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#REDIRECT [[ULNRC-06880, Application to Revise Technical Specifications to Adopt Tstf-569, Rev. 2, Revise Response Time Testing Definition (LDCN 24-0008)]]
| number = ML24158A526
| issue date = 06/06/2024
| title = Proposed Technical Specification Bases Changes (Mark-up)
| author name =
| author affiliation = Ameren Missouri, Union Electric Co
| addressee name =
| addressee affiliation = NRC/NRR
| docket = 05000483
| license number =
| contact person =
| case reference number = ULNRC-06880
| package number = ML24158A521
| document type = Technical Specification, Bases Change
| page count = 1
}}
 
=Text=
{{#Wiki_filter:Attachment 3 Proposed Technical Specification Bases Changes (Mark-up) 1 1 Pages
 
[changes this page. Shown RIS Instrumentation Ifor information only.
B 3.3.1 BASES SURVEILLANCE SR 3.3,1.14 (continued)
REQUIREMENTS The SR is modified by a Note that excludes verification of setpoints from the TADOT. The Functions affected have no setpoints associated with them.
SR 3.3.1.15 SR 3.3. 1. I 5 is the performance of a TADOT of Turbine Trip Functions. A successful test of the required contact(s) of a channel relay may be performed by the verification of the change of state of a single contact of the relay. This clarifies what is an acceptable TADOT of a relay. This is acceptable because all of the other required contacts of the relay are verified by other Technical Specifications and non-Technical Specifications tests at least once per refueling interval with applicable extensions. This TADOT is performed prior to exceeding the P-9 interlock whenever the unit has been in MODE 3. This Surveillance is not required if it has been performed within the previous 31 days. Verification of the Trip Setpoint does not have to be performed for this Surveillance.
Performance of this test will ensure that the turbine trip Function is OPERABLE prior to exceeding the P-9 interlock.
SR 3.3.1.16 SR 3.3.1.16 verifies thatthe individual channel actuation response times are less than or equal to the maximum values assumed in the accident analysis. Response time verification acceptance criteria are included in Reference 8. No credit was taken in the safety analyses for those channels with response times listed as N.A. No response time testing requirements apply where N.A. is listed in Reference 8. Individual component response times are not modeled in the analyses. The analyses model the overall or total elapsed time, from the point at which the parameter exceeds the trip setpoint value at the sensor until loss of stationary gripper coil voltage (at which point the rods are free to fall).
The safety analyses include the sum of the following response time components:
(a)
Process delay times (e.g., scoop transport delay and thermal lag associated with the narrow range RCS RTDs used in the OTAT and OPAl functions) which are not testable; (b)
Sensing circuitry delay time from the time the trip setpoint is reached at the sensor until a reactor trip is generated by the SSPS; (continued)
CALLAWAY PLANT B 3.3.1-62 Revision 25
 
No changes this page. Shown for information only.
BASES SURVEILLANCE SR 3.3.1.16 (continued)
REQUIREMENTS (c)
Any intentional time delay set into the trip circuitry (e.g.,
undervoltage relay time delay, NLL cards (lag, lead/lag, rate/lag) and NPL cards (PROM logic cards for trip time delay) associated with the OThT and OPAT trip functions, and NLL cards (lead/lag) associated with the low pressurizer pressure reactor trip function) to add margin or prevent spurious trip signals; (d)
For the undervoltage RCP trip function, back EMF delay from the time of the loss of the bus voltage until the back EMF voltage generated by the bus loads has decayed; (e)
The time delay for the reactor trip breakers to open; and (f)
The time delay for the control rod drive stationary gripper coil voltage to decay and the rod control cluster assembly (RCCA) grippers to mechanically release making the rods free to fall (i.e.,
gripper release time).
For channels that include dynamic transfer functions (e.g., lag, lead/lag, rate/lag, etc.), the response time verification is performed with the time constants set at their nominal values. lime constants are verified during the performance of SR 3.3. 1.1 0 and SR 3.3.1. 11. The response time may be verified by a series of overlapping tests, or other verification (e.g.,
Ref. 9 and Ref. 15), such thatthe entire response time is verified.
Response time may be verified by actual response time tests in any series of sequential, overlapping, or total channel measurements, or by the summation of allocated sensor, signal processing, and actuation logic response times with actual response time tests on the remainder of the channel. Allocations for sensor response times may be obtained from:
: 1) historical records based on acceptable response time tests (hydraulic, noise, or power interrupt tests); (2) inplace, onsite, or offsite (e.g. vendor) test measurements; or (3) utilizing vendor engineering specifications.
WCAP-1 3632-P-A, Revision 2, Elimination of Pressure Sensor Response Time Testing Requirements, provides the basis andmethodology for using allocated sensor response times in the overall verification of the channel response time for specific sensors identified in the WCAR Response time verification for other sensor types must be demonstrated by test.
WCAP-14036-P-A, Revision 1, Elimination of Periodic Protection Channel Response Time Tests, provides the basis and methodology for using allocated signal processing and actuation logic response times in the RTS Instrumentation B 3.3.1 (continued)
CALLAWAY PLANT B 3.3.1-63 Revision 25
 
RTS Instrumentation B 3.3.1 BASES SURVEILLANCE
*SR 3.3. 1. I 6 (continued)
REQUIREMENTS overall verification of the protection system channel response time. The allocations for sensor, signal conditioning, and actuation logic response times must be verified prior to placing the component in operational service and re-verified following maintenance that may adversely affect response time. In general, electrical repair work does not impact response time provided the parts used for repair are of the same type and value.
Specific components identified in References 9 and 15 may be replaced without verification testing. One example where response time could be affected is replacing the sensing assembly of a transmitter.
The Surveillance Frequency is based on operating experience, equipment reliability, and plant risk and is controlled under the Surveillance Frequency Control Program. Response time verification for the functions listed in References 8 and 1 0 includes testing of the response time for the reactor trip breakers to open (identified as item (e) in the above description of the safety analysis response time components).
Another component of the overall RTS response time verification for the functions listed in References 8 and 1 0 is the gripper release time which is described in item (f) in the above description of the safety response time components. This is the time for the control and shutdown rod drive stationary gripper coil voltage to decay and the RCCA grippers to mechanically release, thereby rendering the control and shutdown rods free to fall.
SR 3.1.4.3 verifies the rod drop time from the beginning of decay of stationary fripper coil voltage to dashpot entry. The end point of the RTS response time definition, i.e., until loss of stationary gripper coil voltage, is less discernible and would overlap a portion of the total rod drop time verified in SR 3.1.4.3. However, the gripper release time may conservatively be quantified as the time from when the reactor trip breaker opens until the time when rod movement is first detected.
Some portions of the response time testing cannot be performed during unit operation because equipment operation is required to measure response times.
SR 3.3.1.16 is modified by a Note stating that neutron detectors are excluded from RTS RESPONSE TIME testing. This Note is necessary because ofthe difficulty in generating an appropriate detector input signal.
Excluding the detectors is acceptable because the principles of detector operation ensure a virtually instantaneous response. Response time of the neutron flux signal portion of the channel shall be verified from detector output or input to the first electronic component in the channel.
(continued)
The response time may be verified for components that replace the components that were previously evaluated in Ref. 9 and Ref. 15 provided that the components have been evaluated in accordance with the NRC approved methodology as discussed in Attachment I to TSTF-569, Methodology to Eliminate Pressure Sensor and Protection Channel (for Westinghouse Plants only)
Response Time Testing, (Ref. 24).
CALLAWAY PLANT B 3.3.1-64 Revision 25
 
No changes this page.
RTS Instrumentation Shown for information only.
B 3.3.1 BASES REFERENCES I.
FSAR, Chapter 7.
2.
FSAR, Chapter 15.
3.
IEEE-279-1971.
4.
10 CFR 50.49.
5.
Caltaway OLAmendment No. 17 dated September 8, 1986.
6.
Callaway Setpoint Methodology Report, SNP (UE)-565 dated May 1, 1984.
7.
Callaway OLAmendment No. 43 datedApril 14, 1989.
8.
FSAR Section 16.3, Table 16.3-1.
9.
WCAP-1 3632-P-A, Revision 2, Elimination of Pressure Sensor Response Time Testing Requirements, January 1996.
10.
FSARTabIe 15.0-4.
11.
WCAP-9226-P-A, Reactor Core Response to Excessive Secondary Steam Releases, Revision I, February 1998.
12.
Deleted.
13.
FSARSection 15.1.1.
14.
RFR - 18637A.
15.
WCAP-14036-P-A, Revision 1, Elimination of Periodic Protection Channel Response lime Tests, October 1998.
16.
FSAR Section 15.4.6.
I 7.
WCAP-1 4333-P-A, Revision 1, Probabilistic Risk Analysis of the RPS and ESFAS Test Times and Completion Times, October 1998.
I 8.
WCAP-1 5376-P-A, Revision I, Risk-Informed Assessment of the RTS and ESFAS Surveillance Test Intervals and Reactor Trip Breaker Test and Completion limes, March 2003.
I 9.
Westinghouse letter SCP-04-90 dated August 27, 2004.
(continued)
CALLAWAY PLANT B 3.3.1-65 Revision 25
 
RIS Instrumentation B 3.3.1 BASES REFERENCES 20.
ULNRC-03748 dated February 27, 1998.
(continued) 21.
IDP-ZZ-0017.
22.
WCAP-1 2472-P-A, BEACON Core Monitoring and Operations Support System, August 1994.
23.
WCAP-12472-P-A,Addendum 1-A 124. Attachment I to TSTF-569, Methodology to Eliminate Pressure ISensor and Protection Channel (for Westinghouse Plants only)
IResponse Time Testing.
CALLAWAY PLANT B 3.3.1-66 Revision 25
 
ESFAS Instrumentation B 3.3.2 BASES SURVEILLANCE SR 3.3.2.8 (continued)
REQUIREMENTS exclusion does not explicitly apply to the AFW pump start on trip of both turbine-driven MEW pumps; howevei the TADOT test procedures for that Eunction do not require the verification of a nominal trip setpoint or allowable value since none have ever been specified in the Technical Specifications for that anticipatory actuation signal which is not credited in any accident or transient analysis.
SR 3.3.2.9 SR 3.3.2.9 is the performance of a CHANNEL CALIBRATION.
CHANNEL CALIBRATION is a complete check of the instrument loop, including the sensor. The test verifies that the channel responds to a measured parameter within the necessary range and accuracy.CHANNEL CALIBRATIONS must be performed consistent with the assumptions of Reference 6.
The Surveillance Erequency is based on operating experience, equipment reliability, and plant risk and is controlled under the Surveillance Erequency Control Program.
This SR is modified by a Note stating that this test should include verification that the time constants are adjusted to the prescribed values where applicable. This does not include verification oftime delay relays.
These are verified via response time testing per SR 3.3.2.10.
The portion of the automatic PORV actuation circuitry required for COMS is calibrated in accordance with SR 3.4.12.9.
SR 3.3.2.10 This SR verifies the individual channel ESF RESPONSE TIMES are less than or equal to the maximum values assumed in the accident analysis.
Response time verification acceptance criteria are included in Reference 9. No credit was taken in the safety analyses for those channels with response times listed as N.A. No response time testing requirements apply where N.A. is listed in Reference 9. Individual component response times are not modeled in the analyses. The analyses model the overall or total elapsed time, from the point at which (continued)
CALLAWAY PLANT B 3.3.2-65 Revision 24
 
ESFAS Instrumentation B 3.3.2 BASES SURVEILLANCE SR 3.3.2.10 (continued)
REQUIREMENTS the parameter exceeds the trip setpoint value at the sensor, to the point at which the equipment in both trains reaches the required functional state (e.g., pumps at rated discharge pressure, valves in full open or closed position). The safety analyses include the sum of the following response time components:
a.
Sensing circuitry delay time from the time the trip setpoint is reached at the sensor until an ESFAS actuation signal is generated by the SSPS (response time testing associated with LSELS and BOP-ESFAS is discussed under SR 3.3.5.4, SR 3.3.6.6, SR 3.3.7.6, and SR 3.3.8.6);
b.
Any intentional time delay set into the trip circuitry (e.g., NLL cards (lead/lag) associated with the steam line pressure high negative rate trip function) to add margin or prevent spurious trip signals; and c.
The time for the final actuation devices to reach the required functional state (e.g., valve stroke time, pump or fan spin-up time).
For channels that include dynamic transfer functions (e.g., lag, lead/lag, rate/lag, etc.), the response time verification is performed with the time constants set at their nominal values. Time constants are verified during the performance of SR 3.3.2.9. The response time may be verified by a series of overlapping tests, or other verification (e.g., Ref. I 0 and Ref. 14), such that the entire response time is verified.
Response time may be verified by actual response time tests in any series of sequential, overlapping, or total channel measurements, or by the summation of allocated sensor, signal processing, and actuation logic response times with actual response time tests on the remainder of the channel. Allocations for sensor response times may be obtained from:
(1) historical records based on acceptable response time tests (hydraulic, noise, or power interrupt tests); (2) inplace, onsite, or offsite (e.g. vendor) test measurements; or (3) utilizing vendor engineering specifications.
WCAP-13632-P-A Revision 2, Elimination of Pressure Sensor Response Time Testing Requirements, provides the basis and methodology for using allocated sensor response times in the overall verification of the channel response time for specific sensors identified in the WCAR Response time verification for other sensor types must be demonstrated by test.
(continued)
CALLAWAY PLANT B 3.3.2-66 Revision 24
 
ESFAS Instrumentation B 3.3.2 BASES SURVEILLANCE SR 3.3.2.10 (continued)
REQUIREMENTS WGAP-1 4036-P-A, Revision
, Elimination of Periodic Protection Channel Response Time Tests, provides the basis and methodology for using allocated signal processing and actuation logic response time in the overall verification of the protection system channel response time.
The allocations for sensor, signal conditioning, and actuation logic response times must be verified prior to placing the component in operational service and re-verified following maintenance that may adversely affect response time.
In general, electrical repair work does not impact response time provided the parts used for repair are of the same type and value. Specific components identified in References JO and 14 may be replaced without verification testing.
One example where response time could be affected is replacing the sensing assembly of a transmitter.
The response time may The Surveillance Frequency is based on operating experience, equipment reliability, and plant risk and is controlled under the Surveillance Frequency Control Program.
This SR is modified by a Note that clarifies that the turbine driven AFW pump is tested within 24 hours after reaching 900 psig in the SGs.
SR 3.3.2.11 SR 3.3.2. 1 1 is the performance of a TADOT for the P-4 Reactor Trip Interlock. A successful test of the required contact(s) of a channel relay may be performed by the verification of the change of state of a single contact of the relay. This clarifies what is an acceptable TADOT of a relay.
This is acceptable because all of the other required contacts of the relay are verified periodically by other Technical Specifications and non-Technical Specifications tests. The Surveillance Frequency is based on operating experience, equipment reliability, and plant risk and is controlled under the Surveillance Frequency Control Program.
The SR is modified by a Note that excludes verification of setpoints during the TADOT. The Function tested has no associated setpoint. This TADOT does not include the circuitry associated with steam dump operation since it is control grade circuitry.
(continued) be verified for components that replace the components that were previously evaluated in Ref. I 0 and Ref. I 4, provided that the components have been evaluated in accordance with the NRC approved methodology as discussed in Attachment I to TSTF-569, Methodology to Eliminate Pressure Sensor and Protection Channel (for Westinghouse Plants only) Response Time Testing, (Ref. 24).
CALLAWAY PLANT B 3.3.2-67 Revision 24
 
ESFAS Instrumentation B 3.32 BASES SURVEILLANCE SR 3.3.2.12 REQUIREMENTS (continued)
SR 3.3.2.12 is the performance of a COT on ESFAS Function 6.h, AFW Pump Suction Transfer on Suction Pressure - Low. A successful test of the required contact(s) of a channel relay may be performed by the verification of the change of state of a single contact of the relay. This clarifies what is an acceptable CHANNEL OPERATIONAL TEST of a relay. This is acceptable because all of the other required contacts of the relay are verified by other Technical Specifications and non-Technical Specifications tests.
A COT is performed to ensure the channel will perform the intended Function. Setpoints must be found within the Allowable Values specified in Table 3.3.2-1.
The setpoint shall be left set consistent with the assumptions of the current unit specific setpoint methodology.
The Surveillance Frequency is based on operating experience, equipment reliability, and plant risk and is controlled under the Surveillance Frequency Control Program.
SR 3.3.2.13 SR 3.3.2. 1 3 is the performance of a SLAVE RELAY TEST as described in SR 3.3.2.6, except that SR 3.3.2.13 has a Note specifying that it applies only to slave relays K602, K622, K624, K630, K740, and K741. These slave relays are tested with a Frequency specified in the Surveillance Frequency Control Program and prior to entering MODE 4 for Functions I.b, 3.a.(2), and 7.a whenever the unit has been in MODE 5 or 6 for
> 24 hours, if not performed within the previous 92 days (Reference 12).
The Surveillance Frequency is based on operating experience, equipment reliability, and plant risk and is controlled under the Surveillance Frequency Control Program.
SR 3.3.2.14 SR 3.3.2.14 is the performance of a SLAVE RELAY TEST as described in SR 3.3.2.6, except that SR 3.3.2.14 has a Note specifying that it applies only to slave relay K750. The slave relay is tested with a Frequency specified in the Surveillance Frequency Control Program and prior to entering MODE 3 for Functions 5.a and 9.a whenever the unit has been in MODE 5 or 6 for > 24 hours, if not performed within the previous 92 days.
(continued)
CALLAWAY PLANT B 3.3.2-68 Revision 24
 
ESFAS Instrumentation B 3.3.2 BASES SURVEILLANCE SR 3.3.2.14 (continued)
REQUI REMENTS The Surveillance Frequency is based on operating experience, equipment reliability, and plant risk and is controlled under the Surveillance Frequency Control Program. Testing slave relay K750 at power would result in opening the PORVs and depressurizing the RCS. lfthe PORV block valves are closed, there is not enough pressure to open the PORVs.
REFERENCES I.
FSAR, Chapter 6.
2.
FSAR, Chapter 7.
3.
FSAR, Chapter 15.
4.
IEEE-279-1971.
5.
10 CFR 50.49.
6.
Callaway Setpoint Methodology Report (NSSS), SNP (UE)-565 dated May I
, I 984, and Callaway Instrument Loop Uncertainty Estimates (BOP), J-U-GEN.
7.
Not used.
8.
Callaway OLAmendment No. 64 dated October 9, 1991.
9.
FSAR Section 16.3, Table 16.3-2.
10.
WCAP-13632-P-A, Revision 2, Elimination of Pressure Sensor Response Time Testing Requirements, January 1996.
11.
Callaway OLAmendment No. 43 datedApril 14, 1989.
12.
SLNRC 84-0038 dated February 27, 1984.
13.
Callaway OLAmendment No. 117 dated October 1, 1996.
14.
WCAP-14036-P-A, Revision 1, Elimination of Periodic Protection Channel Response Time Tests, October 1998.
15.
FSAR, Section 15.5.1.
16.
FSAR, Section 15.6.1.
(continued)
CALLAWAY PLANT B 3.3.2-69 Revision 24
 
ESFAS Instrumentation B 3.3.2 BASES REFERENCES 7 7.
Letter from Mel Gray (NRC) to Garry L. Randolph (UE), Revision (continued) 20 of the Inservice Testing Program for Callaway Plant, Unit I (TAC No. MA4469), dated March 1 9, 1999.
I 8.
WCAP-14333-P-A, Revision I, Probabilistic Risk Analysis of the RPS and ESFAS Test Times and Completion limes, October 1998.
1 9.
WCAP-1 5376-P-A, Revision
, Risk-Informed Assessment of the RTS and ESFAS Surveillance Test Intervals and Reactor Trip Breaker Test and Completion limes, March 2003.
20.
Westinghouse letter SCP-04-90 dated August 27, 2004.
21.
ULNRC-03748 dated February 27, 1998.
22.
IDP-ZZ-00017.
23.
Callaway License Amendment 201, dated July 28, 201 1.
: 24. Attachment 1 to TSTF-569, Methodology to Eliminate Pressure and Protection Channel (for Westinghouse Plants only)
Response Time Testing.
CALLAWAY PLANT B 3.3.2-70 Revision 24}}

Revision as of 18:05, 24 November 2024

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