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ATTACHMENTII SNC Response to NRC Request for Additional Information Related to Conversion to the Improved Technical Specifications - Chapter 3.4 Associated Package Changes Grouped by RAI Number 9902100096 990203 7 PDR ADOCK 05000348 p PDR g | |||
. . -- . - . . - --~_ . . _ - . ~. | |||
O, h // | |||
W 83 R4 opvd.d. 10 we is as A IM5ERT L W E' 5'b, HOTES IM pd y z Emere, ex t m sysTE, ) SRJ,6.5, f $R 3. 4.13sl ?} ; | |||
#3 suavElttAuCE nEouraExEuTs <Continuedi A | |||
l | |||
: c. Measurement of the CONTROLLED LEAKACE from the reactor coolant pump seals at least once per 31 days when the peactor Coolant , | |||
.TQffg system pressure is 2235 2 20 psig with the medulating valve fully l g 7g, open. The provisions of specification 4.0.4 are not applicable 7 for entry into Moot 3 or 4. | |||
gg , | |||
SR3,'/./3,1 [Ierformance of a ne.ctor Coolant systei water inventory datanc. ) | |||
at least once per 12 hours. p l 5 R 3.4.lV.t , p ' | |||
: e. [ Monitor /ngtherfactorheadf)langeleakoffsystemat/ east ongs A / per 24/ hours. / / / / / | |||
M k4.7.2 ach Reactor coolant System Pressure foolation Valverspectfted in 7 / ) | |||
, Tatdo 3. 4-1 } s 11 ce d monstra ed CPERA)lLE pur ant to Specific ton #5 i l4.0.5 xcept at in teu of ny leakage test g rew irdd bv - | |||
g , | |||
of fpm SIa.6 (spee icatie 4.0.5, ach va ve h ould be demonstrated CPERA3LE by l Rc.g ggg vert ytng leakage to be within the allowable leakage criteria of 0.5 l ggg Qg gpm per inch of qominal valve sishtt_h an upper limit of the maximum #h j lb "f2.5 allowaole leakag((tr/ Taprie 3/4-1) M ari meanwrec A a case to any g ] | |||
h -- | |||
Egtven test ca not te uce tne fifference etween the esults of he . | |||
b 1 | |||
prev ous tes and t e enarimugf allowable _ }eakage see tfted in T Die j { | |||
+ 3.4 by mo than 01) g g,,,j ( | |||
_ gg Every (ref ueling outaghring start DE 2 E g & | |||
: b. Prior o return ng the alve to' rvice foi ing mal enanc ,I Mh repa! or rep! cement capa 11ty of -he va b . | |||
rk on tr valve af f crstig the senti - | |||
Y 24 | |||
: c. >ro11owing valve actuation due to automatic or manual action or M g flow through the valva Qor vatves 5.aent i f t ed i n Ta b le _3_. 4 1 by a rd Qate r t s_kMs Y g7g / | |||
NR3.4 Va'^"t l' *li l d. The provisions of specification 4.0.4 are not applicable for | |||
$R 3,*l.14 1 entry into MODE 3 or 4. -. . . | |||
D/SEATO *ER:f E A INSERT P SA 3.4.I4.2. SR M N.3 23 g g,q, g3, g A RHR ado cbsure M N W a5WE SG Tube survelhe lederCoc.k 'IEST MELO'k N I I | |||
Zt h 3 g$ | |||
QTS _n 'l.f.2.d.1) n - -- g g g Y # To satisfy ALARA requirements, leakage may be measured indirectly (as frc a performance of pressure indicators) if accomplished in accordance with approved procedures and supported by computations showing that the method is capable of demcnstrating valve compliance with the leakage crateria. | |||
4 SR3,$l'k/ BASES FARLzr-un1T 1 N 3/4 4-is AMENcMENT no. 50 LA | |||
1 i | |||
E- '' | |||
CHAPTER 3.4 N A. | |||
I 1 | |||
l INSERT EA - j TO CTS 4.4.7.2.2 SURVEILLANCE l g NEW RCS PIV LEAKAGE TS SURVEILLANCE p'V FOR RHR OPEN PERMISSIVE INTERLOCK ; | |||
LCO 3.4.14 SR 3.4.14.3 1 1 | |||
) | |||
i SR 3.4.14.3 -------- - - - - - - - | |||
NOTE -- ----- --..--... | |||
Not required to be met when the RHR System valves are required open in accordance with SR 3.4.12.3. ) | |||
Verify RHR System open permissive interlock prevents the valves from being l | |||
opened with a simulated or actual RCS pressure signal 2 295 psig and s 415 psig. i Every 18 months. j 1 | |||
l 1 | |||
l l | |||
t i | |||
l e | |||
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l l- Chapter 3.4 Insert Page | |||
FNP TS Conversion | |||
, Enclosure 2 - Discussion of Changes to CTS Chapter 3.4 - RCS CTS 3/4.4.7.2 OPERATIONAL LEAKAGE UNIT 1 AND 2 FNP ITS 3.4.13 RCS OPERATIONAL LEAKAGE FNP ITS 3.4.14 RCS PRESSURE ISOLATION VALVE LEAKAGE FNP ITS 3.5.5 ECCS SEAL INJECTION FLOW DOC ! | |||
NQ _SjiE DISCUSSION ) | |||
verified to meet the LCO leakage limits. ) | |||
8 M A new action is added to the CTS 3/4.4.7.2 actions for an RCS PN that I does not meet the leakage limits based on the actions of the STS. Proposed Condition C of the new PN leakage LCO 3.4.14 applies to an inoperable RHR valve autoclosure interlock and has been added to the PN TS to l g N explicitly address this type of PIV inoperability and provide appropriate actions. The actions and completion times proposed for this new condition are similar to the existing actions for an inoperable PlV except that only one isolation valve is required to be closed and maintained closed under administrative control. This difference is required due to the location of the breakers for the associated valves and dose that plant personnel would I receive when restoring power to the valves in the event of a small break LOCA. As the action addresses an inoperable interlock and not valve leakage, and the STS actions Notes require the applicable Conditions and actions of any affected system made inoperable by the inoperable PN to be entered, the proposed action for an inoperable autoclosure interlock is acceptable. As the addition of this new Condition in the FNP TS represents a new requirement not previously addressed by the TS, the addition of this Condition is considered a more restrictive change. | |||
9 L The CTS 4.4.7.2.1.a and .b that require the leak detection particulate and gaseous radiation monitors and containment air cooler condensate level to be monitored every 12 hours are deleted consistent with the STS. The particulate and gaseous radioactivity monitors will continue to be checked every 12 hours by the Channel Check surveillance requirement SR 3.4.15.1 in the RCS Leakage Detection TS LCO 3.4.15. The containment air cooler condensate level monitor receives a Channel Calibration every 18 months per SR 3.4.15.4 in the RCS Leakage Detection TS LCO 3.4.15 and provides an alarm in the control room to alert the operators to an increase in condensate level. The 18 month channel calibration requirement is adequate for instmmentation used for indication and monitoring. As the radioactivity monitors provide a more immediate response to RCS leakage and will continue to be monitored every 12 hours, and the fact that an Chapter 3.4 E2-4-N February,1999 | |||
Associated Package Changes for RAI- 5 l | |||
1 l | |||
l | |||
. . . . . . ~ . _ . - - . - . . - . . . . . . .. . . - ~. . .. . . - . . . . . - | |||
lli RCS Loops - MODE 3 o | |||
3.4.5 SURVEILLANCE REQUIREMENTS (continued) , | |||
SURVEILLANCE FREQUENCY SR 3.4.5.2 Verify steam aentrator secondary side water 12 hours levels are h(:17]Vfor required RCS loops. , | |||
w s __ _ | |||
ro nkM< | |||
[ | |||
SR 3.4.5.3 Verify correct breaker alignment and E 7 days , | |||
indicated power are available to the ,g6 . | |||
required pump that is not in operation. F i | |||
) | |||
l l | |||
! l | |||
? l l 1 i | |||
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4 i | |||
4 i | |||
i WOG STS 3.4-10 Rev 1, 04/07/95 | |||
. . _ - - _ _ - . . - . - . .. .. . - _ . ~ _ . - . . - . - - - _ . . | |||
i | |||
: 7. 2-) RCS Loops - MODE 4 3.4.6 ACTIONS (continued) | |||
CONDITION REQUIRED ACTION COMPLETION TIME B. One required RHR loop B.1 Be in MODE 5. 24 hours inoperable. | |||
M Two required RCS loops inoperable. | |||
C. Required RCS or RHR C.1 Suspend all Imediately i loops. inoperable. operations involving a reduction of RCS DB boron concentration. | |||
No RCS or RHR loop in M operation. | |||
C.2 Initiate action to Imediately restore one loop to OPERABLE status and operation. | |||
l SURVEILLANCE REQUIREMENTS __ | |||
SURVEILLANCE FREQUENCY SR 3.4.6.1 Verify one RHR or RCS loop is in operation. 12 hours I i | |||
SR 3.4.6.2 Verif" G secondary side water levels are 12 hours' 4 | |||
;t: 17, for required RCS loops. | |||
- ~ - - - | |||
: t. [ (continued) wr er h E | |||
l WOG STS 3.4-12 Rev 1, 04/07/95 i | |||
. l RCS Loops - HODE 5, Loops Filled 1 4 | |||
2.7,Q 3.4.7 l I 3.4 REACTOR COOLANT SYSTEM (RCS) l 3.4.7 RCS Loops - MODE 5, Loops Filled ; | |||
i | |||
' l LCO 3.4.7 One residual heat removal (RHR) loop shall be OPERABLE and in operation, and either: | |||
9TF-163 a. One additional RHR loop s'iall be OPERABLE; or ! | |||
nef be in b. The secondary side water level f at least o team b-opdh generators (SGs) shall be a 17] =- l | |||
----------------------------NOTES------- * @ | |||
% (wid e ro.rg e). | |||
- =- = h - | |||
p-5 1 | |||
: 1. The RHR pum the loop in opc-ation may me-enera ue for s per 8 he'ir perio provided: | |||
: a. No operations are permitted that wculd cause reduction of the RCS boron concentration; and | |||
: b. Core outlet temperature is mai taine at least 10'F belt.w saturation temperature 4 g | |||
: 2. One required RHR loop may be inoperable for u t 2 hours f or surveillance testing provided that e other RHR loop is OPERABLE and in operatio . | |||
4 o. | |||
: 3. No reactor coolant pump shall be s v .ed with on or more RCS cold leg temperatures s 2757F unie secondary side water temperature o each SG 'F above each of the RCS cold leg temperaturesg or , | |||
l | |||
: 4. All RHR loops may be removed from operation during planned heatup to MODE 4 when at least one RCS loop is ! | |||
in operation. | |||
: b. The pre, sour *:ze.r u.nder volume. l t5 less, b.n 770 co'o'ic, he} | |||
APPLICAlILITY: MODE 5 with RCS loops filled. W* *bd'' f ' | |||
pressociser level g' C8 1,n). | |||
~- | |||
ct 'e" fu3s$s | |||
-4 | |||
,5 ff-pi,,+knem Son p uecod eseoF g pomp besielecJoet+e cont, nous flou; wh purge Mr( | |||
MnM 4eg po9 outerserviceo J | |||
WOG STS 3.4-14 Rev1,04/07/95 | |||
7q RCS Loops - MODE 5, Loops Filled 3.4.7 | |||
. ACTIONS CONDITION- REQUIRED ACTION COMPLETION TIME A. One RHR loop A.1 Initiate action to Immediately inoperable. restore a second RHR loop to OPERABLE MQ status. | |||
Required SGs secondary E side water levels not within limits. A.2 Initiate action to Immediately restore required SG secondary side water levels to within limits. | |||
B. Required RHR loops B.1 Suspend all Immediately - | |||
inoperable. operations involving a reduction of RCS E boron concentration. | |||
No RHR loop in gQ | |||
. operation. | |||
B.2 Initiate action to Immediately restore one RHR loop to OPERABLE status and operation. | |||
SURVEILLANCE REQUIREMENTS SURVEILLANCE FREQUENCY SR 3.4.7.1 Verify one RHR loop is in operation. 12 hours SR 3.4.7.2 Ver G secondary side water level is 12 hours k 17] in required SGs. _ _ | |||
'iknN MEN (continued) | |||
& W5 WOG STS 3.4-15 Rev 1 04/07/95 | |||
FNP TS Conversion | |||
', Enclosure 5 - JD from STS Chapter 3.4 - RCS STS 3.4.5 RCS LOOPS - MODE 3 | |||
. FNP ITS 3.4.5 RCS LOOPS - MODE 3 JD NUMBER JUSTIFICATION 1 The word " required"is inserted in Conditicn D of LCO 3.4.5 RCS Loops Mode 3 to modify the two RCS loops inoperable condition. The addition of the word | |||
" required"in the Condition D statement is consistent with the Condition A statement and use of" required RCS loop". Since only two of the three total RCS loops are required operable by the LCO statement, the Conditions in this LCO should specify " required RCS loops" (one loop may be inoperable without entering an LCO Condition). The addition of the word " required" provides a clarification to Condition D consistent with the intent of the LCO and the use and application of TS. | |||
2 The secondary side water level required in SR 3.4.5.2 is revised from the CTS value of 10% to 74% consistent with the FNP specific recommendation from Westinghouse. The STS Bases for SR 3.4.5.2 state that the purpose of the A requirement for SG secondary side level is to provide an altemate heat sink. If the | |||
.g SG tubes become uncovered, the associated loop may not be capable of providing this heat sink. To maintain consistency with the Bases for STS SR 3 4.5.2, Westinghouse was asked to provide the SG water leve; necessary to ensee that the tubes remain covered in Modes 3,4, and 5. That level was determined to be 74% | |||
wide range. Since this level is greater that the current level in CTS, this change, to conform with the intent of the STS is seen as more conservative. | |||
Chapter 3.4 ES-1-D February,1999 | |||
4 | |||
. FNP TS Conversion , | |||
. Enclosure 5 - JD from STS Chapter 3.4 - RCS STS 3.4.6 RCS LOOPS - MODE 4 FNP ITS 3.4.6 RCS LOOPS - MODE 4 JD NUMBER JUSTIFICATION 1 The STS LCO 3.4.6 Note 1 is revised consistent with the FNP CTS. The STS I bour allowance for de-energizing pumps is revised to conform with the FNP 2 hour allowance to de-energize pumps in this Mode. The FNP CTS maintain a 1 hour allowance for de-energizing pumps in Mode 3, however, due to the lower operating temperature and reduced decay heat load in Mode 4 the FNP CTS allow 2 hours for de-energizing all pumps. This change to the STS is consistent with the current FNP licensing basis as specified in the CTS. | |||
2 The STS LCO 3.4.6 Note 2 is revised consistent with the FNP CTS. The STS note restricts the starting of a reactor coolant pump in Mode 4 when the RCS cold leg temperatures are less than or equal to the specified temperature. The purpose of the restriction is to prevent RCS pressure transients, caused by energy additions from the secondary system, that could exceed the 10CFR 50, Appendix G limits. The FNP CTS contains an attemate method for limiting the potential RCS pressure transients. The FNP specific provision for starting reactor coolant pumps when the pressurizer water volume is less than the specified volume provides a volume for the RCS to expand into which provides assurance that the potential RCS pressure transient is limited. The addition of this attemate method in the FNP ITS for limiting RCS pressure transients when starting RCPs is consistent with the current FNP licensing basis as specified in the CTS. | |||
3 The STS limitation on the secondary side SG water temperature of s 50 F in Note 2 to LCO 3.4.6 is revised consistent with the FNP CTS requirement of < 50 *F. | |||
This change maintains the current FNP licensing basis as stated in the CTS. | |||
4 The secondary side water level required in SR 3.4.6.2 is revised from the CTS value of 10% to 74% consistent with the FNP specific recommendation from Westinghouse. The STS Bases for SR 3.4.6.2 state that the purpose of the I requirement for SG secondary side level is to provide an alternate heat sink. If the SG tubes become uncovered, the associated loop may not be capable of providing l this heat sink. To maintain consistency with the Bases for STS SR 3.4.6.2, Westinghouse was asked to provide the SG water level necessary to ensure that the tubs remain covered in Modes 3,4, and 5. That level was detennined to be 74% | |||
l wide range. Since this level is greater that the current level in CTS, this change, to combrm with the intent of the STS is seen as more conservative. | |||
i Chapter 3.4 E5-1-E Febmary,1999 | |||
FNP TS Conversion Enclosure 5 - JD from STS Chapter 3.4 - RCS STS 3.4.7 RCS LOOPS - MODE 5 - LOOPS FILLED FNP ITS 3.4.7 RCS LOOPS - MODE 5 - LOOPS FILLED 6 The secondary side water level required in part b. of the LCO statement and SR 3.4.7.2 is revised from the CTS value of 10% to 74% consistent with the FNP specific recommendation from Westinghouse. The STS Bases for SR 3.4.7.2 state that the purpose of the requirement for SG secondary side level is to provide an f | |||
8; alt'emate heat sink. If the SG tubes become uncovered, the associated loop may not 9 be capable of providing this heat sink. To maintain consistency with the Bases for STS SR 3.4.7.2, Westinghouse was asked to provide the SG water level necessary to ensure that the tubes remain covered in Modes 3,4, and 5. That level was determined to be 74% wide range. Since this level is greater that the current level in CTS, this change, to conform with the intent of the STS is seen as more conservative. | |||
i 1 | |||
l l | |||
l l | |||
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1 i | |||
Chapter 3.4 E5-2-F February,1999 | |||
e Associated Package Changes for RAI- 8 I | |||
FNP TS Conversion Enclosure 2 - Discussion of Changes to CTS Chapter 3.4 - RCS CTS 3/4.4.1.4 REACTOR COOLANT LOOPS AND COOLANT CIRCULATION COLD SHUTDOWN FNP ITS 3.4.7 RCS LOOPS - MODE 5 - LOOPS FILLED DOC EO SEE DISCUSSION 1 A The CTS 3/4.4.1.4, RCS Cold hoown, is revised consistent with the STS. The CTS is divided into two new TS, LCO 3.4.7, Mode 5 - Loops Filled, and LCO 3.4.8, Mode 5 - Loops Not Filled. Two separate markups of CTS 3/4.4.1.4 are included to separately illustrate the changes made in converting to the two new STS LCOs. As the division of the CTS into two new LCOs is made solely to conform with the format and presentation of the STS and since the resulting technical impacts are discussed in other DOCS, this change (1 TS to 2 TS) is considered administrative. | |||
2 A The CTS LCO statement 3.4.1.4 and # footnote to the LCO are combined and revised consistent with the STS. The option provided by the # footnote to allow 2 steam generators to be substituted for one of the required RHR loops when 3 RCS loops are filled is incomorated directly into the LCO 4 | |||
g l (new LCO parts a. and b.) and the Applicability statement. This is acceptable since the LCO is specifically for Mode 5 - loops filled. | |||
3 M The CTS 3/4.4.1.4 action statement b is revised consi< tent with the corresponding STS Condition B. CTS action stateme it b addresses the situation where no RHR loops are operating and requi: :s suspension of operations involving a reduction in the boron concentra! ion and action to be initiated immediately to restore a loop to opemtion. The corresponding STS Condition B addresses both the situations of no operating and no operable RHR loops. The STS Condition B actions are the same as the CTS action statement b except that the action required to be initiated immediately includes restoration of a loop to operable status as well as operation. The situation of no operable RHR loops is currently addressed by CTS action statement a (less than required loops operable) which also requires immediate action to restore a loop to operable status be initiated. | |||
As such, the only difference between the STS Condition B actions for no l operable loop and CTS action statement a is the requirement to suspend l operations involving a reduction in the boron concentration. The inclusion of the action to suspend operations involving a reduction of b 'ron concentration for the condition of no operable loops is a reasonable and conservative action to limit the potential for reducing the shutdown margin when the decay heat removal capability of the plant is degraded to the extent that no RHR loops are operable. Additionally, in the situation of no l | |||
Chapter 3.4 E2-1-F February,1999 | |||
1 1 | |||
1 1 | |||
1 i | |||
l l | |||
I i | |||
1 1 | |||
Associated Package Changes for RAI- 10 , | |||
1 I | |||
l i | |||
1 I | |||
( | |||
1 | |||
e FNP TS Conversion Enclosure 2 - Discussion of Changes to CTS Chapter 3.4 - RCS CTS 3/4.4.1.4 REACTOR COOLANT LOOPS AND COOLANT CIRCULATION COLD SHUTDOWN FNP ITS 3.4.7 RCS LOOPS - MODE 5 - LOOPS FILLED DOC EQ EHE DISCUSSION 1 A The CTS 3/4.4.1.4, RCS Cold Shutdown, is revised consistent with the STS. The CTS is divided into two new TS, LCO 3.4.7, Mode 5 - Loops l Filled, and LCO 3.4.8, Mode 5 - Loops Not Filled. Two separate markups ! | |||
of CTS 3/4.4.1.4 are included to separately illustrate the changes made in l converting to the' two ocw STS LCOs. As the division of the CTS into two ! | |||
new LCOs is made solely to conform with the format and presentation of i the STS and since the resulting technical impacts are discussed in other l DOCS, this change (1 TS to 2 TS) is considered administrative. j. | |||
2 A The CTS LCO statement 3.4.1.4 and # footnote to the LCO are combined I and revised consistent with the STS. The option provided by the # footnote ! | |||
to allow 2 steam generators to be substituted for one of the required RHR : | |||
loops when 3 RCS loops are filled is incorporated directly into the LCO i (new LCO parts a. and b.) and the Applicability statement. This is l acceptable since the LCO is specifically for Mode 5 - loops filled. | |||
3 M The CTS 3/4.4.1.4 action statement b is revised consistent with the I corresponding STS Condition B. CTS action b. is revised to reflect the l additional requirement to have the RHR loops operable as stated in STS I Condition B. In addition, the generic term " coolant loop" is changed to Y ,e "RHR loop" consistent with the STS. These changes, combined with the allowance to substitute two steam generators with adequate level as described in the CTS # footnote for an RHR loop, reflect the necessary changes to convert CTS action statements a. and b. to STS Conditions A and B. CTS action statement b addresses the situation where no RHR loops are operating and requires suspension of operations involving a reduction in the boron concentration and action to be initiated immediately to restore a loop to operation. The corresponding STS Condition B addresses both the situations of no operating and no operable RHR loops. The STS Condition 1 B actions are the same as the CTS action statement b except that the action ! | |||
required to be initiated immediately includes restoration of a loop to l operable status as well as operation. The situation of no operable RHR ! | |||
loops is currently addressed by CTS action statement a (less than required l loops operable) which also requires immediate action to restore a loop to ! | |||
operable' status be initiated. As such, the only difference between the STS 'j Condition B actions for no operable loop and CTS action statement a is the l | |||
Chapter 3.4 E2-1-F February,1999 wwvmv +n-., r w we-+ ,--e-me- -esa +- -- su | |||
; e FNP TS Conversion l , | |||
Enclosure 2 - Discussion of Changes to CTS Chapter 3.4 - RCS l CTS 3/4.4.1.4 REACTOR COOLANT LOOPS AND COOLANT CIRCULATION COLD SHUTDOWN FNP ITS 3.4.7 RCS LOOPS - MODE 5 - LOOPS FILLED DOC | |||
: EQ SHE DISCUSSION requirement to suspend operations involving a reduction in the boron concentration. The inclusion of the action to suspend operations involving a reduction of boron concentration for the condition of no operable loops is a reasonable and conservative action to limit the potential for reducing the shutdown margin when the decay heat removal capability of the plant is degraded to the extent that no RHR loops are operable. Additionally, in the situation of no operable RHR loops it is very likely that the condition of no operating RHR loops would also exist and the action to suspend operations involving a reduction in boron concentration would be applicable anyway. | |||
l However, as this revision to the CTS actions introduces a new action j (suspension of operations involving a reduction in boron concentration) that is not specifically stated in the CTS for the condition of no operable loops, it is considered more restrictive. | |||
4 LA CTS surveillance 4.4.1.4 is revised consistent with the STS. The CTS surveillance is revised editorially to conform with the STS format and presentation of this information. In addition, the requirement to verify l l | |||
" circulating reactor coolant" is moved into the bases for this surveillance. l The circulation of coolant is inherent in the operation of an operable RHR loop. The STS bases description for this surveillance contains an explanation for verifying a loop is operating which includes the confirmation of coolant flow. Placement of this information in the bases is acceptable based on the level of change control provided by the bases control program in the administrative controls section of the STS. | |||
5 M The surveillance requirements of CTS 3/4.4.1.4 are revised consistent with the STS. Two new surveillances are added to the CTS to verify operability of the second non-operating RHR loop and the level in the two RCS loop steam generators. Since either the RHR loop, or the level in two steam generators may be relied on to meet the LCO, the STS contains appropriate | |||
, surveillances to verify compliance with the LCO. The addition of the steam | |||
! generator level verification surveillance is consistent with the other RCS loop TS that allow the LCO to be met by RCS loops with a specified minimum steam generator level. The verification of breaker alignment and indicated power for the non-operating RHR pump relied on to meet the LCO is also consistent with the CTS requirements in other TS for RCS t | |||
loops. As the LCO may be met by one or the other of these options, the 1 | |||
I Chapter 3.4 E2-2-F March,1998 l | |||
l | |||
0 Associated Package Changes for RAI- 13 l | |||
l i | |||
I I | |||
l l | |||
1 i | |||
i 1 | |||
I | |||
i a | |||
Y Pressurizer PORVs j - | |||
B 3.4.11 i | |||
j BASES- (continued) | |||
! SURVEILLANCE SR 3.4.11.1 l REQUIREMENTS Block valve cycling verifies that the valve (s) can be closed l if needed. The basis for the Frequency of 92 days is the | |||
; ASME Code, Section XI (Ref. 3). If the block valve is closed to isolate a PORV that is capable of being manually cycled, the OPERABILITY of the block valve is of importance, because opening the block valve is necessary to permit the PORV to be used for manual control of reactor pressure. If the block valve is closed to isolate an otherwise inoperable PORV, the maximum Completion Time to restore the PORV and open the block valve is 72 hours, which is well within the allowable limits (25%) to extend the block valve Frequency of 92 days. Furthermore, these test requirements would be completed by the reopening of a recently closed block valve upon restoration of the PORV to OPERABLE status (i.e., | |||
,D completion of the Required Actions fulfills the SR). | |||
TheNotemodifiesthisSRbystatingthatitisnotrequired i to be met with the block valve closed, in accordance with l the Required Action of this LCO. | |||
- 5 % 46$h A b " D SR 3.4.11.2 .m MODE 3 53w4W4 SR 3.4.11.2 requires a complete cycle of each PORV. *r 4 Ot *Mo M, bO Operating a PORVj rough one complete cycle ensures that t e vohes chstA 5'n" .PORV can be manua y ctuated for mitigation of an SGTR. | |||
g p 4. W if -'The Frequency of 61 months is based on a typical refueling I | |||
. cycle and industry accepted practice. | |||
g 4-N ypyp f I . tah -44 Toinv0mhkwA + SR 3.4.11.3 H ok \t.ser s40sm - | |||
OperatWinoid air control valves a valves MfemfeMe "P"g* - | |||
on the air accumu a nctuates properly who res control system The Frequency of dQn.b'q " 18] months i on a typical re he other Surveillances used to cycle and th trate I b .TMfA4, ._ PERABILITY 1 | |||
{ | |||
n | |||
~SR3. | |||
11.4 _ | |||
~This Surveillance is no with permanent l' | |||
_ IE power supp11 e valves. | |||
(continued) i | |||
.WOG STS 8 3.4-56 Rev 1, 04/07/95 | |||
* l i | |||
i | |||
. 1 l | |||
i l | |||
i l | |||
) | |||
I Associated Package Changes for RAI- 14 ! | |||
i i | |||
) | |||
l i | |||
l l | |||
l l | |||
1 i | |||
1 1 | |||
1 l | |||
1 1 | |||
l I | |||
l | |||
.. - - - - - . .- . .- . - . - - .. ., - -~~ .- - | |||
l *l i | |||
g REACTOR COOLANT g g SURVE!LLANCE REQUIREMENTS e_ | |||
Each PORV shall be demonstrated OPERABLE at least once per 18 months by: | |||
N3sNsIlel Operating the PORY through one complete cycle of full travel during | |||
. MODE 3 or 4,' | |||
' J Ik3*N'0!*$ Operating the PORV through one complete cycle of full travel using the backup PORV control system. and | |||
: h. Performing a CHANNEL CALIBRATION of the actuation instrumentation. l 5 0 .4.11. 1 @ ' Each block vatve shall d. d.monserae.d ePERAsLE se lease one. p.c j 92 days by operating the valve through one complete cycle of full travel unless the block valve is closed in order to meet the requirements of ACTION b or c in Specification 3.4.5. b L | |||
S l | |||
l i | |||
\ | |||
l l | |||
l l | |||
l l | |||
l t | |||
4 FARLEY-UNIT 1 3/4 4-84 AMENDMENT NO. 97 j J | |||
J il | |||
FNP TS Conversion Enclosure 2 - Discussion of Changes to CTS Chapter 3.4 - RCS CTS 3/4.4.5 RELIEF VALVES FNP ITS 3.4.11 PRESSURIZER POWER OPERATED RELIEF VALVES (PORVs) | |||
DOC HQ SHE DISCUSSION STS. In the STS exceptions to LCO 3.0.4 are stated in Notes. This change is an administrative revision made to conform with the format and g presentation of this information in the STS. | |||
l5 Not Used. l | |||
\ l 6 L The CTS surveillance 4.4.5.1.c which requires a Channel Calibration of the PORV actuation instrumentation be performed every 18 months is deleted from the TS consistent with the STS. This surveillance serves to confirm operation of the PORV automatic actuation instrumentation. However, l automatic actuation of the PORVs is not an assumption of the applicable l design basis accidents or transients. PORV operability for the TS is l dependent on manual actuation, which continues to be verified every 18 l | |||
months by required surveillance testing (FNP ITS SR 3.4.11.2). As such, i the CTS Channel Calibration requirement is not required in the TS to confirm PORV operability and is removed. | |||
l l | |||
l a | |||
Chapter 3.4 E2-2-K February,1999 | |||
* i i | |||
d Pressurizer PORVs ! | |||
j . 13 / 3.4.11 ! | |||
I ACTIONS I | |||
i CONDITION REQUIRED ACTION COMPLETION TIME l | |||
F. (continued) F.2 Restore one block 2 hours ; | |||
l' valve to _ OPERABLE o ; | |||
statusjItf three i i l inoperable] flock valves Er | |||
-P i | |||
j F.3 Restore rem g 72 hours . | |||
; block valv s to j OPERABLE sta us. , | |||
1 G. Required Action and G.1 Be in MODE 3. 6 hours associated Completion . | |||
Time of Condition F MQ not met. | |||
G.2 Be in MODE 4. 12 hours . | |||
t SURVEILLANCE REQUIREMENTS SURVEILLANCE FREQUENCY SR 3.4.11.1 -------------------NOTE-------------------- I Not required to be met with block valve closed in accordance with the Required Action of Condition B or E. | |||
l Perform a complete cycle of nch block 92 days valve. | |||
SR 3.4.11.2 'Pe rn a complete cycle of tach PCR months (doring MODE 3 or C , | |||
gq (continued) | |||
WOG STS 3.4-25 Rev 1, 04/07/95 | |||
! y | |||
__ _._..___..-------------"------~~~~~i r l | |||
!' 2 | |||
" FNP TS Convenion i i: | |||
*' Enclosure 5 - JD from STS , | |||
i Chapter 3.4 - RCS !, | |||
t STS 3.4.11 PRESSURIZER PORVs i FNP ITS 3.4.11 PRESSURIZER PORVs a ; | |||
* JD : | |||
NUMBER JUSTIFICATION l | |||
I The STS SR 3.4.11.2 is revised consistent with the FNP CTS. The FNP CTS : | |||
surveillance 4.4.5.1.a requires that the PORVs be operated through one complete l | |||
.[d cycle during Modes 3 or 4. The CTS specifies the surveillance be performed during Modes 3 or 4 to limit the uncertainty that would be introduced by performing the surveillance at lower temperatures. As such, this CTS requirement is retained in the j i | |||
proposed FNP ITS surveillance SR 3.4.11.2. j 2 The bracketed STS SR 3.4.11.3 is replaced with the FNP specific surveillance (CTS ! | |||
4.4.5.1.b). The FNP specific surveillance verifles the operation of each PORV j using the backup nitrogen and air supplies. This FNP specific surveillance I combined with the surveillance requirement to operate the PORVs through one l complete cycle (with the normal air supply) provide adequate verification of the - ; | |||
PORV operational status and are consistent with the CTS. : | |||
3 The bracketed STS surveillance SR 3.4.11.4 is an optional surveillance provided for i PORVs that are not normally supplied by 1E power sources (see STS bases). As . | |||
the FNP PORVs are supplied by 1E power sources, this STS SR is not applicable to FNP and has been deleted from the FNP iTS. | |||
1 l | |||
I l | |||
i Chap *a 3.4 E5-1-H February,1999 j | |||
+ | |||
Y Pressurizer PORVs B 3.4.11 BASES (continued) l i l SURVEILLANCE SR 3.4.11.1 I i REQUIREMENTS l Block valve cycling verifies that the valve (s) can be closed ! | |||
if needed. The basis for the Frequency of 92 days is the ; | |||
, ASME Code, Section XI (Ref. 3). If the block valve is ! | |||
; closed to isolate a PORV that is capable of being manually j cycled, the OPERABILITY of the block valve is of importance, because opening the block valve is necessary to permit the ! | |||
l PORV to be used for manual control of reactor pressure. If i the block valve is closed to isolate an otherwise inoperable | |||
{ PORV, the maximum Completion Time to restore the PORV and | |||
: open the block valve is 72 hours, which is well within the | |||
! allowable limits (25%) to extend the block valve Frequency 1 of 92 days. Furthermore, these test requirements would be completed by the reopening'of a recently closed block valve upon restoration of the PORV to OPERABLE status (i.e., | |||
completion of the Required Actions fulfills the SR). | |||
[g 1 | |||
j The Note modifies this SR by stating that it is not required j to be met with the block valve closed, in accordance with the Required Action of this LCO. | |||
1 *%e 9eRV4 en S h h 465 M W3 SR 3.4.11.2 | |||
#EI 3 # "g .m MODE 3 | |||
*d SR 3.4.11.2 requires a complete cycle of each PORV. | |||
M 6.M bO Operating a PORV j$ rough one complete cycle ensures that the 4 hes closeA ik ,PORV can be manua Ilytactuated for mitigation of an SGTR. | |||
gp .ko hNf -'The Frequency of bl8d months is based on a typical refueling | |||
. cycle and industry accepted practice 4- | |||
/, tsdi$ ea Toity0mN<* M H ' | |||
* SRIMERTD 3.4.11.3 F | |||
f ok kserM sfW*) Operat W inoid air control valves a valves OmPF 6 g-( | |||
on the air accumu a res control system ! | |||
{M f Mg W"M" actuates aroperly whe | |||
[18] montis i on a typical re The Frequency of cycle and th I | |||
9vM 4 | |||
r requ the other Surve111ances used to trate ! | |||
OPERABILITY Camddiims e - | |||
% % i SR 3.5.11.0 _ | |||
This Surveillance is no with permanent | |||
_ IE power supp11 e valves. | |||
(continued) | |||
WOG STS B 3.4-56 Rev 1, 04/07/95 | |||
f i | |||
Associated Package Changes for RAI- 16 9 | |||
N 4 | |||
a 4 | |||
4 l | |||
l i | |||
I | |||
. __ m- _ . . . . . .. ,_. _ . . . , _ _ _ _ _ _ _ _ _ _ __ _ _ _ _ _ ,. _ _ _ . _ _ ~ . . _ . . _ . . _ _ _ _ | |||
, Dnet PTLR chnje Pqe ! | |||
.' (p Q l I | |||
= , . . | |||
oy Syd | |||
%Temperdure witivuurmmuin ap,ey . in t | |||
- V REACTCR COOLANT Sy3 TEM g O ! | |||
E VERPRESSURE PROTECTICN SYSTEMS | |||
,g /A M D/7)(/ 3 l LIMITING CONDITIONS TCR OPE N /43 b AL'f _ | |||
j | |||
.4.10.3 f the fo'11owing es se pro action systems sna11 he OPERAsLE: I | |||
. 2 : | |||
: a. Two MR relief valves with I A lif t setting of less than or equal to 450 psig, and $R 3,Y, C,3 | |||
: 2. The associated MR relief valve isolaeion valves openg or ZA/5ER.T R l | |||
) b. The Reactor Coolant system (RCs) depressurized with an PCS vent of g greater than or equal to 2.85 square inches. . | |||
APPLICABILITY: When the temperature of one or more of the RCs cold legs is less than er equal to 325'r, except when the reactor vessel head is l - | |||
g removed. | |||
[4g Actron: | |||
8 | |||
% A | |||
, ith one MR elief valve inoperable,r---- ~ | |||
WesMBLE status )tithin 24 hours or perform the following: | |||
/ | |||
,a-g m-m valve C4 - | |||
INSERT.S NEld Carddico$ | |||
4, $4 Establish the following requiremerits: | |||
gg, p D*k Redu'ce pressurizer level to less than or equal to 30 percent.(cold calibrated), and i | |||
M Assign a dedicated operator for RCS pressure monitoring , | |||
and control, and i | |||
. h.3 Restore the inoperable valve to OPERABLE status within 7 ; | |||
days, ors , | |||
l E.1 [ copressurire and vent the Res through a greater than or equal IN6ERTI : | |||
to 2.85 square inch vent within the next 8 hours. , M , | |||
With both MR relief valves inoperablehthin 8 hours either: | |||
c @o r & + b e | |||
- For E ConO r E. kl* *** ** ** * | |||
* 1*** * *** "A **li* f **1ve to oPERAnLE s tatus, or) | |||
E.17 c.pr.ssuris. and Ant ef.~.Res through a gra'st. chan or equal to 2.85 square inch vent. | |||
* &( | |||
s f c. In the event a MR relief valve or a RCs vent is used to mitigate a RCs pressure transient, a special Report shall be prepared and M if q submitted to the comunission pursuant to specification 6.9.2' within 30 , | |||
days. The report 'shall describe .the circumstances initiating the g h,g transient, the effect of the MR rslief valves er vent on the transient and any corrective action necessary to prevent recurrence. | |||
: h. The provisions of specification 3.0.4 are not applicable] , | |||
FARLEY-UNIT 1 3/4 (.32 AMENDMENT NO. | |||
__p spp&n.8/,p Noh.7 .y, . ... | |||
a | |||
l FNP TS Conversion i | |||
', Enclosure 2 - Discussion of Changes to CTS Chapter 3.4 - RCS CTS 3/4.4.10.3 OVERPRESSURE PROTECTION SYSTEMS FNP ITS 3.4.12 LOW TEMPERATURE OVERPRESSURE PROTECTION SYSTEM DOC NO SHE DISCUSSION requirement to isolate accumulators was discussed previously. The addition of this note provides more specific guidance on the application of the requirement to isolate accumulators. As such, this change is also I considered administrative made to support the addition of the accumulator isolation requirement discussed previously. | |||
Note 3 simply relocates the existing CTS exception to Specification 3.0.4 into the applicability consistent with the STS. CTS 3.4.10.3 action statement "d" currently contains the exception to specification 3.0.4. The i change to move this exception into an applicability note is consistent with the fonnat and presentation of this type ofinformation in the STS. As such, this change is considered administrative. | |||
4 M CTS 3/4.4.10.3 is revised by the addition of new Actions Conditions consistent with the STS. New Conditions A, B, and C are added. The proposed Conditions and Required Actions address the new LCO requirements for only one charging pump operable and for the accumulators to be isolated. The proposed Conditions provide reasonable actions and allowances for completing them if the new LCO requirements are not met. | |||
The new actions provide adequate remedial measures or remove the plant from the Mode of Applicability. As such the new Conditions are applicable and appropriate to FNP. However, the addition of these Conditions and actions in the FNP TS represent new requirements not previously addressed by the TS. As such, the addition of these Conditions and Required Actions is considered a more restrictive change. | |||
4a A The CTS action statement "a"is revised consistent with the STS by the deletion of the requirement to restore the inoperable valve to OPERABLE status. In the STS, restoration of a component / system to OPERABLE status is always an unstated option. Ifit is accomplished prior to the completion of the required actions, the LCO may be exited. Therefore, it is unnecessary to maintain CTS 3/4.4.10.3 action a. as it is always included by implication. There are three completion times associated with Condition D l | |||
j | |||
[gg in the FNP ITS. Required actions D.1 and D.2 have 24-hour completion times and Required Action D.3 has a completion time of 7 days, consistent i with the completion times of CTS Actions a.l.i, a.l.ii, and a.l.iii. If the inoperable valve is not restored to OPERABLE status within 24 hours, CTS actions a.l.i, a.l.ii, and a.l.iii would be applicable. As 24 hours are l i | |||
Chapter 3.4 E2-2-S February,1999 l | |||
FNP TS Conversion | |||
* Enclosure 2 - Discussion of Changes to CTS Chapter 3.4 - RCS CTS 3/4.4.10.3 OVERPRESSURE PROTECTION SYSTEMS 1 1 | |||
FNP ITS 3.4.12 LOW TEMPERATURE OVERPRESSURE PROTECTION SYSTEM ! | |||
DOC l HQ SEE DISCUSSION allowed in the CTS to restore the valve to OPERABLE status in the CTS, the completion time of required actions D.1 and D.2 (CTS actions a.l.i and | |||
) | |||
a.l.ii) is 24 hours. Required action D.3 has a completion time of 7 days l consistent with STS required action E.1 and CTS action a.l.iii. As these | |||
[A changes are made to revise the CTS to conform with the format and presentation of such information in the STS, and does not introduce a l | |||
technical change, it is considered administrative. | |||
5 M The CTS action statement "b"is revised consistent with the STS. The additional plant conditions of other Required Actions or Completion Times not met and if the LTOP system is inoperable for any reason other than addressed by the other Actions Conditions are included in this CTS action statement. The inclusion of these additional plant conditions provide a comprehensive set of TS Conditions to address not meeting the LTOP LCO. The associated required action to depressurize the RCS and provide a vent path ensures RCS overpressure protection and places the plant in a safe condition. As such, the addition of these plant conditions to CTS Action statement "b"is applicable to FNP. However, as these conditions were not previously addressed in the CTS, this change is considered more restrictive. | |||
6 A The CTS 3.4.10.3 action statement "c"is revised consistent with the format of the STS. The CTS action requires a special report be made in the event an RHR relief valve is used to mitigate an RCS pressure transient. In the STS, the special reports section (CTS 6.9.2) does not exist. As such, it is proposed to move this reporting requirement to the Monthly Operating Report (STS 5.6.4). The STS monthly operating report is required every 30 1 days and contains related information regarding challenges to pressurizer ; | |||
relief and safety valves. Therefore, the CTS reporting requirement for the RHR relief valves will be adequately addressed by inclusion in the monthly l operating report where other safety and relief valve reporting requirements reside. As this change is not intended to introduce a technical change and is made to confonn with the format and presentation of this infonnation in the STS, it is considered an admmistrative change. | |||
1 | |||
! 7 A The CTS specific action statement "d" is moved into the notes to the l applicability consistent with the presentation of similar information in the i STS. The CTS action statement contains a plant specific (not in STS) l l exception to Specification 3.0.4. As this change does not introduce a l l | |||
Chapter 3.4 E2-3-S February,1999 | |||
. .-- - .- .. - .- - - - - -.. - .-.- - - - - - . - .~ - - | |||
. I i | |||
. i | |||
- FNP TS Conversion j Enclosure 5 - JD from STS i Chapter 3.4 - RCS l J | |||
STS 3.4.12 LOW TEMPERATURE OVERPRESSURE PROTECTION (LTOP) SYSTEM FNP ITS 3.4.12 LOW TEMPERATURE OVERPRESSURE PROTECTION (LTOP) SYSTEM JD ) | |||
NUMBER JUSTIFICATION l must be limited. The FNP design consists of only two sets of ECCS pumps, the ! | |||
RHR pumps and the charging pumps. The only high pressure injection pumps j being the charging pumps. As such, only the injection capability of the charging i | |||
. pumps is required to be limited for low temperature overpressure protection at FNP. | |||
l Therefore, the STS conditions are revised to conform with the FNP design. This ' | |||
change also introduces editorial changes to the letter designations used to identify the Actions Conditions that follow this STS Condition. | |||
5 The STS 3.4.12 Conditions E and F are revised to be consistent with the FNP CTS. | |||
The FNP CTS 3/4.4.10.3, Overpressure Protection, action statement "a" provides y additional remedial measures in the event a single required RHR valve is inoperable (proposed Required Actions D.1 and D.2) and maintains a 7 day restoration time in Modes 5 and 6 as well as Mode 4. Therefore, the words "in MODE 4" have been ; | |||
deleted from STS Condition E (ITS Condition D). The FNP CTS 3/4.4.10.3 actions { | |||
contained in action statement "a" provide additional assurance that an RCS pressure | |||
] | |||
transient will be rapidly identified and limited. Therefore, the STS Condition E (proposed FNP ITS Condition D) is revised by the addition of FNP specific actions consistent with the FNP CTS 3/4.4.10.3 action statement "a" and the STS Condition F with a 24 hour Completion Time is not applicable to FNP and is ; | |||
deleted. This change also introduces editorial changes to the letter designation used ] | |||
to identify the Actions Condition that follows this STS Condition. | |||
6 The STS 3.4.12 surveillances SR 3.4.12.1 and SR 3.4.12.2 are revised to be consistent with the FNP design and CTS requirements. The STS 3.4.12 surveillances are written to accommodate all types of plants including those plants | |||
- with 3 sets of ECCS pumps (RHR, Safety Injection, and Charging). In some plants the injection capability of both high pressure pumps (SI and charging) must be limited. The FNP design consists of only two sets of ECCS pumps, the RHR pumps and the charging pumps. The only high pressure injection pumps being the charging pumps. As such, only the injection capability of the charging pumps is | |||
. required to be limited for low temperature overpressure protection at FNP. | |||
Therefore, the proposed change to the STS (deletion of STS SR 3.4.12.1 and retention of STS SR 3.4.12.2) is consistent with the FNP design and CTS requirements for the charging pumps. | |||
l 7 The STS 3.4.12 surveillance SR 3.4.12.4 (FNP ITS SR 3.4.12.3) is revised to be consistent with the CTS. Editorial changes are made to the surveillance statement , | |||
to more closely match the CTS description. In addition, the frequency of the i surveillance is also revised from 12 hours to 72 hours to be consistent with the i i | |||
. Chapter 3.4 E5 21 February,1999 | |||
Associated Package Changes for RAI- 18 l | |||
4 l | |||
i I | |||
l t | |||
.? | |||
s | |||
[Or M Ifju'If reactor cootaNT syg7gg 47gggg g yg suRVE1LLANCE r$EQy!REMENTS | |||
/ | |||
(4.4.10.31] Each RHR relief valve shall be demonstrated CPE LE by: gg l MF.0E*J Verifyinc)the RHR relief valve isolation valve 6701a, 870lb, 8702a) | |||
SR3.4.12 3 8 E d 8702bilare ooen at lamme anee eer ?? heuen h n th RHR relie T (va4ve fis bein4 used f or o/erpresh= ~- -~/{ | |||
. Testing in pu to e/f / eat [on MO:D [O 8 * * ' | |||
SR $,Q,l'[,6 Verification of the RHR relief valve setpoint, of at least one RHR relief valve, at least once per 18 months on a pcpiryg tps , | |||
S E I.Nell i Q .s.10.3.23 The Res vent shall be verified to be open at least once per 12 hours | |||
* when the vent is being used for overpressure protection. | |||
$TA6669,6 ! | |||
A rasr u sis CAck pmule or /d [50 g 3,4,/2,2 Veri l | |||
a ha" | |||
, , - seg ig m | |||
---) sa s.411.1 see mnkop of f llo owi g p9e (crs4.1.2.3.2.. ) | |||
l l | |||
ll 8 | |||
I l | |||
? l 1 | |||
l | |||
[ | |||
* Except when the vent pathway is provided with a valve which is locked, SR 3.4.ll Y sealed, or otherwise secured in the open position, then verify these N' | |||
valves open at least once per 31 days. l r | |||
FARLEY-UNIT 1 jf4 4 33 AMENDMENT NO. 26 | |||
FNP TS Conversion | |||
. Enclosure 2 - Discussion of Changes to CTS Chapter 3.4 - RCS CTS 3/4.4.10.3 OVERPRESSURE PROTECTION SYSTEMS FNP ITS 3.4.12 LOW TEMPERATURE OVERPRESSURE PROTECTION SYSTEM DOC t HQ SHE DISCUSSION and fonnat of the STS. | |||
10a M CTS 3/4.4.10.3 is revised by the addition of a new surveillance, SR 3.4.12.2, related to new Actions Conditions B and C consistent with the STS. The proposed surveillance addresses the new LCO requirement for the accumulators to be isolated. The proposed surveillance provides M reasonable requirements for ensuring compliance with the new LCO. As such, the new surveillance is applicable and appropriate to FNP. However, l the addition of this surveillance in the FNP TS represents a new l requirement not previously addressed by the TS. As such, the addition of l this surveillance is considered a more restrictive change. | |||
I1 A The CTS surveillance 4.1.2.3.2 from the Reactivity Control Systems I | |||
Chapter is moved into the RCS over pressure protection LCO consistent with the STS as SR 3.4.12.1. The CTS 4.1.2.3.2 surveillance addresses the requirement that only one charging pump may be capable ofinjecting into the RCS when one or more cold leg temperatures is less than or equal to | |||
~1 80 *F. This requirement is related to low temperature RCS pressure control and therefore belongs with the LTOP system TS. The CTS surveillance is also revised to change inoperable to incapable ofinjecting into the RCS consistent with the STS. As the CTS requirement to render the pump inoperable was intended to prevent injection into the RCS and the possible overpressure condition that injection might cause, the STS term of | |||
" rendering the pump incapable ofinjecting into the RCS" effectively accomplishes the same thing as the CTS (inoperable) but defines the 3 requirement more precisely. In addition, this CTS surveillance is also ! | |||
revised to remove the reference to the stated Mode of Applicability (except when the reactor vessel head is removed) consistent with the STS. As the proposed FNP ITS 3.4.12 applicability excludes this specific condition (head removed) it is not necessary to repeat the Mode of applicability in the surveillance requirements. As such, the movement of this surveillance to the RCS chapter and revisions described above do not introduce technical changes and are considered administrative in nature. | |||
12 LA The CTS surveillance 4.1.2.3.2 (from the Reactivity Control Systems Chapter) is further revised, consistent with the STS, to remove the specific means by which a charging pump is rendered incapable ofinjecting into the RCS. The CTS surveillance specifies that the motor circuit breakers are Chapter 3.4 E2-5-S February,1999 | |||
l I | |||
i | |||
* 1 | |||
. 1 i | |||
i l | |||
l i | |||
I 1 | |||
l 1 | |||
l l | |||
Associated Package Changes for RAI- 22 , | |||
1 1 | |||
l I | |||
i l | |||
l l | |||
l 1 | |||
I 1 | |||
I I | |||
I I | |||
I 1 | |||
! I l | |||
l l | |||
t | |||
1 FNP TS Conversion Enclosure 2 - Discussion of Changes to CTS , | |||
Chapter 3.4 - RCS CTS 3/4.4.7.2 OPERATIONAL LEAKAGE UNIT I AND 2 i t | |||
FNP ITS 3.4.13 RCS OPERATIONAL LEAKAGE FNP ITS 3.4.14 RCS PRESSURE ISOLATION VALVE LEAKAGE l FNP ITS 3.5.5 ECCS SEAL INJECTION FLOW ; | |||
DOC NQ SEE DISCUSSION 1 A The CTS 3/4.4.7.2.e LCO requirement for Controlled Leakage is revised consistent with the STS. The requirement for Controlled Leakage is moved into the new STS LCO 3.5.5 Seal Injection Flow in the ECCS section of the TS. As any changes to this requirement are addressed in the FNP STS - | |||
conversion documentation associated with section 3.5 of the TS, the i movement out of this CTS LCO is considered an administrative change made to conform with the presentation and format of the STS. , | |||
2 A The CTS 3/4.4.7.2.f LCO requirement for pressure isolation valve (PIV) l leakage is revised consistent with the STS. This LCO requirement is moved into a separate LCO (3.4.14) for PIV leakage. The requirement is simplified consistent with the format and presentation of the STS. The ; | |||
reference to Table 3.4-1 is removed from the LCO and the STS phrase i "within limits"is substituted. The reference to the required RCS pressure is also removed from the LCO. The leakage limits and required RCS pressure - | |||
are stated in the STS surveillance SR 3.4.14.1. CTS Tabic 3.4-1 lists Reactor Coolant System pressure isolation valves with nominal valve sizes ranging from 6 inches to 12 inches. Two limits for allowable leakage criteria are listed in CTS 4.4.7.2.2; (1) 0.5 gpm per inch of nominal valve size and, (2) an upper limit of the maximum allowable leakage in Table 3.4- | |||
, p- 1. For example, using only the first criteria, a six-inch valve would have a limit of 3 gpm, a 10-inch valve would have a limit of 5 gpm, and a 12-inch valve would have a limit of 6 gpm. The valves listed in Table 3.4-1 with a maximum allowable leakage of 3 gpm are 6-inch valves, consistent with the limit of 0.5 gpm per inch of nominal valve size. The Table has a maximum limit of 5 gpm for all larger valves (10 and 12 inch). In each case, the more i i | |||
restrictive of criteria 1 or 2 are used for maximum allowable leakage. | |||
Therefore, the ITS SR 3.4.14.1 requirement to " verify leakage from each | |||
: j. RCS PIV is equivalent to s 0.5 gpm per nominal inch of valve size up to a j | |||
maximum of 5 gpm at an RCS pressure 2 2215 psig and s 2255 psig"is | |||
! equivalent to the CTS requirements for all valves listed in Table 3.4-1. As , | |||
i ~ this change reorganizes the LCO statement to conform with the STS and l t | |||
does not introduce a technical change, it is considered administrative. | |||
Chapter 3.4 E2-1-N February,1999 | |||
.= - -- . . | |||
Associated Package Changes for RAI - 24 | |||
UOIT1 NOTE: THE REQUIREMENTS OF THE CURRENT | |||
. TS FOR OPERATIONAL LEAKAGE ARE 7 | |||
J.'i react 0o COOLANT SYSTEM h DMDED INTO THREE TS IN THE STS. | |||
OPERATIONAL LEAKAGE (LCO 3.4.13). | |||
~,Y, t.7 P.C 3 OPERATIONAL LEAKAGE PRESSURE ISOLATION VALVE LEAKAGE (LCO 3.4.14), AND SEAL INJECTION LIMITING CONDITION FOR OPERATION FLOW (LCO 3.5.5). | |||
........y............................................................... - | |||
3' ' O Q.4.7.2) Reactor Coolant Systes leakage shall be 11ef ted to: | |||
: a. No PRESSURE B0UNDARY LEAKAGE, | |||
: b. 1 GPM UNIDENTIFIED LEAKAGE, I | |||
C8+#- | |||
420 gallons per day total primary-to-secondary leakage through all steam generators and 140 gallons per day through any one steam generator, g C. | |||
kA 10 GPN IDENTIFIED LEAKAGE from the Reactor Coolant System, and Lco 35.{g | |||
= | |||
: e. 31 GPM CONTROLLED LEAKAGE at a Reactor Coolant System pressure of 2235 s 20 psig. Y N' .N*I f. The maximum allowable leakage of any Reactor conlant tvtta= F t.to3.ll.1Y INSEf.T # | |||
b i ted/in u piy hatapressureof2235 Pressure Isolation Yalve shall be M spec /If 7/ble E J.4-M t.ca 3,4. lY AGA0N zopsig7 g NOTES .PPL IC ABIL ITY ? | |||
MODES 1, 2, 3 and 4 (r-{s5EitT G 1.cc J4/Yoyojobcebthh 4 ACTION | |||
* d$rn With any PRESSURE 80VNDARY LEAKAGE, be in at least HOT p g hng STAN08Y following 30within 4 hours and in COLD SHUTDOWN within the hours. | |||
2 With any Reactor Coolant Systes leakage greater than any on | |||
'A INstRTI QanttT8 6 1 A of the above limits, excluding PRESSURE 800NDARY LEAKAGE, l. ' | |||
LL8344 g reduce the leakage rate to within limits within 4 hours or be g in at least NOT STAN08Y within the next 6 hours and OlfloN COLO g SHUTDOWN.within the following 30 hours. | |||
C With any# eactor R Coolant System Pressure Isolation Va ve | |||
--> TRM b ZNSfCT7 5 Loo 3 4.84 CondMorg 4- ''F 1.akage greater than the Itaitgpecmea in 1 bie 3.4-0 Mk'.k 8% ' | |||
isola e the high pressure portion or the arrectea system from th i | |||
ou pressure portion within 4 hours by use ofydt least closed manual or deactivated automaticivalvgf.her be in g M LCo3.4.,9 a Coreho65% SHUTDOWN within the following 30 hours.least -v NOT STAN08Y with z | |||
6 SURVEILLANCE IREMENTS % r ucos.ex '\ | |||
.................................l..............Mnemoric. | |||
L 4.4.T.2.1 Reactor Coolant System leakages shall be demonstrated to be 7 | |||
within each of the above limits by: @> | |||
I-Monitoring the containment atmosphere particul - | |||
9 radioactivity monitor at least once per 12 hours TAT-2.f b. | |||
Monitoring the. containment air cooler condensate level system or containment atmosphire^ gaseous radioactivity monitor' at least once per 12 hours. ' | |||
' ~ " ' ~ ' | |||
FARLEY . UNIT 1 3/4 4-17 AMEN 0 MENT No. IJ, ga u n 'l T 1 - | |||
FNP TS Conversion Enclosure 2 - Discussion of Changes to CTS Chapter 3.4 - RCS CTS 3/4.4 71 OPERATIONAL LEAKAGE UNIT 1 AND 2 FNP ITS 3.4.13 RCS OPERATIONAL LEAKAGE FNP ITS 3.4.I'4 RCS PRESSURE ISOLATION VALVE LEAKAGE FNP ITS 3.5.5 ECCS SEAL INJECTION FLOW DOC NQ SHE DISCUSSION verified to meet the LCO leakage limits. | |||
8 lM A new action is added to the CTS 3/4.4.7.2 actions for an RCS PIV that does not meet the leakage limits based on the actions of the STS. Proposed Condition C of the new PIV leakage LCO 3.4.14 applies to an inoperable RHR valve autoclosure interlock and has been added to the PIV TS to explicitly address this type of PIV inoperability and provide appropriate actions. The actions and completion times proposed for this new condition are similar to the existing actions for an inoperable PIV except that only one isolation valve is required to be closed and maintained closed under administrative control. This difference is required due to the location of the M breakers for the associated valves and dose that plant personnel would receive when restoring power to the valves in the event of a small break LOCA. As the action addresses an inope.rable interlock and not valve leakage, and the STS actions Notes require the applicable Conditions and actions of any affected system made inoperable by the inoperable PIV to be entered, the proposed action for an inoperable autoclosure interlock is acceptable. As the addition of this new Condition in the FNP TS represents a new requirement not previously addressed by the TS, the addition of this Condition is considered a more restrictive change. | |||
9 L The CTS 4.4.7.2.1.a and .b that require the leak detection particulate and gaseous radiation monitors and containment air cooler condensate level to be monitored every 12 hours are deleted consistent with the STS. The particulate and gaseous radioactivity monitors will continue to be checked 1 every 12 hours by the Channel Check surveillance requirement SR 3.4.15.1 in the RCS Leakage Detection TS LCO 3.4.15. The containment air cooler condensate level monitor receives a Channel Calibration every 18 months per SR 3.4.15.4 in the RCS Leakage Detection TS LCO 3.4.15 and provides an alarm in the control room to alert the operators to an increase in condensate level. The 18 month channel calibration requisneut is adequate for instrumentation used for indication and monitoring. As the radioactivity monitors provide a more immediate response to RCS leakage and will continue to be monitored every 12 hours, and the fact that an Chapter 3.4 E2-4-N February,1999 | |||
Associated Package Changes for RAI- 25 l | |||
l | |||
) | |||
i 4 | |||
- 1 CHAPTER 3.4 . | |||
j INSERT L NOTES TO CTS 4.4.7.2.1.d SURVEILLANCE AND FREQUENCY l NEW RCS OPERATIONAL LEAKAGE TS LCO 3.4.13 SR 3.4.13.1 l: | |||
i Surveillance NOTE - ----. . . j Not required to be performed in Mode 3 or 4 until 12 hours of steady state operation. ! | |||
Frequency j | |||
__ NOTE -- ----- - - - - - - - - i Only required to be performed during steady state operation. | |||
I t | |||
INSERT M NOTES TO CTS 4.4.7.2.2 SURVEILLANCE NEW RCS PIV LEAKAGE TS I LCO 3.4.14 SR 3.4.14.1 ! | |||
NOTES--.-- -- -------- | |||
l | |||
: 1. Not required to be performed in Modes 3 and 4. | |||
: 2. Not required to be performed on the RCS PIVs located in the RHR flow path when in the , | |||
shutdown cooling mode ofoperation. | |||
: 3. RCS PIVs actuated during the performance of this Surveillance are not required to be tested | |||
, more than once if a repetitive testing loop cannot be avoided. | |||
l ___ .____._ .. . | |||
%E- 15 i | |||
! INSERT N NOT USED | |||
\ | |||
Cbpter 3.4 Insert Pcge l | |||
l | |||
1 o | |||
FNP TS Conversion c Enclosure 2 - Discussion of Changes to CTS Chapter 3.4 - RCS CTS 3/4.4.7.2 OPERATIONAL LEAKAGE UNIT 1 AND 2 FNP ITS 3.4.13 RCS OPERATIONAL LEAKAGE FNP ITS 3.4.14 RCS PRESSURE ISOLATION VALVE LEAKAGE FNP ITS 3.5.5 ECCS SEAL INJECTION FLOW DOC NO SJLE DISCUSSION water inventory balance is the definitive method to determine RCS leakage and accounts for the reactor head flange leakoff, the deletion of this separate surveillance does not significantly impact the operators ability to detect RCS leakage. | |||
13 A The CTS 4.4.7.2.2 surveillance for the leakage testing of RCS Pressure l | |||
Isolation Valves (PIV) is modified by 3 notes consistent with the STS and the CTS. Note I corresponds to CTS 4.4.7.2.2.d and allows entry into y Modes 3 and 4 to perform this SR. Since in the STS there are no exceptions to SR 3.0.4 CTS 4.4.7.2.2.d is revised consistent with the STS. | |||
I Notes 2 and 3 are consistent with the STS and provide detailed guidance and clarification for performing PIV leakage tests that is consistent with the operational requirements of the plant and the need to provide a reliable means of decay heat removal. Note 2 which provides an exception for PIVs in the RHR flow path during the shutdown cooling mode of operation is also consistent with the | |||
* footnote to CTS Table 3.4-1 which serves as an exception to the PIV leak test requirements (4.4.7.2.2.c) following actuation or flow through the valves for valves used in the RHR flow path. As such, the addition of these notes are considered an administrative change consistent with the CTS or providing clarifications consistent with the STS. | |||
14 LA CTS Table 3.4-1 containing a list of the RCS PIVs is removed from the CTS consistent with the STS. The actualleakage limits are retained within the proposed ITS surveillance SR 3.4.14.1 :onsistent with the STS. The removal of equipment / component lists from the TS is consistent with previous generic guidance from the NRC and consistent with the philosophy of the STS, that the TS contain only the essential requirements for safe operation of the plant. As such, the CTS Table will be moved into the Technical Requirements Manual (TRM). Placement of this information in the TRM is acceptable based on the level of change control provided by the 10 CFR 50.59 process that will be applied to the TRM. | |||
l 15 LA CTS 4.4.7.2.2 is revised to delete references to the requirements of f 1 Specification 4.0.5 consistent with the STS. In the STS,4.0.5 does not Chapter 3.4 E7.-6-N Febmary,1999 | |||
Associated Package Changes for RAI- 27 l | |||
1 1 | |||
l i | |||
l l | |||
i | |||
CHAPTER 3.4 .- | |||
#/ l INSERT J - | |||
TO CTS 3.4.7.2 ACTION C . j NEW PRESSURE ISOLATION VALVE TS 1 LCO 3.4.14 REQUIRED ACTION A.2 j i | |||
AND A.2 Isolate the high pressure portion of the affected system from the low pressure portion by ! | |||
use of a second closed manual, deactivated automatic, or check valve. In 72 hours. ! | |||
i INSERT K i TO CTS 3.4.7.2 ACTIONS ! | |||
NEW PRESSURE ISOLATION VALVE TS . | |||
LCO 3.4.14 CONDITION C ! | |||
CONDITION REQUIRED ACTION COMPLETION TIME C.' RHR System autoclosure C.1 Place the affected valve (s)in 4 hours ! | |||
interlock function the closed position and inoperable, | |||
{ | |||
maintaiu closed under ' | |||
administrative control. , | |||
PAC" 27 l | |||
1 1 | |||
Chapter 3.4 Insert Page 1 J | |||
l l | |||
FNP TS Conversion l | |||
, Enclosure 2 - Discussion of Changes to CTS I Chapter 3.4 - RCS CTS 3/4.4.7.2 OPERATIONAL LEAKAGE UNIT 1 AND 2 FNP ITS 3.4.13 RCS OPERATIONAL LEAKAGE FNP ITS 3.4.14 RCS PRESSURE ISOLATION VALVE LEAKAGE FNP ITS 3.5.5 ECCS SEAL INJECTION FLOW DOC NO SHE DISCUSSION as in Mode 2 (defined as STARTUP in CTS Table 1.1). As such, these changes are considered administrative in nature. | |||
19 LA The CTS surveillance 4.4.7.2.2.b requires post maintenance testing on RCS PlVs and is removed from the TS consistent with the STS. In the STS, post maintenance testing is not explicitly required. However, the TS definition of operability and the general requirements of TS that LCOs must ' | |||
be met or actions taken, provide assurance that upon returning equipment to service appropriate testing is required to declare that equipment operable and any applicable LCO met. As such, the post maintenance testing requirement for the RCS PlVs is moved to the TRM. Placement of this information in the TRM is acceptable based on the level of change control provided by the 10 CFR 50.59 process that will be applied to the TRM and considering the basic TS requirements for equipment operability described above. | |||
20 A The CTS surveillance 4.4.7.2.2.c which requires RCS PIV leakage to be verified after valve actuation is revised to be consistent with the STS. The l CTS requirement is a frequency and has been moved into the frequency section of the STS SR 3.4.14.1. As these changes only reorganize the l i | |||
requirements of this TS they are considered administrative. | |||
21 A A surveillance (SR 3.4.14.2) is added to the TS requirements for RCS PIVs consistent with the STS. This surveillance verifies the RHR system autoclosure interlock functions to close the RHR/RCS isolation valves on high RCS pressure. This surveillance requirement corresponds to the CTS surveillance 4.5.2.d.l. As this surveillance involves RCS PIVs, the STS places this requirement in the RCS PIV LCO. Since this change only l reorganizes the TS requirements to conform with the presentation and ) | |||
: format of the STS it is considered administrative. ! | |||
l 21a M The CTS surveillance 4.4.7.2.2 is revised consistent with the STS. A new surveillance (ITS SR 3.4.14.3) is added to the TS requirements for RCS gd PIVs consistent with the STS. This surveillance verifies the RHR system Chapter 3.4 E2-9-N February,1999 l | |||
l | |||
FNP TS Conversion Enclosure 2 - Discussion of Changes to CTS Chapter 3.4 - RCS CTS 3/4.4.7.2 OPERATIONAL LEAKAGE UNIT 1 AND 2 FNP ITS 3.4.13 RCS OPERATIONAL LEAKAGE FNP ITS 3.4.14 RCS PRESSURE ISOLATION VALVE LEAKAGE FNP ITS 3.5.5 ECCS SEAL INJECTION FLOW DOC NO SHE DISCUSSION open permissive interlock functions to prevent the RHR/RCS isolation valves from opening above a certain RCS pressure. As the addition of this | |||
/L1 new surveillance in the FNP TS represents a new requirement not previously addressed by the TS, the addition of this surveillance is considered a more restrictive change. | |||
22 A A surveillance (SR 3.4.13.2) is added to the TS requirements for Operational Leakage consistent with the STS. This surveillance requires compliance with the Steam Generator Tube Surveillance Program. The CTS LCO for steam generators was removed from TS (discussed previously) and the tube inspection requirements moved intact to an administrative controls program in the TS. As such, the new surveillance in the Operational Leakage TS ensures compliance with the administrative controls program in the same manner as the previous LCO for steam generators ensured compliance with its associated surveillance requirements. This change reorganizes the CTS requirements to conform with the presentation and format of the STS and is considered administrative. | |||
23 A CTS 4.4.7.2.2.d takes exception to the requirements of Specification 4.0.4 for the purposes of testing RCS PIVs. Since the STS does not provide for exceptions to SR 3.0.4 this requirement is expressed as a note in the corresponding STS surveillance SR 3.4.14.1 which simply states the surveillance is not required in Modes 3 and 4. As the STS note provides an allowance for testing in Modes 3 and 4, it effectively accomplishes the same thing as the CTS exception to the provisions of 4.0.4 was intended to do. Therefore, this change is made only to conform with the presentation and format of this information in the STS and is considered administrative. | |||
24 A The CTS | |||
* footnote to Table 3.4-1 is deleted consistent with the STS. The footnote is used to modify CTS surveillance 4.4.7.2.2.c and identifies valves for which the surveillance is applicable (valves which are not in the RHR flow path). CTS surveillance 4.4.7.2.2.c requires leak testing RCS Pressure Isolation Valves (PIVs) following actuation or flow through the 1 | |||
Chapter 3.4 E2-10-N February,1999 | |||
_ _._____m . | |||
', 196 4N ACTIONS CONDITION REQUIRED ACTION COMPLETION TIME A. (continued) A.1 Isolate the high 4 hours pressure portion of l the affected system | |||
' from the low pressure portion by use of one closed manual, deactivated automatic, or check ; | |||
valve. | |||
n - , | |||
.2 Isolate the high 72 hours (f (p l pressure portion of the affected system from the low pressure portion by b ^'8 M o $ cded los d ma a ' | |||
vehe(s)in 4ht deactivated automatic, or check I | |||
eg, g,4,g g j MdnbM c\osed L j l unAte oAmiksb%c | |||
/ l A Restore CS PIV to 72 hour within imits. | |||
l B. Required Action and B.1 Be in MODE 3. 6 hours ) | |||
associated Completion ! | |||
Time for Condition A ANQ not met. | |||
Be in MODE 5. 36 hours s' open pewssw)B.2 Y -=w /- | |||
- b - | |||
\ | |||
j | |||
. RHR System autoclosure C.1 }_solate the affected' 4 hours l interlock function penetration by use of i | |||
inoperable. one closed manual or | |||
/deactivatedautomatig I | |||
valve. f e | |||
l i | |||
l l WOG STS 3.4-36 Rev 1, 04/07/95 L _ | |||
l RCS PIV Leakage gy 3.4.14 SURVEILLANCE REQUIREMENTS SURVEILLANCE FREQUENCY | |||
; SR 3.4.14.1 (continued) 5 in 2 noor,/ ! | |||
l h lowing valve actuation due l | |||
to automatic or I manual action or flow through T/p the valve SR 3.4.14. [---------------e---N O TE-------- --- ----- | |||
] | |||
( J ot reauired to be met when the RSystem Gutnelosure interlock is disable in | |||
$5 _$$$_5 __ __ ' | |||
* N ____ ----- | |||
y' 0 | |||
,PWesem(sive. | |||
Verify RHR System [utoclosurdrinterlock 18 months prevents the valves from being opened with a simu te r actual RCS pressure l signal k 425 sig. . | |||
_ 2*15'e s f u 6 f is -[ | |||
~~v | |||
@ SR 3.4.14. | |||
- 4 | |||
-------------------NOTE--------------- ---- | |||
l Not reautred to be met when the_RHR ystem | |||
~ | |||
c ' | |||
l l | |||
gyq-lyes cautoclosure interlock is d- sabled in | |||
"- $$$_ _$$ .5)I . I I __ ------- l requirecl., Of l open Verify RHR System autoclosure interlock :18 months causes the valves to close 4 automatically with a si u ated or actual RCS pressure signal 2 600 psig. | |||
cp - | |||
700gssg caAd 6 750 2 | |||
l l WOG STS 3.4-38 Rev 1, 04/07/95 | |||
FNP TS Conversion Enclosure 5 - JD from STS Chapter 3.4 - RCS STS 3.4.14 RCS PRESSURE ISOLATION VALVE (PIV) LEAVdGE FNP ITS 3.4.14 RCS PRESSURE ISOLATION VALVE (PIV) LEAKAGE JD NUMBER JUSTIFICATION I The STS LCO 3.4.14 Condition A actions allow a choice of actions to be made for Required Action A.2. The FNP CTS allow continued operation when the affected flow path is isolated by two valves. As such the first A.2 Required Action is applicable to FNP and more consistent with the CTS than the second Required Action A.2. | |||
la The STS 3.4.14 Note in Condition A is revised consistent with the corresponding CTS requirements. The STS note requires that valves used to satisfy Required , | |||
Action A.1 or A.2 must have been verified to meet SR 3.4.14.1 and be in the reactor ' | |||
coolant pressure boundary or the high pressure ponion of the system. The , | |||
I corresponding CTS requirements do not specify that valves used to isolate the high pressure portion of the system from the low pressure portion be previously tested. 1 The FNP CTS Actions and the corresponding STS Actions require that the valves used to meet the Action isolate the PIV leakage. Failure to isolate the leakage (meet the requirements of the LCO)is failure to meet the Action requirements of Condition A and would result in entry into Condition B and a plant shutdown. | |||
Since in order to meet the isolation Actions, the leakage must be monitored after the isolation valves are closed and verified to be within the LCO limits, the FNP cunent practice effectively verifies the isolation capability of the valves when they are actually used to meet the Action requirements. The FNP current practice and , | |||
CTS requirements are adequate to address PIV leakage and the deletion of the STS requirement to only use valves previously tested per SR 3.4.14.1 is consistent with the FNP current licensing basis. | |||
2 The STS SR 3.4.14.2 (FNP ITS 3.4.14.3) is revised consistent with FNP terminology for the RHR isolation valve open permissive interlock function. The FNP-specific RCS pressure range for the open permissive interlock is inserted in place of the single value in the STS. | |||
3 The STS SR 3.4.14.1 frequencies on page 3.4-37 of the PIV Leakage TS are revised ) | |||
to be consistent with the FNP CTS for PIV leakage testing. The STS frequencies N[ on page 3.4-37 are revised to be consistent with the CTS surveillance requirements of 4.4.7.2.2.a and 4.4.7.2.2.d. | |||
i l | |||
4 The STS surveillances 3.4.14.2 and 3.4.14.3 (FNP ITS SR 3.4.14.3 and 3.4.14.2), | |||
which verify the operability of the RHR/RCS open permissive and autoclosure pressure interlocks are revised consistent with the FNP CTS. The STS notes modifying SR 3.4.14.2 and SR 3.4.14.3 are revised to reflect the conesponding i FNP CTS requirements located in FNP ITS SR 3.4.12.3 in lieu of the STS reference t | |||
Chapter 3.4 E5-1-K February,1999 | |||
FNP TS Conversion | |||
. Enclosure 5 - JD from STS Chapter 3.4 - RCS to SR 3.4.12.7. The FNP CTS does not contain a surveillance that corresponds to STS SR 3.4.12.7, which requires that the RHR valves be locked open and de-M energized. Therefore, STS 3.4.12.7 has been deleted from the FNP ITS. The FNP L | |||
(2A ITS SR 3.4.12.3 is associated with the low temperature overpressure protection TS and requires the RHR isolation valves to be verified open. This FNP ITS SR l replaces SR 3.4.12.7 in the notes and corresponds to the FNP CTS low temperature overpressure protection TS surveillance requirement (4.4.10.3.1.a). As such, this l change revises the STS surveillance notes to be consistent with the corresponding requirements in the FNP CTS. | |||
5 The STS surveillance 3.4.14.1 frequency is revised consistent with the FNP CTS. | |||
In the FNP CTS, there is no time limit associated with the PIV testing performed as I a result of valve actuation or flow through the valve. At FNP, there is no installed I test system to test these valves. The valves are tested locally at specified plant conditions. If flow were passed through these valves under certain conditions, the 24-hour time limit would not allow enough time to establish test conditions and I | |||
perform the test. Deleting the 24-hour time limit revises the STS consistent with FNP design and current licensing basis. | |||
l 6 The STS LCO 3.4.14 Condition C action is revised to address an FNP-specific l design feature. At Farley, the location of the electrical switchgear containing the breakers for the RHR isolation valves is subject to very high dose rates in the event of a small break LOCA. Therefore, complying with the Required Action of STS Condition C of LCO 3.4.14 would place the plant in a condition where, should a small break LOCA occur, the plant could not be placed on normal RHR without unacceptably high exposures to plant personnel. To address the issue of dose during a small break LOCA, the Required Action of Condition C has been revised to require isolation of the valves under administrative controls from the control . | |||
room to allow establishment of RHR operation, should it be required, without , | |||
I unacceptable dose to plant personnel in the event of a small break LOCA. In addition, the statement of the condition has been revised to reflect FNP-specific terminology for the associated interlocks. | |||
h I | |||
W j | |||
Chapter 3.4 E5-2-K Febmary,1999 | |||
i RCS PIV Leakage | |||
, p B 3.4.14 8ASES ACTIONS B.1 and B.2 (continued) within 6 hours and M00E-5 within 36 hours. This Action may reduce the leakage and also reduces the' potential for a LOCA outside the containment. The allowed Completion Times are reasonable based on operating experience, to reach the required plant conditions from full power conditions in an | |||
/\ orderly manner and without challenging plant systems. | |||
-6 U we spVdih.of reeAeo N. ssE, Md MR RAeven sucbpermissse ism.iw whesinblo mc *b\e. | |||
3; inoperabil autoc osure nterTockTdmfe l RHR suction isolation valves incapabl of isolating in reventing' | |||
, response to a high pressure condition, ort. inadvertent opening of the valves at RCS pressures in excess . | |||
._ f the RHR r ems design pressure. If the RHR autoclosure 1.nterloclGd operable, operation may continue as lona as' ' | |||
the affected'RHR suctio3/ penetration is closed by2t leas i | |||
,6n! closed manuas nr nametivated mutamatie valve >within | |||
('4 aours. Th s Action acconnlishac the purpose of the i h c Ett pC y inn cdely'm h aw6WnM+ hem cbsed (e.33 gs SURVEILLANCE S ..Y' REQUIREMENTS Performance of leakage testing on each RCS PIV or isolation valve used to satisfy Required Action A.1 and Required l Action A.2 it required to verify that leakage is below the l specified limit and to identify each leaking valve. The ! | |||
--' ". leakage limit of 0.5 gpm per inch of nominal valve diameter l 4., 3 # | |||
* up to*5 gpa maimum applies to each valve. Leakage testing i | |||
requires a stable pressure condition. | |||
( For the two PIVs in series, the leakage requirement applies i to each valve individually and not to the combined leakage across both valves. If the PIVs are not individually leakage tested, one valve may have failed completely and not be detected if the other valve in series meets the leakage requirement. In this situation, the protection provided by redundant valves would be lost. | |||
. Testing is to be performed every/ months, a tvnical refueling cycle.Ette olent coe; not ao'inth M00E/5 fsfr at) 4 OM Qdstg dpy.fThe 18 mont Frequency is consistent with (continued) | |||
WOG STS B 3.4-83 Rev1,04/07/95 | |||
. 1 J | |||
, CHAPTER 3.4 3 i 1 | |||
INSERT FA ' | |||
~ TO STS BASES PAGE B 3.4-83 ACTION C.1 l FNP-SPECIFIC ITS DESCRIPTION Note to Operators: The location of the electrical switchgear containing the breakers for the RHR ; | |||
isolation valves is subject to very high dose rates in the event of a small break LOCA. Therefore, . | |||
opening the breakers for the RHR isolation valves would place the plant in a condition where, ; | |||
should a small break LOCA occur, the plant could not be placed on normal RHR without I unacceptably high exposures to plant personnel. To address the issue of dose during a small break LOCA, the Required Action of Condition C requires isolation of the valves under | |||
. administrative controls from the control room to allow establishment of RHR operation, should it be required, without unacceptable dose to plant personnel in the event of a small break LOCA F4t-27 ) | |||
l l | |||
) | |||
I l | |||
1 I | |||
I I | |||
) | |||
i | |||
; i i | |||
l i | |||
I-I Chapter 3.4 Insert Page | |||
I | |||
* ht- | |||
. 7Q p,oto c.Leaur trderlec_k. RCS PIV Leakage | |||
. 1 isota.;fes the F4M sysfern B 3.4.14 V | |||
nm frornthe. AC.S tohen JTheNN* cQ h BASES inkrLee_k. 6efpoint 15 T | |||
) -s A_~ | |||
7 / | |||
SURVEILLANCE ~ R l.4.14.2 MR 3.4.14.3) (continued) o P ' ~ | |||
RE IREMENTS Noened is set so thefactual RCS pressureXst be) o l PSC. | |||
(< 425] psic to ooen the valves 1/ ThfJisetpoint ensures th_e f i m( desian cressurtwijl notfe exceeded.Gnd the RHR relief) & | |||
The SR is Malves will not liftf;The $18 mont Frequency is based on need to perform the Survet la r conditions that mod.dieckb gofe /hs.t ' | |||
oMalso appl acc ring a plant outage. The month Frequency is table based on considerat on of the design a gg qf l fhe r wrem.p . | |||
reliabilit equipment. | |||
and confirming operating experience) of the t So rickflC-C F These/SRs are/modif%d by Wotes allhwina t'he RHR/autocAosuFe) ; | |||
Juncilion to ve disabledrwh'en using the RHR System suction g5CIS relief valves f r cold overpressure protection in accordance with SR 3.4.12 . | |||
_ l w .. | |||
REFERENCES 1. 10 CFR 50.2. | |||
: 2. 10CFR50.55a(c). | |||
: 3. 10 CFR 50, Appendix A, Section V, GDC 55. | |||
: 4. WASH-1400 (NUREG-75/014), Appendix V, October 1975. | |||
: 5. NUREG-0677, May 1980. n((.' ' , | |||
: 6. (DocumentcontaininglistofPIVs] | |||
TRM) | |||
: 7. ASME, Boiler and Pressure Vessel Code, Section XI. | |||
: 8. 10CFR50.55a(g). | |||
1 WOG STS B 3.4-85 Rev 1, 04/07/95 | |||
. - . . .- - - - - . . . - , - - . . - _ - . . - - - . . . . . . - ~ . . . - . | |||
= . : | |||
w i | |||
~ CHAPTER 3.4 - | |||
52.a, t INSERT GA; T/g TO STS BASES PAGE B 3.4-85 | |||
.l N SR 3.4.14.3 i | |||
.i FNP-SPECIFIC ITS BASES DISCUSSION 1 i | |||
SR 3.4.14.3 i L , | |||
Verifying that the RHR open permissive interlock is OPERABLE ensures that the RCS will not pressurize the RHR system beyond design of 600 psig.' The open . | |||
permissive interlock prevents opening the RHR System suction valves from the RCS I when the RCS pressure is above the setpoint. The setpoint upper /alue ensures the | |||
! RHR System design pressure will not be exceeded at the RHR rump discharge and - i l -was chosen taking into account instrument uncertainty and cahbration tolerances. ; | |||
This value also provides assurance that the RHR System suction relief valves ; | |||
! setpoint will not be exceeded. The minimum value of the setpoint range is chosen ! | |||
based up operational considerations (differential pressure) 6 the RCP seals and thus l | |||
; does not have a safety-related function. The 18 month Frequency is based on the ; | |||
l need to perform the Surveillance under conditions that apply during a plant outage. ! | |||
The 18 month Frequency is also acceptable based on consideration of the design l | |||
reliability (and confuming operating experience) of the equipment. | |||
l The SR is modified by a Note that provides an exception to the requirement to perform this surveillance when using the RHR System suction relief valves for cold i overpressure protection in accordance with SR 3.4.12.3. l i | |||
1 l | |||
l } | |||
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L L 1 l | |||
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[s I | |||
Chapter 3.4 Insert Page y | |||
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1 9 | |||
Associated Package Changes for RAI- 32 i | |||
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7 A - | |||
9 - | |||
l A TABLE 4.4-4 | |||
_ -- - - M tyTC - -- -- " PRIMARY COOLANT SPECIFIC ACTIVITY SAMPLE L-og4.nneA n g gwsdA %f la FA0W % | |||
AND ANALYSIS.. PROGRAM | |||
~/ 5 g . _ _ - - - - - - - | |||
g g T EO MENT SAMPLE AND ANALYSIS MODES IN WHICH SAMPLE I q AND ANALYSIS FBROUENCY AND AM,\ LYSIS REOUIRED | |||
' SRsq,y,,[._GrossActivityDetermination / d At least ones per Q2_had_r3 1, 2, 3, 4 w Sg, 2. Isotopic Analysis for DOSE @' 1 per 14 days' q 1 3,ig,y,, 2_ EQUIVALENT I-131 Concentration 4 , | |||
SR. | |||
3.4.4.3Q. Radiochemical Determinstton for j 1 Per 6 monthe*] 10 W I | |||
[g p,g #4 to 4. sotopic Analysis for Iodine ] Ia') Once per 4 hours, 1#, 2#, 3#, 4#, 5# | |||
A nluding I-131. I-133. and I-139 whenever the specific | |||
? activity exceeds 0.15 0 1 PC1/grasa DOSE EQUIVALENT | |||
\"2. , g I- 31 or 100/E pC1/ gram, z | |||
- NcTIE - - - - b) Onesamplebetween2and] 1,2,3 6 hours frillowing a On repM b M THERMAL POWER change SJ Fer LA b 'AODE 1 51t 3.9. %.7- exceeding 15 percent of f L3 @\ | |||
~~---'---- | |||
the RATED THERMAL POWER ("L g | |||
, within a one hour periody P | |||
It heb s.n | |||
. ' y bu 5% | |||
L A.\ on1 | |||
(/_Until the specific activity of the crimary coolant system is restored within its limits) b.) | |||
* sample to be taken fter a minimum of 2 EFPD and 20 days of POWER O?ERATION have elapsed since reactor | |||
; y _ | |||
was last subcritica for 48 hours or long&r. | |||
in teoDE.1 | |||
--> SR 3. 4. S . 3 , g | |||
; NOTC i | |||
_ . . _ _ _ .___._._._________.________________._____m_. _ _ _ _ _ . _ _ _ _ _ _ _ _ . _ _ _ _ _ _ _ _ -. .- - . - - - | |||
FNP TS Conversion Enclosure 2 - Discussion of Changes to CTS Chapter 3.4 - RCS CTS 3/4.4.9 RCS SPECIFIC ACTIVITY FNP ITS 3.4.16 RCS SPECIFIC ACTIVITY DOC ! | |||
NO SHE DISCUSSION i are revised consistent with the STS. The | |||
* footnote is incorporated into the l surveillance requirement. In addition, the CTS applicable Mode for this surveillance from Table 4.4-4 (Mode 1) is also incorporated directly into the j surveillance requirement. These changes are made to conform with the format and presentation of this information in the STS and are not intended to introduce a technical change to the CTS requirements. As such, these ) | |||
changes are considered administrative in nature. | |||
1 10a M Table 4.4-4 surveillance requirement 4 is revised consistent with the STS. j ITS SR 3.4.16.2 states: " Verify reactor coolant DOSE EQUIVALENT l- j 131 specific activity s 0.15 pCi/gm." DOSE EQUIVALENT I-131 is defined in the TS as that concentration ofI-131 (microcuries/ gram) that alone would produce the same thyroid dose as the quantity and isotopic ysp mixture ofI-131, I-132, I-133, I-134, and I-135 present. Therefore, f performing an analysis for DOSE EQUIVALENT I-131 includes I-131, I-133, and I-135. The surveillance performed to comply with the ! | |||
requirements of Table 4.4-4 Item 4.a and 4.b of the CTS includes analysis l of all 5 Iodine isotopes. Performance ofITS SR 3.4.16.2 will also include l analysis ofI-132 and I-134, in addition to the three isotopes listed in Table 4.4-4 Item 4. As such, performance of SR 3.4.16.2 will envelope the requirements of Table 4.4-4 Item 4 and is slightly more restrictive. | |||
l 11 M The CTS Table 4.4-4 surveillance requirement 3 | |||
* footnote is revised consistent with the STS. This surveillance requires a radiochemical analysis for determining E-bar be performed every 6 months. The time allowed to actually perform this surveillance after reaching the required conditions 1 specified in the CTS | |||
* footnote is limited to within 31 days consistent with the corresponding STS requirement. The CTS requirement did not specify how soon after the conditions of the | |||
* footnote were met th; : the l surveillance must be performed. As the STS requirement of within 31 days l is reasonable to ensure the radioactivity in the RCS is in equilibrium (for i optimum surveillance results) and provides assurance that the surveillance j is performed in a timely manner, it is applicable and appropriate for FNP. i However, as this change represents an additional restriction in the TS, it is ; | |||
considered a more restrictive change. | |||
12 L The CTS surveillance requirement 4.b on Table 4.4-4 is revised consistent with the STS. This surveillance is incorporated into the STS SR 3.4.16.2. | |||
Chapter 3.4 E2-4-P February,1999 | |||
ATTACIIMENT III SNC Identified Editorial Changes Associated Package Changes l | |||
L l | |||
\ | |||
I J | |||
- - - .. .. .- . . . - . . . . . . . - , - - _ .- ._. - .. - . . ~ . . - . _ . - . _ . | |||
) | |||
l . | |||
i I | |||
'Ibe following changes have been made to the Chapter 3.4 submittal to address editorial changes, l omissions, and inconsistencies in the package: | |||
: 1. Page 3/4 4-12b was left out of the package for Chapter 3.4. This page has been added. | |||
: 2. Changed the ITS to state " Level Monitoring System" vice " Flow Rate Monitoring System" to i agree with the revised FSAR. A decision was made after the submittal to retain the CTS j terminology of condensate level monitor vs. condensate flow rate monitor, consistent with the ! | |||
revised FSAR. "Iherefore, editorial changes have been made to the package to reflect this ; | |||
decision. | |||
: 3. Chapter 3.4, CTS 3/4.2.5 (ITS 3.4.1), DOC llM has been revised to correct the SR reference i from SR 3.4.1.5 to SR 3.4.1.4. | |||
1 | |||
: 4. Page B 3.4-32, last paragraph, changed "above" to "2" to agree with the LCO requirements. l | |||
: 5. Page B 3.4-50, last paragraph, PORVs descriptions should read "each having a design relief capacity of 210,000 lb/hr at 2485 psig with a set pressure of 2335 psig." Instead of the current "cach having a relief capacity of 210,000 lb/hr at 2485 psig." (Reference U-166950, Rev.A) I | |||
: 6. ' Page B 3.4-62,2nd to last paragraph, first line, changed "RCS relief valve" to "RHR relief j valve." | |||
~ | |||
j l | |||
: 7. Insert Y to page B 3.4-74, changed " Dose Equivalent I-131" to " DOSE EQUIVALENT l- , | |||
- 131"to identifyit as a defmed term. ! | |||
I I | |||
i I i | |||
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I I | |||
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'l f | |||
l l | |||
l I | |||
i | |||
j 24x | |||
====== coorm symn 4 SURVEILiANCE REQUIRDEDtTS (Continued) | |||
I - | |||
.g - ,, c. Steam generator tumes, witn ancacassons c: - | |||
i' | |||
. potential degradation attributed to outssoe | |||
/ diameter stress cerrosion crackang within the | |||
, bounds of the tube support plate with a bobean i | |||
' weltage greater than the lower voltage repaar | |||
. limit (2.0 welts), but less than er equal to the upper voltage repair limit', may remain in servion if a rotating prebe inspecuon moes not detect degradaties. Steam generater tubes, wath indientions of ausside diameter stress corrosion cracking degradaties with a hobbin voltage greater than the upper weltage repair 12aut., | |||
will be plugged er repaired. | |||
: d. If as tanscheduled mid-cycle Laspection as parfeamed, the fallowing mid-eycle repair 11aats apply instead of the limits identified in 4.4.6.4.a.11.a, 4.4.6.4.a.11.b, and 4.4.6.4.a.11.c. The mid-cycle repair 1smits are detsamined tres the fallowing equatrons: | |||
v. | |||
Vues= 1.0 + NDE + Gr [ _CL-At ] | |||
CL Va.=V.mm-tv.m-Vm1 ! 9.-u 1 CL uheres Vue, = upper voltage repair limit Vua = louer voltage repair limit | |||
= " | |||
, V.me. mid-cycle upper voltage repair limat heaed en time into cycle [ | |||
v.a. = mid-cycle lower weltage repair 11 mat ,' | |||
based on V a and time into cycle . | |||
at = length of time since last scheduled inspection during which Van and Vg, mese taplemented cL or cyuge langer fther Clas hetuses eue sehedaled steen genstatac. | |||
s y 4===l Va = etructural liant weltage er = average growth rate per cycle length NDE = 95-percoat cissulative prehability allemenos for mondestructive | |||
. emana.mation uncertainty (i.e., a valer of 20-peroest has been | |||
* approved by NRC) | |||
Implementaties of these mid-cycle . repair limits should follow the sans appreaek as la TS 4.4.5.4.a.11.a, 4.4.6.4.a.11.h. and 4.4.6.4.a.11.e. | |||
* The upper. weltage repair 11mLt la calculated a-we=g ta the methodelegy la Generic 1stter 95-85 as ==pph*d FARE 2Y-ONIT 1 3/4 4-12b MIENEMENT NO.124 3 | |||
A > M 1.-AEsG+4 ,(" | |||
Levid6u, W$% | |||
5pec42 aran 55,1 | |||
1 | |||
= | |||
Yl 1 1 | |||
xdec+,an Instmaenfd.on i | |||
). h PEACTOR COOLANT SYSTEM u ___ - | |||
ACTOR COOLANT SYSTEM LEAkACE i 3.4.l M ,, | |||
RC.S '=ce octreTrON QSTENyINsTWrEtMCM IN5frurnerdrdon] , | |||
h LIMITING CONDIT!ON FOR OPERATION L LLo ,q.15 , | |||
4.7.1 The following Reactor Coolant System leakage detection systems shall | |||
_J _ be AA8LE: I | |||
~~~ '~* I | |||
: a. The o t atmosphere parti to radioactivity monitor L C,0 3. 0. '/ syste and gg i pV Z | |||
: b. Either e containm'ent air cooler ndensate level rnonito@l | |||
, , , , , W or a containm " struosphere gaseous radioactivity monitonnq eystem](R-12). j | |||
% babes t er om Re.s APPLICA YLTTY: MODES 1, 2, 3 and 4. /,f e | |||
g h ACTION: the 30 g. ( h5e erFormeS 16 i h | |||
leakage detection systems OPERABLE, | |||
/g With only one of the a ve requ l operation may continue to up to days provided grab samples of the containment atmosphere are btained and analysedPat least once per 24 hours 6 l | |||
when the required gaseousg o particulate radioactive monitoring system-is A | |||
! inoperables otherwise, be in at least HOT STAND 8Y within the next 6 hours and I in COLD SHUTDOWN within t is following 30 hours. - | |||
i | |||
* i Ok Q COO COlib S$$ W OY URVEILLANCE REQUIREMENTS C m{j.{h - _ -_ - | |||
w g /g h , | |||
e leakage detection systems shall be demonstrated OPERA 8LE by: | |||
Containment a sphere gaseous and particulate monitori stars I performance f CHANNEL CHECK, CHANNEL CALIBRATION and HANNE $ R3,4efbe 1 l COT tuNCTIONAL T h Qt the Krequenctes specatted in TaDie a.3- 8 g g g f$,3 . | |||
I EAde/*l t g,/$, f b Containment air cooler condensate 11evel monitoring system l perforinance of CHANNEL CALIBRATION at least once per 18 months. | |||
l A | |||
l J | |||
U ConDonot) b - cAA rbttco s.o.s w$ utr ' | |||
Jp l | |||
. 7 FARLEY-UNIT 1 3/4 4-16 AMENDMENT NO. 26 I . | |||
l | |||
~ | |||
1 | |||
. l i | |||
FNP TS Conversion Enclosure 2 - Discussion of Changes to CTS Chapter 3.4 - RCS ? | |||
CTS 3/4.2.5 DNB PARAMETERS : | |||
FNP ITS 3.4.1 RCS PRESSURE, TEMPERATURE, AND FLOW DNB LIMITS . | |||
DOC t NO SHE DISCUSSION ! | |||
8 A The DNB parameters and limits specified on CTS Table 3.2-1 are moved into the TS LCO and surveillance requirements consistent with the format and presentation of this information in the STS. No technical change is - | |||
intended. As such this change is considered administrative. | |||
i 9 A The references to two loop operation on CTS Table 3.2-1 are deleted. FNP l is not licensed for two loop operation. The references to two loop operation on CTS Table 3.2-1 are not applicable and contain no valid limitations on plant operation. As the deletion of this information removes nonessential : | |||
material from the TS and has no technical impact, this change is considered administrative. ; | |||
10 LA The infonnation contained in the *" footnote to CTS Table 3.2-1 is removed from the TS and placed in the bases consistent with the location of + | |||
this information in the STS. The *" footnote of CTS Table 3.2-1 contains I | |||
the measurement uncertainties associated with the calculations used to determine the minimum RCS flow specified in the TS. This information is incorporated into the specified RCS flow and not of direct importance to the ; | |||
operators using the TS. The allowance to place this information in the TS I | |||
bases is acceptable due to the level of control provided by the TS bases control program specified in the administrative controls section of the ITS. : | |||
11 M The CTS surveillance 4.2.5.2 which requires the RCS flow rate to be , | |||
determined every 18 months by precision heat balance is revised by the addition of a note. The use of a note in this surveillance is consistent with | |||
[ gd the corresponding STS surveillance SR 3.4.1.4. However, the time proposed in the FNP note (7 days) for perfonnance of the surveillance is not consistent with the time specified in the STS (24 hours). Since the CTS do not specify a time limit for performing this surveillance FNP proposes 7 days based on operating experience and the fact that performing the precision heat balance is a complicated measurement that requires stable thermal power conditions. Seven days provides adequate time to set up for the measurement, with allowances for typical instrumentation problems, i and to achieve stable conditions without adversely affecting safety. In I addition, the 7 day limit for performing this same surveillance has been | |||
! previously approved by the NRC for Vogtle (CTS and ITS). The note | |||
! specifies a power level at which the surveillance must be performed and a j time (7 days) within which the surveillance must be performed after Chapter 3.4 E2-3-A February,1999 , | |||
I | |||
; i i | |||
l FNP TS Conversion | |||
. Enclosure 2 - Discussion of Changes to CTS Chapter 3.4 - RCS CTS 3/4.2.5 DNB PARAMETERS FNP ITS 3.4.1 RCS PRESSURE, TEMPERATURE, AND FLOW DNB LIMITS l DOC i l | |||
NQ SJiE DISCUSSION exceeding the required power level. The specification of a power level greater than or equal to 90%, ensures the results of the surveillance are , | |||
accurate (higher power more accurate results) and the requirement to l perform the surveillance within a specified time after reaching this power l level ensures that the RCS flows are verified in a timely manner. As such ! | |||
these additional requirements are appropriate and applicable to FNP. ' | |||
However, the addition of the power and time requirements to this , | |||
surveillance represent new TS requirements for FNP and therefore, this ; | |||
change is considered more restrictive. | |||
l l | |||
l l | |||
i l | |||
l l | |||
1 l | |||
Chapter 3.4 E2-4-A March,1998 i | |||
FNP TS Conversion Enclosure 2 - Discussion of Changes to CTS Chapter 3.4 - RCS CTS 3/4.4.7.1 RCS LEAKAGE DETECTION SYSTEMS FNP ITS 3.4.15 RCS LEAKAGE DETECTION INSTRUMENTATION DOC NO StLE DISCUSSION 1 LA The CTS 3.4.7.1 LCO is revised consistent with the STS. The radiation monitor instrument designations (R-11 and R-12) are moved into the LCO section of the bases consistent with the placement of such details in the STS. Placement of this information in the bases is acceptable based on the level of change control provided by the bases control program in the administrative controls section of the STS. | |||
2 A The CTS 3.4.7.1 LCO is revised consistent with the STS. Editorial changes are made to the LCO statement to achieve consistency with the STS. | |||
However, the name of the containment air cooler condensate level monitor is maintained consistent with the revised FNP FSAR description of this system. The condensate level / flow rate monitoring system contains a vertical standpipe in which the level is monitored. As condensate flow EV' \ increases the level in the standpipe also increases and the high condensate flow alarm is actuated from the rising standpipe level. Therefore, the CTS terminology is maintained. The changes are made to confonn with the format and presentation of the STS and are therefore considered administrative in nature. | |||
3 L The CTS 3/4.4.7.1 action statement time allowed to restore an inoperable leakage detection instrument is revised from 7 days to 30 days consistent with the STS. The actions for an inoperable required leakage detection instrument provide for containment atmosphere grab samples to be taken and analyzed or an RCS water inventory balance to be performed once every 24 hours. The performance of these periodic required actions is an adequate remedial measure providing sufficient information to ensure that RCS leakage will not go undetected. Additionally, at least one other form of TS required automatic leak detection will be operable as well as the non-TS dew point temperature monitoring system to provide further assurance that RCS leakage will be detected in a timely manner. As such, this change provides a more reasonable time, considering the remaining operable automatic leakage detection instrumentation, the information provided by the performance of the required actions, and the likelihood of an event occurring during this time that would require all the leak detection instrumentation operable, to affect repairs on a single inoperable leakage detection instrument. | |||
Chapter 3.4 E2-1-M February,1999 j i | |||
l | |||
FNP TS Conversion | |||
. Enclosure 2 - Discussion of Changes to CTS Chapter 3.4 - RCS CTS 3/4.4.7.1 RCS LEAKAGE DETECTION SYSTEMS FNP ITS 3.4.15 RCS LEAKAGE DETECTION INSTRUMENTATION DOC NO SHE DISCUSSION 4 A The CTS 3/4.4.7.1 actions are revised to add an alternate action consistent with the STS. The CTS actions require a containment atmosphere grab sample to be taken and analyzed every 24 hours. The STS provides an altemative action to perfonn an RCS water inventory balance every 24 hours in lieu of the currently required grab sample. The proposed STS attemate action provides direct measurement of RCS leakage, both identified and unidentified, and is an acceptable alternative to the analysis of containment atmosphere grab samples to detect changes in RCS leakage. | |||
As this change does not impact the technical intent of the CTS actions (to compensate for the inoperable automatic leakage detection instrument) and only provides an equally acceptable attemative action to be performed on the same frequency, it is considered an administrative change. | |||
5 A The CTS 3/4.4.7.1 actions are revised to clarify that an actions Condition would not be applicable for the gaseous radioactivity monitor unless the containment air cooler condensate level monitor was also inoperable. This l | |||
is an FNP specific change to the CTS actions made in order to conform A more closely with the STS actions Conditions. The CTS LCO statement b is | |||
[ l not violated unless both the gaseous radioactivity monitor and the condensate level monitor are inoperable. Since the STS provides more specific Conditions for inoperable leakage detection monitors it is necessary to clarify the FNP specific action for these two monitors and provide an action consistent with the requirements of the CTS and FNP ITS LCO statement. Therefore, the containment air cooler condensate level monitor | |||
[ | |||
is added to the action statement to correspond with the requirements of the LCO (statement b) and the proposed FNP ITS Condition B which addresses i the inoperabihty of both these monitors. As this change only serves to clarify the existing relationship of these instruments in the CTS LCO and actions, it is considered administrative in nature. | |||
6 A The CTS 4.4.7.1 surveillance requirements are revised to be consistent with the STS. This includes the following changes: 4 The surveillance requirements for the containment atmosphere radioactivity monitors are no longer contained in the referenced CTS Table 4.3-3. The surveillance requirements for these radiation monitors are now completely contained within the proposed FNP ITS 3.4.15, RCS leakage Detection Instrumentation, consistent with Chapter 3.4 E2-2-M February,1999 | |||
FNP TS Conversion | |||
. Enclosure 2 - Discussion of Changes to CTS Chapter 3.4 - RCS CTS 3/4.4.7.1 RCS LEAKAGE DETECTION SYSTEMS FNP ITS 3.4.15 RCS LEAKAGE DETECTION INSTRUMENTATION DOC HQ SHE DISCUSSION the STS. The technical intent and frequency of the CTS surveillances remain unchanged but the surveillances are now | |||
, located in a single place in the TS. | |||
The CTS Channel Functional Test term is replaced with the ITS COT defined term. The differences between these terms are j discussed in the submittal enclosures associated with the TS definitions in section 1.0 of the TS. This change is made only to conform with the STS. | |||
{ | |||
The surveillance requirements of CTS 4.4.7.1.a and .b are broken out and individually numbered in the proposed FNP ITS consistent with the STS. | |||
As these changes are made to conform with the fonnat and presentation of this information in the STS, these changes are considered administrative. | |||
7 M The CTS 3/4.4.7.1 actions are revised by the addition of a new actions Condition consistent with the STS. The proposed new Condition addresses the situation where all the required leakage detection monitors are inoperable and requires that LCO 3.0.3 be entered immediately. The new Condition is required due to the conventions of actions Condition entry used in the STS. In the STS, all applicable action Conditions may be i entered simultaneously (per general mies of TS section 1.3, Completion I Times). The actions Conditions of the proposed FNP ITS may be entered at I the same time (resulting in all leakage monitors inoperable) and the completion time of the Conditions would still allow 30 days to restore a l monitor to operable status. LCO 3.0.3 would not be applicable as action Conditions exist within the TS to cover all inoperable leakage detection monitors. Therefore, the STS provides an explicit actions Condition requiring immediate entry into LCO 3.0.3 if all required leakage monitors are inoperable and the required leakage detection function is lost. As this l change incorporates specific and new instructions to enter LCO 3.0.3 within the TS, it is considered a more restrictive change. | |||
8 L The CTS 3/4.4.7.1 actions are modified by a note allowing an exception to LCO 3.0.4 consistent with the STS. The note is applied to proposed FNP Chapter 3.4 E2-3-M February,1999 l | |||
_ _ _ _ - _ _ _ _ i | |||
RCS Leakage Detection Instrumentation N 3.4.15 3.4 REACTOR COOLANT SYSTEM (RCS) a.rhc.o kIE 3.4.15 RCS Leakage Detection Instrumentation LC0 3.4.15 The following RCS leakage detecti instrumentation shall be OPERABLE: | |||
3[ One/ cont [inmej[t sup/p (leyd1/or/ disc)large f)4w) m%ito[; | |||
O Onecontainmentatmospherekradioactivitymonitor: | |||
4.[ 46aseous or particulate); | |||
b, Dand g .g One cont nmentaircoolercondensateElowrat[ | |||
monito - , _- = + - - - - - | |||
orone untdnmeni Akmo*P e.r.e- h garecus caa.cm%. mandec. q M - | |||
APPLICABILITY: MODES 1, 2, 3, and 4 | |||
- - - -- - - - N ora - - - - - - - | |||
ACTIONS -'M 3'I b "- | |||
* b- ~- ' | |||
CONDITION REQUIRED ACTION COMPLETION TIME A. Requ containment ------------NOTE------------- | |||
sump mon LCO 3.0.4 is not applicable. | |||
inoperable. -------------------------- - | |||
. Perform .4.13.1. Once per 24 hours ANQ A.2 Restore requi 30 days containment sump j monitor to OPERABLE status. | |||
(continued) l ZNsERT E FNP sPsciFio Conounon A WOG STS 3.4-39 Rev 1, 04/07/95 | |||
"L@ | |||
RCS Leakage Dstection Instrument tion | |||
. 3.4.15 ACTIONS (continued) | |||
CONDITION REQUIRED ACTION COMPLETION TIME r~ | |||
B. | |||
d""O | |||
~ | |||
Required con'inment | |||
-----------NOTE------------ | |||
W atmosphere LC0 3.0.4 is not T3TF-Go radioactivity monitor applicable. | |||
inoperable. --------------------------- | |||
c . | |||
EhlD B.1.1 Analyze gral samples Once per of the containment 24 hours atmosphere. | |||
%did conYEinmen4 oar cooler conder$de. E l mo r B.I.2 Perform SR 3.4.13.1. Once per ino pera.b\c.. 24 hours OM alleadane [p (8.2 store required 30 days rcontainme atmosphere radioactivit monitor to OPERABLE status. i R | |||
B.2 2 Verify contains t 30 ays air c oler cond nsate fl rate | |||
-) | |||
I mon tor is OP RABLE. ! | |||
URquiredcontinment i j | |||
.1 Perf SR3.4.1[.l. Once er ir cooler c ndensate 8 ho rs flow rate nitor E inoperable C.2 rform SR 3 4.13.1. ce per 4 hours | |||
/ | |||
(continued) | |||
N WOG STS 3.4-40 Rev 1, 04/07/95 | |||
t 25V RCS Leakage Detection Instrumentation I | |||
. 3.4.15 l 5 i SURVEILLANCE REQUIREMENTS (continued) | |||
SURVEILLANCE f FREQUENCY f: | |||
SR 3.4.15.2 Perform COT of the required containment 92 days l | |||
. atmosphere radioactivity monitor. l SR 3.4.15.3 Perform RAT equired [18] months !' | |||
.mo or. | |||
yy | |||
~ | |||
3 | |||
- 3.4.15./ Perform CHANNEL CALIBRATION of the required containment atmosphere radioactivity | |||
@l84 months f i l | |||
monitor. | |||
.s I | |||
dSR 3.4.15.84Perform CHANKEL CALIBRAlleii uf the requiredf 8 months containment air cooler condensate C ow rap ! | |||
monitor. | |||
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i WOG STS 3.4-42 Rev 1, 04/07/95 | |||
FNP TS Conversion Enclosure 5 - JD from STS Chapter 3.4 - RCS STS 3.4.15 RCS LEAKAGE DETECTION INSTRUMENTATION l | |||
FNP ITS 3.4.15 RCS LEAKAGE DETECTION INSTRUMENTATION l 1 | |||
JD ! | |||
NUMBER JUSTIFICATION 1 The STS LCO is revised to be consistent with the CTS LCO. The CTS LCO does ) | |||
j | |||
. not include the requirement for a containment sump level or flow monitor. The GM CTS LCO also requires that the containment atmosphere particulate radioactivity i monitor be operable at all times in the Mode of Applicability. The CTS uses the terminology " condensate level monitor" instead of" condensate flow rate monitor." | |||
The CTS LCO allows either the containment atmosphere gaseous radioactivity | |||
[ monitor or the containment air cooler condensate level monitor to be used to meet part b of the LCO requirement. In the original FNP SER (NUREG 75/034, Section 5.6), the NRC found the FNP leakage detection equipment and methods acceptable and to satisfy the requirements of general design criterion 30 of 10CFR Part 50, App A (without a containment sump monitor). | |||
2 The STS is revised by the addition of an FNP specific Condition "A" addressing the containment atmosphere particulate radioactivity monitor.(part "a" of the LCO) which replaces the STS Condition "A" for the containment sump monitor. The requirement for a containment sump monitor is not part of the FNP CTS. The STS addresses the radioactivity monitors (gaseous or particulate) as interchangeable to meet the LCO requirement. Since in the FNP CTS, the containment atmosphere particulate monitor is required operable in Modes 1 through 4 and may not be replaced with the containment atmosphere gaseous radioactivity monitor, a separate j actions Condition addressing the operability of this monitor is proposed as an FNP l specific change to the STS. This change is consistent with the FNP CTS when , | |||
presented in the STS fonnat. | |||
l 3 The STS Condition B which previously addressed the radioactivity monitors is i revised consistent with the CTS LCO statement "b" requirement for a containment i atmosphere gaseous radioactivity monitor or a containment air cooler condensate level monitor to be operable. In order to fail to meet the FNP LCO statement "b", | |||
l both of these monitors must be inoperable at the same time. Therefore, the STS N' Y Condition B is revised as necessary to accommodate the FNP specific LCO l requirements. | |||
4 The bracketed (optional) STS Conditions C and D are not required to address the limited combination ofinoperable equipment allowed by the FNP specific LCO and are deleted. The requirements of these deleted Conditions are effectively incorporated into the proposed FNP ITS specific Condition B. | |||
5 The STS SR 3.4.15.3 is deleted. This SR requires the performance of a channel ! | |||
calibration of the containment sump monitor. The requirement for an operable Chapter 3.4 E5-1-L February,1999 j | |||
l | |||
.l RCS Loops - MODE 5, Loops Filled B 3.4.7 B 3.4 REACTOR COOLANT SYSTEM (RCS) | |||
B 3.4.7 RCS Loops - MODE 5, Loops Filled BASES BACKGROUND In MODE 5 with the RCS loops filled, the primary function of the reactor coolant is the removal of decay heat and transfer this heat either to the steam generator (SG) secondary side coolant +or the component cooling water via the residual heat removal (RHR) heat exchangers. While'the ] | |||
, principal means for decay heat removal is via the RHR | |||
^(g System, the SGsgre specified as a backup means for redunoancy. Even though the SGs cannot produce steam in : | |||
c wwMk this MODE, they are capable of being a heat sink due to ; | |||
y ,) their large contained volume of secondary water. As long as l the SG secondary side water is at a lower temperature than , | |||
the reactor coolant, heat transfer will occur. The rate of ' | |||
heat transfer is directly proportional to the temperature T317_ q difference. The secondary function of the reactor coolant i is to act as a carrier for soluble neutron poison, boric acid. | |||
In MODE 5 with RCS loops filled, the reactor coolant is ) | |||
circulated by means of two RHR loops connected to the RCS, ' | |||
each loop containing an RHR heat exchanger, an RHR pump, and appropriate flow and temperature instrumentation for control, protection, and indication. One RHR pump r circulates the water through the RCS at a sufficient rate to prevent boric acid stratification. | |||
,g The number of loops in operation can vary to suit the operational needs. The intent of this LCO is to provide Ehyr forced flow from at least one RHR loop for decay heat removal and transport. The flow provided by one RHR loop is y- adequate for decay heat removal. The other intent of this ; | |||
LCO is to require that a second path be available to provide ' | |||
redundancy for heat removal. | |||
The LC0 provides for redundan paths of decay heat removal capability. The first path .an be an RHR loop that must be OPERABLE and in o ration. The second path can be another E RH 1 r i aining two SGs with secondary side , | |||
water levels [17]% to provide an alternate method for decayheatremovp. | |||
n*>"frA) | |||
A P (continued) | |||
WOG STS B 3.4-32 Rev 1, 04/07/95 1 | |||
. M Pressurizer PORVs | |||
. B 3.4.11 i B 3.4 REACTOR COOLANT-SYSTEM (RCS) | |||
B 3.4.11 Pressurizer Power Operated Relief Valves (PORVs) ; | |||
., j BASES BACKGROUND The pressurizer is equipped with two types of devices for i pressure relief: pressurizer safety valves and PORVs. The l FSAR PORVs are air operated _ valves that are controlled to open at i 5,5,13.1 a specific set pressure when the pressurizer pressure j y, $,0 L increases and close when the pressurizer pressure decreases. | |||
The PORVs may also be manually operated from the control room. | |||
Block valves, which are normally open,. are located between 1 the pressurizer and the PORVs. The block valves are used to isolate the PORVs in case of excessive leakage or a stuck open PORV. Block valve closure is accomplished manually using controls in the control room. A stuck open PORV is, in effect, a small break loss of coolant accident (LOCA). | |||
As such, block valve closure terminates the RCS depressurization and coolant inventory loss. | |||
The PORVs and their associated block valves may be used by plant operators to depressurize the RCS to recover from certain transients if normal pressurizer spray is not available. Additionally, the series arrangement of the PORVs and their block valves permit performance of surveillances on the valves during power operation. | |||
The PORVs may also be used for_ feed and bleed core cooling in the case of multiple equipment failure events that are not within the design basis, such as a total loss of feedwater. ; | |||
1 The PORVs, their block valves, and their controls are d powered from the vital buses that normally receive power | |||
~ (%p@ g . from offsite power sources, but are also capable of being g,5' powered from emergency power sources in the event of a loss of offsite power. Two PORVs and their associated block ' | |||
valves are powered separ cf:t" t-la- 't !. 'y ' | |||
a e.5E fresfort, oE2.33Spsy ! | |||
@ The plant has two having e reotrcapacity o 210,000 lb/hr'at . The fun onal design of the , | |||
taining pressu below the Pressurizer g 36l g | |||
PORVs is based on Pressure - High reactor trip setpoint following a step 4g reduction of 50% of full lead with steam dump. In addition, f.6M,hb E l (continued) | |||
WOG STS B 3.4 Rev 1, 04/07/95 , | |||
a __ __ . _ _ _ ~ , | |||
3(p LTOP System B 3.4.12 , | |||
I BASES APPLICABLE Heat Inout Tvoe Transients SAFETY ANALYSES (continued) a. Inadvertent actuation of pressurizer heaters; | |||
: b. Loss of RHR cooling; or | |||
: c. Reactor coolant pump (RCP) startup with temperature asymmetry within_the RCS or between the RCS and steam generators. | |||
The following are required during the LTOP MODES to ensure j that mass and heat input transients do not occur, which j either of the LTOP overpressure protection means cannot ' | |||
t.4 handle: | |||
Y[ g4 a. Render g all but 6ne] HPI] pump [and]onecharging pum incapable ofinjec;1on; | |||
^ | |||
: b. Ocactivating the accumulator discharge isolation valves in their closed positions; and | |||
? or c. Disallowing s rt of an R'CP if secondary temperature | |||
\' | |||
is more than 5 *F above primary temperature in any hpeW one loop # LC0 3.4.6, "RCS Loops - MODE 4," and LCO 3.4.7, "RCS Loops - MODE 5, Loops Filled g ". rovid g l Qhis protectioh The Reference 4 analyses demonstrate that ther on p% (M, relief vbve er tne ae>rossurized Rcs and Rcs venTean 1 o_ | |||
mair tainACS pressure >e' imits wh only onet.HPI] pump] - | |||
I CandonBcharginq n'=a d n is are ctuat situs, tne p hcf Ico allows on)y one] [F E] pump .an@ one ing > ump W OPERABLE durJhe(;ne uur nvuts. Sincefeithe one( . MR. | |||
i 3 | |||
j "g relief valvtt[ior t the Rch vont canlhandle the pressure transient need from accumu' ator injection, when RCS 6 to - temperatur s low, the LCO also requires the accumulators RSAR isola when accumulator pressure is greater than or equal S.229 .to th maximum RCS pressure for the existing RCS cold leg te ature allowed in the PTLR. | |||
o_@ The isolated accumulators must have their discharge valves closed and the valve power supply breakers fixed in their open positions g Ihe anas ses sho tne ett t of ac umu or g- schprge is prer a nar wer RC tempera re ran ([ J'F - c andj5elow) t) fan that the L ([275]* and be w) n (continued) | |||
WOG STS B 3.4-62 Rev 1, 04/07/95 | |||
CHAPTER 3.4 , | |||
INSERT Y 370 TO STS BASES PAGE B 3.4-74 FNP SPECIFIC BASES FOR MSLB RADIATION RELEASES i The main steam line break (MSLB) is more limiting for site radiation releases. The MSLB analysis in support of Generic Letter 95-05 has shown that steam generator tube leakage of 23.8 gpm in the faulted loop, and 0.1 gpm (approximately 150 gpd) in each of the intact loops (total leakage of 24 gpm), following a main steam line break outside of containment, but upstream of the main steam isolation valves, results in offsite doses bounded by a small fraction (i.e.,10%) of the 10 CFR 100 guidelines. The RCS specific activity assumed was 0.15 micro-Ci/gm DOSE EQUIVALENT I-131, with either a pre-existing or an accident initiated iodine spike. | |||
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-. .-- .- - --- - --- -- - - - ---- -""~^-- | |||
N- j l | |||
Aqs RCS Leakage Detection Instrumentation i W B 3.4.15 I | |||
l B 3.4 REACTOR COOLANT SYSTEM (RCS) j B 3.4.15 RCS Leakage Detection Instrumentation l , | |||
l BASES BACKGROUND GDC 30 of Appendix A to 10 CFR 50 (Ref.1) requires means i for detecting and, to the extent practical, identifying the location of the source of RCS LEAKAGE. Regulatory l | |||
Guide 1.45 (Ref. 2) describes acceptable methods for ; | |||
L selecting leakage detection systems. | |||
Leakage detection systems must have the capability to detect ! | |||
I significant reactor coolant pressure boundary (RCPB) i egradation as soon after occurrence as practical to i p6b9 - .6 *1,- minimize the potential for propagation to a gross failure. | |||
l g, T Thus, an early indication or warning ' signal is necessary to , | |||
permit proper evaluation of all unid ntified LEAKAGE. I | |||
= _ | |||
gbM tevt.t or . | |||
Industry practice.l as own that w flow changes of 0.5 : | |||
l The coM to 1.0 gpm can b readily detected injontained volumes by | |||
! plow as monitoring chang s in water levpl, & flow rate, or in the o p or k operating freque ncy of a pump. The containment 4 ump used to) " ! | |||
perht , | |||
ccoi sect, unident; fied,tEAKAGE [WC.d(or) andJa cier gl l gA , | |||
densate mw ratamonitor] tarelunstrs= ant ta ala i O.Y*EM t | |||
creases Qf '0.5 to 1.0 opaJin theMlTlow ratsy). | |||
nsitivity is acceptab e ffor detecting Eriases in [ ' | |||
P' R*- 4 R** - nidentified LEAKAGE.4 /b | |||
;0 rue mesesses J. - - - | |||
the waher level The reactor coolant contains radioactivity that, when l' gn we 4%p released to the containment, can be detected by radiation rises, monitoring instrumentation. Reactor coolant radioactivity levels will be low during initial reactor startup and for a few weeks thereafter, until activated corrosion products have been formed and fission products appear from fuel element cladding contamination or cladding defects. | |||
~ Fs AR. Instrumentsensitivitiesof10"pi/ccradioactivityfor 5.27.4.1 Particulate monitoring and of 10 pCi/cc radioactivity for gaseous monitoring are practical for these leakage detection systems. Radioactivity detection systems are included for monitoring both particulate and gaseous activities because of their sensitivities and rapid responses to RCS LEAKAGE. | |||
An increase in humidity of the containment atmosphere would indicate release of water vapor to the containment. Dew point temperature measurements can thus be used to monitor l j humidity levels of the containment atmosphere as an i- i l | |||
! (continued) | |||
WOG STS B 3.4-86 Rev 1, 04/07/95 | |||
, ._n._- ,,-.__,.___3 ,_..- | |||
1 RCS Leakage Detection Instrumentadon | |||
% B 3.4.15 BASES APPLICABLE RCS leakage. detection instrumentation satisfies Criterion 1 SAFETY ANALYSES of the NRC Policy Statement. | |||
(continued) | |||
LCO One method of protecting against large RCS leakage derives \ | |||
Thus the conbnen from the ability of instruments to rapidly datect extremely i mall leaks. This LCO requires instruments of diverse gg[g 4 g;g 4;jjg 4p nitoring principles to be OPERABLE to provide a high degree of confidence that extremely small leaks are detected (R-il j in time to allow actions to place the plant in a safe yh) in combs'oa.f,co/[y".*h condition, when'RCS LEAKAGE indicates possible RCPB egradation. (q (R-s2). er a_cbenmerd l | |||
% C80 W U h # he LCO is satisfied when monitors of diverse measurement lovel Ndar means are available. (Th , the con ainment su monito , in Q (com natign witn A gaseo or part culate rad activit j EAW ' | |||
mo tor [(nd a cAntains t air co er conden te flow atel 4 m itor][ provides an acceptable minimum. ' | |||
l APPLICABILITY Because of elevated RCS temperature and pressure in MODES 1, 2, 3, and 4, RCS leakage detection instrumentation is 3o required to be OPERABLE. | |||
In MODE 5 or 6, the temperature is to be :s; 200*F and pressure is maintained low or at atmospheric pressure. | |||
Since the temperatures and pressures are far lower than those for MODES 1, 2, 3, and 4, the likelihood of leakage and crack propagation are much smaller. Therefore, the requirements of this LCO are not applicable in MODES 5 and 6. | |||
A,l./, A,/,2 M"U^ _ ___ | |||
%U l af rach here. ar+1culsfe) | |||
AC S nd A.2 = | |||
((v donfSenireof With the required containment u monitor inoperable, no i w coo /pe- - | |||
other form of sampling can provide the equivalent i 2 information; however, the containment atmosphere l | |||
beI radioactivity monitorgwill provide indications o anges in rrwmiorf leakage. Togetner with the. atmosphere'uonito the periodic surveillance for RCS water inventory balance,%rR 3.4.13.1, | |||
\ | |||
Y or the coransate. | |||
' . \ t,ve l mo (continued) l _ _ ho r-WOG STS B 3.4-88 Rev 1, 04/07/95 | |||
e CHAPTER'3.4 M TSTF-60 INSERT CA TO STS BASES PAGE B 3.4-88 FNP SPECIFIC IMPLEMENTATION OF TSTF-60 The Actions are modified by a Note that indicates that the provisions of LCO 3.0.4 are not applicable. As a result, a MODE change is allowed when the containment particulate h radioactivity monitor, the containment gaseous radioactivity monitor, and the containment air . | |||
l cooler condensate level monitor are inoperable. This allowance is provided because other instrumentation is available to monitor RCS leakage. | |||
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CHAPTER 3.4 l | |||
. 332 INSERT F TO FNP ITS 3.4.15 CONDITION B BASES DESCRIPTION PAGE B 3.4-89 l and the required containment air cooler condensate level monitoring instrumentation chaanel ; | |||
GS M O l | |||
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'l Chapter 3.4 Insert Page | |||
-}} | |||
Latest revision as of 06:45, 1 January 2021
| ML20203A771 | |
| Person / Time | |
|---|---|
| Site: | Farley  |
| Issue date: | 02/03/1999 |
| From: | SOUTHERN NUCLEAR OPERATING CO. |
| To: | |
| Shared Package | |
| ML20203A758 | List: |
| References | |
| NUDOCS 9902100096 | |
| Download: ML20203A771 (77) | |
Text
{{#Wiki_filter:-. . .. . . . _ - . . ATTACHMENTII SNC Response to NRC Request for Additional Information Related to Conversion to the Improved Technical Specifications - Chapter 3.4 Associated Package Changes Grouped by RAI Number 9902100096 990203 7 PDR ADOCK 05000348 p PDR g
. . -- . - . . - --~_ . . _ - . ~.
O, h // W 83 R4 opvd.d. 10 we is as A IM5ERT L W E' 5'b, HOTES IM pd y z Emere, ex t m sysTE, ) SRJ,6.5, f $R 3. 4.13sl ?} ;
#3 suavElttAuCE nEouraExEuTs <Continuedi A
l
- c. Measurement of the CONTROLLED LEAKACE from the reactor coolant pump seals at least once per 31 days when the peactor Coolant ,
.TQffg system pressure is 2235 2 20 psig with the medulating valve fully l g 7g, open. The provisions of specification 4.0.4 are not applicable 7 for entry into Moot 3 or 4.
gg , SR3,'/./3,1 [Ierformance of a ne.ctor Coolant systei water inventory datanc. ) at least once per 12 hours. p l 5 R 3.4.lV.t , p '
- e. [ Monitor /ngtherfactorheadf)langeleakoffsystemat/ east ongs A / per 24/ hours. / / / / /
M k4.7.2 ach Reactor coolant System Pressure foolation Valverspectfted in 7 / )
, Tatdo 3. 4-1 } s 11 ce d monstra ed CPERA)lLE pur ant to Specific ton #5 i l4.0.5 xcept at in teu of ny leakage test g rew irdd bv -
g , of fpm SIa.6 (spee icatie 4.0.5, ach va ve h ould be demonstrated CPERA3LE by l Rc.g ggg vert ytng leakage to be within the allowable leakage criteria of 0.5 l ggg Qg gpm per inch of qominal valve sishtt_h an upper limit of the maximum #h j lb "f2.5 allowaole leakag((tr/ Taprie 3/4-1) M ari meanwrec A a case to any g ] h -- Egtven test ca not te uce tne fifference etween the esults of he . b 1 prev ous tes and t e enarimugf allowable _ }eakage see tfted in T Die j {
+ 3.4 by mo than 01) g g,,,j (
_ gg Every (ref ueling outaghring start DE 2 E g &
- b. Prior o return ng the alve to' rvice foi ing mal enanc ,I Mh repa! or rep! cement capa 11ty of -he va b .
rk on tr valve af f crstig the senti - Y 24
- c. >ro11owing valve actuation due to automatic or manual action or M g flow through the valva Qor vatves 5.aent i f t ed i n Ta b le _3_. 4 1 by a rd Qate r t s_kMs Y g7g /
NR3.4 Va'^"t l' *li l d. The provisions of specification 4.0.4 are not applicable for
$R 3,*l.14 1 entry into MODE 3 or 4. -. . .
D/SEATO *ER:f E A INSERT P SA 3.4.I4.2. SR M N.3 23 g g,q, g3, g A RHR ado cbsure M N W a5WE SG Tube survelhe lederCoc.k 'IEST MELO'k N I I Zt h 3 g$ QTS _n 'l.f.2.d.1) n - -- g g g Y # To satisfy ALARA requirements, leakage may be measured indirectly (as frc a performance of pressure indicators) if accomplished in accordance with approved procedures and supported by computations showing that the method is capable of demcnstrating valve compliance with the leakage crateria. 4 SR3,$l'k/ BASES FARLzr-un1T 1 N 3/4 4-is AMENcMENT no. 50 LA
1 i E- CHAPTER 3.4 N A. I 1 l INSERT EA - j TO CTS 4.4.7.2.2 SURVEILLANCE l g NEW RCS PIV LEAKAGE TS SURVEILLANCE p'V FOR RHR OPEN PERMISSIVE INTERLOCK ; LCO 3.4.14 SR 3.4.14.3 1 1
)
i SR 3.4.14.3 -------- - - - - - - - NOTE -- ----- --..--... Not required to be met when the RHR System valves are required open in accordance with SR 3.4.12.3. ) Verify RHR System open permissive interlock prevents the valves from being l opened with a simulated or actual RCS pressure signal 2 295 psig and s 415 psig. i Every 18 months. j 1 l 1 l l t i l e l l l l- Chapter 3.4 Insert Page
FNP TS Conversion , Enclosure 2 - Discussion of Changes to CTS Chapter 3.4 - RCS CTS 3/4.4.7.2 OPERATIONAL LEAKAGE UNIT 1 AND 2 FNP ITS 3.4.13 RCS OPERATIONAL LEAKAGE FNP ITS 3.4.14 RCS PRESSURE ISOLATION VALVE LEAKAGE FNP ITS 3.5.5 ECCS SEAL INJECTION FLOW DOC ! NQ _SjiE DISCUSSION ) verified to meet the LCO leakage limits. ) 8 M A new action is added to the CTS 3/4.4.7.2 actions for an RCS PN that I does not meet the leakage limits based on the actions of the STS. Proposed Condition C of the new PN leakage LCO 3.4.14 applies to an inoperable RHR valve autoclosure interlock and has been added to the PN TS to l g N explicitly address this type of PIV inoperability and provide appropriate actions. The actions and completion times proposed for this new condition are similar to the existing actions for an inoperable PlV except that only one isolation valve is required to be closed and maintained closed under administrative control. This difference is required due to the location of the breakers for the associated valves and dose that plant personnel would I receive when restoring power to the valves in the event of a small break LOCA. As the action addresses an inoperable interlock and not valve leakage, and the STS actions Notes require the applicable Conditions and actions of any affected system made inoperable by the inoperable PN to be entered, the proposed action for an inoperable autoclosure interlock is acceptable. As the addition of this new Condition in the FNP TS represents a new requirement not previously addressed by the TS, the addition of this Condition is considered a more restrictive change. 9 L The CTS 4.4.7.2.1.a and .b that require the leak detection particulate and gaseous radiation monitors and containment air cooler condensate level to be monitored every 12 hours are deleted consistent with the STS. The particulate and gaseous radioactivity monitors will continue to be checked every 12 hours by the Channel Check surveillance requirement SR 3.4.15.1 in the RCS Leakage Detection TS LCO 3.4.15. The containment air cooler condensate level monitor receives a Channel Calibration every 18 months per SR 3.4.15.4 in the RCS Leakage Detection TS LCO 3.4.15 and provides an alarm in the control room to alert the operators to an increase in condensate level. The 18 month channel calibration requirement is adequate for instmmentation used for indication and monitoring. As the radioactivity monitors provide a more immediate response to RCS leakage and will continue to be monitored every 12 hours, and the fact that an Chapter 3.4 E2-4-N February,1999
Associated Package Changes for RAI- 5 l 1 l l
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lli RCS Loops - MODE 3 o 3.4.5 SURVEILLANCE REQUIREMENTS (continued) , SURVEILLANCE FREQUENCY SR 3.4.5.2 Verify steam aentrator secondary side water 12 hours levels are h(:17]Vfor required RCS loops. , w s __ _ ro nkM< [ SR 3.4.5.3 Verify correct breaker alignment and E 7 days , indicated power are available to the ,g6 . required pump that is not in operation. F i
)
l l ! l ? l l 1 i l i 4 i 4 i i WOG STS 3.4-10 Rev 1, 04/07/95
. . _ - - _ _ - . . - . - . .. .. . - _ . ~ _ . - . . - . - - - _ . .
i
- 7. 2-) RCS Loops - MODE 4 3.4.6 ACTIONS (continued)
CONDITION REQUIRED ACTION COMPLETION TIME B. One required RHR loop B.1 Be in MODE 5. 24 hours inoperable. M Two required RCS loops inoperable. C. Required RCS or RHR C.1 Suspend all Imediately i loops. inoperable. operations involving a reduction of RCS DB boron concentration. No RCS or RHR loop in M operation. C.2 Initiate action to Imediately restore one loop to OPERABLE status and operation. l SURVEILLANCE REQUIREMENTS __ SURVEILLANCE FREQUENCY SR 3.4.6.1 Verify one RHR or RCS loop is in operation. 12 hours I i SR 3.4.6.2 Verif" G secondary side water levels are 12 hours' 4
;t: 17, for required RCS loops.
- ~ - - -
- t. [ (continued) wr er h E
l WOG STS 3.4-12 Rev 1, 04/07/95 i
. l RCS Loops - HODE 5, Loops Filled 1 4
2.7,Q 3.4.7 l I 3.4 REACTOR COOLANT SYSTEM (RCS) l 3.4.7 RCS Loops - MODE 5, Loops Filled ; i ' l LCO 3.4.7 One residual heat removal (RHR) loop shall be OPERABLE and in operation, and either: 9TF-163 a. One additional RHR loop s'iall be OPERABLE; or ! nef be in b. The secondary side water level f at least o team b-opdh generators (SGs) shall be a 17] =- l
----------------------------NOTES------- * @
% (wid e ro.rg e).
- =- = h -
p-5 1
- 1. The RHR pum the loop in opc-ation may me-enera ue for s per 8 he'ir perio provided:
- a. No operations are permitted that wculd cause reduction of the RCS boron concentration; and
- b. Core outlet temperature is mai taine at least 10'F belt.w saturation temperature 4 g
- 2. One required RHR loop may be inoperable for u t 2 hours f or surveillance testing provided that e other RHR loop is OPERABLE and in operatio .
4 o.
- 3. No reactor coolant pump shall be s v .ed with on or more RCS cold leg temperatures s 2757F unie secondary side water temperature o each SG 'F above each of the RCS cold leg temperaturesg or ,
l
- 4. All RHR loops may be removed from operation during planned heatup to MODE 4 when at least one RCS loop is !
in operation.
- b. The pre, sour *:ze.r u.nder volume. l t5 less, b.n 770 co'o'ic, he}
APPLICAlILITY: MODE 5 with RCS loops filled. W* *bd f ' pressociser level g' C8 1,n).
~-
ct 'e" fu3s$s
-4
,5 ff-pi,,+knem Son p uecod eseoF g pomp besielecJoet+e cont, nous flou; wh purge Mr(
MnM 4eg po9 outerserviceo J WOG STS 3.4-14 Rev1,04/07/95
7q RCS Loops - MODE 5, Loops Filled 3.4.7
. ACTIONS CONDITION- REQUIRED ACTION COMPLETION TIME A. One RHR loop A.1 Initiate action to Immediately inoperable. restore a second RHR loop to OPERABLE MQ status.
Required SGs secondary E side water levels not within limits. A.2 Initiate action to Immediately restore required SG secondary side water levels to within limits. B. Required RHR loops B.1 Suspend all Immediately - inoperable. operations involving a reduction of RCS E boron concentration. No RHR loop in gQ
. operation.
B.2 Initiate action to Immediately restore one RHR loop to OPERABLE status and operation. SURVEILLANCE REQUIREMENTS SURVEILLANCE FREQUENCY SR 3.4.7.1 Verify one RHR loop is in operation. 12 hours SR 3.4.7.2 Ver G secondary side water level is 12 hours k 17] in required SGs. _ _
'iknN MEN (continued)
& W5 WOG STS 3.4-15 Rev 1 04/07/95
FNP TS Conversion
', Enclosure 5 - JD from STS Chapter 3.4 - RCS STS 3.4.5 RCS LOOPS - MODE 3
. FNP ITS 3.4.5 RCS LOOPS - MODE 3 JD NUMBER JUSTIFICATION 1 The word " required"is inserted in Conditicn D of LCO 3.4.5 RCS Loops Mode 3 to modify the two RCS loops inoperable condition. The addition of the word
" required"in the Condition D statement is consistent with the Condition A statement and use of" required RCS loop". Since only two of the three total RCS loops are required operable by the LCO statement, the Conditions in this LCO should specify " required RCS loops" (one loop may be inoperable without entering an LCO Condition). The addition of the word " required" provides a clarification to Condition D consistent with the intent of the LCO and the use and application of TS.
2 The secondary side water level required in SR 3.4.5.2 is revised from the CTS value of 10% to 74% consistent with the FNP specific recommendation from Westinghouse. The STS Bases for SR 3.4.5.2 state that the purpose of the A requirement for SG secondary side level is to provide an altemate heat sink. If the
.g SG tubes become uncovered, the associated loop may not be capable of providing this heat sink. To maintain consistency with the Bases for STS SR 3 4.5.2, Westinghouse was asked to provide the SG water leve; necessary to ensee that the tubes remain covered in Modes 3,4, and 5. That level was determined to be 74%
wide range. Since this level is greater that the current level in CTS, this change, to conform with the intent of the STS is seen as more conservative. Chapter 3.4 ES-1-D February,1999
4
. FNP TS Conversion ,
. Enclosure 5 - JD from STS Chapter 3.4 - RCS STS 3.4.6 RCS LOOPS - MODE 4 FNP ITS 3.4.6 RCS LOOPS - MODE 4 JD NUMBER JUSTIFICATION 1 The STS LCO 3.4.6 Note 1 is revised consistent with the FNP CTS. The STS I bour allowance for de-energizing pumps is revised to conform with the FNP 2 hour allowance to de-energize pumps in this Mode. The FNP CTS maintain a 1 hour allowance for de-energizing pumps in Mode 3, however, due to the lower operating temperature and reduced decay heat load in Mode 4 the FNP CTS allow 2 hours for de-energizing all pumps. This change to the STS is consistent with the current FNP licensing basis as specified in the CTS.
2 The STS LCO 3.4.6 Note 2 is revised consistent with the FNP CTS. The STS note restricts the starting of a reactor coolant pump in Mode 4 when the RCS cold leg temperatures are less than or equal to the specified temperature. The purpose of the restriction is to prevent RCS pressure transients, caused by energy additions from the secondary system, that could exceed the 10CFR 50, Appendix G limits. The FNP CTS contains an attemate method for limiting the potential RCS pressure transients. The FNP specific provision for starting reactor coolant pumps when the pressurizer water volume is less than the specified volume provides a volume for the RCS to expand into which provides assurance that the potential RCS pressure transient is limited. The addition of this attemate method in the FNP ITS for limiting RCS pressure transients when starting RCPs is consistent with the current FNP licensing basis as specified in the CTS. 3 The STS limitation on the secondary side SG water temperature of s 50 F in Note 2 to LCO 3.4.6 is revised consistent with the FNP CTS requirement of < 50 *F. This change maintains the current FNP licensing basis as stated in the CTS. 4 The secondary side water level required in SR 3.4.6.2 is revised from the CTS value of 10% to 74% consistent with the FNP specific recommendation from Westinghouse. The STS Bases for SR 3.4.6.2 state that the purpose of the I requirement for SG secondary side level is to provide an alternate heat sink. If the SG tubes become uncovered, the associated loop may not be capable of providing l this heat sink. To maintain consistency with the Bases for STS SR 3.4.6.2, Westinghouse was asked to provide the SG water level necessary to ensure that the tubs remain covered in Modes 3,4, and 5. That level was detennined to be 74% l wide range. Since this level is greater that the current level in CTS, this change, to combrm with the intent of the STS is seen as more conservative. i Chapter 3.4 E5-1-E Febmary,1999
FNP TS Conversion Enclosure 5 - JD from STS Chapter 3.4 - RCS STS 3.4.7 RCS LOOPS - MODE 5 - LOOPS FILLED FNP ITS 3.4.7 RCS LOOPS - MODE 5 - LOOPS FILLED 6 The secondary side water level required in part b. of the LCO statement and SR 3.4.7.2 is revised from the CTS value of 10% to 74% consistent with the FNP specific recommendation from Westinghouse. The STS Bases for SR 3.4.7.2 state that the purpose of the requirement for SG secondary side level is to provide an f 8; alt'emate heat sink. If the SG tubes become uncovered, the associated loop may not 9 be capable of providing this heat sink. To maintain consistency with the Bases for STS SR 3.4.7.2, Westinghouse was asked to provide the SG water level necessary to ensure that the tubes remain covered in Modes 3,4, and 5. That level was determined to be 74% wide range. Since this level is greater that the current level in CTS, this change, to conform with the intent of the STS is seen as more conservative. i 1 l l l l l l 1 i Chapter 3.4 E5-2-F February,1999
e Associated Package Changes for RAI- 8 I
FNP TS Conversion Enclosure 2 - Discussion of Changes to CTS Chapter 3.4 - RCS CTS 3/4.4.1.4 REACTOR COOLANT LOOPS AND COOLANT CIRCULATION COLD SHUTDOWN FNP ITS 3.4.7 RCS LOOPS - MODE 5 - LOOPS FILLED DOC EO SEE DISCUSSION 1 A The CTS 3/4.4.1.4, RCS Cold hoown, is revised consistent with the STS. The CTS is divided into two new TS, LCO 3.4.7, Mode 5 - Loops Filled, and LCO 3.4.8, Mode 5 - Loops Not Filled. Two separate markups of CTS 3/4.4.1.4 are included to separately illustrate the changes made in converting to the two new STS LCOs. As the division of the CTS into two new LCOs is made solely to conform with the format and presentation of the STS and since the resulting technical impacts are discussed in other DOCS, this change (1 TS to 2 TS) is considered administrative. 2 A The CTS LCO statement 3.4.1.4 and # footnote to the LCO are combined and revised consistent with the STS. The option provided by the # footnote to allow 2 steam generators to be substituted for one of the required RHR loops when 3 RCS loops are filled is incomorated directly into the LCO 4 g l (new LCO parts a. and b.) and the Applicability statement. This is acceptable since the LCO is specifically for Mode 5 - loops filled. 3 M The CTS 3/4.4.1.4 action statement b is revised consi< tent with the corresponding STS Condition B. CTS action stateme it b addresses the situation where no RHR loops are operating and requi: :s suspension of operations involving a reduction in the boron concentra! ion and action to be initiated immediately to restore a loop to opemtion. The corresponding STS Condition B addresses both the situations of no operating and no operable RHR loops. The STS Condition B actions are the same as the CTS action statement b except that the action required to be initiated immediately includes restoration of a loop to operable status as well as operation. The situation of no operable RHR loops is currently addressed by CTS action statement a (less than required loops operable) which also requires immediate action to restore a loop to operable status be initiated. As such, the only difference between the STS Condition B actions for no l operable loop and CTS action statement a is the requirement to suspend l operations involving a reduction in the boron concentration. The inclusion of the action to suspend operations involving a reduction of b 'ron concentration for the condition of no operable loops is a reasonable and conservative action to limit the potential for reducing the shutdown margin when the decay heat removal capability of the plant is degraded to the extent that no RHR loops are operable. Additionally, in the situation of no l Chapter 3.4 E2-1-F February,1999
1 1 1 1 1 i l l I i 1 1 Associated Package Changes for RAI- 10 , 1 I l i 1 I ( 1
e FNP TS Conversion Enclosure 2 - Discussion of Changes to CTS Chapter 3.4 - RCS CTS 3/4.4.1.4 REACTOR COOLANT LOOPS AND COOLANT CIRCULATION COLD SHUTDOWN FNP ITS 3.4.7 RCS LOOPS - MODE 5 - LOOPS FILLED DOC EQ EHE DISCUSSION 1 A The CTS 3/4.4.1.4, RCS Cold Shutdown, is revised consistent with the STS. The CTS is divided into two new TS, LCO 3.4.7, Mode 5 - Loops l Filled, and LCO 3.4.8, Mode 5 - Loops Not Filled. Two separate markups ! of CTS 3/4.4.1.4 are included to separately illustrate the changes made in l converting to the' two ocw STS LCOs. As the division of the CTS into two ! new LCOs is made solely to conform with the format and presentation of i the STS and since the resulting technical impacts are discussed in other l DOCS, this change (1 TS to 2 TS) is considered administrative. j. 2 A The CTS LCO statement 3.4.1.4 and # footnote to the LCO are combined I and revised consistent with the STS. The option provided by the # footnote ! to allow 2 steam generators to be substituted for one of the required RHR : loops when 3 RCS loops are filled is incorporated directly into the LCO i (new LCO parts a. and b.) and the Applicability statement. This is l acceptable since the LCO is specifically for Mode 5 - loops filled. 3 M The CTS 3/4.4.1.4 action statement b is revised consistent with the I corresponding STS Condition B. CTS action b. is revised to reflect the l additional requirement to have the RHR loops operable as stated in STS I Condition B. In addition, the generic term " coolant loop" is changed to Y ,e "RHR loop" consistent with the STS. These changes, combined with the allowance to substitute two steam generators with adequate level as described in the CTS # footnote for an RHR loop, reflect the necessary changes to convert CTS action statements a. and b. to STS Conditions A and B. CTS action statement b addresses the situation where no RHR loops are operating and requires suspension of operations involving a reduction in the boron concentration and action to be initiated immediately to restore a loop to operation. The corresponding STS Condition B addresses both the situations of no operating and no operable RHR loops. The STS Condition 1 B actions are the same as the CTS action statement b except that the action ! required to be initiated immediately includes restoration of a loop to l operable status as well as operation. The situation of no operable RHR ! loops is currently addressed by CTS action statement a (less than required l loops operable) which also requires immediate action to restore a loop to ! operable' status be initiated. As such, the only difference between the STS 'j Condition B actions for no operable loop and CTS action statement a is the l Chapter 3.4 E2-1-F February,1999 wwvmv +n-., r w we-+ ,--e-me- -esa +- -- su
- e FNP TS Conversion l ,
Enclosure 2 - Discussion of Changes to CTS Chapter 3.4 - RCS l CTS 3/4.4.1.4 REACTOR COOLANT LOOPS AND COOLANT CIRCULATION COLD SHUTDOWN FNP ITS 3.4.7 RCS LOOPS - MODE 5 - LOOPS FILLED DOC
- EQ SHE DISCUSSION requirement to suspend operations involving a reduction in the boron concentration. The inclusion of the action to suspend operations involving a reduction of boron concentration for the condition of no operable loops is a reasonable and conservative action to limit the potential for reducing the shutdown margin when the decay heat removal capability of the plant is degraded to the extent that no RHR loops are operable. Additionally, in the situation of no operable RHR loops it is very likely that the condition of no operating RHR loops would also exist and the action to suspend operations involving a reduction in boron concentration would be applicable anyway.
l However, as this revision to the CTS actions introduces a new action j (suspension of operations involving a reduction in boron concentration) that is not specifically stated in the CTS for the condition of no operable loops, it is considered more restrictive. 4 LA CTS surveillance 4.4.1.4 is revised consistent with the STS. The CTS surveillance is revised editorially to conform with the STS format and presentation of this information. In addition, the requirement to verify l l
" circulating reactor coolant" is moved into the bases for this surveillance. l The circulation of coolant is inherent in the operation of an operable RHR loop. The STS bases description for this surveillance contains an explanation for verifying a loop is operating which includes the confirmation of coolant flow. Placement of this information in the bases is acceptable based on the level of change control provided by the bases control program in the administrative controls section of the STS.
5 M The surveillance requirements of CTS 3/4.4.1.4 are revised consistent with the STS. Two new surveillances are added to the CTS to verify operability of the second non-operating RHR loop and the level in the two RCS loop steam generators. Since either the RHR loop, or the level in two steam generators may be relied on to meet the LCO, the STS contains appropriate , surveillances to verify compliance with the LCO. The addition of the steam ! generator level verification surveillance is consistent with the other RCS loop TS that allow the LCO to be met by RCS loops with a specified minimum steam generator level. The verification of breaker alignment and indicated power for the non-operating RHR pump relied on to meet the LCO is also consistent with the CTS requirements in other TS for RCS t loops. As the LCO may be met by one or the other of these options, the 1 I Chapter 3.4 E2-2-F March,1998 l l
0 Associated Package Changes for RAI- 13 l l i I I l l 1 i i 1 I
i a Y Pressurizer PORVs j - B 3.4.11 i j BASES- (continued) ! SURVEILLANCE SR 3.4.11.1 l REQUIREMENTS Block valve cycling verifies that the valve (s) can be closed l if needed. The basis for the Frequency of 92 days is the
- ASME Code, Section XI (Ref. 3). If the block valve is closed to isolate a PORV that is capable of being manually cycled, the OPERABILITY of the block valve is of importance, because opening the block valve is necessary to permit the PORV to be used for manual control of reactor pressure. If the block valve is closed to isolate an otherwise inoperable PORV, the maximum Completion Time to restore the PORV and open the block valve is 72 hours, which is well within the allowable limits (25%) to extend the block valve Frequency of 92 days. Furthermore, these test requirements would be completed by the reopening of a recently closed block valve upon restoration of the PORV to OPERABLE status (i.e.,
,D completion of the Required Actions fulfills the SR).
TheNotemodifiesthisSRbystatingthatitisnotrequired i to be met with the block valve closed, in accordance with l the Required Action of this LCO.
- 5 % 46$h A b " D SR 3.4.11.2 .m MODE 3 53w4W4 SR 3.4.11.2 requires a complete cycle of each PORV. *r 4 Ot *Mo M, bO Operating a PORVj rough one complete cycle ensures that t e vohes chstA 5'n" .PORV can be manua y ctuated for mitigation of an SGTR.
g p 4. W if -'The Frequency of 61 months is based on a typical refueling I
. cycle and industry accepted practice.
g 4-N ypyp f I . tah -44 Toinv0mhkwA + SR 3.4.11.3 H ok \t.ser s40sm - OperatWinoid air control valves a valves MfemfeMe "P"g* - on the air accumu a nctuates properly who res control system The Frequency of dQn.b'q " 18] months i on a typical re he other Surveillances used to cycle and th trate I b .TMfA4, ._ PERABILITY 1 { n
~SR3.
11.4 _
~This Surveillance is no with permanent l'
_ IE power supp11 e valves. (continued) i
.WOG STS 8 3.4-56 Rev 1, 04/07/95
- l i
i
. 1 l
i l i l
)
I Associated Package Changes for RAI- 14 ! i i
)
l i l l l l 1 i 1 1 1 l 1 1 l I l
.. - - - - - . .- . .- . - . - - .. ., - -~~ .- -
l *l i g REACTOR COOLANT g g SURVE!LLANCE REQUIREMENTS e_ Each PORV shall be demonstrated OPERABLE at least once per 18 months by: N3sNsIlel Operating the PORY through one complete cycle of full travel during
. MODE 3 or 4,'
' J Ik3*N'0!*$ Operating the PORV through one complete cycle of full travel using the backup PORV control system. and
- h. Performing a CHANNEL CALIBRATION of the actuation instrumentation. l 5 0 .4.11. 1 @ ' Each block vatve shall d. d.monserae.d ePERAsLE se lease one. p.c j 92 days by operating the valve through one complete cycle of full travel unless the block valve is closed in order to meet the requirements of ACTION b or c in Specification 3.4.5. b L
S l l i \ l l l l l l l t 4 FARLEY-UNIT 1 3/4 4-84 AMENDMENT NO. 97 j J J il
FNP TS Conversion Enclosure 2 - Discussion of Changes to CTS Chapter 3.4 - RCS CTS 3/4.4.5 RELIEF VALVES FNP ITS 3.4.11 PRESSURIZER POWER OPERATED RELIEF VALVES (PORVs) DOC HQ SHE DISCUSSION STS. In the STS exceptions to LCO 3.0.4 are stated in Notes. This change is an administrative revision made to conform with the format and g presentation of this information in the STS. l5 Not Used. l \ l 6 L The CTS surveillance 4.4.5.1.c which requires a Channel Calibration of the PORV actuation instrumentation be performed every 18 months is deleted from the TS consistent with the STS. This surveillance serves to confirm operation of the PORV automatic actuation instrumentation. However, l automatic actuation of the PORVs is not an assumption of the applicable l design basis accidents or transients. PORV operability for the TS is l dependent on manual actuation, which continues to be verified every 18 l months by required surveillance testing (FNP ITS SR 3.4.11.2). As such, i the CTS Channel Calibration requirement is not required in the TS to confirm PORV operability and is removed. l l l a Chapter 3.4 E2-2-K February,1999
- i i
d Pressurizer PORVs ! j . 13 / 3.4.11 ! I ACTIONS I i CONDITION REQUIRED ACTION COMPLETION TIME l F. (continued) F.2 Restore one block 2 hours ; l' valve to _ OPERABLE o ; statusjItf three i i l inoperable] flock valves Er
-P i
j F.3 Restore rem g 72 hours .
- block valv s to j OPERABLE sta us. ,
1 G. Required Action and G.1 Be in MODE 3. 6 hours associated Completion . Time of Condition F MQ not met. G.2 Be in MODE 4. 12 hours . t SURVEILLANCE REQUIREMENTS SURVEILLANCE FREQUENCY SR 3.4.11.1 -------------------NOTE-------------------- I Not required to be met with block valve closed in accordance with the Required Action of Condition B or E. l Perform a complete cycle of nch block 92 days valve. SR 3.4.11.2 'Pe rn a complete cycle of tach PCR months (doring MODE 3 or C , gq (continued) WOG STS 3.4-25 Rev 1, 04/07/95
! y __ _._..___..-------------"------~~~~~i r l !' 2
" FNP TS Convenion i i:
*' Enclosure 5 - JD from STS ,
i Chapter 3.4 - RCS !, t STS 3.4.11 PRESSURIZER PORVs i FNP ITS 3.4.11 PRESSURIZER PORVs a ;
- JD :
NUMBER JUSTIFICATION l I The STS SR 3.4.11.2 is revised consistent with the FNP CTS. The FNP CTS : surveillance 4.4.5.1.a requires that the PORVs be operated through one complete l
.[d cycle during Modes 3 or 4. The CTS specifies the surveillance be performed during Modes 3 or 4 to limit the uncertainty that would be introduced by performing the surveillance at lower temperatures. As such, this CTS requirement is retained in the j i
proposed FNP ITS surveillance SR 3.4.11.2. j 2 The bracketed STS SR 3.4.11.3 is replaced with the FNP specific surveillance (CTS ! 4.4.5.1.b). The FNP specific surveillance verifles the operation of each PORV j using the backup nitrogen and air supplies. This FNP specific surveillance I combined with the surveillance requirement to operate the PORVs through one l complete cycle (with the normal air supply) provide adequate verification of the - ; PORV operational status and are consistent with the CTS. : 3 The bracketed STS surveillance SR 3.4.11.4 is an optional surveillance provided for i PORVs that are not normally supplied by 1E power sources (see STS bases). As . the FNP PORVs are supplied by 1E power sources, this STS SR is not applicable to FNP and has been deleted from the FNP iTS. 1 l I l i Chap *a 3.4 E5-1-H February,1999 j
+
Y Pressurizer PORVs B 3.4.11 BASES (continued) l i l SURVEILLANCE SR 3.4.11.1 I i REQUIREMENTS l Block valve cycling verifies that the valve (s) can be closed ! if needed. The basis for the Frequency of 92 days is the ;
, ASME Code, Section XI (Ref. 3). If the block valve is !
- closed to isolate a PORV that is capable of being manually j cycled, the OPERABILITY of the block valve is of importance, because opening the block valve is necessary to permit the !
l PORV to be used for manual control of reactor pressure. If i the block valve is closed to isolate an otherwise inoperable { PORV, the maximum Completion Time to restore the PORV and
- open the block valve is 72 hours, which is well within the
! allowable limits (25%) to extend the block valve Frequency 1 of 92 days. Furthermore, these test requirements would be completed by the reopening'of a recently closed block valve upon restoration of the PORV to OPERABLE status (i.e., completion of the Required Actions fulfills the SR). [g 1 j The Note modifies this SR by stating that it is not required j to be met with the block valve closed, in accordance with the Required Action of this LCO. 1 *%e 9eRV4 en S h h 465 M W3 SR 3.4.11.2
#EI 3 # "g .m MODE 3
*d SR 3.4.11.2 requires a complete cycle of each PORV.
M 6.M bO Operating a PORV j$ rough one complete cycle ensures that the 4 hes closeA ik ,PORV can be manua Ilytactuated for mitigation of an SGTR. gp .ko hNf -'The Frequency of bl8d months is based on a typical refueling
. cycle and industry accepted practice 4-
/, tsdi$ ea Toity0mN<* M H '
- SRIMERTD 3.4.11.3 F
f ok kserM sfW*) Operat W inoid air control valves a valves OmPF 6 g-( on the air accumu a res control system ! {M f Mg W"M" actuates aroperly whe [18] montis i on a typical re The Frequency of cycle and th I 9vM 4 r requ the other Surve111ances used to trate ! OPERABILITY Camddiims e -
% % i SR 3.5.11.0 _
This Surveillance is no with permanent _ IE power supp11 e valves. (continued) WOG STS B 3.4-56 Rev 1, 04/07/95
f i Associated Package Changes for RAI- 16 9 N 4 a 4 4 l l i I
. __ m- _ . . . . . .. ,_. _ . . . , _ _ _ _ _ _ _ _ _ _ __ _ _ _ _ _ ,. _ _ _ . _ _ ~ . . _ . . _ . . _ _ _ _
, Dnet PTLR chnje Pqe !
.' (p Q l I
= , . .
oy Syd
%Temperdure witivuurmmuin ap,ey . in t
- V REACTCR COOLANT Sy3 TEM g O !
E VERPRESSURE PROTECTICN SYSTEMS
,g /A M D/7)(/ 3 l LIMITING CONDITIONS TCR OPE N /43 b AL'f _
j
.4.10.3 f the fo'11owing es se pro action systems sna11 he OPERAsLE: I
. 2 :
- a. Two MR relief valves with I A lif t setting of less than or equal to 450 psig, and $R 3,Y, C,3
- 2. The associated MR relief valve isolaeion valves openg or ZA/5ER.T R l
) b. The Reactor Coolant system (RCs) depressurized with an PCS vent of g greater than or equal to 2.85 square inches. .
APPLICABILITY: When the temperature of one or more of the RCs cold legs is less than er equal to 325'r, except when the reactor vessel head is l - g removed. [4g Actron: 8
% A
, ith one MR elief valve inoperable,r---- ~
WesMBLE status )tithin 24 hours or perform the following:
/
,a-g m-m valve C4 -
INSERT.S NEld Carddico$ 4, $4 Establish the following requiremerits: gg, p D*k Redu'ce pressurizer level to less than or equal to 30 percent.(cold calibrated), and i M Assign a dedicated operator for RCS pressure monitoring , and control, and i
. h.3 Restore the inoperable valve to OPERABLE status within 7 ;
days, ors , l E.1 [ copressurire and vent the Res through a greater than or equal IN6ERTI : to 2.85 square inch vent within the next 8 hours. , M , With both MR relief valves inoperablehthin 8 hours either: c @o r & + b e
- For E ConO r E. kl* *** ** ** *
- 1*** * *** "A **li* f **1ve to oPERAnLE s tatus, or)
E.17 c.pr.ssuris. and Ant ef.~.Res through a gra'st. chan or equal to 2.85 square inch vent.
* &(
s f c. In the event a MR relief valve or a RCs vent is used to mitigate a RCs pressure transient, a special Report shall be prepared and M if q submitted to the comunission pursuant to specification 6.9.2' within 30 , days. The report 'shall describe .the circumstances initiating the g h,g transient, the effect of the MR rslief valves er vent on the transient and any corrective action necessary to prevent recurrence.
- h. The provisions of specification 3.0.4 are not applicable] ,
FARLEY-UNIT 1 3/4 (.32 AMENDMENT NO. __p spp&n.8/,p Noh.7 .y, . ... a
l FNP TS Conversion i
', Enclosure 2 - Discussion of Changes to CTS Chapter 3.4 - RCS CTS 3/4.4.10.3 OVERPRESSURE PROTECTION SYSTEMS FNP ITS 3.4.12 LOW TEMPERATURE OVERPRESSURE PROTECTION SYSTEM DOC NO SHE DISCUSSION requirement to isolate accumulators was discussed previously. The addition of this note provides more specific guidance on the application of the requirement to isolate accumulators. As such, this change is also I considered administrative made to support the addition of the accumulator isolation requirement discussed previously.
Note 3 simply relocates the existing CTS exception to Specification 3.0.4 into the applicability consistent with the STS. CTS 3.4.10.3 action statement "d" currently contains the exception to specification 3.0.4. The i change to move this exception into an applicability note is consistent with the fonnat and presentation of this type ofinformation in the STS. As such, this change is considered administrative. 4 M CTS 3/4.4.10.3 is revised by the addition of new Actions Conditions consistent with the STS. New Conditions A, B, and C are added. The proposed Conditions and Required Actions address the new LCO requirements for only one charging pump operable and for the accumulators to be isolated. The proposed Conditions provide reasonable actions and allowances for completing them if the new LCO requirements are not met. The new actions provide adequate remedial measures or remove the plant from the Mode of Applicability. As such the new Conditions are applicable and appropriate to FNP. However, the addition of these Conditions and actions in the FNP TS represent new requirements not previously addressed by the TS. As such, the addition of these Conditions and Required Actions is considered a more restrictive change. 4a A The CTS action statement "a"is revised consistent with the STS by the deletion of the requirement to restore the inoperable valve to OPERABLE status. In the STS, restoration of a component / system to OPERABLE status is always an unstated option. Ifit is accomplished prior to the completion of the required actions, the LCO may be exited. Therefore, it is unnecessary to maintain CTS 3/4.4.10.3 action a. as it is always included by implication. There are three completion times associated with Condition D l j [gg in the FNP ITS. Required actions D.1 and D.2 have 24-hour completion times and Required Action D.3 has a completion time of 7 days, consistent i with the completion times of CTS Actions a.l.i, a.l.ii, and a.l.iii. If the inoperable valve is not restored to OPERABLE status within 24 hours, CTS actions a.l.i, a.l.ii, and a.l.iii would be applicable. As 24 hours are l i Chapter 3.4 E2-2-S February,1999 l
FNP TS Conversion
- Enclosure 2 - Discussion of Changes to CTS Chapter 3.4 - RCS CTS 3/4.4.10.3 OVERPRESSURE PROTECTION SYSTEMS 1 1
FNP ITS 3.4.12 LOW TEMPERATURE OVERPRESSURE PROTECTION SYSTEM ! DOC l HQ SEE DISCUSSION allowed in the CTS to restore the valve to OPERABLE status in the CTS, the completion time of required actions D.1 and D.2 (CTS actions a.l.i and
)
a.l.ii) is 24 hours. Required action D.3 has a completion time of 7 days l consistent with STS required action E.1 and CTS action a.l.iii. As these [A changes are made to revise the CTS to conform with the format and presentation of such information in the STS, and does not introduce a l technical change, it is considered administrative. 5 M The CTS action statement "b"is revised consistent with the STS. The additional plant conditions of other Required Actions or Completion Times not met and if the LTOP system is inoperable for any reason other than addressed by the other Actions Conditions are included in this CTS action statement. The inclusion of these additional plant conditions provide a comprehensive set of TS Conditions to address not meeting the LTOP LCO. The associated required action to depressurize the RCS and provide a vent path ensures RCS overpressure protection and places the plant in a safe condition. As such, the addition of these plant conditions to CTS Action statement "b"is applicable to FNP. However, as these conditions were not previously addressed in the CTS, this change is considered more restrictive. 6 A The CTS 3.4.10.3 action statement "c"is revised consistent with the format of the STS. The CTS action requires a special report be made in the event an RHR relief valve is used to mitigate an RCS pressure transient. In the STS, the special reports section (CTS 6.9.2) does not exist. As such, it is proposed to move this reporting requirement to the Monthly Operating Report (STS 5.6.4). The STS monthly operating report is required every 30 1 days and contains related information regarding challenges to pressurizer ; relief and safety valves. Therefore, the CTS reporting requirement for the RHR relief valves will be adequately addressed by inclusion in the monthly l operating report where other safety and relief valve reporting requirements reside. As this change is not intended to introduce a technical change and is made to confonn with the format and presentation of this infonnation in the STS, it is considered an admmistrative change. 1 ! 7 A The CTS specific action statement "d" is moved into the notes to the l applicability consistent with the presentation of similar information in the i STS. The CTS action statement contains a plant specific (not in STS) l l exception to Specification 3.0.4. As this change does not introduce a l l Chapter 3.4 E2-3-S February,1999
. .-- - .- .. - .- - - - - -.. - .-.- - - - - - . - .~ - -
. I i
. i
- FNP TS Conversion j Enclosure 5 - JD from STS i Chapter 3.4 - RCS l J
STS 3.4.12 LOW TEMPERATURE OVERPRESSURE PROTECTION (LTOP) SYSTEM FNP ITS 3.4.12 LOW TEMPERATURE OVERPRESSURE PROTECTION (LTOP) SYSTEM JD ) NUMBER JUSTIFICATION l must be limited. The FNP design consists of only two sets of ECCS pumps, the ! RHR pumps and the charging pumps. The only high pressure injection pumps j being the charging pumps. As such, only the injection capability of the charging i
. pumps is required to be limited for low temperature overpressure protection at FNP.
l Therefore, the STS conditions are revised to conform with the FNP design. This ' change also introduces editorial changes to the letter designations used to identify the Actions Conditions that follow this STS Condition. 5 The STS 3.4.12 Conditions E and F are revised to be consistent with the FNP CTS. The FNP CTS 3/4.4.10.3, Overpressure Protection, action statement "a" provides y additional remedial measures in the event a single required RHR valve is inoperable (proposed Required Actions D.1 and D.2) and maintains a 7 day restoration time in Modes 5 and 6 as well as Mode 4. Therefore, the words "in MODE 4" have been ; deleted from STS Condition E (ITS Condition D). The FNP CTS 3/4.4.10.3 actions { contained in action statement "a" provide additional assurance that an RCS pressure
]
transient will be rapidly identified and limited. Therefore, the STS Condition E (proposed FNP ITS Condition D) is revised by the addition of FNP specific actions consistent with the FNP CTS 3/4.4.10.3 action statement "a" and the STS Condition F with a 24 hour Completion Time is not applicable to FNP and is ; deleted. This change also introduces editorial changes to the letter designation used ] to identify the Actions Condition that follows this STS Condition. 6 The STS 3.4.12 surveillances SR 3.4.12.1 and SR 3.4.12.2 are revised to be consistent with the FNP design and CTS requirements. The STS 3.4.12 surveillances are written to accommodate all types of plants including those plants
- with 3 sets of ECCS pumps (RHR, Safety Injection, and Charging). In some plants the injection capability of both high pressure pumps (SI and charging) must be limited. The FNP design consists of only two sets of ECCS pumps, the RHR pumps and the charging pumps. The only high pressure injection pumps being the charging pumps. As such, only the injection capability of the charging pumps is
. required to be limited for low temperature overpressure protection at FNP.
Therefore, the proposed change to the STS (deletion of STS SR 3.4.12.1 and retention of STS SR 3.4.12.2) is consistent with the FNP design and CTS requirements for the charging pumps. l 7 The STS 3.4.12 surveillance SR 3.4.12.4 (FNP ITS SR 3.4.12.3) is revised to be consistent with the CTS. Editorial changes are made to the surveillance statement , to more closely match the CTS description. In addition, the frequency of the i surveillance is also revised from 12 hours to 72 hours to be consistent with the i i
. Chapter 3.4 E5 21 February,1999
Associated Package Changes for RAI- 18 l 4 l i I l t
.?
s [Or M Ifju'If reactor cootaNT syg7gg 47gggg g yg suRVE1LLANCE r$EQy!REMENTS
/
(4.4.10.31] Each RHR relief valve shall be demonstrated CPE LE by: gg l MF.0E*J Verifyinc)the RHR relief valve isolation valve 6701a, 870lb, 8702a) SR3.4.12 3 8 E d 8702bilare ooen at lamme anee eer ?? heuen h n th RHR relie T (va4ve fis bein4 used f or o/erpresh= ~- -~/{
. Testing in pu to e/f / eat [on MO:D [O 8 * * '
SR $,Q,l'[,6 Verification of the RHR relief valve setpoint, of at least one RHR relief valve, at least once per 18 months on a pcpiryg tps , S E I.Nell i Q .s.10.3.23 The Res vent shall be verified to be open at least once per 12 hours
- when the vent is being used for overpressure protection.
$TA6669,6 !
A rasr u sis CAck pmule or /d [50 g 3,4,/2,2 Veri l a ha"
, , - seg ig m
---) sa s.411.1 see mnkop of f llo owi g p9e (crs4.1.2.3.2.. )
l l ll 8 I l ? l 1 l [
- Except when the vent pathway is provided with a valve which is locked, SR 3.4.ll Y sealed, or otherwise secured in the open position, then verify these N'
valves open at least once per 31 days. l r FARLEY-UNIT 1 jf4 4 33 AMENDMENT NO. 26
FNP TS Conversion
. Enclosure 2 - Discussion of Changes to CTS Chapter 3.4 - RCS CTS 3/4.4.10.3 OVERPRESSURE PROTECTION SYSTEMS FNP ITS 3.4.12 LOW TEMPERATURE OVERPRESSURE PROTECTION SYSTEM DOC t HQ SHE DISCUSSION and fonnat of the STS.
10a M CTS 3/4.4.10.3 is revised by the addition of a new surveillance, SR 3.4.12.2, related to new Actions Conditions B and C consistent with the STS. The proposed surveillance addresses the new LCO requirement for the accumulators to be isolated. The proposed surveillance provides M reasonable requirements for ensuring compliance with the new LCO. As such, the new surveillance is applicable and appropriate to FNP. However, l the addition of this surveillance in the FNP TS represents a new l requirement not previously addressed by the TS. As such, the addition of l this surveillance is considered a more restrictive change. I1 A The CTS surveillance 4.1.2.3.2 from the Reactivity Control Systems I Chapter is moved into the RCS over pressure protection LCO consistent with the STS as SR 3.4.12.1. The CTS 4.1.2.3.2 surveillance addresses the requirement that only one charging pump may be capable ofinjecting into the RCS when one or more cold leg temperatures is less than or equal to
~1 80 *F. This requirement is related to low temperature RCS pressure control and therefore belongs with the LTOP system TS. The CTS surveillance is also revised to change inoperable to incapable ofinjecting into the RCS consistent with the STS. As the CTS requirement to render the pump inoperable was intended to prevent injection into the RCS and the possible overpressure condition that injection might cause, the STS term of
" rendering the pump incapable ofinjecting into the RCS" effectively accomplishes the same thing as the CTS (inoperable) but defines the 3 requirement more precisely. In addition, this CTS surveillance is also !
revised to remove the reference to the stated Mode of Applicability (except when the reactor vessel head is removed) consistent with the STS. As the proposed FNP ITS 3.4.12 applicability excludes this specific condition (head removed) it is not necessary to repeat the Mode of applicability in the surveillance requirements. As such, the movement of this surveillance to the RCS chapter and revisions described above do not introduce technical changes and are considered administrative in nature. 12 LA The CTS surveillance 4.1.2.3.2 (from the Reactivity Control Systems Chapter) is further revised, consistent with the STS, to remove the specific means by which a charging pump is rendered incapable ofinjecting into the RCS. The CTS surveillance specifies that the motor circuit breakers are Chapter 3.4 E2-5-S February,1999
l I i
- 1
. 1 i
i l l i I 1 l 1 l l Associated Package Changes for RAI- 22 , 1 1 l I i l l l l 1 I 1 I I I I I 1 ! I l l l t
1 FNP TS Conversion Enclosure 2 - Discussion of Changes to CTS , Chapter 3.4 - RCS CTS 3/4.4.7.2 OPERATIONAL LEAKAGE UNIT I AND 2 i t FNP ITS 3.4.13 RCS OPERATIONAL LEAKAGE FNP ITS 3.4.14 RCS PRESSURE ISOLATION VALVE LEAKAGE l FNP ITS 3.5.5 ECCS SEAL INJECTION FLOW ; DOC NQ SEE DISCUSSION 1 A The CTS 3/4.4.7.2.e LCO requirement for Controlled Leakage is revised consistent with the STS. The requirement for Controlled Leakage is moved into the new STS LCO 3.5.5 Seal Injection Flow in the ECCS section of the TS. As any changes to this requirement are addressed in the FNP STS - conversion documentation associated with section 3.5 of the TS, the i movement out of this CTS LCO is considered an administrative change made to conform with the presentation and format of the STS. , 2 A The CTS 3/4.4.7.2.f LCO requirement for pressure isolation valve (PIV) l leakage is revised consistent with the STS. This LCO requirement is moved into a separate LCO (3.4.14) for PIV leakage. The requirement is simplified consistent with the format and presentation of the STS. The ; reference to Table 3.4-1 is removed from the LCO and the STS phrase i "within limits"is substituted. The reference to the required RCS pressure is also removed from the LCO. The leakage limits and required RCS pressure - are stated in the STS surveillance SR 3.4.14.1. CTS Tabic 3.4-1 lists Reactor Coolant System pressure isolation valves with nominal valve sizes ranging from 6 inches to 12 inches. Two limits for allowable leakage criteria are listed in CTS 4.4.7.2.2; (1) 0.5 gpm per inch of nominal valve size and, (2) an upper limit of the maximum allowable leakage in Table 3.4-
, p- 1. For example, using only the first criteria, a six-inch valve would have a limit of 3 gpm, a 10-inch valve would have a limit of 5 gpm, and a 12-inch valve would have a limit of 6 gpm. The valves listed in Table 3.4-1 with a maximum allowable leakage of 3 gpm are 6-inch valves, consistent with the limit of 0.5 gpm per inch of nominal valve size. The Table has a maximum limit of 5 gpm for all larger valves (10 and 12 inch). In each case, the more i i
restrictive of criteria 1 or 2 are used for maximum allowable leakage. Therefore, the ITS SR 3.4.14.1 requirement to " verify leakage from each
- j. RCS PIV is equivalent to s 0.5 gpm per nominal inch of valve size up to a j
maximum of 5 gpm at an RCS pressure 2 2215 psig and s 2255 psig"is ! equivalent to the CTS requirements for all valves listed in Table 3.4-1. As , i ~ this change reorganizes the LCO statement to conform with the STS and l t does not introduce a technical change, it is considered administrative. Chapter 3.4 E2-1-N February,1999
.= - -- . .
Associated Package Changes for RAI - 24
UOIT1 NOTE: THE REQUIREMENTS OF THE CURRENT
. TS FOR OPERATIONAL LEAKAGE ARE 7
J.'i react 0o COOLANT SYSTEM h DMDED INTO THREE TS IN THE STS. OPERATIONAL LEAKAGE (LCO 3.4.13).
~,Y, t.7 P.C 3 OPERATIONAL LEAKAGE PRESSURE ISOLATION VALVE LEAKAGE (LCO 3.4.14), AND SEAL INJECTION LIMITING CONDITION FOR OPERATION FLOW (LCO 3.5.5).
........y............................................................... -
3' ' O Q.4.7.2) Reactor Coolant Systes leakage shall be 11ef ted to:
- a. No PRESSURE B0UNDARY LEAKAGE,
- b. 1 GPM UNIDENTIFIED LEAKAGE, I
C8+#- 420 gallons per day total primary-to-secondary leakage through all steam generators and 140 gallons per day through any one steam generator, g C. kA 10 GPN IDENTIFIED LEAKAGE from the Reactor Coolant System, and Lco 35.{g
=
- e. 31 GPM CONTROLLED LEAKAGE at a Reactor Coolant System pressure of 2235 s 20 psig. Y N' .N*I f. The maximum allowable leakage of any Reactor conlant tvtta= F t.to3.ll.1Y INSEf.T #
b i ted/in u piy hatapressureof2235 Pressure Isolation Yalve shall be M spec /If 7/ble E J.4-M t.ca 3,4. lY AGA0N zopsig7 g NOTES .PPL IC ABIL ITY ? MODES 1, 2, 3 and 4 (r-{s5EitT G 1.cc J4/Yoyojobcebthh 4 ACTION
- d$rn With any PRESSURE 80VNDARY LEAKAGE, be in at least HOT p g hng STAN08Y following 30within 4 hours and in COLD SHUTDOWN within the hours.
2 With any Reactor Coolant Systes leakage greater than any on
'A INstRTI QanttT8 6 1 A of the above limits, excluding PRESSURE 800NDARY LEAKAGE, l. '
LL8344 g reduce the leakage rate to within limits within 4 hours or be g in at least NOT STAN08Y within the next 6 hours and OlfloN COLO g SHUTDOWN.within the following 30 hours. C With any# eactor R Coolant System Pressure Isolation Va ve
--> TRM b ZNSfCT7 5 Loo 3 4.84 CondMorg 4- F 1.akage greater than the Itaitgpecmea in 1 bie 3.4-0 Mk'.k 8% '
isola e the high pressure portion or the arrectea system from th i ou pressure portion within 4 hours by use ofydt least closed manual or deactivated automaticivalvgf.her be in g M LCo3.4.,9 a Coreho65% SHUTDOWN within the following 30 hours.least -v NOT STAN08Y with z 6 SURVEILLANCE IREMENTS % r ucos.ex '\
.................................l..............Mnemoric.
L 4.4.T.2.1 Reactor Coolant System leakages shall be demonstrated to be 7 within each of the above limits by: @> I-Monitoring the containment atmosphere particul - 9 radioactivity monitor at least once per 12 hours TAT-2.f b. Monitoring the. containment air cooler condensate level system or containment atmosphire^ gaseous radioactivity monitor' at least once per 12 hours. '
' ~ " ' ~ '
FARLEY . UNIT 1 3/4 4-17 AMEN 0 MENT No. IJ, ga u n 'l T 1 -
FNP TS Conversion Enclosure 2 - Discussion of Changes to CTS Chapter 3.4 - RCS CTS 3/4.4 71 OPERATIONAL LEAKAGE UNIT 1 AND 2 FNP ITS 3.4.13 RCS OPERATIONAL LEAKAGE FNP ITS 3.4.I'4 RCS PRESSURE ISOLATION VALVE LEAKAGE FNP ITS 3.5.5 ECCS SEAL INJECTION FLOW DOC NQ SHE DISCUSSION verified to meet the LCO leakage limits. 8 lM A new action is added to the CTS 3/4.4.7.2 actions for an RCS PIV that does not meet the leakage limits based on the actions of the STS. Proposed Condition C of the new PIV leakage LCO 3.4.14 applies to an inoperable RHR valve autoclosure interlock and has been added to the PIV TS to explicitly address this type of PIV inoperability and provide appropriate actions. The actions and completion times proposed for this new condition are similar to the existing actions for an inoperable PIV except that only one isolation valve is required to be closed and maintained closed under administrative control. This difference is required due to the location of the M breakers for the associated valves and dose that plant personnel would receive when restoring power to the valves in the event of a small break LOCA. As the action addresses an inope.rable interlock and not valve leakage, and the STS actions Notes require the applicable Conditions and actions of any affected system made inoperable by the inoperable PIV to be entered, the proposed action for an inoperable autoclosure interlock is acceptable. As the addition of this new Condition in the FNP TS represents a new requirement not previously addressed by the TS, the addition of this Condition is considered a more restrictive change. 9 L The CTS 4.4.7.2.1.a and .b that require the leak detection particulate and gaseous radiation monitors and containment air cooler condensate level to be monitored every 12 hours are deleted consistent with the STS. The particulate and gaseous radioactivity monitors will continue to be checked 1 every 12 hours by the Channel Check surveillance requirement SR 3.4.15.1 in the RCS Leakage Detection TS LCO 3.4.15. The containment air cooler condensate level monitor receives a Channel Calibration every 18 months per SR 3.4.15.4 in the RCS Leakage Detection TS LCO 3.4.15 and provides an alarm in the control room to alert the operators to an increase in condensate level. The 18 month channel calibration requisneut is adequate for instrumentation used for indication and monitoring. As the radioactivity monitors provide a more immediate response to RCS leakage and will continue to be monitored every 12 hours, and the fact that an Chapter 3.4 E2-4-N February,1999
Associated Package Changes for RAI- 25 l l
)
i 4
- 1 CHAPTER 3.4 .
j INSERT L NOTES TO CTS 4.4.7.2.1.d SURVEILLANCE AND FREQUENCY l NEW RCS OPERATIONAL LEAKAGE TS LCO 3.4.13 SR 3.4.13.1 l: i Surveillance NOTE - ----. . . j Not required to be performed in Mode 3 or 4 until 12 hours of steady state operation. ! Frequency j __ NOTE -- ----- - - - - - - - - i Only required to be performed during steady state operation. I t INSERT M NOTES TO CTS 4.4.7.2.2 SURVEILLANCE NEW RCS PIV LEAKAGE TS I LCO 3.4.14 SR 3.4.14.1 ! NOTES--.-- -- -------- l
- 1. Not required to be performed in Modes 3 and 4.
- 2. Not required to be performed on the RCS PIVs located in the RHR flow path when in the ,
shutdown cooling mode ofoperation.
- 3. RCS PIVs actuated during the performance of this Surveillance are not required to be tested
, more than once if a repetitive testing loop cannot be avoided. l ___ .____._ .. .
%E- 15 i
! INSERT N NOT USED
\
Cbpter 3.4 Insert Pcge l l
1 o FNP TS Conversion c Enclosure 2 - Discussion of Changes to CTS Chapter 3.4 - RCS CTS 3/4.4.7.2 OPERATIONAL LEAKAGE UNIT 1 AND 2 FNP ITS 3.4.13 RCS OPERATIONAL LEAKAGE FNP ITS 3.4.14 RCS PRESSURE ISOLATION VALVE LEAKAGE FNP ITS 3.5.5 ECCS SEAL INJECTION FLOW DOC NO SJLE DISCUSSION water inventory balance is the definitive method to determine RCS leakage and accounts for the reactor head flange leakoff, the deletion of this separate surveillance does not significantly impact the operators ability to detect RCS leakage. 13 A The CTS 4.4.7.2.2 surveillance for the leakage testing of RCS Pressure l Isolation Valves (PIV) is modified by 3 notes consistent with the STS and the CTS. Note I corresponds to CTS 4.4.7.2.2.d and allows entry into y Modes 3 and 4 to perform this SR. Since in the STS there are no exceptions to SR 3.0.4 CTS 4.4.7.2.2.d is revised consistent with the STS. I Notes 2 and 3 are consistent with the STS and provide detailed guidance and clarification for performing PIV leakage tests that is consistent with the operational requirements of the plant and the need to provide a reliable means of decay heat removal. Note 2 which provides an exception for PIVs in the RHR flow path during the shutdown cooling mode of operation is also consistent with the
- footnote to CTS Table 3.4-1 which serves as an exception to the PIV leak test requirements (4.4.7.2.2.c) following actuation or flow through the valves for valves used in the RHR flow path. As such, the addition of these notes are considered an administrative change consistent with the CTS or providing clarifications consistent with the STS.
14 LA CTS Table 3.4-1 containing a list of the RCS PIVs is removed from the CTS consistent with the STS. The actualleakage limits are retained within the proposed ITS surveillance SR 3.4.14.1 :onsistent with the STS. The removal of equipment / component lists from the TS is consistent with previous generic guidance from the NRC and consistent with the philosophy of the STS, that the TS contain only the essential requirements for safe operation of the plant. As such, the CTS Table will be moved into the Technical Requirements Manual (TRM). Placement of this information in the TRM is acceptable based on the level of change control provided by the 10 CFR 50.59 process that will be applied to the TRM. l 15 LA CTS 4.4.7.2.2 is revised to delete references to the requirements of f 1 Specification 4.0.5 consistent with the STS. In the STS,4.0.5 does not Chapter 3.4 E7.-6-N Febmary,1999
Associated Package Changes for RAI- 27 l 1 1 l i l l i
CHAPTER 3.4 .-
#/ l INSERT J -
TO CTS 3.4.7.2 ACTION C . j NEW PRESSURE ISOLATION VALVE TS 1 LCO 3.4.14 REQUIRED ACTION A.2 j i AND A.2 Isolate the high pressure portion of the affected system from the low pressure portion by ! use of a second closed manual, deactivated automatic, or check valve. In 72 hours. ! i INSERT K i TO CTS 3.4.7.2 ACTIONS ! NEW PRESSURE ISOLATION VALVE TS . LCO 3.4.14 CONDITION C ! CONDITION REQUIRED ACTION COMPLETION TIME C.' RHR System autoclosure C.1 Place the affected valve (s)in 4 hours ! interlock function the closed position and inoperable, { maintaiu closed under ' administrative control. , PAC" 27 l 1 1 Chapter 3.4 Insert Page 1 J
l l FNP TS Conversion l
, Enclosure 2 - Discussion of Changes to CTS I Chapter 3.4 - RCS CTS 3/4.4.7.2 OPERATIONAL LEAKAGE UNIT 1 AND 2 FNP ITS 3.4.13 RCS OPERATIONAL LEAKAGE FNP ITS 3.4.14 RCS PRESSURE ISOLATION VALVE LEAKAGE FNP ITS 3.5.5 ECCS SEAL INJECTION FLOW DOC NO SHE DISCUSSION as in Mode 2 (defined as STARTUP in CTS Table 1.1). As such, these changes are considered administrative in nature.
19 LA The CTS surveillance 4.4.7.2.2.b requires post maintenance testing on RCS PlVs and is removed from the TS consistent with the STS. In the STS, post maintenance testing is not explicitly required. However, the TS definition of operability and the general requirements of TS that LCOs must ' be met or actions taken, provide assurance that upon returning equipment to service appropriate testing is required to declare that equipment operable and any applicable LCO met. As such, the post maintenance testing requirement for the RCS PlVs is moved to the TRM. Placement of this information in the TRM is acceptable based on the level of change control provided by the 10 CFR 50.59 process that will be applied to the TRM and considering the basic TS requirements for equipment operability described above. 20 A The CTS surveillance 4.4.7.2.2.c which requires RCS PIV leakage to be verified after valve actuation is revised to be consistent with the STS. The l CTS requirement is a frequency and has been moved into the frequency section of the STS SR 3.4.14.1. As these changes only reorganize the l i requirements of this TS they are considered administrative. 21 A A surveillance (SR 3.4.14.2) is added to the TS requirements for RCS PIVs consistent with the STS. This surveillance verifies the RHR system autoclosure interlock functions to close the RHR/RCS isolation valves on high RCS pressure. This surveillance requirement corresponds to the CTS surveillance 4.5.2.d.l. As this surveillance involves RCS PIVs, the STS places this requirement in the RCS PIV LCO. Since this change only l reorganizes the TS requirements to conform with the presentation and )
- format of the STS it is considered administrative. !
l 21a M The CTS surveillance 4.4.7.2.2 is revised consistent with the STS. A new surveillance (ITS SR 3.4.14.3) is added to the TS requirements for RCS gd PIVs consistent with the STS. This surveillance verifies the RHR system Chapter 3.4 E2-9-N February,1999 l l
FNP TS Conversion Enclosure 2 - Discussion of Changes to CTS Chapter 3.4 - RCS CTS 3/4.4.7.2 OPERATIONAL LEAKAGE UNIT 1 AND 2 FNP ITS 3.4.13 RCS OPERATIONAL LEAKAGE FNP ITS 3.4.14 RCS PRESSURE ISOLATION VALVE LEAKAGE FNP ITS 3.5.5 ECCS SEAL INJECTION FLOW DOC NO SHE DISCUSSION open permissive interlock functions to prevent the RHR/RCS isolation valves from opening above a certain RCS pressure. As the addition of this
/L1 new surveillance in the FNP TS represents a new requirement not previously addressed by the TS, the addition of this surveillance is considered a more restrictive change.
22 A A surveillance (SR 3.4.13.2) is added to the TS requirements for Operational Leakage consistent with the STS. This surveillance requires compliance with the Steam Generator Tube Surveillance Program. The CTS LCO for steam generators was removed from TS (discussed previously) and the tube inspection requirements moved intact to an administrative controls program in the TS. As such, the new surveillance in the Operational Leakage TS ensures compliance with the administrative controls program in the same manner as the previous LCO for steam generators ensured compliance with its associated surveillance requirements. This change reorganizes the CTS requirements to conform with the presentation and format of the STS and is considered administrative. 23 A CTS 4.4.7.2.2.d takes exception to the requirements of Specification 4.0.4 for the purposes of testing RCS PIVs. Since the STS does not provide for exceptions to SR 3.0.4 this requirement is expressed as a note in the corresponding STS surveillance SR 3.4.14.1 which simply states the surveillance is not required in Modes 3 and 4. As the STS note provides an allowance for testing in Modes 3 and 4, it effectively accomplishes the same thing as the CTS exception to the provisions of 4.0.4 was intended to do. Therefore, this change is made only to conform with the presentation and format of this information in the STS and is considered administrative. 24 A The CTS
- footnote to Table 3.4-1 is deleted consistent with the STS. The footnote is used to modify CTS surveillance 4.4.7.2.2.c and identifies valves for which the surveillance is applicable (valves which are not in the RHR flow path). CTS surveillance 4.4.7.2.2.c requires leak testing RCS Pressure Isolation Valves (PIVs) following actuation or flow through the 1
Chapter 3.4 E2-10-N February,1999
_ _._____m .
', 196 4N ACTIONS CONDITION REQUIRED ACTION COMPLETION TIME A. (continued) A.1 Isolate the high 4 hours pressure portion of l the affected system
' from the low pressure portion by use of one closed manual, deactivated automatic, or check ; valve. n - ,
.2 Isolate the high 72 hours (f (p l pressure portion of the affected system from the low pressure portion by b ^'8 M o $ cded los d ma a '
vehe(s)in 4ht deactivated automatic, or check I eg, g,4,g g j MdnbM c\osed L j l unAte oAmiksb%c
/ l A Restore CS PIV to 72 hour within imits.
l B. Required Action and B.1 Be in MODE 3. 6 hours ) associated Completion ! Time for Condition A ANQ not met. Be in MODE 5. 36 hours s' open pewssw)B.2 Y -=w /-
- b -
\
j
. RHR System autoclosure C.1 }_solate the affected' 4 hours l interlock function penetration by use of i
inoperable. one closed manual or
/deactivatedautomatig I
valve. f e l i l l WOG STS 3.4-36 Rev 1, 04/07/95 L _
l RCS PIV Leakage gy 3.4.14 SURVEILLANCE REQUIREMENTS SURVEILLANCE FREQUENCY
- SR 3.4.14.1 (continued) 5 in 2 noor,/ !
l h lowing valve actuation due l to automatic or I manual action or flow through T/p the valve SR 3.4.14. [---------------e---N O TE-------- --- -----
]
( J ot reauired to be met when the RSystem Gutnelosure interlock is disable in
$5 _$$$_5 __ __ '
- N ____ -----
y' 0
,PWesem(sive.
Verify RHR System [utoclosurdrinterlock 18 months prevents the valves from being opened with a simu te r actual RCS pressure l signal k 425 sig. . _ 2*15'e s f u 6 f is -[
~~v
@ SR 3.4.14.
- 4
-------------------NOTE--------------- ----
l Not reautred to be met when the_RHR ystem
~
c ' l l gyq-lyes cautoclosure interlock is d- sabled in
"- $$$_ _$$ .5)I . I I __ ------- l requirecl., Of l open Verify RHR System autoclosure interlock :18 months causes the valves to close 4 automatically with a si u ated or actual RCS pressure signal 2 600 psig.
cp - 700gssg caAd 6 750 2 l l WOG STS 3.4-38 Rev 1, 04/07/95
FNP TS Conversion Enclosure 5 - JD from STS Chapter 3.4 - RCS STS 3.4.14 RCS PRESSURE ISOLATION VALVE (PIV) LEAVdGE FNP ITS 3.4.14 RCS PRESSURE ISOLATION VALVE (PIV) LEAKAGE JD NUMBER JUSTIFICATION I The STS LCO 3.4.14 Condition A actions allow a choice of actions to be made for Required Action A.2. The FNP CTS allow continued operation when the affected flow path is isolated by two valves. As such the first A.2 Required Action is applicable to FNP and more consistent with the CTS than the second Required Action A.2. la The STS 3.4.14 Note in Condition A is revised consistent with the corresponding CTS requirements. The STS note requires that valves used to satisfy Required , Action A.1 or A.2 must have been verified to meet SR 3.4.14.1 and be in the reactor ' coolant pressure boundary or the high pressure ponion of the system. The , I corresponding CTS requirements do not specify that valves used to isolate the high pressure portion of the system from the low pressure portion be previously tested. 1 The FNP CTS Actions and the corresponding STS Actions require that the valves used to meet the Action isolate the PIV leakage. Failure to isolate the leakage (meet the requirements of the LCO)is failure to meet the Action requirements of Condition A and would result in entry into Condition B and a plant shutdown. Since in order to meet the isolation Actions, the leakage must be monitored after the isolation valves are closed and verified to be within the LCO limits, the FNP cunent practice effectively verifies the isolation capability of the valves when they are actually used to meet the Action requirements. The FNP current practice and , CTS requirements are adequate to address PIV leakage and the deletion of the STS requirement to only use valves previously tested per SR 3.4.14.1 is consistent with the FNP current licensing basis. 2 The STS SR 3.4.14.2 (FNP ITS 3.4.14.3) is revised consistent with FNP terminology for the RHR isolation valve open permissive interlock function. The FNP-specific RCS pressure range for the open permissive interlock is inserted in place of the single value in the STS. 3 The STS SR 3.4.14.1 frequencies on page 3.4-37 of the PIV Leakage TS are revised ) to be consistent with the FNP CTS for PIV leakage testing. The STS frequencies N[ on page 3.4-37 are revised to be consistent with the CTS surveillance requirements of 4.4.7.2.2.a and 4.4.7.2.2.d. i l 4 The STS surveillances 3.4.14.2 and 3.4.14.3 (FNP ITS SR 3.4.14.3 and 3.4.14.2), which verify the operability of the RHR/RCS open permissive and autoclosure pressure interlocks are revised consistent with the FNP CTS. The STS notes modifying SR 3.4.14.2 and SR 3.4.14.3 are revised to reflect the conesponding i FNP CTS requirements located in FNP ITS SR 3.4.12.3 in lieu of the STS reference t Chapter 3.4 E5-1-K February,1999
FNP TS Conversion
. Enclosure 5 - JD from STS Chapter 3.4 - RCS to SR 3.4.12.7. The FNP CTS does not contain a surveillance that corresponds to STS SR 3.4.12.7, which requires that the RHR valves be locked open and de-M energized. Therefore, STS 3.4.12.7 has been deleted from the FNP ITS. The FNP L
(2A ITS SR 3.4.12.3 is associated with the low temperature overpressure protection TS and requires the RHR isolation valves to be verified open. This FNP ITS SR l replaces SR 3.4.12.7 in the notes and corresponds to the FNP CTS low temperature overpressure protection TS surveillance requirement (4.4.10.3.1.a). As such, this l change revises the STS surveillance notes to be consistent with the corresponding requirements in the FNP CTS. 5 The STS surveillance 3.4.14.1 frequency is revised consistent with the FNP CTS. In the FNP CTS, there is no time limit associated with the PIV testing performed as I a result of valve actuation or flow through the valve. At FNP, there is no installed I test system to test these valves. The valves are tested locally at specified plant conditions. If flow were passed through these valves under certain conditions, the 24-hour time limit would not allow enough time to establish test conditions and I perform the test. Deleting the 24-hour time limit revises the STS consistent with FNP design and current licensing basis. l 6 The STS LCO 3.4.14 Condition C action is revised to address an FNP-specific l design feature. At Farley, the location of the electrical switchgear containing the breakers for the RHR isolation valves is subject to very high dose rates in the event of a small break LOCA. Therefore, complying with the Required Action of STS Condition C of LCO 3.4.14 would place the plant in a condition where, should a small break LOCA occur, the plant could not be placed on normal RHR without unacceptably high exposures to plant personnel. To address the issue of dose during a small break LOCA, the Required Action of Condition C has been revised to require isolation of the valves under administrative controls from the control . room to allow establishment of RHR operation, should it be required, without , I unacceptable dose to plant personnel in the event of a small break LOCA. In addition, the statement of the condition has been revised to reflect FNP-specific terminology for the associated interlocks. h I W j Chapter 3.4 E5-2-K Febmary,1999
i RCS PIV Leakage
, p B 3.4.14 8ASES ACTIONS B.1 and B.2 (continued) within 6 hours and M00E-5 within 36 hours. This Action may reduce the leakage and also reduces the' potential for a LOCA outside the containment. The allowed Completion Times are reasonable based on operating experience, to reach the required plant conditions from full power conditions in an
/\ orderly manner and without challenging plant systems.
-6 U we spVdih.of reeAeo N. ssE, Md MR RAeven sucbpermissse ism.iw whesinblo mc *b\e.
3; inoperabil autoc osure nterTockTdmfe l RHR suction isolation valves incapabl of isolating in reventing'
, response to a high pressure condition, ort. inadvertent opening of the valves at RCS pressures in excess .
._ f the RHR r ems design pressure. If the RHR autoclosure 1.nterloclGd operable, operation may continue as lona as' '
the affected'RHR suctio3/ penetration is closed by2t leas i
,6n! closed manuas nr nametivated mutamatie valve >within
('4 aours. Th s Action acconnlishac the purpose of the i h c Ett pC y inn cdely'm h aw6WnM+ hem cbsed (e.33 gs SURVEILLANCE S ..Y' REQUIREMENTS Performance of leakage testing on each RCS PIV or isolation valve used to satisfy Required Action A.1 and Required l Action A.2 it required to verify that leakage is below the l specified limit and to identify each leaking valve. The !
--' ". leakage limit of 0.5 gpm per inch of nominal valve diameter l 4., 3 #
- up to*5 gpa maimum applies to each valve. Leakage testing i
requires a stable pressure condition. ( For the two PIVs in series, the leakage requirement applies i to each valve individually and not to the combined leakage across both valves. If the PIVs are not individually leakage tested, one valve may have failed completely and not be detected if the other valve in series meets the leakage requirement. In this situation, the protection provided by redundant valves would be lost.
. Testing is to be performed every/ months, a tvnical refueling cycle.Ette olent coe; not ao'inth M00E/5 fsfr at) 4 OM Qdstg dpy.fThe 18 mont Frequency is consistent with (continued)
WOG STS B 3.4-83 Rev1,04/07/95
. 1 J
, CHAPTER 3.4 3 i 1
INSERT FA '
~ TO STS BASES PAGE B 3.4-83 ACTION C.1 l FNP-SPECIFIC ITS DESCRIPTION Note to Operators: The location of the electrical switchgear containing the breakers for the RHR ;
isolation valves is subject to very high dose rates in the event of a small break LOCA. Therefore, . opening the breakers for the RHR isolation valves would place the plant in a condition where, ; should a small break LOCA occur, the plant could not be placed on normal RHR without I unacceptably high exposures to plant personnel. To address the issue of dose during a small break LOCA, the Required Action of Condition C requires isolation of the valves under
. administrative controls from the control room to allow establishment of RHR operation, should it be required, without unacceptable dose to plant personnel in the event of a small break LOCA F4t-27 )
l l
)
I l 1 I I I
)
i
- i i
l i I-I Chapter 3.4 Insert Page
I
- ht-
. 7Q p,oto c.Leaur trderlec_k. RCS PIV Leakage
. 1 isota.;fes the F4M sysfern B 3.4.14 V
nm frornthe. AC.S tohen JTheNN* cQ h BASES inkrLee_k. 6efpoint 15 T
) -s A_~
7 / SURVEILLANCE ~ R l.4.14.2 MR 3.4.14.3) (continued) o P ' ~ RE IREMENTS Noened is set so thefactual RCS pressureXst be) o l PSC. (< 425] psic to ooen the valves 1/ ThfJisetpoint ensures th_e f i m( desian cressurtwijl notfe exceeded.Gnd the RHR relief) & The SR is Malves will not liftf;The $18 mont Frequency is based on need to perform the Survet la r conditions that mod.dieckb gofe /hs.t ' oMalso appl acc ring a plant outage. The month Frequency is table based on considerat on of the design a gg qf l fhe r wrem.p . reliabilit equipment. and confirming operating experience) of the t So rickflC-C F These/SRs are/modif%d by Wotes allhwina t'he RHR/autocAosuFe) ; Juncilion to ve disabledrwh'en using the RHR System suction g5CIS relief valves f r cold overpressure protection in accordance with SR 3.4.12 . _ l w .. REFERENCES 1. 10 CFR 50.2.
- 2. 10CFR50.55a(c).
- 3. 10 CFR 50, Appendix A, Section V, GDC 55.
- 4. WASH-1400 (NUREG-75/014), Appendix V, October 1975.
- 5. NUREG-0677, May 1980. n((.' ' ,
- 6. (DocumentcontaininglistofPIVs]
TRM)
- 7. ASME, Boiler and Pressure Vessel Code, Section XI.
- 8. 10CFR50.55a(g).
1 WOG STS B 3.4-85 Rev 1, 04/07/95
. - . . .- - - - - . . . - , - - . . - _ - . . - - - . . . . . . - ~ . . . - .
= . :
w i
~ CHAPTER 3.4 -
52.a, t INSERT GA; T/g TO STS BASES PAGE B 3.4-85
.l N SR 3.4.14.3 i
.i FNP-SPECIFIC ITS BASES DISCUSSION 1 i
SR 3.4.14.3 i L , Verifying that the RHR open permissive interlock is OPERABLE ensures that the RCS will not pressurize the RHR system beyond design of 600 psig.' The open . permissive interlock prevents opening the RHR System suction valves from the RCS I when the RCS pressure is above the setpoint. The setpoint upper /alue ensures the ! RHR System design pressure will not be exceeded at the RHR rump discharge and - i l -was chosen taking into account instrument uncertainty and cahbration tolerances. ; This value also provides assurance that the RHR System suction relief valves ; ! setpoint will not be exceeded. The minimum value of the setpoint range is chosen ! based up operational considerations (differential pressure) 6 the RCP seals and thus l
- does not have a safety-related function. The 18 month Frequency is based on the ;
l need to perform the Surveillance under conditions that apply during a plant outage. ! The 18 month Frequency is also acceptable based on consideration of the design l reliability (and confuming operating experience) of the equipment. l The SR is modified by a Note that provides an exception to the requirement to perform this surveillance when using the RHR System suction relief valves for cold i overpressure protection in accordance with SR 3.4.12.3. l i 1 l l } l 1 L L 1 l I l 1 i l 1 [s I Chapter 3.4 Insert Page y
1 e 1 l 1 9 Associated Package Changes for RAI- 32 i 1 1 I l l I i f l l
7 A - 9 - l A TABLE 4.4-4 _ -- - - M tyTC - -- -- " PRIMARY COOLANT SPECIFIC ACTIVITY SAMPLE L-og4.nneA n g gwsdA %f la FA0W % AND ANALYSIS.. PROGRAM
~/ 5 g . _ _ - - - - - - -
g g T EO MENT SAMPLE AND ANALYSIS MODES IN WHICH SAMPLE I q AND ANALYSIS FBROUENCY AND AM,\ LYSIS REOUIRED
' SRsq,y,,[._GrossActivityDetermination / d At least ones per Q2_had_r3 1, 2, 3, 4 w Sg, 2. Isotopic Analysis for DOSE @' 1 per 14 days' q 1 3,ig,y,, 2_ EQUIVALENT I-131 Concentration 4 ,
SR. 3.4.4.3Q. Radiochemical Determinstton for j 1 Per 6 monthe*] 10 W I [g p,g #4 to 4. sotopic Analysis for Iodine ] Ia') Once per 4 hours, 1#, 2#, 3#, 4#, 5# A nluding I-131. I-133. and I-139 whenever the specific
? activity exceeds 0.15 0 1 PC1/grasa DOSE EQUIVALENT
\"2. , g I- 31 or 100/E pC1/ gram, z
- NcTIE - - - - b) Onesamplebetween2and] 1,2,3 6 hours frillowing a On repM b M THERMAL POWER change SJ Fer LA b 'AODE 1 51t 3.9. %.7- exceeding 15 percent of f L3 @\
~~---'----
the RATED THERMAL POWER ("L g
, within a one hour periody P
It heb s.n
. ' y bu 5%
L A.\ on1 (/_Until the specific activity of the crimary coolant system is restored within its limits) b.)
- sample to be taken fter a minimum of 2 EFPD and 20 days of POWER O?ERATION have elapsed since reactor
- y _
was last subcritica for 48 hours or long&r. in teoDE.1
--> SR 3. 4. S . 3 , g
- NOTC i
_ . . _ _ _ .___._._._________.________________._____m_. _ _ _ _ _ . _ _ _ _ _ _ _ _ . _ _ _ _ _ _ _ _ -. .- - . - - -
FNP TS Conversion Enclosure 2 - Discussion of Changes to CTS Chapter 3.4 - RCS CTS 3/4.4.9 RCS SPECIFIC ACTIVITY FNP ITS 3.4.16 RCS SPECIFIC ACTIVITY DOC ! NO SHE DISCUSSION i are revised consistent with the STS. The
- footnote is incorporated into the l surveillance requirement. In addition, the CTS applicable Mode for this surveillance from Table 4.4-4 (Mode 1) is also incorporated directly into the j surveillance requirement. These changes are made to conform with the format and presentation of this information in the STS and are not intended to introduce a technical change to the CTS requirements. As such, these )
changes are considered administrative in nature. 1 10a M Table 4.4-4 surveillance requirement 4 is revised consistent with the STS. j ITS SR 3.4.16.2 states: " Verify reactor coolant DOSE EQUIVALENT l- j 131 specific activity s 0.15 pCi/gm." DOSE EQUIVALENT I-131 is defined in the TS as that concentration ofI-131 (microcuries/ gram) that alone would produce the same thyroid dose as the quantity and isotopic ysp mixture ofI-131, I-132, I-133, I-134, and I-135 present. Therefore, f performing an analysis for DOSE EQUIVALENT I-131 includes I-131, I-133, and I-135. The surveillance performed to comply with the ! requirements of Table 4.4-4 Item 4.a and 4.b of the CTS includes analysis l of all 5 Iodine isotopes. Performance ofITS SR 3.4.16.2 will also include l analysis ofI-132 and I-134, in addition to the three isotopes listed in Table 4.4-4 Item 4. As such, performance of SR 3.4.16.2 will envelope the requirements of Table 4.4-4 Item 4 and is slightly more restrictive. l 11 M The CTS Table 4.4-4 surveillance requirement 3
- footnote is revised consistent with the STS. This surveillance requires a radiochemical analysis for determining E-bar be performed every 6 months. The time allowed to actually perform this surveillance after reaching the required conditions 1 specified in the CTS
- footnote is limited to within 31 days consistent with the corresponding STS requirement. The CTS requirement did not specify how soon after the conditions of the
- footnote were met th; : the l surveillance must be performed. As the STS requirement of within 31 days l is reasonable to ensure the radioactivity in the RCS is in equilibrium (for i optimum surveillance results) and provides assurance that the surveillance j is performed in a timely manner, it is applicable and appropriate for FNP. i However, as this change represents an additional restriction in the TS, it is ;
considered a more restrictive change. 12 L The CTS surveillance requirement 4.b on Table 4.4-4 is revised consistent with the STS. This surveillance is incorporated into the STS SR 3.4.16.2. Chapter 3.4 E2-4-P February,1999
ATTACIIMENT III SNC Identified Editorial Changes Associated Package Changes l L l
\
I J
- - - .. .. .- . . . - . . . . . . . - , - - _ .- ._. - .. - . . ~ . . - . _ . - . _ .
)
l . i I
'Ibe following changes have been made to the Chapter 3.4 submittal to address editorial changes, l omissions, and inconsistencies in the package:
- 1. Page 3/4 4-12b was left out of the package for Chapter 3.4. This page has been added.
- 2. Changed the ITS to state " Level Monitoring System" vice " Flow Rate Monitoring System" to i agree with the revised FSAR. A decision was made after the submittal to retain the CTS j terminology of condensate level monitor vs. condensate flow rate monitor, consistent with the !
revised FSAR. "Iherefore, editorial changes have been made to the package to reflect this ; decision.
- 3. Chapter 3.4, CTS 3/4.2.5 (ITS 3.4.1), DOC llM has been revised to correct the SR reference i from SR 3.4.1.5 to SR 3.4.1.4.
1
- 4. Page B 3.4-32, last paragraph, changed "above" to "2" to agree with the LCO requirements. l
- 5. Page B 3.4-50, last paragraph, PORVs descriptions should read "each having a design relief capacity of 210,000 lb/hr at 2485 psig with a set pressure of 2335 psig." Instead of the current "cach having a relief capacity of 210,000 lb/hr at 2485 psig." (Reference U-166950, Rev.A) I
- 6. ' Page B 3.4-62,2nd to last paragraph, first line, changed "RCS relief valve" to "RHR relief j valve."
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- 7. Insert Y to page B 3.4-74, changed " Dose Equivalent I-131" to " DOSE EQUIVALENT l- ,
- 131"to identifyit as a defmed term. !
I I i I i l l I I l l
'l f
l l l I i
j 24x
====== coorm symn 4 SURVEILiANCE REQUIRDEDtTS (Continued)
I -
.g - ,, c. Steam generator tumes, witn ancacassons c: -
i'
. potential degradation attributed to outssoe
/ diameter stress cerrosion crackang within the
, bounds of the tube support plate with a bobean i ' weltage greater than the lower voltage repaar
. limit (2.0 welts), but less than er equal to the upper voltage repair limit', may remain in servion if a rotating prebe inspecuon moes not detect degradaties. Steam generater tubes, wath indientions of ausside diameter stress corrosion cracking degradaties with a hobbin voltage greater than the upper weltage repair 12aut.,
will be plugged er repaired.
- d. If as tanscheduled mid-cycle Laspection as parfeamed, the fallowing mid-eycle repair 11aats apply instead of the limits identified in 4.4.6.4.a.11.a, 4.4.6.4.a.11.b, and 4.4.6.4.a.11.c. The mid-cycle repair 1smits are detsamined tres the fallowing equatrons:
v. Vues= 1.0 + NDE + Gr [ _CL-At ] CL Va.=V.mm-tv.m-Vm1 ! 9.-u 1 CL uheres Vue, = upper voltage repair limit Vua = louer voltage repair limit
= " , V.me. mid-cycle upper voltage repair limat heaed en time into cycle [
v.a. = mid-cycle lower weltage repair 11 mat ,' based on V a and time into cycle . at = length of time since last scheduled inspection during which Van and Vg, mese taplemented cL or cyuge langer fther Clas hetuses eue sehedaled steen genstatac. s y 4===l Va = etructural liant weltage er = average growth rate per cycle length NDE = 95-percoat cissulative prehability allemenos for mondestructive
. emana.mation uncertainty (i.e., a valer of 20-peroest has been
- approved by NRC)
Implementaties of these mid-cycle . repair limits should follow the sans appreaek as la TS 4.4.5.4.a.11.a, 4.4.6.4.a.11.h. and 4.4.6.4.a.11.e.
- The upper. weltage repair 11mLt la calculated a-we=g ta the methodelegy la Generic 1stter 95-85 as ==pph*d FARE 2Y-ONIT 1 3/4 4-12b MIENEMENT NO.124 3
A > M 1.-AEsG+4 ,(" Levid6u, W$% 5pec42 aran 55,1
1
=
Yl 1 1 xdec+,an Instmaenfd.on i
). h PEACTOR COOLANT SYSTEM u ___ -
ACTOR COOLANT SYSTEM LEAkACE i 3.4.l M ,, RC.S '=ce octreTrON QSTENyINsTWrEtMCM IN5frurnerdrdon] , h LIMITING CONDIT!ON FOR OPERATION L LLo ,q.15 , 4.7.1 The following Reactor Coolant System leakage detection systems shall _J _ be AA8LE: I
~~~ '~* I
- a. The o t atmosphere parti to radioactivity monitor L C,0 3. 0. '/ syste and gg i pV Z
- b. Either e containm'ent air cooler ndensate level rnonito@l
, , , , , W or a containm " struosphere gaseous radioactivity monitonnq eystem](R-12). j
% babes t er om Re.s APPLICA YLTTY: MODES 1, 2, 3 and 4. /,f e
g h ACTION: the 30 g. ( h5e erFormeS 16 i h leakage detection systems OPERABLE,
/g With only one of the a ve requ l operation may continue to up to days provided grab samples of the containment atmosphere are btained and analysedPat least once per 24 hours 6 l
when the required gaseousg o particulate radioactive monitoring system-is A ! inoperables otherwise, be in at least HOT STAND 8Y within the next 6 hours and I in COLD SHUTDOWN within t is following 30 hours. - i
- i Ok Q COO COlib S$$ W OY URVEILLANCE REQUIREMENTS C m{j.{h - _ -_ -
w g /g h , e leakage detection systems shall be demonstrated OPERA 8LE by: Containment a sphere gaseous and particulate monitori stars I performance f CHANNEL CHECK, CHANNEL CALIBRATION and HANNE $ R3,4efbe 1 l COT tuNCTIONAL T h Qt the Krequenctes specatted in TaDie a.3- 8 g g g f$,3 . I EAde/*l t g,/$, f b Containment air cooler condensate 11evel monitoring system l perforinance of CHANNEL CALIBRATION at least once per 18 months. l A l J U ConDonot) b - cAA rbttco s.o.s w$ utr ' Jp l
. 7 FARLEY-UNIT 1 3/4 4-16 AMENDMENT NO. 26 I .
l
~
1
. l i
FNP TS Conversion Enclosure 2 - Discussion of Changes to CTS Chapter 3.4 - RCS ? CTS 3/4.2.5 DNB PARAMETERS : FNP ITS 3.4.1 RCS PRESSURE, TEMPERATURE, AND FLOW DNB LIMITS . DOC t NO SHE DISCUSSION ! 8 A The DNB parameters and limits specified on CTS Table 3.2-1 are moved into the TS LCO and surveillance requirements consistent with the format and presentation of this information in the STS. No technical change is - intended. As such this change is considered administrative. i 9 A The references to two loop operation on CTS Table 3.2-1 are deleted. FNP l is not licensed for two loop operation. The references to two loop operation on CTS Table 3.2-1 are not applicable and contain no valid limitations on plant operation. As the deletion of this information removes nonessential : material from the TS and has no technical impact, this change is considered administrative. ; 10 LA The infonnation contained in the *" footnote to CTS Table 3.2-1 is removed from the TS and placed in the bases consistent with the location of + this information in the STS. The *" footnote of CTS Table 3.2-1 contains I the measurement uncertainties associated with the calculations used to determine the minimum RCS flow specified in the TS. This information is incorporated into the specified RCS flow and not of direct importance to the ; operators using the TS. The allowance to place this information in the TS I bases is acceptable due to the level of control provided by the TS bases control program specified in the administrative controls section of the ITS. : 11 M The CTS surveillance 4.2.5.2 which requires the RCS flow rate to be , determined every 18 months by precision heat balance is revised by the addition of a note. The use of a note in this surveillance is consistent with [ gd the corresponding STS surveillance SR 3.4.1.4. However, the time proposed in the FNP note (7 days) for perfonnance of the surveillance is not consistent with the time specified in the STS (24 hours). Since the CTS do not specify a time limit for performing this surveillance FNP proposes 7 days based on operating experience and the fact that performing the precision heat balance is a complicated measurement that requires stable thermal power conditions. Seven days provides adequate time to set up for the measurement, with allowances for typical instrumentation problems, i and to achieve stable conditions without adversely affecting safety. In I addition, the 7 day limit for performing this same surveillance has been ! previously approved by the NRC for Vogtle (CTS and ITS). The note ! specifies a power level at which the surveillance must be performed and a j time (7 days) within which the surveillance must be performed after Chapter 3.4 E2-3-A February,1999 , I
- i i
l FNP TS Conversion
. Enclosure 2 - Discussion of Changes to CTS Chapter 3.4 - RCS CTS 3/4.2.5 DNB PARAMETERS FNP ITS 3.4.1 RCS PRESSURE, TEMPERATURE, AND FLOW DNB LIMITS l DOC i l
NQ SJiE DISCUSSION exceeding the required power level. The specification of a power level greater than or equal to 90%, ensures the results of the surveillance are , accurate (higher power more accurate results) and the requirement to l perform the surveillance within a specified time after reaching this power l level ensures that the RCS flows are verified in a timely manner. As such ! these additional requirements are appropriate and applicable to FNP. ' However, the addition of the power and time requirements to this , surveillance represent new TS requirements for FNP and therefore, this ; change is considered more restrictive. l l l l i l l l 1 l Chapter 3.4 E2-4-A March,1998 i
FNP TS Conversion Enclosure 2 - Discussion of Changes to CTS Chapter 3.4 - RCS CTS 3/4.4.7.1 RCS LEAKAGE DETECTION SYSTEMS FNP ITS 3.4.15 RCS LEAKAGE DETECTION INSTRUMENTATION DOC NO StLE DISCUSSION 1 LA The CTS 3.4.7.1 LCO is revised consistent with the STS. The radiation monitor instrument designations (R-11 and R-12) are moved into the LCO section of the bases consistent with the placement of such details in the STS. Placement of this information in the bases is acceptable based on the level of change control provided by the bases control program in the administrative controls section of the STS. 2 A The CTS 3.4.7.1 LCO is revised consistent with the STS. Editorial changes are made to the LCO statement to achieve consistency with the STS. However, the name of the containment air cooler condensate level monitor is maintained consistent with the revised FNP FSAR description of this system. The condensate level / flow rate monitoring system contains a vertical standpipe in which the level is monitored. As condensate flow EV' \ increases the level in the standpipe also increases and the high condensate flow alarm is actuated from the rising standpipe level. Therefore, the CTS terminology is maintained. The changes are made to confonn with the format and presentation of the STS and are therefore considered administrative in nature. 3 L The CTS 3/4.4.7.1 action statement time allowed to restore an inoperable leakage detection instrument is revised from 7 days to 30 days consistent with the STS. The actions for an inoperable required leakage detection instrument provide for containment atmosphere grab samples to be taken and analyzed or an RCS water inventory balance to be performed once every 24 hours. The performance of these periodic required actions is an adequate remedial measure providing sufficient information to ensure that RCS leakage will not go undetected. Additionally, at least one other form of TS required automatic leak detection will be operable as well as the non-TS dew point temperature monitoring system to provide further assurance that RCS leakage will be detected in a timely manner. As such, this change provides a more reasonable time, considering the remaining operable automatic leakage detection instrumentation, the information provided by the performance of the required actions, and the likelihood of an event occurring during this time that would require all the leak detection instrumentation operable, to affect repairs on a single inoperable leakage detection instrument. Chapter 3.4 E2-1-M February,1999 j i l
FNP TS Conversion
. Enclosure 2 - Discussion of Changes to CTS Chapter 3.4 - RCS CTS 3/4.4.7.1 RCS LEAKAGE DETECTION SYSTEMS FNP ITS 3.4.15 RCS LEAKAGE DETECTION INSTRUMENTATION DOC NO SHE DISCUSSION 4 A The CTS 3/4.4.7.1 actions are revised to add an alternate action consistent with the STS. The CTS actions require a containment atmosphere grab sample to be taken and analyzed every 24 hours. The STS provides an altemative action to perfonn an RCS water inventory balance every 24 hours in lieu of the currently required grab sample. The proposed STS attemate action provides direct measurement of RCS leakage, both identified and unidentified, and is an acceptable alternative to the analysis of containment atmosphere grab samples to detect changes in RCS leakage.
As this change does not impact the technical intent of the CTS actions (to compensate for the inoperable automatic leakage detection instrument) and only provides an equally acceptable attemative action to be performed on the same frequency, it is considered an administrative change. 5 A The CTS 3/4.4.7.1 actions are revised to clarify that an actions Condition would not be applicable for the gaseous radioactivity monitor unless the containment air cooler condensate level monitor was also inoperable. This l is an FNP specific change to the CTS actions made in order to conform A more closely with the STS actions Conditions. The CTS LCO statement b is [ l not violated unless both the gaseous radioactivity monitor and the condensate level monitor are inoperable. Since the STS provides more specific Conditions for inoperable leakage detection monitors it is necessary to clarify the FNP specific action for these two monitors and provide an action consistent with the requirements of the CTS and FNP ITS LCO statement. Therefore, the containment air cooler condensate level monitor [ is added to the action statement to correspond with the requirements of the LCO (statement b) and the proposed FNP ITS Condition B which addresses i the inoperabihty of both these monitors. As this change only serves to clarify the existing relationship of these instruments in the CTS LCO and actions, it is considered administrative in nature. 6 A The CTS 4.4.7.1 surveillance requirements are revised to be consistent with the STS. This includes the following changes: 4 The surveillance requirements for the containment atmosphere radioactivity monitors are no longer contained in the referenced CTS Table 4.3-3. The surveillance requirements for these radiation monitors are now completely contained within the proposed FNP ITS 3.4.15, RCS leakage Detection Instrumentation, consistent with Chapter 3.4 E2-2-M February,1999
FNP TS Conversion
. Enclosure 2 - Discussion of Changes to CTS Chapter 3.4 - RCS CTS 3/4.4.7.1 RCS LEAKAGE DETECTION SYSTEMS FNP ITS 3.4.15 RCS LEAKAGE DETECTION INSTRUMENTATION DOC HQ SHE DISCUSSION the STS. The technical intent and frequency of the CTS surveillances remain unchanged but the surveillances are now , located in a single place in the TS.
The CTS Channel Functional Test term is replaced with the ITS COT defined term. The differences between these terms are j discussed in the submittal enclosures associated with the TS definitions in section 1.0 of the TS. This change is made only to conform with the STS. { The surveillance requirements of CTS 4.4.7.1.a and .b are broken out and individually numbered in the proposed FNP ITS consistent with the STS. As these changes are made to conform with the fonnat and presentation of this information in the STS, these changes are considered administrative. 7 M The CTS 3/4.4.7.1 actions are revised by the addition of a new actions Condition consistent with the STS. The proposed new Condition addresses the situation where all the required leakage detection monitors are inoperable and requires that LCO 3.0.3 be entered immediately. The new Condition is required due to the conventions of actions Condition entry used in the STS. In the STS, all applicable action Conditions may be i entered simultaneously (per general mies of TS section 1.3, Completion I Times). The actions Conditions of the proposed FNP ITS may be entered at I the same time (resulting in all leakage monitors inoperable) and the completion time of the Conditions would still allow 30 days to restore a l monitor to operable status. LCO 3.0.3 would not be applicable as action Conditions exist within the TS to cover all inoperable leakage detection monitors. Therefore, the STS provides an explicit actions Condition requiring immediate entry into LCO 3.0.3 if all required leakage monitors are inoperable and the required leakage detection function is lost. As this l change incorporates specific and new instructions to enter LCO 3.0.3 within the TS, it is considered a more restrictive change. 8 L The CTS 3/4.4.7.1 actions are modified by a note allowing an exception to LCO 3.0.4 consistent with the STS. The note is applied to proposed FNP Chapter 3.4 E2-3-M February,1999 l _ _ _ _ - _ _ _ _ i
RCS Leakage Detection Instrumentation N 3.4.15 3.4 REACTOR COOLANT SYSTEM (RCS) a.rhc.o kIE 3.4.15 RCS Leakage Detection Instrumentation LC0 3.4.15 The following RCS leakage detecti instrumentation shall be OPERABLE: 3[ One/ cont [inmej[t sup/p (leyd1/or/ disc)large f)4w) m%ito[; O Onecontainmentatmospherekradioactivitymonitor: 4.[ 46aseous or particulate); b, Dand g .g One cont nmentaircoolercondensateElowrat[ monito - , _- = + - - - - - orone untdnmeni Akmo*P e.r.e- h garecus caa.cm%. mandec. q M - APPLICABILITY: MODES 1, 2, 3, and 4
- - - -- - - - N ora - - - - - - -
ACTIONS -'M 3'I b "-
- b- ~- '
CONDITION REQUIRED ACTION COMPLETION TIME A. Requ containment ------------NOTE------------- sump mon LCO 3.0.4 is not applicable. inoperable. -------------------------- -
. Perform .4.13.1. Once per 24 hours ANQ A.2 Restore requi 30 days containment sump j monitor to OPERABLE status.
(continued) l ZNsERT E FNP sPsciFio Conounon A WOG STS 3.4-39 Rev 1, 04/07/95
"L@
RCS Leakage Dstection Instrument tion
. 3.4.15 ACTIONS (continued)
CONDITION REQUIRED ACTION COMPLETION TIME r~ B. d""O
~
Required con'inment
-----------NOTE------------
W atmosphere LC0 3.0.4 is not T3TF-Go radioactivity monitor applicable. inoperable. --------------------------- c . EhlD B.1.1 Analyze gral samples Once per of the containment 24 hours atmosphere.
%did conYEinmen4 oar cooler conder$de. E l mo r B.I.2 Perform SR 3.4.13.1. Once per ino pera.b\c.. 24 hours OM alleadane [p (8.2 store required 30 days rcontainme atmosphere radioactivit monitor to OPERABLE status. i R
B.2 2 Verify contains t 30 ays air c oler cond nsate fl rate
-)
I mon tor is OP RABLE. ! URquiredcontinment i j
.1 Perf SR3.4.1[.l. Once er ir cooler c ndensate 8 ho rs flow rate nitor E inoperable C.2 rform SR 3 4.13.1. ce per 4 hours
/
(continued) N WOG STS 3.4-40 Rev 1, 04/07/95
t 25V RCS Leakage Detection Instrumentation I
. 3.4.15 l 5 i SURVEILLANCE REQUIREMENTS (continued)
SURVEILLANCE f FREQUENCY f: SR 3.4.15.2 Perform COT of the required containment 92 days l
. atmosphere radioactivity monitor. l SR 3.4.15.3 Perform RAT equired [18] months !'
.mo or.
yy
~
3
- 3.4.15./ Perform CHANNEL CALIBRATION of the required containment atmosphere radioactivity
@l84 months f i l
monitor.
.s I
dSR 3.4.15.84Perform CHANKEL CALIBRAlleii uf the requiredf 8 months containment air cooler condensate C ow rap ! monitor. aw \ l i I i I i
'I I
l l l i i WOG STS 3.4-42 Rev 1, 04/07/95
FNP TS Conversion Enclosure 5 - JD from STS Chapter 3.4 - RCS STS 3.4.15 RCS LEAKAGE DETECTION INSTRUMENTATION l FNP ITS 3.4.15 RCS LEAKAGE DETECTION INSTRUMENTATION l 1 JD ! NUMBER JUSTIFICATION 1 The STS LCO is revised to be consistent with the CTS LCO. The CTS LCO does ) j
. not include the requirement for a containment sump level or flow monitor. The GM CTS LCO also requires that the containment atmosphere particulate radioactivity i monitor be operable at all times in the Mode of Applicability. The CTS uses the terminology " condensate level monitor" instead of" condensate flow rate monitor."
The CTS LCO allows either the containment atmosphere gaseous radioactivity [ monitor or the containment air cooler condensate level monitor to be used to meet part b of the LCO requirement. In the original FNP SER (NUREG 75/034, Section 5.6), the NRC found the FNP leakage detection equipment and methods acceptable and to satisfy the requirements of general design criterion 30 of 10CFR Part 50, App A (without a containment sump monitor). 2 The STS is revised by the addition of an FNP specific Condition "A" addressing the containment atmosphere particulate radioactivity monitor.(part "a" of the LCO) which replaces the STS Condition "A" for the containment sump monitor. The requirement for a containment sump monitor is not part of the FNP CTS. The STS addresses the radioactivity monitors (gaseous or particulate) as interchangeable to meet the LCO requirement. Since in the FNP CTS, the containment atmosphere particulate monitor is required operable in Modes 1 through 4 and may not be replaced with the containment atmosphere gaseous radioactivity monitor, a separate j actions Condition addressing the operability of this monitor is proposed as an FNP l specific change to the STS. This change is consistent with the FNP CTS when , presented in the STS fonnat. l 3 The STS Condition B which previously addressed the radioactivity monitors is i revised consistent with the CTS LCO statement "b" requirement for a containment i atmosphere gaseous radioactivity monitor or a containment air cooler condensate level monitor to be operable. In order to fail to meet the FNP LCO statement "b", l both of these monitors must be inoperable at the same time. Therefore, the STS N' Y Condition B is revised as necessary to accommodate the FNP specific LCO l requirements. 4 The bracketed (optional) STS Conditions C and D are not required to address the limited combination ofinoperable equipment allowed by the FNP specific LCO and are deleted. The requirements of these deleted Conditions are effectively incorporated into the proposed FNP ITS specific Condition B. 5 The STS SR 3.4.15.3 is deleted. This SR requires the performance of a channel ! calibration of the containment sump monitor. The requirement for an operable Chapter 3.4 E5-1-L February,1999 j
l
.l RCS Loops - MODE 5, Loops Filled B 3.4.7 B 3.4 REACTOR COOLANT SYSTEM (RCS)
B 3.4.7 RCS Loops - MODE 5, Loops Filled BASES BACKGROUND In MODE 5 with the RCS loops filled, the primary function of the reactor coolant is the removal of decay heat and transfer this heat either to the steam generator (SG) secondary side coolant +or the component cooling water via the residual heat removal (RHR) heat exchangers. While'the ]
, principal means for decay heat removal is via the RHR
^(g System, the SGsgre specified as a backup means for redunoancy. Even though the SGs cannot produce steam in :
c wwMk this MODE, they are capable of being a heat sink due to ; y ,) their large contained volume of secondary water. As long as l the SG secondary side water is at a lower temperature than , the reactor coolant, heat transfer will occur. The rate of ' heat transfer is directly proportional to the temperature T317_ q difference. The secondary function of the reactor coolant i is to act as a carrier for soluble neutron poison, boric acid. In MODE 5 with RCS loops filled, the reactor coolant is ) circulated by means of two RHR loops connected to the RCS, ' each loop containing an RHR heat exchanger, an RHR pump, and appropriate flow and temperature instrumentation for control, protection, and indication. One RHR pump r circulates the water through the RCS at a sufficient rate to prevent boric acid stratification.
,g The number of loops in operation can vary to suit the operational needs. The intent of this LCO is to provide Ehyr forced flow from at least one RHR loop for decay heat removal and transport. The flow provided by one RHR loop is y- adequate for decay heat removal. The other intent of this ;
LCO is to require that a second path be available to provide ' redundancy for heat removal. The LC0 provides for redundan paths of decay heat removal capability. The first path .an be an RHR loop that must be OPERABLE and in o ration. The second path can be another E RH 1 r i aining two SGs with secondary side , water levels [17]% to provide an alternate method for decayheatremovp. n*>"frA) A P (continued) WOG STS B 3.4-32 Rev 1, 04/07/95 1
. M Pressurizer PORVs
. B 3.4.11 i B 3.4 REACTOR COOLANT-SYSTEM (RCS)
B 3.4.11 Pressurizer Power Operated Relief Valves (PORVs) ;
., j BASES BACKGROUND The pressurizer is equipped with two types of devices for i pressure relief: pressurizer safety valves and PORVs. The l FSAR PORVs are air operated _ valves that are controlled to open at i 5,5,13.1 a specific set pressure when the pressurizer pressure j y, $,0 L increases and close when the pressurizer pressure decreases.
The PORVs may also be manually operated from the control room. Block valves, which are normally open,. are located between 1 the pressurizer and the PORVs. The block valves are used to isolate the PORVs in case of excessive leakage or a stuck open PORV. Block valve closure is accomplished manually using controls in the control room. A stuck open PORV is, in effect, a small break loss of coolant accident (LOCA). As such, block valve closure terminates the RCS depressurization and coolant inventory loss. The PORVs and their associated block valves may be used by plant operators to depressurize the RCS to recover from certain transients if normal pressurizer spray is not available. Additionally, the series arrangement of the PORVs and their block valves permit performance of surveillances on the valves during power operation. The PORVs may also be used for_ feed and bleed core cooling in the case of multiple equipment failure events that are not within the design basis, such as a total loss of feedwater. ; 1 The PORVs, their block valves, and their controls are d powered from the vital buses that normally receive power
~ (%p@ g . from offsite power sources, but are also capable of being g,5' powered from emergency power sources in the event of a loss of offsite power. Two PORVs and their associated block '
valves are powered separ cf:t" t-la- 't !. 'y ' a e.5E fresfort, oE2.33Spsy !
@ The plant has two having e reotrcapacity o 210,000 lb/hr'at . The fun onal design of the ,
taining pressu below the Pressurizer g 36l g PORVs is based on Pressure - High reactor trip setpoint following a step 4g reduction of 50% of full lead with steam dump. In addition, f.6M,hb E l (continued) WOG STS B 3.4 Rev 1, 04/07/95 , a __ __ . _ _ _ ~ ,
3(p LTOP System B 3.4.12 , I BASES APPLICABLE Heat Inout Tvoe Transients SAFETY ANALYSES (continued) a. Inadvertent actuation of pressurizer heaters;
- b. Loss of RHR cooling; or
- c. Reactor coolant pump (RCP) startup with temperature asymmetry within_the RCS or between the RCS and steam generators.
The following are required during the LTOP MODES to ensure j that mass and heat input transients do not occur, which j either of the LTOP overpressure protection means cannot ' t.4 handle: Y[ g4 a. Render g all but 6ne] HPI] pump [and]onecharging pum incapable ofinjec;1on;
^
- b. Ocactivating the accumulator discharge isolation valves in their closed positions; and
? or c. Disallowing s rt of an R'CP if secondary temperature
\'
is more than 5 *F above primary temperature in any hpeW one loop # LC0 3.4.6, "RCS Loops - MODE 4," and LCO 3.4.7, "RCS Loops - MODE 5, Loops Filled g ". rovid g l Qhis protectioh The Reference 4 analyses demonstrate that ther on p% (M, relief vbve er tne ae>rossurized Rcs and Rcs venTean 1 o_ mair tainACS pressure >e' imits wh only onet.HPI] pump] - I CandonBcharginq n'=a d n is are ctuat situs, tne p hcf Ico allows on)y one] [F E] pump .an@ one ing > ump W OPERABLE durJhe(;ne uur nvuts. Sincefeithe one( . MR. i 3 j "g relief valvtt[ior t the Rch vont canlhandle the pressure transient need from accumu' ator injection, when RCS 6 to - temperatur s low, the LCO also requires the accumulators RSAR isola when accumulator pressure is greater than or equal S.229 .to th maximum RCS pressure for the existing RCS cold leg te ature allowed in the PTLR. o_@ The isolated accumulators must have their discharge valves closed and the valve power supply breakers fixed in their open positions g Ihe anas ses sho tne ett t of ac umu or g- schprge is prer a nar wer RC tempera re ran ([ J'F - c andj5elow) t) fan that the L ([275]* and be w) n (continued) WOG STS B 3.4-62 Rev 1, 04/07/95
CHAPTER 3.4 , INSERT Y 370 TO STS BASES PAGE B 3.4-74 FNP SPECIFIC BASES FOR MSLB RADIATION RELEASES i The main steam line break (MSLB) is more limiting for site radiation releases. The MSLB analysis in support of Generic Letter 95-05 has shown that steam generator tube leakage of 23.8 gpm in the faulted loop, and 0.1 gpm (approximately 150 gpd) in each of the intact loops (total leakage of 24 gpm), following a main steam line break outside of containment, but upstream of the main steam isolation valves, results in offsite doses bounded by a small fraction (i.e.,10%) of the 10 CFR 100 guidelines. The RCS specific activity assumed was 0.15 micro-Ci/gm DOSE EQUIVALENT I-131, with either a pre-existing or an accident initiated iodine spike. EibM l i l l l l l ? l l l l l !
- l. l i
i Chapter 3.4 Insert Page
-. .-- .- - --- - --- -- - - - ---- -""~^--
N- j l Aqs RCS Leakage Detection Instrumentation i W B 3.4.15 I l B 3.4 REACTOR COOLANT SYSTEM (RCS) j B 3.4.15 RCS Leakage Detection Instrumentation l , l BASES BACKGROUND GDC 30 of Appendix A to 10 CFR 50 (Ref.1) requires means i for detecting and, to the extent practical, identifying the location of the source of RCS LEAKAGE. Regulatory l Guide 1.45 (Ref. 2) describes acceptable methods for ; L selecting leakage detection systems. Leakage detection systems must have the capability to detect ! I significant reactor coolant pressure boundary (RCPB) i egradation as soon after occurrence as practical to i p6b9 - .6 *1,- minimize the potential for propagation to a gross failure. l g, T Thus, an early indication or warning ' signal is necessary to , permit proper evaluation of all unid ntified LEAKAGE. I
= _
gbM tevt.t or . Industry practice.l as own that w flow changes of 0.5 : l The coM to 1.0 gpm can b readily detected injontained volumes by
! plow as monitoring chang s in water levpl, & flow rate, or in the o p or k operating freque ncy of a pump. The containment 4 ump used to) " !
perht , ccoi sect, unident; fied,tEAKAGE [WC.d(or) andJa cier gl l gA , densate mw ratamonitor] tarelunstrs= ant ta ala i O.Y*EM t creases Qf '0.5 to 1.0 opaJin theMlTlow ratsy). nsitivity is acceptab e ffor detecting Eriases in [ ' P' R*- 4 R** - nidentified LEAKAGE.4 /b
;0 rue mesesses J. - - -
the waher level The reactor coolant contains radioactivity that, when l' gn we 4%p released to the containment, can be detected by radiation rises, monitoring instrumentation. Reactor coolant radioactivity levels will be low during initial reactor startup and for a few weeks thereafter, until activated corrosion products have been formed and fission products appear from fuel element cladding contamination or cladding defects.
~ Fs AR. Instrumentsensitivitiesof10"pi/ccradioactivityfor 5.27.4.1 Particulate monitoring and of 10 pCi/cc radioactivity for gaseous monitoring are practical for these leakage detection systems. Radioactivity detection systems are included for monitoring both particulate and gaseous activities because of their sensitivities and rapid responses to RCS LEAKAGE.
An increase in humidity of the containment atmosphere would indicate release of water vapor to the containment. Dew point temperature measurements can thus be used to monitor l j humidity levels of the containment atmosphere as an i- i l ! (continued) WOG STS B 3.4-86 Rev 1, 04/07/95
, ._n._- ,,-.__,.___3 ,_..-
1 RCS Leakage Detection Instrumentadon
% B 3.4.15 BASES APPLICABLE RCS leakage. detection instrumentation satisfies Criterion 1 SAFETY ANALYSES of the NRC Policy Statement.
(continued) LCO One method of protecting against large RCS leakage derives \ Thus the conbnen from the ability of instruments to rapidly datect extremely i mall leaks. This LCO requires instruments of diverse gg[g 4 g;g 4;jjg 4p nitoring principles to be OPERABLE to provide a high degree of confidence that extremely small leaks are detected (R-il j in time to allow actions to place the plant in a safe yh) in combs'oa.f,co/[y".*h condition, when'RCS LEAKAGE indicates possible RCPB egradation. (q (R-s2). er a_cbenmerd l
% C80 W U h # he LCO is satisfied when monitors of diverse measurement lovel Ndar means are available. (Th , the con ainment su monito , in Q (com natign witn A gaseo or part culate rad activit j EAW '
mo tor [(nd a cAntains t air co er conden te flow atel 4 m itor][ provides an acceptable minimum. ' l APPLICABILITY Because of elevated RCS temperature and pressure in MODES 1, 2, 3, and 4, RCS leakage detection instrumentation is 3o required to be OPERABLE. In MODE 5 or 6, the temperature is to be :s; 200*F and pressure is maintained low or at atmospheric pressure. Since the temperatures and pressures are far lower than those for MODES 1, 2, 3, and 4, the likelihood of leakage and crack propagation are much smaller. Therefore, the requirements of this LCO are not applicable in MODES 5 and 6. A,l./, A,/,2 M"U^ _ ___
%U l af rach here. ar+1culsfe)
AC S nd A.2 = ((v donfSenireof With the required containment u monitor inoperable, no i w coo /pe- - other form of sampling can provide the equivalent i 2 information; however, the containment atmosphere l beI radioactivity monitorgwill provide indications o anges in rrwmiorf leakage. Togetner with the. atmosphere'uonito the periodic surveillance for RCS water inventory balance,%rR 3.4.13.1,
\
Y or the coransate.
' . \ t,ve l mo (continued) l _ _ ho r-WOG STS B 3.4-88 Rev 1, 04/07/95
e CHAPTER'3.4 M TSTF-60 INSERT CA TO STS BASES PAGE B 3.4-88 FNP SPECIFIC IMPLEMENTATION OF TSTF-60 The Actions are modified by a Note that indicates that the provisions of LCO 3.0.4 are not applicable. As a result, a MODE change is allowed when the containment particulate h radioactivity monitor, the containment gaseous radioactivity monitor, and the containment air . l cooler condensate level monitor are inoperable. This allowance is provided because other instrumentation is available to monitor RCS leakage. EM 4 i ! 1 1 4 i i i l 1 l i l Chapter 3.4 Insert Page
l i CHAPTER 3.4 l
. 332 INSERT F TO FNP ITS 3.4.15 CONDITION B BASES DESCRIPTION PAGE B 3.4-89 l and the required containment air cooler condensate level monitoring instrumentation chaanel ;
GS M O l l 1 l l l
'l Chapter 3.4 Insert Page
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