifies that the RTS l Actuation Iogic Test includes testing of the trip and " permissive" logic circuits, and notjust the permissive input to applicable trip logic circuits. 98 M The CTS Table 4.3-1 CFT requirement for the RTS interlocks is revised as appropriate to add a Channel Operational Test consistent with the STS. The CTS CFT for the RTS interlock functions as modified by Note 8 is a logic test which is required to be performed prior to reactor startup if not

                - performed in the previous 92 days. The CTS includes no explicit channel functional test for these functions. Nevertheless, plant procedures do include provisions for functional testing and verification of the trip setpoint for the RTS pennissives in conjunction with the associated instrument channel functional tests. In addition, the allowances for instrument drift in QN      \    the supponing setpoint uncertainty calculations are based on performance of pf          periodic functional testing consistent with their associated RTS functions.

Therefore, this new ITS requirement is consistent with existing plant practices and analyses. The STS COT is only required to be performed every 18 months. In addition, the proposed ITS COT frequency of prior to each reactor stanup unless performed within the previous 92 days may be more frequent than every 18 months. Considering that the individual instrument channels that input to interlock functions are assigned separate quarterly COTS, the proposed RTS permissive COT frequency will be consistent with the associated trip circuit test frequency. In addition, the proposed surveillance frequency for the RTS permissives is consistent with CTS Table 4.3-1 Note 8. In that the P-7 interlock is a logic circuit function, not subject to setpoint drift or other similar setpoint inaccuracies that are a Chapter 3.3 E2-67-A May,1999

FNP TS Conversion Enclosure 2 - Discussion of Changes to CTS Chapter 3.3 - Instrumentation CTS 2.2 LIMITING SAFETY SYSTEM SETTINGS CTS 3/4.3.1 REACTOR TRIP SYSTEM INSTRUMENTATION FNP ITS 3.3.1 REACTOR TRIP SYSTEM (RTS) INSTRUMENTATION DOC NQ SHE DISCUSSION applicable to pmcess instrumentation, no COT or CALIBRATION requirements are specified. The addition of the RTS permissive COTS is pc, g g reasonable and acceptable for FNP. However, in that this is a new requirement, the change is' considered to be more restrictive. 99 LA The CTS CFT surveillance assigned to the RTB function on Table 4.3-1 is revised consistent with the STS. The CTS surveillance notes 14 and 15 which describe the testing required by this CFT are moved to the bases for the corresponding STS surveillance. The CTS details of the undervoltage and shunt trip mechanism tests that are required for the RTBs complement and enhance the existing STS bases discussion for this surveillance. The placement of the details describing this surveillance in the bases effectively retains the CTS reqmrements for this surveillance and is consistent with the genemi philosophy of the STS concerning the location of such detail in the bases. Reliance on the information contained in the bases for guidance in performing surveillance testing is acceptable since changes to the information in the bases is controlled by the Bases Control Program specifbd in 'he aiministrative controls section of the TS. 100 A The CTS CFT and associated surveillance note 5 assigned to the RTB function on CTS Table 4.3-1 are revised to a TADOT and formatted consistent with the STS. The TADOT is an STS defined test (STS section 1.0) that is one of the surveillances used to replace the CTS CFT surveillance. The introduction of the different STS surveillance tests and the differences from the CTS surveillances are identified and discussed in the markups and DOCS associated with Section 1.0. The conversion of this CTS CFT into the STS TADOT does not reduce the CTS surveillance requirements for this function. The TADOT surveillance continues to verify the operability of the RTBs in the same manner as the CTS CFT. The change to a TADOT surveillance is made to conform with the presentation and format of this information in the STS and does not result in a technical change to the required testing for this function. In additicn, ! the CTS note 5 which contains the test frequency applicable to the RTB l function surveillance is incorporated into the frequency of the corresponding STS TADOT surveillance. CTS note 5 specifies that the surveillance be performed at least every 62 days on a Staggered Test Basis. j Chapter 3.3 E2-68-A May,1999 l

FNP TS Conversion Enclosure 3 - Significant Hazards Evaluations Chapter 3.3 -Instrumentation III. SPECIFIC SIGNIFICANT HAZARDS EVALUATIONS CTS 2.2 LIMITING SAFETY SYSTEM SETTINGS CTS 3/4.3.1 REACTOR TRIP SYSTEM INSTRUMENTATION FNP ITS 3.3.1 REACTOR TRIP SYSTEM (RTS) INSTRUMENTATION EL Deleted 1 May,1999 Chapter 3.3 E3-24-A

978 RTS Instrumentation 3.3.1 SURVEILLANCE REQUIREMENTS (continued) SURVEILLANCE FREQUENCY 0 o SR 3.3.1. C ----------------NOTE------------------A

g + Verification of setpoint is not required. is Q ------------ .)

   $                                                                    s S                y             Perform TADOT.                                                 9    days W

[SR 3.3.1.1jH----------m----NOTE----_---------------- ' j I Z,This Surveillance shall includeverification'thatthetimeconstantsare] I adjulted to the prescribed values.

                                    -- =---------........... - -----------------

erform CHANNEL CALIBRATION. [18] mont SR 3.3.1.g,L U ._~-------------------NOTE-------------------- {

1. Neutron detectors are excluded from CHANNEL -

wCALIBRATION. r------------------------------------------- Perform CHANNEL CALIBRATION. 18 months

l l 2 SR 3.3.1. -------------------NOTE-------------------- Thi eillance shall include verificat Reactor Coola em 16 resistance temper or bypass loop flow rate. .

                                    ----------             -- ----------------       --------                            l erform CHANNEL CALIBRATION.                                        months 11                                                                                             .

SR 3.3.1. Perform COT. 18 months

     $ 4'                                        ,                                                   4 AH                                                                        (continued) p         i
                              . . . . . N rnc o       re       +d wb od l                        LM pnhAn N h. _6 WOG STS           Prior +o                                3.3-13                        Rev 1, 04/07/95 mW SWb?

L

2h RTS Instrumentation

                                                                                                                         ,      3.3.1 Table 3.3.1 1 (pose 5 of 8)

Reactor Trip System Instrumentation O FUNCTION APPLICAkEMODES OR OTHER SPECIFIED CONDITIONS REQUIRED CHANNELS SURVEILLANCE CONDITIONS REQUIREMENTS ALLOW 48L VALUE TRIP SETPo!NT is 16 Turblne Trip Q+ 8*e3-g o m-m 43 NS

e. Low !! 1 3 P SR 3.3.1. t psIg Q750 - 1 (8001 Pressure geh SR 3 3- e l (, b. Turbine 1 4 P SR 3. 1. (t (11% openJ {[11% open]

Velve Closure SR 3

7. Safety 1,2 2 trains 0 SR 3.3.1. NA NA Injection (SI)

Input from Engineered Safety Feature Actuation 17 System (ESFAS)

18. Reactor Trip System Interlocke , C)

a. Intermedfate Renee Neutron 2 2 hS SR 3.3.1.

SR 3.3.1. tk6E11T esp t 11E 10 esp Flux, P-6 M

b. Low Power 1 1 per T SR 3.3.1.11 [ NA NA Reactor Trips train SR 1 1 1 111 P

Stock, P 7 *

c. Power Range 1 4 T SR 3.3.1.1 5 60. s 48 RTP Neutron Flux, SR3.3.1.(

P8 50 d.- Power Renee 1 4 T 31 SR 3.3.1. 5 2.2 7 5 1501% RTP Neutron Flux, 3.3. P9 l l ,,, 7, '

e. Power Range 1,2 4 5 SR 3. 1 2 .8 % t RTP e d ran Flm, SR 3.1 T

                                                                                                                           $ tof,   e  gyp

f. Turbine lopulse 1 2 T gSR3.3.1.1QL s 12 '".2 sf10I%y

> Pressure, P 13 SR 3.3.1.1 T tu turbine SR 3.3.1. power power (continued) Reviewer's Note: Unit specific laptementations may contain only Allowable Value depending on Setpc , methodology used by the unit. 4 Below the P-6 (Intermodlate Range Neutron Flux) Interlocks. Above the P 9 (Power Range Neutron Flux) Interlock. WOG STS 3.3-19 Rev 1, 04/07/95

FNP TS Conversion Enclosure 5 - JD from STS Chapter 3.3 - Instrumentation STS 3.3.1 REACTOR TRIP SYSTEM (RTS) INSTRUMENTATION FNP ITS 3.3.1 REACTOR TRIP SYSTEM (RTS) INSTRUMENTATION JD NUMBER JUSTIFICATION surveillance practices. The Farley-specific approach provides assurance that the

              ' OTAT & OPAT reactor trip functions will always respond conservatively with respect to the safety analyses that credit these trip functions. A summary of the STS deviations follows.

The OTAT & OPAT dynamic compensation term changes reflect the as-built hardware configuration as approved in Technical Specifications Amendment Nos. 87 (Unit 1) and 85 (Unit 2), FNP RTD Bypass Manifold Elimination. The equalities, inequalities and values associated with the static and dynamic constants and allowable values were approved in Technical Specifications Amendment Nos. 121 (Unit 1) and 113 (Unit 2), Revision to Core Limits and OTAT & OPAT L Setpoints. Use of equalities for the static constants is required because these are explicit scaling calculation inputs that must be implemented within the hardware calibration tolerances. The requirement to set T' and T" to equal the full power operating reference temperature (Tw) was also approved in these amendments, j along with the clarification that ATo must be normalized at the full power operatmg ] reference temperature. The tenn descriptions for AT, T, and AToclarify that these l terms for each pmtection system channel are associated with specific RCS " loops." The term description for P' clarifies that the process control parameter is the

" pressurizer" pressure reference setpoint (i.e., Pw). The use of an equality for the nominal operating pressurizer pressure value reflects the transient and accident analyses modeling of a nominal setpoint with a plus/minus uncertainty. Inclusion ,

of the fi(AI) term description clarifies that it is an " indicated" function which must 4 be calibrated (i.e., normalized) based on cycle-specific test data following each refueling. These Farley-specific deviations fmm STS provide assurance that FNP is operate:1 ! and the OTAT & OPAT reactor trip functions are maintained consistent with applicable FNP transient and accident analyses, safety analysis limits, and setpoint ! l & I uncertainty and scaling calculations. These STS deviations also reflect the current fr/ FNP licensing design basis. l 26 The smeillance requirements for FNP ITS Table 3.3.1-1, Function 17.b, Permissive P-7, will be specified as N/A. The STS specifies SR 3.3.1.10, Channel i Calibration, and SR 3.3.1.11, Channel Operability Test, for the P-7 interlock. The P-7 interlock receives input from the P-10 and P-13 interlocks and, as such, does not have individual channels. Without individual channels P-7 is purely train-l oriented logic, and the channel calibration and channel operability are not appropnate. The P-10 and P-13 channel calibrations are covered by their respective [ l- '- Chapter 3.3 - E5-14-A May,1999 L

FNP TS Conversion Enclosure 5 - JD from STS Chapter 3.3 - Instrumentation STS 3.3.1 REACTOR TRIP SYSTEM (RTS) INSTRUMENTATION FNP ITS 3.3.1 REACTOR TRIP SYSTEM (RTS) INSTRUMENTATION JD NUMBER JUSTIFICATION Channel Calibration and Channel Operability Tests, and specifying a Channel Calibration or Channel Operability Tests for P-7 would be ra4= Ant. Therefore, the Channel Calibration SR 3.3.1.10 and Channel Operability Test 3.3.1.11 are not applicable to the P-7 interlock. The CTS requirement to check the total interlock function every 18 months is met by the individual 18 month channel calibrations and channel operability tests of P-10 and F-13. The Automatic Trip Logic, Function 20, Automatic Logic Test SR 3.3.1.5, performed every 31 days on a staggered test basis, tests each train of P-7 logic. This is consistent with the CTS current licensing basis, the FNP specific RTS design, and the STS P-7 Bases discussion. N 27 The FNP ITS SR 3.3.1.11 COT periodicity will be revised to include a requirement for completing the COT prior to startup if not performed in the previous 92 days. The STS specifies SR 3.3.1.11 as the COT for the RTS interlocks. This' surveillance is intended, in part, to meet the CTS requirement of 4.3.1.2 and Table 4.3-1 that the total interlock function be demonstrated operable at least every 18 months and at startup. Under the CTS, this requirement is met by performing channel calibrations which calibrate and functionally check the individual channels, including bistable setpoints and the SSPS input relays, and by testing the logic using the SSPS semi-automatic tester during the SSPS actuation logic operability tests. The ITS will retain the requirement to calibrate these channels every 18 months. When necessary, the COT will test channel components and verify bistable setpoints to prove operability (The channel calibration includes all functional testing requirements imposed by the periodic COT). The ITS Automatic Logic Test will encompass the coincidence logic for permissive logic functions. These tests are sufficient to completely test the total interlock function as required by the CTS. Farley will add the additional startup requirement to the applicable COT to consistent with the CTS Table 4.3-1 Note 8. The proposed frequency for the new COT is also consistent with plant procedures, setpoint uncertainty calculations allowances for rack drift, and the COTS for the associated reactor trip functions. Since P-7 is logic function only, the COT is not applicable (See JD-26). Performance of the periodic logic tests and the proposed COT provides assurance that the total interlock function is operable prior to reactor startup and power ascension. Chapter 3.3 ES-15-A May,1999 L _ _ --___

                                                }h                       RTS Instrumentation B 3.3.1
     . BASES ensure that the intermediate range is OPERABLE prior to leaving the source range.

When the source range trip is blocked, the high voltage to the detectors is also removed; T l

on decreasing power, the P-6 interlock automatically energizes the NIS source range detectors and enables the NI Source Range Neutron Flux reactor trip; an N/A FNP I

F - on increasing ower, the P-6 interlock provides a bac up block signal to the source range flux doubling circuit. Nc g Normally, this Function is manually blocked f by the control room operator during the g reactor startup. 48 ""S# b The LC0 requires two channels of Intermediate Scune P-f , Range Neutron Flux, P-6 interlock to be OPERABLE Reu W -E p (cT6 in MODE 2 when below the P-6 interlock setpoing is en*We,A Above the P-6 interlock setpoint,fthe NIS Source is n.4 guia) 1 Range Neutron Flux reactor trip will be blocked, 4.sJc,g. gnffthis Functiopill no longer be necessary. APPLICABLE a. Intermediate Ranae Neutron Flux. P-6 (continued) SAFETY ANALYSES, . LCO, and In MODE 3, 4, 5, or 6, the P-6 interlock does not APPLICABILITY have to be OPERABLE because the NIS Source Range is providing core protection,

b. Low Power Reactor Trios Block. P-7 The Low Power Reactor Trips Block, P-7 interlock is actuated by input from either the Power Range Neutron Flux, P-10, or the Turbine Impulse ;

Pressure, P-13 interlock. The LCO requirement ! for the P-7 interlock ensures that the following l Functions are performed: (1) on increasing power, the P-7 interlock I automatically enables reactor trips on the following Functions:

Pressurizer Pressure - Low; (continued)

WOG STS B 3.3-31 Rev 1, 04/07/95

hb RTS Enstrumentation B 3.3.1 BASES tb h y.gk he.c 4e 9-7 'Me'IO requires one channel per train of Low Power has no c6Ms, no Reactor Trips Block, P-7 interlock to be OPERABLE C.H6WEL. CAU6@6ilon in MODE 1.

          N E' #                        The low power trips are blocked below the P-7 TEST b nedd' W                    setpoint and unblocked above the P-7 setpoint.

In MODE 2, 3, 4, 5, or 6, this Function does not l lo7i *is 4csV h have to be OPERABLE because the interlock 51t, 3. 3. l. S v 4 c r performs its Function when power level drops . Fun.4ih 2.0, Ashm.F below 10% power, which is in MODE 1. ffG E PU'5' - c. Power Ranae Neutron Flux. P-8 '30 Yo tipA The Power Range Neutron Flux. 28 interlock is 6ge, I actuated at approximately(4gfp6wer as determined by two-out-of-f3ur NIS power range detectors. The P-8 interlo:N automatically enables the Reactor Cool.g Flow - Low (Single Loop) and RCP Breakor PosElon (Single Loop) reactor trips on Gow f' ow fnJone or more RCS loops on increasing g power. ine LCO requirement for this trip 1 g Function ensures that protection is pr d gM pp against a 1<:,ss of flow in an't RCS lo at could esult in Dn B condition < M "ha enrel when greater g 5 tnan approximately 8 power. On decreasing W n APPLICABLE c. Power Ranae Neutron Flux._P-8 (continued) cafd.Mf

SAFETY ANALYSES, LCO, and ower the reactor tri ~ ow flowhn any lYq:ceWiors r"

APPLICABI @a,maticallyblocked. Melb 0' The i. requires four channels of Power Range ggg [ gen Neutron Flux, P-8 interlock to be OPERABLE in

   $                     g               MODE 1.

his In MODE 1, a loss of flow in one RCS loop could result in DNB conditions, so the Power Range Neutron Flux, P-8 interlock must be OPERABLE. In MODE 2, 3, 4, 5, or 6, this Function does not have to be OPERABLE because the core is not _o . y, aroducing sufficient power to lbe concerned about Tms conatttons1

                                                                   ,    chden          re DNS des n         I5               d PSC (continued)

WOG STS B 3.3-33 Rev 1, 04/07/S5

3 3N RTS Instrumentation 8 3.3.1 i BASES l SURVEILLANCE SR 3.3.1.4 REQUIREMENTS 3 (continued) SR 3.3.1.4 is the performance of a TADOT every 31 days on a c,TsTalda4.1-1 STAGGERED TEST BASIS. This test shall verify OPERABILITY by g ps iv+1 actuation of the end devices.. . . l '[INdigy fThe RTB test shall include separate verification of the undervoltageland. shunt trip mechanisms. Independent

 '    1 N                       verification of RTB undervoltage and shunt tris Function is not required for the bypass breakers. No capasility is                      a provided'for performing such a test at power. The independent test for bypass breakers is included in SR g.Qt
            -k,31 N8t*                 3.3.1,14. The bypass breaker. test shall include a local' A                                . A Note has been added to indicate that this shunt   trip,be performed on the bypass breaker prior to test mus't
          /"
                   ,l                  placing it.in service.

The Frequency of every 31 days on.a STAGGERED TEST BASIS is adequate. It is' based on industry operating experience, considering instrument iabilit and o erating history data.

                        ,.                                                     7A 4
                       $g (            SR 3.3.1.5                                                    cmJ P8"m'MW. . i-SR 3.3.1.5 is the performance of an ACTUATION LOGIC TEST.

The SSPS is tested every 31 days on a STAGGERED TEST BASIS, using the semiautomatic tester. The train being tested is . placed in the bypass condition, thus preventing inadve t actuation. Through the semiautomatic tenter. ssible ! logic combinations,-with and wgi out app' icable permissives, are tested for each protectionvfunction. The Frequency of every 31 days on a STAGGERED TEST BASIS is ade_quate. It is based on inaustry operating experience, consiaeringAr~ Onstrument reliability and oneratina history dat V '

                                                                             =                 g[ewmd                ,

mon To ' SR 3.3.1 correct + i twmedd. i SR 3.3.1 s a calibration of the excore channels to the Lcdion neo.re channelst 'If the measurements do not agree, the

                                   . excore chanph are not declared inoperable but must be                ok Bot.

W A m MP5 G11 )ratesto agree with the incore detector measurements re , Df' tie excorjt channels cannot be adjusted,'the channe : gCMAf* o. f declared it)perable. This Surveillance is performed o anrity therF(AI) input to the overte erature TFunction[ L fm- ep p ' estele. j l gg {p (continued) m- - WOG STS' , B 3.3-54 i 9 Rev 1, 04/07/95 L

p] RTS Instrumenta i n \ i BASES SURVEILLANCE REQUIREMENTS hR 3.3.1.11 (continuedh w ~ plat _eauMareamp discriminator curves /e,, valuating tho NOTE ishde5 Urves, and comparing Ine curves to the manufacturer's d

   ,b              5g This Surveillance is not required for the NIS power range M             [ g          , detectors for entry into MODE 2 or 1, and is not required

[t D' for the NIS intermediate range detectors for entry into MODE 2, because the unit must be in at least MODE 2 to L LM M." %* *

perform the test for the intermediate rance detectors and M

e. M 'i

_ MODE 1 for the power range detectors. /Th (18] mont 1 M,*h '1 Frequen y is base ~on uis ne a to perform this Surve 11anc under < e condit ons that a' ly during a plant outa e and OT AT, oPET, ani. the p ;ential f an unpla 1ed transien if the Su eilla I g g f, were erformed ith the r ctor at pow expe ience has shown the

                                                                                      . Operati g components sually pas the gygp cm w ta m h .-

Lur eillance en perfo , d on the [1 ] month Fr quency N f fSR 3.3.1.1I cambene 3RN SR 3.3.1 2 is the erformance f a CHANN CALIB ION, as describ 6 in SR 3 .1.10, eve [14 s. Thi SR is T by a No' stating t t this] te mont shall nelude Tsc-15; .modifi verif ation of ;he RCS res stance le erature etector (RTD bypass 1 p flow rat . Th test wi 1 verify th rate lag ompensat n for f w f a the co e to the RT . he Frequ cy is justi ted by the assumpti of an riv tp CTS Tdle. 4,31 calibrati n . interval n the dete ination f the m 8 month nitude ( NOTE B of equip nt drift i the setpo t analys s. l SR 3.3.1 13 [__ ( Th'is ccT i s Ao 9

11

       ,ggg                          SR 3.3 11. is the performance of a COT of RTS interlocks every018gnths.

I Ig g The requency is based on the known reliability 6f the inte ks and the multichannel redundancy available, and

         ? M, do Sb         '

i has been own to be acceptable through operating

         'S not er                   experience.>

9 b m # in fne previW5

           % a6 y..

3 b OLT M D (continued) WOG STS B 3.3-58 Rev 1, 04/07/95 L -.

393 A CHAPTER 3.3 INSERT BBB 4th g gW TO STS PAGE B 3.3-58 FNP SPECIFIC ITS BASES DISCUSSION < FOR STS SR 3.3.1.13 (ITS SR 3.3.1.11) l The 92-day Frequency for RTS Interlock COT performance prior to startup is consistent with the ' uncertainty allowances for rack drift in the setpoint calculations (Ref. 6) and the COT (SR 3.3.1.7 and SR 3.3.1.8) Surveillance Frequencies for the associated trip functions. Performance of the RTS Interlock COTS in conjunction with periodic actuation logic tests (SR 3.3.1.5) provides assurance that the total interlock function is OPERABLE prior to reactor startup and power ascension. 1 1 l l Chapter 3.3 Insert Page L

I Associated Package Changes for SNC Identified Item 2 I l l 1 J l i

I FNP TS Conversion Enclosure 2 - Discussion of Changes to CTS Chapter 3.3 - Instrumentation CTS 3/4.3.3.1 RADIATION MONITORING INSTRUMENTATION FNP ITS 3.3.3 POST ACCIDENT MONITORING INSTRUMENTATION FNP ITS 3.3.6 CONTAINMENT PURGE AND EXHAUST ISOLATION INSTRUMENTATION FNP ITS 3.3.7 CREFS ACTUATION INSTRUMENTATION FNP ITS 3.3.8 PRF ACTUATION INSTRUMENTATION FNP ITS 3.4.15 RCS LEAKAGE DETECTION INSTRUMENTATION DOC NQ SHE DISCUSSION accomplished, the plant is placed in a safe mode of operation, and continued operation of the CREFS system is assured even in the event of a single failure. The STS Actions provide funher assurance that the plant is maintained in a safe mode of operation or is removed from the Applicable Mode for the affected equipment by the addition of default Actions.' If the Actions or Completion Times of STS Conditions A and B, described above, are not met the STS default Conditions C and D pmvide Actions which will ) remove the unit from the Applicable Mode. Condition D effectively eliminates the potential for a design basis fuel handling accident for which the two channels of radiation monitors are required and Condition C removes the unit from Modes 1-4 and eliminates the potential for a design basis LOCA for which the one channel of radiation monitor is required as a backup to the Containment Isolation Phase A Function. The STS Actions 3 described above provide acceptable Completion Times, altemate Actions, and default Conditions to ensure continued operation is limited or the plant is maintained in a safe mode of operation, or the plant is removed from the Applicable Mode. As such, the STS Actions for the control room radiation monitors are applicable and appropriate for FNP and have been incorporated into the FNP ITS 3.3.7. 22 LA CTS 3/4.3.3.1 Action 27a is applicable to the containment area radiation f monitors (R27A&B) and the noble gas emuent monitors R29B, j l c, R60A,B,&C, R60D, RISB&C, (CTS Table 3.3-6 items 2.d.i-iv). The p# y containment area radiation monitors in CTS 3/4.3.3.1 are moved into the FNP ITS Post Accident Monitoring LCO 3.3.3 as discussed previously. CTS Action 27a is marked up to show the changes applicable to the ; containment area radiation monitors due to the incorporation of those monitors into LCO 3.3.3. However, the noble gas emuent monitors (2.d.i-iv) which also use Action 27a are not retained in the FNP ITS and are

 . Chapter 3.3                                 E2-24-C                                     May,1999 i
                                                                                                      )

L 1

1 FNP TS Conversion Enclosure 2 - Discussion of Changes to CTS Chapter 3.3 - Instrumentation CTS 3/4.3.3.1 RADIATION MONITORING INSTRUMENTATION FNP ITS 3.3.3 POST ACCIDENT MONITORING INSTRUMENTATION FNP ITS 3.3.6 CONTAINMENT PURGE AND EXHAUST ISOLATION INSTRUMENTATION FNP ITS 3.3.7 CREFS ACTUATION INSTRUMENTATION FNP ITS 3.3.8 PRF ACTUATION INSTRUMENTATION FNP ITS 3.4.15 RCS LEAKAGE DETECTION INSTRUMENTATION DOC , NQ SIE DISCUSSION moved into the TR.M as discussed previously in the DOC associated with those monitors. The markup of Action 27a does not apply to the monitors moved into the TRM. All the CTS requirements applicable to the noble gas effluent monitors, including Action 27a, will be retained without technical change in the TRM along with the associated monitors. As changes to the TRM will be controlled consistent with the provisions of 10 CFR 50.59, the placement of this infonnation in the TRM is acceptable.

-23 L The CTS 3/4.3.3.1 Action 27a for the containment area radiation monitors (R24A&B) is revised consistent with the correspotuling STS Actions in LCO 3.3.3," Post Accident Monitoring". The CTS Action 27a requirement to initiate the preplanned attemate method of monitoring the appropriate parameters within 72 hours is deleted. This is not a requirement for any post accident monitoring instruments in the STS. In the STS, the use of preplanned alternate methods of monitoring must be described at the time the special repomng requirements become applicable (upon failure to restore within the Completion Time). The STS Actions allow time for the inoperable monitoring channel to be restored to operable status prior to initiating the attemative methods of monitoring. The additional time l allowed by the STS prior to requiring a special report and for initiating altemative methods for monitoring is based on the remaining operable l channel of a function or the diverse and non-Regulatory Guide 1.97 l instrumentation available for monitoring the parameter. The radiation monitors are used to diagnose accidents and measure the radiation level inside containment. Other plant instrumentation (pressure, temperature, radiation) or the analysis of air samples may be used to accomplish these functions at FNP. In addition, the time allowed by the STS is based on the passive nature of the instrumentation (the instruments do not perform
~

critical automatic actions) and the small likelihood of an event occurring i

Chapter 3.3 E2-25-C March,1998}}

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