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| =Text= | | =Text= |
| {{#Wiki_filter:Mr. Charles H. Cruse . | | {{#Wiki_filter:}} |
| August 26, 1997 !j Vice President - Nuclear Energy -
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| ) Baltimore Gas and Electric Company j Calvert Cliffs Nuclear Power Plant hp 1650 Calvert Cliffs Parkway W Lusby, MD 20657-4702 $6
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| ==SUBJECT:==
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| STATUS OF CALVERT CLIFFS IMPROVED TECHNICAL SPECIFICATIONS
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| , CONVERSION SUBMITTAL -
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| ==Dear Mr. Cruse:==
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| | |
| On August 21, 1997. NRR staff spoke to Peter Chabot and Ray Schiele Baltimore Gas and Electric Co@any (BGE) licensing management, regarding the status of the Calvert Cliffs Technical S Technical Specifications (ITS)pecifications
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| . The purposeconversion of the phone to call the was Improved to reaffirm NRC's comitment to successfully complete the Calvert Cliffs conversion with BGE assistance. When we receive BGE responses to all NRC comments we will be able to give you a date for the draft Calvert Cliffs Safety Evaluation (SE).
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| Enclosed is a copy of the draft H. B. Robinson SE to provide your staff with a newly proposed format for future SEs. The draft SE departs from previously issued SEs through the use of tables to provide a more concise document. The licensee assisted NRC in preparing the tables. The enclosed draft SE remains under internal NRC review, but the format has been discussed with senior NRR management and the Office of General Council (0GC) and has been simultaneously
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| , mailed to the licensee and a copy placed in the Public Document Room (PDR),
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| We appreciate the discussion candor of August 21. and look forward to working with BGE to complete the Calvert Cliffs conversion and issuance of the SE.
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| Sincerely.
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| Original signed by:
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| Will b i D. Beckner Chief Technical Specifications Branch Associate Director for Proiects Office of Nuclear Reactor Itegulation Dochet Nos. 50 317 and 50 318
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| ==Enclosure:==
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| Draft H. B. Robinsor SE cc: See next page NBC lFILE DEHER COPY Sistribution iard Co3v w/ encl Hard Coov w/o encl.
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| )occet :ile JAZwolinski LDoerflein RI PUBLIC WDBeckner TSB Reading File AWDr vmerick FMReinhart MLReardon OGC RSchiele. BGE ACRS m(C vr (
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| j DOCUMENT NAME: G:\ LETTER-8.21 '
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| ll[ {llll ll ll l llll l l See previous concurrence A [ '
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| OFFICE TSB/ADPR PM:PDI-1 iPD:PDl-1 C:ISB/ADPRW~l NAME MLReardon* AWDromerick* JAZwolinsk1* WDBeckner l DATE 8/25/97 8/25/97 8/26/97 8/ 6 /97 l j p , . .g 3 Official Record Copy D 05 317 P PDR .
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| p .y 1
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| j p UNITED STATES g ]. NUCLEAR REEULATCRY CSMMISSION el '
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| WASHINGTON, D.C. RoseMcM
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| %, * * * * ) August 26, 1997 Mr. Charles H. Cruse Vice President - Nuclear Energy Baltimore Gas and Electric Compan Calvert Cliffs Nuclear Power Plar.yt 1650 Calvert i,liffs Parkway
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| * Lusby, MD 20657-4702
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| | |
| ==SUBJECT:==
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| STATUS OF CALVERT CLIFFS IMPROVED TECHNICAL SPECIFICATIONS CONVERSION SUBMITTAL
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| | |
| ==Dear Mr. Cruse:==
| |
| | |
| On August 21, 1997, NRR staff spoke to Peter Chabot and Ray Schiele. Baltimore Gas and Electric Company (BGE) licensing management, regarding the status of the Calvert Cliffs Technical Specifications conversion to the Improved Technical Specifications (ITS). The purpose of the phone call was to reaffirm NRC's comitment to successfully complete the Calvert Cliffs conversion with BGE assistance. When we receive BGE responses to all NRC coments we will be able to give you a date for the draft Calvert Cliffs Safety Evaluation (SE).
| |
| Enclosed is a copy of the draft H. B. Robinson SE to provide your staff with a newly proposed format for future SEs. The draft SE departs from previously issued SEs through the use of tables to provide a more concise document. The
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| ' licensee assisted NRC in preparing the tables. The enclosed draft SE remains under internal NRC review, but the format has been discussed with senior NRR management and the Office of General Council (OGC) and has been simultaneously mailed to the licensee and a copy placed in the Public Document Room (PDR).
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| We apareciate the discussion candor of August 21. and look forward to working with EE to complete the Calvert Cliffs conversion and issuance of the SE.
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| Sincerely, W L b. $A William D. Beckner. Chief Technical Specifications Branch
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| . Associate Director for Projects Office of Nuclear Reactor Regulation
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| * Docket Nos. 50-317 and 50-318
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| | |
| ==Enclosure:==
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| Draft H. B. Robinson SE cc: See next page
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| | |
| l Mr. Charles H. Cruse Calvert Cliffs Nuclear Power Plant
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| ~ Baltimore Gas & Electric Company Unit Nos. I and 2 cc w/o enc 1:
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| President Mr. Joseph H. Walter, Chief Engineer Calvert County Board of Public Service Commission of Comissioners Maryland 175 Main Street Engineering Division Prince Frederick, MD 20678 6 St. Paul Centre Baltimore, MD 21202-6806 James'P Bennett, Esquire Counsel Kristen A. Burger, Esquire Baltimore Gas and Electric Company Maryland People's Counsel P.O. Box 1475 6 St. Paul Centre Baltimore, MD 21203 Suite 2102 Baltimore, MD 21202-1631 Jay E. Silberg, Esquire Shaw,. Pittman, Potts, and Trowbridge Patriciu i. Birnie. Esquire 2300 N Street, NW Co Director Washington.>DC 20037 Maryland Safe Energy Coalition P.O. Box 33111
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| . Mr. Thomas N. Prichett, Director Baltimore, MD 21218
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| . NRM Calvert Cliffs Nuclear Power Plant Mr. Loren F. Donatell 1650 Calvert Cliffs Parkway NRC Technical Training Center Lusby. MD 20657-4702 5700 Brainerd Road
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| , Chattanooga, TN 37411-4017 Resident Inspector U.S. Nuclear Regulatory Mr. Peter G. Chabot
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| - Commission - Nuclear Engineering Manager P.O. Box 287 Baltimore Gas and Electric Company St. Leonard, MD 20685 Calvert Cliffs Nuclear Power Plant
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| -1650 Calvert Cliffs Parkway Mr. Richard I. McLean Lusby, MD 20657-4702 Administrator - Radioecology 1
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| Department of Natural Resources i -580 Taylor Avenue Tawes State Office Building, B3 g Annapolis. HD -21401
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| * Regional' Administrator, Region I ;
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| U.S. Nuclear Regulatory Commission !
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| 475 Allendale Road King of Prussia, PA 19406 k - - . = , , <
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| - . ..,o-
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| ~~
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| 7.lRiMG6WYruse August 26, 1997 Vice President - Nuclear Energy 4
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| Baltimore Gas and Electric Company Calvert Cliffs Nuclear Power Plant 4 1650 Calvert Cliffs Parkway
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| -Lusby, MD- 20657-4702-
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| | |
| ==SUBJECT:==
| |
| STATUS OF CALVERT CLIFFS IMPROVED TECHNICAL SPECIFICATIONS
| |
| . _, CONVERSION SUBMITTAL i
| |
| | |
| ==Dear Mr. Cruse:==
| |
| | |
| On August 21, 1997. NRR staff spoke to Peter Chabot and Ray Schiele Baltimore Gas and Electric Company (BGE) licensing management, regarding the status of the Calvert Cliffs Technical Specificatione. conversion to the Improved Technical Specifications (ITS). The purpose of the phone call was to reaffirm NRC's commitment to successfully complete the Calvert Cliffs conversion with BGE assistance, When we receive BGE responses to all NRC comments we will be able to give you a date for the draft Calvert Cliffs Safety Evaluation (SE).
| |
| Enclosed-is a copy of the draft H. B. Robinson SE to provide your staff with a newly proposed fermat-for future SEs. The draft SE departs from previously issued SEs through the use of tables to provide a more concise document. The licensee assisted NRC in preparing the tables. The enclosed draft SE remains under internal NRC review, but the format has been discussed with senior NRR management and the Office of General Council (0GC) and has been simultaneously
| |
| , mailed to the licensee and a copy placed in the Public Document Room (PDR).
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| We appreciate the discussion candor of August 21. and look forward to working-with BGE to complete the Calvert Cliffs conversion and issuance of the SE.
| |
| Sincerely.
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| Original signed by:
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| William D. Beckner, Chief Technical Specifications Branch Associate Director for Projects l- Office of Nuclear Reactor Regulation Docket Nos. 50-317 and 50-318
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| | |
| ==Enclosure:==
| |
| Draft H. B. Robinson SE 5=
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| cc: See next page Distribution lard Co3v w/ encl Hard Cc:~4 /o encl.
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| Docket :11e JAZwolinski LDoerflein. RI PUBLIC WOBeckner TSB Reading File AWDromerick FMReinhart
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| , -MLReardon OGC o RSchiele BGE ACRS DOCUMENT NAME: G:\ LETTER-8.21
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| * See previous concurrence 3 0FFICE TSB/ADPR PM:PDI-l PD:PDl C:TSB/ADPR W '
| |
| NAME MLReardon* AWDromerick* JAZwolinsk1* WDBeckner i DATE 8/25/97 8/25/97 8/26/97 8//L1,/97 Official Record Copy
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| : p. ., a +m--swa - - - -
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| <w
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| | |
| Mr. Charles .He Cruse -
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| -August 26,-1997
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| .* -Vice President - Nuclear Energy- ;
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| Baltimore Gas-and Electric Company i- . - Calvert C11ffs Nuclear-Power P1 ant-
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| '' :1650 Calvert Cliffs Parkway l _
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| Lusby,;MB 20657-4702-
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| | |
| ==SUBJECT:==
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| - STATUS OF CALVERT CLIFFS IMPROVED TECHNICAL SPECIFICATIONS
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| ., ~ CONVERSION SUBMITTAL
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| .. i
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| | |
| ==Dear Mr.-Cruse:==
| |
| | |
| 1 On: August 21, 1997, NRR staff spoke'to Peter Chabot and Ray Schiele, Baltimore 4
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| Gas'and Electric Company (BGE) licensing management, regarding the status of Lthe Calvert Cliffs Technical S Technical. Specifications (ITS)pecifications
| |
| .: The purpose of conversion the phone to the call Improved was to reaffirm i
| |
| :Nf!C's commitment to successfully complete the Calvert Cliffs conversion with-
| |
| : BGE assistance. When we receive BGE responses to all NRC-comments we will be
| |
| ; able to give you a date for the draft Calvert Cliffs Safety Evaluation (SE).
| |
| E Enclosed is a copy of the draft H. B. Robinson SE to provide your staff with a-newly proposed format for future SEs. The draft SE departs from previously
| |
| -issued SEs through the use of tables to provide a more-concise document. The licensee assisted NRC in. preparing the tables. The enclosed draft SE remains under internal NRC review . but the format has been discussed with senior NRR 1 management and the G U1ce of Gcneral Council (0GC) and has been simultaneously '
| |
| , mailed to the licensee and a copy placed in the Public Document Room (PDR) - i We appreciate the discussion candor of August 21 and look fonvard to working with BGE to complete the Calvert Cliffs conversion and issuance of the SE, .
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| Sincerely.
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| Original signed by:
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| ^
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| William.0, Beckner --Chief-Technical Specifications Branch Associate'Directorz for Projects Office of, Nuclear-Reactor Regulation Docket Nos. 50-317 and 50-318
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| | |
| ==Enclosure:==
| |
| Draft H. B. Robinson SE_ ;
| |
| cc: 'See next page Distribution Hard Co)v w/ encl Hard Cocy w/o encl.
| |
| Docket ile JAlwolinski LDoerflein, RI-PUBLIC -_ WDBeckner TSB Reading File AL'Drcaerick FMReinhart
| |
| -MLReardon OGC- ,
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| RSchiele, BGE ACRS DOCUMENT NAME: G:\ LETTER-8.21
| |
| * See previous concurrence _b 0FFICE TSB/ADPR PM:PDl-1 PD:PDI-1 C:TSB/ADPR W ~
| |
| NAME MLReardon*- AWDromerick* JAZwolinsk1* WDBeckner-DATE 8/25/97 8/25/97 8/26/97 8/ 6 /97 official Record copy
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| | |
| SAFETY EVALUATION BY THE OFFICE OF NUCLEAR REACTOR REGULATION RELATED TO AMENDMENT NO. W TO FACILITY OPERATING LICENSE DPR 23 H. B. ROBINSON STEAM ELECTRIC PLANT UNIT NO. 2 CAROLINA POWER & LIGHT COMPANY
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| : DOCKET NO. 50-261
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| : 1. INTRODUCTION i
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| H. B. Robinson Steam Electric Plant Unit No. 2 (HBR) has been operating with technical specifications (TS) issued with the original operating license on July 31,1970, as amended from time to time. By {{letter dated|date=August 27, 1996|text=letter dated August 27,1996}}, as supplemented by letters dated January 17, 4
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| February 18, March 27, April 4, April 25, April 29, May 30, June 2, June 13, June 18, August 4, and August 8,1997, Carolina Power & Light (the licensee) proposed to amend Appendix A of Operating License No. DPR 23 to completely revise the HBR TS. The proposed amendment was based upon NUREG 1431, " Standard Technical Specificatic,'s - Westinghouse Plants,"
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| Revision 1, dated April 1995, and upon guidance in the "NRC Final Policy Statement on
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| ; Technical Specification improvements for Nuclear Power Reactors" (Final Policy Statement),
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| published on July 22,1993 (58 FR 39132). The overall objective of the proposed amendment,
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| , consistent with the Final Policy Statement, was to rewrite, reformat, and streamline completely the existing TS for HBR, Hereinafter, the proposed TS are referred to as the improved TS (ITS), the existing HBR TS are
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| , refenad to as the current TS (CTS), and the TS in NUREG-1431 are referred to as the standard TS (STS). The corresponding TS Bases are ITS Bases, CTS Bases, and STS Bases, respectively, in addition to basing its ITS on STS and the Final Policy Statement, the licensee retained portions of the CTS as a basis for the ITS. Plant-specific issues, including design features, requirements, and operating practices, were discussed with the licensee during a series of conference calls and meetings that concluded on July 30,1996. Based on these discussions, i the licensee revised its proposed changes by submittals dated August 8,1997, and [**] 1997, in addition, the licensee proposed matters of a generic nature that were not in STS. The NRC staff requested that tne licensee submit such generic issues as a proposed change to STS through the Nuclear Energy Institute's Technical Specifications Task Force (TSTF). These generic issues were considered for specific applications in the HBR ITS. Consistent with the Final Policy Statement, the licensee proposed transferring some CTS requirements to licensee-controlled documents. In addition, human factors principles were emphasized to add clarity and understanding to the CTS requirements being retained in the (Plant Name) c \...\draf tse.a20 -1* revised: noon; August 20, 1997 4
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| . ~ -
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| j ITS cnd to de'ine m:re clearty th9 cppropriate scope of the ITS, Further, significant changes
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| ! were proposed to the CTS Bases to make each ITS requirement clearer and easier to
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| . understand, L The Commission's proposed action on the HBR application for an amendment dated
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| : August 27,1996, was published in the FEDERAL. REGISTER on October.?g,1996
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| - (61 FR 55830)J Supplements to the licensee's ITS proposal, submitted by Jetters dated January 17, February 18, March 27, April 4, April 25, April 29, May 30, June 2, June 13, June 18, August 4, and August 8,1997, that resulted from discussions with the licensee during the staff review, are incorpurated in this Safety Evaluation (SE). These plant specific changes serve to clarify the iTS with respect to the guidance 8n the Final Policy Statement and STS. Therefore, the changes
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| - are within the scope of the action described in the initial FEDERAL REGIMF8t notice.
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| During its review, the NRC staff relied on the Final Policy Statement and on WTS as guidance for
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| ;. acceptance of CTS changes. This SE provides a summary basis for the staff conclusion that i HBR can develop ITS based on STS, as modified by plaat specific changes, and that the use of 1 the ITS is acceptable for continued operation. The staff also acknowledges that, by the Final
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| : Policy Statement, the conversion to STS is a voluntary process. Therefore, ITS differs from STS, j reflecting the current licensing basis. The staff accepts the licensee changes to the CTS with l modifications documented in the revised submittals.
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| ! For the reasons stated Infra in this SE, the staff finds that the TC issued with this license
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| ! amendment comply with Section 182a of the Atomic Energy Act,10 CFR 50.36, and the
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| ! guidance in the Final Policy Statement, and that they are in accord with the common defense and
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| ; security and provide adequate protection to the public health and safety.
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| ; ll. BACKGROUND i
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| Section 182a of the Atomic Energy Act requires that applicants for nuclear power plant operating
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| . . licenses will state:
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| l j- [S)uch technical specifications, including information of the amount, kind, and .
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| t source of special nuclear material required, the place of the use, the specific
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| ! characteristics of the facility, and such other information as the Commission may, l by rule or regulation, deem necessary in order to enable it to find that the
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| , utilization . . . of special nuclear material will be in accord with the common l- defense and security and will provide adequate protection to the health and safety of the public, Such technical specifications shall be a part of any license issued.
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| [ In 10 CFR 50.36, the Commission established its regulatory requirements related to the content -
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| L of TS, in doing so, the Commission placed emphasis on those matters related to the prov6ntion of accidents and the mitigation of accident consequences; the Commission noted that applicants were expected to incorporate into their TS "those items that are directly related to maintaining the integrity of the physical barriers designed to contain radioactivity." Statement of Consideration,
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| , - ' Technical Specifications for Facility Ucenses; Safety Analysis Reports," 33 FR 18610 -
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| l (December 17,1968).- Pursuant to 10 CFR 50.36 TS are required to include items in the i
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| ' following five specific categories: (1) safety limits, limiting safety system settings and limiting -
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| control settings; (2) limiting conditions for operation (LCOs); (3) surveillance requirements (SR);
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| ;: (4) design features; and (5) administrative controls. - However, the rule does not specify the -
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| i particular requirements to be included in a plant's TS, Y
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| l j
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| plant usme) c \...\draf tee.n20 revised: 12 noon, August 20i 1997
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| ) ,
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| -.Aenum._--en.5ar' e44&And-in. SpW NeNM P-
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| , , , , _ p. ..e
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| n
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| - For several years, NRC and industry representatives have sought to develop guidelines for 4
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| - improving the content and quality of nuclear power plant TS On February 6,1987, the ;
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| - Commission issued an interim policy statement on TS improvements, " Interim Policy Statement on Technical Specification improvements for Nuclear Power Reactors"(52 FR 3788) During the
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| ' period from 198g to 19g2, the utility Owners Groups and the NRC staff developed improved standard technical specifications that would establish models of the Commission's policy for each -
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| primary reactor type.- in addition, the staff, licensees, and Owners Groups developed generic j administrative and editorial guidelines in the form of a " Writers Guide" for preparing technical j specifications, which gives greater consideration to human factors principles and was used j- throughout the development of licensee specific ITS. '
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| k - in September 19g2, the Commission issued NUREG-1431, which was developed using the i guidance and criteria contained in the Commission's interim policy statement. STS were
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| ! established as a model for developing improved TS for Westingnouse plants in general. STS l reflect the results of a detailed review of the application of the interim policy statement criteria to -
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| l- generic system functions, which were published in a " Split Report" issued to the Nuclear Steam System Supplier (NSSS) Owners Groups in May 1988. STS also reflect the results of extensive L discussions concoming various drafts of STS, so that the application of the TS criteria and the l Writer's Guide would consistently reflect detailed system configurations and operating j
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| characteristics for all NSSS designs. As such, the generic Bases presented in NUREG 1431 provide an abundance of information regarding the extent to which the STS present requirements -
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| that are necessary to protect the public health and safety.-
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| i on July 22,19g3, the Commission issued its Final Policy Statement, expressing the view that l . satifs ying ht e gui dance in the policy statement also satisfies Section 182a of the Act and 10 CFR l 50.36. The Final Policy Statement described the safety benefits of the improved STS, and i
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| encouraged keensees to use the improved STS as the basis for plant specific TS amendments,
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| ! and for complete conversions to improved STS. Further, the Final Policy Statement gave 3 guidance for evaluating the required scope of the TS and defined the guidance criteria to be used L in determining which of the LCOs and associated surveillances should remain in the TS. The j Commission noted (58 FR 39132) that, in allowing certain items to be relocated to licensee-
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| , controlled documents while requiring that other items be retained in the TS, it was adopting the j qualitative standard enunciated by the Atomic Safety and Licensing Appeal Board in Portland i GeneralElectric Co. (Trojan Nuclear Plant), ALAB 531,9 NRC 263,273 (1979). There, the Appeal Board observed:
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| [T]here is neither a statutory nor a regulatory requirement that every operational
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| !- detail set forth in an applicant's safety analysis report (or equivalent) be subject to j a technical specification, to be included in the license as an absolute condition of l operation which is legally binding upon the licensee unless and until changed with -
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| i specific Commission approval. Rather, as best we can discem it, the j-contemplation of both the Act and the regulations is that technical specifications are to be reserved for those matters as to which the imposition of rigid conditions or limitations upon reactor operation is deemed necessary to obviate the
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| - possibility of an abnormal situation or event giving rise to an immediate threat to I the public health and safety, f
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| ] By this approach, existing LCO requirements that fall within or satisfy any of the criteria in the
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| : Final Policy Statement should be retained in the TS; those LCO requirements that do not fall j- within or satisfy these criteria may be relocated to licensee-controlled documentsi The i
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| t
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| { (Mont Name) c \...\draf tse.e20 3- revised: 12 noon, Ateust 20, 1997 4
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| i i
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| -- ~_
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| Commission codified the four criteria in 10 CFR 50.36 (60 FR 36593, July 19,1995). The Final Policy Statement criteria are as follows:
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| - Cntedon 1 installed instrumentation that is used to detect, and indicate in the control room, a significant abnormal degradation Of the reactor coolant pressure boundary.
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| Cntenon 2 A process variable, design feature, or operating restriction that is an initial condition of a design basis accident or transient analysis that either assumes the failure of or presents a challenge to the integnty of a fission product barrier.
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| Cntenon 3 A structure, system, or component that is part of the primary success path and which functions or actuates to mitigate a design basis accident or transient that either assumes the failure of or presents a challenge to the integrity of a fission product barrier.
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| Cntenon 4 A structure, system, or component which operating experience or probabilistic safety assessment has shown to be significant to public health and safety.
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| Part 111 of this SE explains the staff conclusion that the conversion of the HBR CTS to those based on STS, as modified by plant specific changes, is consistent with the HBR current licensing basis and the requirements and guidance of the Final Policy Statement and 10 CFR 50.36.
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| Ill. EVALUATION The staff ITS review evaluates changes to CTS that fall into four categories defined by the licensee and includes reviewing whether existing regulatory requirements are adequate for controlling future changes to requirements removed from the CTS and placed in licensee-controlled documents. This evaluation also discusses the staff plans for monitoring the licensee's implementation plans of these controls at HBR.
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| The staff review identified the need for clarifications and additions to the submittal in order to 2 establish an appropriate regulatory basis for translatien of current TS requirements into ITS.
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| Each change proposed in the amendment request is identified as either a discussion of change to CTS or a justification for deviation from STS. . The staff comments were documented as requests for additional information (RAls) and forwarded to the licensee for response by letters dated January 10, February 24, March 6, March 28, April 9, and May 22,1997. The licensee provided written responses to the staff requests in letters dated February 18, March 27, April 4, April 25, Aptil 29, May 30, June 13, June 18, and August 8,1997. The docketed letters clarified and revised the licensee basis for translating CTS requirements into ITS. The staff finds that the docketed material related to the review of ITS provides sufficient detail to reach conclusion regarding the adequacy of the licensee proposed changes.
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| - IPlant llame] c \...\draf tse.a20 - 4* revised: noon; August 20, 1997
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| ~ .. _ . -
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| The license amendment application was organiz:d such that changes were included in c:ch of the following CTS change categories, as appropriate: administrative changes, less restrictive
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| . requirements (LR), more restrictive requirements (MR), STS differences, and relocated specifications.
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| (1) Administrative, i.e., non-technical changes in the presentation of existing requirements; (2) Less Restrictive, i.e., deletion of existing TS requirements, by movement of information and requirements from existing specifications (that are otherwise being retained) to licensee-controlled documents, including TS Bases; (3) More Restrictive, require, i.e., new or additional CTS requirements; (4) STS differences, i.e., retention of existing requirements based on plant specific design or current licensing basis; and (5) Relocated specifications (from CTS Chapter 3/4.0 only), i.e., relaxations in which
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| .whole specifications (the LCO and ass::,iated action and SR) are removed from the existing TS (an NRC-controlled document) and placed in licensee-controlled documents. .
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| These general categories of changes to the licensee's current TS requirements and STS differences may be better understood as follows:
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| Administrative Changes Administrative (non-technical) changes are intended to incorporate human factors principles into
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| - the form and structure of the ITS so that plant operations personnel can use them more easily.
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| These changes are editorial in nature or involve the reorganization or reformatting of CTS requirements without affecting technical content or operational restrictions. Every section of the ITS reflects this type of change. In order to ensure consistency, the NRC staff and the licensee have used STS as guidance to reformat and make other administrative changes. Among the changes proposed by the licensee and found acceptable by the staff are:
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| - (1)- providing the appropriate numbers, etc., for STS bracketed information (information that must be supplied on a plant-specific basis and that may change from plant to plant)
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| (2) identifying plant-specific wording for system names, etc.
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| (3) changing the wording of specification titles in STS to conform to existing plant '
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| practices (4) splitting up requirements currently grouped under a single current specification to more appropriate locations in two or more specifications of ITS (5) combining related requirements currently presented in separate specifications of the -
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| CTS into a single specification of ITS.
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| - Conclusion (Plant name) cab ..\ draftee.a20 5* revised: noon; August 20, 1997
| |
| | |
| -- The staff reviewed all of the cdministrative and editorial changes propos:d by the licensee end finds them acceptable, because they are compatible with the Writers Guide and STS and are consistent with the Commission's regulations.
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| More Restrictive Requirements -
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| The licensee, in electing to implement the specifications of STS proposed a number of requirements more restrictive than those in the CTS, ITS requirements in this category include requirements that are either new, more conservative than corresponding requirements in the CTS, or that have additional restrictions that are not in the CTS but are in STS Examples of more restrictive requirements are placing an LCO on plant equipment which is not required by the CTS to be operable, more restrictive requirements to restore inoperable equipment, and more restrictive SRs.
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| Table MR lists the more restrictive changes proposed in ITS. Table MR is organized by the corresponding ITS section discussion of change and provides a summary description of the more restrictive change that was adopted, and CTS and ITS LCO references.
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| Conclusion These changes are additional restrictions on plant operation and are appropriate and acceptable.
| |
| Less Restrictive Requirements Less restrictive requirements include changes, deletions and relaxations to portions of current TS requirements that are not being retained in ITS, or the ITS Bases. When requirements have been shown to give little or no safety benefit, their removal from the TS may be appropriate. In most cases, relaxations previously granted to individual plants on a plant. specific basis were the result of (1) generic NRC actions, (2) new ataff positions that have evolved from technological advancements and operating experience, or (3) resolution of the Owners Groups comments on STS. The NRC staff reviewed generic relaxations contained in STS and found them acceptable because they are consistent with current licensing practices and the Commission's egulations.
| |
| The HBR design was also reviewed to determine if the specific design basis and licensing basis are consistent with the technical basis for the model requirements in STS, and thus provide a
| |
| . basis for ITS .
| |
| A significant number of changes to the C TS involved the removal of specific requirements and detailed information from individual specifications. Such changes have been made to requirements and detailed information of the following general Categories:
| |
| Category 1 CTS LCO Applicability chaages (Category l}
| |
| Category 2 CTS Surveillance Frequency changes (Category ll)
| |
| Category 3 CTS LCO revised to address train configuration (Category til)
| |
| Category 4 CTS Allowed outage time extensions (Categories IV & Vil) 2 Category 5 CTS Action requirements for exiting LCOs are changed (Category V)
| |
| EPlant Name) c \...\draftse.a20 revised: noon; August 20, 1997
| |
| | |
| Category 6 CTS sury;illance accept:noe criteria tre changed (Cat:gtry VI)
| |
| Category 7. Elimination of CTS reporting requirements (Category Vill)
| |
| Category 8 Relaxation of LCO requirement (Category IX)
| |
| The staff has reviewed changes to the CTS in the above categories and concluded that these
| |
| ._ types of detailed information and specific requirements are not necessary to ensure the
| |
| . effectiveness of ITS to adequately protect the health ud safety of the public because they do not affect safe operation of the plant. The TS requirements that remain are consistent with current licensing practices, operating experience, and plant accident and transient analyses, and provide reasonable assurance that the public health and safety will be protected.
| |
| The following discussions address why each of the eight categories of information or specific requirements do not need to be included in ITS .
| |
| CTS LCO Anoticability channes (Category 1)
| |
| Reactor operating conditions are used in CTS to define when the LCO features are required to be operable. CTS applicabilities can be specific defined terms of reactor-
| |
| - conditions: hot shutdown, cold shutdown, reactor critical or power operating condition. '
| |
| Applicabilities can also be more general. Depending on the circumstances, CTS may require that the LCO be maintained within limits in "all modes" or "any operating mode."
| |
| Generalized applicability conditions are not contained in STS, therefore ITS eliminate CTS requirements such as "all mode" or "any operating mode."
| |
| ITS use defined modes or applicable conditions that are consistent with the application of the plant safety analysis assumptions for operability of the required features. In another application of this type of change, CTS requirements may be eliminated during conditions for which the safety function of the specified safety system is met because the feature is performing its intended safety function. DeletMg applicability requirements that are indeterminant or which are inconsistent with application of accident analyses :
| |
| assumptions is acceptable because when I.COs cannot be met, the TS can be satisfied by exiting the applicabilty thus taking the plant out of the conditions that require the safety system to be operable. These changs are consistent with STS. Therefore, deletion of Category 1 requirements is acceptable.
| |
| CTS Surveillance Frecuency channes (Category ll)
| |
| CTS and ITS surveillance frequencies specify time interval requirements for performing surveillance requirement testing, increasing the time interval between surveillance tests in the iTS results in decreased equipment unavailability due to test which increases equipment availability. In general, the STS contain test frequencies that are consistent with industry practice or industry standards for schelving acceptable levels of equipment reliability. Adopting testing practices specified in the STS is acceptable based on similar design, like-component testing for the system application and the availability of other TS requirements which provide regu!sr checks to ensure limits are met.
| |
| Reduced testing can result in a safety enhancement because the unavailability due to test is reduced; however, reliability of the affected structure, system cr component should remain constant or increase. Reduced testing is acceptable if operating experience, (Plant name) c \.. --\draf tse.a20 revised: 12 noon, August 20,-1997
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| ]_..%. J.
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| _e
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| .__ 4yJ 1-w
| |
| | |
| industry practice er the industry standards such as manufacturers' recommendations have shown that these components usually pass the Surveillance when performed at the specifed interval, thus the freqency is acceptable from a reliability standpoint. Altemate train testing is acceptable if there are other qualitative or quantitative test requirements which are established predictors of system performance, e.g., air flow is an indicator that positive pressure in a controlled space will be maintained since a more frequent (31 day) air flow test would use the same fans as the less frequent (36 month) pressartration test and experience shows that components usually pass the pressurization test.
| |
| Surveillance frequency extension can be based on staff approved topical reports. The staff can accer,t topical report changes if the topical report bounds the plant specific design and component reliabiltiy assumptions are met. These changes are consistent with STS. Therefore, deletion of Category 2 requirements is acceptable.
| |
| CTS LCO revised to address train confiauration (Category lil)
| |
| Due to the redundancy of trains and the diversity of subsystems, the inoperability of one component in a train does not render a safety system incapable of performing its intended design function. Neither does the inoperability of two different components, each in a different train, necesrarily result in a loss of functional capability for a safety system.
| |
| The intent of STS Conditions is to control the inventory of the equipment taken credit for in the safety analysis such that a sufficient complement of safety systems is available to
| |
| . perform their intended safety function for analyzed accidents. This allows increased flexibility in plant operations under circumstances when components in different trains are ,
| |
| inoperable; however, fundamental requirements for train separation are required to be met.
| |
| Specified STS Actions and Completion Times for trains are based on availability of redundant operable features, reasonable time for repairs, and low probability of a design basis accident (DBA) occurring during the period features remain inoperable, in general the STS use industry practice or industry standards for restoring trains to operable status.
| |
| These changes are consistent with STS. Therefore, deletion of Category 3 requirements is acceptable.
| |
| CTS Attowed outaae time extensions (Category IV & Vil)
| |
| Upon discovery of a failure to meet an LCO, STS specify times for completing required actions of the associated TS conditions. - Required actions of the associated conditions are used to establish remedial measures that must be taken within specified completion times (allowed outage times). These changes are consistent with STS. These times define limits during which operation in a degraded condition is permitted.
| |
| Adopting completion times from the STS is acceptable because completion times take into account the operability status of the redundant systems of TS required features, the capacity and capability of remaining features, a reasonable time for repairs or replacement of required features, and the low probability of a DBA occurring during the ,
| |
| repair pcriod. These changes are consistent with STS. Therefore, extension of Category 4 allowed outage times is acceptable.
| |
| CTS Action roouirements for exitina LCOs are chanaed (Category V)
| |
| IPtent heme) c \...\draf tee.a20 - s- revloeo: 12 noon, Aunust 20, 1997 I
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| 7 hww "' eNW AW2
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| | |
| CTS require that, in the event that any of the specifed LCOs are not met, specifed
| |
| ' reactor operations shall cease, work shall be initiated to correct the comfitions so that the spec fied limits are met, and no operations which may affect reactivity of the core shall be made. The STS actions are constructed to specify only conditions of required features made inoperable. Change to CTS action requirements for exiting LCO applicabilities is acceptable because CTS conditions include actions which also apply when some or all-required features are inoperable. This change is also acceptable because the Required
| |
| - Actions assure that operations that could challenge other TS sy;tems are ceased within an appropriate Completion Time.~ Additionally, making these types of changes is -
| |
| acceptable because they place the reactor in a Mode where the specification no longer applies; and these actions provide the same degree of protection required by the applicable safety analyses. These changes are consistent with STS. Therefore, deletion of Category 5 requirements is acceptable.
| |
| CTS surveillance reauirement accootence criteria are chanced (Category VI)
| |
| CTS require safety systems to be tested and verifed operable prior to entering applicable conditions. ITS provide the additonal requirement to verify operablility by actual or test conditions. Adopting the STS allowance is accept:5!e because TS required features cannot distinguish between an " actual" signal or a " test" signal. Category 6 also includes changes to CTS requirements that are replaced in the ITS with separate and distinct -
| |
| testing requirements which when combined include operability verification ci all TS required components for the features specified in the CTS, Adopting this format preference in the STS is acceptable because TS SRs that remain include testing of all previous features required to be verifed operable. These changes are consistent with STS. Therefore, deletion of Category 6 requirements is acceptable.
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| Elimination of CTS reportina reauirements (Category Vill)
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| CTS include requirements te submit Special Reports when specified limits are not met.
| |
| . Typically, the time period for de report to be issued is within 30 days. However, the STS eliminates the TS administraQe control requirements for Special Reports and instead relies on the reporting requi'ements govemed by the requirements of 10 CFR 50.73. ITS changes to reporting requi'ements are acceptable because special reporting
| |
| - requirements do not assuis that the plant will operate in a safe manner and there is no regulatory basis for the ',taff to accept or deny the reports it receives. Therefore, this change has no impact on the safe operation of the plant. Additionally, deletion of TS reporting requirement; reduces the administrative burden on the plant and allows efforts to be concentrated o'1 restoring TS requirert limits. These changes are consistent with STS. Therefore, deletion of Category 7 requirements is acceptable.
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| Relaxation ofI OO_renutrement (Category IX)
| |
| CTS list acceptable devices that may be used to satisfy the LCO requirements. Ttm ITS reflect the STS approach to provide requirements that specify the protective limit that is required to meet the safety analysis assumptions for operable features in place of acceptable mechanisms that are acceptable for meeting the TS limit for the specified feature. The ITS changes provide the same degree of protection required by the safety analysis and provide flexibility for meeting limits without adversely affecting operations since equivalent features are required to be operable. These changes are consistent with STS. Therefore, deletion of Category 8 requirements is acceptacle, rPlant namel c \...\draf tse.a20 revised: 12 noon, August 20, 1997
| |
| | |
| i Table L lists specific CTS requirements that have been deleted and which pertain to the above -
| |
| _ general types of changes. Table L is organized by ITS section discussion of change and provides a summary description of the change, CTS and ITS LCO references, a reference to the specific change category as discussed above, and a characterization of the discussion of change. These eight general categories oi CTS requirements that have been deleted from CTS are not required by 10 CFR 50.36 to be in the TS.
| |
| The licensee, in electing to ims lement the specifications of STS, also proposed a number of requirements less restrictive t'ian those in the CTS and which are not included in the general discussion of change-typ:3. The mest significant of these changes are discussed below.
| |
| Section 1.0 L.1 The CTS 1.6.2 defines channel calibration to encompass the entire channel and does not
| |
| - exclude resistance temperature devices (RTDs) and thermocoeples. For channels with RTDs and/or thermocouples, the ITS definition of channel calibration allows performing
| |
| "...an in place qualitative assessment of sensor behavior..." for these devices. This change is a less restrictive requirement for unit operations and is consistent with the STS.
| |
| A qualitative assessment af sensor behavior is acceptable for RTDs and thermocouples since the operation of these devices is govemed by well understood and predictable physical relationships between the temperature of the sensed medium and the output of the RTD or thermocouple. Additionally, the output of RTDs and thermocouples is the same manner as other sensors. As a result a qualitative assessment of sensor behavior is sufficient to determine its OPERABILITY and acceptability for continued use.
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| Section 2.0 none-Section 3.0 L1 CTS 3.0 does not include a provision equivalent to ITS 3.0.5 which allows retuming equipment to service under administrative control, solely to perform testing to _ .
| |
| demonstrate its OPERABILITY or the OPERABILITY of other equipment. This is an exception to ITS 3.0.2. It allows certain equipment to be restored to OPERABLE status while certinuing to comply with ACTIONS associated with the LCOs, thus avoiding a plant shitdown. This allowance represents a stable, safe attemative to requiring a plant shutdown to complete restoration and confirmatory testing of equipment removed from service or declared inoperable. Because this provision is restricted to activities deemed necessary to restore equipment Operability, it is acceptable.
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| -L2 CTS 4.0 does not include a provision equivalent to ITS SR 3.0.2, which states,"If a Completion Time requires periodic performance on a "once per..." basis,'the above _
| |
| Frequency extension applies to each performance after the initial performance." The purpose of ITS SR 3.0.2 is to allow the "1.25 times the interval specified in the Frequency" concept to apply to periodic Completion Times associated with Actions. This provides consistency in scheduling flexibility for all performances of periodic requirements, whether they are Surveillances or Required Actions. The activity is still (Plant Itame) c:\...\draftse.a20 revised: 12 noon, August 20, 1997
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| ~
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| | |
| ' performed, on the cvorage, once during each speciftd int:ry:1. Therefore, this is cn acceptable less restrictive change.
| |
| Section 3.1 L2 CTS 3.1.3.3 requires that the reactor be made subcritical by an amount greater than or equal to the potential reactivity insertion due to depressurization if the Moderator Temperature Coefficisnt (MTC) is outside the limits provided in thw Core Operating Limit Report (COLR). No completion tiene is stated. CTS 3.0 requires hot shutdown be -
| |
| achieved within 8 hours. ITS 3.1.3 Action A.1 requires establishment of administrative withdrawal limits for control banks to maintain MTC within the upper limit with a -
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| completion time of 24 hours if MTC is not within the upper limit. If ITS 3.1.3 Action A.1 is satisfied, no further action is required. The CTS does not preclude establishtrant of administrative withdrawal limits for control banks to maintain MTC within the upper limit.
| |
| However, the completion time of 24 hours allowed by the ITS is less restrictive than the 8 hours permitted t:y the CTS.
| |
| If ITS 3.1.3 Action A.1 is not met, ITS 3.1.3 Action B.1 requires being in MODE 2 with K,.
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| < 1.0 within 6 hours. This completion time is in addition to the 24 hours permitted by ITS
| |
| - 3.1.3 Action A.1 and is less restrictive than the 8 hours permitted by CTS.
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| (A specific Completion Time for CTS 3.1.3.3 to restore MTC to within the upper limit.) in '
| |
| order to place the plant in a non-applicable MODE, evaluating the MTC measurement and 4 obtaining the necessary input to compute the bank withdrawal limits for MTC limit compliance may require a time period longer than 8 hours. The ITS 3.1.3 Action A.1 completion time of 24 hours provides sufficient time for evaluating the MTC measurement and computing the required bank withdrawal limits. Additionally, the 24-hour Completion Time is based on the low probability of an accident occurring during this period and takes into consideration the fact that as cycle bumup is increased, reactor coolant system (RCS) boron concentration is reduced which causes MTC to become more negative.
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| 3 This reduces plant shutdown transients while in a condition where unit respons6 .iuring postulated events may not be as predicted. The change provides a specific action and completion time for falling to satisfy the LCO. This is an acceptable less restrictive change,
| |
| .L5. CTS 3.1.3.3 requires that the reactor be made subcritical by an amount greater than or equal to the potential reactivity insertion due to depressurization if the MTC is outside the limits provided in the COLR. No completion time is explicitly stated. CTS 3.0 requires hot shutdown be achieved within 8 hours. ITS 3.1.3 Action C.1 requires being in MODE 4 with a completion time of 12 hours if MTC is not within the lower limit. The completion time allowed by the ITS is greater than the 8 hours permitted by CTS 3.1.3.3. This change allows for a more controlled shutdown which reduces thermal stress on components and also reduces the chances for a plant transient which could challenge safety systems. This is an acceptable less restrictive change.
| |
| L6 CTS 3.10.1.5 actions associated with a misaligned rod are required to be taken within 2 hours if the rod position indication requirements of CTS Table 4.1-1 items 9 and 10 are not satisfied. The rod position indication instruments do not necessarily relate directly to rod OPERABILITY Q g., rods aligned within limits) or the ability to maintain rods within alignment limits. Because of this, ITS 3.1.7 is added to require the Analog Rod Position Indication (ARPI) System and the Demand Position Indication System to be OPERABLE (Plant name) c:\...\draftse.s20 - 11
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| * rwloed: 12 noon, August 20, 1997
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| -su.,. wy ,-m vupm Ph tmusH w- W4 e m.-__.-.. _ _ _ . - - . _
| |
| | |
| ^
| |
| in MODES 1 cnd 2 cnd provide altimate Actions to determine rod position or reduos power to s 50% RTP in the event of inoperable rod position indication. - Reducing power to s 50% RTP puts the core into a condition where rod position is not significantly
| |
| - affecting core peaking factors. The ITS 3.1.7 Actions am modified by a Note which allows separate Condition entry for each inoperable rod position indicator per group and each demand position indicator per bank. The ITS 3.1.7 Actions and the Completion Times contained in ITS 1.3 provide appropriate compensatory actions for each inoperable position indicator. There is a low probability of having a rod significantly out of position and an event sensitive to that rod position during the time period allowed to either implement an attomate mathod of determining rod position or reducing power to a level where rod position does nst significantly affect core peaking factors _ Any reduction in a margin of safety resulting from the proposed change will be offset by the potential benefit gained by avoiding an unnecessary plant power reduction or shutdown transient when attomate means exist to determine rod position. The change eliminates the requirement to consider rods to be misaligned when rod position indication is inoperable by providing an LCO and associated ACTIONS for rod position indication. This is an acceptable less restrictive change.
| |
| Section 3.2 L7 CTS 3,10.2.g allows calibration of the excore detectors if the axial flux difference (AFD) is .
| |
| within the target band for > g0% rated power, and if the AFD does not exceed the limits specified in the COLR for reactor power between 50% and 90% rated power. ITS 3.2.3 Applicability Note allows up to 16 hours of operation to be accumulated with AFD outside the target band without penalty deviation time while the excore detectors are being calibrated. Some deviation from the target band is necessary to perform the calibration of the excore detectors. - The duration that the AFD will be outside the target band for the purposes of excore detector calibration is sufficiently low to provide reasonable assurance that the overall effect on the axial peaking factor and axial xenon distribution will not impact the consequences of analyzed accidents. The process of the incere .
| |
| excore calibration involves inducing short-term axial power deviations in attomai.ng -
| |
| directions in order to develop a plot of excore detector response, Since the axial power deviations are attomated, the overall effect on axial xenon distribution is small. As such, any reduction in the margin of safety will be insignificant and offset by the benefit of avoiding an unnecessary change in Thermal Power during the calibration process. Some deviation from the target band is necessary to perform the calibration, and the axial offsets that are used to calibrate the excore detectors altomate between a plus and minus axial offset, such that the overall effect is small. This is an acceptable less -
| |
| restrictive change.
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| Section 3.3 '
| |
| L1 The CTS is revised to adopt the " ALLOWABLE VALUE" column from ISTS Tab'.e 3.3.1 1 and Table 3.3.2-1. This limit includes allowances for calibration tolerances, instrument uncertainties, instrument drift, and errors due to severe environmental conditions for RPS and ESFAS channels that must function in a harsh environment. The Allowable Values specified in Table 3.3.1-1 and Table 3.3.2-1 are conservatively set with respect to the analyticallimits. In establishing these allowable values, some have been determined to be less conservative than the CTS trip setpoint limits. The ITS limits fo. power range neutron flux (high and low), OTAT, OPAT, low pressurizer pressure, and RCS loop low flow result in a less conservative requirement for declaring channels inoperable, tPlant meme) c:\.. Adraftee.e20 rwined: 12 noon, August 20, 1997 i
| |
| 3 WW $ . sui m u - pumps. -4=ee.e ,gg4h. .4 h -v.Mc
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| | |
| However, because the actual nominal trip setpoint (operational limit as opposed to the TS limit) is still more conservative than that specified by the Allowable Value to account for changes _in random measurement errors, such as drift during a surveillance interval, these changes are acceptable. Setpoints set in accordance with the Allowable Value
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| ~
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| ensure that safety limits are not violated during abnormal operational necurrences -
| |
| (AOos), and that the consequences of design basis accidents (DBAs) will be acceptable,
| |
| - providing the unit is operated from within the LCOs at the onset of the ADO or DCA and the equipment functions as designed. The Allowable Values listed in Table 3.3.1 1 is the Limiting Safety System Setting as defined by 10 CFR 50.36. The Allowable Values listed in Table 3.3.1-1 and Table 3.3.2-1 are conservatively set with respect to the analytical limits, and are based on the methodology described in the company setpoint methodology procedure. The magnitudes of uncertainties are factoeed liito the determination of each
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| ' trip setpoint. ' All field sensors and signal processing equipment for these channels are assumed to operate within the allowances of these uncertainty magnitudes. This dange is consistent with STS.
| |
| L2 CTS 2.3.1.2.d and 2.3.1.2.s set the values of certain OTaT and OPaT parameters as being *=" to specific values. ITS Taule 3.3.1 1, Notes 1 and 2, set these same parameters as being either *1' or 'S' specific values. This is a relaxation of current TS requirements, and is less restrictive in that the ITS specifies a range of values, not previously permitted, as meeting TS requirements. This change is acceptable, however, because these parameter settings only permit the use of a more conservative setpoint in the plant hardware. Although these parameters normally do not change, they are cycle-specific and may change from time to time as a result of evaluations performed in the .
| |
| review of refueling safety analyses. This change is consistent with STS.
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| L7 The CTS is revised to adopt STS Specification 3.3.1, Required Action D.2.2 " Note." CTS Table 3.5 2, Action 2, requires that the Quadrant Power Tilt Ratio (QPTR) be monitored every 12 hours. This is required when Nuclear Flux Power Range channels are inoperable but only if thermal power is not restricted to less than 75% RTP and the Power Range Neutron Flux channel setpoints are not reduced to less than or equal to 85% of RTP within 4 hours. The ITS Required Action D.2.2 Note requires only that the QPTR surveillance be performed whsn the Power Range Neutron Flux QPTR input is inoperable. This is a relaxation of CTS remedial actions for TS requirements, and is less
| |
| . restrictive. This change is acceptable because failure of a component in the Power Range Neutron Flux chtnnel which does not render the High F'ux Trip Function Inoperable does not affect QPTR monitoring capability. As such, performing the CTS -
| |
| surveillance using the movable incore detectors, when the Power Range Neutron Flux input is operable, is unnecessary. Yherefore, the SR can be eliminated. This change is consistent with STS.
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| Le The CTS is revised to adopt STS Specification 3.3.1 Required Action G in the ITS. The CTS has no specific action requirements in the event two Interme&;
| |
| Range Neutron Flux channels become Inoperable when the unit is operating at a Thermal power >P-6 and <P-10. CTS Section 3.0 would therefore be entered, requiring the unit to be in hot shutdown in 8 hours and in cold shutdown within -
| |
| the next 30 hours or the reactor placed in a non-applicable Mode or condition.
| |
| STS Required Action G requires, under these conditions, that operations
| |
| , involving positive reactivity additions be suspended immediately, and Thermal (Plant name) c \...\draftse.a20
| |
| * 13 - revised: 12 noon, August 20, 1997
| |
| | |
| L power be reduced 13 <P4 in 2 hours (i.e., placing the plant in a non-applicable condition). Below P4, STS Required Action H.1 requires restoration of two -
| |
| inoperable Intermediate Range Neutron Flux channels prior to increasing power above the P4 interlock. This change is acceptable, however, because with no intermediate range channels Operable, Rvquired Action G.1 is added to immediately suspend operations involving positive reactivity additions. -This will preclude any power level increase when the ability to monitor neutron flux is not evallat:le (above the P4 setpoint and below the P-10 setpoint, the intermediate range performs the neutron flux monitoring function). Power must also be reduced below the P4 setpoint within 2 hours (Required Action G.2) Below P-6, the Source Range Neutron Flux channels (STS Table 3.3.1-1 Function 4) are required to be Operable _ and will be able to monitor neutron flux. Therefore, since adequate neutron flux monitoring capability and trip capability is provided by the Source Range Neutron Flux channels and positive reactivity additions are required to be suspended, it is not necessary to require a plant shud.swn in accordance with CTS 3.0. - This change is consistent with STS.
| |
| L27 CTS Table 4.1 1 requires that the power-operated relief valve (PORV) Position Indication, PORV Block Valve Position Indicator, and Safety Relief Valve Position Indicator, '
| |
| Containment Level, Pressure, Hydrogen and Radiation Monitors be testad at an "R" Frequency. ITS Specification 3.3.3 has no such requirement. This is a relaxation of requirements and is less restrictive. This change is acceptable, however, because a
| |
| - channel calibratien is performed on these channels at an 18-month frequency. The channel calibration encompasses all the testing requirements for these Functions, from sensor to indicator, and provides reasonable assurance that the entire channel is operable.- This change is consistent with STS.
| |
| L30 CTS 3.5.1 is revised to adopt the STS Specification 3.3.5 ' Note" to Required Action B.1 in -
| |
| the ITS. The Note permits an inoperable Degraded Voltage Function channel to be bypassed for up to 4 hours for surveillance testing of other channels. Adoption of this Note is a relaxation of requirements, and is therefore less restrictive. This change is acceotabis, however, because there are three Degraded VoMage channels per bus, and tLb allowance is given where bypassing the channel does not cause an actuation, and where at least two other channels por bus are monitoring the parameter. The Degraded Voltage Function is arranged in a two-out of three configumtion. Bypassing one channel would still provide a two-out-of-two logic. The time allowed is reasonable, considering the Function remains fully operable on each bus and the low probability of an event occurr;r.3 during the interval. This change is consistent with STS.
| |
| l.32 CTS Table 3.41, Function 1, requires under certain channel inoperability conditions that
| |
| * the unit be maintained in hot shutdown. ITS 3.3.8, Required Action B, requires under similar conditions, that the inoperable channel be placed in trip in 6 hours, or be in Mode 3 in 12 hours, and MODE 4 in 18 hours. This is a relaxation of requirements, and is less restrictive. This change is acceptable, however, because placing the inoperable channel in trip maintains the AFW pump autostart FuncCon Operable, but in a one-out of-two configuration, instead of two-out-of-three. The ellowance of 6 hours to ratum the channel
| |
| ' to operable status or place it in trip is consistent with WCAP 10271. AA, Supplement 2, '
| |
| Rev.1, June 1930. This change is consistent with STS, (Plant alone) c:\...\draf tse.s20 - 14
| |
| * revised: 12 noon, August 20, 1997
| |
| {
| |
| | |
| ! As required by the staff Saf ty Ev:luation (dated April 30,1990) accepting the generic reliability analysis in WCAP 10271 P A, Supplement 2 Rev.1, CP&L has confirmed that the HBR logic design of the affected instrumentation is bounded by that analyzed in the ;
| |
| . reliability analysis and the oor.clusions are applicable to the HBR design. In addition, CP&L has confirmed that the instrument drift due to extended Surveillance Frequencies, associated with application of the generic reliability analysis to the HBR instrumentation, is already property accounted for in the setpoint calculation methodology.
| |
| L36 CTS Table 3.5-2 Action 3 requires for an inoperable intermediate range neutron flux channel with thermal power above the P4 setpoint, but below 10% RTP, that the inoperable channel be restored to operable status prior to increasing thermal power above 10% RTP. ITS 3.3.1 F4 quired Action F requires for an inoperable intermediate range neutron flux channel with thermal power above the P 6 setpoint, but below the P-10 t
| |
| setpoint, that thermal power either be reduced to below P-6 or increased above P 10 in 2
| |
| . hours. The intermediate range neutron flux channels must be operable when the power levelis above the capability of the source range and below the capability of the power range. The CTS does not permit an increase in power level to exit the Applicability of the -
| |
| intermediate range detectors. The required action to increase thermal power to exit the ,
| |
| Applicability for the intermediate range detectors is less restrictive. The change is '
| |
| acceptable since the intermediate range detectors are not required to be operable above P-10 setpoint, and power range instrumentation provides the necessary protection above .
| |
| P 10 and this allowance represents exiting the LCO Applicability. -This change is consistent with STS, '
| |
| L41 = This change adds a Note to the calibration requirement in CTS Table 4.1-1 for items 1,2, and 3 (Nuclear Power Rai ge, Nuclear Intermediate Range, and Nuclear Source Range) excluding the neutrun detectors from this Surveillance (ITS SR 3.3.1.11). The ::hannel calibration is a complete check of the int,trument loop and the sensor. The test verifies that the channel responds to the measured parameter within tt.a necessary range and accuracy. The neutron detectors are excluded from the channel calibration because they are passive devices with minimal drift, and because of the difficulty of simulating a meaningful signal. This change is consistent with industry practice and with STS.
| |
| L50 CTS Tats's 3.5-3 does not address the condition of all channels of an ESFAS instrumentation Function inoperable or a train of ESFAS Instrumentation inoperable. Due to the plant des'gn, maintenance or survel: lance testing of a single channel can not be performed without causing all channels of the associated Function to be inope.%Ie. In many cases, maintenance or surveillance testing will also cause the associated train to be inoperable. Therefore, ITS 3.3.2 Required Actions Note 2 is adopted to permit a single ESFAS instrumentafon train to be inoperable for the purpose of maintenance or surveillance testing for up to 12 hours provided the other train is Operable. The Note also specifies that the provision does not apply to manual actuation Functions.
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| Currently, all Functions of an assoolated ESFAS train are tested at one time. The proemdure for performing testing does not result in the entire train being made inoperable.
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| However, each of the Functions within an ESFAS train are made inoperable for short periods of time until testing of all channels of the associated ESFAS train is completed.
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| . Repetitive action entry and exit during testing of the at,5ociated ESFAS train, on a per Function basis, represents an unnecessary administrative burden on the plant operations staff and would result in extending the time period required to complete the testing.
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| (Plant Name) c:\...\ & eftse.a20 revloed: 12 noon, August 20, 1997 o m. .- . -*-
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| y-r.--. bm eS L .ur Em er .-- -
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| | |
| Therefore, a single time period is provided to cover all testing of the associated ESFAS -
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| train.
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| For repair or replacement of Engineered Safeguard System relays and/or test switches, .
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| 12 hours has been determined to be a reasonable Completion Time for restoration of the two most frequently occurring types of failures that occur in the HBR Engineered Safeguards System. These two failures are 1) failure of a logic or actuation relay, and 2) failure of the test switches used for the performance of the surveillance testing. A failure of either of these items only causes one pcrtion of the Engineered Safeguards System to be inoperable, but due to the wiring configuration of the system (the common side of the relay power source is " daisy chained" together) the entire train must be considered inoperable once maintenance on the failed item has commenced. In addition, with the test switches in " test" during surveillance testing, all channels in an ESFAS instrumentation Function are rendered inoperable.
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| The change to provide 12 hours for the performance maintenance or surveillance testing _
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| on an ESFAS instrumentation train is acceptable based on the other ESFAS instrumentation train that is available to perform the actuation function and the low -
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| probability of an event requiring an ESFAS actuation, in addition, the change provides $
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| the potential bene 91 of the avoidance of a plant shutdown transient by providing a time period to perform required surveillance testing or necessary maintenance prior to -
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| requiring a plant shutdown.
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| Section 3.4 L1 ITS 3.4.5 " Note," ITS 3.4.6
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| * Note 1,' and ITS 3.4.7 " Note 1' permit all reactor coolant pumps (RCPs) or residual heat removal (RHR) pumps to be de-energized for up to 1 hour in any S-hour period to permit tests designed to validate various accident analyses values. This exception is not addressed in the CTS. This change is acceptable, however, because such an operation would be performed as part of a special test, and be controlled under close scrutiny by shift operating personnel, in addition, the allowances of the Notes may only be used if no operations which could cause a reductien of RCS i
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| boron concentration are being performed, core outlet temperature is maintained at least 10 degrees F below saturation temperature, and for ITS 3.4.5 and 3.4.6 measures are taken to preclude a power excursion resulting from an inadvertent control rod withdrawal event (the Rod Control System is incapable of md withdrawal). Industry operating L = experience has shown boron stratification is not a problem during a 1-hour period with no forced flow and natural circulation in conjunction with the core outlet temperature restriction discussed above ensure the core remains adequately cooled. For the above
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| , reasons this change is acceptable.
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| s -
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| L4 CTS 3.3.1.4.b requires that, if both RHR loops become inoperable, all containment penetrations providing direct access from the containment atmosphere to the outside atmosphere be closed prior to the RCS average temperature exceeding 200*F, This requirement is not retained in ITS 3.4.7 and 3.4.8. This is a relaxation of requirements, and is less restrictive. This change is acceptabla because ITS 3.4.7 and 3.4.8, unlike the CTS, require action be initiated immediately to restore one RHR train to OPERABLE -
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| status and operation. Further, to preclude any change in the shutdown margin and in tum any increased possibility of a radioactive release, the ITS suspends all operations involving the reduction in RCS boron concentration.
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| tPlant Ilame) c:\...\ draftee.e20 revised: 12 noon, August 20, 1997 e t E8=6
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| | |
| L5 The CTS is revised to adopt ITS 3.4.7 " Note 2,* and ITS 3.4.8 ' Notes 1 and 2.* ITS 3.4.8 Note 1 permits all RHR pumps to be de energized for up to 15 minutes when switching from one train to another or to perform testing of the RHR loop supply valves. Note 2 -
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| allows one RHR train to be inoperable and doenergized (for ITS 3.4.7 Note 2) for a period of up to 2 hours. These are relaxations of requirements because CTS does not contain -
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| these exceptions, and they are therefore less restrictive. The changes are acceptable, however, because the circumstances for stopping both RHR pumps are limited to
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| - situations when the outage time is short and core outlet temperature is maintained > 10*F :
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| . below saturation temperature. Boron dilution and draining operations are prohibited when
| |
| - RHR forced flow is stopped thus reducing risk of boron stratification. An RHR train is only permitted to be inoperable for a period of 2 hours provided the othat train is OPERABLE.
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| Additionally, these exceptions provide the added safety benefit of permitting periodic surveillance tests to bs peiformed on the inoperable train during the only time when these tests are safe and possible.
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| L6 CTS 3.3,1.4 requ!res that both RHR loops be OPERABLE in the cold shutdown condition.
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| ITS 3.4.7 requires, when in MODE 5 with the RCS loops filled, that either both RHR trains be OPERABLE and one in operation, or one RHR train OPERABLE and in operation and ono SG be OPERABLE. This change is less restrictive because both trains of RHR are not required to be OPERABLE at all times during MODE 5. This change is acceptable, however, because in either ITS configuration (as in the CTS), redundant decay heat . -
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| removal systems are required to be OPERABLE and available for use.
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| L7 CTS 3.1.1.3.c.1 requires that pressurizer code safety valve lift settings be between 2485
| |
| , psig and 2560 psig. ' ITS 3.4.10 requires that safety valve lift settings be between 2410 -
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| psig and 2560 pain. This is a relaxation of requirements and is less rest ictive. This change is acceptable, however, since the same level of overpressure protection is provided.' The wider OPERABILITY range of 2485 psig 13% allows for drift during valve setpoint test intervals, as permitted by Section 111 of the ASME Code. During setpoint
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| . testing, the valves are reset to 2485 psig i 1%, as required by Section XI of the ASME Code L8- CTS 3.3.1.3 requires that the safety injection (SI) pump breakers be racked out when RCS temperature is below 350*F end the system is not vented to containment atmosphere. ITS 3.4,12.a.2 recluires all but one 81 pump be made incapable of injecting into the RCS when the RCS temperature is a 175'F. This is a relaxation of requirements, '
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| and is less restrictive. This change is acceptable based on a new overpressure -
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| protection analysis performed to allow OPERABILITY of one train of Si in MODE 4. The analysis assumes one Si pump capable of injection into the RCS with RCS temperature a 175'F and < 350'F. -
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| - Lg - Not Used. [L DOC Matrix includes L.g as in the "none" category.
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| L12 CTS 3.1.5.4.b requires that, with leakage from'any pressure isolation valve (PlV) not within limits, operation may continue provided at least two, valves are confirmed to be in, and remain in, the position corresponding to the isolated condition. ITS 3.4.14 requires isolation of the high pressure line by a single valve within 4 hours, followed with isolation of the line by a second valve within 72 hours. This is a relaxation of requirements and is i-less rest'ictive. This change is acceptable, however, because although the CTS requires both valves to be closed essentialty simultaneously, it does not specify a completion time limit for the required actions. The extended interval is also acceptable because it is (Plant name) c:\...\ draftee,a20 - 17 - redsed: 12 noon, August 20, 1997 w-e 4 v eshau4kA 6L4 trudem e s=m e4P++ 'a ew =
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| | |
| based on the time usualty required to perform this action and considers the low probability of another valve falling during this period.
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| L13 CTS Table 4.13, item 17.1, requires Piv leakage be verified prior to entering reactor operation whenever the unit has been in cold shutdown for 72 hours. ITS 3.4.14 requires -
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| PlV leakage be verified whenever the unit has been in MODE 5 for 7 days or more. Since the result of this change is a not reduction in the number of times PlV leakage verification will be required over the remaining life of the plant, it is a relaxation of requirements and is less restActive. This change is acceptable, however, since PiV leakage verifcation is performed routinely at an 18-month frequency, and historical leakage verification experience has shown the PlVs usually pass the survell'ances when performed at that frequency. Further, any maintenance pedormed on a PlV while the plant is in cold shutdown for any length of time is required to be followed up with the appropriate post-maintenance testing. Consequently, extending the shutdove period for which the testing
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| . exception will apply should have little ' impact on safety.
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| L17 CTS 3.3.1.4.a requires, in the event of an inoperable RHR loop, the existence of a method to add make-up water to the RCS be verified wt'.hin 24 hours, and the inoperable RHR loop be restored to operable status within 14 days. ITS 3.4.7 and 3.4.8 each require action be initiated immediately to restore a socor,d RHR trein to operable status. This change imposes less restrictive requirements because in the ITS there are no time requirements within which the inoperable RHR train is to be restored nor are there any requirements to verify a method to add make-up water. These changes are acceptable because while the specific action times are removed, en immediate completion time is .
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| added. As discussed in ITS 1.3, when an "Immediately" is used as a Completion Time, '
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| the Required Action should be pursued without delay and in a controlled raanner. The substitution of a requirement that results in immediate action in place o' two requirements which would allow action to be delayed for hours and days, respectiv'.,1y, has been determined to provide an acceptable level of safety.
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| L20 The CTS is modified by the addition of ITS 3.4.17. Required Actions D.1, D.2, and D.3 to require that in the event that seal injection to any RCP is not within limits and both required charging pumps are inoperable, then the plant must be cooled down and depressurized to an RCS pressure < 1400 psig. No comparable action is contained in the CTS. In such a condition, the CTS would require entry into CTS 3.0 which requires that the plant be placed in hot shutdown within 8 hours and in cold shutdown within an additional 30 hours. Therefore, the ITS requirement to reduce reactor pressure to below 1400 psig is a less restrictive requirement. The changes, however, are acceptable.
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| Depressurizing the reactor to < 1400 psig would allow the SI pumps to perform the RCS makeup function during the rer. sir period to restore charging pumps to operable status.
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| With RCS inventory controlled in such a manner, there would not be a need to proceed to a shutdown mode, if at anytime, seal failure (s) increased plant leakage above the limit of ITS 3.4.13 "RCS Operational LEAKAGE," then the failure to comply with these limits would require the plant to be placed in cold shutdown in a time period consistant with CTS requirements, thereby assuring adequate protection of public health and safety.
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| L21 CTS 3.2.2.d requires system piping, instrumentation, controls, and valves be operable to the extent of establishing one flow path from the BASTS and one flow path from the RWST to the RCS. That is modified in ITS 3.4.17 to require two operable Makeup Water Pathways from the RWST. This change is acceptable because it assures that there are two pathways available from the RWST to the charging pump suction heade,r, each of (Plant meme) c \...\eiraftee.a20 revised: 12 noon, August 20, 1997
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| _ m-- ._u.---_
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| | |
| which provides cn adequate source of makeup for RCP seal injection. Further, removal of the requirements for one flow path from the BASTS is acceptable because, boration flow paths are not required to prevent or mitigate the consequences of any accident analyzed as part of the plant design basis. .
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| I 1.24 CTS Table 4.13 item 17.2 requires, whenever the integrity of a RCS pressure isolation valve cannot be demonstrated, the integrity of the remaining valve to be determined and recorded daily, in this condition, CTS Table 4.1.3 item 17.2 also requires that the position of the other closed valve located in the high pressure piping to be recorded daily. Under this same condition, ITS 3.4.14, HCS Pressure Isolation Valves (PlVs), Required Actions A.1 and A.2 require isolation of the high pressure portion of the piping from the low pressure portion of the piping by the use of two valves. In addition, ITS 3.4.14 Required ;
| |
| Actions A.1 and A.2 are modified by a Note that requires the valves used to meet the requirements of Required Actions A.1 and A.2 to satisfy the leakage criteria of SR 3.4.14.1 (i.e., integrity determined to be acceptable) and that the valves be in the reactor coolant pressure boundary or high pressure portion of the piping. This is less restrictive because the ITS does not require daily determinations and recordings of valve integrity.
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| However, this change is acceptable because with two valves providing the isolation the normal periodic surveillance frequency (ITS SR 3.4.14.1) for RCS PlV leakage testing
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| _ provides adequate assurance of PlV OPERABILITY. While during the surveillance interval it would be possible that both valves could lose their integrity, that is very unlikely, if the Surveillance is not performed within the normal surveillance interval, compliance ,
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| with the requirements of the Note to Required Actions A.1 and A.2 would not be satisfied for these valves and a shutdown per Required Actions C.1 and C.2 would be required (i.e., action taken to exit the Applicability of the LCO). If at any time it is discovered that the valves used to comply with Required Actions A.1 and A.2 did not satisfy the requirements of SR 3.4.14.1, Condition C must be immediately entered and Required Actions C.1 and C.2 taken.
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| Section 3.5 L3 CTS 4.5.1.1 requires the SI System tests be performed in such a manner to prevent injection into the reactor coolant system. This requirement is not retained in the ITS. It is expected future testing will be consistent with current methodology which does not result in actual injection. Testing which results in actual injection is acceptable since the test .
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| would still demonstrate acceptable system operation. This change is consistent with the STS.
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| L4 CTS 4.5.1.2 specifies certain details regarding test method (e.g., control board indications and visual observation, proper sequence and timing, etc.) regarding acceptable Si System test results. These test method details are not retained in ITS. The ITS specified verification of pump starts and valve actuations is sufficient to demonstrate OPERABILITY. This change allows increased flexibility in testing methodclogy while still requiring verification of OPERABILITY. This change is consistent with STS.
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| L5 CTS 4.5.2.1 mandates a test method for the verification of the specified valve positions.
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| Specifically, this specification requires ve;ification ". . . from the RTGB indicators / controls
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| . . . that the specified valves are in the proper position with control power removed. This test method detail is not retained in ITS. The ITS SR 3. _.1 specified verification that the valves are in their proper position with control power removed is sufficient to demonstrate OPERABILITY. This change allows increased flexibility in testing
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| 'Ptent mene) c:\...\ draftee.e20 - revised: 12 noon, August 20, 1997
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| -ww++
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| mgv n h .1
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| methodology while still requiring verification of OPERABILITY. This change is consistent with the STS.
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| L6- In Hot Shutdown, CTS 3.3.1.3 imposes raquirements for ECCS in motordance with CTS 3.3.1.1 and 3.3.1.2. CTS 3.3.1.1 requires two ECCS trains to be operable. CTS 3.3.1.2 permits one ECCS component (81 pump, RHR pump, RHR heat ex: hanger) to be inoperable for up to 24 hours. Wdh less than one ECCS train OPERABLE, no specific action is provided. in this condition, entry into CTS 3.0 is required. CTS 3.0 requires the unit be placed in Cold Shutdown within 30 hours. ITS 3.5.3 requires only one ECCS train to be OPERABLE in MODE 4. With the required ECCS RHR subsystem inoperable, ITS 3.5.3 Required Action A.1 requires action be Iriitiated immediately to restore one required -
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| ECCS RHR subsystem to OPERABLE status. This change is consistent with the STS.
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| Due to the stable conditions associated with operation in MODE 4 and the reduced probability of occurrence of a DBA, the ECCS operational requirements are reduced.
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| With both RHR pumps and heat exchangers inoperable, it would be unwise to require the plant to go to MODE 5, where the only available heat removal system is the RHR.
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| Therefore, the appropriate action is to initiate measures to restore one ECCS RHR subsystem and to continue the actions until the subsystem is restored to OPERABLE status.
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| L7 With the RWST boron concentration not within limits, CTS-required action is specified in 3.0. CTS 3.0 requires achieving hot shutdown within 8 hours, followed by cold shutdown within an additional 30 hours. ITS 3.5.4 Required Action A.1 permits 8 hours to restore the RWST to OPERABLE status. With Required Action A.1 and its associated completion time not met, ITS Required Actions C.1 and C.2 require achieving MODE 3 within 6 hours, and MODE G within 36 hours.
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| The 8 hours to restore the boron concentration to within limits is acceptable based upon' consideration of the time required to change the boron concentration and the fact that the contents of the tank are still available for injection. Permitting prompt corrective action to restore the boron concentration to within limits is preferable to requiring immediate plant shutdown, with the increased risk for a plant transient. This change is consistent with the STS.
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| L8 A CTS provision comparable to the Note to the Applicability of ITS Specification 3.5.2 does not exist. This ITS Note permits one ECCS train to be inoperable for up to four hours after entry into MODE 3 or until the RCS cold leg temperatures exceed 375'F, whicinever comes first. Operation in MODE 3 with one ECCS train decia.ad inoperable pursuant to LCO 3.4.12. " Low Temperature Overpressure Protection (LTOP) System,'is necessary for plants with an LTOP arming temperature at or near the MODE 3 boundary L temperature of 350'F. LCO 3.4.12 requires that certain pumps be rendered inoperable at and below the LTOP arming temperature. When this temperature is at or near the MODE 3 boundary temperature, time is needed to restors the inoperable pumps to OPERABLE status. This Note permits entry into MODE 3 without first meeting the LCO requirements. The limitations imposed on duration and cold leg temperatures are bounded by the 72 hours permitted by ITS 3.5.2 Required Action A.1 for one ECCS train being inoperable when in MODES 1,2 and 3. This change is consistent with the STS.
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| Section 3.6 (Plant llame) ct\...\draf tee.a20 revised: 12 rioon, Atsust 20, 1997
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| *--km .+-=w-
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| | |
| i l L1 CTS 3.6.1.c cnd d contain unique requirements, p
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| l- _ CTS 3.6.1.c limits positive reactivity changes by rod drive motion when containment I-integrity is not intact except during specified evolutions. During the specified evolutions SDM is limited to a 1% ak/k.~ CTS 3.6.1.d limits positive reactive changes made by boron dilution when containment integrity is not intact. The limitatioins are not retained in ITS.
| |
| ITS 3.1.1 directly limits SDM and ITS 3.g.1 directly limits SDM by imposing a limit on boron concentration independent of containment status. Limiting positive reactMty changes which do not challenge the required SDM is unnecessary, since the specified SDMs are the minimum values assumed in the applicable safety analysis. This less restrictive change eliminates unnecessary restrictions on plant operatiori and is acceptable.
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| L2 CTS requirements comparable to ITS 3.6.3 ACTION Note 1 do not exist. ITS 3.6.3 ACTION N 1 permits an INOPERABLE penetration flow path to be unisolated -
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| intermittermy under administrative control. This is a less restrictive requirement upon -
| |
| plant operation. Permitting intermittent unisolation of an inoperable penetration under administrative control may be required in order to meet other Surveillance Requirements, tr d 'he Note is not intended to allow circumvention of the Completion Times, An exa spie of when the capabilities afforded t y this Note may be utilized is temporarily unkdating a sample flow path to acquire a required sample. --
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| L6 CTS 3.3.2.2.a permits a containment cooler or flow path to be inoperable provided both containment spray pumps are OPERABLE. This restriction regarding OPERABILITY of the two containment spray pumps is not retained provided the four containment coolers are OPERABLE. LThis restriction regarding OPERABILITY of the four containment coolers is not retained in ITS. ITS 3.6.6 R.A A.1 and R.A C.1 permit a containment cooling unit associated with the same train to be inoperable simultaneously without regard to other systems OPERABILITY. These are less restrictive requirements upon plant operation.
| |
| The combination of ITS Condition A and Condition C is bounded by failure of a single ,
| |
| emergency diesel generator (EDG), A failure of a single EDG results in loss of one containment spray train and one containment cooling train. ITS Condition A and : '
| |
| CondiJon C are both predicted upon a short term relaxation of the single failure criteria (i.e., for the duration of the Completion Time of the applicable ACTION, no additional single failure is assumed).- One containment spray train in combination with one train of containment cooling provides sufficient heat removal capacity to maintain containment peak pressure and temperature below the design limits. Aciditionally, the iodine removal capability remains consistent with the assumptions of the a,x:ident analysis. The individual Completion Times were developed taking into account the redundant heat removal capabilities afforded by combinations of the Containment Spray System and Containment Cooling System and the low probability of DBA occurring during this period.
| |
| Section 3.7 L1 CTS 3.4.1.a requires 12 main steam safety valves (MSSVs) OPERABLE. ITS 3.7.1 requires MSSVs OPERABLE as specified in ITS Tables 3.7.1-1 and 3.7.1-2. Table 3.7.1-1 permits fewer MSSVs to be OPERABLE at reduced power levels. This is a relaxation of CTS requirements which is less restrictive. This change is acceptable, however, because Section ill of the Ameri:an Society of Mechanical Engineers (ASME) Boiler and ,
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| -(Plant stene) c \...\ draftee.a20
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| * 21 - revised: 12 noon, August 20, 1997 c- p ewP es --mea
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| | |
| L Pressure VCasel Code permits operation with fewer than 12 MSSVs OPERABLE as long as THERMAL POWER is limited to the relief capacity of the MSSVs remaining OPERABLE. This is accomplished by restricting THd^ RMAL POWER so the energy
| |
| - transfer to the most limiting steam generator is not greater than the available relief-capacity in that steam generator, Such limitations are specified in ITS Table 3.7.1-1.
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| L2- CTS 3.4.1 requires the plant to be shut down if the requirements for OPERABILITY of the -
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| MSSVs are not met within 24 hours. A Note to ITS Action 3.7.1 is added that allows separate condition entry for each MSSV, Since the CTS has no provision to increase the allowed outage time when one MSSV becomes inoperable afler another, this change is less restrictive. This change is acceptable because ITS 3.7.1 Required Action A.1 allows only 4 hours for THERMAL POWER reductions to maintain the steam generator stored -
| |
| energy below the available relief capacity. Separate condition entry for each inoperable MSSV is necessary to allow the use of ITS Table 3.7.12 and allows the orderty
| |
| - adjustment of THERMAL POWER in response to the Required Actions.
| |
| -L5 ITS 3.7.4 Required Action E.1 and Note include requirements for three inoperable AFW pumps or hur inoperable AFW flow paths. CTS 3.4.5 has no ascific required action to address the inoperability of all three AFW pumps and essential features. Hence, those conditions would result in entry into CTS 3.0 anel the required action is to place the plant in hot shutdown in 8 hours and cold shutdown within an additional 30 hours. Because the, addition of ITS 3.7.4 Required Action E.1 allows continued operation until at least one pump and flow path of AFW is restored to OPERABLE status, this change is less restrictive. This change is acceptable, however, because it is appropriate to restore at-least one pump and flow path of AFW to OPERABLE before placing the unit in conditions ,
| |
| where AFW is required to provide inventory to the steam generators.
| |
| L12 - The CTS 3.151.b requirement suspending any operation which would reduce shutdown margin to less than required for cold shutdown or refueling is not retained in the ITE This is a relaxation of requirements, which is less restrictive. This change is acceptable, however, because ITS 3.7.10 is applicable specifically during the times during cold -
| |
| s shutdown or refueling (CORE ALTERATIONS and movement of fuel assemblies) where radioactive releases could potentially occur. Those activities are suspended if both Wins of control room emergency air temperature control are inoperable, thereby this eliminW 5 any activities that could result in a release of radioactivity that might enter the control room.
| |
| Section 3.8 - :
| |
| --3.8.6 L7 CTS Surveillance Requirement 4.6.3.3 requires an annual equalization charge o'f each battery. This requirement is not retained in the ITS. An equalization charge is a special-charge given a battery when non-uniformity in voltage or specific gravity has developed between cells, it is given to restore all cells to a fully charged condition using a charging voltage higher than the normal float voltage. Therefore, it is inappropriate to mandate an equalization charge at a set frequency, The ITS SRs provide appropriate vertfication of battery parameters. When the need for an equalization charge is indicated by battery parameters, an equalization charge is utilized to restore all cells to a fully charged condition. This is controlled by plant procedures, but required to keep the cells above the
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| -(Plant mene) c:\...\draftse.a20
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| * 22
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| * revised: 12 noon, August 70, 1997 e
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| | |
| l i
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| Category A limits. Deleting the required annual equalizing charge on each battery is a less restrictive requirement upon plant operation, consistent with the ftTS.
| |
| . L8 ' CTS Surveillanoe Requirement 4.6.1.5 requires testing the DG with a load between 1650 ;
| |
| kW and 2750 kW (110% of continuous load rating) for two hours of the 24-hour loaded run test. ITS SR 3.8.11 requires this load be maintained for a 1.75 hours of the 24 hour loaded run test. The 2-hour duration specified in CTS Surveillance Requirement 4.6.1.5 cannot be exceeded in any 24 hour period. The ITS test duration of a 1.75 hours _
| |
| ' confirms the DG OPERABILITY without exceeding the DG rating. The actual DG load
| |
| . during an accident will exceed the continuous load rating of 2500 kW for a period less than the specified test interval of 1.75 hours. This less restrictive change upon plant operation is consistent with the DG design requirements and increases safety.
| |
| Table 3.8.94 Lg CTS Table 4.1 3, item 18, requires testing the magnetic and thermal trip elements for the
| |
| . molded case circuit breakers supplying the automatic bus transfer (Ab f) device
| |
| , associated with Auxiliary Feedwater header discharge valve to steam generator A, V2-16A, and Turbine Building Cooling Water isolation valve, VS 16C. ITS SR 3.8.g.2 requires verifying the trip capability (magnetic only) for both of these breakers. Circuit breakers with a higher current interrupt capability and no thermal trip have replaced the
| |
| ! - original circuit brea'.. ors. A circuit thermal protection device is provided at the motor -
| |
| ; contactor. Elimination of the testing of these thermal trip elements reflects the current plant configuration and is a less restrictive requirement upon plant operation.
| |
| Section 3.g l
| |
| i none-I .
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| ' Section 4.0 l
| |
| { L1 _ CTS Specification 5.3.1.1 is revised by adopting the STS Specification 4.2.1 allowances for limited substitutions of filler rods and limited use of lead test assemblies in the ITS, This is relaxation of requirements and is less restrictive. This change is acceptable, however, because it provides specific recognition that reconstitution of a fuel assembly to
| |
| { replace damaged and leaking fuel rods is not considered to be an unreviewed safety
| |
| ! question if the repaired fuel assembly constitutes a previously approved design. This I
| |
| change will not result in modifications to fuel assemblies that would have a significant effect on safety because of the necessity to justify such changes using an NRC-approved methodology. This requirement will confirm (a) conformance to existing design limits, and (b) that safety analyses criteria are met before operation during the next fuel cycle. This change provides flexibility for improved fuel performance and is consistent with Supplement 1 to Generic Letter 90"02, and STS.
| |
| CTS Section 5.0
| |
| * 5.2.2 -
| |
| Li - - CTS 6.2.3f, which requires that an individual qualified in radiation protection proesdures
| |
| :- be on site when there is fuel in the reactor, it revised in ITS 5.2.2d to add a sentence j which permits this position to be vacant for up to'2 hours to provide for unexpected
| |
| [ tPlant meme).c:\...\ drafts.. 20 revised: 12 noon, Ausust 20, 1997 L
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| .,m,-1_ _a-.-M %ees segg- -m *->
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| - - yeE d'- -r=-- ,-- ' W '
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| absences. This is a less restrictive requirement that b realistic since unexpected absences can, and do, occur. 'Ihis change considers the unlikelihood of a radiological occurrence during the period of absence, and the added provision of ITS 6.2.2d requiring immed6ste action to fill the vacant position. This change is consistent with the STS.
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| L2 CTS 6.3.3h, whloh allows the operating shift complement to be one less than minimum requirement for up to 2 hours, is revised in ITS 5.2.2c to delete the word 'one.' This
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| . allowance for the absence of more than 'one' shift crew member is a less restrictive rwquirements that is realistic ,ince unexpected absences can, and do, occur. The impact of the change it th61 it raises the threshold for reporting a less than full-complement condition as a violation of the ITS requi sments. This change requires immediate action to fill the vacant position, and does not negate the requirement that such a condition shall not exceed 2 hours. Additionally, Footnote i to the Minimum Staffing Table in 10 CFR 50.54(m) permits temporary deviations from the required staffing numbers as established in the unit's Technical Spolfications. This change is consistent with the STS.
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| L3 CTS 6.3.2 requir, . t% " Manager. Operations" to hold, or have held, an SRO license, and, the "Managt . Whm operatiens" to hold an GRO license. ITS 5.2.2f requires either the
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| * Operations Manager" or (P.e " Superintendent in charge of the operations shift crews" hold an SRO license. The Superintendent in charge of the shift crews is an off shift manager reporting to the Operations Manager who can be delegated the Operations .
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| Manager duties. This is a less restrictive isquiremsnt.10 CFR S5 requires that an individual directing the licensed activities of licensed operators hold an SRO license. The on shift Superintendent Shift Operations (SSO), who is in oomtr.and of the control room, meets this requirement. This change does not impact safety and is consistent with the STS.
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| Section 5.3 L4 CTS 6.3.3 requires the manager of the radiation protection function meet or exceed the qualifications of Regulatory Guide 1.8, September 1975. ITS 5.3.1 requires that the manager of the radiation protection function meet or exceed the min! mum qualifications of ANSI /ANS 3.1 1981. In addition to other requirementt Pogulatory Guide 1.8 specifies that this individual have at least 5 years experience in >;. plied radiation protection, while ANSI /ANS 3.1 1981 requires only 4 years of such experience. This is a less restrictive requirement. An industry standard, ANSI /ANS 3.1 1961, reflects current qualification requirements for nuclear power plant personnel and is updated as necessary, based on operating experience and lessons loamed throughout the commercial nuclear industry.
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| Section 5.6 LE CTS 6.9.1.2.1 requires submitting the annual Occupational Radiation Exposure Report by March 1 of each year, ITS 5.6.1 requires submitting this report by April 30 of each year.
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| CTS 3.g.1.2.3 requires submitting the annual Radiological Environmental Operating Report by May 1 of each year, ITS 5.6.2 requires submitting this report by May 15 of each year. These are less restrictive requirements. The reports cover the previous calendar year, and there is no requirement for the NRC to approve either report. Completion and submittal of the reports are not necessary to ensure safe operation of the unit during the additional time intervals provided by these changes. These changes are consistent with the STS.
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| (Plant samel et\...\ereftee.a.3 . s4 revised: 12 noon, August 70, 1997
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| & 6 e M WM
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| .s
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| , _ ____-_.u-_--.u-..- -
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| pu is i nii L6 CTS 6.9.1.2.1 contains reporting requirements assoaisted with the reactor coolant exceeding specific activity limits. These reporting requirements are not retained in ITS
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| - 5.6. This is a relaxation of requirements, which is less restrictive. These reporting requirements are specified in 10 CFR 60,73, and failure to retum specific activity to within specification limits in the allotted time resuNs in a unN shutdown and those rolsted reporting requirements. This change is consistent with the STS.
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| L7 CTS 6.9.1.3, which requires submitting the Radioactive Effluent Release Report on a somlannual basis, is revised in ITS 5.6.3 to require submitting this report on en annual basis in accordance with 10 CFR 60.36a. This is a less restr6ctive requirement. This report covers the previous calendar year, and there is not a requirement for the NRC to approve the report. Completion and submittal of the report is not necessary to ensure soie operation of the unit during the additional 6 months. This change is consistent with the STS.
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| L8 CTS 6.9.1.4 requires submittal of the Monthly Operating Report to the NRC no later than the 10th of the month following the calendar month covered by the report. IT8 5.6.4 requires submitting this report by the 15th of each month. This is a less restrictive requirement. This report covers the previous month, and there is not a requirement for the NRC to approve the report. Completion and submittal of the report is not necessary to ensure safe operation of the unit during the addhional 6 days. This change is 4 consistent with the STS.
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| Lg CTS 4.2.1.3.2 requires including the complete results of the Steam Generator (8G) tube inservice inspection in the Operating Report for the period in which the inspection was completed. ITS 5.6.6b requires including the complete results of the steam generator tube inspection in the Monthly Operating Report for the period beginning after the -
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| inspection was completed. This is a 19ss restrictive requirement. The current requirement can impose an unnecessary burden if the inspections are completed late in the reporting period; there nuld be little time to include inspection results in the report and obtain appropriate review and approval by the required completion date. Submitting
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| - the inspection resuMs in the subsequent Monthly Operating Report is acceptable. This -
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| report is an after the fact report covering planned inspection activities, and there is no requirement for the NRC to approve these reports. Completion and submittal of the report is not necessary to ensure safe operation of the unit during the additional time interval provided by this change, i L10 CTS 6.9.3.1.a, which requires the submittal of a Containment Leak Rate Test Resort to the NRC upon completion of each containment leak rate test, is not retained in ITS 5.5.16 ' Th2 temovel of a reporting requirement is a relaxation of requirements and is less restrictive. The terr sval of this reporting requirement is not necessary to ensure safe operation of the unit. This change is consistent with 10 CFR 50, Appendix J Option 8.-
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| Conclusion For the reasons presented above, these less restrictive requirements are acceptable because they will not affect the safe operation of the plant. The T8 requirements that remain are consistent with current licensing practices, operating experience, and plant socident and transient analyses, and provide reasonable assurance that the public health and safety will be protected. Such information and requirements are not required to obviate the possibility of an -
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| abnormal situation or event giving rise to an immediate threat to the public health and safety.
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| (Plant name) c:\...\ draftee.et0
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| * 25 - revised: it noon, Anguet 20, 1997
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| ;E S W%-
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| Y Y '
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| _ S ibe *d*@
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| om- .g< cmu &eweet w-u +
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| 7
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| Further, where such information cnd requirements are contained in LCOs cnd associated requirements in the CTS, the staff has concluded that they do not fall within any of the four criteria in the Final Policy Statement (discussed in Part 11 of this safety evaluation). Accordingly, existing detailed information and specific requirements, such as generally described above, may be deleted from CTS.
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| Relocated Less Reetriotive Requirements When requirements have been shown to give little or no safety benefN, their removal from the T8 may be appropriate. In most cases, relaxations previously granted to individual plants on a plard specific basis were the result of (1) generic NRC actions, (2) new staff posit %ns that have evolved from technological advancements and operating experience, or (3) resolution of the Owners Groups comments on ST8. The NRC staff reviewed generic relaxations contalfwd in STS and found them acceptable because they are consistent with current licensing practices and the Commission's regulations. The HBR design was also reviewed to determ!ne if the specific design bests and licensing basis are consistent with the technical basis for the model requirements in STS, and thus provide a basis for IT8.
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| A significant number of changes to the CTS involved the removal of specific requirements and detailed information from individual specifications that can be adequately maintained in licensee-controlled documents, by applicable regulatory requirements. Such changes have been made to ,
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| retained specifications that contained specific requirements and detailed information of the following general types:
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| Typei Details of system design und system description including design limits Type 2 Descriptions of systems operation Type 3 Procedural details for T8 requirements and related reporting problems Type 4 Performance requirements for indication only instrumentation and alarms The following discussions address why each of the four types of information or specific requirements do not need to be included in ITS .
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| Details of System Desian and System Descriotion includinn Desian Limits (Type 1)
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| The design of the facility is required to be described in the UFSAR by 10 CFR 50.34. In addition, the quality assurance (QA) requirements of Appendix B to 10 CFR Part 50 require that plant design be documented in controlled procedures and drawings, and maintained in accordance with an NRC-approved QA plan (UFSAR Chapter 17). In 10 CFR 50.5g contrt ls are specifled for .
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| changing the facility as described in the UFSAR, and in 10 CFR 50.54(a) artteria are specified for changing the QA plan. - In IT8, the Bases also contain -
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| descriptions of system design. ITS 5.5.10 specifles sontrols for changing the Bases. Removing details of system design from the CTS is acceptable because this informa%n will be adequately controlled in the UFSAR, controlled design documents and drawings, or the TS Bases, as appropriate Cycle specific design limits are moved from the CTS to the Core Operating Limits Report (COLR) in (Plant bene) c:\...\draf tee.a20 - 26
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| * revised: 12 noon, August to, 1997 4 4 4mkgW q -w g p h+
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| .uw+-%%udg.Aw. .- r ->r--
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| accordance with Generic t.etter 8816. ITS Administrative Controls are revised to include the programmatic requirements for the COLR.
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| Descriptions of Systems Operation (Type 2)
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| The plans for the normal and emergency operation of the facility are required to be desertbed in the UFSAR b/10 CFR 50.34. ITS 5.4.1.s requires wrttien procedures to be established, implemented, and maintained for plant operating orocedures including procedures recommended in Regulatory Guide 1.33, Revision 2, Appendix A, February 1978. Controls spoolfied in 10 CFR 50.6g appy to changes in procedures as desertbed in the UFSAR. In ITS, the Bases also contain descriptions of system operation it is noceptable to remove details of system operation from the TS becaus,a this type of information will be adequately controlled in the UFSAR, plant operating procedures, and the TS Bases, as appropdate.
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| P ecedural Details for Meetina TS Renuirements & Related Reportina Pr%ms (Type 3)
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| Details for performing action and surveillaces requirements are more appropdately specified in the plant procedures requireo by ITS 5.4.1, the UFSAR, and ITS Bases. For example, control of the plant conditions appropriate to perform a surveillance test is an issue for procedures and scheduling and has previously been determined to be '
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| unnecessary as a TS restriction. As indicated in Generic Letter g104, allowing this control is consistent with the vast majority of other SRs that do not dictate plant conditions for surveillances. Prescriptive proceduralinformation in an action requirement is unlikely to contain all procedural considerations necessary for the plant operators to complete the actions required. Such information in the TS could distreet the plant operators from focusing on applying the appropdate plant operational or emergency procedure to accomplish the action requirement. Thus, removal of such information from the TC is potentially beneficial to safe operation of the plant during compliance with a TS action statement. In addition to tha potential safety benefit, the removal of these kinds of procedural details from the CTS is acceptable because they will be adequately controlled in the UFSAR, plant procedures, and the Bases, as appropriate. In addition, removal of.
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| reporting requirements from LCOs is appropdate because ITS 5.6,10 CFR 50.36 and 10 CFR 50.73 adequately cover the reports the staff deems necessary.
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| Performance Reauirements for In&m4n Oniv instrumentatim and Alarms (Type 4) indication-only instrumentation, test equipment, and alarms are usually not required to be operable to support TS operability of a system or component. Thus, with the exception of the Accident Monitoring instrumentation, STS generally contain no operability requirements for indication-onh equipment. The availability of such indication inst uments, monitoring instruments, and alarms, and necessary compensatory activities if they are not available, are more appropriatey specified in plant operational, maintenance, and annunciator response procedures required by ITS 5.4.1, Removal of requirements for indication-only instrumentation and alarms from the CTS is noceptable because they will be adequatey controlled in plant procedures.
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| Table RL lists specific CTS details that are relocated to licensee controlled documents in ITS.
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| Table RL is organized by ITS section discussion of change and provides a CTS reference, a summary description of the item, the name of the document that retains the CTS requirements, (Plant same) c \...Wref tee.sa0 - 27 - revi si ta n n, august ao, twr c-wr..p*<%,yr-w r + 4.f.-++.e-
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| _,,,,.,_ m__ mom.__ - - - -'- -- -
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| the method for controlling future changes to relocated requirements, a characterization of the change including a type of change reference.
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| Conclualon The staff has concluded that these types of detailed information and specific requirements are not nootstery to ensure the offectiveness of ITS to adequately protect the health and safety of the public. Accordingly, these requirements may be moved to one of the following licensee-controlled documents for which changes are adequately govemed by a regulatory or T8 requirement: (1) T8 Bases controlled by IT8 5.5.14 " Technical Spoolfications Bases Control >
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| Progrem;* (2) UF8AR (includes the Technical Requirements Manual (TRM) by referonos) controlled by 10 CFR 50.5g; (3) the Offsite Dose Calculation Manual (ODCM) controlled by 10 CFR 50.59; (4) the Inservios Testing Program controlled by 10 CFR 50.5g; and (5) the QA plans as approved by the NRC and contained in UFSAR Chapter 17. For each of these changes, Table i of the leter also lists the licensee-controlled documents and the T8 or regulatory .
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| requirements goveming changes to those documents.
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| Meloosted Speelfloations The Final Policy Statement states that CTS Section 3/4.0 specifications (LCOs and associated requirements) that do not satisfy or fall within any of the four specified ortleria may be relocated 4 from existing TS (en NRC-controlled document) to appropriate licensee-controlled documents.
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| These requirements include the LCOs, (system description, design limits, func'ional capabilities, and performance levels), Action Statements (ACTIONS), and associated SRs. In its application, the l6censee proposed relocating such specifications to the Updated Final Safety Analysis Report (UFSAR) (includes the Technical Requirements Manual (TRM) by reference), and the ODCM, as appropriate, Accordingly, these specifications may be relocated to one of the following licensee-controlled documents for which changes are adequately govemed by a regulatory or T8 requirement: UFSAR (includes the TRM by reference) controlled by 10 CFR 50.59; and the Offsite Dose Calculation Manual controlled by 10 CFR 50.5g. These provisions wilt continue to be implemented by appropriate plant procedures: 1.e., operating procedures, maintenance procedures, surveillance and testing procedures, and work control procedures.
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| The licensee, in electing to implement the specifications of STS, also proposed, in accordance with the criteria in the Final Policy Statement, to entirely remove the following spoolfications from the CTS and place them in licensee-controlled documents noted in Table R.
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| Table R lists specifications and specific CTS details that are relocated, based on the F6nal Policy Statement, to licensee controlled documents in IT8. Table R is organized by ITS section
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| . discussion of change and provides a CT8 refersnoe, a summary description of the item, the name of the document that retains the CT8 requirements, the method fer controlling future changes to relocated requirements and a charactertration of the discussion of change.
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| CT8 3.1.1.4 REACTOR COOLANT 8Y8 TEM VENT PATH .
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| When the RCS t;,mperature is greater that 200'F, the RCS vent paths, consisting of at least two valves in series powered from emergency buses, are required to be operable (except that valves RC 567,568,56g and 570 shall be closed with power removed from the valve actuators) from ~
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| the reactor vessel head and pressurtzer steam space, tPlent bene) et\...Waf tee.aN *25* rwised: it noon, August N,1991 w w% +m w anp w-.%e er -ewe-.-
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| hkkfh h The RCS vent paths are provided to exhaust non-condensible gases and/or steam from the RCS which could inhibit natural circulation coro cooling following any event involving a loss of offsite power and requiring long te rm cooling, such as a Loss of Cnolant Accident (LOCA). Their function, capabilities, and testing requireinents are consistent with the requirements of item II.B.1 of NUREG-0737,' Clarification of TMI Action Plan Requirements" However, the operation of reactor vessel head vents is not assumed in the safety analysis. This is because the operation of the vents is not part of the primary success path in the Updated Final Safety Analysis Report (UFSAR). The operation of these vents is an operator action after the event has occurred, and is only required when there is indication that natural circulation is not occurring.
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| QIS 3.1.2.2 STE AM GENERATOR PRESSURETTEMPERATURE (P/T) LIMITS The secondary side of the steam generator must not be pressurized above 200 psig if the temperature of the primary and vessells below 70'F.
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| The strism generator pressure and temperature (P/T) limits ensuro that pressure-induced stresses on the steam generatort do not exceed the maximum allowable fracture toughness limits. These P/T limits are based on maintaining steam generator RTc sufficient to prevent brittle fracture. As such, the TS places limits on variables consistent with structural analysis results. However, these limits are not initial condition assumptions of a UFSAR accident analysis. These limits represent operating restrictions and Criterion 2 includes operating restrictions. However, the Final Policy Statement criterion 2 discussion specified only those operating restrictions required to preclude unanalyzed accidents and transients be included in TS.
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| CTS 31.2 3 PRESSURIZER TEMPERATURE LIMITS The pressurizer shall neither exceed a maximum heatup rate of 100'F/hr nor a cool down rate of 200'F/hr. The spray shall not be used if the temperature difference between the pressurizer and the spray fluid is greater than 320'F.
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| Limits are placed on pressurtzer operation to prevent a non-ductile failure. These limitations are consistent with structural analysis results. However, these limits are not an initial condition assumption of a DBA or transient. These limits represent operating restrictions and Criterion 2 includes operating restrictions, The Final Policy Statement discussion for Criterion 2 specified only those operating restrictions required to preclude unanalyzed accidents and transients be included in TS.
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| * 3.1.6. (TABLE 41.2. Item 1) MAXIMUM REACTOR COOLANT OXYGEN AND CHLORIDE CONCENTRATION 3.1.6.1 The concentration of oxygen in the reactor coolant shall not exceed 0.1 ppm when the reactor coolant temperature exceeds 250'F.
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| 3.1.6.2 The concentration of chloride in the reactor coolant shall not exceed 0.15 ppm when the reactor coolant temperature exceeds 250'F.
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| 3.1.6.3 If the oxygen concentration or the chloride concentration of the reactor coolant exceed the limits given in 3.1.6.1 or 3.1.6.2, respectively, corrective action is to be taken immediately to retum the system to within normal operation specifications, if the IPtent hane) c:\...\draf tse.a20 *29* revised: 12 noon, August 20, iP9r 1
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| normal operational limits are not achieved within 24 hours, the reactor is to be placed in the cold shutdown condition utillaing normal operating Procedures.
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| Poor coolant water chemistry contributes to the long term degradation of system materials of construction and thus is not of immediate importance to the plant operator, Reactor coolant water chemistry is monMored for a variety of reasons. One reason is to reduce the possibility of failures in the RCs pressure boundary caused by corrosion. However, the chemistry monHoring activity is of a long term preventative purpose rather than mitigative.
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| 3li POST ACCIDENT CONTAINMENT VENTING SYSTEM The reactor shall not be made ortlical unless the valves of the post sooident containment venting system are operable.
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| The containment venting system ensures that hydrogen concentration within containment will be maintained below its flammability limit during post LOCA conditions. The containment venting e system is capable of controlling expected hydrogen generation associated with: (1) zirconium-water reaction, (2) radiolytic decomposition of water, and (3) corrosion of metals within containment. The builoup of hydrogen is expected to be quite small initially, such that the use of the Containment Venting System is not anticipated before 24 hours after the initiation of an accident and containment isolation valves will be maintained operable for closure and purging as -
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| provided for by ITS 3.6.3 and 3.3.6.
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| 3.5.1 Table 3.5 5. Operational Safety instrumentation 3.5.1.2 For on-line testing or in the event of a subsystem instrumentation channel failure, plant operation at rated power shall be permitted to continue in accordance with Tables 3.5 2 through 3.5 5.
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| 3.5,1.3 in the event the number of channels in a particular subsystem in servios falls below the limits given in the column entitled Minimum Operable Channelt, or Minimum -
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| Degree of Redur dancy cannot be achieved, operation shall be limited according to the requirements shown in Column 3 of tables 3.5 2 through 3.5-4 and column 2 of Table 3.5 5 Note: MBR cunent TS 60 not include a unique LCO that requires the operablNty of the instrumentation identmed Table 3.5 6.
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| Each individual sooident monitoring parameter has a specific purpose; however, the general purpose for accident monitoring instrumentation is to provide sufflaient information to confirm an ;
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| accident is proceeding as predicted (i.e., automatic safety systems are performing property, and deviations from expected accident course are minimal).
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| The application of deterministic selection ortteria to post socident monitoring instrumentation is documented in NRC letter dated May g,1g88 from T. E. Murtey (NRC) to R. A. Newton (Westinghouse Owners Group). The position was that the post accident toonitoring instrumentation table list should contain, on a plant specific basis, Regulatory Guide 1.g7 Type A instruments specified in the SER on Regulatory Guide 1.g7, and Regulatory Guide 1.g7 Category
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| - 1 instruments dated March 5, igg 7. Accordingty, this position has been applied to the HBR Regulatory Guide 1.g7 instruments. Those instruments meeting this ortteria have remained in
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| . 30
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| ~ hra+-4m.wy
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| .@_+; 4
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| T8. The instrun nts not meeting this orHerta may be relocated from the T8 to plant-controlled documents.
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| The following summartres the HBR position for those instruments currently in T8:
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| From NRC SE dated March 5,1g87 Subjoot: Regulatory Guide 1.g7 Emergency Response Capability.
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| Type A Variables
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| : 1. Pressurtser Level 2.
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| : 3. Containment Containment Vessel Vessel PressureLevel (Wde (Wide tenge Range) )
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| : 4. Containmord Vessel Hydrogen Concentration
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| : 6. Incore Thermocouple other Type, Category i Variables
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| : 1. Containment Area Radiation (High Range)
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| Additional Instrumentation, Assoolated With Risk Significant Scenarios or Mitigation Systems (These Indications are not specifically modeled in the HBR Probabilistic Safety Assessment -
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| (PSA); however they provide information to the operators regarding risk significant systems modeled in the PSA.)
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| : 1. Auxiliary Feedwater Flow (SD AFW Pump) 2, Auxiliary Feedwater Flow (MD AFW Pump)
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| : 3. - PORV Position indicator (Primary)
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| : 4. PORV Blocking Valve Position Indicator (Primary)
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| : 6. Safety Valve Position Indicator For other post accident monitoring instrumentation currently in T8, their loss is not considered risk significant since the variable they monitor does not qualify as a Type A or Category i variable (one that is important to safety, or needed by the operefor so that the operator can
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| . perform necessary manual actions).
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| Because the selection ortleria heve not been satisfied for other non-Regulatory Guide 1.g7 Type A or Category i variable instruments, their associated LCO and Surveillances may be relocated to other plant controlled documents outside the T8. The instruments to be relocated are as follows:
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| : 1. Reactor Coolant System Subcooling Monitor
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| : 2. Noble Gas Effluent Monitor. Main Steam Lines 3.-- Noble Gas Effluent Monitor. Main Vent Stack High Range
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| : 4. Noble Gas Effluent Monitor Main Vent Stack Mid Range
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| : 5. Noble Gas Effluent Monitor. Spent Fuel Pit Lower Level High Range
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| : 8. Reactor Vessel Level Instrumentation System (RVLIS)'
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| 3.5.2. (Table 316V RADIOACTIVE LIQUID EFFLUENT INSTRUMEbfTATION Ligd 8YSTEM
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| - 31
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| -. i
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| 3.5.2.1 The radioactive liquid effluent monitoring instrumentation channels shown in Table 3.5 6 shall be operable with their alarm / trip setpoints set to ensure that the limits of Specification 3.g.1.1 are not exceeded. The alarm / trip setpoints shall be determined in accordance with the ODCM.
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| 3.5.2.2 With a radioactive liquid monitoring instrumentation channel alarm / trip setpoint less conservative than required by the above specification, without delay suspend the release of radioactive liquid effluent monitored by the affected channel, change the setpoint so it is acceptably conservative, or declare the channel not operable.
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| 3.5.2.3 With less than the minimum number of radioactive liquid emuent monitoring instrumentation operable, take the action shown in Table 3.56, 3.5.2.4 The provisions of Specification 3.0 are not applicable.
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| The purpose of the Radioactive Liquid Effluent Instrumentation is to monitor routine radioactive releases. This instrumentation provides a surveillance of release points and initiates automatic alarm and trip functions to terminate the release prior to exceeding the limits of 10 CFR 20. The alarm and trip functions are set in accordance with the ODCM. Radioactive liquid emuent instrumentation and associated requiremwnts for effluent releases are used to assure conformance to the discharge limits of 10 CFR Part 20. The radioactive liquid effluent monitors are used routinely to provida a continuous check on the release of radioactive liquid effluent from the normal plant effluent flow paths. These requirements ensure the various liquid effluent monitors are maintained operable with setpoints established n accordance with the ODCM.
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| Plant DBA and transient analyses do not assume any action, either automatic or manual, resulting from radioactive liquid emuent monitors.
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| 3 5 3. (Table 3.5 71/ RADIOACTIVE GASEOUS EFFLUENT iltl INSTRUMENTATION SYSTEM 3.5.3.1 The radioactive gaseous effluent monitoring instrumentation channels shown in Table 3.5 7 shall be operable with their alarm / trip setpoints set to ensure that the limits of Specification 3.9.3.1 are not exooeded. The alarm / trip setpoints of these channels shall be determined in accordance with the ODCM.
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| 3.5.3.2 With a radioactive emuent monitoring instrumentation channel alarm / trip setpoint less conservative than required by the above specification, without delay suspend the release of radioactive gaseous effluents, change the setpoint so it is acceptably conservative, or declare the channel not operable.
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| 3.5.3.3 With less than the minimum number of radioactive liquid effluent monitoring instrumentation channels operable, take the action shown in Table 3.5 7.
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| 3.5.3.4 The provisions of Specification 3.0 are not applicable.
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| The purpose of the Radioactive Gaseous Effluent Instrumentation is to monitor routine and control, as applicable, radioactive releases. This instrumentation provides a surveillance of release points and initistes automatic alarm / trip functions to terminate the release prior to exceeding the limits of 10 CFR 20. The alarm / trip functions are set in accordance with the ODCM. Radioactive gases emuent monitoring instrumentation and associated requirements for
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| - 32 -
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| . = _= _.
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| -mm. .a 4 .w. +
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| gaseous effluent releases are used to assure conformance to the discharge limits of 10 CFR Part
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| : 20. The radioactive gaseous effluent monitors are used routinely to provide a continuous check on the release of radioactive gaseous effluents from the normal plant gaseous effluent flow paths. These requirements ensure the various effluent monitors are maintained operable with setpoints established in accordance with the ODCM. Plant DBA and transient analyses do not assume any action, either automatic or manual, resulting from radioactive gaseous effluent monitors.
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| ).1Lg SPENT FUEL STORAGE AREA RADIATION MONITORING DURING REFUELING Radiation levels in the contalnment and spent fuel storage areas shall be monitored continuously.
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| This relocated item addresses only the portion of the specification associated with spent fuel storage area radiation monitoring. The portion associated with containment radiation monitoring is retained in the HBR ITS Radiation monitoring in the spent fuel storage area during refueling operations provides waming of abnormal or unusually high radiation levels in the spent fuel storage area. However, these monitors do not automatically initiate the Spent Fuel Building Ventilation System. The Spent Fuel Building Ventilation System is required to be in operation with the exhaust discharging through high-efficiency participate operator air (HEPA) and charcoal .
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| filters during movement of irradiated fuel in the Spent Fuel Building.
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| 3.01g COMMUNICATIONS DURING REFUELING Direct communication between the control room and the refueling cavity manipulator crane shall be available whenever changes in core geometry are taking place.
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| Communication between the control room personnel and personnel performing core alterations is maintained to ensure that personnel can be promptly informed of significant changes in the plant status or core reactivity condition during refueling. The communications allow for coordination of activities that require interaction between the control room and containment personnel. However, the refueling system design accident or transient response does not take credit for communications in analyzing accident consequences.
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| }1} SPENT FUEL POOL WATER TEMPERATURE During the discharge of a full core into the spent fuel pit, the temperature of the spent fuel pool water shall be maintained at or below 150'F. The spent fuel pool water temperature shall be monitored once each shift when the temperature is at of below 125'F. If the temperature exceeds 125'F, it shall be monitored hourly, if the pool temperature reaches 150'F, fuel assemblies will be transferred back to the containment to reduce the pool temperature below 150'F.
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| The spent fuel cooling system is designed to maintain the pool temperature less than or equal to 16E'F. The restriction of 150'F provides a margin to prevent the fuel pool temperature from reaching the design value. Plant operating procedures provide adequate controls for this plant parameter. These limits are not related to protection of the public from the consequences of any DBA or transient.
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| | |
| LM BPENT FUEL CARK HANDLING CRANE 3.6.4 The following restnotions and requirements shall be applied to the Spent Fuel Cask Handling Crane:
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| : a. Use of the Spent Fuel Cask Handling Crane for lifting operations shall be permitted only when the ambient outside air temperature is greater than 33'F. If the temperature falls below this limit, lifting operations shall be suspended, with the load placed in a safe configuration, until the temperature increases above the limit,
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| : b. Limit swhches provided to limit travel of the bridge, trolley, and hoist shall be tested every 6 months when the orano is not in servloe, and shall be tested prior to each period of service and on a monthly basis while the orsne is in service.
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| : c. Crane repos shall be inspected in accordance with ANSI B30.2.0 1967 overy 6 months when the crane is not in service, and shall be inspected prior to each period of servios and on a monthly basis while the crane is in servios. A crane rope shall be replaced if any of the replacement ortteria given in ANSI B30.2.01967 are met.
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| The requirements of Specifloation 3.6.4 are based on limiting the potential for a cask drop accident. Provisions have been made to reduce the potential for a spent fuel cask drop as a -
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| credible accident. Redundancy has been incorporated in the design of the spent fuel cask lifting yoke and the 125 ton spent fuel cask handling orane to reduce the risk to public health and safety. A discussion of the safety features of the cask and handling components is contained in Letter NG 741246, dated October 17,1974, CP&L to U.S. Atomic Energy Commission, Spent Fuel Cask Handling. Other actions impiomonted associated with the control of heavy loads include training of personnel; use of appropriate load hadling procedures; identification and utilization of safe load paths; inspection, testing and maintenance of oranes; appropriate design of orano and lifting devices, etc. These actions and the redundancy associated with the design of the spent fuel cask lifting yoke and crane provide reasonable assurance regarding the limited potential for a cask drop sooident.
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| 3.9.1/4.10.1 COMPLIANCE WITH 10 CFR 20 RANOACTIVE MATERIALS IN LIQUlO EFFLUENTS 3.9.1.1 The concentration of radioactive material in liquid effluents released at any time from the site to unrestricted areas (see Figure 1.1 1) shall be limited to the concentrations .
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| specified in 10 CFR 20, Appendix B, Table 11, Column 2 for radionuclides other than dissolved or entrained noble gases. For dissolved or entrained noble gases, the concentration shall be li,nhed to 2 x 104 pCi/ml total activity.
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| 3.9.1.2 - With the concentration of radioactive materialin liquid effluents released from the site to unrestricted arers exceeding the above limits, without delay restore the concentration to within the above limits.- in addition, notification must be made to the
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| - Commission in socordance with Specifloation 6.6.
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| 3.9.1.3 in the event that the immediate action required by 3.9.1.2 above cannot be satisfed, the facility shall be placed in hot shutdown within 12 hours and in cold shutdown within the next 30 hours, and entry into the power opemting condition shall not be made unless Specification 3.9.1.1 is met.
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| . 34
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| ___ ~ - _ _ _ .
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| -s
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| . u-u.- ..;_.e .--- -
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| | |
| 3.9.1.4 The provisions of Specification 3.0 are not applicable, i.
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| The Liquid Emuent Conoontration Limit ensures that the concentration of radioactive materials -
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| released in liquid waste emuent to unrestricted areas will be less than the concentre. ion levels specified in 10 CFR 20, Appendix B.10 CFR Part 20, Bil(2) refers to liquid release to an unrestricted area of radioactive material in concentrations that exceed the specified limits. No screenin;l criteria apply because the process variable of the LCO (concentration of radioactive material in liquid emuents)is not an initial condition of a DBA or transient analysis. Emuent control is for protection against radiation hazards from licensed activities, not sooidents.
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| 312 COMPLIANCE WITH 10 CFR 50 RADIOACTIVE MATERIALS IN LIQUID EFFLUENTS 3.9.2.1 The dose commitment at all times to a member of the public frcm radioactive metodels in liquid effluents released to unrestricted areas (See Figure 1.1 1) shall be limited:
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| : a. During any calender quarter to s 1.5 mrom to the total body and to s 6 mrom to any organ, and --
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| : b. During any calendar year to s 3 mrom to the total body and to s 10 mrom to -
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| any organ.
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| 3.9.2.2 With the calculated dose commitment from the release of radioactive materials in l liquid effluents exceeding any of the limits prescribed by Specification 3.9.2.1 above, prepare and submit a report to the Commission in accordance with Specification 6.9.3.2.
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| This specification is provided to implement the requirements of Sections ll.A, Ill.A, and IV.A of Appendix 1,10 CFR Part 50. The LCO implements the guides set forth in Section ll.A of Appendix 1. The action statement provides the required operating flexibility and at the same time implements the guides set forth in Section IV.A of Appendix I of 10 CFR Part 50 to assure that the release of radioactive material in liquid effluents will be kept "as low as is reasonably achievable." Limitation of the quarterty and annual projected doses to MEMBERS OF THE PUBLIC as a result of oumulative liquid effluent discharge during normal operation over extended periods is intended to assure compliance with the dose objectives of 10 CFR Part 50, Appendix I, These limits are not related to protection of the public from the consequences of any DBA or transient.
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| 3.9 3/4.10.2 COMPLIANCE WITH 10 CFR 20 - RADIOACTIVE MATERIAL IN GASEOUS EFFLUENTS 3.9.3.1 The dose rate due to radioactive materials in gaseous emuents released from the site
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| . boundary (see Figure 1,1 1) shall be limited to the following:
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| : a. For radionoble gases: s 500 mromtyr to the total body, s 3000 mrom/yr to the skin, and
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| - 35
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| . = _ =
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| 2.__,____._--m___m.._.__ -
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| : b. For 1 131, l 133, and tritium, cnd for all radioactive materials in particulate fonn, inhalatio p thn a way only, with half lives greater than 6 days: s 1600 mromlyr to any organ.
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| 3.9.3.2 With tne dose rate (s) exceedir's the above limits, without delay decrease the release rate to within the above limits, in addition, a notification must be made to the Commission in accordance with Specification 6.6.
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| 3.9.3.3 in the event that the immediate action required by 3.9.3.2 above cannot be satisfied, the facility shall be placed in hot shutdown within 12 hours and in cold shutdown within the next 30 hours, and entry into the power operating condition shall not be made until Specification 3.9.3.1 is met.
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| This spoolfication is provided to ensure the dose rate at any time at the site boundary from gaseous emuents is within the annual dose limits of 10 CFR 20 for unrestricted arv as. The annual dose limits are the doses associated with the concentrations of 10 CFR 20 Appendix 5 Table ll, Column 1. These are limits which apply to normal operation of the plant. They are not assumed as an initial condition of any DBA on transient analysis and are not relied upon to limit the consequences of such events.
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| 3.9.4/4.10.3 COMPLIANCE WITH 10 CFR 50 RADIONOBLE GASES .
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| 3.9.4.1 The air dose commitment due to radionoble gases released in gaseous effluents to areas at and beyond the site boundary (See Figure 1.1 1) shall be limited, at all times, to the following:
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| : a. During any calendar quarter, to s 5 mrad for gamma radiation and s 10 mrod for beta radiation;
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| : b. During any calendar year, to s 10 mrad for gamma radiation and s 20 mrod for beta radiation.
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| 3.9.4.2 With the calculated air dose commitment from radioactive noble gases in gaseous effluents exceeding any of the limits prescribed by Specification 3.9.4.1 above, prepare and submit a report to the Commission in accordance with Specification 6.9.3.2.
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| The specification ensures that the concentration of radioactive materials released in gaseous emuent to unrestricted areas are kept as low as reasonably achievable. This specification is
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| - provided to implement the requirorients of Sections 11. 5, Ill.A and IV.A of Appendix 1,10 CFR Part 50. The LCO implemeriting the guides provides the a quired operating flexibility and at the same time implements the guides set forth in Section IV.A of Appendix l to assure that the releases of radioactive material in gaseous effluents will be kept 'as low as is reasonably achievable.* These limits are not related to protection of the public from the consequences of any DBA or tansient.
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| 3 9.5/4.10.4 COMPLIANCE WITH 10 CFR 50 R&EOIODINES. RADIOACTIVE MATERIALS -
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| IN PARTICULATE FORM AND RADIONUCLIDES OTHER THAN RADIONOBLE GASES
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| . 36 Q , ye wy e'
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| | |
| i i
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| l' E
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| ! l
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| ! 3.9.5.1 The dose to a ,nember of the public from h131, h133, tritium and radioactive materials j j in particulate form, with half lives greater than 8 days in gaseous effluents released to :
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| l unrestricted areas (See Figure 1.1 1), shall be limited, at all times, to the following:
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| l i
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| : s. During any calendar quarter, s 7.5 mrom to any organ, and I l
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| : b. During any oalendar year, s 15 mrom to any organ. !
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| (
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| - 3.9.5.2 With the calculated dose commitment from the release of h131, h133, tritium and ;
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| radioactive materials in particulate form, with half lives greater than 8 days, in gaseous I effluents exceeding any of the limits presortbed by Speelfloation 3.9.5.1 above. -
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| prepare and submit a repori to the Commission in accordance with Speelfloation ,
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| 6.9.3.2. ;
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| l This spoolfloation is provided to implement the requirements of Sections ll. C, Ill.A, and N.A of .
| |
| Appendix 1,10 CFR Part 60. The LCO implements the guides set forth in Section ll.C of !
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| Appendix 1. The action statement provides the required operating flexibility and at the same time :
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| Implements the guides set forth in Section IV.A of Appendix l to assure that the releases of >
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| radioactive materials as gaseous effluents will be kept *as low as reasonably achievable ' These limits are not related to protection of the public from the consequences of any DSA or transient.
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| ! 3.9.6/4.10.5 COMPLIANCE WITH 10 CFR 190 RADIOACTIVE EFFLUENT FROM URANIUM
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| [
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| FUEL CYCLE SOURCES 3.9.6.1 The dose commitment to any member of the public, due to releases of licensed ,
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| materials and radiation from urenium fuel cyoie sources shall be limited to s 25 mrom l- to the total body or any organ except the thyrold, which shall be limited to s 75 mrom '
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| I- over 12 consecutive months. This specification is applicable to H8R only for the area :
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| within a 5 mile radius around the H8R.
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| l 3.9.6.2 With the calculated domes from the release of the radioactive materials in liquid or i i gaseous effluents exceeding twice the limits of TS 3.9.2.1.a. 3.9.2.1.b,3.9.4.1.a.
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| 3.9.4.1.b,3.9.5.1.a, or 3.9.5.1.b, calculations should be made including direct radiation j contributions from the reactor unit and from outside storage tanks to determine :
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| whether the above limits of Speelfication 3.9.6.1 have been exceeded if such !s the
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| ! case, prepare and submit to the Commission within 30 days, pursuant to Specification 6.9.3.2.d, a Special Report that defines the corrective action to be taken to reduce subsequent releases to prevent recurrence of exceeding the above limits and includes the schedule for achieving conformance with the above limits, This Special Report, as ;
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| defined in 10 CFR Part 20.405c, shall include an analysis that estimates the radiation exposure (dose) to a member of the public from utanium fuel cycle sources, including i all effluent pathways and direct radiation, for the calendar year that includes the . ,
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| j - release (s) covered by this report. It shall also desortbo levels of radiation and ;
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| [ concentrations of radioactive material involved, and the cause of the exposure levels
| |
| ; or concentrations. If the estimated dose (s) exceeds the above limits, and if the i
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| : i. release condition resulting in violation of 40 CFR Part 190 has not already been i corrected, the Special Report shall include a request for a variance in accordance with i the provisions of 40 CFR Part 190. Submittal of the report is considered a timely j request, and a variance is granted until staff action on the same request is complete.
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| i V
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| , 37- >
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| j.
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| --,.,,,.-----_._.-.-m_. _ _ _ _ _ _ _ , , . _ . _ . - . _ . . ~ . . _ . _ . - . - _ . - . - ~ . , . _ . . . _ - - - . - . _ . .
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| | |
| 3.9.6.3 - The provisions of Specifloation 3.0 are not applicable.
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| This specification ensures the dose limitations of 10 CFR 40 Part 190 which were incorporated into 10 CFR 20 are not exceeded. This is intended to staurs that normal operation of the plant is in compliance with the provisions of 40 CFR Part 190. These lim is are not related to protection of the public from any DBA or transient.
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| 1111 POWER RAMP RATE LIMITS 3.10.7.1 Dudng the retum to power following a shutdown where fuel assemblies have been handled (e.g., refueling, inspection), the rate of reactor power incrosse shall be -
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| limited to 3 percent of rated power in en hour between 20 percent and 100 percent of rated power. This romp rate requirement applies during the initial startup and may apply during subsequent power increases, depending on the maximum power
| |
| %el achieved and length of operation at that power level. Spoolfloally, this
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| - autrement can be moved for reactor power levels below a power level P (20 percent < P s 100 percent), provided that the plant has operated at or above power level P for at least 72 oumulative hours in any 7 day operating period following the shutdown.
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| The rate of reactor power increases above the highest power level .
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| sustained for at least 72 oumulative hours during the proceding 30 oumulative days of reactor power operation shall be limited to 3 percent of rated power in an hour. Altomatively, reactor power increase can be accomplished by a single stop increase less than or equal to 10 percent of '
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| rated power followed by a maximum ramp rate of 3 percent of rated power in an hour beginning 3 hours after the step increase.
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| Calculations show that high cladding stresses can occur if the reactor power increase is rapid after startup from a refueling. The 72 hour period allows for thermal stress relaxation of the clad before the ramp rate requirement is removed, therefore reducing the potential harmful effects of possible pellet or fragment relocation. The 3 percent limit is imposed to minimize the effects of adverse cladding stresses resulting from reduced power operation for extended periods of time.
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| The time period of 30 days is based upon the sucesssful power ramp demonstrations performed on Zircoloy clad in operating reactors, resulting in no cladding failures. The limits associated with this specification are related to minimizing fuel clad damage normal operation. ITS LCO 3.4.16, itOS Specific Activity provides controls to limit allowable radionuclides in the RCS. The limits associated with CTS 3.10.7 are not directly related to a DBA or transient.
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| 1 11 MOVABLE IN-CORE INSTRUMENTATION 3.11.1 A minimum of 15 total accessible thimbles and at least 2 per quadrant sufficient movable in-core detectors shall be operable during recalibration of the excore symmetrical offset detection system.
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| .- 3.11.2 Power shall be limited to 90% of rated power if recalibration requirements for the -
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| exoore symmetrical offset detection system defined in Table 4.1 1 are not met.
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| The movable in core instrumentation is used to determine the gross power distribution in the core n indicated by the power balance between the top and bottom halves of the core. The full
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| . 33
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| 'o 9 % rM %_44-19hMM_' -.'M-'"4%--M&=4
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| | |
| system has more capability than is needed for the ostibration of the excore detectors. If the onlibration is not performed, the mandated power reduction assures safe operation since it will compensate for an error of 10% in the exoore detection system.
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| 3.16.1/4.20.1 LlQUID RADWABTE TREATMENT SYSTEM 3.16.1.1 The appropriate portions of the Liquid Radweste Treatment System shall be mainteined and used to reduce the concentrations of radioactive materials in liquid wastes prior to their discharge when the projected dose commitments, due to the release of radioactive liquid emuents to un.estricted areas (See Figure 1.1 1) when averaged over a calendar quarter, would exceed 0.2 mrom to the total body or 0.6 mrom to any organ.
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| 3.16.1.2 With radioactive liquid wastes being discharged without treatment while in excess of the limits of Specification 3.16.1.1 above, prepare and submit a report in the Commission in accordance with Specification 6.g.3.2.b.
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| The Liquid Redweste Treatment System ensures that effluents will be treated prior to release to the environment. Appropriate portions of the system are required to be operable to maintain doses as low as reasonably achievable. The requirement for a liquid weste ireatment system -
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| pertains to controlling the release of site liquid effluents during normal operational occurrences. -
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| No loss of primary coolant is involved; neither is an accident condition assumed or implied. The limits for release in 10 CFR Part 50, Appendix I for liquids are design objectives for operation, in addition, the liquid redweste subsystems are not credited in the safety sequence analysis and are not part of the primary coolant pressure boundary.
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| 3.16.3/4.20.3 GABEOUS RADWASTE AND VENTILATION EXHAUST TREATMENT SYSTEMS 3.16.3.1 The appropriate portions of the Gaseous Radweste Treatment System and the Ventilation Exhaust Treatment System shall be maintained and used to reduce the concentrations of radioactive materials in gaseous wastes prior to their discharge when the projected dose commitments due to the release of gaseous effluents to unrestricted areas (See Figure 1.1 1) when averaged over a calendar quarter would exceed:
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| : a. 0.6 mrom for gamma radiation and 1.3 mrom for beta radiation due to radionoble gases or,
| |
| : b. 1.0 mrom to any organ due to radiolodines, radioactive materials in particulate form, and radionuolides other than radionoble gases.
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| 3.16.3.2 With the Gaseous Radweste Treatment System and/or the Ventilation Exhaust Treatment System not operable and with radioactive gaseous wastes being discharged without treatment while in excess of the limits of Spoolfk:stion 3.16.3.1 above, prepare and submit a report to the Commission in socordance with Speelfication 6.g.3.2.b.
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| The specification ensures that appropriate portions of these systems are maintained and used when specified to ensure that the releases of radioactive material in gaseous effluent is kept as
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| - 3g.
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| Jyu 1= % - %Qs a
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| | |
| low as reasonabh achievable, in addition, the operebility of the gaseous redweste treatment system is not assumed in the anahsis or any DBA or transient.
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| 3.16 6/4.20.6 SOLIDIFICATION OF WET RAD lOACTIVE WASTE 3.16.6.1 The Solid Redweste System shall be used in accordanos with a Process Controi Program (PCP) to process wet radioactive weste to meet shipping and burtal ground requirements.
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| 3.16.6.2 With the provisions of the PCP not satisfied, suspend shipments of defootiveh processed or defectively packaged solid radioactivs waste from the sNo.
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| 3.16.6.3 If any test specimen, as required by the PCP, falls to verify solidification, the solidifloation of the batch under test shall be suspended until such time se additional test specimens can be obtained, altomative solidification parameters can be determined in accordance with the PCP, and a subsequent test vertfies sol 6dification, The PCP shall be modified as required in accordance with ! votion 6.15, and solidification of the batch may then be resumed using shomative solidification parameters as determined by the PCP.
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| This specification ensures that the packaging of wet radioactive waste meets the requirements of .
| |
| 10 CFR 20 and 10 CFR 71 prior to their shipment from the site for disposal. The solid radioactive waste system is a logloal continuation of the liquid redweste system, it operates on the same requirement for effluent control, identified as controlling the release and handling of radioactive solid wastes. The system serves to control operational release of solid waste, not socidental release.
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| 3.17.114.21.1 MONITORING PROGRAM 3.17.1.1 The Radiological Environmental Monitoring Program shall be conducted as specified in Table 3.171.
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| 3.17.1.2 With the radiologloal environmental monitoring program not being conducted as spoolfied in Table 3.171, prepare and submit to the Commission, in the Anntst Radiological Environmental Operating Report required by Specification 6,9.1.e, a description of the reasons for not conducting the progrom as required and the plans for preventing a recurrence.
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| 3.17.1.3 With the level of radioactivity as the result of plant effluents in an environmental sampling medium at a specified location exceeding the reporting levels of Table 3.17 2 when averaged over any calendar quarter, prepare and submit to the Commission within 30 days, pursuant to Specification 6.g.3.2, a Special Report that identifies the cause(s) for exceeding the limit (s) and defines the corrective actions to be taken to -
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| reduce radioactive effluents so that the potential annual dose to a member of the public is less than the calendar year limits of Speelfications 3.g.2.1, 3.9.4.1, and 3.g.5.1, When more than one of the radionuolides in Table 3.17 2 are detooted in the sampling medium, this report shall be submitted if:
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| concentration (1) . concentration (2) +...>10 reporting level (1) reporting level (2) 40-l
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| . ~ . ~ .
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| ~
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| T'~ --- - =
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| | |
| 9 When radionuclides other than those in Table 3.17 2 are detected and are the result of plant emuents, this report shall be submitted if the potential annual dose' to a member of the public is equal to or greater than the calendar year limits of Specifications 3.9.2.1,3.9.4.1, and 3.9.5.1. This report is not required if the measured level of radioactivity was not the result of pl ant effluents: however, ,
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| in such an event, the condition shall be reported and tiescribed in the Annual Radiological Environmental Operating Report.
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| 3.17.1.4 With milk or fresh leafy vegetable samples unavailable from one or more of the sample locations required by Table 3.171, identify locations for obt61ning replacement samples and add them to the radiological environmental monitoring program within 30 days. The specific locations from which samples were unavailable may then be deleted from the monitoring program. Pursuant to Specification 6.9.1.d, Identify the cause of the unavailability of samples and identify the new location (s) for obtaining replacement samples in the next Semlannual Radioactive Effluent Release Report and also include in the report a revised figure (s) and table for the ODCM reflecting the new location (s).
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| 3.17.1.5 The provisions of Specification 3.0 are not applicable.
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| 3.17.1.6 Deviations are permitted from the required sampling schedule if specimens are ,
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| unobtainable due to hazardous conditions, seasonal unavailability, or to malfunction of automatic sampling equipment. If the latter, every effort shall be made to complete corrective action prior to the end of the next sampling period.
| |
| The Environmental Monitoring Program provides data on radiation levels and radioactive materials in exposure pathways for those radionuclides that lead to the highest potemial radiation exposure to members of the public resulting from plant operation. Thir is accomplished by effluent measurement and modeling the environmental exposure pathways. This program is not tolated io protection of the pubtle from any DBA or transient.
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| 1 17.2/4.21.2 LAND USE CENSUS 3.17.2.1 A land use census shall be conducted and shallidentify the location of tha nearest milk animal, the nearest residence and the nearest garden of greater than 500 square feet producing fresh leafy vegetables in each of the 16 meteorological sectors within a 4 distance of 5 miles.
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| 3.17.2.2 With a land use census identifying a location (s) that yloids a calculated dose or dose commitment greater that the values currently being calculated in Specification 4.10.4,1, identify the new location (s) in the next Semlannual Radioactive Emuent report, pursuant to Specification 6.9.1.d.
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| 3.17.2.3 With the land use census identifying a location which yloids an annual calculated dose or Jose comm!! ment of a specific pathway which is 20% wier than that at a current sampling location:
| |
| ) (a) add the new location (s) to the radiological environmental monitoring program within 30 days and,
| |
| - 41
| |
| | |
| (b) If desired, delets the sampling location having the lowest omiculated
| |
| - dose or dose commitments v6a the same esposure pathway, excluding the con'rol station location, from the monhering program after Odober 31 of the year in which the land use consus was conducted, and >
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| (c) 6dentify the new location (s) in the next Semlannual Radioactive EfRuont Release Report, Spoolfication 6.g.l.d, Including a revised flgure(s) and table for the ODCM refloating the new location (s).
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| The Land Use Census ensures that changes in the use of land are identified and sooounted for in the Ruiological Environmental Monitoring Program given in the ODCM. This program is not related tc protection of the public from any DSA or transient.
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| n 3.17.1/4.21.3 INTERLABORATORY COMPARISON PROGRAM 3.17.3.1 Analys1s shall be performed on radioactive materials supplisd by EPA as a part of an interiehorntory Comparison Program of like media within the envitorimental program as per Table 3.171, 3.17.3.2 With analyses not being performed as required above, report the corrective actions taken to prevent a recurrence to the Commission in the Ar,nual Radiological Environmental Operating Report pursuant to Spoolfloation 6.g.1.e.
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| 3.17.3.3 The provisions of Specification 3.0 are not appliomble.
| |
| l 3.17.3.4 The intertaboratory comparison Program shall be described in the ODCM.
| |
| A summary of the results obtained as part of the above required intertaboratory Comparison Program shall be included in the Annual Radiologloal Environmental Operating Report pursuant to Specification 6.g.1.e.
| |
| The interlaboratory comparison program ensures that independent checks on the precision and accuracy of the measurements of radioactive materials in the environmental samples are performed as part of the QA program for the environmental tr:onitoring program. This program is not related to p'otection of the public from any (DSA) or transient.
| |
| US RADIOACTIVE SOURCE LEAKAGE TESTING The following surveillance requirements imply LCOs exist; however, unique LCOs are not spoolfloslly identified in Section 3 of the CTS. These surveillance requirements are comparable to surveillance requirements contained in 3/4.7.10, Sealed Source Contamination of NUREG-0452 Rev. 4, " Standard Technical Spoolfloations For Westinghouse Pressurimod Water 7
| |
| . Reactors."
| |
| h 4.16.1 The leakage test shall be cepable of detecting the pretence of .005 microcurie of radioactive material on the test sample, if the test reveals the presence of . 005 m'orocurie or more of removable contamination, it shall immediately be withdrawn -
| |
| from use, decontaminated, and repaired, or be disposed of in accordance with
| |
| , - ~.-
| |
| wg s s- u r k
| |
| | |
| Commission regulations. Scaled sources are exempt from such leak t:sts when the source contains 100 microcuries or less of beta and/or gamma emitting material or 10 microcuries or less of alpha emitting material.
| |
| 4.16.2 Tests for leakage and/or contamination shall be performed by the l6censee or by other persons specifically authortred by the Commission or an Agreement State as follows:
| |
| A. Fech sealed source, except startup sources subject to core flux, containing radioactive mettrW, c'her than Hydrogen 3, with a half life greater than 30 days and in any form einer than gas shall ba tested for leakage and/or contamination at in'ervais not to oceed 6 rnonths.
| |
| B. TM Mitocff 'ad ie si required does not apply to sealed sources that are stared r
| |
| and not b6Mg usu The sou oes excepted fmm this test
| |
| * hall be tested for leakage prior tc, say use of transfer to another user uniesi they have boon leak tested within 6 months p,W to the date of use or transfer, in the absence of a certificate from a transforor indicating that a test has been inade within six months prior to the transfer, sealed sources shall not be put into use until tested.
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| C. Startup sources shall be leak tested prior to and following any repair or maintenance art oefore being sub}ected to core flux.
| |
| This specification ensures that leakage from Byproduct, Source and Special Nuclear Material souxes will not exceed allowable intake values. The limitation on removable contamination for sources requiring leak testing, including alpha emitters, is based on 10 CFR Part 70.3g(a)(3) limits for plutonium. This program is not related to protection of the public from any DBA or transient.
| |
| APPENDlX B (TECHNICAL SPECIFICATION)
| |
| A. Radioactive Effluent Releases A statement of the quantities of radioactive effluents released from the plant with data summartzed on a morithly basis following the format of USNRC Regulatory Guide 1.21,
| |
| : 1. Gaseous Effluents (a) Gross Radioactivity Releases .
| |
| (1) Total gross radioactivity (in curies), primarily noble and activation gases,
| |
| -(2) Maximum gross radioactivity release rate during any 1 hour period.
| |
| (0) - Total gross radioactivity (in curies) by nuclide released based on repie ,entative isotopic analyses performed.
| |
| (4) Percent of technical specification limit.
| |
| < (b) lodine Releases (1) Total iodine radioactivity (in curies) by nuclide released based on representative isotopic analyses performed.
| |
| (2) Percent of technical specification limit for 1 131 released.
| |
| (c) Particuiste Releases
| |
| )
| |
| | |
| (1) Total gross radioactivity (py) released (in ourles) excluding background radioactivity.
| |
| (2) Gross alpha radioactivity released (in curies) excduding background radioactivity.
| |
| (3) Total gross radioactivity (in curies) of nuclides with half lives greater than eight days.
| |
| (4) Percent of technical spoolfication limM for particulate radioactivity with half-lives grooter than eight days.
| |
| - 2. Liquid Effluents (a) Total gross radioactivity (py) released (in curies) excluding tritium and average concentration released to the unrestricted eroa.
| |
| (b) The maximum concentration of gross radioactivity (py) released to the unrestricted area (averaged over the period of release).
| |
| (c) Total trttium and total alpha radioactivity (in curies) released and everage concentratiote. leased to the unr6stricted area.
| |
| (d) - Total dissolved gas radioactivity (in curies) and everage concentration released to the unrestricted area.
| |
| (e) Total volume (in liters) of liquid waste released.
| |
| (f) Total volume (in liters) of dilution water used prior to release from the restricted area. ,
| |
| (g) Total gross radioactivity (in curies) by nuotide released based on representative isotopic analyses performed.
| |
| (h) Percent of technical specification limit for total radioactivity.
| |
| B. Solid Weste
| |
| : 1. The total amount of solid waste shipped (in cubic feet).
| |
| : 2. The total estimated radioactivity (in curies) Involved.
| |
| : 3. Disposition including date and destination.
| |
| C. Environmental MonHoring
| |
| : 1. For each medium sampled during the toporting period, e.g., sir, boybottom, surface water, soll, fish, include:
| |
| (a) Number of sampling locations, (b) Total number of samples, (c) Number of locations at which levels am found to be significantly above local backgrounds, and (d) Highest, lowest, and the average concentrations or levels or radiation for the -
| |
| sampling point with the highest everage and description of the location of that point with respect to the site.
| |
| The Appendix B Technical Specifications contain environmental reporting requirements which were relocated to Appendix B as an interim action in 1976 pending completion of issuance of comprehensive Appendix B Environmental Technical Specificatiens. These requirements are comparable to portions of other Radiological Environmental Monitoring Technical Specifications which are also being separately relocated.
| |
| Conclusion 44
| |
| . .. . . . - . . _ . . _ . - - l m___.________..
| |
| | |
| These current specifications are not required to be in the TS under 10 CFR 50.36 cnd do not meet any of the four criteria in the Final Policy Statement. They are not needed to obviate the possibility that an ubnormal situation or event will give rise to an immediate threat to the public health and safety, in addition, the staff finds that sufficient regulatory controls exist under the regulations cited above to maintain the effect of the provisions in these specifications. The staff has concluded that appropriate controls have been established for all of the current specifications, information, and requirements that are being moved to licensee controlled documents. Until incorporated in the UFSAR and procedures, changes to these specifications, information, and requirements will be controlled in accordance with the applicable current procedures that control these documents. Following implementation, the NRC will audit the removed provisions to ensure that an appropriate level of control has been achieved. The staff has concluded that, in accordance with the Final Policy Statement, sufficient regulatory controls exist under the regulations, particularly in 10 CFR 50.5g Accordingly, these specifications, information, and requirements, as described in detail in this Safety Evaluation, may be relocated from CTS and placed in the UFSAR or other licensee controlled documents as specified lst6er e.mm y Control of Speelfloations, Requirements, and information Removed from the CTS The facility and procedures described in the UFSAR and TRM, incorporated into the UFSAR by reference, can only be revised in accordance with the provisions of 10 CFR 50.5g, which ensures '
| |
| - an auditable record and establishes appropriate control over requirements removed from CTS and over future changes to the requirements. Other licensee-controlled documents contain provisions for making changes consistent with other applicable regulatory requirements: for -
| |
| example, the Offsite Dose Calculation Manual (ODCM) can be changed in accordance with 10 CFR Part 20; the emergency plan implementing procedures (EPIPs) can be changed in accordance with 10 CFR 50.54(q); and the administrative instructior1 that implement the Quality Assurance Manual (QAM) can be changed in accordance with 10 CFR 50.54(a) and 10 CFR Part 50, Appendix B. Tamporary procedure changes are also controlled by 10 CFR 50.54(a). The documentation of these changes will be maintained by the licensee in accordance with the record retention requirements specified in the licensee's QA plan for HBR and such applicable regulations as 10 CFR 50.5g.
| |
| The licensee committed by a' letter (s) dated"*NO996, to confirm that CTS requirements designated for placement in the UFSAR or the TRM are appropriately reflected in these documents, or that they will be locluded in the next required update of these documents. The licensee has also committed to maintain an auditable record of, and an implementation schedule for, the procedure changes associated with the development of ITS . The licensee will also maintain the documentation of these changes in accordance with the record retention requirements in the QA plan and the LCS4TableMin the letter lists the~ changes involvird s" peelfle requirem6nts that have been hved from the CTS.- For each of these changes, "able ll also lists the licensee-contmaled documents and the TS or seguialory foquirements goverrline changes tothtmo documents 3 IV. STATE CONSULTATION in accordance with the Commission's regulations, the South Carolina State official was notified
| |
| , of the proposed issuance of the amendment. (The State offleist had no" comments.}[The stats offional provided commentsETIThis action WW to pwformed when #w staff issues Sw enal reJ 45
| |
| ______-._--__m.__._.m-__
| |
| | |
| V. ENVIRON ENTAL CONSIDERATION Pursuant to 10 CFR 61.21,51.32, and 51.35, an environmental assessment and finding of no significant impact was published in the Federal Renister on 6 FR ).
| |
| Accordingly, based upon the environmental assessment, the Commission has determined that issuance of this amendment will not have a significant effect on the quality of the human environment.
| |
| VI. CONCLUSION The improved HBR T8 provide clearer, more readily understandable requirements to ensure safe operation of the plant. The staff concludes that they satisfy the guidance in the Commission's colicy statement with regard to the content of technical specifications, and conform to the model provided in NUREG 1434 with appropriate modifications for plant specific considerations. The staff further concludes that the improved HBR Ts satisfy section 182a of the Atomic Energy Act, 10 CFR 50.36 and other applicable standards. On this basis, the staff concludes that the
| |
| - proposed improved HBR TS ate acceptable.
| |
| The staff has also reviewed the plant specific changes to CTS as described in this evaluation.
| |
| On the basis of the evaluations described herein for each of the changes, the staff concludes ,
| |
| that these changes are acceptable.
| |
| The Commission has concluded, based on the considerations discussed above, that: (1) there is reasonable assurance that the health and safety of the public will not be endangered by operation in the proposed manner; (2) such activities will be conducted in compliance with the Commission's regulations; and, (3) the iss.:ance of the amendments will not be inimical to the common defense and security or to the health and safety of the public.
| |
| Principal Contributors:
| |
| I Date:
| |
| 6
| |
| . 46-
| |
| & +
| |
| +* < euw % .yM
| |
| | |
| - APPENDlX IT O 3.3.1 INSTRUMENT BETPOINT METHODOLOGY USED TO ESTABLISH THE
| |
| " ALLOWABLE VALUE' column in ITS Tables 3.3.1 1. 3.3.21. and 3.3 S 1.
| |
| This
| |
| * ALLOWABLE VALU::" column is added to provide an allowance for calibration tolerences, instrumentation uncertainties, instrument drift, and severe environment errors for those Reactor Protection System (RPS), Engineered Safety Features Actuation System (E8FAS), and AFW aduation channels that must function in harsh environments. The 160ensee submitted Rev. 3 of Design Guido No. DG Vill.60,
| |
| * instrument Setpoints" which was used to calculate instrument setpoints and to determine the allowable values and trip setpoints indicated in the ITS.- These instrumorit setpoint calculations resulted in some allowable values and trip setpoints which were less restrictive and some which were more restrictive than the values provided in the current TS.
| |
| The methodology used by the licensee is based on the guidelines provided in AN81/18A 867.04-1988, "Setpoints for Nuclear Safety Related instrumentation," dated February 4,1988, ISA -
| |
| dRP67.04, Part 11, Draft Recommended Practice, " Methodology for the Determination of Setpoints for Nuclear Safety Related instrumentation," Draft 10, dated August 1992, and NRC
| |
| . Regulatory Guide,1.105, " instrument Set.noints for Safety Related Systems,' which endorses 18A =
| |
| 867.04 1988. Design Guido No. DG Vill.60 was used by the licensee to calculate instrument setpoints for all three of the licensee's nuclear plant sites. The NRC staff has previously ,
| |
| reviewed and approved this setpoint methodology for use at Brunswlok Steam Electric Plant,-
| |
| Units 1 and 2, during the review of the power uprate license amendments. Dudng a meeting on July 16 and 17,1997, the licensee also provided two sample calculations for Robinson which the staff determined were consistent with the setpoint methodology discussed in the DG Vill.50.
| |
| Based on its review, the staff finds the setpoint methodology to be acceptable.
| |
| The NRC staff confirmed that the proposed ITS trip setpoints and allowable values are intended to maintain scooptable margins between operating conditions and trip setpoints, and do not significantly increase the likelihood of a falso trip nor failure to trip upon demand Therefore, the existing licensing basis is not effected.
| |
| Based on the above, the staff concludes that the licensee's setpoint methodology and the resulting trip setpoints and allowable values incorporated in the ITS conversion package are
| |
| - consistent with the HBR licensing basis, and are, therefore, acceptable, 111 ECC8 OPERABILITY WITHIN LTOP OPERATION RANGE The LTOP system controls RCS pressure at low temperatures so that the integrity of the RC8 pressure boundary is not compromised by violating 10 CFR Part 50, Appendix G. H.B. HBR's LTOP system utilizes the pressurizer PORVs to accomplish this function. The system is manually enabled by the operators. When enabled, the system signals the PORVs to open if the RC8 pressure reaches the LTOP actuation pressure setpoint.
| |
| The design basis of HBR's LTOP system considers both mass-addition and heat addition transients during water solid RC8 conditions. The transients considered in the design of the system were inadvertent 81 and charging / letdown flow mismatch for mass addition; and inadvertent actuation of pressurizer heaters, loss of RHR ocoling, and RCP startup with temperature asymmetry within the RC8 or between the RCS and the steam generators for heat-addition.
| |
| - 47-
| |
| ...e.ss 4-m--w w . d y- w ~agc-= - "
| |
| | |
| The scope of the NRC staff review was primarty lim tod to the mass addition anaYsis and spoolficaly, the case for a temperature range of 175'F s T. s 350'F where one 81 pump and all three charging pumps are capable of injecting into the RCS The application of the new LTOP actuation pressure setpoint limit of s 400 psig to the entire LTOP operation range, including T. < 175(F, was also addressed.
| |
| The licensee's LTOP analysis of record (old analysis) was performed for three charging pumps arid no 81 pumps operable over the entire LTOP operating range (i.e., T. s 350'F).
| |
| Accorviingy, the current T8 do not allow any 81 pumps to be operable when T is less than or equal to 350'F. The old analysis methodology remains valid for operational configurations within the assumptions used in that methodology, including but not limited to the assumption that no 81 pumps be capable of injecting into the RCS. The licensee evaluated the effect of the poposed LTOP setpoint of 400 psig and instrument uncertainty value of 45.g psi on the old ana ysis, in socordance with that previously approved methodology, the new peak pressures achieved remain acceptable. Therefore, the licensee proposes to continue to rely on the old analysis methodology for LTOP operation below T. of 175'F.
| |
| To support the proposed changes whleh would allow an 81 pump to be operable in Mode 4 and 5 when T 2175'F, the licensee performed a new analysis for that configuration. The licensee's new analysis was performed using a modified ANF.RELAP model based on the plant's Cycle 17 non LOCA transient model. The new analysis models the injection from all three charging pumps <
| |
| and one 81 pump into a water solid RC8 with all three RCPs and both RHR pumps in operation.
| |
| Assumptions relabd to the number of injection pumps operating (i.e., three charging and one 81 in this case) affect the mass addition rate and hence the pressurization rate. Assumptions relating to the number of RCPs and RHR pumps in operation affect the dynamic head between the pressure transmitter used for actuating the PORV and the location of interest for the analysis (i.e., most limiting location from a material embrittlement perspective).
| |
| The analysis conservatively assumed that onY one PORV actuated and, further, did not credit dynamic compensation for this actuation. Dynamic compensation would have resulted in eariy actuation of the PORV leading to a lower analysis peak pressure. In addition, the analysis did not ersdit the operation of the RHR system relief valves or the coolant letdown system since these would have also assisted the PORV in limiting the peak pressure. A pressure of 445.g psig was used to actuate the LTOP system in the new analysis. Thus, the proposed T8 -
| |
| limit of 400 psig ensures that an instrument uncertainty value of 45.g psi, as calculated by the licensee's setpoint methodology procedure, is accounted for, in addition, the static pressure, dynamic pressure, and peak ansysis pressure were calculated at the bottom of fuel elevetion 5 the reactor vessel downcomer, which is below the lower circumferential beltline wold of the reactor vessel. The lower circumferential beltline wold of the reactor vessel ls the most limiting location from a material embrittlement peropoetive for HBR. The difference in position (with regard to elevation and flow) between the location at which the peak pressure was calculated and the lower circumferential beltline weld of the reactor vessel results in added conservatism when static and dynamic heads are considered.
| |
| To bound the operstng range affected by the licensee's request, itve separete cases were analyzed. The cases analyzed considered different combinations of maximum and minimum initial RCS pressures, temperatures, and iriection water temperatures. The following table summarizing these cases was submitted to the NRC by the licensee in a letter dated
| |
| . April 25, igg 7:
| |
| w.-.+-e--o
| |
| | |
| 4 LTOP system Analysis Resulta For The Temperature Ran6e of 178'F s T., s 350'F Case initial Conditions Total P/T Limit Margin Downoome (psig) to r Limit Pressure Temperature 81 Temp- Pressure (pslo)- (psi)
| |
| ('F) ('F) in e A 276 175 38 597.72 602.61 4.89 8 275 175 100 599.25 602.61 3.36 C 400 176 100 599.44 602.61 3.17 D 275 350 100 575.15 813.68 238.73 E 400 350 100 574.57 813.88 239.31 For the range of 160'F to 220'F, plant heatup procedures restrict plant heatup to a maximum rate of 30'F/ hour. For this range and heatup rate, an Appendix G P/T limit of 602.61 psig is applied by the licensee. This limit corresponds to the lower end of the range (i.e.,160'F) and is -
| |
| therefore conservative for that range. For the range of 200'F to 170'F, plant cooldown procedures restrict plant cooldown to a maximum rate of 10'F/ hour. For this range and cooldown rate, an Appendix 0 P/T limit of 612.54 psig is applied by the licensee. This limit corresponds to the lower end of the range (i.e.,170'F) and is therefore conserv' ave L that range. For LTOP Cases A, B and C above, the licensee applied the more conservative of the two limits (i.e., the heatup limit of 602.61 psig). This value is consistent with plant operational limitations, is more limiting than the steady state limit, and is therefore scooptable.
| |
| For the range of 220'F to 350'F, plant heatup procedures restrici plant heatup to a maximum rate of 60'F/ hour, For this range and heatup rate, an Appendix G P/T limit of 813.68 psig is applied by the licensee, This limit corresponds to the lower end of the range (i.e.,220'F) and is therefore conservative for that range. For the range of 350'F to 300'F, plant cooldown procedures restrict plant cooldown to a maximum rate of 60'F/ hour. For this range and cooldown rate, an Appendix G P/T limit of 1450 psig is applied by the licensee. This limit corresponds to the lower end of the range (i.e.,300'F) and is therefore conservative for that range. For LTOP Cases D and E above, the licensee applied the more conservative of the two limits (i.e., the heatup limn of 813.86 psig). This value is consistent with plant operational limitations, is more limiting than the steady sin's limit, and is therefore acceptable.
| |
| For all cases, the licensee has shown that the peak pressures achieved remained below their respective P/T limit. The resulting limiting case was Case C from the table, where the initial RCS inlet pressure and temperature were 400 psig and 175'F, respectively, and the 81 water temperature was 100'F. This case resulted in an acceptable peak pressure value of 599.44 psig (3.17 palless than the P/T limit of 602.61 psig at 175'F).
| |
| The NRC staff has reviewed the licensee's submittals relating to the mass addition --
| |
| - overpressurisstion analyses for the range of 175'F s T s 350'F.: Based on our myiew of this '
| |
| material and the above discussion, the NRC staff finds the licensee's analyses of mass addition overpressurization event soceptable. The staff further concurs with the licensee's conclusions
| |
| -4g.
| |
| _m.,__.m_m_m.m_ - - - - - - - -
| |
| | |
| that the peak pressures achieved in those analyses are below the P/T limits and, therefore, acceptable. The licensee's proposals to: a) amend the LTOP TS to allow one Si pump to be capable of injecting into the RCS when operating within the range of 175'F s T s 350'F, and b) change the PORV lift setpoint to s 400 psig; consistent with the licensee's analyses and, therefore, also acceptable.
| |
| In addition, for T < 175'F the old anatysis methodology and therefore limitations of that methodology (including but not limited to the assumption that no Si pumps be capable of injecting into the RCS) remain valid. Therefore, since the new lift setpoint limit of s 400 psig and new instrument uncertainty value of 45.g pal have been verified by the licensee 'o olve acceptable results, the staff finds the application of this limit to the entire LTOP range, including Tu < 175 psig, acceptable. Note that for T < 175 psig the licensee is appropriately maintaining the restriction that none of the SI pumps be capable of injecting into the RCS.
| |
| 4 50-
| |
| ~ ~ T 11... ..-______~~~~~'
| |
| | |
| TABLE M - MATRIK OF MOREE REST 7tCTWE CHANGES SECTKW 1.0 "Use and Appucation" page 1 of1
| |
| - et sunumery of Change ITS Session CTSSeselon Change 1.0 W and .W" 1.1 M1 DoEneon of G was expanded to indude wesghted average and ' 1.1 ' 2.1.4 composeon at isotopes enceueng ioene insseed of average of been and gamme energy ' & _-4--. of the W achvily 1.1 M2 ' DeEnton for Refuehng Opershons was expanded to indude the 1.1 1.2.6 time som ineel desenmarung of sm Em rencoor vessel hood doeure bon unes the W vessel heed is unboned and the time torn begmnsng reed % of the Srst reactor vessel hood c$osure bolt unas the seactor vessel head is fuBy tenmoned 1.1 M3 De9 neon for Channel Funchonal Test was expanded to indude 1.1 - 1.64 specdyng to point of test segnal snpecmon. The more prescnptwo ,
| |
| requwement provides for ingschon of the test sognet as csose to the ,
| |
| sensor as e. I r i
| |
| 1
| |
| | |
| TABLE M - MATRIX OF MORE RESTRICTIVE CHANGES SECTION 2.0 " Safety Limits (SL)" page 1 of 1 Discussion Summary of Change ITS Section CTS of Change Section 2.0 " Safety Limits (SL)"
| |
| 2.0 M1 The requirements for Reactor Core Safety 2.1.1 - 2.1 Limit were expanded to apply to MODE 2 and -
| |
| the reacter is subcritical instead of-when the reactor is critical.
| |
| 2.0 M2 Requirements when Safety Limits are violated were expanded to include restoration of 2.2 6.7 compliance with the Safety Limit within S. )
| |
| minutes and specifying a time of one hour to place the unit in MODE 3. The requirement to restore compliance with the Safety Limit and e the time to place the unit in shutdown were not'previously specified.
| |
| - - - . . . -. . . _- + -. - . - - - . . . . - . - .- . . - . . . . . . . . . .
| |
| .- ,. ,. --..._.....>...m__. ... . .;..
| |
| , , ,--i. . _ . - . . -s;.A- ..
| |
| ...ii.-a-. . . . . .- .,, , , . .. .. .. - .i,:
| |
| | |
| TABLE M - MATRIX OF MORE RESTRICTIVE CHANGES '
| |
| SECTION 3.0, " LIMITING CONDITION FOR OPERATION (ILO) APPLICABILITY" page 1 of 1 ITS Section CTS Section Discussion of " J cciof Change l_
| |
| Charg If a spoofication cannot be mst and there is no speafic action to be LCO 3.0.3 3.0 3.0 M1 taken, the time allowed to reach MODE 3 was hmsted to seven (7) hours, the time atowed to reach MODE 4 was limded *o 13 hours, and the time allowed to reach MODE 5 was hmded to 37 hours.
| |
| The previous times allowed were eight (8) hours to reach hot shutdown and 38 hours to reach cold shutdown A requirement was added that prohstuts entry into a MODE or other LCO 3.0.4 3.0 3.0 M2 speedied conddson when a specification is not met and the requwed SR 3.0.4 4.0 -
| |
| echon for that specdicahon does not pommt entry into the MODE. A requirement was added that prohsbited entry ir'n a MODE or -
| |
| specdied conddson unless the survesilence requrements for the specdicahons applicable to the MODE or specdied condsbon are
| |
| - met.
| |
| For frequencies of survedlance requwements speedied as "once," a SR 3.0.2 4.0 3.0 M3 requwement was added to clanfy that an extensson of 25% does not .
| |
| -8Y I
| |
| n U
| |
| | |
| MATRIX- OF MORE RESTRICTIVE CHANGES SECTION 3.1, " REACTIVITY CONTROL SYSTEMS," :page 1 of 5 F ur Discussion of Summary cf Change ITS Secdon CTS Secdon Change LCO 3.1.1, " SHUTDOWN MARGIN (SDM)"
| |
| 3.1 M1 A survedance requwements was added to venfy that Shutdown S' R 3.1.1.1 3.10.8 Marge is withm the Imts of the Core Operahng Limds Report (COLR).
| |
| LCO 3.1.2, " Core Reactnnty" 3.1 M2 A frequency requirement of prior to entenng MODE 1 after each SR 3.1.2.1 4.9 mfuehng and 31 Effectwo Full Power Days (EFPDs) thereaner was added to the survedance requwement to compare actual to :
| |
| predsted boron concentrabon values. Norm e r=han of prh values was requwed to be performed prior to exceedmg a fuel bumup of 60 EFPDs.
| |
| 3.1 M3 Requwements were added that the measured core reactwdy be LCO 3.1.2 4.9 withm i ak/k of predcted values in MODES 1 and 2, and if not met, '
| |
| to reevaluate design and safety analyses and determee that the )
| |
| core is acceptable for conhnued operabon within 72 hours, e=*M appropnate operahng restnchons withm 72 hours, or be in MODE 3 in six (6) hours LCO 3.1.3, " Moderator Temperature Coefficient (MTC)"
| |
| 3.1 M4 The requwements for the Moderator Temperature Coefficent (MTC) - LCO 3.1.3 Applicabdity 3.1.3.1 lower limit were extended to apply to all of MODE 2 and MODE 3, rather than only to reactor enhcal and power operatens as was prevaaa*8y r=M.
| |
| 3.1 M6 Survedance requwements were added that venfy that the MTC is SR 3.1.3.1 3.1.3 withm the uppsr limit once prior to entenng MODE 1 after each SR 3.1.3.2 refuelmg and venfy that MTC is within the lower limit once each cvcie
| |
| | |
| MATRIX OF MORE RESTRICTIVE CHANGES SECTION 3.1, " REACTIVITY CONTROL SYSTEMS,a page 2 of.5-Discussion of. Sumrnary of Change ITS Section CTS Section Change LCO 3.1.4, " Rod Group Abgnment Limds" 3.1 M7 The allowed time to restore a rod to wittun ahonment Imts was LCO 3.1.4 Requwed 3.10.1.5 reduced to one (1) hour from two (2) hours Achon B.1 3.1 M9 Requwements were added for the condshon when one rod is not LCO 3.1.4 3.10.1.5 withm abgnment Imts to venfy that SOM is wdhin the lets of the Requwed Achons COLR or indsate boration to restore SDM to within limit within one B.2.1.1,B.2.1.2,B.2.3, .l "
| |
| (1) hour, venly SDM is within limits of the COLR once per 12 hours, B.2.6,C.1,D.1.1, reevaluate the safety analyses and confirm results remain valid for D.1.2, and D.2 durabon of operabon within 5 days, or if the requwements for a rod not within abgnment Imts cannot be met, be in MODE 3 in six (6) hours. Requwements were added for the condshon when more than i one rod that is not within the abgnment limit to venfy SOM is within ;
| |
| l the hmds of the COLR within one (1) hour, initiate borabon to restore l
| |
| - i SDM to wdhe limit within one (1) hour, and be in MODE 3 in six (6) l 3.1 M8 The allowed time to measure the hot channel factors when a rod is L'O 3.1.4 3.10.1.5
| |
| * not wittun abgnment Imts was Imled to 72 hours. No time limit Requwed Actions B.2.4 pic.ixW existed. and B.2.5 ,
| |
| 1 3.1 M28 The requwements for rod group abgnment Imts were made LCO 3.1.4 3.10.1.5 !
| |
| specdically apphcable to MODES 1 and 2. No specdic reactor ApptcatMhty condshon +r21 to the rod group W limits previously.
| |
| 3.1 M24 A requwemord to measure the rod drop time from the point of decay SR 3.1.4.3 3.10.4.1 of the stahonary gnpper coil voltage rather than the beginning of rod mobon dunng the rod drop test. The effect of this change is to sliahtly decrease the allowed rod drop time.
| |
| - _ . . . . . . ~ . . . . . . . . . . . . . . .. .
| |
| | |
| MATRIX OF MORC RESTRICTIVE CHANGES SECTION 3.1, " REACTIVITY CONTROL SYSTEMS," page 3'of 5 -i Summary of Change ITS Section CTS Section Discussion of Cha.w A requrement was added to the rod drop time survedance test to SR 3.1.4.3 3.10.4.1 3.1 M29 measure Sie time from the fully withdrawn posihon. No posebon was ri o,%31.ny w .
| |
| Requrements were added for the condshon when control rod drop LCO 3.1.4 Requwed 3.10.4.1 3.1 M26 times are not withri limits to venfy SOM is withm the irmts provided Achons A.1.1, A.1.2, in the COLR withen one (1) hour, rutsate boraison to restore SOM to and A.2 withm the limit withen one (1) hour, and the time allowed to react MODE 3 was limited to six (6) hours rather than eight (8) hours as was preva>W r M.
| |
| A requwement that allowed conhnuous opershon with one control LCO 3.1.4 3.10.6.2 3.1 M10 rod inoperable was deleted Requwaments were added for the condshon when one or more LCO 3.1.4 3.10.6.3 3.1 M25 control rods cannci be moved by its mechanism to restore SDM or ,
| |
| i venfy SDM is within limits within one (1) hour. No cei>@N time previously existed. For the same condshon, the time allowed to 4 reach MODE 3 was hmded to six (6) hours rather than eight (8) hours as was piety >=ly r= dred.
| |
| A requrements was added to the rod exercise test to move control SR 3.1.4.2.- Table 4.1-3 3.1 M11 rods at least ten (10) steps dunng the test. No movement entenon item 2 was ,,.e.?>>=iv g+:n 1 ,
| |
| A survedance requwement was added to venfy individual rod SR 3.1.4.1 Table 4.1-3 gl 3.1 M12 90 &9s are withen =8awient limit ;;; y 12 hours LCO 3.1.5, " Shutdown Bank Inserhon Limes" 3.1 M13 Requwements for the shutdown bank inserhon limits were extended LCO . 5 Applicabety 3.1.5 to apply to MODES 1 and 2 with any control bank not fully inserted, rather than to reactor enhcal and power opershons.
| |
| . . - . . = . - . . . .
| |
| | |
| I MATRIX OF MORE RESTRICTIVE CHANGES SECTION 3.1, " REACTIVITY CONTROL SYSTEMS," page 4 of 5 l
| |
| l Discussion of Summary of Change ITS Section CTS Section Change 3.1 M14 Requirements were added for the condition where one or both LCO 3.1.5 Required 3.10.1 shutdown banks are not within limits to verify SDM is within the Actions A.1.1, A.1.2 limits in the COLR within one (1) hour or initiate boration to restore A.2, and B.1 SDM to within limits within one (1) hour, and to restore shutdown banks to within limits in two (2) hours. The time allowed to reach MODE 3 with one or more shutdown banks, not within limits was limited to six (6) hours rather than eight (8) hours as previously required.
| |
| 3.1 M15 A surveillance requirement to verify each shutdown bank is within SR 3.1.5.1 3.10.1 .
| |
| limits specified in the COLR every 12 hours was added. l LCO 3.1.6, " Control Bank Insertion Limits" 3.1 M16 Requirements to maintain control rods within insertion, sequence LCO 3.1.6 3.10.1.3 i and overlap limits specified in the COLR were added. l 3.1 M17 Requirements were added for the condition when control bank LCO 3.1.6 Required 3.10.1 insertion Fmits are not met to verify SDM is within the limits of the Actions A.1.1. A.1.2, ,
| |
| COLR within one (1) hour, initiate boration to restore SDM within B.1.1, 8.1.2, B.2.2, and one (1) hour, and restore control banks within limits within two (2) 8.2.3 hours. Similarty, requirements were added for the condition when control bank sequence or overiap limits are not met to verify SDM is within the limits of the COLR within one (1) hour, initiate boration to restore SDM within one (1) hour, and restore control banks within limits within two (2) hours.
| |
| 3.1 M18 Surveillance requirements were added to verify that estimated SR 3.1.6.1 3.10.1 critical control bank position is within limits specified in the COLR SR 3.1.6.2 within four (4) hours prior to achieving criticality, each control bank SR 3.1.6.3 insertion is within the limits specified in the COLR every 12 hours. .
| |
| and sequence and overlap limits specified in the COLR are met for control banks not fully inserted in the core every 12 hours.
| |
| | |
| MATRIX OF.MORE RESTRICTIVE CHANGES SECTION 3;1, " REACTIVITY CONTROL SYSTEMS," 'page 5 of 5-Summary of Change iTS Section CTS Secelen Discussion of C;.se ;
| |
| LCO 3.1.7," Rod Posshon fr%"
| |
| A requirement was added to perform the surveillance requwement to SR 3.1.7.1 Table 4.1-1 3.1 M27 compare analog rod posation w% and bank demand posshon items 9 and 10 wxhcation once withen four (4) hours following rod mobon in evemes of six (6) 'wx:hes when the rod posshon devishon monitor is ire.
| |
| LCO 3.1.8, W Test E=caaams-MODE 2" Requwements were added for the condsbon that the SDM is not LCO 3.1.8 Requwed 3.10.1 3.1 M20 withen hmits dunng physecs tests to inshale borabon to restore SOM Achons A.1, A.2, B.1, to within limit within 15 minutes, and to suspend physses tests within C.1, and D.1 one (1) hours. A requwement was added for the condshon that the thermal power is not less than or equal to 5% rated thermal power to .'..w =' ":"; open the reactor trip breakers. A requwement was added for the condition that the lowest Reactor Coolant System ,
| |
| ,a (RCS) loop average temperature is not withen limit to restore the RCS lowest average loop temperature to within limit within 15 -!
| |
| manutes or be in MODE 3 within 15 minutes l[
| |
| 3.1 M21 Survesilence requirements were added dunng physics tests to SR 3.1.8.1 3.10.1 {+
| |
| perform a channel cahbrabon on power range and intermodeste SR 3.1.8.2 lp range channels within 7 days prior to inshahon of physses tests, to - SR 3.1.8.3 ' l SR 3.1.8.4 0 venfy the RCS lowest loop average temperature is 2 530"F every b
| |
| 30 trunutes, venfy thermal power is s 530*F 5% rated thermal '
| |
| power every 30 minutes, and to venly that SDM is within the limits
| |
| * of the COLR ;;; i24 hours.
| |
| An allowance for the SDM not to meet the limits in the COLR dunng LCO 3.1.8 3.10.1.6 3.1 M23 physics tests while measunng control rod worth and SOM was deleted.
| |
| -'-.-.-...,r..... - - - - - - - -- --.- -. ..-- . . , . -. .. - . -.
| |
| - ... ii . . - - . . . - - .
| |
| .. ' - . . . - p . '---- --- - 1.:.u....J.. - . - -- - - -- ---- 1..--s.
| |
| - - s -.r .. - . . .. l-i..-1.--i.+--------"
| |
| _ _ . i.i~--
| |
| | |
| TABLE M - MATRIX OF MORE RESTRICTIVE CHANGES SECTION 3.2, " REACTIVITY CONTROL SYSTEMS" . page 1_of 5 t
| |
| Summary of Change ITSSecdon CTS Section Discussion of CW LCO 3.2.1,
| |
| * Heat Flux Hot Channel Factor" An exception from meehng heat flux hot channel factorlimds dunng LCO 3.2.1 3.10.3.1 3.2 M1 reiycks tests was deleted Requerements were added for the conditen when the heat flux hot - LCO 3.2.1 Requwed 3.10.2.1 3.2 M2 channel factor is not withm Imts to reduce the power range high Actions A.2.2, A.2.4, neutron flux setpoent by 21% for each 1% that the factor ewemada B.1 the limit withen 72 hours, and to venfy that heat flux hot channel factor is wdhm limits prior to increaseng thermal power above the requwed schon value. The allowed time to reach MODE 2 if the requwements for heat flux hot channel factor outsade of lmts cannot be n.at was limded to six (6) hours mstead of eight (8) hours as previaW r-M.
| |
| Requrements were added to venfy that the heat flux hot channel SR 3.2.1.1 3.10.2.1.1 3.2 M3 factor is withm limit once after each refueleg outage prior to exceeding 75% rated thermal power, and once within 12 hours aner achieving equilibnum conddions sner exceedmg by 2 10% rated
| |
| .j thermal power the thermal power at which the heat flux hot channel ;
| |
| was inst dehwaned An allowance to not reduce the overpower and overtemperature aT LCO 3.2.1 Requred 3.10.2.1.1 3.2 M28 - '
| |
| setpoints . . .if subsequent incore mappng . . . demonstrate that Acton A.2.3 the hot channel factors are not met is deleted A requwement was added to reduce the AFD target band Imts to LCO 3.2.1 Reqused 3.10.2.2.1 3.2 M4 restore the heat flux hot channel factor to withm Imts withm 15 Achon A.1 mmutes was added
| |
| ........,,...,,.,..s. _ . , , , , . . r . .- - -. .- . -- - - ... . - . . . . . . . , _ . . - _ . . . . . ... .m........ . . . . .
| |
| - _ - -...-_m.
| |
| --i
| |
| | |
| I TABLE M - MATRIX OF MORE RESTRICTIVE CHANGES SECTION 3.2, " REACTIVITY CONTROL SYSTEMS" page 2 of 5 Discussion of Summary of Change ITS Section CTS Secelen Chance 3.2 MS A time limit of 30 mmutes was " unposed upon the requwement to LCO 3.2.1 Requwod 3.10.2.2.1 reduce thermal power when the heat flux hot channel factor Achon A.2.1 exceeds the lumts speedied in the Core Operahng bmds Report (COLR).
| |
| 3.2 M6 An allowance to raise thermal power above the thermal power lumts LCO 3.2.1 3.10.2.2.1 speedied when the heat flux hot channel factor is not withm lismts by 3.10.2.2.2 utizahon of the Axial Power Destnbubon Mondonng System 4.11 (APDMS) was deleted. Requwements for the APDMS that, when in r=p=8==1, permd less restnctive thermal power limits were deleted.
| |
| LCO 3.2.2, " Nuclear Enthalpy Rise hot Channel Factor" 3.2 M7 An excephon from meetmg nuclear enthalpy rise hot channel factor LCO 3.2.2 3.10.2.1 limits dunna phy= tests was deleted 3.2 M8 A requwements was added to the survedance to venfy the nuclear SR 3.2.2.1 3.10.2.1.1 enthalpy rise hot channel factor is withen Iwats to perform the j
| |
| survedance once after each refuelmg outage prior to thermal power exceedmg 75% rated thermal power. No powerlimit previously l existed. p I
| |
| 3.2 M9 The allowed time for reducmg thermal power and the high neutron LCO 3.2.2 Requwod 3.10.2.1.1 flux setponts when the nuclear enthalpy rise hot channel factor Achon A.1.1, A.1.2.1, exceeds limits was lumted to four (4) hours and 72 hours, and A.1.2.2 !
| |
| reg +fedi. No time limits existed prev ==>=8y. i 3.2 M10 The requrements for reducang thermal power and the high neutron LCO 3.2.2 Requred 3.10.2.1.1 flux setpoents by a frachon relating to the degree to which the Achon A.1.2.1 and nuclear enthalpy rise hot channel factor exceeds limits was changed A.1.2.2 to a requwement to reduce power to less than 50% rated thermal power and to reduce the high neutron flux setpoents to s 55% rated thermal pc ;.~.
| |
| | |
| TABLE.M - MATRIX OF MORE RESTRICTIVE CHANGES
| |
| -SECTION 3.2, " REACTIVITY CONTROL SYSTEMS"- page 3 of 5 Di=an==3ag of Summary of Change ITS Sec5on CTS Secuen Change 3.2 M11 Requrements were added for when the nuclear enthalpy hot LCO 3.2.2 Requred 3.10.2.1.1 channel factor exceeds Imts to venfy the host flux hot channel Achon A.2 A.3, and factor is withm limits vnthm 24 hours, venfy the nuclear enthalpy rise P1 hot channel factor is withen limsts prior to thermal power exceedmg 50% rated thermal power and prior to thermal power +-c : Mii 75%
| |
| rated thermal power and 24 hours after thermal power reaches 2 95
| |
| % rated thermal power, and if the requrements to restore ruriaar enthalpy rise hot channel factor cannot be rnet, to be in MODE 2 in six (6) hours 3.2 M12 A requrement was added to a surveellence note to revenfy that the SR 3.2.2.1 3.10 ? ? ?
| |
| heat flux hot channel factor is vnthen iets in the event that the nuclear enthalpy rise hot channel factor shows and incrm trend LCO 3.2.3, " Axial Flux D6erence (AFD) (PDC-3 Axial offset Control Methodology) 3.2 M13 A time limit of once withe 31 Effective fun Power Days (EFPDs) SR 3.2.3.3 3.10.2.3 after each refuehng was imposed on the requirement to detemune the target flux deerence of each aa.,.haa excore channel .y f I An excephon from meeting axial flux deerence requrements dunng LCO 3.2.3 3.10.2.5 3.2 M14 .j phy- tests was deleted. i LCO 3.2.3 3.10.2.5 I 3.2 M15 A requirement mantam a.ial flux dmorence within W=Na anar=th lmts W in the COLR was added. "
| |
| The requrements for axial flux difference were extended to apply to LCO 3.2.3 Applicabdity 3.10.2 3.2 M16
| |
| * MODE 1 with thermal power greater than 15% rated thermal power, rather than to greater than 50% rated thermal power as previously rar= > ired.
| |
| i
| |
| | |
| . TABIE M - MATRIX OF MORE RESTRICTIVE CHANGES SECTION 3.2, " REACTIVITY CONTROL SYSTEMS" page 4 of 5 Discussion of Summary of Change ITS Section CTS Section i
| |
| Chane. -
| |
| 3.2 M17 The time allowed to reduce thermal power to less than 90% rated LCO 3.2.3 3.10.2.6 thermal power or 0.9 Allowable Power Level (APL) whichever is less Requwed Acton B.1 was Imled to 15 mmutes No time r-W previously emsted.
| |
| 3.2 M18 A requwemord to reduce thermal power to less than 15 % rated LCO 3.2.3 Requwod 3.10.2-thermal power vnthm nine (9) hours was added for the condemn Action D.1 when requwements to reduce thermal power or restore cumulatsve SR 3.2.3.1 penalty deviation time to less than one (1) are not met. A survedance requwement to venly that axial flux deerence is withm limits for each excore channel every seven (7) days was added 3.2 M19 The requwements for the accumulabon of penalty deviatson time LCO 3.2.3 3.10.2.8 were extended to apply to greater than or equal to 50% rated thermal power rather than greater than 50% rated thermal power as pi./ x=4r - % .
| |
| 3.2 M20 A requrement was added to log axial flux ddlerence once wdhm 15 SR 3.2.3.2 3.10.2.10 minutes and every 15 minutes thereaner when the axial flux difference alarms are out of service and the reactor is 2 90% rated thermal pcur or 0.9 APL ,
| |
| 3.2 M21 The time allowed after refuelmg to perform the survedance SR 3.2.3.3 3.10.2.1.1 requwament to determee the target flux dSerence of eads awwe channel was Imted to 31 EFPDs. No time limit emsted previously. 1 LCO 3.2.4, "Quadrard 'r 80wer Tsit Ratio" .
| |
| 3.2 M22 An excephon from meetmg Quadrant Power Tilt Ratso (QPTR) LCO 3.2.4 3.10.3.1 r-Ws dunng phym tests was deleted 3.2 M23 An allowed time to restore QPTR to withm hmets without talung any LCO 3.2.4 3.10.3.1 other schons was almnated l
| |
| | |
| TABLE M - MATRIX OF MORE RESTRICTIVE CHANGES
| |
| :SECTION 3.2, " REACTIVITY CONTROL SYSTEMS" ' page 5 of 5 Discussion of Summary of Change iTS Section CTS Section change l 3.2 M24 The time allowed to reduce thermal power when QPTR is in eacess LCO 3.2.4 Raquired 3.10.3.1 of limds was hmded to two (2) hours. No time limit pronously Achons A.1 -
| |
| existed 3.2 M25 The requwed power reduchon when OPTR exceeds limits was . LCO 3.2.4 Requwod 3.10.3 '
| |
| increased from two (2) percent for each percent that QPTR aveaade Achon a.1 1.02 to three (3) percent for each percent that QPTR exceeds 1.02.
| |
| 3.2 M26 Requwements were added where none existed previously as LCO 3.2.4 3.10.3 follows. The QPTR is requwed to be s 1.02. If QPTR is not wdhin Regeired Achons A.2, the limit, the OPTR is requwed to be determined once per 12 hours A.3, A.4, A.5, and A.6 and thermal power further reduced by 2 3% for each 1% that QPTR SR 3.2.4.1 is greater than 1.00. the hot channel factors are required to be SR 3.2.d.2 venfied wdhm limits wdhm 24 hours and once per seven (7) days thereafter, the safety analyses are requwed to be reevaluated for contmuous operation prior to increasing thermal pcwer abms the restncted levels, the excore detectors are requwed to be normahzed to show zero QPTR prior to increasing power above the restricted levels, and the hot channel factors are requwed to be venfied wdhm hmets wethen 24 hours of reachmg rated thermal power or withen 48 j .!
| |
| hours of increaseng thermal power above the restncted levels. , h Survenlance requirements were added to vvify that QPTR is wdhen ;
| |
| ' [
| |
| the limit by c=le.d=8aan every seven (7) days and once withm 12 i hours and every 12 hours thereafter when the QPTR alarm is out of service and to venly QPTR is within the limit by usmg the incore d detectors once within 12 hours and every 12 hours thereafter when one or more power range neutron flux channels are inoperable and thermal pc :.-is > 75% rated thermal power
| |
| | |
| TABLE M - NATRIX OF M)RE RESTRICTIVE CHANGES SECTION 3.2,.." REACTIVITY CONTROL SYSTEMS" page 6:of~5 rhen==lari of Summary of Change ITS Sec6on CTS Section l Cha.s Requwements were added for the surveSance requrement in the SR 3.2A.1 1.8 3.2 M27 conditson when one excore detectoris out of service, that the remawung three excore detectors may be used to calculate QPTR if reactor power is less than 75% rated thermal power. No power restriction pier;xW W.
| |
| C \
| |
| a I
| |
| i-
| |
| | |
| [
| |
| TABLE H - MATRIX OF MORE RESTRICTIVE CHANGES SECTION 3.3, "INSTIndENTATION" page 1-of 9 Discussion of Summary of Change ITS Section CTS Seceon Change l
| |
| LCO 3.3.1, "RPS instrumentahon" 3.3 M1 Trip setponts have been speedied in accordance with the loconsee LCO 3.3.1 2.3.1.2 setpoent methodology procedure. The setponts are more Table 3.3.1-1 2.3.1.3 restnchve. Funchons 2,3,4.a.
| |
| 4.b, 5, 6, 7, 8, 9,11, 12,13,14,'15 & 17 3.3 M2 The allowed time for an inoperable channel was restncied LCO 3.3.1 Requwod 3.5.1.5 kiw+' "f; where no allowed time was provsously =-+::'-
| |
| ; 1 Achons A and I Table 3.5-2 Acton 4 3.3 M3 When the requwed number of source range mondors cannot be met, LCO 3.3.1 Requwod Table 3.5-2 .
| |
| requwements were added to suspend actrvebes swolvmg posshve Achon L Acton5 l reachydy aMaan avs+'" r;. and to esose unborated water source asotabon valves in one (1) hour.
| |
| 3.3 M4 The allowed time before the unit must be shut down when an LCO 3.3.1 Requwod 3.0 inoperable channel is not placed in trip was rdM from eight (8) Action D & E - Table 3.52 - ,
| |
| Achon 6 I hours to six (6) hours Table 3.5-2 3.3 M6 A requwement was added to reach MODE 3 in 12 hours for an LCO 3.3.1 Requwed inoperable excore channel. Achon E Table Notahon l'l ACTION 2.b 1 l 3.3 M7 Requwements were added to requwe the unit be placed withm edher LCO 3.3.1 Requwod Table 3.52 the range of the source range mstrumentshon or the power range Achon F ACTION 3.b instrumentation withen two (2) hours
| |
| | |
| < TABLE M - MATRIX OF MORE RESTRICTIVE CHANGES-SECTION 3.3, "INSTRLM:NTATION" page 2 of 9 ru.e. =ian of Summary of Change ITS Section CTS Section Change 3.3 M8 The agowed time to restore an inoperable channel of automahc trip LCO 3.3.1 Requwod 3.10.5.2 -
| |
| logic to OPERABLE status was restncied to six (6) hours from 12 ' Achon Q and R i l
| |
| hours and if not restored, the agowed time to reach MODE 3 was restncied to six (6) hours from eight (6) hours. The agowed time to -
| |
| restore an inoperable reactor trip tweakers (RTBs) to OPERABLE status was reduced from 12 hours to one (1) hour and if not restored, the agowed time was reduced from eight (8) hours to six (6) hours to e the unit in MODE 3.
| |
| LCO 3.3.1 Required 3.10 i 3.3 M9 The requrements for the ranciar protecton system (RPS) were mcreased to include the RTBs, RTB UV & shunt trip mecharusms Achon C & V;Tatdo '
| |
| and Automahc Trip funchons in MODES 3,' 4 and 5 includeg 3.3.1-1 Funchons 18, ,
| |
| assocasted raaah when the RTBs are closed 19 & 20 t 3.3 M10 The allowed times when the RTB trip mecharusm is inoperable were LCO 3.3.1 Reqused 3.10.5.3 kmded to requwe the unit be placed in MODE 3 in 54 hours and RTB Achon U -
| |
| aa=ned withm 55 hours instead of hot shutdown withm 56 hours 3.3 M11 Requwements were added for two inoperable source range LCO 3.3.1 Requesd 3.10 y .l i
| |
| instruments; one inoperable P-6 or P-10 interlock; one inoperable P- Achons J. S T and V 4 7, P-8 and turtune empulse pressure intertock; and two inoperable l; RPS trams . >i LCO 3.3.1 3.10 3.3 M12 Allowable Values were estabhshed that are more restnctwo than the current technical specdications for RPS Instrumentshon, ESFAS Table 3.3.1-1 f,j instrumentaten and AFW System instrumentahon in accordance l I
| |
| with the company setpoent methodology.
| |
| 3.3 M13 Requrements added for reactor coolant pump breaker possbon Table 3.3-1 Funchons 3.10 (ssngle loop and two loops); safety mjechon input from ESFAS; and 10,16 & 17-RPS interlocks for intermediate range neutron flux, P-7. P-8, P-10 and turtune ima+ oressure.
| |
| i
| |
| | |
| l-TABLE M - MATRIX OF MORE RESTRICTIVE CHANGES ~
| |
| SECTION 3.3, "INSTIOGENTATION" page 3 of 9-Sununary of Change ITS Secuen CTS Secelen Discussion of Ch ,iie Survedlance requrements were added regianng compenson of SR 3.3.1.3 Tatdo 4.1-1 3.3 M14 incore measurement results to NIS axial flux ddforence and SR 3.3.1.6 cahbrabon of the encore t==4aarinseW. channels to agreewith SR 3.3.1.1 OTaT and OP4T funchons Survedlance requrements were added SR 3.3.1.8 requmng CHANNEL CHECKS, Channel Opershonal Tests (COTS) SR 3.3.1.11 and CHANNEL CALIBRATION for the Power Range Neutron Flum- SR 3.3.1.13 Low funchon. Survedlance requrements were added requmng a SR 3.3.1.14 TADOT for the Reactor Coolant Pump (RCP) tweaker pondson, Survemance requrements were added requang a COT for the RPS interlock funcison P-6, P-8 and P-10 funchons. Safety inpochon (SI) input from ESFAS funchons and the RPS P-7 interlocit .
| |
| Survedlance Frequency requrements were added for a COT of the SR 3.3.1.8 Tatdo 4.1-1 .f 3.3 M15 Nuclear intermediate Range and Nucioar source range items 2 and 3 I
| |
| - instrumentation to include withen four (4) hours aner seducmg power i below P-10, within four (4) hours aner reducang power below P 6 if l i
| |
| the COT has not been performed in the previous 92 days, and every 92 days thereaner.
| |
| A survedlance requrement was added to perform a CHANNEL SR 3.3.1.11 Tatdo 4.1-1 3.3 M16 CALIBRATION for the Nuclear intermediate Range and Nucioar atoms 2 and 3 Source RanDe instruments every 18 months j Survedlance requirements were added to perform a TADOT for the SR 3.3.1.15 Tatdo 4.1-1 3.3 M17 Turtune Trip Logic psior to startup if not performed in the previous SR 3.3.1.10 item 22 31 d=y and a CHANNEL CALIBRATION every 18 months Survedlance requrements were extended to apply to MODES 1,2, SR 3.3.1.5 Tatdo 4.1-1 3.3 M18 leem 27
| |
| ^
| |
| 3,4, and 5 when the RTBs are closed for performance of an ACTUATION LOGIC TEST every 31 days on a staggered test bases.
| |
| The previous requrement requred a similar survemance dunng hot shutdown and r,cr e ordv.
| |
| i I
| |
| | |
| TABLE M - MATRIX OF MORE RESTRICTIVE CHANGES SECTION 3.3, "INSTRUENTATION" page 4 of 9 Discussion of Summary of Change ITS Section CTS Secelen I Change 3.3 M19 Survemance requwements were extended to apply to MODES 1,2, SR 3.3.1.5 Table 4.1-1 3,4 and 5 when the RTBs are closed for performance of an SR 3.3.2.2 leem 27 -
| |
| ACTUATION LOGIC TEST every 31 asys on a staggered test bases.
| |
| The previous requwement requwed a similar survedance prior to startup when not tested in the preveous month 3.3 M20 Trip setpoent values were added for intermediate range neutron flux, LCO 3.3.1 2.3.1 source range neutron flux, steam generator water level and turtune Table 3.3.1-1 Funcemn trip (Iow oil pressure and turbine stop valve closure. 3,4,14 and 15.
| |
| 3.3 M21 Survesilence requwements were added to perform a CHANNEL SR 3.3.1.1 Table 4.1-1 CHECK for SteamIFeedwater Flow Mismatch and Low Steam items 3g and Generator Level 40 3.3 M49 The allowed Eme to place the plant in MODE 3 was ranwwi from LCO 3.3.1 Requimd Table 3.5-2 eight (8) hours to ;,6,i+' ^ ", open the RTBs.
| |
| Achon J.1 Requwe Achons 4,5,8 ; i o
| |
| 3.3 M50 The requwements for Reactor Coolant Flow - Low, single loop, trip LCO 3.3.1 Table 3.5-2 j d were extended to apply to the range of MODE 1 power operation Table 3.3.1-1 Funcien Funcemn 10A - J !
| |
| between the P-8 setpoent at appnnamately 40% rated thermal power g. Footnote (g) 1
| |
| * I u
| |
| (RTP) and 45% RTP. 0 LCO 3.3.2,"ESFAS Instrumentaten" 3.3 M1 Trip setposts have been speedied in accordance with the hoensee LCO 3.3.2 Table 3.5-1 setpost methodology procedure. The setpoents are more Table 3.3.2-1 Items 1,2,3, . [(
| |
| restnctive. Funchons 1.c,1.d.1.e, 4,and5 l 1.f.1.g, 2.c, 3.b.3, 4.c, h; 4.d. 4.e & 6
| |
| . . . . . ,-i
| |
| | |
| TABLE M - MATRIX OF MORE RESTRICTIVE CHANGES SECTION 3.3, " INSTREEENTATION" page 5 of.9 Descussion of Summary of Change ITS Section CTS Section Change 3.3 M2 The allowed time for an inoperable chesnel was resencted LCO 3.3.2 Requwod 3.5.1.5
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| ;..w =-' ^ Mi where no allowed time was previously specded. Acton A ~ Tame 3.5.2 Acton 4 4 3.3 M12 Allowable Values were estabbshed that are more restnchve than the LCO 3.3.2 fWA current technscal specsficahons for RPS Instrumenlabon, ESFAS Table 3.3.2-1
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| ^
| |
| Instrumentation and AFW f/,_ .. Instrumentabon in accordance with the company W metf=6*=y.
| |
| 3.3 M19 Surveilleccu requwements were extended to apply to MODES 1,2 SR 3.3.2.2 Table 4.1-1 Item 27 3, and in one case MODE 4 for performance of an ACTUATION LOGIC TEST every 31 days on a staggered test bases. The previous requwement required a samdar survedance prior to startup when not tested in the prmm=_a* month 3.3 M22 The allowed time to reach MODE 3 was kmded to six (6) hours LCO 3.3.2 Requesd Tabis 3.5-3 ,
| |
| rather than eight (8) hours as was previously required for an Achon 8 ACTION 11 g inoperable channel or train of the manual Si ar*==han funchon and j
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| .q the Manual Contanment Phase A isolabon funchon 3.3 M23 The allowed time to reach MODE 3 was Imted to six (6) hours LCO 3.3.2 Requwod Table 3.5.3 l 1
| |
| rather than eight (8) hours and to reach MODE 5 was Imted to 36 Actons C, D E, and G ACTION 12 -
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| hours rather than 38 hours for inoperable channels in which the time '
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| to :*= the channel in trip cannot be met.
| |
| 3.3 M24 The allowed time to reach MODE 3 was hmded to seven (7) hours LCO 3.3.2 Requwed Table 3.5-3 rather than eight (8) hours and to reach MODE 5 was limded to 37 Actoni flom 2.a hours rather than 38 hours for an inoperable manual ininston channel in which the time to restore the channel to operable status cannot be met. i e
| |
| m
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| -- - - - - w- ,-
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| +
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| ' TABLE ~M - MATRIX OF MORE RESTRICTIVE CHANGES
| |
| .SECTION 3.3, "INSTRLBENTATION" page 6 of 9 Summary of Change ITS Secelen CTS Seceden Discu ssion of -
| |
| Change 3.3 PA25 The agowed time to reach MODE 3 was kmded to six (6) hours LCO 3.3.2 Requred Table 3.5-4 rather than 74 hours plus the time requred to bring the plant to hot Achon F leem 2.d shutdown utdang normal operahng procedures when a channel of main steam line isolshon is not restomd to OPERABLE status in to requred time penod. The allowed time to reach MODE 4 was hmded to 60 hours rather than 72 hours when a cnannel of main steam line isolation is not restored to OPERABLE status in the -
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| r-M time period The agowed time between surveillances for the containment SR 3.3.2.6 Table 4.1-3 3.3 M26 isolabon trip functson were limited to 18 months rather than refuehng item 5 1 mterval The length of time t'etween refuehng meervals was not '
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| -+:P:
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| ; j in the prev == requrements 3.3 M27 Requrements were added for one inoperable channel of Pressunzer LG 'L3.2 Requred Tabis 3.5-4 Pressure-Low and T -Low meerlock to venty the interlocks are in Achon H SR 3.3.2.1 requred state. ,
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| Survedlance requirements were added to perform a CHANNEL SR 3.3.2.3 CHECK, MASTER RELAY TEST, SLAVE RELAY TEST and SR 3.3.2.4 i.
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| SR 3.3.2.5 i CHANNEL CALIBRATION on ESFAS instrumentation.
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| Regurements added for the setpoents for ESFAS interlocks which SR 3.3.2.7 .I-did not exist orevir=>=ly. Table 3.3.2-1 llem 6 }
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| '\
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| j '. 1 i 1
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| sr --
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| TABLE M - MATRIX OF MORE RESTRICTIVE CHANGES SECTION 3.3, " I N S T R L M i:N T A T I Ot3 " page'7 of 9-Discussion of ' Summary of Change ITS Secelen CTS Section Change LCO 3.3.3, "PAM instrumentaten*
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| 3.3 M28 The requrements for Post Acaderd Monitoring (PAM) LCO 3.3.3 3.5.1.2 instrumentaten were extended to apply to MODES 1,2,3, rather than dunna powerope 3.3 M31 The allowcJ time to restore inoperable contamment hydrogen LCO 3.3.3 Requirad Table 3.3-5 channel to GPERABLE status was luruled to 72 hours ralhar than - Achon E Note 6 14 days as was prevously r=%. .
| |
| 3.3 M32 Requwaments were added for adddenal PAM funchons of Steam LCO 3.3.3 N/A I generator Pressure and Level, Contamment Spray Adddeve Tank Table 3.3.3-1 Level, Contanment isolabon Vahm Poston, Power Range and Source Range Neutron Flux, RCS pressure, Hot and Cold leg temperature, Refueleg Water Storage tank and Condensate
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| .edarage tank level.
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| 3.3 M33 The allowed time to reach MODE 3 was reduced to six (6) hours LCO 3.3.3 Requred Table 3.5-5 q and MODE 4 to 12 hours from 12 hours and 42 hours, respectively, Action G Note 8 -
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| when a thermocouple is not restored to OPERABLE status in the ,
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| r-M time penod. .
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| 3.3 M47 The allowed outage time for one inoperable channel of contanment Table 3.3.3-1 Table 3.5-5 Mo esv mondors was limded to 30 days rather than allow item 11 Funcien 11 continuous W with one charrel otd of serwce LCO 3.3.4, " Remote Shutdown System" 3.3 M35 Requrements were added for the Rends Shutdown System. No LCO 3.3.4 Table 4.1-1
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| ~
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| r=Ws existed prev =W.
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| l
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| TABLE M - MATRIX OF MORE RESTRICTIVE CHANGES' SECTION 3.3, "INSTRLMENTATION" 'page 8 of 9 Discussion of Summary of Change ITS Section CTS Section Change LCO 3.3.5, *1.OP DG Start instrumentahon" 3.3 M36 The requwements for loss of voltage and degraded voltage LCO 3.3.5 Table 3.5 3 instrumentabon were extended to apply to MODES 1,2,3, and 4 Items 3A and rather than reactor entcal 38 3.3 M37 A requwement was added to restore all but one degraded voltage LCO 3.3.5 Required Table 3.5-3 channel to OPERABLE status withen one (1) hour if two or more Achon C channels are inopetrable.
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| LCO 3.3.6, "Contaenment Venblabon isolabon instrumentahon" 3.3 M38 A requrement was added to enter appleable requrements for an LCO 3.3.6 Requwod Table 3.5-4 anoperable contanment penetrabon when one or more funchons or Achon A.2 ACTION 15 radsabon monitoring channels of the contaenment venblation isolation instrumentahon system is inoperable.
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| 3.3 M40 The requrements for"h Venhiahon isolabon LCO 3.3.6 . 3.5.1.4 Instrumentation were extended to apply to core altershons or dunng Table 3.3.6 Table 3.5-4 movement of irradsated fuel assembises insede contenment. Funchons 3.a & 3.b leems c.i and ,
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| c.ii l i
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| 3.3 M41 Survedlance Requrements were added for the Automatic Actuation LCO 3.3.6 Table 3.5-4 {
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| Loge and Actuahon relays funchon including associated Table 3.3.6-1, ti survedlance requrements for a ACTUATION LOGIC TEST, Funchon 2 'jI MASTER RELAY TEST and SLAVE RELAY TEST. SR 3.3.6.2 lj SR 3.3.6.3 i:
| |
| SR 3.3.6.5 4 3.3 M42 Survedlance requwements were added to perform o CHANNEL ' SR 3.6.6.1 3.8 CHECK, COT, TADOT and CP.ANNEL CALIBRATION for the SR 3.6.6.4 contasnment ventdation isolahon system. SR 3.6.6.6 & Note SR 3.6.6.7 l
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| TABLE M - MATRIX OF MORE RESTRICTIVE CHANGES SECTION 3.3, " INST 1RBdENTATIOHa page 9 of 9 Discussion of Summary of Change ITS Section CTS Section Change l LCO 3.3.7, 'CREFS Actusbon Instrumentaten*
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| 3.3 M43 Requrements were added for the CREFS Actuahon instrumentahon LCO 3.3.7 3.5 System. No r=<=h existed previously.
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| LCO 3.3.8, 'AFW System instrumentahon" 3.3 M12 Allowable Values were estatished that are more rest.ictive than the LCO 3.3.8 Table 3.+2 current techracal specdcahons for RPS Instrumentahon. ESFAS Table 3.3.8-1 instrumentahon and AFW System Instrumentatson in accordance with the company setpoent methodology 3.3 M44 A compWson time to reach MODE 3 was imposed of six (6) hours LCO 3.3.8 Requwod Table 3.4-1 and a requrement was added to reach MODE 4 was imposed of 12 Action D & E Note 2 hours rather than no specded times for esther MODE, when AFW pump start instrumentahon is not restored to OPERABLE status withri required time of 48 hours.
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| 3.3 M48 The complebon time to reach MODE 3 was reduced to six (6) hours LCO 3.3.8 Requwod Table 3.4-1 from eight (8) hours and a requrement was added to reach MODE 4 Achon B Note 1
| |
| * in 12 hours when AFW undervoltage channel instrumenlahon is not restored to OPERABLE status withen requred time of 48 hours ij N
| |
| 3.3 M51 The allowance for one channel of steam generator water low low LCO 3.3.8 Table 3.4-1 il level to be inoperable conhnuously was eliminated and an allowed Table 3.3.8-1 Funchon Function 1 j
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| <=_4e time of for one inoperable channel was imposed. 1 .. N
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| -U
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| *\
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| l u
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| .pr TABLE,M.- MATRIX OF MORE RESTRICTIVE CHANGES-SECTION 3.4, " REACTOR COOLANT SYSTEM" page.1 of 11 Discussion of Summary of Change ITS Section CTS Section Change LCO 3.4.1, "RCS Pressure, Temperature, and Flow Departure from M 4a=8a Boiing (DNB) Limds" 3.4 M1 A new specsficahon for Reactor Coolant System (RCS) pressure, LCO 3.4.1 3.1 temperature and flow to be within iets was added. No r=_%rnents for these values previously emsted LCO 3.4.2, "RCS Mwnmum Temperature for Crihcaldy" 3.4 M2 The allowou mmunum temperature for enhcaldy was Imted to LCO 3.4.2 3.1.3.2 greater than or equal to 530*F. Lower temperature values for rmnemum temperature forecr W were pnmously allowed 3.4 M2 The time requwed to reach sutx:nhcal condshons when the reactor is LCO 3.4.2 3.1.3.2 cnbcal and the merumum temperature for enbcality was not met was Requred Action A.1 restncted to 30 mmutes from the pnmous requwement of 8 hours.
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| A survedance requwement to venly that the mrumum temperature for crw%is met was added 3.4 M4 Requwements were added for fadura lo meet RCS Pressure, RCS LCO 3.4.3 Requwed 3.1.2.1 Temperature, and RC6 Heatup and raaMawn rate Imts to restore Achons A.1, A.2, B.1, parameters to withm limits in 30 rmnutes, to detemune if the RCS is B.2, C.1, and C.2 ,
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| acceptable for conhnued operabon, to bring the unit to MODE 3 in 6 SR 3.4.3.1 W hours and MODE 5 with RCS pressure less than 400 psig in 36 Y hours if complebon bmes are not met, and to restore parameters to withm Imts ;Tw+'''?, and detemwie if the RCS is accepbble for :
| |
| conhnued operabon prior to entenng MODE 4 when the unit is not in r;j MODES 1,2,3, or 4. A survedlance requwement was added to '
| |
| verify that RCS pressure, RCS temperature, and RCS heatup and cooldown rates are withm limits wery 30 rmnutes dunng RCS heatup, RCS cooldown and RCS inservice and hydrostabc teshng LCO 3.4.4. "RCS LNS 1 and 2 1
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| - - - - . - - - ..- ~ - - - - - . - - . . - - . .
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| ..--=----g----- -
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| | |
| TABLE M - MATRIX OF MORE RESTRICTIVE CHANGES SECTION 3.4, " REACTOR COOLANT SYSTEM" page 2 of 11 Discussion of Summary of Change ITS Section CTS Section Change The requirements for maintaining three RCS loops operable and in LCO 3.4.4, App;nW-nty 3.1.1.1 3.4 M5 operation were extended to apply to MODES 1 and 2, rather than 3.3.1.1 only to power operation as previously existed.
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| 3A M6 The time requirement to bring the unit to MODE 3 was reduced to 6 LCO 3.4.4 Required 3.1.1.1 hours from 8 hours and a surveillance requirement to venfy inat Action A.1 each RCS loop is in operation every 12 hours was added SR 3.4.4.1 )
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| 3.4 M7 The requirements for maintaining two RCS loops operable and in LCO 3.4.4 Applicabelsty 3.1.1.1 operatson were extended to apply to MODE 3, rather than only to reactor pc' greater than or equal to 2% rated thermal power.
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| LCO 3.4.5, "RCS Loops-MODE 3" LCO 3.4.6, *RCS Loops-MODE 4" LCO 3.4.7, "RCS Loops-MODE 5, Loops Failed" LCO 3.4.8, "RCS Loops-MODE 5, Loops Not Filled" ;i LCO 3.4.5 3.1.1.1 !
| |
| 3.4 M8 Requirements are added to de-energize all control rod drive mechanisms immediately, suspend all operations involving a Required Action D.1, reduchon of RCS boron concentration immediately, and initiate D.2,D.3 ,
| |
| action to restore one RCS loop to operable status and operation SR 3.4.5.1 I
| |
| immediately. Surveillance requirements are added to verify required SR 3.4.5.2 RCS loops in operation, verify that steam generator secondary side SR 3.4.5.3 water levels are 2 16%, verify that the rod control system is not SR 3.4.5.4 capable of rod withdrawal when required, venfy that the reactor trip SR 3.4.5.5 breakers are open when required, and verify that the lift disconnect SR 3.4.5.6 switches are opec for all control rods not fully --;ttakown when SR 3.4.5.7 required, all every 12 imurs.
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| A NOTE is added to the specifications that restricts operation with LCO 3.4.5 NOTE 3.1.1.1 3.4 M38 less than two RCS Loops in operation under certain conddsons to a LCO 3.4.6 NOTE 1 maximum of 1 hour. LCO 3.4.7 NOTE 1
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| TABIE M - MATRIX OF MORE RESTRICTIVE CHANGES SECTION 3.4, " REACTOR COOIJGIT ~ SYSTEM" page 3 of'11-rm hwi or ! ummary S of Change ITS Secuen CTS Section Change 3.4 M36 The requirement for two steam generators to be operable in MODE LCO 3.4.5 3.1.1.2 3 is extended to apply to two ' RCS Loops whsch irweh two Ramr4ar Coolant Pumps (RCPs).
| |
| 3.4 M9 The requwements for one RCS loops or RHR trains were resencted LCO 3.4.6, Appiscatulity 3.1.1.1 L to apply only to MODE 4 ralher than for RCS temperature 2 200*F and reactor power less than 2% rated thermal power as was prewously r=%.
| |
| 3.4 M10" The requwements for operable RCS loops and/or RHR trains in LCO 3.4.6 3.1.1.1 MODE 4 were extended to apply to two loops or trains, rather than te one RCS loop or RHR train as was previously requwed.
| |
| 3.4 M11 ' A requwemert was aMed to irubate achon ww+' ^ r; to restore a LCO 3.4.6 Requwed 3.1.1.1 ' J'''
| |
| second RCS ioop or RHR train to operable status if one requwed Achons A.1, B.1, C.1
| |
| ~
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| and C.2 F ;)
| |
| loop or train is inoperable and one RCS loop is operable. A '
| |
| requirement was added to be in MODE 5 in 24 hours if one requwed SR 3.4.6.1, SR 3.4.6.2, lI loop or train is inoperable and one RHR train is operable. .The time SR 3.4.6.3 ;'
| |
| allowed to restore one inoperable loop or train to operable status was restricted to kiw+' ~ ",, rather than 14 days as was previously
| |
| - '[
| |
| allowed. The time allowed to suspend aN operations swolving i reduchon of boron concentrabon was restncted to 6,w+' ^ ",. _
| |
| Sunrealiance requerements were added to venly one RHR train or RCS loop is in opershon every 12 hours, venfy that the secondary side water levels are 2 16% for requwed RCS loops every 12 hours, and to venfy correct breaker alignment and indscated power are avadahia to the r=*ed pump that is not in operabon every 7 days.
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| ~ ,
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| . TABLE M - MATRIX OF MORE RESTRICTIVE CHANGES SECTION 3.4, " REACTOR COOLANT SYSTEM" page 4 of 11 Discussion of Summary of Change ITS Section CTS Section Change 3.4 M12 A Note was added which restncied removal of both RHR loops from LCO 3.4.7 NOTE 4 3.3.1.4 operation in MODE 4 durir J heatup to only when at least one RCS SR 3.4.7.1 loop is in operahon. Surveillance requwements were added to venfy SR 3.4.7.2 that one RHR train is in opershon every 12 hours, venfy that the SR 3.4.7.3 steam generator secondary side water level is 2 16% in the requred steam generator every 12 hours, and venfy that the correct breaker alegnment and indicated power are available to the required RHR l
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| pump that is not in aparaam every 7 dap.
| |
| 3.4 M14 Requrements were added to suspend all operahons involving a LCO 3.4.7 Requwed 3.3.1.4 rodr*an of RCS boron concentrabon MT- " ^ 'iand inshate Actions B.1 and B.2 action to res' ore one RHR train to operable status and in operabon LCO 3.4.8 Requred immediately when required RHR trains are inoperable c no RHR Achons B.1 and B.2 train is in c9er=*m.
| |
| 3A M15 A requerement for one RHR train to be in operabon was added for LCO 3.4.7 3.3.1.4 MODE 5 W%s. LCO 3.4.8 i 3.3.1.4 I 3.4 M39 The time requwement to restore an inoperable RHR train to operable LCO 3.4.7 status was restncied to br+'Mi, rather than 14 days _as was Requwed Achons A.1 previously allowed. A requrement was added to restore requred and A.2
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| *i steam generator secondary side water level to within irruts '
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| i unmediateN if the water level is not withen Imts 3.4 M16 Surveillance requrements were added to venfy that one RHR train SR 3.4.8.1 3.3.1.4 II is in operahon every 12 hours, and to venfy that the correct breaker SR 3.4.8.2 '
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| alegnment and w" xbcated power are avadable to the RHR pump that is not in apar=eh every 7 days.
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| LCO 3.4.9. Pressurizer"
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| TABLE M - MATRIX OF MORE RESTRICTIVE CHANGES SECTION 3.4, " REACTOR COOIANT EYSTEM" page 5 of 11 Descussion of Summary of Change ITS Section CTS Section Change 3.4 M17 The requwements for the pressunzerwere extended to apply to LCO 3.4.9 3.1.3.4 MODE 3, rather than only to reactor subentecahty less than 1% as Apphcabihty was prev =W r-M.
| |
| 3.4 M18 The time to reach MODE 3 was limited to 6 hours and the time to LCO 3.4.9 Requwod 3.1.1.3 reach MODE 4 was limited to 12 hours when the pressunzer - Actions D 1 and D.2 heaters and emergency power supplies cannot be restored within the allowed twnes. Completion times for these schons did not preveusly exist.
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| 3.4 M19 Requwaments were added :a be in MODE 3 with the reactor trip LCO 3.4.9 Requred 3.1.1.3 breakers cpen and to be in MODE 4 in 12 l ours when the - Achons A.1 and A.2 pressunzer water level is not withen limits. l LCO 3.4.10. "Pressunzer Safety Valves" 3.4 M20 Requwements were added to restore one inoperable pressunzer LCO 3.4.10 Requwed 3.1.1.3 ,
| |
| safety valve to operable status within 15 minutes or if not restored Actions A.1, B.1 and t B.2 f wdhin 15 minutes, or if two or more safety valves are inoperable, be in MODE 3 in 6 hours and MODE 4 in 12 hours.
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| I j!
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| LCO 3.4.11. " Pressurizer Power naarated relief Valves (PORVs)" ll I
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| il r
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| e b
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| . . . . . . . . _ _ ~ . . . . . . . . . . . . . , . . . . . . _ _ . , . . . . .
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| n TABLE M - MATRIX OF MORE RES2RICTIVE CHANGES SECTION 3.4, " REACTOR COOIANT SYST*W" page-6 of.11 Discussion of - Summary of Change ITS Section CTS Secelen Change 3.4 M21 The time to reach MODE 3 was hmsted to 6 hours and the time to LCO 3.4.11 Requwed (3.1.1.5 reach MODE 4 was lw uted to 12 hours when one or both . Achons D.1, D.2, E3 -
| |
| pressunzer PORVs are 6 and cannot be manually cycled, E.4, G.1, and G.4 and the associated block v.% cannot be closed and power removed withm one hour. The time to reach MODE 3 was bmded to 6 hours and the time to reach MODE 4 was hmded to 12 hours when both pressunzer block valves are inoperable and cannot be manually cycled, and the associated PORVs cannot be placed in manual control in one hour or one block valve cannot be sestored in two hours. Completion hmes for these achons were previously 12 hours to reach MODE 3 and 24 hours to reach MODE 4.
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| 3.4 M22 A note was deleted that allowed power opershon to conhnue with a LCO 3.4.11 3.1.1.5 pressunzer block valve closed to isolate mmor leakage from the
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| - associated PORV.
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| 3.4 M23 An excephon to entering requwed schons when perfemung LCO 3.4.11 3.1.1.5 survesilence teshng on the pressunzer PORVs and associated block valves was deleted.
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| "LCO 3.4.12, " Low Temperature C=yi.ssure Protechon (LTOP) System" 3.4 M35 The $cnnt for the LTOP Systam was lowered from 420 psig to LCO 3.4.12 3.1.2.1 400 a=ia with an allowable value of 418 psig.
| |
| 3.4 M24 The time allowed to depressunze the RCS and estabbsh a verd to LCO 3.4.12 Requwed 3.1.2.1 the contamment when two PORVs are inoperable, or when LTOP Achon G.1 cannot be restored to operable status as requered, was restncted to 3 8 hours rather than 12 hours as was e>=hr r=r== ired. l
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| . - - . . . - - ~ - -
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| TABIK M - MATRIX OF MORE RESTRICTIVE CHA00GES SECTION 3.4, " REACTOR COOtJMT SYSTEte" page 7 of 11 e
| |
| h of - Samusery of Change ITS Seselon CTS Section Change 3.4 M25 Requirements wem added to tie LTOP W as fogows N LCO 3.4.12 Reqused .3.1.2.1 weisch did not exist ~ .-Mf;. The accumulator isotahon valves are Actons A.1,8.1, C.1, required to be closed and doschwated in acconlance witi conditons D 1, and D.2 in a NOTE. N two or neore Safety inyechon (SI) pumps are capable SR 3.4.12.1 of ingschng into tie RCS wiWi RCS temperature 2 175'F and the SR 3.4.12.2 RCS is not vented, immodate schon must be tahan to render one St SR 3.4.12.3 pump incapabie of ingsceng into tie RCS. W one or nuovo Safety ingotton (SI) pumps are capetda of irisceng into tie RCS witi RCS temperature < 175'F and Sie RCS is not vented, immediate achon must be taken to render at Si pump incapeMe of injectng into tie RCS. N an accumulator isolahop vehe is not domed and doenergued when requesd sie valve is requeed to be domed and doenergend in one (1) hour. K 9 e accumulator cannot be isoisted l
| |
| wishen one hour, Wie RCS is recuired to be heated up to > 350*F wsIhan 12 hours or Die accuerAmtoris requesd to be depresounmod ,
| |
| weten 12 hours. Survoigana Requwements are added to venty a masamurn of one (1) Si pu: vip capelde ofinsectng into be RCS .
| |
| when requesd every 12 hours, venty no Si pumps capetdo of ingschng into Wie RCS when requesd every 12 hours, a# mnfy endi accumuistorisoisson vesse is domed and doenergend ews.y .
| |
| 1 12 hours 3.4 M37 The par ====ry RCS vent size to the contenment to assure LCO 3.4.12 3.1.2.1 overpmssure prreareast for Wie RCS was specdied to be at best 4.4 square inches No = par
| |
| * vent size value was W prowsously 3.4 M26 An agowance to not render a5 but one Se rpume 3rP of LCO 3.4.12 3.1.2.1 wigochng into tie RCS when the RCS is venumf to contamment atmosphere is m ;
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| LCO 3A.13. "RCS C_ M " Leekane"
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| | |
| T TABIZ M - MhTRIX OF MOERE RESTRICTIVE CHAB8GES SECTIcet 3.4, " REACTOR COOIJWIT STSTEN" page 8 of 11 Discussion of Suoemary of Cheese ITS Soeden CTS Sessee Change 3.4 M27 The time doured to reduce RCS leakage (otier mien pressure LCO 3.4.13 Requesd 3.1.5.1 boundary leakage) to restore leakage to wilhet times was reduced to Actons A.1, B.1, and 3.1.5.2 4 hours from 12 houras was p;i t agossed. The time asowed
| |
| - B.2 to reach MODE 3 if leakage requwements cannot be met was r=rhM to 6 hours %m 12 hours as was ;i=_t amouwd. The time agossed to reach MODE 5 itleakage r ' _._.:. cannot be met was reduced to as hours from 42 hours as was r.o x';
| |
| man ,e 3.4 M28 A requwement was added whch pomuts no RCS pressure boundary LCO 3.4.13 3.1.5 leakage.
| |
| LCO 3.4.14, E Pressure isolahan Vahes (PlVs)"
| |
| 3.4 M29 A requwement in a NOTEwas added that resencted separate LCO 3.4.14 3.1.5.4 condson entry to a PlV Sour path rather than to a PlV, A Reqused Acton B 1 requwement was added to isolate tie =m=r*=r8 penetrabon SR 3.4.14.2
| |
| ==h witt an inoperaMe RHR System intadock witun 4 hours. ,
| |
| A Survasance Requeament was added to venty tant sie RHR !
| |
| System meadock prevents tw valves from operung on a sunulated .
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| or actual pressum signal every 18 months. l 3.4 M30 T% survoitance requwement to venty PIV leakage was requwed to SR 3.4.14.1 Tatdo 4.1-3, be performed usihin 24 hours fogousing valve actuaten or Now Item 17 tirough #se valve. No pnyvious requrement ====amd for sie condson when a PfV ar*ame=d or flow occurred through a PfV.
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| LCO 3.4.15. "RCS Lcakaos Detecton instrumentahon" 4
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| | |
| i TABIJi: M - 39LTRIX OF DEMIE IEESTRICTIVE CHANGES SECTION 3.4, "ItEACTOR CODIJetT SYSTEM" page 9 of 11 Discueeien of Sunnnery of Change ITS Secelen CTS Seemen Channe 3.4 M31, and Requrementswc:s cddsd for RCS Leskage Detechon LCO 3.4.15. Requesd 5.4.3
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| ; 3.4 M32 inwA ch followsL Only a survedlance requemment for Achons A.1. A.2, B.1.1, RCS Leekage Detector;instrumentshon masted prewsously. A S.1.2,8.2.1,B.2.2, regurement wins added that one contenment sump level mondor, C.1, C.2, D.1, D.2, E.1, cpe contenment atmosphere r=6aar* wily morutor (gaseous or E.2, and F.1 5' pa;1m>date), and orc conhnnment fan cooler condensate now rate SR 3.4.15.1 SR 3.4.15.2
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| { morwtor be operable. Rwausements were added to perform an RCS wager inven6ery belance every 24 hours and restore an inoperable SR 3.4.15.4
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| -l cc h. sump level mondor to operable status wsIhst 30 days if SR 3.4.15.5 the suinp level rnt :stor is inoperable. Requwements were added to
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| +
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| analyze grab samples of sw contenment 2. :-f ie every 24 hours, perform an RCS water inventory betence every 24 hours, restore i.i, :.d contanment atmosphere r==8iaar*vsty mondor to operable status wdhm 30 days and wenty that the contanment fan consor conder-a= saw rate monnor is operande every 30 days if the 4
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| contenment atmosphere r==6aar6vdy mondoris inoperalde. If the ll amter.mont fan cooler condensate now rate monnor is inoperalde, l requwements were added to pericam a diennel check of the contanment _1..:+fs radoecamty monnor every 8 hours, and y perform an RCS waterinventory balance every 24 hours. If boet See 'l contenment atmosphem r-6aaraivdy monnor and the contenment ran coater condensate now rate mondor are inoperable, i=r , . i.;i, are added to
| |
| | |
| -- . r -- - --- -
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| .- . - , , . - - -..c_ :-
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| tam E M - MATRIX OF MORE RESTRICTIVE CHANGES SECTION 3.4, " REACTOR COOLANT SYSTEM" page 10 of 11 thes===3ast of ? - rf of Change ITS Section CTS Section Change 3.4 M31, and restore each mondor to operable status vnthin 30 days. If these 3.4 M32 schons cannot be met, requrements are added to be in MODE 3 in (Conhnued) 6 hours and MODE 5 in 36 hours. If a5 requred monitors are inoperable, a requrement is added to enter LCO 3.0.3. Surveillance Requrements were added to perform a channel check every 12 hours on the containment atmosphere radioactmty monitor, perform a channel opershonal test on the containment atmosphere r w& mondor f every 92 days, and perform a channel calibration on the contaenment atmosphere radioactivdy monitor and contanment fan cooler condensate flow rate monitor every 18 .
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| months.
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| LCO 3.4.15. *RCS Lan=aa Detechon Instrumentabon" 3.4 M34 The agowed frequency requirements for sampling RCS specdic LCO 3.4.16 Required 3.1.4 actihnty when the W acimty limds are exceeded was limited to Act,on A.1 once per 4 hours, rather than the frequency speedied in the survedance rar=W as was previoushr allowed.
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| LCO 3.4.17, " Chemical and Volume Control System FCVCS)"
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| 3.4 M40 A surveitance requrement was added to venfy seal injection flow 2 SR 3.4.17.1 3.2.5 6 gpm every 12 hours.
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| 1 3.4 M41 The time a50wed to reach MODE 3 when requwements for the LCO 3.4.17 Requred 3.2.3 CVCS cannot be met was limded to 6 hours. No time limit was Action C.1 p@'*4 W-3.4 M42 Survemance requirements were added to venfy seal injechon flow of SR 3.4.17.2 3.2.5 2 6 gpm from each makeup water pathway from the RWST every 18 SR 3.4.17.3-months and to venfy 300,000 gaBons of water in the RWST every 7 dre:.
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| 'I TABM M - MATRIX OF MORE RESTRICTIVE CHANGES SECTION 3.4, "REACToa rwwantT SYSTEM" page 11 of 11 Discussion of Susenery of Change iTS Sostion CTS Sossen Change 3.4 M43 A requwement that the RCP seel injeden be operable was added. LCO 3.4.17 3.2.2 3.4 h Requirements were added as follows. YWhen seat injechon to any LCO 3.4.17 Requwod 3.2.3 RCP is r.ot witun limes or both requwed diertyng pumps are Actons D.1, D.2, D.3, 3
| |
| y inoperable, anon is requwed snmeestely to restore seal insechon to E1, E2, E3, F.1, and the RCP and the unit is requesd to be pinced in MODE 3 in 6 hours F.2.
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| and to cool down and " , --his= the RCS to < 1400 peig witun 12 hours. When sool ingschon to any RCP is not wishri limds or at least one charipng Pump is inoperable, achon is requwed immodately to restore seal ingacion to Wie RCP and the unit is i4% to be placed in MODE 3 in 6 hours and in MODE 5 in 36 hours. K boti mahoup water patamoys from Wie RWST are inoperable, Wie unit is requesd to be pieced in MODE 3 'm 6 hours t
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| and in MODE 5 in 36 hours.
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| ~
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| 3.4 M45 The time aEomed to reach MODE 5 when sie requesments for LCO 3.4.17 Roquesd 3.2.5 CvCs cannot be met were resencted to 36 hours. No time limit Acton C.2 e m ste d g ;. i d ;.
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| 11 3.4 M46 An agonence to extend sie h hmes for CVCS for seended LCO 3.4.17 - 3.2.4 momeonence purposes beyond sie kmes required in Wie
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| ,,--A +-= was deseted.
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| I 11
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| TABLE M - MATRIX OF MORE RESTRICTIVE CHANGES SECTION 3.5, "E9ERGENCY CORE COOLING SYSTEMS (ECCS)" page 1 of 4 i Discussion'et Seesunary of Change ITS Secelen CTS Session chanee LCO 3.5.1,
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| * Accumulators
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| * 3.5 M1 Requwements for the accumulatorwere entended to apply to LCO 3.5.1 ApplicatuTay 3.3.1.1 MODES 2 and 3 with pressunzer pressure yester then 1000 psig ralhar then to seactor enhcal as par ==W r-N.
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| 3.5 M2 - A .4 . 4 to venly the posten of Wie accumulator isoinhon SR 3.5.1.1 3.3.1.1 valves once prior to removing power from fie valves was added to SR 3.5.1.5 tie survedence requwements for the accumulator anoinhon valves.
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| A frequency of 31 days was imposed on the survoitance requwament to:venly power is removed from sie accumuistor ierd=8=an valves.- No surveiEence fr=_ -icy pronously ===And 3.5 M3 A Rw.r.y of 12 hours was imposed on tie survedence SR 3.5.1.2 3.3.1.1 requwements to venty meumum accumulator pressure and - SR 3.5.13
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| ' contened barased wesor. No survemance sequency r_fr ?;
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| museemd 3.5 M4 The time to readi MODE 3 was limded to 6 hours in the requwod LCO 3.5.1 Requesd 3.3.1.2 schon for ese acasmuistors =W Compiehon hmes for Achon D.1 these achans did not pre -~m ==ee 3.5 MS The time to reach MODE 4 witi pressureer pressure s 1000 psig LCO 3.5.1 Reqused 3.3.1.2 <
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| was limded to 12 hours in Sie requwed acaen for sie accumulators Acton D.2 W C= ; ":1:+. kmes for these achons did not _i-==8y I
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| east.
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| 3.5 M7 A requwement was added to enter LCO 3.0.3 immodately in the LCO 3.5.1 Required 3.3.1.2 event that two or more accumulators are inoperable. The a5 owed Acton E.1 time to reach MODE 3 in this condemn was Sterefore limded to seven (7) hours ratier Stan eight (8) hours as was prowsously r-- 1.3.
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| TABIJi. M - MkTRIX OF N00tE RESTRICTIVE CHANGES 11: SECTION 3.5, "EDERGEDICY CORE COOLING SYSTEBE5 (ECCS)* page 2 of 4 Descussion of Sensunary of Change ITS SecWen CTS Seeden Change . , , , , , ,
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| 3.5 MS A requwement muss added to venfy accumuistor baron concentrahon SR 3.5.1.4 -
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| Table 4.1-2 untun irruts once uneun six (6) hours aner each solukon volume hasn6 increase of 2 70 geuons Sist is not Wie resut of addison from See RWST.
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| 3.5 M 9 Requirements vuore added to venfy that the accasmutator boron SR 3.5.1.4 Table 4.1-2 concentrabon is 21950 ppen and s 2400 ppm tuhon perfornung Wie - leem 6 survedence .T; . -4 for See accumulators. No nuusmum r=W ===na%.-M. -
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| 3.5 M10 The rnmemurn muoused time boeussen performance of the SR 3.5.1.4 Table 4.1-2 I
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| surveiumnce requwement for ventying accumuistor boron home6 concentration is infuri lirruts vues Isruled to 30 days ratier tien 45 days. ,'
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| ~
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| LCO 3.5.2 TCCS-Operahnif 3.5 M11 A surveigence . : , -- .:re vues added to venfy by visuoi W SR 3.5.2.6 3.3.1.1 the ECCS train contenment sump ssection inlet is not resencted by dotms and See suchon inlet trash racks and screens shour no evidence of senectural distress or atmormal conosson every 18 1 months.
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| 3.5 M12 A survedena pequwement was added to venfy Wiet manuel wahm SR 3.5.2.8 3.3.1.1~
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| RHR-764 is locked in the open poetson every 92 days.
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| 3.5 M22 The requeements for removing control posuer and air from cortem SR 3.5.2.1 3.3.1.1 ECCS vahms vuore endended to apply to MODES 1,2, and 3. rasier SR 3.52.7 then to plant condtons with RCS pressum poster than 1000 psig as was s-Jx4 r-M
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| TABIZ M - MATRIX OF MOIRE RESTRICTIVE CHANGES SECTICBE 3.5, "Ete34GENCY COgg entw.TNG sygTEDg5 (ECCS) " . page 3 of 4 Discussion of. Sumunary of Change ITS Secean CTS Seeuen Chante 3.5 M13 The agowed time behusen surveibance requsements were linuted to SR 3.5.2A 411.1 18 montes ratier tien resuoling interval. The longen of time SR 3.515 between resusEng interveis was not e in sie previous i+7 _. e.
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| 3.5 M14 A surveibanceiroquemment was citenged to requre that the SR 3.5.2.5 . 4.5.1.2 appropnete ECCS pump stests. rusher then the appropnete ECCS m tweakercloses 3.5 M15 A requemmentrwes added to venfy two addhonal high hood St SR 3.5.2.1 4.5.2.1 vehes in sie open poseon witi Wie control power to tie operators removed every 12 hours LCO 3.5.3, "ECCS-St=*er===i" 3.5 M11 A survoiRence i+-._.; to most survoiEence (6_.
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| O SR SR 3.5.3.1 3.3.1.1 3.5.2.3 and SR 3.5.2.6 was added to tie specdications for ECCS SR 3.5.2.6 dunne shutdown 3.5 M17 E; _;_e were added to restore requwed high hood angocton LCO 3.5.3 Reqused 3.3.1.2 subsystem to operable stelus wieun one (1) hour when sie requesd Actons B.1 and C.1 high heed ingocton subsystem is inoperstde, and if not restored wsIhan Wie timellimit, to be in MODE 5 in 24 hours. The eSoct of Weis citenge is to resenct Wie time to reach MODE 5 to five hours less tien 6; %agowed.
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| 3.5 M16 A Surveigence Requwement to venfy specdied valves are in tie SR 3.5.3.1 4.5.2.2 conect m was extended to M to MODE 4.
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| _ _ _ ..- _ _ _-- _ -- - __ _ _ __ _ ._ _ _ ._._. _ . _ _ _ _ _ _ . _ ... _ _ . _ _ _ _ s j ..
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| i a
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| ! TABIK M - MATRIX OF MuttE RESTRICTIVE CHANGES
| |
| ! SECTIOtt 3.5, "EDE3tGENCY CORE COOLING SYSTEMS (ECCS) " page 4 of 4 l
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| j-1
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| ! Discussion of Susumery of CIsenge IT S S emelen CTS Seedon l Change l LCO 3.5.4, " Refueling Water Storage Tank" 3.5 M18 Requirements were added to restore an inoperaMe RWST to LCO 3.5.4 Required 3.3.1.1 j operaMe status wisiin one (1) hour. The time to sencit MODE 3 was Actions B.1, C.1, and I
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| l luruled to 6 hours and Sie time to reacti MODE 5 was Istuted to 36 C.2 t hours when Wie RWST cannot be restored wieun one (1) hour. The
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| : aWect of Weis change is to resenct Wie time to most appliceMe f MODES to oneiless hour Sten previously a5amed.
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| } 3.5 M19 A'surveigence seguirement was added to vonfy Wie RWST borated SR 3.5.4.1 3.3.1.1 water temperature is 2 45'F and s 100*F every 24 hours.
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| 3.5 M20 The eBowed time behusen surveigence requsements for the RWST SR 3.5.4.3 Table 4.1-2 horon concentrabon was resencted to 7 days ratier Wien 10 days as - Item 3 was gi C requwed. ";i_C #sers was no requsement on
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| ;_ mammum baron concentrahon. _
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| i 3.5 M21. Requsements were added to sie surveinance requsement to wenty SR 3.5.4.3 Tame 4.1-2 ,
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| ; shot baron concentrabon is wdhm 21950 ppm and s 2400 ppen in item 3 :
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| i the RWST.
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| ;{
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| : 3.5 M23 An asomance to pernut any St Sow palh to be isolated for Pressure LCO 3.5.2 3.3.1.1.e ';
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| 3 isoiehon valve teshng was resencted to apply to only to -% of a cold les safety ingschon Sow palh as opposed to any one Si or RHR Appscemety o ~
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| : now palh asr.M h '
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| i a
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| (
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| 1 t
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| I r i
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| TABIE M - MATRIX OF DORE RESTRICTIVE CHANGES SECTION 3.6, "CONTAI1 TENT SYSTEDGB," page 1 of 6 Discussion of Seousnery of Change ITS Season CTS Soemen Channe LCO 3.6.1, T:entamment*
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| 3.6 M1 Requirements were added to restore an inoperaMe contamment to LCO 3.6.1 Required 3.6.1 operable status witun one (1) hour. The time to reach MODE 3 was Actons A.1, B.1, and luruled to 6 hours and the time to react MODE 5 was limited to 36 B.2 hours when the contamment cannot be restored wieun one (1) hour.
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| l I
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| The enact of this change is to resenct the time to meet apphceMe MODES to one less hour than pronously aBowed.
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| LCO 3.6.2 T:entamment Air Lock" 3.6 M2 M ~ _.ce were added for when one contamment airlock dooris LCO 3.62 Roquesd 3.6.1 moperable to wenty Wie operable dooris closed wieun one (1) hour, Actons A.1, A.2, and lock Wie operatde door closed wishm 24 hours and wenty Wie A.3 operatde dooris lar*ami closed once per 31 days.
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| 3.6 M3 Requwements were added for when one contamment air lock LCO 3.6.2 Required 3.6.1 mechanism is iinoperaide to venty an operalde dooris closed witun Actons B.1, 8.2, and one (1) hour, lock an operalde door dosed witun 24 hours and B.3 venfy an operalde door is locked dosed once por 31 days. A ,j surveigence requrement was added to venty stat only one '
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| contamment air lodt door can be opened at a time every 24 rnonets.
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| 3.6 MS R-- t. O were added forwhen the contamment airlock is LCO 3.6.2 Reqused 3.6.1 inoperatde for reasons atter than an inoperatde door or lock Actons C2 and C.3 machensam to venfy a dooris closed in Wie air lock wishet one (1) hour and restore the air lock to operatde status witun 24 hours.
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| 3.6 MS When requwements for Sie contamment air lock cannot be met, the LCO 3.6.2 Requwod 3.6.1 time to reach MODE 3 was limded to 6 hours and the time to reach Actons D.1 and D.2 MODE 5 was limited to 36 hours, raster stan 8 hours and 38 hours, i--+:^21. as was previousiv t-M
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| TABIZ M - MATRIX OF MOEtE RESTRICTIVE CHANGES SECTICBE 3.6, N SYSTEMS," page 2 of 6 Descassaien of Seouunary of Change ITS Secelen CTS Semelen Change LCO 3.6.3, T,ontasnmord l=<d=8==i Vatwes" 3.6 MS A requsement was added to place the plant in MODE 3 wsIhin 6 LCO 3.6.3 Respaired 3.6.3 hours in the event that the requrements for inoperaMe contamment Acton D.1 isolation valves cannot be mot. No previous is-; _. ;;4 to sentin MODE 3 ===aad.
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| 3.6 M7 Requrements for inoperaMe automate cantamment isotshon valves LCO 3.6.3 Requesd 3.6.3 were endended to apply to manual valves. Achons A.1, B.1, and C.1 3.6 MS An maa== rice to use a check valve to isolate an inoperable LCO 3.6.3 Roquesd 3.6.3 penetraten wies only one isolahan valve and a closed system was Achon C.1 dahead.
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| . > 3.6 M9 The aBoused outage time for tuso inoperable containment isolabon LCO 3.6.3 Requesd 3.6.3 vatwes was rMrad to one (1) hour from four (4) hours. Achon B.1 3.6 M10 R=~h were added to venty tie allected containment LCO 3.6.3 Required 3.6.3 penetrabon flour path is isolated every 31 days when an inoperable Achons A.2 and C.2 contamment penetration has been isolated in acconiana wilh
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| =w 3.6 M32 The time to reach MODE 3 was limited to 6 hours and the time to LCO 3.6.3 Consteson D 3.6.4 reach MODE 5 was limmed to 36 hours when both tie 6* and 42" purge valves are decxwered open, ratier Stan 8 hours and 38 hours, i =;+:^~;fa as was previously r-M.
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| 3.6 M11 The aBoused time betuveen surveigences for the contamment SR 3.6.3.5 Table 4.1-3 i=aisamn valves were kmsted to 18 montis rafter Wien refuehng item 5 interval The longIh of time between refuehng intervals was not ^
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| s+1 s in the orew=a=== r-h l
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| TABLE M - MATRIX OF MORE 1tESTRICTIVE CHANGES SECTION 3.6, N SYSTEBS," page 3 of 6 Discussion of Seasunary of Change ITS Session CTSSeseien Change 3.6 M12 Requwements were added to the surveibance of the contamment SR 3.6.3.5 Tame 4.1-3 '
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| isoleton valves to venfy each automahc contamment isoimeen valve item 5 that is not lodood, sealed or otenusse secured in poseon =r**
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| to the % poseon on an actual or senad=nad actuohon senal.
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| 3.6 M13 Survedance requwements were added to venfy the poseon of SR 3.6.32 4.4.2 contamment isolaimn valves Inc=sarf n=d=da contamment every 31 SR 3.6.3.6 l days, wenty Wie posson of contamment inannawwi valves inside SR 3.6.3.6 l.
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| containment prior to entenng MODE 4 from MODE 5 if not l performed wahin the pronous 92 days, and venty each 42 inch inboant contamment purge valve is bloded to resenct Wie vatwo from opensne > 70*.
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| LCO 3.6.4,"Contamment Pressure
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| * 3.6 M14 The aboused time to restore contamment pr====e to wieun the LCO 3.6.4 Requesd 3.6.2 requwed irruts was limded to one (1) hour, ralhor than eight (8) Actori A.1 hours as was .c4 required 3.6 M15 The aEomed time to roads MODE 3 in the event that requerements LCO 3.6.4 Rsquesd 3.6.2 for contamment pressure cannot be met was imuted to six (6) hours Achons B.1 and B.2 where no time requwement pre.iously === sari. A requirement was added to reach MODE 5 in 36 hours 'm Wie event West 9 e '
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| requirements for contamment pressure cannot be met.
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| 3.6 M16 Requwements for contammer1 pressure were extended to apply to LCO 3.6.4 Applicatdity 3.6.2 I MODES 1,2,3, and 4, ratier tien to power operatens and reactor j cnhcalaswas .c4requwed.
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| 3.6 M17 A surveiBance m ' . c4 was added to venfy that contenment SR 3.6.4.1 3.6.2 l pressure is witun Isruts every 12 hours. l LCO 3.6.5. 'Contamment AirTemperature"
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| - - - - - = .
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| TABL M - BRTRIX OF MORE RESTRICTIVE CHANGES SECTICBE 3.6, "CONTAIBGENT SYSTDEB," page 4 of 6 l.
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| m of Susenery of Change ITB Section CTS Seselon j Change l 3.6 M18 Requeements were added for contamment air temperature. No LCO 3.6.5 3.6 r- w pr s W W .
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| LCO 3.6.6, Tentamment Spray and Cooling Systems" I
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| 3.6 M19 A requemment was added to enter LCO 3.0.3 immodately in Wie LCO 3.6.6 Requesd
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| * 3.6.2.2 event that tuvo contamment spray trams or any comtuneson of Stree Acton F.1
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| - or more trams are inoperaNo. The aBouwed time to reach MODE 3 in Weis condition was teorefore linuted to severt (?) hours suster then l eight (6) hours as ines previously m irad.
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| 3.6 M20 Survedence . : . ' n3 inere added to operate each contamment SR 3.6.6.2 4.5.1.6 cochng fan unit for 2 15 meutes every 31 days, venty cooling water SR 3.6.6.3 Sour rate to endi cooling unit is 750 gwn every 3's days, and venfy SR 3.6.6.7 eerJi contamment coolmg train starts autometscaBy on an adual or simdated actuohon segnal overy 18 monets 3.6 M30 Requirements were added to tie survedence requsements to venfy SR 3.6.6.5 4.5.1.3 .
| |
| each contamment spray pump starts automaticaBy and to venty SR 3.6.6.6 each automahc contamment spray weeve in Wie Sour past Stat is riot locied, emanad or olhenmuse secured in poedian actuales to tie conect poe on an actual or semulated ssenet 3.6 M31 The atmoed time behusen surveitances for Sie contamment spray SR 3.6.6.5 4.5.1.3 system was lineted to 18 montes ratier Wien refueling interval. The SR 3.6.6.6 lenglh of time between refuoEng intervals was not spooEed in #m prw . _ _ _ _ _ s.
| |
| 3.6 M34 A.:, 4 Stat allouved surveigence tests to be e on Sie SR 3.6.6.5 4.5.1.5 bases of visual observaten Want components have operated SR 3.6.6.6
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| ^ -M:--% has been d=A=aad l
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| l p
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| TABLE M - MATRIK OF MOEEE IEESTRICTIVE CIUW8GSS SECTION 3.6, " COB 8TADGENT SYSTEDs," ,page 5 of 6 Descussion et SamussieryatChange ITS Sommen C T S S e selo n change 3.6 M33 The survemence i+; _.-e. to venly vehes int he conismment SR 3.6.6.1 4.5.2.2 spray system Sour petts are in tie comsci posson were estended to apply to MODES 1,2,3, and 4. rasier tien to power aparations as was preWi+7--M LCO 3.6.7," Spray Addeve Systenf 3.6 M21 Survemance requsements were added to venty sist sie spray SR 3.6.7.2 3.6.2.1 additive tank solukon volume is 2 2505 gebons every 184 days and . SR 3.6.7.3 to venfy mie spray adderve tank NaOH solukon 6 is 2 30% overy 184 days.
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| 3.6 M34 - A requirement # set aBowed survedence loses to be seested on the SR 3.6.7.4 4.5.1.3 booss of venuel otsoorvekon stat components have operated 4.5.1.5 set siocionly has been deleted. A requsement was added to sie
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| ~
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| survemence . n z_4 for sie spray additive system to venty each automehc velow in tne Sour peti tiet is not lar* art. easient or -
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| otnenusse secured in posseion =r** to tie conect pooshon on an actualorsimulated W. i 4:
| |
| 3.6 M33 The surveitmrie requeements to venty valves in Wie contenment SR 3.6.7.1 4.5.2.2 spray N system Sour penes are in Wie conect pombon wero ,.
| |
| esd.sruled to apply to MODES 1,2,3, and 4. rasier tien to power l:
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| W as was pre ==_W r-M. ,i Lc0 3.6.s, isoinhan valve SealwaterSystenc 3.6 M24 The requirements for Wie isotshon Valve Seal Water System (IVSW) LCO 3.6.8 3.6.6.1 i were endended to apply to NM 1,2,3, and 4, rasier tien to l
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| ; oouver e as was preW f-M. E i
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| )
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| 1 I
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| ~
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| TABLE M - MhTRIX OF 3CEtE RESTRICTIVE CHMIGES SECTIct( 3.6, "CONTAIIGENT SYSTDGS," page 6 of 6 h of Seesseery of Change ITS semelen CTS session Change 3.6 M25 The aBoused time to reach MODE 5 if tie requwements of an LCO 3.6.8 Requesd 3.6.6.2 inoperatslo NSW System cannot be met was limded to 36 hours. Acton B.2 No time limit 6.fM W.
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| 3.6 M26 A r ' _._4 was added to Wie sunmEence requwement for Wie SR 3.6.8.4 Talde 4.1-3 IVSW system to venty endt automate valve actuates to tie conect atom 15
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| - - - - ^ -. on an actuoi or samulated =r** ssenet 3.6 M29 The aBoused time betuveen surveillences for the IVSW system was SR 3.6.8.4 Tobis 4.1-3 irruled b 18 monWis rather Sten refuehng interval The longen of SR 3.6.E.6 Itsee 15 time between resueEng interveis was not speased in sie pronous en ._ .".. ,
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| Requwements were added to sie surveigence requwement for sie SR 3.6.8.6 4.4.2 i 3.6 M23 '
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| wsW System to venty specsse header now rates wench demonstrate the 4. ;-/s c.pshady for sealing contanment isotesson valves.
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| ^ .
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| 3.6 M27 Survoisence requwements were added to venfy the IVSW tank SR 3.6.8.1 4.4.2 pressure is a 44 psig every 12 hours, venly Wie IVSW tank volume SR 3.6.8.2 is 2 85i h every 31 days, and venfy Bie NSW h SR 318.5 ruimgen .m wiB pressunse Sie IVSW tank to 2 44 peig every 18 montis.
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| l
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| ;a.. - - - _ - - - . . -
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| TABEK M - MRTRIX OF MORE HESTRICTIVE CBAIGGES SECTION 3.7, "PLAbfT SYSTEses," page 1 of 9 rm f . o Suomeery atChange ITS Secelen CTS Seseles Change LCO 3.7.1, h Steam Sofety Valves," and LCO 3.7.2, M Stoem trJishon VaW 3.7 M1 The Requesd Actons for Main Stoem Sofety Valves (neSSVs) and LCO3.7.1 ApptcebEty 3.4.3 Main Steam loolston Valves (MSIVs) were enade to be apptcalde to LCO 3.7.2 Applicebely MODES 2 and 3 for the asSSVs, and adODES 2 and 3 wies sie MSIVs open for #se MSNs, ranter Wien only to MODE 1 as is currendy required.
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| 3.7 M2 The time to seedi MODE 3 was limded to 6 hours and the time to LCO 3.7.1 3A.3 readi MODE 4 was limded to 12 hours in schons for Sie RSSSV Respeed Actons C.1 W
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| miner C----/_^ : . hmes for Wiese schons did notc;Z:1:';
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| and C.2 3.7 M3 The 24 hour time asowed for more Wien two (2) inoperaldo RSSSVs LCO 3.7.1 3.4.3 was elimmsted from current i- , __a Requeed Actons C 1 and C.2 3.7 M4 The time to reach MODE 2 was limded to 6 hours in #w achon for LCO 3.7.2 Reqused 3.4.3 the MSIV W A compiehon time did not _ c_::x*; onest. Actons B.1, C.1, C.2, '.
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| A near achon to cdoes an inoperaide MSfV witun 8 hours wiei tee D.1 and D2 plant in MODE 3 and wenty tie BASIV cioned once per7 days was added where no requsements previously N A near schon to j piece Wie plant in MODE 3 witun 6 hours and MODE 4 wieun 12 hours if the inoperaWe h4SIV cannot be cloeod was addr.1 where no r=h prew masted l
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| TABI2 M - MATRIX OF MOERE ItESTRICTIVE CHANGES SECTION 3.7, "PIAI8T SYSTEMS," page 2 of 9 Discussion of Suesmery of Cheogo iT5 Seemen CT5 Session I Change LCO 3.7.3 h Foodsmeer Isaiston valves (RFIVs). Main Feodwater Reguishen Valves (RERVs), and Bnnss Vafwes" 3.7 MS A near W for Main Feodoster Isotshon, Reguinhon, and LCO 3.7.3 3.4 sypass Vseves to be operable was added. No equirernents for these veeves -_ fr-w w LCO 3.7.4, "Ausiliary Feedmeter System
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| * 3.7 MS The requirements for a single Auxiliary Feedwater (APW) Systern LCO 3.7.4 Applicabitty 3.4.1 pump and Sour peNi were entended to apply to when ese Steam Generators are being used for heat removal.
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| 3.7 M7 The total time Wat the equsements for Sie AFW System carnot be LCO 3.7.4 Requesd 3.4.5 met sor any and as reasons was snused to a days besore as Achens A.1 ans a.1 requsements for tie AFW system must be met. An overas -
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| completon time for Emilure to mee: #se AFW System requsements did noe ./:cmost. ;
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| 3.7 M S A requwement to readi MODE 4 wsIhm 18 hours was added for the LCO 3.7.4 3.4.4 l-condihon when Sie plant is requesd to shut dossi due to inoperable Required Action C.2 AFW components. No requsement to reach MODE 4 previously messed.
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| 3.7 M9 A requwement to reed MODE 4 wsIhst 18 hours was added for the LCO 3.7.4 3.4.5 condihon when Rio plant is requeed to shut dousi due to inoperable Requead Achon C.2 AFW components. No requusment to reach MODE 4 pseviously existed
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| -=
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| TABLE M - MATRIX OF MOtW: RElmLICTIVE CHABIGES SECTICBE 3.7, "PLAIET SYSTERS ," page 3 of 9 h of Seesenery of Chan8e ITS Seedon CTS Seselon Change 3.7 M10 A condihon for three rnator drwen AFW Sow paths was added. K ' LCO 3.7.4 Reqused 3.4.4, 3.4.5 the plant is in this condton, the plant must be shut down to MODE Achons D.1, D.2 F.1 .
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| 4 conddions. A i@a,a4 to reach MODE 3 in 6 hours and MODE 4 in 18 hours was added for the condton when a steem drwen AFW pump or Sour past is inoperatdo in conymchon wMi a motor driven AFW pump or Sour past. A requsement to restore a requwed inoperaldo AFW pump or Sour path iri MODE 4 immodately was added.
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| I 3.7 M11 Acceptance cntene were added to the . : , ~ _2 for techng See SR 3.7.4.2 4.8.1, 4.8.2 Ane:iliary Feedmeter Pumps. The =rr=an=gce cntene reques test the measured pump perfonnance be compared to and escoed the wired pevnp as.. ca.
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| SR 3.7.4.3 ,4.8.3
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| ~
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| 3.7 M12 The toseng r--7 22a for AFW system pump diodierge vofwes was extended to include a5 volves sist actuate automehcm5y whsch ar not locked, ===an,f or olhensee secured in the regured posson 4.8 i 3.7 M13 Survenamnce requrements for the AFW system were added venfpng SR 3.7.4.1, SR 3.7.4.4, that AFW va%es are in Sie correct poemon every 31 days, venfpng SR 3.7.4.5, l l
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| tiet sie AFW pumps start automehcag yon an aceumi or simulated SR 3.7.4.8 l monal every 18 rnonihs, venfpng that the AFW system is property shoned to sw Condensate Storape System aner an sidended piant spea- i, and venfpng that the automate bus transfer subch suppipng power to one AFW volve operates automehcogy when requesd.
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| LCO 3.7.5. Tondensate -W Tank (CSTy' 3.7 M14 The requwements for the Cendensate Storage Tank requnements LCO 3.7.5 Ap6cabitty 3.4.1 were extended to include MODE 4 when em Steam Generators are beenn used for heat removal j 1
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| e
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| 1 TABER M - MATRIX OF MOEtE RESTRICTIVE CHANGES SECTION 3.7, " PLANT SYSTEMS,"' page 4 of 9 Discussion of Samunnery of Change ITS Secelen CTS Soseion Change i 3.7 MIS The Requwod Actiores for the Condensate Storage Tank (CST) were LCO 3.7.5 ApptcabEty 3.4.3 rnede to be applicable to MODES 2,3, and 4 when the steers -
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| genormors are used for heat removal, ralhar Wien only to MODE 1 as is currently r-W.
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| 3.7 M16 The time to reach MODE 3 was linused to G hours and tie time to LOO 3.7.5 Roquesd 3.4.3 reach MODE 4 was luvuted to 18 hours in schon for tie CST Acaans B.1 and B.2 W Completon tmos for Wiese actions did not r f:M; exist.
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| 3.7 M17 A i=g z_./ to venty by adnunestrahve means that the hockup LOO 3.7.5 3.4 water supply to tie AFW is operable within 4 hours and once per 12 Roquesd Actons A.1, hours tierositor was added for Wie condshon when tie CST water C.1 and C.2 levelis below the requwed limit. No i+1 ~ _ -.ra t::, venty Wie SR 3.7.5.1, backup water supply p..f:-W ===sart A requrement to readi SR 3.7.5.2 MODE 3 witun 6 hours and MODE 4 weteout reliance on tie steem generators for host removal was added for Wie awithhon when sie Servia Water System (SWS) supply to tie AFW system is anoperable. No requwement for tiis conditen c _fr-t ===ames SurveiNance requwements for wie CST were added wentying tiet j CST level is yester than the requesd limit every 12 hours and venrying by administrahve means the operabibly of the bedup SWS 9_M to tw AFW system
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| TABd2 M - MATRIX OF MMIE RESTRICTIVE CHANGES SECTION_3.7, " PLANT SYSTEss," page 5 of 9 f CTS Seselon Discussion of Sumunary of Change ITS Seselon Change LCO 3.7.6, TW Cooling Water System," and LCO 3.7.7, Sensco Water Systenf 3.7 M18 The time to reach MODE f5 was limeed to 6 hours and tie time to LCO 3.7.6 Reqused 3.3.32 reach MODE 5 was linuted to 36 hours for actons in boti tie Actons B.1 and B2 3.3.42 Component Cooling Water (CCW) System and SWS W LCO 3.7.7 Roquesd C-- -f ^ : . tmes for tiese actons did not ;J:- ;==8 Actons D.1 and D 2 3.7 M19 The requirement to enter the Resedual Heat Removal (RHR) System LCO 3.7.6 Reqused 3.3.32 requirements, which is a system supported by tie CCW System, Adson A note, when one requered train of CCW is inoperable was added. SR 3.7.6.1, Survetence requusments for ese CCW System were added SR 3.7.62 .
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| ventying that CCW valves are in sie correct pombon every 31 days and wenfying test tie CCW pumps start automahcagy on an actual ,
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| or simuleled segnal overy 18 rnonths, ,
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| 3.7 M20 The time to reach MODE 5 was limded to 36 hours for achons in LCO 3.7.6 Required 3.3.3.3, i
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| < bott sie CW Cooling Water (CCW) System and SWS Actons B.1, 3.3.4.3 :
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| W Ce.- ^l:{. hmes for tiene achons did not ' LCO 3.7.7 Roquesd l pronously exist. Achon D.2 3.7 M21 The requsement to enter the AC eiedncal power sources LCO 3.7.7 Required 3.3.42 requwements, which is a system supported by tie SWS, when one Acton A Note, requwod train of SWS is inoperatne was added. A requeement to Requwod Actons S.1, close and doectivate an inoperaldo Turtune Building loop isoinhan B2, and C.1 valve witan 72 hours and to venfy Wie valve is dosed every 31 days was added. A requwament to cdose and doectivate one of huo inoperable Turtune Buiktng loop isoishon valves in 2 hours was added 1
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| - - r TABI2 M - MhTRIX OF MORE HESTRICTIVE CSIANGES SECT:l:ON 3.7, "PIANT SY.N," page 6 of 9 Descussion of - Sunumery of Change ITS Seselon CTS Someten Change 3.7 M22 Surveimance requeenm1ts for the SWS were added ventying Wiet SR 3.7.7.1 3.3.4 valves in en SWS are in the correct posshon every 31 days and SR 3.7.7.2 vaifying Wust autornate valves in Wie Sour path acsuste to the correct
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| ,e on an actual or simuisted signal every 18 montes.
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| 3.7 M23 A surveiBance requrement for the SWS was added wentying West SR 3.7.7.4 3.3.4 the airamiste hu. transfer suutch supplying power to one Turtune Bustaing kyJp W valve operates ^ ~- . _ ^ "; when reqused.
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| LCO 3.7.8, h sat Sink (UHS)*
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| 3.7 M24 The reqursments for the UIhmete Heat Sink were extended to LCO 3.7.8 Applicahitty 3.4.1 i indude MODE 4 condesons. l 3.7 M25 The requmements for talung adions associated wish inc,seratite LCO 3.7.8 App 5catsby 3.4.3
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| . components of sie ununst Nest sink were extended to indude .
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| MODE 4 condissons.
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| 3.7 M26 The time to reach MODE 3 wLs hmited to 6 hours and the time to LCO 3.7.8 Requend 3.4.3 reach MODE 5 was limded to 36 hours in Wie Ultenste Heat Sink Actons s.1 and id.2 Required Acasons. Compiston hmes for tusse achons did not
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| ;;/sw most.
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| 3.7 M27 Surveigence Reqwrements for Wie UIhmate Heat Sink were added SR 3.7.8.1, 3.4 ventying test Wie Lake water level meets twquwements every 24 SR 3.7.8.2 hours and wentying Stet sie SWS ^_ ;--.^.we is less th!=n or aquel to 95'F every 24 hours
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| TABLE M - MATRIX OF MORE RESTRICTIVE CHANGES SECTION 3.7, "PIANT SYSTERS," 'page 7 of 9 rh* et Sununary atChange ITS Season CTS Sostion Change LCO 3.7.9, Tantrol Room Emergency Filtrahan System (CREFS)." and LCO 3.7.10, Tontrol Room Emergency Air temperature Contml (CREATC)"
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| 3.7 M28 The time to reach MODE 3 was changed from eight (8) hours to sir LCO 3.7.9 Requesd 3.15.1.a (6) hours for an inoperaWe Contml Room Emergency Filtraton Acton B.1 System (CREFS) or Control Room Emergency Air Temperature LCO 3.7.10 Required Control (CREATC) System train that cannot be restored to operaldo Achon B.1 status withm the anowed time.
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| 3.7 M29 The time to reach MODE 3 was changed from eight (8) hours to sin LCO 3.7.9 Regured 3.15.1.b (6) hours for two inoperatdo CREFS or CREATC System trans of Aeons F.1 and F.2 whdi one cannot be restored to operable status wehm Wie atowed LCO 3.7.10 Requesd time. Achons F.1 and F.2
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| , 3.7 M30 A requsement to suspend movement of irradiated fuel assemblies LCO 3.7.9 Requesd 3.15.2.b
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| ~
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| was added when both trans of CREFS and CREATC are inoperaldo Amon C.2 - .
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| dunne movement of irradiated fuel asserpM== LCO 3.7.10 Roquesd Action C.2 3.7 M31 The Survetence R ~ _.m4 forvendicahon of Control Room SR 3.7.9.4 4.15.f.4 3 Possene pressure was made more resenchwe by requinns a specsEc value be met for sie air pressure relatswe to the we=e= almospnere. .
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| ll The requwement is tiet the dillerenhal air pressure be at least one-eighlh (1/8) inch wotor column. l {;
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| 3.7 M32 A Surveinance Requsement for h of Control Room Air SR 3.7.10.1 4.15.f.2 .'
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| Tomoerature Control <~Enn & was added
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| _ . _ . _ _ -........w-_-. . = . . . . . .
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| TABIE M - METRIX OF MDGE RESTRICTIVE CBANGES SECTION 3.7, "PIANT SYSTDW," page 8 of 9
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| ' Discussion et Seouunary atChange ITS Session CTS Semelen Channe LCO 3.7.11, Tuol Budding Air Cleanup System" 3.7 M33 Surveigence Requsements were added for Sie Fuel Building Air SR 3.7.11.1 3.83 Clemmap System (FBACS) venipng Stet Wie FBACS be run for 10 SR 3.7.11.2 conhnuous hours M #ie hestors operahng a-W every 31 SR 3.7.11.3 days, ventyng Wiet Nie FBACS be tested in accontence witi tie Ver.ailekon FiberToshng Program, and wentying Wiet Wie FBACS can mentesi a nogetwo pressure in the Fuel Building wien respect to the .-
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| andenem ^_. +.-tx every 18 nuorens.
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| LCO 3.7.12 Yumi 54:3 rage Poolwater Lever' 2
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| 3.7 a434 A new W%n for Fuel Storage Pool Water Level was added LCO 3.7.12 3.8 whicit requees tiet a trunonum of 21 fact of water be mentaned above tie fuel. No i- . 21.4 for Weis value f:t aaneand i LCO 3.7.13 Tuoi -W Pool Baron Concentrabon" 3.7 M35 A i+; 1.1/ to suspend nuovament of fuel assembhos in sie fust LCO 3.7.13. Requimd 5.4.3 storage pool was added when sie fusi storage pool baron Acton A.1 concentration is not wahm requsements dunne nuovement of fuel assemises in the fuel storage aaan 3.7 M36 The frequency for sempling bomn concentreten in the fuel storage SR 3.7.13.1 Table 4.1-2, p
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| i pool was increened frorn prior to refueling or fuel movement in See tem 7 fuel h aaa8 to every seven (7) ders.
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| _ _ _ - \1
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| : I r i :
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| I li 8
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| )
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| II I III mg 1 1g .
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| Ie e
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| l I1 n
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| 5 I I~
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| l l?!
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| x
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| * ! i B !
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| 1 I, p
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| i-k
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| ~
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| l !
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| TABLE M - MhTRIX OF DOIV! IEESTRICTIVE CHA00GE SECTIC88 3.8, "EI2CTRICAL PIAlfT SYSTERS," ' 'page 1 of 8 h of Sensumery of Change ITS Seesee CTS Soemese Change LCO 3.8.1, "AC Soure- ^._J 3.8 M1 The requsements for AC elecences power sounzes dunng opershon LCO3.8.1 Applicebety 3.7.1 were estended to apply to R400ES 3 and 4, talhar Sean only to 3.7.2 reactor cnhcal and power- ; _ - =e.
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| l 3.8 M21 A requisernent was added for the quelded arcui behusen the cNate LCO 3.8.1 3.7.1 l transemesson network and she onnes emergency AC elecencal disenbuhon system to be operable 3.8 M2 Requimments lhet agowed power opershon to conhnue beyond 24 LCO 3.8.1 3.7.2
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| . hours prended one or boIh the diesel generators are operaide and
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| ^
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| reportprig. ; z._. to the 754C are met were deleted.
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| 3.8 M3 The time eBowed for em requeements for AC sources dunng LCO 3.8.1 Requimd 3.7.2 e
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| . opershon to not be rnet regensees of actons talen was linused to 8 Achons A.2 and B.4 ,
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| days. t 3.8 M4 The time to readi MODE 3 was lirrded to 6 hours and the time to LCO 3.8.1 Requeed 3.7.2 saech MODE 5 was linated to 36 hours when requsements to Actons C.1 and C.2 restore an inoperaide spa =Emad oNete circast or shosel generator cannot be met. l 3.8 M25 A seguesment for See diesel generators to achsovo steady state SR 3.8.1.2 4.6.1.1 vanage 2 467 vous and s 493 volts and frequency of 2 58.8 He and s 61.2 Hr was added to tee nion8tly surveiBance test of tae diesel generator
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| 'l l
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| [
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| _ _ . _ - ~ . - .- . . . . . . . . - . . . - . . . . ,
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| TABLE M - MATRIX OF MORE RESTRICTIVE CHANGE SECTION 3.8, " ELECTRICAL PLANT SYSTEMS," page 2 of 8 i
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| rh-=M of Semunary of Change ITS Section CTS Secelen y
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| CW 3.8 MS Requrements to venfy that the diesel generators enenpze SR 3.8.1.14 4.6.1.2 ).
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| permaneney connected loads in s 10 seconds, oneqpres auto-connected emergency loads trough the load sequencer, acheves steady state voltage 2 467 volts arut s 493 volts and frequency of 2 58.8 Hz and s 61.2 Hz, and supplies permanently connu: led and autoconneted emergency loads for a S rmnutes, were added to the 18 month diesel generator survedance test.
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| I l
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| fi'\
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| I
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| TAEKK M - DSLTRIX OF MOERE RESTRICTIVE CBAttGE SECTICBE 3.8, "EI2CTRICAL PLABIT SYSTEDs," page 3 of 8 Discussion of Susseery of Cheese ITS Sostion CTS Sessen Change 3.8 MS Surveisance requemments were added as fotows. S!anty correct SR 3.8.1.1 4.6.1 tweetier alignment and indmated power awedobility for the ased= SR 3.8.1.4 cecus every 7 ders. wenty each day tank contans 2 140 gesons of SR 3.8.1.5 fuel of every31 days. Check for and remove accumulated water SR 3.8.1.6 from each day tank every 31 days. Venty Wie fuel oil transfer system SR 3.8.1.7 operates to automstmagy transfer from sie storage tank to tie day SR 3.8.1.8 tank every 31 days. Venty each diesel generator starts from SR J.8.1.9 storicapy condson and acNewes required voltage and frequency SR 3.8.1.10 every 184 days. Venry sects diesel generator 6 a load greater SR 3.8.1.13 Wian or aquel to its h segle largest load wipiout inppung on SR 3.8.1.14 overspeed every 18 anontes. Venfy test endi diesel starts ort a SR 3.8.1.15 samuisted or actual loss of opste power segnal and achsevos SR 3.8.1.17 required condtons in Wie requwod teos every 18 montis. Venty tiet each diesel generator starts and acheves requwed conditions in twe requwod tunes witun Eve wunutes of sie 24 hour kled test every 18 montes. Venfy Stat Wie interval beguneen endt sequenced lood block is witun 10.4 seconds of demgn siterval every 18 l
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| i niontes. Venty West each daeal starts on a samulated or actual l Engineered Safety Features (ESF) segnal and achsovos requesd j condtons in die requesd tunes every 18 monets. Venty sie automesc transfer capabety of Wie 4.16 kV bus 2 and tie 480 von emergency bus 1 loads from sie unit anaaliary transformer to sie startup transformer every 18 man:hs. Venry that when started senumaneously from standby condson each diesel actuoves required condissons witun 10 seconds every 10 years.
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| 3.8 M19 A survedience frequency requusment of 18 niontes was added to SR 3.8.1.11 4.6.1.3 test sie emernancy *===' nonerators trips defeat sunemon.
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| 3.8 M24 An aBouvence for % rvunimum and meemum =Ar===N= kW SR 3.f.1.12 4.6.1.5 1 l
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| values under tie drect morutonna of tie manufacturerwas doisted
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| .1 1
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| . -._--__..m. _ _._. _ _ _ . _ _ _ _ _ _ _ _ _ _ _ _ . _ _ . _ . _ _ _ _ _ _ _ _ _ _ _ _ _ . - - _ _ . - _ _ . . _ _ .
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| i !
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| {
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| ;- l TNBEK M - MhTRIX OF MORE IIESTRICTIVE CBANGE SECTICBf 3.8, "EIRCTRICAL PIANT SYSTEBEE," page 4 of 8 [
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| I !
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| : one.cosio. < s.somer, w Chm.8e i7s seeme. c7s - I l l Change l-LCO 3.8.2, *AC Sources-ShuMoosf _
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| 3.8 M7 Requusments were added for AC elecencal poser soun:ss in .
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| LCO 3.8.2 3.7 j
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| : MODES 5 and 6, and dunne rnovament of irradiated fuel i i assemMiss. No i- . _ G m e ~ .~ T ; in 9tese snodes.
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| I LCO 3.8.3, "Desel Fuel Oil and Starkng Air" I
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| ; 3.8 M1 The requsements forrh s Fuel Oil and Startng Air were enemnded LCO 3.8.3 Applicability 3.7.1 ,
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| l to apply to when sie h diesel generator is requesd to be l l operaMe, ralhar than only to reactor cnhcal and power operatens. -
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| 3.8 MS A requsement was added to restorm Wie diesel generatar air recesver LCO 3.8.3 Roepsed 3.7.1 l- l l pressure to a 210 poig wehst 48 he s when pressure in one or Achons D.1 j more diesel & air accumulators is he-s fian 210 psia.
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| i ..
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| } 3.8 M28 A requsement was added to restore stored fusi oil proportes to LCO 3.8.3 Requwed 3.7.1 ;
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| wdhm linuts adhm 30 days of when one or mod diesel generators Achon C.1 !
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| wiIh fuel oil proportes are not wetun limds. i i 3.8 M9 SurveiBance requsements were added to venty Sist each naimens SR 3.8.3.3 4.8.2 l generator air start receiver pressure is 2 210 peig and to ched for SR 3.8.3.4 !;
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| and remove accumulated water from eeds fuel oil storage tank. '
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| ; 4 -
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| i LCO 3.8.4, "DC Sources-Operahng" 3.8 M1 The requsements for DC elecencel power sources were adonded to LCO 3.8.4 Apptenbitty 3.7.1 apply to MODES 1,2, 3, and 4, rapier tien enfy to reactor cnhcal .
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| ; and power operamans I
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| l 3.8 M10 The time to reach MODE 3 was limded to 8 hours and sie time to LCO 3.8.4 3.7.2
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| } reedi MODE 5 was limded to 36 hours when one inoperable DC Requend Actons B.1 i elecencal power source cannot be restored to operatde status in tuvo and8.2 j _m hours I
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| 2
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| .. . . , , - . , , , , - . , -. .- ._- - - = - . ~ , - . . - - - , , _ _ . , - - . . _ . . - ~ , . - - . - _ . _ _ . - . ~ , . - . - - -
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| M "-
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| TADLE M - MATRIX OF MCRE RESTRICTIVE CHANGE SECTION 3.8, " ELECTRICAL PLANT SYSTEMS," page 5 of 8 Discussion of Summary of Change ITS Section CTS Section !
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| Change 3.8 M11 Requirements to verify that the "A" Battery capacity is 80% and SR 3.8.4.6 4.6.3 the "B" Battery capacity is 2 90% were added fa the surveillance requirement to perform a performance disci f .c;y 'est. I 3.8 M13 Surveillance requiremen were added to w %dat battery cells, SR 3.8.4.2 4.6 cell plates, and racks shew no visual indicatics : physical damage SR 3.8.4.3 or abnormal deterionzation that could degratu battery performance SR 3.8.4.4 every 18 months, remove visible terminal corrosion, verify battery celi to cell and terminal connections are dean and tight, and are coated with anti-corrosion material every 18 months, and venfy each battery charger supplies 2 300 amps at 125 2 volts for 2 4 hours every 18 months.
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| 3.8 M12 A requirement to verify battery terminal voltage is 2 125.7 volts was SR 3.8.4.1 4.6.5 added to the surveillance requirement performed on the battery chargers everv 7 days.
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| ii
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| i TABLE M - MATRIX OF MORE RESTRI'.?D?. CHANGE SECTION 3.8, " ELECTRICAL PLANT F: WJIS , " -page 6'of 8 Discussion of Summary of Change ITS Section CTS Section ,
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| Change
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| ' LCO 3.8.5, "DC Sources-Shutdown" 3.8 M14 Requrements were added for AC electncal power tources in LCO 3.8.5 3.7.1 MODES 5 and 6, and dunng movement of irradated fuel -
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| assemtWees. No r-h emsted previously in these modes LCO 3.8.6, " Battery Cell Parameters *-
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| 3.8 M15 Requwements were added for battery ceN parameters and averaga LCO 3.8.6 Applicat2ty 4.6.3 i=^ 'f.- temperature to be withen specdied limits when the SR 3.8.6.2 associated DC electncal power subsystems are requwed '.o be SR 3.8.6.3 opendde. Survedlance requrements were added to venfy that battery ceN parameters be wehen Category B limds aner a battery decharge or a bettery overcharge and to venty average electrolyte temperature ofi.yiex - c cens is :t 67'F.
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| ^^
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| 3.8 M26 A requrement was added to the battery survedience requwemend to - SR 3.8.6.1 4.6.3 venfy that battery ceN parameters he weihin Category A Irruts.
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| AdditonaNy the survesRance requwe-nent was made to apply to aN ' i
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| ?
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| banery ceNs rather than to evay finh ceN, and the aNowed frequency of the survedhmce was decreased from monthly to seven m days.
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| 3.8 M29 The survedlance requrement for measunng and recording the SR 3.8.6.3 4.6.3 ternperature of the battery electrolyte of the batter /s pilot ceN- ^was 1
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| ^
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| extended to requre measurement of the average ofiore n-- ^ 2 ceNs.
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| ' ' ~ - '
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| TABLE M - MATRIX OF MORE' RESTRICTIVE CHANGE SECTION 3.8, " ELECTRICAL PIANT SYSTEMS," page 7 of 8-Discussion of Summary of Change ITS Sec6on CTS Section C'=4 LCO 3.8.7, "AC instrument Bus Sources-Operahng" 3.8 M16 Requwements were added for AC Instrument Bus Sources dunng LCO 3.8.7 3.7 MODES 1,2,3, and 4. No requwements existed previously in these modes.
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| LCO 3.8.8, "AC Instrument Bus Sources-Shutdown" 3.8 M17 RWs were added for AC inshumont Bus Sources dunng LCO 3.8.8 3.7
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| 'wiCESS 5 and 6, and dunng movement of irradssted fuel assemt. lies.- No r-h emsted prewmahr in these modes.
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| LCO 3.8.9, "Dmenbubon Systems-Operahng" 3.8 M18 The requirer,:"nts for AC doinbubon systems dunng opershon were LCO 3.8.9 3.7.1 i extended to apply to MODES 3 and 4, rather than only to reactor Appbcatxhty enhcal and power ope shons.
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| 3.8 M27 The requwament for the 480 volt emergency buses to be energced LCO 3.8.9 3.7.1 was extended to requwe also that all of Train A and Train B AC, DC, ..'I and AC instrument bus electncal power delnbubon subsystems be 3 j' I
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| W. ll 3.8 M20 The tc,lal time allowed for failure to meet the doinbubon systems LCO 3.8.9 3.7.1 specdicahons was hmded to 16 hours. Requwements to be in Requwod Actons B.1, .jl MODE 3 in 6 hours and MODE 5 in 36 hours were added in the C.1, F.1, and F.2 ijj event that requwements to restore inoperable AC and DC electncal ljl pc;c dminbubon =w can not be met. >a Survedlance requwements were added to venfy conect breaker SR 3.8.9.1 Table 4.1-3, 3.8 M22 alegnments and voltage to AC, DC, and AC instrument bus electrical item 18 x;r distnbubon systems
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| ~ TABLE: M'- MATRIX OF MORE RESTRICTIVE CHANGE SECTION 3.8, " ELECTRICAL PIANT SYSTEMS," page 8 of 8~
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| Discussion of Summary of Change ITS Secuon CTS Secuen Chango LCO 3.8.10, "Distnbubon Systems-Shutdown" 3.8 M23 Requrements were added for distnbubon systems dunng MODES 5 LCO 3.8.10 3.7 and 6, and dunng movement of imedseted fuel assembhos. No r=a _h emsted pnmously in these modes.
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| 1
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| . I I
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| ! 4 1
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| l 'i i
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| -.-w=-.
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| : TABLE M - MATRIX OF MORE RESTRICTIVE CHANGES
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| ~SECTION 3.9, " REACTIVITY CCHTROL SYSTEMS" page 1.of 3 Discussion of Summary of Change ITS Section CTS Section Chance LCO 3.9.1, " Boron Concentrabon" 3.9 M1 The requrements for mantaming boron correntrabon in the pnmary LCO 3.9.1 Applicately 3.8.1 coolant dunng refuehng operabons were extended to apply to MODE 6 rather than to reactor vessel head removal and unloadmg fuel from the reactor.
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| LCO 3.9 2,"fer4aar instrumentshon" 3.9 M3 The requrements for nuclear instrumentahon dunng refueing LCO 3.9.2 Applicatihty 3.8.1 operathns were extended to MODE 6 rather than to whenever core L-=netry is being charW.
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| 3.fr M13 A requwod achon was added for the condson of one source range LCO 3.9.2 Requwed 3.8.1 neutron mondor bemg inoperable to suspend posshve reactevdy Achons A.1 and A.2 addebons. A requwement to cease refuelmg of the reactorin the event that the specdicabons for neutron instrurpentabon cannot be met was extended to manay to core alterabons 3.9 M4 A requwement was added when the specaficahons for neutron LCO 3.9.2 Required 3.8.1 .;
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| instrumentabon cannot be met to perform a sunellance to venty Action B 2 :
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| boron concentrabon is vnthin the kmds of the Core Operahng Limits ;
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| Report (COLR) once vnthm four (4) hours and every 12 hours .:
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| thereafter.
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| 3.9 M5 A survesitance requwement was added to perform a channel SR 3.9.2.2 3.8.1 cahbrahon ;=.y 18 months. l LCO 3.9.3, "Contamment Penetrabons" 3.9 M6 A surveirance requwement was added b venfy each contamment SR 3.9.3.1 3.8.1 oenetr=8*=1 is in the r=W status everv 7 days. j
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| .u._..__
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| .u. . - - - - - . . _ _ . , _ .--- -
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| | |
| TABLE M - MATRIX OF MORE RESTRICTIVE CHANGES SECTION 3.9, " REACTIVITY CONTROL SYSTEMS" page 2 of'3 Discussion of Summary of Change ITS Section CTS Secosen Change LCO 3.9.4, "RHR and Coolant Cuculabon-High Water Level" 3.9 M7 A requwement was added to the specsficahons for the Residual Host LCO 3.9.4 3.8.1 removal (RHR) system for one RHR train to be in opershon, and a note was added to allow the operahng train to be removed from apar=hari for one (1) hour in any eight (B) hour penod 3.9 M15 The requwaments for RHR and coolant cand=han were extended to LCO 3.9.4 Appbcatukty 3.8.1 apply to MODE 6 with water level at least 23 feet above the reactor vessel flange, rather than to whenever fuel assembhos are bosng moved vnthen the reactor pressure vesset 3.9 M8 A requwement was added for the condetson when the RHR and LCO 3.9.4 Reqund 3.8.1 coolant cwndahnn requeroments cannot be met to close all Acton A.4 penetr= harm with dwect access to outsede within four (4) hours 3.9 M9 A'survesilence requwament was added to venfy that one RHR train SR 3.9.4.1 3.8.1 is in aaar=han every 12 hours LCO 3.9.5, "RHR and Coolant Can dahan-Low Water Level" 3.9 M10 Requwaments were added for RHR and coolant csculabon with LCO 3.9.5 3.8.1 water level less than 23 feet above the top of the reactor vessel flange No r=_Ws prev-%r emsted.
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| LCO 3.9.6, "Ra6=hng Cavsty Water Level" 3.9 M11 Requwements for refuehng cavdy water level were extended to apply LCO 3.9.6 Appiscatuhty 3.8.1 to dunng movement for of irradsated fuel assem.Aies withen contaenment rather than to whenever fuel assembises are bosng moved within the reactor vessel.
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| TABLE M - MATRIX OF MORE RESTRICTIVE CHANGES-
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| 'SECTION 3.9, " REACTIVITY CONTROL SYSTEMS" page 3 of 3 Discussion of Summary of Change ITS Section CTS Section Change 3.9 M16 Requrements for refuehng canty water level were extended to apply LCO 3.9.6 Appbcatutty 3.8.1 to core alterabons from whenever fuel assemises are bang moved within the reactor vessel.
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| LCO 3.9.7, T,ontaenment Purge Fdier System" 3.9 M18 Survedlance requrements were added to venly that the contaenment SR 3.9.7.2 3.8.1 purge filter system is in opershon and mentarung contanment SR 3.9.7.3 pressure r4 .0relative to the MW =aahmy buddag every 12 hours and to perform requred contanment purge filter system testing in accordance with the Ventilation Fdter Testeg Program.
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| l
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| TABLE M - MATRIX OF MORE RESTRICTNE CHANGES SECTION 4.0 " Design Features" Sheet 1 of 1 I
| |
| Discussion of Summary of Change ITS Section CTS Section Change ,
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| 4.0
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| * Design Features" 4.0 M1 Requwements regarding fuel storage were expanded to include 4.3.1.1.c 5.4 nomenal center to center distance between fuel assemblies placed 4.3.1.1.d in the high density and low density fuel racks 4.0 M2 Requerements regarding fuel storage were expanded to include 4.3.2 5.4 provisions lwnshng inadvertent draeneng the spent fuel pool below 18 feet above the top of the fuel.
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| 4.0 M3 Requwements regarding design of spent fuel storage racks and new 4.3.1.2.b 5.4.2.1 fuel storage racks were expanded to include requong allowances 4.3.1.2.c for uncertainties in calculation of reactivity. 4.3.1.1.t>
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| t -
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| TABLE M - MATRIX OF MORE RESTRICTIVE CHANGES SECTION 5.0, " ADMINISTRATIVE CONTROLS" page 1 of 3..
| |
| Discussion or summary at change ITs secuen cts secuen Change Sechon 5.1, "Responsstukty" 5.0 M14 Requrements were added for the control room command funchon, 5.1.2 6.1.1 and for succession for that funchon. No requirements previously existed.
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| Sechon 5.2, " Organo =Ean" 5.0 '1 The requrements for two bcensed operators to be present in the Sechon 5.2.2 6.2.3 control room under certain conddeons were extended to be at all tunes dunng MODES 1,2,3, and 4, and the requrement was added that one of the two aparators be a Sensor Reactor Operator.
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| Sechon 5.4, " Procedures" 5.0 M2 A requrement was added to mamtaen wntten emergency operstmg Sechon 5.4.1 6.5.1.1.1 prw-es.
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| 5.0 M3 A requrement was added for written procedures to cover all Sechon 5.4.1 6.5.1.1.1 programs W in W% 5.5.
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| Sechon 5.5, " Programs and Controls" ij 5.0 M4 The level of approval for the Offsete Dose Ndahan Manual Sechon 5.5.1 6.16.2 (ODCM) was restncted from rewsw and acceptance of the Plant Nuclear Safety Commettee to maaroval ty the Plant Manager.
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| 5.0 M12 Requrements were added for the content of the ODCM to include Secton 5.5.1 6.16.2 I the radioachve effluent controls and radelogmal envronmental mondonng actmtses, and descnptons of the informahon that should "
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| be included in the Radiologmal Envronmental Operahng and Radmachve Effluent Release Raaarts
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| TABLE M - MATRIX OF MORE RESTRICTIVE CHANGES SECTION 5.0,-" ADMINISTRATIVE CONTROLS" page 2 of.3 Discussion of Summary of Change ITS Section CTS Section channe 5.0 MS A program for component cyche or transient hmits was added to Sechon 5.5.5 1.0 I track Updated Final Safety Analyses Report (UFSAR) transsent occurrences.
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| 5.0 M11 A program was added that provides centrols for the relocate 1 S echon 5.5.4 1.0 requwements for control of r*W effluents contamed in the Current Technical Speedicabons Radelogscal Envwonmental l Technscal Sh%s.
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| 5.0 M13 A program was added for pnmary coolant sources outsede of Sechon 5.5.2 1.0 contamment that dupbcates Facdity Operahng License DPR-23, paragraph 3.G(2).
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| 5.0 M9 Requerements for the Prestressed Concrete Containment Tendon Sechon 5.5.6 4.4.4.1 Survedance Program were added for controls for monstonng any tendon degradabon and eNechveness in corrosson protection medsum, fr=a=_=ncies, and acceptance criteria.
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| 5.0 M6 Requwements were added for the Techmcal Specslicahon Bases Sechon 5.5.14 4.20 Control Program. ;;
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| 5.0 M7 Requwements were added for the Safety Function Determmabon Sochon 5.5.15 4.20 .
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| Program (SFDP). [
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| 5.0 MIS Requwements were added to perform survemance tests in the hr*an 5.5.13 Tabis 4.1-2, ,k Diesel Fuel Oil teshng Program to sample for cloud point, sample items 11 and i overy 31 days rather than prior to transfer to the Unit No. 2 storage 12 !l tank, restrict the allowed extension of the survedance anterval to 38.75 days imm 45 days, and determmmg that the fuel oil is W=Na for use prior to addag the oil to the storage tanit Sechon 5.6. "Recorbna RaaaaWments"
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| ' TABLE M - MATRIX OF HORE RESTRICTIVE CHANGES SECTION 5.0, " ADMINISTRATIVE CONTROLS" page 3 of 3 I
| |
| Discussion of Summary of Change ITS Section CTS Section {
| |
| Char.ge 5.0 M10 A requirement was added that pnmary safety and relief valve Section 5.6.4 6.9.1.2.4 challenges shall be included in the monthly Operating Report, rather than in an annual report as previously required.
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| A requirement was added to include the Emergency Core Cooling Section 5.6.5 6.9.3.3 5.0 M8 System (ECCS) limits in the Core Operating Limits Report (COLR).
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| l 1 ;l k i i
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| TABLE L - MATRIX OF LESS RESTRICTNE CHANGES l
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| SECTION 1.0 "Use and Applicahon" page 1 of 1 Discussion of Description ITS Section CTS Section C": ,;-rf Charactofization Change 1.0 "Use and Appiscation" 1.1 L1 The definition for 1.1 1.6.2 None Unique CHANNEL CAUBRATION was relaxed to exclude RTDs and thermocouples, requiring an in place cross channel comparison.
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| 1 Categories ;
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| L Rea n enviof Ar9ernhasy ,
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| lie Pelaxson of Swvemance Frequency IIL LCO stated in terms of Trans rather than componerts IV. Asowed Outage Time Edension frorn 24 hours to 72 hours V. Relaxabort of Requred Actions to exit Apprrahmey VI. Relaxahan of Sunemance Requrement acceptance creena Vll. Ran===euws of Allowed Outage Time Viit. Deeshon of Requremert for 30 day Spedal Report to NRC
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| --- =. .
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| TABLE L - MATRIX OF LESS RESTRK:TWE CHANGES SECTION 2.0 " Safety Umits (SL)" pp 1 of 1 Discussion or Description ITS Section CTS Section er ;-:-rf l cheracterization Change i 2.0 " Safety Limits (SL)"
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| 2.0 L1 The requirements 2.1.2 2.2 I Unique with for Reactor respect to .
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| Coolant System Applicability (RCS) Pressure details Safety Limits (SL) were reduced to exclude the time when. fuel is in the reacto'r vessel and the rector vessel head closure bolts are not fully tensioned or the reactor vessel +
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| head is removed. I i
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| Catesones I. Reismation d Appecabety II. He of Surveemnce Frequency IIL LCo stated in tonne of Traine rather then camponents IV. Anowed Outage Tme Edenelon troen 24 hours to 72 hours V. Rolanahon of Requwed Actons to ed A M -
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| t1. Reismahon of SurveGence E-- - _ l accepance crierte V!l. RW of Anowed Outage Time Vill. Delehan of Requeemort for 30 day 9W Report to NRC
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| | |
| - m = - .. . .
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| TABLE L - RIATRIX OF LESS RESTRICTWE CHANGES SECTION 3.0, "URIITING CODWITION FOR OPERATION M:0) APg= rama rTY," page 1 of 1 Discussion of Description ITS Sectior. CTS Section Category Characterization Change 3.0 L1 An excephon to compipng LCO 3.0.5 - 3.0 None unique with required schons when a specificahon was not met was added to a50w for teshng of inoperable eqwpmentin order to restore the inoperable eqtapment to operable status -
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| 3.0 L2 An atowance for exmnding SR 3.0.2 4.0 None Unique the frequency by 1.25 hmes aner the first performance of a required schon when a specsficahon is not met was added.
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| The fre-m must be i l specsfied as "once per . . ." , j '
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| i lJ t ,
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| e Categories I. Relaxation of Applicability.
| |
| II. Relaxation of Surveillance Frequency , r III. 100 stated in terms of Trains rather than components j IV. Allowed Outage Time Extension from 24 hours to 72 hours ,I V. Relaxation of Required Actions to exit Applicability VI .. Relaxation of Surveillance Requirement acceptance criteria VII. Relaxation of Allowed Outage Time VIII. Deletion of Requirement for 30 day Special Report to NRC
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| - = . . = - - - - - - - - - - - - - - - - - - -
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| | |
| TABLE L - MATRIX OF LESS RESTRICTIVE CHANGFS
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| - SECTION 3.1, "REACTMTY CONTROL SYSTEMS," page 1 of 4 Discussion of Description IT3 Section CTS Sechon C r ; -:- i Characterization Change LCO 3.1.1, " SHUTDOWN MARGIN (SDM)*
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| 3.1 L1 The allowed time to LCO 3.1.1 3.10.8 Vil Uneque with.W to restore SDM to within the Requwed Action allowed outage time requiredlimits was A.1 extensson onen extended from no allowed time to 15 minutes.
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| LCO 3.1.2, " Core Reactivity" 3.1 L7 A requirement was deleted LCO 3.1.2 4.9 Vill Uneque with respect to to submit a Special Report circumstances of to the NRC within 30 days repost of observance of a difference between predicted and actual boron concerdration that is equivalent to one percent in reactivity.
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| ? l l
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| l Categories L Reisetion of Wi. , 4 I
| |
| IL Reimudion of Sunesence Frequency I!L LCO stated in terms of Trans reiher than componeres i IV. Agowed Outage Tune Edenelon Irorn 24 hours to 72 hours V. RW of Requred Aceans to est W^i VL Reimehon of Sunmaance Requrement arregnance criterte VIL Reimenon of Agowed Otdage Trno Vill. Delsbon of Requrement for 30 day W Report to NRO
| |
| ...r - - . . - --ri
| |
| - .-.,.l-..
| |
| '' -.. i'' ' ' ' '' ' -- -''.' ' ' ' ' " ' ' " ' -' ''" ' '' ' " ' ' ' ' ' ' '
| |
| | |
| m . ._. .-____ - ____ ___
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| TABLE L - MATRIX OF LESS RESTRICTIVE CHANGES SECTION 3.1, "REACTMTY CONTROL SYSTEMS," page 2 of 4 Discussion of Description ITS Section CTS Section ci;-: y Characterization Change LCO 3.1.3, " Moderator Temperature Coefficient" 3.1 L2 A requirement to make the ' LCO 3.1.3 3.1.3.3 None Unque reactor subc.fscal by an Requred Action amount greater than or A.1 equal to the potential reactivityinsertion from depressurization was relaxed to require that I
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| administrative control rod withdrawallimits to maintain Moderator Temperature Coeffeient (MTC) within limit within 24 d
| |
| hours.
| |
| l l
| |
| I l
| |
| I Categmes L Ran===han of Apparamy l tl Ratavahnq cf Sungdignm ffgquency ill LCO stated in terms of Trams rather than components IV. Anowed OWage Time EAenwon from 24 hours to 72 hours V. Relaxahon of Requred Actons to est Apptcabdily VL Relaxahon of Sunedlance Requrm acceptance creerte Vit Reinxahon of AEowed OWage Time Vllt Dolchan of Requiremert kV 30 day 9 m Report to NRC
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| | |
| TABLE L - MATRIX OF LESS RESTRICTWE CHANGES SECTION 3.1, "REACTMTY CONTROL SYSTEMS," page 3 of 4 Discussion of Description ITS Section CTS Section Category Characterizateor.
| |
| Change 3.1 L5 The time allowed for LCO 3.1.6 3.1.3 None Uneque ,
| |
| shuttmg down the reactor Requred Action a 4
| |
| when the MTC lowerlimit C.1 t is not metwas extended
| |
| ! from eight (8) hours to 12 l
| |
| hours 3.1 L3 The surveillance SR 3.1.4.2 Table 4.1-3 I, 11 Uneque with respect to requirement for verifying item 2 frequency and rod freedom of movement survealance was relaxed to apply only applicabshly details -
| |
| to rods not fullyinserted only and to be performed only every 92 days rather than every 14 days as previously required.
| |
| canegones
| |
| : 1. Relaxahon or AM ,
| |
| II. R% of Sunesence Frequency ill. LCO stated in terms or Trains rusher than componards IV. Akmed Outage Time Edension from 24 hours to 72 hours V. Relaxatson or Required Actiors to est Apgscately Vt. Reimmhan or Sunamance Rg-_: ___," = mage =rze cnione .
| |
| Vit Res =* or Aeoned Osmage Tyne Vtil. Deedson of Requirement for 30 day Special Report to NRC
| |
| - - _ _ _ _ =
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| | |
| TABLE L - MATRIX OF LESS RESTRICTNE CHANGES SECTION 3.1, "REACTMTY CONTROL SYSTERSS " page 4 of 4 -
| |
| Discussion of Descripdon ITS SectR CTS Section Category Characterisahen Change LCO 3.1.6, " Control Bank Insetton tmuts" 3.1 L4 The time allowed for LCO 3.1.6 3.10.1.3 None Unque restonng control banks to Requred Acton vnthen inserbon limits when A.2 control banks are not vnthen Ismets was extended from one (1) hour to two (2) hours LCO 3.1.7, " Red Posdson indscation" 3.1 L6 Requirements were added LCO 3.1.7 Table 4.1-1, None Unsque for rod posstson indicahon items 9 and 10 which provide attemate achons forinoperable '
| |
| posson inecahon to the requrements for rod }.
| |
| insertion limits. j Catogertoe
| |
| : 1. Reinamon of Appbcebey IL Reinamon of Sunemence Frequency 111. LCO stated in tenns of Trasis rosier then components IV. Aw Outogo Time EdeneVA inun 24 hours to 72 hours V. Reimmhanof Requeed Achanctoeast am VI. Retamales of Sunodence W ecomptance creerie Vll. Reimaton of AAomed Oute0s Tune Vill. Deloton of Requsement ser 30 day Specul Report to NRC
| |
| - - + - - - - .. --1-1-*-:. ._. .
| |
| s..- m. . -.. .. ni 1-w-
| |
| ...g% 2-w... .. ...,,,.,a.
| |
| | |
| TABLE L - MATRIX OF LESS RESTRICTIVE CHANGES SECTION 3.2, " POWER DISTRIBUTION LittlTS" page 1 of 7 Discussion of Description ITS Section CTS Section Category Charactortsstion Charr2e LCO 3.2.1, " Heat Flux Hot Channel Factor" 3.2 L1 The requrements forthe LCO 3.2.1 3.10.2 I Unique with respect to heat flux hot channel factor Appbcatnhty appbcatuktydetals were w to apply only only to MODE 1 rather than all times as previously apphed 3.2 L2 The allowed time to reduce LCO 3.2.1 3.10.2.1.1 Vil Unsque with respect to the overpower and Requred Achon allowed outage time overtemperature aT A.2.3 extensson only.
| |
| setpoents when the heat flux hot channel factorlimit cannot be met was extended from 24 hours to 72 hours casecones ;
| |
| L R%of appecommmy l IL R% of Suneemnce Frequency sit LCO sieted in tonns of Trains father than compone$
| |
| IV. Aw Outage Tune Edenelon kom 24 hours to 72 hours V. R% of Regnared Actons VI. R% of Sunedence Regurement accagnance creeria Vit Relembon of Atowed Outsee Time VtN. Delston of Requremers for Y any Specimi Report to NRC l
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| | |
| TABLE L - MATRIX OF LESS RESTRICTIVE CHANGES SECTION 3.2, " POWER DISTRIBUTION LatelTS" page 2 of 7 Discussion or Description ITS Section CTS Section Category Characterization Change LCO 3.2.2, "priaar Enthalpy Rise hot Ctennel Fador" 3.2 L3 The requrements forthe LCO 3.2.2 3.10.2.1 i Unque with respect to heat flux hot channel factor ApphcatMisty appimatulity detais were Imted to apply only only to MODE 1 rather than aN tunes as previous >f apphed 3.2 L4 The .W to LCO 3.2.2 3 eu.2.1.1 11 Unque with respect to -
| |
| perform a survesidence to frequency dotads only verify the nuclearenthalpy rise hot channel fadoris withen limits after exceedmg by 10% the powerlevel at whch the heat flux hot channel factor j was last determened was .
| |
| deleted.
| |
| Categones L Reimaton er Applicatey
| |
| : 11. Reimaton er S memence Fmquency ill. LCO mested in tems er Trains ralhar Wien componeres IV. Asowed Outogra Time Ejdension fman 24 hours to 72 hours V. Reimmemn er Roguesd Actions VL R% or Surposence Regdromerit acceptance creene Vll. F.W or Asowed Outage Tone Vill. DeletonerR ; __ / for 30 day SpecialReport to NRC
| |
| , , , . . . . . , . . , . . . . . - . . ., -- ~ ,
| |
| . - - . _ = = - ,
| |
| | |
| .. . . . . t . . . . . .
| |
| 4 TABLE L - MATRIX OF LESS RESTRICTIVE CHANGES SECTION 3.2, " POWER DISTRIBUTION LIMITS" page 3 of 7 Discussion of Descr:ption ITS Section CTS Section Category Characteriza3on I Change 3.2 L5 Requirements to reduce LCO 3.2.2 3.10.2.1.1 V Uneque with respect to the uverpower and requered achons that overtemperature aT are deleted
| |
| ! setpoints if the nuclear enthalpy rise hot channel factoris not met within 24 hours were deleted.
| |
| LCO 3.2.3, " Axial Flux Difference (AFD) (PDC-3 Axial offset Control Methodology) 3.2 L6 A requerement was deleted LCO 3.2.3 3.10.2.7 V Urnque with respect to to reduce the high neutron required schons that flux setpoints to below are deleted 55% when accumulated penalty deviation time exceeds one (1) hour.
| |
| 1 categones
| |
| : t. n%ofAm II. Reimzahon of Survomance Frequency ill. LCO etated in terms of Trano rather than componeres IV. Agowed Odage Tkne Estensson from 24 hours to 72 hours V. Relaxahon of Requesd Achons VI. Relaxahon of Sunemance Requirement are=rdance creoria Vts. Relaxahon of Agowed Odage Time Vill Delebon of Requiremord for 30 day 9W Report to NRC I
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| _ _ . _ - _ m
| |
| | |
| I -
| |
| - TABLE L- MATRIX OF LESS RESTRICTIVE CHANGES SECTION 3.2, " POWER DISTRIBUTION LIGGITS" page 4 of 7 Discussion of Description ITS Sechon CTS Section Category Charactorkation Change 3.2 L7 An allowance was added LCO 3.2.3 3.2.3 None Uneque to pommt a total of 16. Applicatuidy hours of operabon to be accumulated with AFD outside of the target band without penalty deviation time dunng surveellance of the power rance channess 3.2 L8 A requwament to log AFD SR 3.2.3.2 3.10.2.10 11 Unique with fespect to evefy half houraRer the frequency dotads first 24 hours that the AFD mondoris out of service was relaxed to once within one (1) hour and evefy one (1) hourwhen themial poweris < 90% of rated thermal power or 0.9 Allowable Power Level wtucheveris less.
| |
| : 1. Reimatonof am_
| |
| : 11. . Reimahan of Sunemance Fsequency
| |
| : 15. LCO simind in terms of Tsaine regner man compenses IV. Aw Ouimen Time Emansion torn 24 hours so 72 hours V. Reimaton of Requesd Acelons VL Reimaton of Sunemence Requiremed acceplance creene Vit. Reimmbon of Asoned Outmos Time VM. Daisson of Requuement for 30 der Spedal Report so NRC -
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| l l
| |
| l l
| |
| | |
| ' TABLE L- RAATRIX OF LESS RESTRICTWE CHANGES SECTION 3.2, " POWER DISTRIBUTION LJRAITS" page 5 of 7_
| |
| Discussion of _- Descripdon ITS Secekm CTS Section Category Characterisation Change 3.2 L9 The requrement to LCO 3.2.3 3.10.2.1.1 11 Unique with respect to perform a survedlance to frequency dotads only deterrmne the AFD target flux deerence aner exceedmg by.10% the powerlevel at whch the heat flux hot channel factor was last detonaned was deleted l
| |
| l-F categones I
| |
| L Reimatonof AppecstGEy N. Reinemen or Surwomance F#equency M. LCO stated in tenne of Trelne romer than componeMs IV. W Outage Tkne Edenelon tem N haws to 72 hows
| |
| : v. Rotenhan er Requead Adlone VI. Retmohon af Survesence Reghumed ecceptance aterte vH. R%of AmonedOutageTone vs. omisten er Regwement hr 30 der Specisi Repet to NRC
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| | |
| TABLE L- MATRIX OF LESS RESTRICTIVE CHANGES SECTION 3.2, " POWER DISTRIBUTION LIMITS" page 6 of 7 Discussion of Descriphon ITS Section CTS Secten C_t;-:-ey Characterization {
| |
| Change I l
| |
| LCO 3.2.4, " Quadrant Power Tdt R .tio" 3.2 L10 Requirements for quadrant LCO 3.2.4 3.10.3.1 I Uneque with respect to power tilt ratio (QPTR) Applecatality appiscabehty dotads were relaxed to apply only only to MODE 1 with thermal power above 50% rated thermal power to not include powerincreases below 50% rated thermal power 3.2 L11 A requirement was deleted LCO 3.2.4 3.10.3.1 V Uneque with respect to to reduce the high neutmn required achons tint flux setpoents to two are deleted percent of rated Values for every percent ofindicated ,
| |
| power tilt ratio exceeding j !
| |
| 1.0 when QPTR exceeds 1.02.
| |
| l I
| |
| ca!egones L Reismation of Appicabety.
| |
| I!. Relaxatum of Surveennce Frequency ill. LCo stated h terms of Trains rather tien campanaris IV. Abowed Outage Time E;eeneian from 24 hours to 72 hows V. Relamamon of Requred Achons VI. Relemahan c4 Survedunce Requiremord are=re anos creerte Vll. Rh=8=wn of Asowed Oidage Tune Vill. Delsbon of Requrement for 30 der Special Report to NRC
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| | |
| m TABLE L - MATRIX OF LESS RESTRICTWE CHANGES SECTION 3.2. " POWER DISTRBUTION LaRIITS" page 7 of 7 Discussion of Description iTS Section CTS Section Category Charactertantion Chane.
| |
| 3.2 L12 Requrements were LCO 3.2.4 3.10.3.1 V Unique with respect to relaxed to permd contwiced requesd actions tis; operahon above 50% rated are deleted thermal powerwith QPTR -
| |
| in excess oflimes for greater than 24 hours. A req:mroment to reduce the high neutmn flux setpoints to 55% rated thermal powerif QPTR remains in excess ofImts for greater than 24 hours was deleted.
| |
| 3.2 L13 Requrements were LCO 3.2.4 3.10.3 2 V Uneque with respect to deleted that were 3.10.3.3 required acasons tuut associated with the are deleted conddson that QPTR is greater than 1.09 .
| |
| simultaneous'with a rN*W fod.
| |
| caegones
| |
| : l. Reimmhanof am
| |
| : 11. R% of Swwesence Frogsency IIL LCO stated in tenns of Trans romer men components N. Aammed Oudege Time Edenelon spem 24 hours to 72 hows V. Reimahonof Requesd Achens VI. Reimmhan of Surweennce Requiresnard neceptance creerte VII Reimmhanof AsmusedOutageTens Vill. Doeshan of Requirement for 30 eley Special Report to NRC
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| | |
| TABLE L - REATRIX OF LESS RESTRICTIVE CHANGES SECTION 3.3,"INSTRURAENTATION" page 1 of 30 Discussion of Description ITS Section CTS Section Category Characterization Chance LCO 3.3.1, T,ontanment" 3.3 L1 Allowable values have LCO 3.3.1 2.3.1.2 None Unque Table 3.3.1-1, been speedied for trip setpoents in accordance Funchons 5 and 6 with the hconsee setpoint "
| |
| methodology procedure.
| |
| The allowable values for the overtemperature and overpressure 4T setponts are less restnchve 3.3 L2 An instrument tolerance of Table 3.3.1-1, 2.3.1.2 None Unque i10% was added to the Funchons5and8 time constants for the .,
| |
| overtemperature and overpressure aT setponts.
| |
| Inequakey segns were added for parameters in the overtemperature and overpressure 4T =a8aamts I
| |
| f'
| |
| * I. l; L Relaushan of Appecalday IL Raimusemn of Suneannce Fsequency let LCO samlad in tonne of Trains rumor than camponents N. Aw Oidage Time Edension turn 24 hours to 72 hours V. Rolauahon of Required Acelons toeast Apptcatuny VI. - RW of Survemance Requuement acceptance cuenne vil Reimmahonof hOndagsTime Vill. Deleton of Resparemert for 30 day Spedal Report to NRC
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| | |
| TABLE L- MATRIX OF LESS RESTRICTIVE CHANGES SECTION 3.3,"INSTRUMENTATsON" page 2 of 30 Discusski of Description ITS Section CTS Section Category Characterisellen Change 3.3 L3 The allowed time to place LCO 3.3.1 Table 3.5-2 Vil Allowed Outage Tune a channelinto tepped Required Achon E ACTION 6 Extension imm 1 hour condebon was extended to 6 hours, from one (1) hour to six (6) hours in accofdance with WCAP 10271-P-A.
| |
| l 6
| |
| I f
| |
| ca - e L Rahmatonof am.
| |
| N. R% of Surteennon Frepancy
| |
| ' IIL . LCO stated h terms of Trains rafier than componards .
| |
| N. Agamed Ousage Tune Em from 24 hours to 72 hows V. Reimummon of Requesd Adians to est Apptcabety VL Reimaton of Suneennee Requsement @ oressis Vil Reimmeonof AtomedOttageTime ~
| |
| VNL- Delston of Requremord for 30 day Spadet Report to NRC i
| |
| ~ ' ' ' ~ ~ ~ ' ' ~ ~ ~ ~
| |
| - ' ' -- --- - ---- - -~ ~-- - - ' - ~ - ~ - ~ ~ - ~ ~ ' ~ ' " - ' " ' " -" ~ ~ ~ ~ ~ ~ ~ ~~
| |
| - - - - - - - - - = - -
| |
| | |
| TABLE L- MATRIX OF LESS RESTRICTIVE CHANGES SECTION 3.3,"SISTRUMENTATION" page 3 of 30 Discussion of ' Doocription ITS Section CTS Section Category Characterisation change 3.3 L4 The allowed time to place LCO 3.3.1 Table 3.5-2 V, Vil A50wed Outage Tune a channelinto inpped Requred Achons leem 14 Extensson from 1 hour conddKm was extended M,N P ACTION 7 to 6 hours, reimmasson from one (1) hour to six (6) Funchon 11 ofJhutdown hours in accordance with requwement
| |
| (
| |
| WCAP 10271-P-A. The shutdown requwement for when a channel cannot be ,
| |
| placed in trip as required was relaxed to requwe only -
| |
| that reactor power be reduced to below the P-7 intedock wdhen 12 hours, rather than to be in MODE 3 in 8 hours.
| |
| 3.3 L5 Mode appbcabilty for LCO 3.3.1 Table 3.5-2 I Uneque with respect to i certam reactor trip Table 3.3.1-1 Notes ~* and applicabdity dotads l functions were relaxed to Notes (h) and (f) only !
| |
| requere the functions only l 5 above the P-7 interlock ,
| |
| cassemtes .
| |
| L Reimmelon or Appicahmy. ,
| |
| M. Reinamon or Swwumance F#equency Ill. LCO semesd in tunne or Traine sadher Stan conpanenH i IV. Aw Odage Time Leansion tem 24 hnurs to 711e=
| |
| * V. R% or Requesd Adone to ed AM VI. Reimmhan or Sunmemnos Requimment W creeria Vu. Reimmemnor aw ouenos Time Vill. Delston or Requeomere for 30 day Spedal Repost to NRC
| |
| = _ _ _
| |
| | |
| TAEM.E L-eEATIWK OF LESS NC CHANGES ~
| |
| SECTION 3.3, NATIO0r" page 4 et30 osacessenen er Descripeten IT s s eceien cts session category -
| |
| Chenee 3.3 L6 . The amoumed time foran LCO 3.3.1 Tahis3 52 VII ! eonedOutageTame A
| |
| inoperatde snenuelreactor Roquesd Acton B ACTION 1 Endonmon toen 12 trip suncaen was esdended hours to as hours, from 12 hours to 48 hours assumed sNedown tinus and tie time to be in Essensson Sposa 20 heODE3 essended from 20 hours to 54 haurs hours to 54 hours.
| |
| 3.3 L7 The requirement to LCO 3.3.1 Table 352 None Unsque snonnor Quadrant Pomer Requesd Acton ACTION 2 Tdt Rato (QPTR) overy 12 D.2.2 hours wth one encore channel anoperatde is reimmed to sequee ,
| |
| - rnandonng only when Sie diennelinput to QPTR is inoperatdo cassess t naammaarerappacenser
| |
| : u. naammann er sisweennes Fsessmuy at Lco samens e annus er Tsums sumer mai semosames IV. Asmuse Ouence Then Benneen tene 24 temus as 72 hauss
| |
| : v. naammen er am,mme Assens to es mysecamar vi. nesmenen er senweennes nessamme e cseems vit meimamener - ouemenTmme VM. Delamen er negsenusW tur 31 day Speedal nepet to folC
| |
| | |
| TAEK.E L-IIATfuK OF LESS fESTNCTNE CHANGES SECTION 3.3, WTMmENTATION" page 5 of 30 Diocessaion of Doocription ITS Section CTS Sostion Category Cherastosteetion Change __
| |
| 3.3 L8 The agowed time to piece LCO 3.3.1 Table 3.5-2 VII and Amoemd Outage Tone a diennelinto inpped Requesd Acton E . ACTION 2 eirvanston of Extension imm 1 hour condshon was eatended. requosment to 6 hours,and unsque from one (1) hourto six (6) initi seeped to hours in accordance with essenenen of WCAP 10271-P-A. A requeensent requemment to reduce thermal power to s 85%
| |
| rated thermalpowerwhen one channelis inoperable D
| |
| was elimeneted Categmus L maimmann er Aggeconsay L notanton er Surwaammee Fsequency ut LCO atuted in tunns er Tsesus seger Wien coniponeses IV Asomed Outage Tbne Osanamn tenut 24 haws to 72 tunes
| |
| : v. nasamme- w negused Aceans to em Ass ecumsay vt nusammen er semamanne noemenium e cremna vu. neemuten erAsamed Ondays rame -
| |
| VIIL Desumen er negimenised ler M day Spor 4 nepest to 9sRC
| |
| | |
| TABLE L-IRATfuKOFLESSIESTIWCTWECHAsdGES SECTION 3.3, NATIDIf' page 6 of 30 Discussion of P:.ecription ITS Section CTS Secelen Catogery Chm Change 3.3 L9 The requirements for two LCO 3.3.1 3.10.5 None Unugue snoperable intermediate Requred Achon G range neutron aux :
| |
| channels were relemed to requwe only that reactor power be reduced to below the F- d interlockwelhen two (2) hours and to suspend ,
| |
| operamons twohne posswe roeceuty addeons, ralhar then to be in MODE 3 in 8 hours L Rateaten er AppecebMy ,
| |
| E. Reimagen of Sestemance Fsequency IE. LCO etmand h tenns of Tsuins sueur men eesponses rV. Asmund Otomos Tone Esemnaien Issue 24 hows to 72 hauss
| |
| ' V. Reimaten of Regndsed Assues to se Apptendumy vt Rasmesma er suneennes Reesamune esempennce momen vE. Rosummen et Assued Outmos rene vie. Deenman of Requaesment sur 30 esmy Spechd Repest to NRC
| |
| | |
| - TABLE L- etat 3EK OF LESS fESTIWCTWE CHANGES SECTION 3.3, NATION" page 7of 30 rheaan anaa of Descripelen ITS Session CTS Section Category Characterisselon Change 3.3 L10 The asowed time to piece LCO 3.3.1 Table 3.5-2 V, VII Asowed Outage Tane a channelintoinpped Table 2.3.1-1 leems 7,9,10 Estensson groen 1 hour condshon was exionded Funcerons 2a,8,9, 13 to 6 hours, seimmaton from one (1)hourno six @) 12 of shutdown hours in accontence udh sequsentent WCAP 10271-P-A. The s>% requwement for vehen a channel cannot be placed in trip as requered was reiemed to requwe only that reactor power be reduced to below the P-7 interlock westen 12 hours, ratuur tien to be in MODE 3 in 8 hours em L m erAppacemany
| |
| : a. Rasemmen ersaneamnes Fsequency ut. LCO samese in tenus er Tsume susher man e IV. Aasmed Oidags Tsne Essension tosn 24 hense to 72 hems .
| |
| : v. numaman er negumes Aceans en om Appecumany vs. nessamen er summannae neemumme e manns vu. nanusman ermesmes oimmesTene
| |
| : vut. osammen er asememme sur ao emy spesas napest to senc
| |
| -....--...-------.-6,. . ~ . . . , . . . . . . . . - . . - - - - J . - .. - - - - - . . - - - - - - - - - - .. .
| |
| . .ii- . . . - :. . . . . .. .
| |
| g______
| |
| | |
| TAEKE L- 00ATIWK OF LESS IESTIWCTIVE CHANGES SECTION 3.3,"9fSTIWJW38TATION" page 8 of 30 name.m go - Desorgpeien ITS Secelan CTS Semelen Coengery Chesamterimetion Change 3.3 L11 The asowed time to piece LCO 3.3.1 Tatdo 3.5-2 V VII Answed Ouenge Tone a channelinto inpped Table 3.3.1-1 Item 11 Extensson front 1 hour condenen was entended Function 15 to 6 hours,seimmation from one (1) hourto sist(6) ofshutdown hoursin accontence wth requeentent WCAP 10271-P-A. The shutdown E-- ; n e for when a channelcannot be placed in trip as required was ressmed to requwe only Nunt reactorpowerbe reduced to below the P-7 intestock wdhun 10 hours, th WINI to be El M 3 in 8 hours cessgenes L Reimsten er Appeasemy
| |
| : u. neemmien erseveaunes Fugency NL LCO semand he tunne d Tsess seenr enan osayenses N. Aemmed Ondage Thue Beunmen tuun 24 homes to 72 heems '
| |
| y Renamen er asemed Assens to est Assecamer VL , Reimmhan er SnowsAnnes RepsemeW ecceptune esemen WW. Reimmhan er Assued Ondmo6 Tone VM. Duluten er flegmemed ter Elemy Sposauf flepost to letc
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| | |
| TABLE L- RAATRIX OF LESS RESTRICTfWE CHANGES SECTION 3.3,"W8STRUGRENTATION" page 9 of 30 rme..musani er t - 4 l c. - ITS Section CTS Secesen Category Clearacterismeien Change 3.3 L12 The requwements for LCO 3.3.1 Table 3.5-2 I Ureque wies respect to underfrequency and Table 3.3.1-1 Items 13 and M details undervoltage trips have Funchons 11 and 14 been reiamed to apply only 12 to A4 ODE 1, raeter than reactor cnbcal, as was Previously requred. __
| |
| 3.3 L14 The frequency of LCO 3.3.1 Table 4.1-1 B CUga witi respect to surweinance requrements Table 3.3.1-1 Items 1,4 } Nr. Aance frequency for the ruarinar power Funchons 2a,5, &
| |
| l range and reactor coolant and 6 temperature trip funchons SR 3.3.1.7 were reiamed from bi- SR 3.3.1.8
| |
| . weeldy to 92 days ~wn accordance wist WCAP 10271-P-A.
| |
| Cassonnue L h or Appetet2r N. Roemanon er Survesence Fseesency W. LCO seated h tunns or Tsees susher sun componeres IV. Aw Odeos Tone EAnnesen tean 24 heiss to 72 homas
| |
| : v. Reemahan er Roemed AcAnns to ed W VL Reimmhan er Suneennes Roomunese acceptmes creene vu. Resammen er Asened owage rene vs. Dusseen er Rospssenient ser 30 day Specar Report to MRC
| |
| | |
| TABLE L- RIATRIX OF IESS RESTRIC . , (2VJ E3 SECTION 3.3,"1pr3TRURIENTATKm: page 10of 30 the====% of C:: 'fl:-i ITS Section CTS Section Category Clearacteriaalmon Change 3.3 L15 The frequency of LCO 3.3.1 Table 4.1-1 il Ureque wilh respecito survedance requwements Table 3.3.1-1 Items 2,3 surveitance frequency as it applies to reactor Functons 3 and 4 startup for the naw4==r SR 3.3.1.7 intermediate range and SR 3.3.1.8 source range were reiamed from requang the survedance to be performed wnthwi 77 days prior to startup to wenn 92 days prior to startup in accordance with WCAP 10271-P-A.
| |
| Canganes L Reisenhen or App 6cahWy B. Redemahan erSunemance Fsegsancy ut. LCO stated in tunns or Trane susher than carmponents IV. W Oidnem Tirne Emanmien tent 24 hours to 72 haws V. Reimmhon er Resparert Actans to and Appheshaly VL Rehmmhan or Sunusunce Rotweniere amagegnoe cremna VM. Raimunhan or h OiduceTene -
| |
| VIIL Delskon or Regameniere lur M dmy Specomi Report to peRC l
| |
| 1
| |
| | |
| TABLE L-ISATNX OF LESS fESTNCTWE CHANGES SECTION 3.3, NATIOfr* page 11 of 30 re t e Descripelen iTs seceien cts session Caeogery W Chans.
| |
| 3.3 L16 The ;iw.sy of LCO 3.3.1 Table 4.1-1 N Unnlue wist nopect to surveigene requwements Table 3.3.1-1 learns 5,6,7,8 surweiBance troquency forthe reactorcootent Funciens 9,8,7, 11,3g,40 Sow, pressunter pressure, 11,13, and 14 Reacsor Coolant Pump (RCP) voltage, steem generaeorlevel, steamseedwesernow mesmeldt, and low steem generatorlevelfuncmons were ruiemed from moneMy to 92 days in accontence wish WCAP 10271-P-A.
| |
| , 3.3 L17, The frequency of LCO 3.3.1 Table 4.1-1 N Unsque wiWi seeped to survedence requrements Table 3.3.1-1 leem 25 surveigenos frespaancy forthe turtune first stage Funcemn 17e -
| |
| pressure fundson was relemed from monINy to 18 i i months cassomus L maammann er Appecuemy.
| |
| N. netmeten er Sunemones Fempsmecy M. ' LM stated in tensus er Temene seger sesi componesse IV. Asemed Ondese Times EJeanense been 24 Inows to 72 Itenes
| |
| : v. naammmen er naapses Assono seas Appacemmay vt naamaman er sunemones negutement accupamine esamia vit. metschen er Atomed Ondose Tees vilt. Desseen er naqueenuest for 3D day Spammi flapest to SetC
| |
| | |
| TABLE L-IIATIWX OF LESS RESTIWCTWE CHANGES SECTION 3.3,"BASTRUIENTATION" page 12of 30 Discussion of - Description ITS Secuen CTS Section Category Cherasterimetion Change 3.3 L ' ' ' The frequency of LCO 3.3.1 Table 4.1-1 N Unuque wish respect to survedence requwements SR 3.3.1.5 leem 27 -
| |
| survesence foractuohon logic teshng frequency. See LCO were reismed from monthly 3.3.2 L18. Sin wits to 31 days on a staggered . L19 test bases 3.3 L19 The frequency of LCO 3.3.1 Table 4.1-1 N Ureque wiIh respect to survesence requwements SR 3.3.1.4 Item 30 surveimonce forreactortrip tweaker t , - x , Bin weh teshng were relemed from L18 monthly to 31 days on a F_ J test basis.
| |
| 3.3 L20 The frequency of LCO 3.3.1 -
| |
| Table 4.1-1 N ._ Unugue wilh sospect to survedence requwements SR 3.3.1.4 - leem 47 surveigence forreactortrip bypass esquency. Bin weh .
| |
| tweakerlessing were . L18 relemed frorn monthly to 31 6 days on a staggered test boms -
| |
| cassonnes L Rahmahan er Appicebey
| |
| : u. notammenerswweisano Feewancy
| |
| : 31. LCO samlad h teens er Tseks saour sima conspenses
| |
| ' IV. Acoused Osaames Tene Esaanmaan tone 24 hows to 72 heiss
| |
| - V. Rehmaken er Regused Ateens to ese Appecately
| |
| " vi. nessamen er sweemence newmenism e emens vu. nesmusen er Asamed Oiamen Teme vs. osammen er negususene ser so emy speam napset to senc
| |
| ^- x-
| |
| | |
| TABLE L - RIATRIX OF LESS RESTIUCTIVE CHANGES SECTION 3.3,"9fSTNATION" page 13 of 30 Discussion of Description ITS Section CTS Section Category CInaractortsatsen Change 3.3 L35 Appicatihtywas reduced Table 3.3.3-1 Note Tatne 3.5-2 I unuque witirespect to in MODES 3,4 and 5 for a Note O reduced Appimatuity.
| |
| rnanual reactor trip, source range neutron flux, reactor trip tweakers, reactor trip tweaker UV and shunt trip mechanom and automate trip 100c-3.3 L36 Reqused Acton was LCO 3.3.1 Tatne 3.5-2 None Unuque wilh respect to reiemed to pommt emeng Requesd Acaen F ACTION 3 seducemnin Requesd m
| |
| 3 Appimatnhly byincrossmo power to a P-10 setpoent.
| |
| 3.3 L37 CompletonTune was LCO 3.3.1 N/A VII Unuque with sospect to reiamed by adoping Requwed Acton O increened Completon Requwed Acten pomuskng Tune.
| |
| 6 hours to restore channel where no th time w eS DreV " '*h M . ! ,
| |
| censomms L HeimatenerAppetsemy N. Reimaton er Seneennos Feuemacy El LCO semand bitunns er Tsumes sulher man componeses IV. Aassed Ondmgo Tune Essenmien tune 24 Iisass to 72 heiss V. Ralmaton or Regned Assens to av Appece*ier ^
| |
| vt neemaman er sineennes noemement acompennom amans vu. naam umen erAssmed Oiemps Ttme vus. Desmann or negumenise sur 30 day Speami Rupat to MRC O
| |
| | |
| TABLE L- ABATfuK OF LE.SS fESTfuCT1WE CHANGES SECTION 3.3," Bet >TIEIRENTATION" page 14 of 30 Discussion of Doocription ITS Section CTS Section Cotegery N Change 3.3 L38 Requwod Acton was LCO 3.3.1 Tatdo 3.5-2 V Unuque weet reepect to relemed to pomut two Roquesd Acton H ACTION 3 Vil Apptcetsitty. -
| |
| Neutron thatintonnodiste range channels inoperable when below the P-6 seepoent.
| |
| 3.3 L39 SR frequency was reissed SR 3.3.1.11 Tatde 4.1-1 It Unuque wies suspect to to eisrunele montily item 1 T.:; x.
| |
| caldershon for Nudeer Power range citannels.
| |
| 3.3 L40 SR frequencies were SR 3.3.1.2 Table 4.1-1 11 Unuque witi respect to rehosed to pernut deisysng SR 3.3.1.3 Items 1,3, & 4 T.- ; - z .
| |
| perfonnance of cortesi SR 3.3.1.6 SRs unt5 a W SR 3.3.1.7 interval after achsevang specmed unit condsons cansemas.
| |
| L Retsudsen af M N. Reemmemn af Sumeannon Fsegasuy Nt. LCO semand in tunns et Tempus suseer een P N. Assued Oidage Ttne Essensten som 24 punsa to 72 haass
| |
| : v. Raimanen er nessed Aseene to est Appecumser VL Reimahan et Summemnoe Magdsamassa P csemus VII. Reimaten af Assmed Ouence Tasse VNI. Duiseen af Rogssessued Ier 3D day spesse Reyest to toiC
| |
| . . . . . . - . . . . . . . .-i.-....-.-- _ . .
| |
| --i.-...-.----.,__..........._m , . - - - . . . . . . . . . .
| |
| . ..,.__..tri .
| |
| | |
| ~
| |
| i TABLE L- ABATIWK OF LESS IESTIWCTIVE CHANGES SECTION 3.3,"9ASTRUIRENTATION" page 15 of 30 Discussion of Doocription ITS Section CTS Secean Category Cherasterimetion Change 3.3 L41 Survedlance requusments SR 3.3.1.11 Table 4.1-1 None Unupse wilh respect to are reisted byeachmeno noms 1,2. 3 sR scope.
| |
| neueron ma-ream som ceEarabon t
| |
| i, l
| |
| 4 1
| |
| Cahganse L Rubuseen d ApptoshWF
| |
| : s. MessmendsunemanosFsepanor -
| |
| K LCO reemd in tunne of Tsesse somer een consenesen .
| |
| W. ' Assue.? Outmas Tsus Esannoun eusn 24 heise to 72 heiss
| |
| : v. Reemsben at Reemed amans to em Appassessy WL ftstumbum W Sisweennes Rogs unged P estuna Vet Retmuman af Aasmod Oneuse Tsue WE C Wehen d Respmenient ter M day Speed Repest to 954C
| |
| | |
| t c f
| |
| TABLE L- RSATRIK OF LESS RESTIWCTWE CHAN.MES SECTION 3.3,"DISTRUMENTATION" page 16of 30
| |
| - et peecrepelen ITs seceien cts session casseery charassers; amen Channe LCO 3.3.2 "ESFAS Instrumentshon" 3.3 L13 r ; _. e for LCO 3.3.2 Tahis 3.5-4 Vil Unupse witi sospect to automaticactuelenlogic Table 3.3.2-1 asowed outage time and actuaten relays for tie Funcemns 1.b,2.b. desags i- O.y.- - M Safety 3.a(2), 3.b(2),4.b.
| |
| Features Actuaten System and5.a l
| |
| were added,which ancdude Requesd Actons C agowed outage hmes and G which were not c.it permitted.
| |
| 3.3 L18 The frequency of LCO 3.3.2 Table 4.1-1 II Unsque wist respect to survedana serparements SR 3.3.2.2 leem 27 survemana foraccuseenlogicteshng frequency,See LCO 3.3.1 L18 were rehused from montdy to 31 days on a staggered test bases i
| |
| 1 Campens L nesmanenerM
| |
| : m. - neemmemn er s<w %
| |
| NL LCO samend in tonna er Tsahs sueur% canyonoms W. Aessed Ommen Tlnus FJdERee3n DEIn 24 hows to 72 homas
| |
| : v. Raimunen er negused Aegens to es Appausesy vi.- neemamen er saneannae nemmemme anospennae aamu vu. naamanener Assued OwnesTheo vu. osamen er noememme sur so emy sysness napest to seic
| |
| | |
| TABLE L- MATUWK OF LESS fESTUWCTlWE CHANGES SECTh3N 3.3, NATIDIT' page 17et30 h of Description ITS Section CTS Scollon Cuengary Chasestestemden Change 3.3 L21 The abouped time foran LCO 3.3.2 Tatdo 3.5-3 Vil Unugue wise sospect to inoperalde c5annelto Reqused Achons ACTION 12 aboused outage sinne rememin #seinpped C, D, E, and G slutets condeson was reissed imm Wie survoiBance frequency intervalto conemuous operaten. The ascused time to piece a channel into inpped condshon was esdended from one (1) hourto sin (6) hours in accontance wist WCAP 10271-P-A.
| |
| - 3.3 L42 Applicabdity forsteem line LCO 3.3.2-1 Note e Tatdo 3.5-4 i Reduced applicatuTdy isoisten funchons was Funchons 2A, shse to pombon of reduced to auctude when 2B,2C&2D =** equgument AASIVs are teamarf Bin wid L43, L46 and L49.
| |
| caemus L NelemmeafAM.
| |
| m.- nessuten etsenesunne Fsequeuy MI. LCO essend in tusne of Tsens suster een esseenants IV. AEmused Oedmes Tinue Estenman teen 24 hueso to 728tes.
| |
| V. nelmaken of Reeshed Asemos toes Appenster vt naammen et seneshamem nee amed P cuente Vit. netmunen et Amazed Onames Tese WW. Delmaan of naquessest for 5 day Spectui ftspost to letC k
| |
| | |
| TABLE L-MATiuKOFLESSfESTIWCTWECHANGES SECTION 3.3,"DISTIENNENTATIOff' page is of 30 thecussion et Deeceipeien ITs seamen cts secten cesseory Chesamenstmedan channe 3.3 L43 Applicabihty for feedwater Table 3.3.2-1 Note 3.0 i Reduced appEcateer isolahon functons was f due to poseen of Mar ==8 to endude when actuated eququnent MFIVs WRVs and bypass Bin witt L4A L46 and valves are closed or L49.
| |
| escisted tra a dosed ,
| |
| manualvawe i
| |
| i L asemaman erm
| |
| : s. nasammen et senemance Fsequency
| |
| : m. Lco sensus mi tanno er Tains scher man eenysnmes
| |
| : w. Ansmed ouence Thn. Edensen been 24 hows to 72 heess
| |
| : v. neemamen or neemos Acmens se met Appecenasy -
| |
| vt' nessmeen or seamance neemunem accapannes eranno vu. nelmaten of Asamed Ondage Ttne vet ossenen or neipmanism ser ao serspades nepet to NRC
| |
| | |
| TABLE L- RSATNX OF LESS RESTNCTWE CHANGES .
| |
| SECTION 3.3, NATION" page 19of 30 Discussion of Description iTS Section CTS Section Cologery Choraetorisselon Change 3.3 L50 Requirements relemed to LCO 3.3.2 NfA None Unegue wipi respect to l
| |
| pomut all channels of a Recured Actions Action relematon.
| |
| ESFAS instrument funcison Note 2 ora single ESFAS anstrumentation train (except for manuel Actuaten functons) to be inoperable for meentenance or survestance testing for up to 12 hours
| |
| +
| |
| Celegenes L' natussen af Appscatmy R. ' naimagen d Survemmico Fse,sency Hl. - LCO samtad in tenus of Tnimis semier sinn canyonsee W. . Assued Oiange Tinie Emansion teen 24 hains to 72 hours
| |
| : v. nameusen er me,med Aseens to ens Appecenser vs. neemunen at senemsnee nogmesnam acceptenos eseems vu. Reemamen et Assued amassa Ttne
| |
| - vue. Demeen at me,menemm sur ao esy spores napen en NRC j l
| |
| | |
| TABLE L 4 MATRIX OF LESS RESTRICTIVE CHANGES SECTION 3.3,"NdSTRUMENTATION" page 20 of 30 n=ea=% of Deecription ITS Section CTS Section Catogery CIneractestselsen Channe LCO 3.3.3, " Post Amdarit Morntonno (PAM) instrumentaten" 3.3 L22 The agowed time for an - LCO 3.3.3 Table 3.5-5 VII Unuque wisi respect to moperable contanment Table 3.3.3-1 agowed outage time high range rachsten Funcemn 10 raonitanno channelwas extended from 7 days to 30 days.
| |
| j 3.3 L23 The agowed time foran LCO 3.3.3 Table 3.5-5 Vil Unuque with resped to inoperable aimahary Table 3.3.3-1 Note 1 abound outage tunes feedweser(AFW) flow Funchon 19 only, Bin with L22 irm channelwas extended from 7 days to 30 days.
| |
| 4-Categostas L Raimaton et Appecamely.
| |
| E. Retudon of Surweemnce Fsupsoncy IIL LCO stated in tunns of Tramus rather than componeses IV. AAmmed Oiempo Time Emannoian tesa 24 hense to 72 hours V. Reimmenn of W Actons to ess Appecaheir vL Rahmamen et suneennes Regusemese e esende vu. Reineman of AAmmed Oidage Thus yet m at Requsammes sur 30 emy speans Repen no NRC
| |
| .. . . .- .-- .\
| |
| | |
| TABLE L-IAATIWK OF LESS RESTIWCTIVE CHMIGES SECTION 3.3,"DISTRUIENTATION" page 21 of 30 Deecueedon of Description iTS Section CTS Section Category Cherasteriseelen Change 3.3 L24 The requwements for both LCO 3.3.3 Table 3.5-5 V Unsque wien reaped to inoperable containmord Reqused Achon E Note 6 requusd schons only hydrogen anondonng channels were renamed to requre only east MODE 4 be reached within 6 hours, ralhar than MOOE 5 within 36 hours as was pneviously regured 3.3 L25 The agowed time foran LCO 3.3.3 Table 3.5-5 VII Unsque wies respect to Ntoperable thermocouple Requred Actions A Note 8 aeoused outage air se, ,
| |
| channelwas extended andB unsque wiGi respect to '
| |
| from 7 days to 30 days. K removalof shuldemn the channel cannot be requsement restored as equired, requrements were reissed to requwe only a speaal 6 report to the NRC, ralhor than to shut down the reactor ,
| |
| r L netsamenerApytcamehr
| |
| : u. nesmanen er seawamance Fagsamy NL LCO seded h tenne er Tsuine sumer men companwee tv. Asemed Osmos Times Essensen tem 24 hows to 721eeers
| |
| : v. naimamaner noemed Assenetoest e VL netmanen er suvemence nuemumana e amene VIL maimmten er AAssad Ondage Thus vut Dataman er negsament ser 30 ders paced napse to func h
| |
| | |
| TABLE L- MATRIX OF LESS RESTRICTIVE CHANGES SECTION 3.3," INSTRUMENTATION" page 22of 30 Discussion of Description ITS Section CTS Section Category Characterisation Change 3.3 L26 The aliowed time for an LCO 3.3.3 Table 3.5-5 VII U.% with respect to anoperable :heiri ccouple Table 3.3.3-1 Note 8 a50wed outage time channelwas extended Funchons 15-18 detals frorn 48 hours to 7 days.
| |
| 3.3 L27 A refuehng interval test LCO 3.3.3 Table 4.1-1 None Unuque.
| |
| requrement for pressunzer noms 35, as, Power Operated Relief 37 Valve (PORV) pcsition andcahon, block valve posdson indcahon, and safety valve possbon andscahon was relaxed was eimnated.
| |
| L Reimmhanof M IL Reimmhon of Sunatence Frequency 111. Lc0 sensed in terms of Trans ramer em connponents IV. Aw Outage Tkne EJeansion Imm 24 hours to 72 hows V. Reimmhan of Requesd Achens to out Appicatulty VI. Reimmhan of S:.neemnce Respmemmet ecomptance creene VM. Reimmeon of W Ondugo Tene VIIL Delukon of Requeemora for 30 der Specist Report to NRC l
| |
| i I
| |
| | |
| (
| |
| TAEKE L- MATIWX OF t Filts IESTIWCTNE CHANGES SECTION 3.3,"WGSTRURIENTATION" page 23 of 30 i
| |
| Descussion of Description ITS Secesen CTS Section Catsgery CInesentertmemen Change 3.3 L44 E+; -.. C tuvo PAM -
| |
| LCO 3.3.3 Tame 3.5-5 VII Unegue wieuespect to channels inoperatde : vers Requi.ed Acton H Note 5 Rossumed Actons.
| |
| relaxed to elorunste shutdoien requwements when innseen of attemetwo mondonngis not estetdished wdhin 7 ders.
| |
| Table 3.3.2-1 Tatdo 3.5 4 I Uneque mist respect to 3.3 L49 MM for sie learn 2.c requesd accons. Bin steem line isoleton- Funcson 4.c contenment pressure- witiL42 L43 and L46.
| |
| hegh-tugh function were -
| |
| relaxed to exclude MODE
| |
| - 3 when a5 MSIVs are ,
| |
| r4nearf and to eescith MODE 4.
| |
| i' Catagenes L nahummen erM E. neteneen erSesweennos Fsegsency ut. LCO stated ti tunne er Tsues sesser sun omnquenmes W. As.med Outues inne Emunsden tuna 24 hense to 72 samass
| |
| : v. . naamsemier negused Assens se em Appmummy vi. Rosemaaners+=-t anospamnoeesemen vu. neusseener Assued Oienen 7tne vet. osammen er neipmemme ser 30 my syssem napest es este
| |
| | |
| li TABLE L - MATRIX OF LESS RESTRICTIVE CHANGES SECTION 3.3," INSTRUMENTATION" page 24 of 30 Discussion of Doocription ITS Section CTS Sectson Category Characterisation Change LCO 3.3.4
| |
| * Remote Shutdown System" None LCO 3.3.5,
| |
| * LOP DG Start instrumentataon" 3.3 L28 Requrerrents for Diesel LCO 3.3.5 Table 3.5-3 V. VII Reduchon in Requred Generator (DG) start Requred Achons A Funcbonal Unit Achons by antenng ristrumentabon were and D 3.a ACTION 14 Condskon and relaxed by allovnng entry Requred Achon -
| |
| into the requred achons supported equiptrant.
| |
| for the DG made Bin with L29.
| |
| inoperable ~r tstead of requenng the unit to be shut dowrt AN allowed outage time of one (1)was permetted to restore one or more anOperable channels.
| |
| cenegones L Reinambon or AppBcetimy N. Reimeston er Swwesence F#equency M. LCO casted h terms or Trams reshor men cargonento N. Asowed Oidson Tune Emensam emon 24 hows to 72 hows V. ReematonorRequesd Achanstoed AM vt Reimmhan or Swwesence Regwamart P creens vu. Reemmean erww outage Tkne VItt. Deleton er r Sur 30 day Specul Report to NRC t l l l l
| |
| | |
| TAEKE L- MATRIX OF LESS RESTRBCTIVE CHANGES SECTION 3.3 " INSTRUMENTATION" page 25of 30 Discussion of Descnption ITS Section CTS Section Category Charactensation Change ~
| |
| 3.3 L29 The allowed outage time LCO 3.3.5 Table 3.5-3 V VII Reduchon in E; --M for an inoperable degraded Requwed Achons B Funchonal Unit Achons by entenng voltage channel to be and D 38 ACTION 14 Condihon and placed in trip was relaxed Requwed Achon of l from one (1) hourto six(6) supported equiprnent.
| |
| hours. Bin witi L28.
| |
| l Requwements were ,
| |
| relaxed by allowing entry into the requwed achons forthe DG made inoperableinstead of requinne the unit to be Shutdown ,
| |
| Categmse L Reinammon d Apptembety iL Ratmuseon af Sesweemnce Frequency at LCO sesend in tames of Trans easier C/91 cJrPCterita '
| |
| IV. Amassed Oidago Tene Emoneen Ers W 5enso to 72 hours V. Reimmehan of Regured Athens to est A = 4 VL Reimumbon of Surveenrice Regaremert ==r e akscreens VIL Reimmenonof hOidageTune VHL Duishan of Resparemert for 30 day Special Report to NRC a_____
| |
| | |
| TABLE L- MATRIX OF LESS RESTRICTWE CHANGES SECTION 3.3,"WSTRUMENTATION" page 26of 30 Discussion of Description n(S Section CTS Section Category Characterization Change 3.3 L30 Requrements for an LCO 3.3.5 3.5.1 None Unque moperable degraded Requred Acbon Voltage channelwere B.1 Note relaxed by adophon of Note wtuch pomWs bypassing the inoperable channelfor up to four hours for teshng of other channels.
| |
| 3.3 L45 Sunmilance teshng SR 3.3.5.1 Table 4.1-1 VI Unique with respect to requrements were relaxed item 32 e cneena.
| |
| to pemd excludog sin with L48.
| |
| inpcbon of the test signal
| |
| . into Channel duftng the i
| |
| funcbonal test. l .
| |
| I Casagones L Reimaten of Appkutmy IL Reimmemn of Swvemance Fesquency at LCO samled h tunns of Trans neier een componards IV. Acoused Oidage Tlme Odenman kom 24 hours to 72 hours V. Reinnahan of Regared Achens to end W VL Reinnahan of Survedance Requeumart P creens ~
| |
| Vit Reinsten of W Ondues Tone VidL Datuten of Resparemord for 30 emy Spaced Report to NRC
| |
| . .. .. l
| |
| | |
| TABLE L- MATIWK OF LESS f4EST5WCTWE CHANGES SECTION 3.3,"50STIEJMENTATION" page 27ci30 Discussion of Description ITS Section CTS Secelon Cesegery Cherasterisesten Channe LCO 3.3.6, 'Contenment Ventilshon isolohon '.nstruerentshon" 3.3 L31 The survoitence frequency LCO 3.3.8 3.8.1.b N Unique wieuespect to for tookne Sie contenment fiequency.
| |
| ventdetion isolshon instrumentshon was reissed by ahmmekng teshng immediateer prior to refuehne 0.3 L46 The requirements foran LCO 3.3.6 Table 3.5-4 V Reduced applicabibly anoperutde Contesenent Requesd Action A loom 1.Ciii due to poeshon of ventilston isoishan Phase h equigenent.
| |
| A fundson were reinsed to Bin witi L42, L43 and penr.st contnued operabon L40.
| |
| wish the purge and went .
| |
| valves riaeart and meantaned cdosed LCO 3.3.7, TREFS Actuation instrumentesson" sone I L- noemeLa erAppaceer
| |
| : u. ausmusen er Sunusuum FsegsmacF IIL LCO semand in tenus er Tseum seer een emngsmanes IV. Aemmed Ouesom Ttne Essenmien tasa 24 haws to 72 hows
| |
| : v. maammeen er negames Amans es est appacememy vt naamanen er sunemense noemense acompennae aanna wet naammenermammes oimenTone Veu. Delaman er megemsmest ter 3D emy Speast napse to NnC
| |
| | |
| , - TABLE L-asATMK OF LESS fESTNCTWE CHANGES SECTION 3.3, NATIOfr* page 28 of 30 Discussion of Descripeten ITs secelen cts seceien conegory charasserisselen Change LCO 3.3.8 "AFW System instrumentahon" 3.3 L32 Requwements for the LCO 3.3.8 Tatdo 3.4-1 Nono unnguewish aspect to Aimaliary Feedwater(AFW) Required Acton 8 Functon 1 Requesd Actons insanonenemann were missed by pornulkng pesans channelin trip woun six @) hours -
| |
| insemed of mantenung the unit m hot shusdown e
| |
| i i
| |
| 4 L neem mien d Aspecie my f It animmann af Sam Fsessmacy N. LCO almend be amnes er Tsahs smeier man comymmmes W. Asamed Oidnes Thius Edension teen 24 haeme to 72 semos
| |
| : v. maiseman er amipsed Aasens es est Appecahdby vt amammemn er senemanne neomamme acompemano caemum vit . maammeen er Asumed Oedios Tune vut Dessman er naipennem sur ao any speem nopet to unc
| |
| _ _ _ _ _ . _ _ . _ _ _ _ _ _ . . . _ . . . . . . . . . . . . . . . . . - = . . - - . . . . .
| |
| | |
| TABLE L- RAATRIX OF LESS BESTRICTWE CHAf0GES SECTION 3.3, MTNATION" page 29 of 30 Descueeien of Description ITS Secteen CTS Section Category C8earactestantion Change 3.3 L33 The eBowed outage time LCO 3.3.8 Table 3.4-1 V.VII Unuque witi seepect to for aninoperable rainywas Requred Acton B Note 1 agowed outage time reismed from four(4) hours to six(6) hours forplacing inoperable channelin trip.
| |
| Requsements foran inoperable seierwere renamed to armnste sw requwement to ressors reley to OPERABLE status withm save (7) ders.
| |
| 3.3 L47 The surveigence method SR 3.3.8.3 - Table 4.5-1 V Unuque wise seapoct to was relaxed to perms use Functonal Unit P catene
| |
| . of anactualsegnalin e addshon to a simulated segnal for Die funchonal test.
| |
| l Caengmes L HelmutenerAppeceber
| |
| : 5. Reinamen er Seeweennes Fsuspsesuy at LCO semand in tunns er Tsemen susier seen casuponeses W. AAmmed Outsps Tone Esempaten tuse 24 heims es 72 house V. Rutensman er Magissed Acmans to og am Vt. naammmen er senvaamim nogemenemie anospannes essens VIL Reemmann er Assued Omduge Tsus VHL Datuben er Requbesnese ter E eny Speede Hupest to IntC
| |
| | |
| TABLE L-ERATRIK OF LESS IEST54CTIVE CHANGES SECTION 3.3, WTIENENTATION" page 30 of 30 Discussion of Dooeription ITS Someten CTS Seceson Catagery Charactortenden Change 3.3 L48 The survemence SR 3.3.8.3 Tetdo4.8-1 V Unupsewien mapoct to requirements were reiemed llem b and d P creene.
| |
| to permd excduding Bin wien L45.
| |
| insecton at a test monet into the channeldunne #m sunemonel test.
| |
| e I
| |
| 4 L RaamamanerAppasseesy
| |
| : a. Raamsten er Swumanum Fsequency W. LCO sameed to tunne er Tsubes sueur man osapenses IV. Assued Ondage Thus Esemumen tune 24 hanse to 72 haams
| |
| : v. Reinamen er Roemed Asenne to se Appensaany VL Reinamen er Swwesence Roosumme esemplance meeste -
| |
| VIL Reinstener Asumed Oueses Tsus WWL Delaman er Respeamese tr 30 day Speaud Repet to NRC .
| |
| A
| |
| | |
| _ _ _ _ . _ __ __ _ . ._. _ __ ._. . ._ _ . _ _ . ..~._ . _ _ _ . . __ _
| |
| I TABLE L - MATRIX OF LESS RESTRICTIVE CHANGES SECTION 3.4, " REACTOR COOLANT SYSTEM," Sheet 1 of 12
| |
| (
| |
| l rs=e====3ami of Descnption ITS Secteon CTS Section C:t;--rf Charactonantoon I
| |
| ! Change l LCO 3.4.5, PCS Loops-MODE 3" !
| |
| LCO 3.4.6, "RCS Loops-MODE 4" l LCO 3.4.7, "RCS Loops-MODE 5, Loops Filled" ,
| |
| LCO 3.4.8, "RCS Loops-MODE 5, Loops not Fded" l 3,4 L1 An allowance was added LCO 3.4.5, 3.3.3.1, None Umque ;
| |
| for Reactor Coolant Pumps LCO 3.4.6, 3.3.1.4 l 1- (RCPs) and Residual Heat LCO 3.4.7 !
| |
| l Removal (RHR) Pumps to be de-eneqpred for up to I one hourin any eight (8)
| |
| ]' hour penod.
| |
| 3.4 L18 An allowed outage time of LCO 3.4.5 3.1.1.2 Vil Uneque with respect to [
| |
| ; 72 hours for a sangle RCS Requwed Achons agowed outage time !
| |
| Loop was added and an A.1 and B.1 details only, i action to be in MODE 4 if j the loop was not restored ;
| |
| withen 72 hours was
| |
| * i added l !
| |
| I Categones ;
| |
| a :
| |
| 1 L Reimmatumor agyar many, j i n. Redematen of Swveemnce Frequency !
| |
| j ist. LCO stated in terms of Trans redher man arnpansres f IV. Amoued Owings Time Eisensson from 24 hows to 72 hows
| |
| ~
| |
| V. Re?.amaten of Regared Actons to edt Appicatululy l VI. Reimunhan of Surveannce Regaremert P czeans !
| |
| Vll. Reimaston of Aw Oulage Tirme !
| |
| VIII. Delsbon of "#- -, _ a for 30 day W Report to NRC ;
| |
| }
| |
| f i
| |
| | |
| TABLE L - MATRIX OF LESS RESTRICTIVE CHANGES SECTION 3.4, " REACTOR COOLANT SYSTEM," Sheet 2 of 12 Discussion of Description iTS Section CTS Section Category Characternahon l
| |
| l Change 3.4 L19 An allowed outage time of LCO 3.4.5 3.1.1.2 Vil Urnque with respect to Required Action allowed aJtage time l one (1) hourwas added for the condition where C.1 details only, rasctwity requirements are not met in the specification.
| |
| 3.4 L2 Actions in response to no LCO 3.4.6 3.1.1.1 Vill Ufugue with respect to RCPs or RHR pumps in circumstances of operation are changed report from estab'ishing a required shutdown margin to suspension of operations hvciving reduction in boron concentration.
| |
| categmes L Relaxationof aM
| |
| : 11. Relaxahon of Survedanc3 F.w Ill LCO stated in terms of Trains rather than -,w#s N. Asowed Outage Tkne Estension from 24 hours to 72 hours V. Relaxahon of Required Acsons to est Appicatulty VL Relaxahon of Survemance Requremers amessance creene Vil Retaxaban of Anowed Outaes Teme Delehan of Reaurement for 30 duy M Report to NRC j VHL l
| |
| l
| |
| | |
| TABLE L - MATRIX OF LESS RESTRICTIVE CHANGES SECTION 3.4, " REACTOR COOLANT SYSTEte," Shoot 3 of12 G5cussion of Description ITS Section CTS Section Category Characterisesion Omnge 3.4 L3 A requirement was deleted LCO 3.4.6 3.1.1.1 Vill Unuque witi respect to to sutwrut a Spooel Report arcumstances of to liie NRC within 30 days report l
| |
| i of falure to restore one l
| |
| RCP or RHR pump to operetson aner one (1) .
| |
| hour dunna shutdown.
| |
| 3.4 L4 Requwement was deleted LCO 3.4.6 3.3.1.4 None Unsque to close contenment prior to exceeding 200*F when both RHR pumps are d W i Categones L Reinsehen or am it. Relemehan or Swwaeanos F#equency M. LCO stated in tunne er Trains regner Wien components N. Aw Ondege Tkne Edension torn 24 hours to 72 hows V. Retamahan or Required Adians to eset Appicatimy VI. Retamahan or Survesanu Requeernant amspeance creene Vit_ Reinsehen or A5ctand Outogo Tone -
| |
| Vlti. Desehen or Requeemord sur:MIday Spedei Report to NRC
| |
| .u_ .
| |
| | |
| TABLE L MAThiX OF LESS RESTRICTWE CHANGES SECTION 3.4, " REACTOR COOLANT SYSTEel," Sheet 4 of 12.
| |
| Discussion of Description ITS Section CTS Section Category Charactortsselon Ct-ge -
| |
| 3.4 LS Note 1 was added to LCO LCO 3.4.6, . 3.3.1.4 None Unsque 3.4.8 that allows all RHR LCO 3.4.7 pumps to be doenegpzed for up to 15 nunules under certain condsbons. Note 2 was added to LCOs 3.4.7 and 3.4.8 wtuch allows one RHR train to be inoperable for up to two (2) hours for surveinance testing 3.4 L6 An allowance was added LCO 3.4.7 3.3.1.4 None Unique to pommt use of a steam generatorinstead of an RHR train for decay heat removalin MODE 5.
| |
| caegones L Reimmbon of M IL Reinmuon of Survesence Frequency lit LCO easted in tenns of Trans telhor then corsponards N. Agowed Outage Time Odension turn 24 hows to 72 hows V. Relematon of Reqused Adians to ed M VL Reisenhan of Swwesence Requirement acceptance enterte VIL Redesellanof AEowedOutageTime Vllt Doishon of Requbemord for 30 der SW Repen to NRC 1
| |
| | |
| TABLE L- MATRIX OF LESS RESTRICTIVE CHANGES SECTION 3.4, " REACTOR COOUWT SYSTEM," Sheet 5 of 12 Discussion of Description ITS Section CTS Section Category Characterization Change 3.4 L16 A requirement was deleted LCO 3.4.7, 3.3.1.4 Vill Urwque with respect to to sutxnit a Special Report LCO 3.4.8 cucumstances of to the NRC within 30 days report of failure to restore an mopei bie RHR train to operation after 14 days i i
| |
| during shutdown 3.4 L17 A requirement to verify a LCO 3.4.7, 3.3.1.4 None Unique backup method for decay LCO 3.4.8 heat removal when one RHR train is inoperable was deleted.
| |
| I l
| |
| : l. Resaxatmof Arphrahany, '
| |
| : 11. Relaxatm of Survesence Frequency 111. LCO statM iriterms of Trams radher ihon components IV. Amowed i .lage Time Extenom from 24 hotra to 7.:1ours .
| |
| V. Resaxahon of Required Actone to endt AM VI. Relaxahan of Surveihnee Requremord W=nce craerts Vll. Relaxateof AmowedOttageTene Vllt. Deleteri of Requrement for 30 day Special Report to KRC
| |
| : s. .i__.: - . .
| |
| i,.--.1
| |
| . - .-._.r.. . . . . . . . . . . . -. . .
| |
| | |
| i l
| |
| TABLE L- MATRIX OF LESS RESTRICTIVE CHANGES SECTION 3.4, " REACTOR COOLANT SYSTEM," Sheet 6 of 12 Discussion of Description ITS Sect 6on CTS Section Category Charactr,rizatson Change LCO 3.4.10, " Pressurizer Safety Valves" 3.4 L7 The operabilitylimits for LCO 3.4.10 3.1.1.3 None Unique the pressurizer code safety valve lift settings were increased frorn 2485 psig and 2560 psig to 2410 psig and 2560 psig.
| |
| 3.4 L9 A note was added which LCO 3.4.10 3.3.1.3 None Unique allows the pressurizer safety valves lift settings to be outside operability limits for the purpose of testing under certain conditions.
| |
| Relaxahonof AM
| |
| : 1. l it. Relaxaten of Survedance Frequency Ill. LCO stated in terms of Trains rather than w.W-es IV. Asowed Outage Tame Exter.sion frorn 24 hours to 72 hours V. Relaxahon of Requred Actons to exit Appbcabety VI. Retaxation of Survemance Requirement Wmze enterts Vll. Relaxabon of Anowed Outage Time Vtlt Delebon of Requrerrent for 30 day Specomi Report to NRC l
| |
| | |
| TABLE L - REATRIX OF LESS RESTRK:TIVE CHANGES SECTION 3.4, " REACTOR COOLANT SYSTERA." Sheet 7 of 12 -
| |
| Discussion of Description ITS Section CTS Section Category Cherasterismelon N nee LCO 3.4.12. "f.aw Temperature Overpressure Protecten (LTOP) System 3.4 L8 An agowance was added LCO 3.4.12 3.3.1.3 None unique for one Safetyinjecten (SI) pump to be capable of' injechng into the Reactor Coolant System (RCS) when the RCS is > 175'F.
| |
| Categostos L Reimmhon of ApptcehEly.
| |
| H. Reimahan of Surwesence Frequency 111. LCO stated in tenna of Treme rather tien - .
| |
| IV. Aw Outogo Time Deension fress 24 hours to 72 hours V. Redemmon of Rogered Acmens to ao ApptcebEly .
| |
| VL Reimmhan of Surtedence Requhement acceptance creene Vll. Reimmhanof AtomedOutogoTone VitL Deleton of Requkement par 30 der Special Report to MRC f
| |
| | |
| TABLE L - MATRIX OF LESS RESTRICTNE CHANGES SECTION 3.4, " REACTOR COOUWT SYSTEM," Sheet 8 of 12 Discus,sion of Description ITS Section CTS Section Category Characterisation change LCO 3.4.13. "RCS Operahonal Leekage" 3.4 L10 A time was allowed for LCO 3.4.13 3.3.1.3 Vil Uneque with respect to pomary to secondary details of extended leakage to exceed A3 owed Outage Tunes requirements of four(4) hours and the time required to reach MODE 5 if the leakage is not .
| |
| restored to requwed lamets was extended from 30 hours to 36 hours 3.4 L11 The Survedlance SR 3.4.13.1 Table 4.1-3, 18 Uruque with respect to Frequency for performing a item 9 dotads of Frequency pnmary system water inventory balance was extended from daily to once everV 72 hours t I
| |
| celegenes
| |
| : 1. Retuelenof Apptcetely.
| |
| N. % of Sunemence Fmquency lit. LCO stated h tenne of Trains rather then components tv. Ammmed Outogo Time EWensten hem 24 hows to 72 hows V. Reiselon of Requead Actone to ese Appecately vs. Reimahan of Sunemence Requeemem acceptance atens VN. ReimmemnorAsomedOutogoTone -
| |
| VM. Deleton of Requement for 30 der Spedal Reped to NRC
| |
| ____ _ __ . _ __ _=.
| |
| | |
| TABLE L - MATRIX OF LESS RESTRICTWE CHANGES
| |
| ' SECTION 3.4, " REACTOR COOLANT SYSTERA," Sheet 9 of 12 Discussion of C:: -Li's ITS Section CTS Section Category Characterization Change s, 3.4 L12 The allowance for a LCO 3.4.14 3.1.5.4 None Unsque Pressure leal =ervi Valve (PlV)with leakage that exceeds limits to remain unisolated by two valves was extended to four(4) hours and to remain isolated by only one valve was extended to 72 hours 3.4 L13 The length of time that the SR 3.4.14.'1 Table 4.1-3, None Uruque plant can be shut down item 17 -
| |
| before the Survesitance Requwement for
| |
| . per.ormng PlV testing was extended from72 hours to i 7 days.
| |
| i n
| |
| i Categones L R%of AM 11.' R% of Sunmaance Frequency ill. LCO stoled in terms of Tralrus regier then car ;nents IV. Agossed Outogo Time Emension torn 24 hours to 72 hours V. R% of Regnared Actons to ess.am VI. Retenamon of Sunemence Requhement P creerte V!I. Reisemon of Adamed Outogo Tune Vilt Deletion of Reguremord for 30 der Spedal Report to IdRC l
| |
| l
| |
| . . . . . . . ~ . . . . . _ . . . . _ . . . . . . . . . . . ,
| |
| | |
| TABLE L - MATRIX OF LESS RESTRICTNE CHANGES SECTION 3.4, " REACTOR COOUWdT SYSTERS," Sheet 10 of 12' ITS Sectson C T S # a e*iant Category Charactortamelon Discussion of . C::4 ^' - . _
| |
| Change 3.4 L24 Requsements were - LCO 3.4.14 Table 4.1-3, None Uruque deleted to record daily the item 17 meegnty of a remaining PfV and record daily the poseon of the other closed valve in a line where the integnty of a PlV cannot be determined.
| |
| 3.4 L14 The requrements for RCS LCO 3.4.16 3.1.4 i Unuque with respect to Speedic Actuty were Appbcatuisty detals of appbcabshly l
| |
| ! reduced to be apptcable only to MODES 1,2, and 3 with RCS temperature 2 500*F.
| |
| Ceegones L Reimmemn of Apptcehmy
| |
| : 11. Reimmhan of Surwomann Frequency ill. LCO stated in topns of Trains retter then components tv. Aw Ouenge Tiene Edension torn 24 hows to 72 hows V. Reimeonof Requesd Actonstoendt Af9ershesy .
| |
| VI. R% of Surwesence Regnareneont acceptance aderie W. Retastenof Adowed Ondeen Tiene VIII. Daishon of Requsemere par 30 day Special Report to NRC
| |
| | |
| TABLE L'- MATRIX OF LESS RESTRICTNE CHANGES SECTION 3.4, " REACTOR COOLANT SYSTEM," Sheet 11 of12 l
| |
| Discussion of: Description ITS Section CTS Section Category Characterization Change 3.4 L15 The Survesitance SR 3,4,16.1 Table 4.1-2, 11 Unique with respect to Frequency forvenfying item 1 frequency details only, reactor coolant gross specsfic activity was extended from once every 72 hours to once per7 days.
| |
| LCO 3.4.17. "Chernecal and Vosame Control System (CVCS)"
| |
| 3.4 L20 Requwaments to bring the LCO 3.4.17 3.2.3 None Unsque plant to MODE 3 and cool Requred Actions down and depressunze the D.1, D.2, and D.3 RCS were added where no achons ed existed.
| |
| Catolpmos
| |
| : 1. Reemahanof Apptcohaty.
| |
| M. Reimaten of Survesence Frequency ill. LCO stated in tonns of Traine rather then componeres IV. Asomed Oidege Time EAension torn 24 hows to 72 hows V. Reimmhon of Required Acelons to est am VL R% of Survedence Respausnard W creene Vit. Reimsbon of Aw Ondege Tirne vut Doeshon of Requsement for 30 day Spedal ReporHo NRC
| |
| | |
| ~. .
| |
| TABLE L - MATRIX OF LESS RESTRICTIVE CHANGES SECTION 3.4, " REACTOR COOLANT SYSTEM," Sheet 12 of 12 Discussion of Description ITS Section CTS Sechon Category Characterization Change
| |
| .4 L21 Specific requirements for LCO 3.4.17 3.2.2 None Unaque operai&ty of boron C - nuvu pamways were M relaxed to apply only to two pathways of makeup water from the Refueling Water Storage Tank (RWST).
| |
| 3.4 L22 The allowed time for one LCO 3 417 't 9 3 tv Asse- r4 r%d=a Time c% pump to be Required Action Extension from 24 ifiopei ble was extended A.1 hours to 72 hours from 24 hours to 72 hours 3.4 L23 A requirement was added LCO 3.4.17, 3.2.3 None Uneque A which allowed 72 he ine t'e p :; d A t i i _
| |
| L/ --ene makeup water B.1
| |
| / i pathway from the RWST to be inoperable.
| |
| cate0mes .
| |
| : 1. Relawationof Apphcabety l
| |
| : 11. Renar=Han of Survesence Frequency 111. 8 CO stated in terms of Trans rather then componerits IV. Asowed Outage Time Emsensaan from 24 twurs to 72 hours V. Res a==han of Required Actons to esit AM VI. Renar=srwi of Sunemence Requrement arrardance creersa Vll. Ran= =han of Asowed O@ Time Viit. Delsbon of Requvemord for 30 der Spedet Report to NRC
| |
| | |
| s ~
| |
| TABLE L- MATRIX OF LESS RESTfuCTNE CHANGES SECTION 3.5, " EMERGENCY CORE COOLING SYSTEMS (ECCS)" page 1 of 5 Discuss'en or Description ITS section CTS secuan Category Charactorhation Change LCO 3.5.1, " Accumulators" 3.5 L1 The allowed time for an LCO 3.5.1 3.3.1.2 VII Uneque with respect to accumulator to be ReqJired Action allowed outage time inoperable due to boron A.1 extension only concentration not within limits was relaxed from four(4) hours time to 72 hours O
| |
| ( _ M
| |
| | |
| TABLE L - MATRIX OF LESS RESTRkM CHANGES SECTION 3.5, " EMERGENCY CORE COOUNG SYSTEMS (ECCS)" page 2 of 5 Discussion of Desertption ITS Section CTS Section Category Characterization '
| |
| Change LCO 3.5.2, "ECCS-Operating" 3.5 L2 The condition assoasted LCO 3.5.2 3.3.1.2 til. IV with an inoperable Requwed Acton Emergency Core Cooling A.1 System (ECCS) component was extended to allow one or more trains of ECCS to be irioperable as long as 100% of the .
| |
| ECCS flow equivalent of a smgle operable train is available. The allowed time for one or more ECCS trams to be inoperable was relaxed from 24 hours to 72 hours.
| |
| 3.5 L8 A note was added to LCO 3.5.2 3.3.1.2 None Unique Permet operation in MODE 3 with one requwed Safety injection (SI) pump inoperable for a limited penod of four(4) hours pursuant to the speofications for Reactor Cooient System ovemressure e
| |
| | |
| TABLE L - MATRIX OF LESS RESTRICTIVE CHANGES SECTION 3.5, " EMERGENCY CORE COOUNG SYSTEMS (ECCs)" page 3 of 5 Discussion of Description ITS Section CTS Section Category Charactertration f: Change -
| |
| 3.5 L3 A requirement to restrict SR 3.5.2.4 4.5.1.1 None Uruque survedance testeg of the SR 3.5.2.5 ECCS such that the ECCS is p.a...ded from injectog into the Reactor Coolant System (RCS)was deleted 3.5 L4 Detailed requirements for SR 3.5.2.4 4.5.1.2 None Unique performance of SR 3.5.2.5 surveillance testeg relatog to control board indicaten and visual observaten that all components have received the safetyinjechon single in the pmper sequence and tuning were deleted 3.5 L5 Detailed requirements to SR 3.5.2.1 4.5.2.1 None Unique morntor controlroom indication and controls dunng performance of survedance testeg were deleted I
| |
| 1 a
| |
| | |
| \ i{ lll1ll1 l!l !~
| |
| ~
| |
| 5 f
| |
| o 4
| |
| e g n a
| |
| p i o
| |
| t a
| |
| hr t
| |
| e c e a
| |
| r u a q h m C U
| |
| ) y S r C o g
| |
| C e e S
| |
| E(E t a
| |
| n o
| |
| GS C N .
| |
| NM AE HT CS n EY o VS i t
| |
| c "n TG I
| |
| e w CN I
| |
| S o 23 .
| |
| RU S d t
| |
| 11 TO T u 33 SO C h S- 33 EC R E S SR C SO C E n EC L ", i o
| |
| FY n o
| |
| 3 t c
| |
| OC N i t
| |
| 5
| |
| : 3. A XE c 3 I
| |
| e 5. d e RG S O 3ir TR C Oq u AE S L Ce1 MM T I LRA E
| |
| L",
| |
| E5 L3 o dt BN 4reS A
| |
| TIO e DEuC i
| |
| h qC T t C
| |
| E oOreE r
| |
| f s Moo f
| |
| S t n gdin t
| |
| n o e nxt nead r i
| |
| t p mua eier i
| |
| r edle rSr oq nu c
| |
| s u
| |
| qC er yr e e eCelne D REwob f
| |
| o n
| |
| i o
| |
| s se u
| |
| c s
| |
| L 6
| |
| 5 DN i
| |
| 3
| |
| ,l ll llll .l
| |
| | |
| TABLE L - MATRIX OF LESS RESTRICTIVE CHANGES SECTION 3.5, " EMERGENCY CORE COOUNG SYSTEMS (ECCS)" - page 5 of 5 Discussion or Desertption ITS Section CTS Section Category Characterization Change LCO 3.5.4, " Refueling Water Storage Tank" L! 3.5 L7 An allowed outage time of LCO 3.5.4 3.3.1.1 None Umque
| |
| , 8 hours was added to the_ Requwed Action requwements for the . A.1 Refusing Water Storage Tank (RWST) to be inoperable due to boron concentraton not vnthin limits.
| |
| | |
| i 0
| |
| }
| |
| I a 1 1
| |
| I.! e ] $
| |
| n n 3 I
| |
| 5 51 1 It i a i 8 ag g I!.
| |
| l* 1 1 1
| |
| 1 I i il 0 ll i illill 11 ( i L_,,,
| |
| | |
| 1 M
| |
| f TABLE L - MATRIX OF LESS RESTRICTIVE CHANGES SECTION 3.S, '' CONTAINMENT SYSTEMS," ' page 2 of 6 Discussion of Description ITS Section CTS Section Category Charactortestion Change LCO 3.6.3, -"
| |
| (
| |
| .3.6 L5 The allowed outage time LCO 3.6.6 3.6.2.2 Vil Urwque with respect to for a smgle inoperable Required Actions 3.6.2.3 allowed outage tunes contamment spray train A.1, B.1, and B.2 only was extended to 72 hours from 24 hours as was previously requwed. If the '
| |
| train is not restored to operable status as required, the suowed time to bring the plant to cold shutdown was extended to 156 hours from 72 hours plus the time required to shuidown the reactor uhliz ng normal operatmg procedures l
| |
| l caengersee L Rotammen or Appaestday.
| |
| : n. Reinamon or sunemence Fesquency Hl. LCO simbed in tenns er Trains reemr Wien components tv. Anmmed Ondago Time Edenelon Wern 24 hows to 72 hows V. R%orRequhod Acsonstoed Arter=68my vt Raimuson or Sunemence Requhemord W creeds vu. Reinamon or Asamed oimage Time
| |
| - vnt Deseson or Requhement for 30 day M Report to NRC -
| |
| | |
| TABLE L- MATRIX OF LESS RESTRICTWE CHANGES SECTION 3.6," CONTAINMENT SYSTEMS," page 3 of 6 Discussion of Description ITS Section CTS Section Category Charactertzstion
| |
| ,' Change 3.6 L6 Restnctions that required LCO 3.6.6 3.6.2.2 None Unique
| |
| ;i noinoperatnTityof the I diverse coolmg subsystem when a contammerd fan cooler or contamment j'
| |
| spray pump is inoperable were deleted.
| |
| 3.6 L7 LCO 3.6.6 3.6.2.2 Vil Unique with respect to An allowance for two (2) contamment coohng trains Requwed Acticm allowed outage time to be inoperable for up to D.1 details .
| |
| 72 hours was added.
| |
| A requirement to test the LCO 3.6.6 4.5.1.6 None Unique
| |
| , 3.6 L8 Contalnmerd Cooling units monthhr was deleted.
| |
| caesp nes I. Reisellon of Atier=MBy.
| |
| N. Reisemon et Survenance Ffoquency ill. LCO eteled h tonne of Traine redher then tempenento IV. Anoused Outage Time Enteneden 9 mon 24 hours to 72 heiss V. ReimeGen of Requhed Aceans to me AppstabWly vi. Reimmeon of Sunsemence Requbemord acceptance aterlo Vil. Ret == man of Amoused Outage Time vin. Deseson of Raphomord for 30 day W Report to NRC
| |
| | |
| TABLE L- MATRIX OF LESS RESTRICTTVE CHANGES SECTION 3.6, " CONTAINMENT SYSTEMS," page 4 of 6 1
| |
| Discussion of Description ITS Section CTS Section Category Characterization Chano.
| |
| LCO 3.6.7," Spray Adchtsve System" -
| |
| 3.6 L9 The allowed outage time LCO 3.6.7 3.6.2.2 lit, Vil Uneque with respect to for one (1) inoperable .
| |
| Requwed Action train and allowed spray system flow path for A.1 outage time details 24 hours was extended to apply to the spray additive system with at least 100%
| |
| of the spray additive system train flow avaihsble, and the allowed outage time was extended to 72 ,
| |
| hours frtyn 24 hours.
| |
| 3.6 L10' The allowed outage time LCO 3.6.7 3.S.2.3 Vil Unique with respect to for an inoperable spray Requwed Achons allowed outage time additive system.in MODE 3 B.1 and 8.2 details only was extended to 48 hours from no time allowed l
| |
| categortse
| |
| : 1. Reimagencf agyacessay.
| |
| M. Reisellen of Sunemence Frequency 111. LCO stated bi tonne of Trains velhor Dion componente IV. Alkmed Outoge Tbne Edension tem 24 hows to 72 heure V. Ran== man of Regubed Actions to edt M VI. Ran== man of Survesente Requirement etxeptance cstarte VII. Reinemen of Aucued Odeos Time VM. Decemon of Requkement for 3D day M Report to NRC
| |
| | |
| TABLE L- MATRIX OF LESS RESTRICTIVE CHANGES SECTION 3.6, "CONTANWENT SYSTEMS," page 5 of 6 Discussion of Description ITS Section CTS Section Category Characterization Change 3.6 L11 The required surveillance SR 3.6.7.3 Table 4.1-2 !! Urwque with respect to frequency forvenfymg item 5 frequency details only NaOH concentration in the spray additive tank was extended from monthly with a maximum time between surveillances of 45 days to 184 days.
| |
| t casegories I. Reineman of Apr*=hany.
| |
| M. Rolesson of Sunemence Frequency NI. LCO steled in tems of Traine esther the cornpanonle IV. Agowed Otdage Tkne Emlenolon hem 24 hours to 72 hours
| |
| : v. Reissaan of Required Adsons to em Appsesemir VI. Reisellon of Survemence Requiremord streptance aterte VN. RelesNon of Apowed Otdees Time vm. Deiseen of Requirement for 30 day Spedal Report to NRC
| |
| | |
| TABLE L- MATRIX OF LESS RESTRK:TvE CHANGES SECTION 3.6, " CONTAINMENT SYSTE'AS," page 6 of 6 Discussion of Description ITS Section CTS Section Category Characterization Change ,
| |
| I LCO 3.6.8, " Isolation Valve Seal Water System" l Unique with respect to 3.6 L12 The allowed outage time LCO 3.6.8 3.8.6.1 III, VII
| |
| ,' train and allowed
| |
| ; for a single inoperable Required Action Isolation Valve Seal Water A.1, B.1 outage time details (ivSW) system was only extended to apply to the entire system. The allowed outage time for the IVSW system was extended from 24 hours to 72 hours. The time allowed to reach MODE 3 when the IVSW cannot be restored as required was extended to 80 hours from 32 hours.
| |
| categorwe
| |
| : 1. Releenort of Appscobaty.
| |
| B. Reimation of Sunesence Frequency IM. LCO stated kiterms of Trains rulher than coreponerde IV. AAowed Outage Time Edension from 24 hours to 72 hours V. Retention of Required Actions to edt Appecabaly VI. Reimation of SuneIIence Requirement acceptance crterte !
| |
| Relemtion of Alkmed Outage Time l Vll. 1 vm. DeleHon of Requirement for 30 day Speelmi Report to NRC 1
| |
| I
| |
| | |
| TABLE L- MATRIX OF LESS RESTRICTIVE CHANGES SECTION 3.7," PLANT SYSTEMS," page[1 of 8 Discussion of Description ITS Section CTS Section Category Characterization Change s'
| |
| ' ' LCO 3.7.1, " Main Steam Safety Valves 3.7 L1 An allowance was added LCO 3.7.1 Table 3.4.1.a None Unique for one or mofe Main 3.7.1-1 .
| |
| Steam Safety Valves (MSSV) to be inoperable.
| |
| 3.7 L2 A Note was added to ITS LCO 3.7.1 Note to 3.4.1.a None Unique actions for separate Actions condition entry for each ,
| |
| inoperable MSSV.
| |
| LCO 3.7.2, " Main Steam Isolshon Valves" 3.7 L3 The requwements for the LCO 3.7.2 3.4.1.s I ' Unique with respect to Main Steam isolation Applicabelity details of Applicability.
| |
| Valves (MSIVs) were relaxed to apply to only when the MSIVs are open categories L Reimenonof Aprernhasy.
| |
| : 11. Relemtion et Survemence Frequency lit. Lc0 stated in tonne of Trains rulher then componente IV. Anowed Outage Time Edenelon from 24 hours to 72 hours V. RetemNon of Required AcHone to ed AppsesbMiy VI. Reiseben of Surveennee R$-.- 4 acceptance creerte V11. Reimmlion of Anowed Oulege Tirne
| |
| _ _ _ _ _ - _ _ _ a - - - -
| |
| | |
| TABLE L - MATRIX OF LESS RESTRICTIVE CHANGES SECTION 3.7," PLANT SYSTEMS," paget 2 of 8 .
| |
| Discussion of . Description ITS Section CTS Section Category Characterization Change j: 3.7 L4 The frequency for SR 3.7.2.1 4.7.1 II Unique with respect to frequency M only, ii ! performing a Surveillance J
| |
| on the MSIVs was extended from every 15 l months to as specsfied by '
| |
| l IST.
| |
| LCO 3.7.4, " Auxiliary Feedwater System" 3.7 L5 An schon and Note were . LCO 3.7.4 RA E.1 3.4.4 None Unique added forthe condihop of ,
| |
| a w .,.",, ,. loss of the .
| |
| Auxiliary Feedwater(AFW)
| |
| Function.
| |
| 3.7 L6 The frequency for SR 3.7.4.2 4.8.1, 4.8.2 11 Uruque with respect to performing testino of the frequency details only, AFW pumps was extended from rnonthly to Staggered Test Bases (i.e.,31 days to 93 Ce for erw one pump.
| |
| ca e I. Reisesener M .
| |
| : 11. R% erSesweemnce Fw R. LCO sisend in tunne er Trelms rester Wien compensuds tv. w outage Time F;esnesen ran 24 hein to 72 hows V. RM or Reguled AcSans to ed AppeceldBy VI. Reinaten er Survumence Requiremerd ecomptance etterte
| |
| ~
| |
| vu. Reimmeen or Agamed Outage Time i
| |
| | |
| TABLE L - MATRIX OF LESS RESTRICTNE CHANGES SECTION fi.7, " PLANT SYSTEMS," paget 3 of 8 Discussion of Description ITS Section CTS Section Category Characterization
| |
| _ Change A Surveillance SR 3.7.4.2 4.8.1, 4.8.2 VI Urnque with respect to 3.7 L20 Requirement was relaxed details of acceptance to require that the AFW critenon.
| |
| Pumps be no longer run for 15 rrunutes.
| |
| The frequency for SR 3.~/.4.3 4.8.3 11 Unique with respect to 3.7 L7 performing a Surveillance frequency details only, on AFW valves was extended from 31 days to 18 months.
| |
| l Colegories
| |
| : 1. Relemtionof Appar wey it. Retention of Survesence Frequency IX. Lc0 stoled kt terms of Traine reiher then cargonerto IV. Anowed Outage Time Emlension fircen 24 hours to 72 hours V. Reimshon of Required Actions to ed AppAcately VI. Reimation of Survemence Requkemerd acceptance catorio VII. Relemtion of ANowed Outage Time
| |
| | |
| TABLE L - MATRIX OF LESS RESTRBCTIVE CHANGES SECTION 3.7," PLANT SYSTEMS," paget 4 of 8 osecueeson et - ossertption iTS Secuen CTS Secean Caessory characeerteamen Change LCO 3.7.6, " Component Cooling Water System," and
| |
| ' LCO 3.7.7, Sennce Water System" 5 ,
| |
| 3.7 L8 Actions required when the LCO 3.7.6 3.3.3.2, 3.3.3.3, m LCO stated in terms of specification is not met LCO 3.7.7 3.3.4.2, 3.3.4.3 Trains rather then -
| |
| ll components
| |
| ! were changed from a single component basis to a train basis for the Component Coomng Water -
| |
| (CCW) System and the -
| |
| Service Water System (SWS).
| |
| 3.7 L9 The allowed time forone LCO 3.7.6 3.3.3.2, 3.3.4.2 IV Agowed OutageTwne inoperable CCW System LCO 3.7.7 Extension from 24 orSWS train was hours to 72 hours extended from 24 to 72 hours celeawee L Reimanener ArgareMay N. Reineman er Survetence Fsequency IIL LCO stated h terme er Treme regier 9mn eenoonente IV. Asowed Ottage Time Endension tem 24 heure to 72 heure i j
| |
| V. R% or Required AcIlone toese AyyareNay VI. R% or Surysmance Requirement W cotute VM. Retungen er Atomed Outage Tkne ,
| |
| ~
| |
| | |
| TABLE L - MATRIX OF LESS RESTRICTIVE CHANGES SECTION 3.7," PLANT SYSTEMS," paget 5 of 8 Discussion of Description ITS Section CTS Section Category Characterization Change LCO 3.7.9, " Control Room Emergency Filtration System (CREFS)," and
| |
| . ' LCO 3.7.10, " Control Room Emergency Air temperature Control (CREATC)"
| |
| ' Umque with respect to 3.7 L10 The requwements for the LCO 3.7.9 3.15.1 I CREFS and CREATC LCO 3.7.10 details of ApplicatAty.
| |
| were reduced to apply only to MODES 1 through 4, movement of'wradiated fuel, and CORE ALTERATIONS. .
| |
| 3.7 L11 An action was added to LCO 3.7.9 3.15.2.a V Unique with respect to suspend CORE LCO 3.7.10 details of Required Action.
| |
| ALTERATIONS or moveM .n er aasaw,1 fuel (i.e., e.it Applicat: lity) rather than piece CNFS into emeroenc nede.
| |
| csiegorwe
| |
| : 1. Rad ==dian of Appecately.
| |
| II. Releahon of Survesence Frequency lit. LCO stoled h terms of Traine relhor then companords IV. Akmed Oulege Time Emlension from 24 hours to 72 hours V. Reisellan of Required Actions to ed Appecetdmy VI. Reimehan of Survettence Requirement acceptance creerte VII. Reesellen of AAowed Otdage Time
| |
| . . - . . . - . . - . - ~ . . -. . . . . - - . . . . . . .
| |
| | |
| TABLE L - RIATRIX OF LESS RES'iRICTIVE CHANGES SECTION 3.7," PLANT SYSTERNS," paget 6 of 8 Discussion of . Description ITS Section CTS Section Category Characterisation Change 3.7 L12 A requwement was deleted LCO 3.7.9 3.15.2.b None Unsque
| |
| : r. to suspend reduchon of LCO 3.7.10 Shutdown Margin if both trains of CREFS or CREATC are inoperable.
| |
| 3.7 L13 A Surveillance SR 3.7.9.1 4.15.b VI Unique with respect to Requwement was relaxed detasis of acceptance to requwe that the CREFS crilenon.
| |
| be operated for15 rrunutes rather than 1 hour. t 3.7 L14 A Surveillance SR 3.7.9.1 4.15.c VI Unique with respect to Re.gu;rement was relaxed details of acceptance to no longerVenry postrve entenon.
| |
| pressure during .
| |
| Operational testing of the CREFS.
| |
| categense )
| |
| i L Reimmean er M. l l
| |
| N. Reimmeen er Sunemence Feequency W. LCO stated h terme er Treho regier Wien congenses IV. Aammed Ondege Time Emlensieri torn 24 lueurs to 72 fieurs
| |
| : v. Reemumen or negumed Acanne to ed Asyseemsey ,
| |
| VI. Reimmuun er Sunseenee Requeemord P ceterte i' VII. Reimenen erW Outege This i
| |
| | |
| TABLE L - MATRIX OF LESS RESTRICTNE CHANGES SECTION 3.7,"PUWT SYF"~ 4." paget 7 of S Discussion of Descriptkm ITS Section CTS Section C i ;_., Characterization Change 3.71,15 Thefrequency for SR 3.7.9.4 4.15 f.4 !! Ureque with respect to perfomung a Serveillance frequency details only, was extended from 18 months to 18 months on a St=ggared Test Basrs 3.7 L16 The acowed time that Tm LCO 3.7.10 3.15.1.s. Vtf Unque with respect to train of CREATC can be 3.15.2.a Allowed Outage Tene inoperable was extended details only, from 7 days to 30 days.
| |
| LCO 3.7.11. " Fuel Building Air Cleanup System
| |
| * 3.7 L19 An r*;on was added to LCO 3.7.11 3.8.2 V Urwque with respect to susnxi movement of Requwed Achon details of Requred irradiated feel assemblies A.1 Achon.
| |
| (i.e., exit Applicatzlity) rather than termnate fuel handling opershons . . , _
| |
| LCO 3.~r.15. " Secondary SpecG Actrvit/
| |
| L ReemamenerAppecstay it. Reinadon er Swweente Frequency NI. LCO Muted h tenns er Trains remer Wien compenseds tv. Answed outsee TIrne Estension torn 24 hows to 72 hows V. Retoution er Required Acsons to me Appaester VL Reemasonof Swweente _ ,_ _ atemptente create Vit. Retesson er Asessed Out'Oe TWne
| |
| | |
| TABLE L - MATRIX OF LESS RESTRICTfVE CHANGES SECTION 3.7. *PtANT SYSTEMS " paget 8 of 8 tn cussion or c.grs ITS section CTS section Cat cory Cherneterlastion Change 3.7 L17 The requirements for LCO 3.7.15 3.4.2 I Unique with respect to i
| |
| secondary w's schvdy detsiis of Applicatzlity.
| |
| i I were reduced to apply only I to MODES 1 through 4 from as modes of opersbon from cold shutdown."
| |
| 3.7 L18 The frequency for SR 3.7.15.1 Table 4.1-2 R Unique with respect to perfomung a Surveillance ite m 8 frequency detsiis only, for secondary W'c aCfMty was extended from 72 hours to 31 days cw L Retueellan of M R. Retusstenof Sesveennes Frogsecy IIL LCO sessed h terms of Trams rather Dion componeres IV. Assumed OtAnge The Essesween from 24 haws to 72 hours
| |
| : v. nesmuson er neessed Acsare to est M vt seemmuun er swwmance n_ _.-_ : scoes ence e creeres VW. Retusmuon of AAoused Oismge The
| |
| . . .I
| |
| | |
| TABLE L- MATRIX OF LESS RESTRICTWE CHANGES SECTION 3.8,
| |
| * ELECTRICAL POWER SYSTEMS." page 1 of 7 Discussion of C;n. ",^'s ITS Section CTS Section Category Charactertration Change
| |
| ! LCO 3.8.1, *AC Sources-Operahng" 3.8 L1 The allowed time to LCO 3.8.1 1.3 VII Unsque with respect to deciare requwed features Requered Action asowed outage time with no offsite power A.1 and 8.2 extensson only.
| |
| available inoperable when its redundant requwed featureisinoperabie was extended frorn no allowed time to 12 hours. The allowed time to declare requwed features supported by the inoperable diesei generatorwhen its redundard required feature is inoperable was extended from no allowed time to 4 hours cassenme L Relemton dAppecebety IL Reimusbon of Survesence Frequency E. LCO sessed in terms of Trains rather then components IV. Allowed Outage Tune Extensen from 24 hours to 72 hours V. Relemson of Requred Actons to edt Appicabaly VL Relembon of Survesence Requwement acceptance critens VI. Relemsson of Apowed OutageTime Vitt Deleton of Requeement for 30 doy Spedal Report to NRC l
| |
| | |
| TABLE L- IRATRIX OF LESS RESTRICTIVE CHANGES SECTION 3.8, MCTRICAL POWER SYSTERRS," page 2 of 7 Discussion of C;d; ^' -a ITS Section CTS Section Category Charactertestion Change ,
| |
| s 3.8 LS The requeed time that the SR 3.8.1.11 4.6.1.5 None t..%
| |
| ! diesel generatoris tested between 2650 kW and 2750 kWis reduced from two (2) hours to 21.75 -
| |
| hours.
| |
| LCO 3.8.3, Thesel Fuel Oil and Starbng Air" 3.8 L2 The time sAlowed for LCO 3.8.3 3.7.1 VII Unsque with respect to restorshon of fuel oil to Requred Achon allowed outage time ,
| |
| withm limds is extended A.1 and B.1 details only, from no allowed :irne to 48 hours casseem.
| |
| I. Reimuseon of APrde"h''y R. Relaxaton of Survesence Frequency IE. LCO stated in terms of Trains rather then components IV. Asowed Outage Time Extensen from 24 hours to 72 hours V. Relexseon of Requeed Actons to est Appsenhasy vt. Relaxaton of Survesence Res..d acceptance esserie VII. Relaxaton of Asowed Outage Time Vill. Deleton of Requwement for 30 day Special Report to NRC
| |
| | |
| TABLE L- MATRIX OF LESS RESTRK;TIVE CHANGES SECTION 3.5,'T.LECTRICAL POWER SYSTEMS," page 3 of 7 Discussion of Description ITS Section CTS Section Category Charactortzstion Change LCO 3.8.4, *DC Sources-Operatrf 3.8 L4 The Surveigence SR 3.8.4.1 4.6.5 ft Unique with respect to Frequency forverdyng fmxy details only battery voltage is a 125.7 volts was extended from I daily five days perweek to once every 7 days.
| |
| Ca p L Redesraton of Applicebety E. Relausbon of Survesence Frequency l
| |
| NI. LCO stated in tenns of Trains rather then components l
| |
| IV. Asowed Outage Trne Estenemon from 24 hours to 72 hours V. Relematon of Required Adions to ed AppEcabety VI. Relausbon of Survesence R@ .. 4 acceptance creerie VII. Relauston of Asowed Outage Time -
| |
| VIN. DeleSon of Requrement for 30 der Speoallteport to NRC
| |
| . - - .- ~ -. -
| |
| | |
| I
| |
| ' ~'
| |
| TAEKE L- MATFEK OF LESS fESTTWCTIVE CHANGES SECTION 3.S, " ELECT 5WCAL POWER SYSTEMS," page 4 of 7
| |
| % of Doocdpean ITS SocGon CTS Seceen Catsgery Chersetorteamen U Change t;.
| |
| !'l-~ LCO 3.8.6, W Cet Paromotors"
| |
| !I Uniquesuitinopect to lj 3.8 L3 The Mme agoured for -
| |
| ben y ces paramoi =
| |
| LCO 3.8.6 nequ.ed aeson.
| |
| 4.6.3 VH ano.ed aumee smo N A.1, A2, and A.3 deteEs only t ! not be vultun Category A .
| |
| i- i and B Nmitsvues extended t from no time to 31 days ishon pent ceE electrolyte sevet arvi noet vastage are verWied to most Calogory C Enuts wNhin 1 hour and Sist bettery ceE paramesers am vermed to most Category Clirsuts witiin 24 hours and every 7 dors wereener L Rehuseon ofM.
| |
| : a. R% of Sweemanos Fsequemy ,
| |
| : s. Lco seatsd in tems of Tsains rusher then components IV. W ouence Thne Edension tem 24 hoess to 72 hows
| |
| - V. Reimmeon of Regulsed Actons to es AppecebmIr VL Reinden of Sumumence Regehement acceptance cues,le .
| |
| VIL Reimeson of AAswed OuengeTene vs. Ossemon of Requbement for 30 der M Report to NRC e
| |
| ._ a_ - -
| |
| | |
| 11 8 TABt.E L -- REATfuK OF LESS IESTRICTIVE CHANGES SECTION 3.S, "ELECTIWCAL POWER SYSTEMS," page 5 of 7 r% or ossertpmon ITs secesen cts secesen category csierastesteeseen chenee 4
| |
| 3.8 L6 The Survemence SR 3.8.6.1 4.6.3 N Uniquewaitirespect to 3 Frequency for venVying ". : ,_ _ _ q namamme only p5ot coE voltage ansi temperature was extended from cielly five cesys per week to once every 7 f days.
| |
| > f
| |
| ; 3.8 L7 A survesence i;, .._-4 LCO 3.8.6 4.6.3 None Unique ll to subject the betteries to an =,% charge -
| |
| annumerwas desseed 3.8 L10 - The Survemence SR 3.8.6.3 4.6.3 N UniquewiWirespect to Frequency forvertFying frequency tieteils only everage esecerewe temperature was extended from 5issys perweekto once everv 92 ders.
| |
| cameses L Reimmeon etApptesheir N. R% of Surwesence Fsequency lit LCO stated in tenne of Trains rester tien osmponente W. Asowed ovenge Time esensen tem 24 hours to 72 hours
| |
| : v. Rossummen er Rasehed Adiene to ma M VL Resumeson at Survesence Rognement e creerte VW. - Reisenson of Agassed OuengeTune VNL ' Deleton of Requirement for 30 der Spedal Repost to PetC
| |
| | |
| TAIN.E L- MATIWK OF LESS fESTIWCTWE CHM 0GES SECTION 3.S, TLECT54 CAL PotVER SYSTEMS," page 6 of 7 Desemoeien of Dooeripean ITS Soeden CTS Secelen Catogery Cherastertenden 3.8 L11 The Survomence SR 3.8.6.2 4.6.3 N UmqueiaWi respect to Frequency forvertFying frequency detets only baneryces parameters vues extended frorn 31 j days to 92 days.
| |
| LCO 3.8.9, Tlecincel Disertsulion 0,1^1. W 3.8 L5 The time a5 owed for LCO 3.8.9 3.7.1 Vil Uniqueimigt re'pect to resma of an Requesd Acton aBoned outage time inoperstde AC electrical A.1 details only .-
| |
| powerdisertbusion system is extended tem no aAomed time to 8 hours and 16 hours frorn
| |
| ~
| |
| -- -: .x, of feBure to meet LCO.
| |
| L Reimm5en of Apptester.
| |
| N. Reimmeon of Sensomme Fsequency
| |
| : m. Lco sessed in tonne of Trame rusher sun componenh tv. Asowed outage Thne Edenalen som 24 hows to 72 hems
| |
| : v. Remesson of Rogused Actone to ese AppAceMay VL Reimagen of Sememence W W aemio I
| |
| VIL Reimmeon of h Outege Time VIs. Deisson of Requhement for 30 deF M Report to 95tC
| |
| | |
| TABLE L- MATRIX OF LESS RESTRfCTIVE CHANGES SECTION 3.8, " ELECTRICAL POWER SYSTEMS," page 7 of 7 Discussion of Description ITS Section CTS Section Category Characterization Change 3.8 L9 A requwement to test SR 3.8.9.2 Table 4.1-3, None Unique thermal trip d.a.ments of SR 3.8.9.3 ftem 18 molded case cwcust
| |
| : breakers is . .sced from i a surveiNance requirement.
| |
| canganes L Relazagon of Apptcebaty R. Reinaston of Survesence Fesquency M. LCO stated in terms of Trains rather 9m components IV. Agowed Outage Tone Extension from 24 hours to 72 hours V. Relouston of Requred Actone to estM VL Relexseon of Survesence Requrement acceptance creeds VII. Raamaden of Apowed Outage Trne VIII. Deleton of Requrement for 30 day Special Report to NRC
| |
| | |
| TABLE L- MATRIX OF LESS RESTRICTWE CHANGES SECTION 3.9, N OPERATIONS" page 1 of 10 Discussion 3f C; W J ;-i; ITS Section CTS Section Category Characterization Ct +
| |
| I LCO 3.9.1, " Boron Concentrabon" i II Unique with respect to 3.9 L1 The required frequency for DR 3.9.1.1 3.8.1 performing the sh surveillance frequency j
| |
| ; requirement to venty the detsits only L boron concentration in the pnmery cooient during refueling was relaxed from once per shift to once per 72 hours a
| |
| L Reem muun d Anr e W ear N. Re$mme nerSeaweenesFseguancy K LCO slueed h terms er Trains reener Wien asioenerte N. Anoused Otdeve Thie Edensten trent 24 hours to 72 hours
| |
| : v. - Mensemaner Reemed Aceans vt Reememen er suneennee Reesomere acespeance ere no vW. Roemenen er Amened Ouempe The vnt cessaan er Roememort for 30 day W Repet to NRC DL Reismuon er LCO Re,*emort
| |
| | |
| TABLE L- MATRIX OF LESS RESTR$CTIVE CHANGES SECTION 3.9,"REFUELWG OPERATIONS" page 2 of 10 Discussion of Description ITS Sechon CTS Section Category CharacL%
| |
| Change LCO 3.92, " Nuclear Instrumentation"
| |
| , 3.9 L5 The required schons for LCO 3.9.2 3.8.1 V Unique with respect to the condition when any of Requwed Achons requwed action details the refueling specdicahons A 2 , 8.1 and app 5catMty n
| |
| were not rnet were relaxed to apply only to the condition where both source ranges are inoperable Categories t Reisemen af Appecater.
| |
| : s. R.euemen et survemence Frespeney l Bt. LCO stated h terms et Trehe rumor tien components IV. Anomed Outage Time Eidwision trarn 24 hows to 72 heers V. Rosessenof Respeed Acsons vt Rosseman of Survemance Rogmemord @ creerte vfl Retmegenof AposedOutspeThis vm. o* mon er r : --_ .. ._ ser 30 day W Report to NRC DL Reiseson of LCO 7 - ; ^ ..._
| |
| | |
| TABLE L- MATRIX OF LESS RESTRICTIVE CHANGES SECTION 3.9, 'HEFUELING OPERATIONS" page 3 of 10 rune. aasi of Description ITS Section CTS Section Category Chorectorisation Change
| |
| ; LCO 3.9.3, " Containment Penetrahons" 3.9 L2 The requirements for LCO 3.9.3 3.8.1 IX Unique wies respect to
| |
| ; Closure of the Containment SpeCINCelport i equ, ment door were requnements or#
| |
| reiexed to requwe or$ four
| |
| : 8) boltsin piece rusher then as boets in piece as previaedr required Coseg m es I. Reimadan er M R. Redesullen er Senseente F squency lu. LCO eteled h tenne er Trehe regier sem coneeneren W. Asessed Oulege 7tne Deension tone 24 homes to 72 heiss
| |
| : v. Reemason er negubed Aconne VI. Relmussen er Senemonee Rosessened W aserte vu. Reemason er Asened Outege Time
| |
| *f.d. Detellen er Reearement for 30 der W Report to P2RC DL Roleeuilun er LCO Requbemord 1 I
| |
| | |
| TABLE L- MATRIX OF LESS RESTRICTNE CHANGES SECTION 3.9, N OPERATIONS" page 4 of10 Discuselon of Description ITS Section CTS Section Category Charactortantion CL +
| |
| Unique with resped to 1 3.9 L9 The requirements for LCO 3.9.3 3.8.1 IX f closure of containmerd Specdcahon penetrahons were relaxed requrements only
| |
| , from requinns an automshe volves to be operable or have atleast one valve in a penetrahon
| |
| : be closed to atleast one i manusi orautomsbe valve, I blind fienge or equivalent '
| |
| being closed.
| |
| The required frequency for LCO 3.9.3 3.8.1 It Unique with respect to 3.9 L7 .
| |
| performing the surveillance surveNiena frequency requwement to venfy the details ordy contanwners purge system was relaxed fmm prior to refueling operations to 18 months cosausnes L neinamen er Appscommy.
| |
| : s. Rossionen erSurvesence Ffogsency M. LCO alseed h tunns er Treams seener een eenpensees W. AAsumed OnAspe Time Edension tem 24 hours to 72 huese
| |
| : v. Reenmaaner neomed Acmens vt neemmesn er senemones noemenient -=p - we crearen VIL netsumlen er Assumed Outsg Theo e
| |
| ommsen er ne,* m e ser30 der .r=*e mapset is NnC vul IX. neemmeer'er LCO nogmemord ,
| |
| 4
| |
| | |
| TABLE L- MATRIX OF LESS REST 35CTIVE CHANGES SECTION 3.9,"REFUEUNG OPERATIONS" page 5 of10 h* of Descrip6on ITS Section CTS Section Category Chorectortestion Change
| |
| . 3.9 L8 The requirements for LCO 3.9.3 3.8.1 VI Unique with r'espect to
| |
| ! performing a surveNIance surveillance to verdy that each volve in requiremord l
| |
| I the mntainment vent and anuf dance crtene purge system actusses to the correct position were relaxed to permd the surveisance to be met utilinng an actual segneiin addihon to the currency required simuissed sensi consemas.
| |
| L neemseen erAppseemer-
| |
| : n. nessammen er sursemenee resquency III. LCO sisted In tenna er Trains easier tun conquenores '
| |
| sv. W ownse The Besnaian tem 24 hows to 72 heure
| |
| : v. neemmasa er noemed Acsons vi. nesmusan er seewmenoe p.,meniere e esenen vu. notsmaaner Asamed ouempoTime va psessen er negunemere ser 3D der s peem neport to NnC Ix. nonemaanerLeo Requesmere
| |
| | |
| TABLE L - MATRIX OF LESS RESTRICTNE CHANGES SECTION 3.9," REFUELING OPERATIONS" page 6 of 10 Discussion of Description ITS Section CTS Section Category Charactertantion Change 3.9 L3 The requrements for LCO 3.9.3 3.8.1 IX Umoue with respect to
| |
| , mentainmg contamment specnicaban
| |
| , purge penetrabon system requirements only operable when the system
| |
| : is not in opersbon were relaxed from requang one valve to be securely closed to requaing both contamment isolabon valves in the penetration operable m L R%orAppecalmy R. RedesNon of Surwawice Frapsuncy M. LCO sinend in terms er Truhs rueier Sun compimores IV. Amossed Oulage Time Estension Ipom 24 hours to 72 hours
| |
| : v. Reemanan or Required Adians VI. Releasion of Surwemence Regthemerg an-ye=noe aterte VII. RMcf AllousedOtAmpeTime ^
| |
| vm. Deken at Rapdremere for 30 der Special Report to NRC IX. R % ofLCO L - .. "
| |
| l l
| |
| | |
| m TAEK.E L-IRATRDC OF LESS RESTRBCTIVE CHANGES SECTION 3.9, N OPERATIONS" page 7 of 10 -
| |
| Discussion of Doocription ITS Section CTS Sec6en Category Characterization Chenes t
| |
| 3.9 L4 The requwed schons for LCO 3.9.3 3.8.1 V Unique witi respect to i the condihon when any of. Requwed Achons requwed action details the refueEng specdicehons A.1, A 2 -
| |
| ,j were not met were teamed 11 ~ to require that core i' allershons and rnovement ofirradiated fuel be suspended, rueier then to suspend as refueling opershons as was - -
| |
| . g :(
| |
| * veauwed cassonnes L neemumenafAppeceMay M. neemasonerSeeweennae Freguancy M. LCO acaded h tumus er Trebis resher Sun componeses .
| |
| ry. Aassed ouempo Tbne Edensian tem 24 hours to 72 hoess -
| |
| : v. neemassa er negumed Aceans vs. neemaman er seevemence neeemmest eeospennee aemen vu. neemmesnermesmesoueuseTime -
| |
| vs. osassen er noememuse ser 30 sesy spaces papest is NnC .
| |
| oc nesmamen erLe o nag eomose
| |
| | |
| TABLE L- REATRIK OF LESS RESTRBCTIVE CHANGES SECTION 3.9," REFUEL 90G OPERATIONS" page 8 of 10 rum .m.sans of Doncription ITS Section CTS Section Category Charactortsetion
| |
| : Change
| |
| * LCO 3.9.4, "RHR and Coolant Circulatoon44igh Water Level" 3.9 L6 The requwed schons for LCO 3.9.4 ' 3.8.1 V- Unsque with respect to t; . the condihon when any of Requesd Achons' requred schon detaAs i the refueling specificehons A.1 and A.2 were not met were retexed to require that core alterations and movement ofirradiated fuel be suspended, rather then to suspend air refuesing operations as was
| |
| ~:xwM L noemudlen erAppAustely.
| |
| : s. neemusun er Surusemico Fsessmity K LCO stated be tems er Tsubio sociar sem eeniponeres tv. Am==-s oissee The seensten som 24 home to 72 hours
| |
| : v. neemamaner negumed Acanne ,
| |
| vs. nesmusen er sunamunee negamenant e creerie vu. maammmenermomed ouempoThe vet oneseen er noseemere ser ao emy spades neport to NnC Ix. neemaman orLco negamemart I
| |
| | |
| TABLE L-MATRDC OF LESS RESTRICTWE CHANGES SECTION 3.9, *REFUEUNG OPERATIONS" page 9 of 10 Discussion of Description ITS Section CTS Section Category Characterization Change LCO 3.9.7, Tontaanment Purge Filter System"
| |
| ^
| |
| 3.9 L9 Requirements forisolation LCO 3.9.7 3.8.1, 3.8.2 V Unique with respect to of a containment purge Required Action required schon details system penetrabon when A.1 the system is inoperable were relaxed to include addibonal means of isolatron pnrnously not considered. The additenal means ofisolabon are a closed manual or automahcisolation vahre, blind flange, or an equivalent method that can provide a temporary a.w;c pressure and ventilation bemer caessones t Reemanon er.M II. Reinamun of Survenance Fsmiguancy ill. LCO stated in terms of Trains rusher fun corsquaneses IV. Asomed outsee Tbne Ezeension frorn 24 hours to 72 hours V. Retmuseon of Retphed Adians vi. ReineNon of Surweennee Requbumord @ crGute VII. Reematon of Aapsed Oulmpo Time Vill. Deereonof R4 ._; for 30 day Spedef Report to NRC IX. Reinmuon of LCO R;.,.' .-.2 l
| |
| | |
| TABLE L-MATRIX OF LESS RESTRBCTIVE CHANGES SECTION 3.9,
| |
| * REFUELING OPERATIONS" page 10 of 10 Discussion of Cw' h ITS Section CTS Section Category Charactortantion Change
| |
| . 3.9 L4 The requred schons for LCO 3.9.4 3.8.1 V Unique with respect to
| |
| ! the condsbon when any of Requred Achons requred schons that the refueling specdicshons A.1 and A 2 are deleted were not met were retaxed
| |
| ; to requre that core allerabons and movement ofimediated fuel be suspended, rather than to t
| |
| suspend all refueling opersbons as was -
| |
| prewously regured.
| |
| casearwe t neemuson er W.
| |
| R. Reineman er Surweennee Feupency IIL LCO stated b terms er Trshe refier Wien cangmaneres IV. Atened Outuge Time Edenmien Inim 24 hairs to 72 tours
| |
| : v. neemaman er Required Aceans vi. Reemaman or sunsannee cr - . _ : e creares VM. Reissenen er Atsused Oulmge Theo vnt cessaan er neemwnere var 30 der e += ** Repet to ##tc DL Retsuman er LCO Requiremert
| |
| | |
| TABLE L- RAATRIX OF LESS RESTRICTWE CHANGES SECT 10N 4.O W Features" page 1 of 1 Discusolon of Description ITS Section CTS Section Category Charactortassen
| |
| ;- Chene.
| |
| 4.0 "Desegn Features
| |
| * l f
| |
| 4.0 L1 Requinsments regenfing 42.1 5.3 None Unique witi respect to I
| |
| Design Features for the applicatWIity details
| |
| 'i reactorcore were a:~
| |
| expended to eBoWF for simded substituten of meer rods and limded use of leed test essemblies N
| |
| L Reiennon of Appicater N. Relesson of Sunmeence Frequency
| |
| : 31. LCO eteled in terms of Trains regier Wien componento N. ABovuod Outsee Tone Edensen groen 24 hours to 72 hours V. Reisuston of Requred Actone to ese Apptcelsely VL RelsusEos. of Survesence Requirement =msgeance crilsete VII.' Relasmeon of A8oused OutageTirne .
| |
| Vill. Deleton of R=c 1_. a for 30 day Spedal Report to NRC
| |
| | |
| l
| |
| , Discussion of Description TABOE L- MATRIX OF LESS RESTRfCTIVE CHANGES SECTION 5.0, " ADMINISTRATIVE CONTROur' ITS Section CTS Section Category Characterization page 1 of 6 Change Section 52, *Org.cholion" 5.0 L1 The pes;i;e6 of qualified Section 5.2.2 6.2.3 None Unque radiabon control technician was allowed to be vacant for two G) hours to provide
| |
| : for unexpected absence, provided immediate action is taken to fill the requred position.
| |
| 5.0 L2 The allowance for shift Sechon 5.22 6.2.3 None Unique w.i A6 661 to be one less than the mirwmum requremerit for two p) hours was relaxed to allow that the shift w w;ecr,ent can be less than the minimum requrement for two (2) hours c*w**
| |
| L Reiseennof Ap5 cater.
| |
| : n. Reisenen er Surveemnce Frequency 111. LCO stated h terme of Trains rulher than corrponents IV. A8oumf Oulage T1rne Entensen frorn 24 hours to 72 hones
| |
| : v. Reineman of Required Actlens to ed Apptcatsy VI. Retemmen of Surveemnoe Requerernent W cfterte Vit. Releeman of Aspeed Outage Tkne Vill Delegen of Requirement for 30 day Special Report to NRC
| |
| | |
| TABLE . L - MATRIK OF LESS RESTRfCTIVE CHANGES SECTION 5.0, "ADMNSTRATIVE CONTRO8E" page 2 of 6 Discussion of Description ITS Section CTS Section Category Chorectorization Change 5.0 L3 The requwement that the Socison 5.2.2 6.3.2 None Ureque MenegorW shall hold or have held a sensor roedoroperators licer:se for end HBRSEP ora
| |
| : similar pleM and that the Manager-shnt operations shall hold a se-jor operator limnse was reiexed to the ManagerW orthe suponrwendentin charge of ShiR Crews sheE hold a
| |
| : seniorreactoroperators license l
| |
| came==
| |
| L naamamen erAppsomesar
| |
| : n. neemaman er swasome.Fsegunney
| |
| : m. Leo semoed h imme er Teams esem een esmposes IV. Ammd Odeon TDne Essenehm tem 24 hows to 72 hows ..
| |
| : v. mer nogenes Acmens tose m vi. Reemaman er seveennee nequesnes e creenn Vit. nutmasse er Assued Ouenge Tbne vs. % or negunemere ser ao emy spaces nepet to nne
| |
| | |
| TABLE L- MATRIX OF LESS RESTRICTWE CHANGES SECTION 5.0 "ADepINISTRATNE CONTROLS" page 3 of 6 Discuomion of Description ITS Sectkm CTS Section Category Characterisation Change Sechon 5.3, " Unit Staff Qualificsbons" l 5.0 L4 The 7- 2nx.
| |
| ~
| |
| 5.3.1 6.3.3 None . Unique
| |
| .i , requirements forthe rnanagerof theredishon protechon funchon were relaxed fmm .;;;.w.c;r.g Reguistory Gun $e 1.8, September 1975, to ANSI /ANS 3.1-1961, which relaxes the exponence .
| |
| requwement from five (5)
| |
| .na to four (4) vears.
| |
| L Reimasoner W N. Reimadan er Swwomemoe Frogsuncy M. Lc0 stated in tonna er Trains scener seen casequenuds IV. Aw odass Tbne Edension tem 24 hours to 72 hears V. Raimusen er Requked Actone te sA AppAcetEBr vt Rdssenen er se e Amne. Regumamare e assets VW. Reemamen er Asamed OusepsTene VM. Desman er nogekomere ser 30 der w Report to NRC
| |
| | |
| v -< . . . . . . .
| |
| E TABLE L- MATRDC OF LESS RESTRICTIVE CHANGES SECTION 5.0, "ADINNISTRATIVE CONTROLS" page 4 of 6 Discussion of Description ITS Section CTS Section Category Charactertantion Change Sechon 5.6, "Reportant Requrements*
| |
| 5.0 L5 The due dele forthe Sechon 5.62 6.9.2.1 None Unique Occupational Radiabon 6.9.2.3
| |
| ;i Exposure Report was 4
| |
| relaxed frorn March 1 to f April 30 of rach year. The due date for the annual Radiological Envronmental Operahng Report was relaxed from May 1 to May 15 of each year. _
| |
| 5.0 L6 A specie' ,A requred Sechon5.G 6.9.1.2.1 None Unique when reactorcooient exceeds WE actreity limits was deleted l
| |
| l L Rahumann er Appecately.
| |
| E. ReimeGen er Swwesence Freepsency M. LCO etened h ierme er Treme romer 9 ers conveneres N. AAoused Ouence Time Ejeension hem 24 hews to 72 howe V. Rosenden et Requbed Actone to esE &ar*=May vt Reinemen er swveennee Re,*wnere =~=r e nee creerte VIL Refuseman er ABossed Odege Tkne vs. Deiseen er ;_ _. : sur 30 day Specist Report to NRC
| |
| | |
| TABLE L- MATRDC OF LESS RESTRBCTWE CHANGES SECTION 5.0 "ADMINISTRATNE CONTROLS" page 5 of 6 Discussion of Description ITS Sec6on CTS Section Category Characteriantion Cheng.
| |
| 4 5.0 L7 The requwemord for- Section 5.6.3 6.9.1.3 None Unque j.
| |
| ;i reportmg informehon in the i
| |
| Radioicgical Effluert
| |
| ,' Release Report was relaxed from tuna peryear to once a year.
| |
| 5.0 L8 The due date for the Sechon 5.6.4 6.9.1.4 None Unique mone# operahng report
| |
| . was reiemed from the 10th
| |
| ,! of the month to the 15th of .
| |
| ; the month I
| |
| Cseegertes L Reemosen er Appermler.
| |
| : n. Renommon er Surwomwice Fsegmener M. LCO eluded bi terme er Tusine regner Sisi componerte N. Agamed Oisspe Tbne Edensten tem 24 lemme to 72 foemen
| |
| : v. Reinamener negumes Aceanstome e 1 VI. Reinamen er Surwomenos Regubemord P esterte Vs. ReimasenerAsemed odese Tbne VNL Desseen er Regmement for 3D stor 't-ed Report to NRC
| |
| | |
| TABLE t.- MATR!X OF LESS RESTRICTNE CHANGES SECTION 5.0 "ADMINISTRATNE CONTROLS" page 6 of 6 rume.
| |
| * of C:: -"^"{. : ITS Section CTS Section Cologory Charactortsetion Change s
| |
| j, 5.0 L9 The due dele forthe steem Sec6on 5.6.8 4.2.1.3 None Unique
| |
| ; guerskr tut = insavice inSpeCbon report woS reiexed imm bewig
| |
| ; inesudedin the operasng Report forthe penodin which the inspechon was w 6%d to the Operating Report for the penod begrining aner the -
| |
| inspecbon was completed.
| |
| 5.0 L10 The requirement forthe Sedion 5.6 6.9.3.1 None Unique Containment Look Rate Test Report was deleted.
| |
| C8"U''**
| |
| L Reemmeoner M .
| |
| : s. Reimmeon er Surveaunce Fsequmey EL LCO cested h terms er Trains ressor Sumn esmpensen i tv. w ouempo Thee Estension tem 24 hours to 72 haws
| |
| : v. Reemmesn er Regumed Acmens toes e vt Reemmeen er senseannee Requhamsw e aemets vit. Reemmean erW Outage Tbne vnt oveseen er Reguteme1 for 30 day Specdul Rupert to NRC
| |
| | |
| TABLE RL-RELOCATEDSPECE9C4TERIMATRIK pseeIar51 CTS Doessiption General Location Change C3earacterisation Cherastadammen ITS & DOC Reference Centrees Type Reference 6.7.1.c,d,e' Safety Limit repothng Quakty Assurance 10 CFR 50.54(a) faminc=a==i of ITS 2.0 LA1 i+; -. iG Prtgrarn Descnphon reportng 1 (UFSAR Secton 17.3) ; _ . ~ _ . : r-;
| |
| ^
| |
| ITS 3.0 LA1 - 4.0 "Pnor to returang the Bases Bases Control % of systern to sorwce, Wie Program in ITS tashng dotads Secton 5.5.14 specdied cahtrabon and teshng survemance shes 3
| |
| be performed.-
| |
| ITS 3.1 LA1 3.10.6.3 and Shutdown Magpn Core Operahng Luvuts 10 CFR 50.50 PW of Figure 3.10-2, requwements for an ' Report (COLR) values inoperable fue longIh h witt [
| |
| :: - _. .;;e control rod ITS 3.1 LA1 3.10.8.1
| |
| * Shutdown Magpn - Hot COLR 10 CFR 50.50 Rotocahon of m .- % ,
| |
| h wist I
| |
| ;: . __e ITS 3.1 LA1 3.10.8.2
| |
| * Shutdown Magpn - Cold COLR 10 CFR 50.59 Relocahon of Shutdown" values l
| |
| , wini I i+; _..; G j ITS 3.1 LA1 3.10.1.4 "At 50% of the cycle as COLR 10 CFR 50.59 P % of l
| |
| defined by burnup, the proceduraldeemit lirmes shan be =tm to I the endd-core values i
| |
| as specdied in the COLR." t
| |
| | |
| TABLE 8tL-RELOCATED SPEQFIC-ITEM MATRIK page2 of51 CTS' Doocriphon General Locahon Change Charactertmetion Cherastertmaston ITS & DOC Reference Controls Type Reference ITS 3.1 LA2 3.10.1.3 "If bankinserhon is not Bones Bemes Control Raiocahon of restored to the W Prograrn in ITS details regenting Isruts" h reactorshed Sechon 5.5.14 hour requend
| |
| .1 be pieced in the hot shutdousn condeon schonis
| |
| ---,"_'M_
| |
| ]
| |
| utdiang normaloperahng procedures witun six hours
| |
| * ITS 3.1 R1 3.10.7 Resenchons placed on UFSAR 10 CFR 50.50 IMae= hart of pauper ramp rate - rnesiodology for foNouang a shutdoum reactorposser where core fuel cfienges assemtses have been handled .
| |
| ITS 7 2 LA1 3.10.2.1 Algonthms descntung the COLR 10 CFR 50.50 % of ,
| |
| limsts of Fa(Z) doecnpene [
| |
| infonnskon .
| |
| ITS 3.2 LA1 3.10.2.2: AlgonIhms descntung the COLR 10 CFR 50.50 Relocahon of I limsts of Fa(Z)witi core descnphvo l Penaltyfactor V(Z), mformation included ITS 32 LA2. 3.10.2.1 Algonthm descntung the COLR 10 CFR 50.50 % of -
| |
| .nds of em4. -
| |
| * ecnp e i, dor,ri. hon i
| |
| fec.or.and fec.or m - _ .. _-
| |
| - - 2. . - - .. i . -. - . ..>..........:-
| |
| | |
| c TABLE RL - RELOCATEE SPECIFIC-ITEM MATRIX pege3 of51 ITS & DOC CTS Description General Locahon Change Charactorttalion Characterization Reference Reference Controis Type ITS 3.2 LA3 3.10.2.11 Details concemmg the Bases Bases Control Relocahon of
| |
| ? redefinition of the axial Proyi-w in ITS desceptive flux target bands Sechon 5.5.14 mformabon and medxxfology 1 oeiaiis ITS 3.2 LA4 3.10.2.2.2 Details concemog the Bases Bases Control Relocahon of desenphon of Program in ITS desenpbve de'wmenmg Fo(2) from a Sechon 5.5.14 informahon and power distnbution map in methodology terms of measurement dotads and engmeenng factor 1 uncertainties, and Allowable Power Level ITS 3.3 lA1 2.3.1.2.d Details (AmcinTdag how Bases Bases Control Relocahon of the electronic dynamec Program in ITS descnphve compensation and delta - Sechon 5.5.14 informahon fluxinput to the r Overtemperature AT I Reactor Protechon System (RPS) function affects its setpoint ITS 3.3 LA1 2.3.1.2.e Detaas concommg how Bases Bases Control Relocahon of the electr nic dynamic Program in ITS descnpbve l i
| |
| compensation and delta Sechon 5.5.14 informabon
| |
| {
| |
| fluxinput to the Ove@c..c.- AT RPS '
| |
| function affects its setpoint 4
| |
| | |
| TABLE RL - RELOCATED SPECIFIC-ITERI ISATRIX page 4 of 51 ITs a poc cts poecription General Location change characterissaion Charactertsselon Reference Centrots Type Reference ITS 3.3 LA2 2.3.3 "The RCS narrow range Bases Bases Control RW of temperature sensors Prograrn in ITS toshng dotads response time shall be Sechon 5.5.14 l less than or equal to a 4.0 second lag constant."
| |
| iTS 3.3 LA3 3.10.5.1.b "The reactor shaN not be Bases Bases Control RW of made enhcal"...*unless Prograrn in ITS procedure dotads the reactor trip bypass breakers are racked os.4 Sechon 5.5.14 3
| |
| or removed "
| |
| ITS 3.3 LA4 Table 4.1-1, instrument channel Techrucal 10 CFR 50.50 Relocahon of Testeg Requrements. Re ,th Manual tests not requesd (TRM) to demonstrate operatnidy onsde cose Na= hon Manual (OOCM)
| |
| ITS 3.3 LA6 Table 3.5-5, Preplanned allemate Bases Bases Control Rh% of Note 5, method of monitoring be Program in ITS dotads avadable Sechon 5.5.14 concommg avadabildy of propionned anernate method of mondonna l
| |
| i
| |
| -s.,- - - - - - -
| |
| | |
| TABLE RL-RELOCATED SPECIFIC 4 TERA MATRIX page5or5I CTS Description General Location Change Character'& Charactortention ITS & DOC Controls Type Reference Reference iTS 3.3 LA7 Table 3.5-2 Control Rod TRM 10 CFR 50.59 % of item 15A. Misafegnment Mondor dotaded funchon as provided by requwaments the "ERFIS Rod Position Dewahon" feature and relahng to systems not
| |
| [ "
| |
| related ACT:ON No. 9. requred for operabihty or to i
| |
| maintain requesd i m es ITS 3.3 LA7 Table 3.5-2 , Control Rod TRM 13 CFR 50.59 RW of .
| |
| Item 158. Misabgnment Mondor detailed funchon as prended by requusments ,
| |
| the" Quadrant Power Tilt -
| |
| relehng to fL systems not i
| |
| - Monitor" and related ACTION No.10. requwod for operatukty orto masntain required hmds I
| |
| I i
| |
| l
| |
| .. . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . _ . . . . . . . . . . . . . _ . . _ . _ . = . . _ . . . . . . . . . . . . _ . . . . . . . . . . . . . . . . . . . , . . _ _ _ _ _ . _ _ _ _ . _ _ , . . _ . . _ . , , . . . . . . _ . . . . . .
| |
| | |
| b TABLE RL - RELOCATED SPECIFIC-ITEM MATRIX page 6 of 51 ITS & DOC CTS Description General Location Change Characterization Characterizabon Reference Reference Controls Type ITS 3.3 LA8 Table 4.1-1 Remark associated with Bases forITS Bases Control Relocation of item 4, RTD cross calibration SR 3.3.1.4 and Program in ITS testing detaas Remark (4) and Remark associated SR 3.3.1.12 Section 5.5.14 associated with testing of the RTB with RTD UV and shunt trips.
| |
| cross calibration and Table 4.1-1 Item 30, Remark (1) associated with testing of the RTB UV "
| |
| and shunt trips.
| |
| ITS 3.3 LA9 Table 3.5-1 The Functions
| |
| * chmnel UFSAR 10 CFR 50.59 Relocation of f items 6.a and action is " Trip normal descriptive 1 6.b supply breaker." information iTS 3.3 R1 Table 3.5-5 Requirements for the TRM 10 CFR 50.59 Specifications ,
| |
| item No. 3 RCS Subcnoling Monitor that do not meet and 12, Notes and Reactor Vessel 10 CFR 50.36 ,
| |
| i 2 and 7 Level Instrumentation criteria System (RVLIS) .
| |
| i
| |
| | |
| . TABLE RL - RELOCATED SPECIFIC ITEM MATRIX page7of51 CTS Description General I
| |
| * Change Charactertention Charactertmetion ITS & DOC Captrots Type' Reference Reference i- ITS 3.3 R1 Table 3.5-5 Requrements for the TRM 10 CFR 50.59 W
| |
| that do not meet ltem No. 7 Noble Gas Effluent and Note 4 Monstor- Main Steam 10 CFR 50.36 Line, Noble Gas Effluent cntens Mondor- Main Vent -
| |
| Stack -High Range, and Noble Gas Effluent Mondor- Spent Fuel PM Lower Level ITS 3.3 R1 Table 4.1-1 Teshng requrements for TRM 10 CFR 50.59 W that do not most ltem No. 38 the Noble Gas Effluent Mondor- Main Steam 10 CFR 50.36 Line, Noble Gas Efiluent cntena Mondor- Main Vent
| |
| - l--
| |
| Stack-High Range, and Noble Gas Effluent Mondor- Spent Fuel Pit Lower Level Table 4.1-1 Tesang requrements for TRM 10 CFR 50.59 Specdicahons ITS 3.3 R1 item No. 34 the RCS Subcoohng that do not meet and 48 and Mondorand Reactor 10 CFR 50.36 assocuded VesselLevel' cntens testing instrumentation System
| |
| * require- (RVLIS) m onts
| |
| ,..n. .
| |
| | |
| TABLE RL-RELOCATESSPECIFIC4TEREISATRIX pesesa(51 Description General Location Change Characterisation Characterisselon ITS & DOC CTS Controls Type Reference Refevence ITS 3.4 LA1 3.1.2.1.a "Over the temperature Bases Bases Control R% of range from cold Program inITS methodology for -
| |
| shutdown to hot Sechon 5.5.14 hoseup of reactor operahng condeons, the heatup rate shan not 1
| |
| aveaare 607 in any one -
| |
| hour."
| |
| ITS 3.4 LA1 3.1.2.1.b " Allowable comtunabons Bases Bases Control P % of of pressure and Program inITS methodology for temperature fora Sechon 5.5.14 W of specdic cocidown rate reactor and are below and to the right of the limit lines for desenpenm informanon 1
| |
| that rate as shown on
| |
| . Figure 3.1-2. This rate shall not exceed 1007thr in any one hour. The limit lines for coolmg rates between those shown in Figure 3.1-2 i
| |
| may be obhuned by
| |
| }.
| |
| 1 p
| |
| 1
| |
| | |
| TABLE RL - RELOCATED SPECIFIC-ITEM MATRIX pese9 or51 Change Charactortestion Charactortantion ITS & DOC CTS' C:41':-5 General i
| |
| * Controts Type Reference Reference iTS 3.4 LA1 3.1.2.1.c "Pnmary system Bases Bases Control Relocahon of hydrostaticleak tests Program in ITS toshng details may be performed as Sechon 5.5.14 necessary, provided the temperature intahon as '
| |
| _, noted on Figure 3.1-1 is r.ot violatei Mammum hydrostahc test pressure should roman below 2350a=ia" ITS 3.4 LA1 3.1.2.4.a Requwements for UFSAR 10 CFR 50.59 P % of maintaeneng the . detais pressure-temperature limit curves in TS Figures concommg mentasung RCS ]
| |
| 3.1-1 and 3.1-2 P/T curves ITS 3.4 LA1 3.1.2.4.b Reportmg requwements UFSAR 10 CFR 50.59 Relocsbon of of results of irr=*=8ad reporeng specamen samples requerements 2 anahsis and updated J heatup and cocidown curves ITS 3.4 LA2 3 1.1.1.a.1 The specWic 4% COLR 10 CFR 50.59 P W of shutdown magpn when < values 2% Rated Thermal assocsated with Power (RTP) and < 2 requrements reactor coolant pumps aaaratmo
| |
| | |
| -TABLE RL-RELOCATESSPECIFIC-4 TEM MATRIX page10 of51:
| |
| CTS- Description General Location Change Charactertuation Characteriaalien ITS & DOC Type Reference Rowence Contrets 3.1.1.3.a "At least one Pzr code TRM 10 CFR 50.59 Relocaten of ITS 3.4 LA3 -
| |
| safety valve shaN be dotaded operable whenever the sogarements Reactor Head is on the relahng to vessel and the RCS is systems not I not open for . requred for operabsty or to ;
| |
| h maintenance."
| |
| maintain requred limds 4.2.4.1.a Requremord that each TRM 10 CFR 50.59 Relocaten of ITS'3.4 LA4 Pressunzer Power detals Operated Relief Valve concommg testmg methology (PORV) be demonstrated operable by performme a not required for channel cahbrahon at operabety each rdW ,
| |
| 4.2.4.3 Requwement to - Bases Bases Control Reloc.'eion of j.
| |
| ITS 3.4 LA4 demonstrate that the Program in ITS . details t concommg I ^:
| |
| ndrogen accumulators Sechon 5.5.14 - 7 for the Pressunzer teshng "j d PORVs are operable by methodology cychng the PORVs 1 through one complete ce at each rer -Ma ~I
| |
| :1
| |
| ~l
| |
| | |
| TABLE RL - RELOCATED SPECIFIC-ITEM MATRIX page 11 or51 ITS & DOC CTS Descriphon General Locahon Change Characterization Characterizabon Reference Reference Controls Type ITS 3.4 LAS 3.1.5.4.a Requrement that all Bases Bases Control Relocahon of pressureisolation valves Program in ITS desenptive listed in Table 3.1-1 be Sechon 5.5.14 details funchonal as a pressure concerning isolabon device except operabehty as speedied in TS Sechon 3.1.5.4.6 ounng reactor operation and hot shutdown coiMi;0ns ITS 3.4 LAS 3.1.5.4.b The compensatory Bases Bases Control Relocahon of measure for a non- Program in ITS descnptive funchonal pressure Sechon 5.5.14 dotads isolabon valve; Wanual assoosted with valves shall be locked in talung a requwed the closed position." achon ITS 3.4 LAS Table 4.1-3 Requrement to perform Bases Bases Control Relocahon of item No.17 Pnmary Coolant System Program in ITS detads l check valve tests after maintenance, repair or Sechon 5.5.14 associated with post
| |
| ] i l
| |
| replacement work is maintenance performed testing to declare operabekty
| |
| )
| |
| l
| |
| | |
| TABLE RL - RELOCATEDSPEC2FIC 4 TERE BRATRIX page 12 of 51 '
| |
| CTS ~ C:: 2;"s General 8 e% Change Characterisation Charactortmotion ITS & DOC -
| |
| Reference Controts Type Reference .
| |
| ITS 3.4 LAS Table 4.1-3 Allowance that Pressure Bases Bases Control R W of item No.17.1 Isolabon Valve (PlV) Program in ITS details Note a. leakage may be hee-wi 5.5.14 concomme measured'm drectlyif testag accomphshed in methodoigy accordance with approved procedures and supported by computshons showng that the method is capable of demonstrahng valve leakage comphance iTS 3.4 LAS Table 4.1-3 Muumum test dWierenhal Bases Bases Control P W of item No 17.1 pressure for PlVs shall Program in ITS dotads Note b. be 2150 psid. Secton 5.5.14 concommg testeg methodoiny I ITS 3.4 LAS Table 4.1-3 -- A50wance that more Bases Bases Control P % of.
| |
| Item No.'17.1 than one PlV may be Program in ITS dotads Note c. tested in parallel Sechon 5.5.14 - amcomme ^
| |
| provided the total - testeg leakage does not exceed methodoigy 5opm-ITS 3.4 LAS Table 3.1-1 Listing of safety injechon Bases Bases Control P % of-system PlVs Program in ITS desenptwo Section 5.5.14 :;ystem Jl udormahon 1
| |
| | |
| TABLE - RL - RELOCATED SPECIFIC-ITEM MATRIX page 13 or51 CTS Description General Locahon Change Charactonastion Characterization ITS & DOC Type Reference Reference Controls Table 4.1-2 Requwement to perform - TRM 10 CFR 50.59 Relocahon of iTS 3 4 LA6 item No.1 reactor coolant details radeochemical test on a concommg montt@ frequency teshng methology not requwed for operabildy Table 4.1-2 Requwement to perform TRM 10 CFR 50.59 Relocabon of ITS 3.4 LA6 item No. 2 reactor coolant boron details concentration test on a tecehveek frequency concemog teshng methology Q
| |
| not requwed for operab*ty .
| |
| Table 4.1-2 Description of a gross Bases Bases Control Relocahon of ITS 3.4 LA6 activity analysis. Program in ITS details Note (1)
| |
| Section 5.5.14 concemeng j teshng methodolay ,
| |
| Table 4.1-2 Description of a TRM 10 CFR 50.59 Relocahon of ITS 3.4 LA6 radiochemecal analysis details Note (2) concemog !
| |
| teshng t methodoigy ITS 3.4 LA7 Table 4.1-2 Requirement to perform TRM 10 CFR 50.59 Relocahon of .,
| |
| H item No. 4 Boric Acid Tank boron details concentration test on a concemeng teceAveek frequency testing methology not requwed for operetnPtv I l I
| |
| | |
| - TABLE RL - RELOCATED SPECIFIC 4 TERR RSATRIX page 14 of 51 '
| |
| CTS Description GeneralI % Change Characterization CharactertsaAlen ITS & DOC Reference Controls Type Reference ITS 3.4 LA8 Table 4.1-3 Requrement to perform TRM. 10 CFR 50.59 R W of item No.14 RHR compartment fan dotads funchonal test and concoming teshng methology laboratory tests of filter media on a once per not requwod for operahng cycle operainity fr m ITS 3.4 LA9 - Table 4.1-2 Requrement to posform TRM 10 CFR 50.59 R W of.
| |
| Item No.10 S/G samples 5 details dept = concomme testag methology 3
| |
| not requwed for operatukty ITS 3.4 R1 Table 4.1
| |
| * Requirement to sample TRM. 10 CFR 50.59 R % of item No.1 the reactor coolant details system for Chionde and concommg Oxygen on a frequency testeg melhology of 5 tunes perweek not requwed for operatnhty ITS 3.4 LA10 Table 4.1-2 Requrament to sample ,ODCM ODCM in ITS Ph=a==i of Stack Gas lodme and S echon 5.5.1 details Note (3)'-
| |
| Parbculate on a weeldy concommg .
| |
| bases when iodme or Radelogical parboulate radioactivity . Efiluent levels exceed 10% of the Technical limit in TS Section Specdicahons 3.9.2.1, the sampling samphng frequency shan be increased to a minimum of once per day ,
| |
| I
| |
| | |
| i
| |
| 's TABl.E ' RL - RELOCATED SPECIFIC 4 TEM BRATRIX Pese 15 or51 j
| |
| ; ITS & DOC CTS- P- - ~ '' i General Lc.,ation Change Cherectortention Characterination Reference Reference Controis Type" ITS 3.4 LA11 3.2.1 Requirement for an TRM 10 CFR 50.59 RW of 1 anpochon flow path and detaled ;
| |
| boric acid equivalent to requwements
| |
| . that supphed from the relatmg to RWST in au piant systems not :
| |
| condsbons with fuelin the requwed for / ,
| |
| vessel operatuhty or to (
| |
| mantan required i m es i i
| |
| i ITS 3.4 LA12 3.2.2.b,c.e, & Requwements for boric TRM 10 CFR 50.59 R% of f acid transfer pump, bonc , dotmied j
| |
| , acid tanks, heat tracing requwements !
| |
| and pomary water reichng to r t storage tank systems not l
| |
| ' - requwed for i ,
| |
| operstmhty or to ,
| |
| manten requwod :
| |
| hmsts l.
| |
| ITS 3.5 LA1 3.3.1.2.e .M exclusion of the Bases Bases Control Relocaleon of j' safetyinpochon hot Program in ITS MM ; !)
| |
| injection pathways and Sechon 5.5.14 ' requwements i f valves from the relanno to 4 :
| |
| requwements of TS systems not 4 Sechon 3.3.1.2 requwed for J operatniity or to y masntaen requered l[
| |
| i m es 1 o
| |
| i i
| |
| | |
| TABLE RL-RELOCATEESPECIFIC-ITEM MATRIX page 16 of 51 CTS Description General Location Change Characterizabon Characterization ITS & DOC Type Reference Reference Controls 3.3.1.1.c, d. Details of ECCS Bases Bases Control Relocation of ITS 3.5 LA2
| |
| * Program in ITS system e, & f Operabelity Sechon 5.5.14 desenpteon [
| |
| details 1.7.a Details specifying non- Bases Bases Control Relocahon of ITS 3.6 LA1 automatic isolaton Program in ITS details valves be closed and Sechon 5.5.14 concemog methodology for g
| |
| blind flanges be property installed meeting requirements 4.5.1.3 "The test shall be Bases Bases Control Relocation of ITS 3.6 LA2 l performed with the Program in ITS details isolation valves in the Sechon 5.5.14 concemang spray supply lines at the testing containment and spray roethodoigy additive tank blocked closed."
| |
| 1.7.d " " Manual valves qualifying Bases Bases Control Relocation of ITS 3.61.A3 as automatic Program in ITS details containment isolation Sechon 5.5.14 cors=Tiirg valves are secured methodology for closed." meetog reqmrements )l 3.6.4.3 Details of testing of 42 Bases Bases Control Relocation of iTS 3 6 LA4 inch purge valves Program in ITS details Sechon 5.5.14 concemmg testing methodology
| |
| .__._._____m
| |
| | |
| TABLE ' RL - RELOCATED SPECIFIC-ITEM MATRIX page 17 af 51 General Location Change Characterization Charactortanteen ITS & DOC CTS C::: ~f' +. Type Reference Reference controls ITS 3.6 LAS 1.7.d " "All automahc trip valve Bases Bases Control R % of requwed to be closed Program in ITS dotads dunng acodont Sechon 5.5.14 concermng conditions are operable methodology for or are secured closed." meshng requwements 1.7.b .* Equenent dooris Bases Bases Contml Relocahon of ITS 3.6 LA6 propedy closed and ' Prograr's in ITS dotads sealed
| |
| * Sechon 5.5.14 concermng 1.7.c
| |
| * Bases methodology for -
| |
| At least one doorin the mechng personnelairlockis requwsments property closed and sealed -
| |
| 3.3.5 "The reactor shaN not be TRM 10 CFR 50.59 Relocahon of 4 ITS 3.6 R1 i made enhcal unless the detaded valves of the post requwements l-acodont containment relahng to :
| |
| venhng system are systems not' :
| |
| operable." requwod for ,
| |
| operabsty orto ,l m requwod limits Table 4.1-3 Requwement to check TRM 10 CFR 50.59 Relocahon of q ITS 3.7 LA1 ltem No.12, closure of Turtune Steam dotads l Stop, Control, Reheat concermng Stop, and interceptor teshng not valves on a quartedy requwed for ;
| |
| operabsty !
| |
| fem I
| |
| i
| |
| | |
| ...,, , ~
| |
| TABLE . RL - RELOCATED SPECIFIC-ITEM RSATRIX pese Is of 51 '
| |
| CTS Description GeneralI e% Change Characterisation Charactertantion ITS & DOC .
| |
| Reference Controis Type l Reference ITS 3.7 LA2 3.13.1.a Requirement that when TRM 13 CFR 50.59 % of the reactoris at power or -M gn hot shutdown,if a details schis determned to concameng be inoperable and an components that '
| |
| engmoenng evalualson support cannot validate the operatdty operatzhty of the '
| |
| supported component then the supported component shad be .
| |
| declared inoperable. If '
| |
| 1 operately can be validated then the snubber shaN be retumed to operable j status withen 72 hours ITS 3.7 LA2 3.13.1.b "If a snubberis TRM 10 CFR 50.59 R h =8=m of ?!
| |
| determened to be testeng details il moperable whsie the conco mrg reactoris in cold componais that ;
| |
| shutdown, the snubber (if support ;
| |
| needed for a supported . operatety U,
| |
| component protection) shot be repaired and . [
| |
| reinstalled or replaced g prior to reactor startup
| |
| * i;
| |
| ''a '- - ' ' ' ' '' ''''% - - '"'''M ' ' ' ' '' ' ' ' "' ' -
| |
| ' - '1 ' ' ' I''''''''i-
| |
| ''IM' ' '- '"'- 2--''''- - ' ' - - ' - ' " '' -"
| |
| . . . . . . , . . . .-- ..' ' - ' ' ' ' - - ':''J- '' - " *'"''''''''*'--~"""""'"-''"-''''''''"'''T
| |
| | |
| TABLE RL-RELOCATEDSPECIFIC-ITEM MATRIX page 19 of 51 ITS & DOC CTS Description General Location Change Characterization Characterization Reference Reference Controls Type ITS 3.7 LA2 4.13 SnubberTesting TRM 10 CFR 50.59 Relocation of Requirements testing details conceming components that support operatety IT3 3.7 LA3 4.15.a . Requirements to verify TRM 10 CFR 50.59 Reloca%n of Control Room air details temperature every 12 hrs cor ccining testing not required for operatety
| |
| !TS 3.7 LA4 5.4.3 "This minimum boron UFSAR 10 CFR 50.59 Relocahon of concentration ensures details subenticality underworst concerning case design events," and methodology for references rneeting requerements ITS 3.7 LA5 3.12 Seismic shutdown TRM 10 CFR 50.59 Relocation of descriptive achons and procedural detail assooated with a seismic event ITS 3.7 LA6 5.4.2.1 New Fuel Storage Rack UFSAR 10 CFR 50.59 Relocation of secured location system '
| |
| restnchons description details
| |
| | |
| TABLE RL-RELOCATESSPECIFIC-ITERA REATRIX pase20of51 CTS Description General Location Change Characterisation Characterisation ITS & DOC Reference Controis Type Reference ITS 3.7 LA7 CTS 4.8.1 Requirements to test inservice Teshng 10 CFR 50.5g P % of and 4.8.2 AFW pumps monthly Program details concenung toshng not e requwed for l
| |
| operabihty
| |
| , ITS 3.7 LA8 CTS 4.12.3 Requwement to mondor TRM 10 CFR 50.59 P % of
| |
| ! relative humiddy of air. details processed by spent fuel concomme venhishon porhon of the _ _
| |
| seshne not Refuehng Fdter System requwod for operatzhty ITS 3.8 LA1 3.7.1.d Descriphon of specdic Bases Bases Control Relocahon of ,
| |
| automate trips that are Program in ITS system , l-requwed to be bypassed Sechon 5.5.14 desenphon j for an operable dotads i Emergency Diesel ,
| |
| Generator (EDG).
| |
| ITS 3.8 LA1 3.7.2.e and Desenphon of specife Bases Bases Control P % of 4.6.1.3 automahc trips that are ' Program in ITS system requwed to be bypassed Secton 5.5.14 - descnphon for an operable EDG. dotads (As referenced to CTS 3.7.1.d) 1 l
| |
| . -, , , , . - .-ing.-.--l ,
| |
| .,--.---i.---, . , , ,
| |
| g,, - ,. a i,. . .i....iis- -
| |
| -...-.s-'1.---m.- .
| |
| -.s-- - . . - .c --, . .- ... .._ -.- . - .,.. .....i.
| |
| ....h.c.- .. - ... . ...- :-...- ........i._., .
| |
| | |
| Y j
| |
| TABLE RL - RELOCATED SPECIFIC-ITEM MATRIX page 21 of 51 CTS Description General Location Change Characternation Characternatson ITS & DOC Type Reference Reference Controls 3.7.3 Restriction allowing the Bases Bases Control Relocaten of iTS 3.E LA2 back-feeding of the Program in ITS detaded emergency busses via Section 5.5.14 requirements the unit auxiliary relating to transformer only while systems not the reactoris in cold required for shutdown unless nuclear operability or to safety considerations maintain required require it to be done limits during hot shutdown 4.6.1.3 Details describing how Bases Bases Control Relocation of ITS 3.8 LA3 the testing of the EDG Program in ITS details l
| |
| automatic trips " trips Section 5.5.14 concemog defeat" feature is testing methodology i
| |
| l accomplished 4.6.1.3 "Each diesel generator UFSAR and TRM 10 CFR 50.59 Relocation of l ITS 3.8 LA4 shall be inspected at details l
| |
| ! least once every conceming ;
| |
| refueling interval." testing ,
| |
| l methodology : i 4.6.1.4.a Details describing the Bases Bases Control Relocation of ITS 3.81.A5 continuous load limits of Program in ITS details _.
| |
| the EDGs and restriction Section 5.5.14 conceming preventing the testing continuous operation of methodoigy the EDGs above these limits i
| |
| | |
| TABLE RL-RELOCATEIISPECFIC4 TERE ISATRIX pese 22 of 51 <
| |
| CTS Description General Location Change Characterization Charactorination
| |
| !TS & DOC Reference Controls Type Reference ITS 3.8 LAS 4.6.1.4.b Dotads desentung the Bases Bases Control P % of:
| |
| short-term load Prograrnin ITS details Imtabons of the EDGs Sechon 5.5.14 concommg testeg and restnchon prevenhng ,
| |
| the operabon atme this mottododgy simit ITS 3.8 LAS 4.6.1.5 Dotada desentnng how Bases Bases Control P% of the EDG is started and Program in ITS dotads synchronued to the bus - Secton 5.5.14 concommg in preparabon for the 24 teshng hour fullload test melhodoler ITS 3.8 LA6 Table 4.1-2 Items No.11 and 12 Bases Bases Control R % of '
| |
| dotads of EDG fuel oil - Program in ITS descnpleve teshng (tanks to wluch teshng requerements Sechon 5.5.14 - dotads
| |
| }
| |
| L
| |
| %)
| |
| ITS 3.8 LA7 . 4.6.3.2 Dotad descntnng the Bases Bases Control Ph% of processon at whsdi the Program in ITS dotads ,
| |
| cell voltage must be Sechon 5.5.14 concommg !.
| |
| detemuned and the testmg requwament that the methodology amount of water added to each cell be measured and recorded 1
| |
| 'l l
| |
| | |
| w TABLE RL-RELOCATEDSPECIFIC-ITEM MATRIX page 23 c(51 -
| |
| CTS E: f' ; '
| |
| General Locatsore Change Characterization Characterisation ITS & DOC Type Reference Reference Controis ITS 3.8 LA7 4.6.3.4 Requrement that when Bases Bases Control Paancmanwi of battery data is recorded. Program in ITS dotads the new data shall be Sechon 5.5.14 concommg compared to prewous toshng data in order to detect methodology signs of abuse or -
| |
| detenoration.
| |
| ITS 3.8 LA8 3.7.1.s and Regankng 110 KU-4160 Bases Bases Control P% of 3.7.1.c V startup transformerin Program in ITS system .
| |
| i serwce and 4160 V Sechon 5.5.14 desenphon buses 2 and 3 enereiM dotads ITS 3.8 LA9 3.7.1.b Regardmg 480 V buses Bases Bases Control P W of
| |
| * E1 and 2 energued Program in ITS system Seceson 5.5.14 desenphon -
| |
| dotads ITS 3.8 LA10 3.7.1.e Regardmg detads of the Bases Bases Control PW of '
| |
| battenes and battery Program in ITS system f charger Sechon 5.5.14 desenphon '
| |
| m ITS 3.9 LA1 3.8.1.f Reference to specsc _ COLR 10 CFR 50.59 Rh% of boron concentrabon of values 1950 ppm to be assocseted with 1 mantained dunng head requerements
| |
| * removal or movement of .
| |
| fuel ~m the reactor 1
| |
| i 4
| |
| ...-..i-..........,.-.. -
| |
| . . ..- ..............c..
| |
| ......iil,,.,..._;..--r - -
| |
| i s. ..:......,-._..s.-.o
| |
| | |
| TABLE RL-RELOCATEDSPECIFIC-ITEM MATRIX pese24 af 51 CTS Description General Location Change Characterisation Characesetuation ITS & DOC Type Reference Reference Contrais ITS 3.9 LA2 Table 4.1-3 Requwement to test TRM 10 CFR 50.59 R W of item No. 6 refuehng system dotads interlocks prior to each concemsig /
| |
| refuehng system . teseng not (fs shutdown requesd for I i
| |
| operstmey ITS 3.9 LA3 3.10.8.3 "When the reactoris in COLR 10 CFR 50.59 R W of values I the cold shutdown constion, the shutdown assoanted wish margin shall be a least 1 requwaments percent Ak/k."
| |
| ITS 3.9 LA4 3.8.1.d Requrement that ' Bases Bases Control R W of whenevercore geometry Program in iTS dotads is being changed that the Sechon 5.5.14 concemwig source range channels provide " continuous methodology for meetng {r '
| |
| visualin& cation in the requrements L control room and one with =whhia indicehon avadable in the -
| |
| cost ic.i-at" ITS 3.9 LA6 3.8.1.e Requirement that dunng TRM 10 CFR 50.59 Ph=8-wi of refueling operations, T., dotaded .f sh . he ,na.,ia.ied ,equire,,,onts s 140" F reichng to systems not requesd for operabinty or to maintain requwed s m ts
| |
| | |
| TABLE RL-RELOCATEDSPECIFIC-ITEM hiiATRIX pese25 af 51 ITS & DOC CTS Description Genemi Location Change Charactortuation Charactertuotion I controls Type Reference Reference ITS 3.9 LA7 3.8.1.h "Movemant of sust wittun TRM 10 CFR 50.59 P % of-detailed
| |
| ' the core shall not be mutisted prior to 100 ' requsements hours after shutdown." relating to systems not requesd for operabitty or to maintain requesd iimes ITS 3.9 R1 3.8.1.c Requirement that dunng TRM 10 CFR 50.59 R W ,does refueling operations not most 10 CFR Pe=em levels in the 50.36 cnione contasnment and spent ~
| |
| fuel storage areas shall ;
| |
| . be morutored .---
| |
| continuously - .- j.
| |
| ITS 3.9 R1 3.8.1.g Requirement that TRM 10 CFR 50.59 .Pt W M ,does whenever core geometry ."
| |
| not meet 10 CFR is being changed, detect 50.36 cntena not.een ihe co,* oi ,d i room and the refueling }l ll cavity shau bemanspulator avadable crane . l - :l G
| |
| L-- - - - . _ - .
| |
| | |
| e
| |
| . TABLE RL - RELOCATE 5 SPECIFIC-ITEM MATRIX - pese26 o(51-ITs a poC cts- Desertption GeneraD % Change Characterization Characte4mmelen Refe ence Reference Controls Type-ITS 4.0 LA1 5.1- Species desentung the UFSAR 10 CFR 50.59 . Phm of locahon of H. B. details Rotunson Steam Elechic concurrung Plant (HBRSEP), Unit locabon of plant No. 2 in reishon to HBRSEP 'Jnit No.1 and - E~
| |
| the fact that L%t No. 2 is owned and operated by i Caronna Power & l.ight Co. In addden the statement desentung site exckmon boundary (per -
| |
| 10 CFR 100.3) as tunng a cucie of1400 ft radmas from the reactorconter line. l ITS 4.0 LA2 5.3.1.1 Speedics descntung the UFSAR 10 CFR 50.59 Relocahon of ' i reactor core i.e. system "approxunately sa meine desenphon tons", fuel rods 'Which details , i I
| |
| are pre pressurized,"and 'l fuel assemtdies each [ ]
| |
| contaen "204 fuel rod locations occagned by ,
| |
| rods consashng of natural j or shghtly annched urannam pellets, solid inert matenals, or a comtunahon of the N .
| |
| ++
| |
| - :----'----- l u- - - , . - . - - --.:- --- -- -- - - - -
| |
| .- - .- .. -.4 .
| |
| ------.---------u - . - - . . + -. . i.. -t
| |
| -.m
| |
| | |
| page27 of 51 TABLE RL- RELOCATEDSPECIFIC-ITEM MATRIX j General Location Change Characternatson Charactonandon ITS & DOC CTS Description Controis Type l Reference Reference Descnptive dotads of - UFSAR 10 CFR 50.59 Relocahon of ITS 4.0 LA2 5.3.1.3 system reload fuel 7 I-detads Design code UFSAR 10 CFR 50.59 Relocahon of ITS 4.0 LA2 5.3.2.1 requrements of the RCS system desenphon detads i Desenptive information UFSAR 10 CFR 50.59 Relocahon of ITS 4.0 LA2 5.3.2.2 concommg the pgang system ,
| |
| and components of the desenphon .l RCS meet Amencan dotads Society of Mecharucal L Engmeets (ASME) Boder ,
| |
| l and Pressure Vessel l Code (B&PV) Class l '
| |
| r-4(rsits Desenptsve information UFSAR 10 CFR 50.59 Relocahon of l ITS 4.0 LA2 5.3.2.3
| |
| * concemog the nomenal system i volume of coolant desenphon '
| |
| detads contamed in the RCS at rated operatmg cc,r- % xis )
| |
| . = _ . _.
| |
| | |
| ~ g TABLE RL-RELOCATEDSPECIFIC4 TEM MATRIX pese2s ar51 -
| |
| CTS Description General Location Change Charactoriantion Characterisation ITS & DOC Reference Controis Type Reference 5.4.1 "The new and spent fuel UFSAR 10 CFR 50.59 - Panar= hart of ITS 4.0 LA3 pit structures are system desagned to vnthstand desenpten the anhcapated dotads earthquake loadmgs as ASME B&PV Code Class .r i structures. The spent fuel pit has a stamiess t steelliner to ensure est loss of water."
| |
| 5.4.2.1 Detads desenbeg UFSAR 10 CFR 50.59 Relocahon of ITS 4.0 LA3 features of the new fuel system storage facdebes that desenphon mantam K, <0.95 dotads 7
| |
| . assummg the racks are flooded with pure water ,
| |
| i.e.," adddional -l' separation is masntamed by use of the storage rack secured locahon restnchons". "m~ orderto establish a geometry which ensures that.. "
| |
| | |
| TABLE RL-RELOCATEDSPECIFICMEMIRATRIX pese29 af'51 I
| |
| Description General I ~% Change Charactortantion Charactonsation ITS & DOC CTS Controls Type Reference Reference ITS 4.01.A3 5.4.2.2 Dotads descntung UFSAR 10 CFR 50.59 R W of features that mentam K, system i
| |
| less than 0.95 in the desenphon t
| |
| spent fuel pool i.e.,"a dotads comtunation of nommal assemt@ specmo, . I neutron absorber matenal between the - L assemtdes, and restnchons on fuel design, integral bumable absorber content, reconstdubon, and storage is required to :
| |
| assure that..."
| |
| ITS 4.0 LA4 5.2.1.1 Desenpteve informahon UFSAR 10 CFR 50.59 Rh% of concemeng the purposes system desenphon b :
| |
| of the contamment h% dotads {l Descnptive informahon UFSAR 10 CFR 50.50 P W of l4 ITS 4.0 LA4 5.2.1.2 -
| |
| concemog the desson system [,
| |
| pressure rahngs of the descnphon g ;4 contammerd h% dotads !4 ITS 4.0 LA4 5.2.2.1 DessiFt informahon UFSAR 10 CFR 50.59 RW of concoming the desegn of system desenphon U the contamment i penetrabons for electncal dotads and mechanecal systems
| |
| | |
| ~
| |
| -TABLE RL-RELOCATEDSPECIFIC-ITEM MATRIX :page30of 51 CTS Description General Location Change Characterization Characterisation ITS & DOC Reference Controls Type Reference ITS 4.0 LA4 - 5.2.2.2 Desenptive informahon UFSAR 10 CFR 50.59 P % of concorrung the Phase A system and Phase B descnphon contenment isoishon detaes segnals and the fact that f
| |
| they rnust be capable of withstandmg a sogie -
| |
| component fadure and stiu mawwan contanment I- P, isolabon ITS 4.0 LA4 6.2.3.1 Desenphve informahon UFSAR 10 CFR 50.59 Re W of concommg the system contanment spray desenphon ,
| |
| system and its purpaea dotads Relocahon of l'
| |
| ITS 4.0 LA4 5.2.3.2 Desenphve informahon concanno the UFSAR 10 CFR 50.59 system i j contanment intemal air desenphon 3 recwculabon system and detmis its heat removal
| |
| . =.. .e=i s
| |
| ,l
| |
| .i
| |
| _,_.l
| |
| =. . . , . . . . . . . . . _ . . . . . . , . . . . . . . . . _ . . _ . . . . . . . . . . . . . . . . . . . . . . . . . .
| |
| | |
| ET A
| |
| TAEBLE RL- RELOCATED SPECRC4 TERE REATRIK pec31d51 CTS Deecription General Locatsen Change Characensimmten Chesacterfambien ITS & DOC Reference Reference Centrols Type ITS 4.0 LAS 5.5 Descriptwo wWormahon UFSAR 10 CFR 50.50 Relocahon of concommg the desgn of system the containment buildme, desenphon maahary buiktng, ASME detsds B&PV Code Class i - f tutune boy, and as contamed EW Safety Feature (ESF) systems be desoned for a mnemum credele earthquake with an aN of 0.20 g ,
| |
| ITS 4.0 8,A6 1.19 Defineon of Site '- UFSAR 10 CFR 50.50 % of details I Boundary and Figure 1.1-
| |
| : 1. Plant Site Boundary concomme .
| |
| and Fursaeari Zone." locahon of plant ITS 5.0 LA1 6.5.1.1.2 .t ; -. wee Quakty Assurance 10 CFR 50.54(a) % of concommg how safety Program Desenphon ademisershve analyse shaN be detags (UFSAR Seckon 17.3) propened foran procedures, ksts, and expenments covenne procedures ksenediedin TS Sochon 6.5.1.1.1 and procedures tiet asect nucisar safety
| |
| | |
| ' TABLE RL-RELOCATEDSPECFIC4TERIIIATRIK page32of5I Description General Location Change Charactedmation Cherastedessen ITS & DOC CTS Centrols Type Reference Reference ITS 5.0 LA1 6.5.1.1.3 Requwements Quality Assurance 10 CFR 50.54(a) % of concenung when a Program Desenphon admrustratwo second safety rewour (UFSAR Seckon 17.3) details shot be performed on procedums affectng rmw4aar safety 6.5.1.1.4 Requwoments for QuaktyAssurance 10 CFR 50.54(a) Relocahon of '
| |
| ITS 5.0 LA1 approvalof procedures Prograin Descnphon admmetrahvo that do notinwohe an (UFSAR Seckon 17.3) deemts unrenound safety g queston as doginedin 10 CFR 50.59 nor a change to Wie TS 6.5.1.1.5 W ^ _c_s Quatty Assurance 10 CFR 50.54(a) % of ITS 5.0 LA1 concommg approvalof Program Descnphon aderustratwo rg temporary changes to procedures and am (UFSAR Sechon 17.3) details 4 mammum time it may be in effect i.e.,214 6.5.1.1.6 Requwements QualityAssurancs 10 CFR 50.54(a) Relocahon of
| |
| ! ITS 5.0 LA1 concammg changes to Program Descnphon adesustratwo procedures that (UFSAR hr*==i 17.3) dateds conshoute an unrenewed safety W, or involve a change to tie TS
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| | |
| l TABLE RL-RELOCATEDSPECFIC-ITEM IIATRIK page33 d51 Description General Location Change Cherastertention Cherasterimetion iTs a Doc cts Rrference Reference Centrats Type iTS 5.0 LA1 6.5.1.1.7' Roquemments Quakty Assurance 10 CFR 50.54(a) %W concommig dienges Program Descripten asinunistrahvo which consteute a (UFSAR Sochon 17.3) details cfiange to the facshty as desenbod in the UFSAR ITS 5.0 LA1 6.5.1.2.1 Requirements Quatty Assurance 10 CFR 50.54(a) %W mennustrahvo O amcoming plant Pregram Descnphon nN that aNect MSAR hr*ani17.3) dotats c-nucteer safety ITS 5.0 LA1 G.5.1.2.2 Requwement concameng QuaktyAssurance 10 CFR 50.54(a) %W
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| #se second safety rowaw Program C ,-4-s adnunestratwo on a5 N that (UFSAR Secton 17.3) deemts aNect nuctear safety
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| ~
| |
| ITS 5.0 LA1 6.5.1.2.3 Requirements Quahty Assurance 10 CFR 50.54(a) Relocahon W ,
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| concomwig approval at Program Descrgton admunuksame desats
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| ( i nm awwis Stat do not (UFSAR Secton 17.3) l invoeve an unrewswed C-safety queston ora change to the TS ITS 5.0 LA1 6.5.1.2.4 & Requrements QuaktyAssurance 10 CFR 50.54(a) %W g t
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| 6.5.1.2.5 concoming approval of Program Desenpten adnunstratwo A that entier (UFSAR Secton 17.3) delats [;
| |
| conshtute an unrenewed safety queshon or a channe to the TS 1
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| | |
| TAEILE RLiIELOCATEI4SPECFIC4 TEM RSATIWK page34of51 Description General Lacassen Change Cherasterlamelen Chassetestenden ITS & DOC CTS Reference Centrees Type Reference ITS 5.0 LA1 6.5.1.3.1 "Esch proposed QualeyAssurance 10 CFR 50.54(a) % of Tecsuncoi W Program Descnphon adnenstraeme or Operahng Licones (UFSAR Secemn 17.3) detets j change shed be l revioused by tie Plant )
| |
| ! peucier Sonny Commasse and sulmutted to Wie fWtC for ;
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| W .- ,
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| ITS 5.0 LA1 6.5.1.4.1 Requwements QuettyAssurance 10 CFR 50.54(a) % of l.'
| |
| concaming Techracol Program Desenpeen aderustraeme (UFSAR hreart 17.3) deemds t% vioistens ITS 5.0 LA1 6.5.1.5.1 n% Quatty Assurance 10 CFR 50.54(a) Rotocoton of adnunestrative i+. ' - ei, for Nucieer Program Desenpean datods Safety Reviewers (UFSAR Secten 17.3)
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| ITS 5.0 LA1 6.5.1.6.1.a P= tam for Quakty Assurance 10 CFR 50.54(a) % of and b estatdatung a Plant Prograrn Descnpean adsunseraswo Nuclew Safety (UFSAR Sechon 17.3) deters Commetoe (PNSC) and the advisory role it plays to the Plant General heme = =r ITS 5.0 LA1 6.5.1.6.2 Requwement for the Quakty Acymco 10 CFR 50.54(a) Relocesan of compossbon of #se PNSC Program Descnpemn admwestraeme (UFSAR hrmari 17.3) detets 6.5.1.6.3. 2+- s L for PNSC QuattyAssurance 10 CFR Sa54(a) Rakicahon W ITS 5.0 LA1 members and seemmes Program Doncnpemn adnunshahm members (UFSAR Secemn 17.3) detois
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| TABLE RL-RELOCATEDSPEQFMNTEMIRATIWK pese 35 of51 ITs a doc cts Deeceiption General Lacation Change Cherastertestion Cherastertestion Reference Reference Centrois Type ITS 5.0 LA1 6.5.1.6.4.a Definshon of"quonmf ss QuaktyAssurance 10 CFR 50.54(a) P W of and b it pertens to the PNSC. Program Descaphon asumustratwo Aamolirruts ese numberof (UFSAR Sechon 17.3) detmas anemates that rney con- a em ITS 5.0 LA1 6.5.1.6.5 hensnum PNSC moshng Quakty Assurance 10 CFR 50.54(a) P % of
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| :=
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| . / Program Desenpten adasustrahve (UFSAR Secten 17.3) detaEs ITS 5.0 LA1 - 6.5.1.6.6.e k Lishng of acemtes QuattyAssurance to CFR 50.54(a) P % of requmng PNSC Program L- 5 adnunnerutvo involvement (UFSAR hrew= 17.3) deters ITS 5.0 LA1 6.5.1.6.7 Requesd schons to be QuattyAssurance 10 CFR 50.54(a) P % of !
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| ?
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| taken upon disagreement Program Desenpten adnunstratwo
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| * behusen Wie PNSC and (UFSAR Secton 17.3) doests achons contempested by the Plant General W
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| 6.5.1.6.6 Requwement for Quality Assurance 10 CFR 50.54(a) P% of ITS 5.0 LA1 mentasung nunutes of ' Program Descnplan adnunestratwo O PNSC meetngs and tioir desats b (UFSAR hr*an 17.3) r.ununum content ITS 5.0 LA1 6.5.2.1 Descnpten of the QuaktyAssurance 10 CFR 50.54(a) % of funchon of tie Nucieer Program Desenpten admsustative Assessment Sechon (UFSAR Secten 17.3) deemis peas)
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| TABLE RL-RELOCATEESPECFIC-ITERI BIATRIX page36of51 ITS & DOC CTS Doocription General Location Change Charactoriastion Cherasterieellen Reference Reference Centruts '
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| Type -
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| ITS 5.0 LA1 6.5.2.2.1 ^ % of Quality Assurance 10 CFR 50.54(a) Relocaten of indwusuais for Program Descnphon a6nsustratwo independent reinsors in (UFSAR Secten 17.3) deemits to NAS ITS 5.0 LA1 6.5 7 2 7 n % ofsie- QuattyAssurance 10 CFR 50.54(a) % of q Managerh Program Desenplen adnunstratwo /
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| v A====* ment hr* art (UFSAR hr* art 17.3) details ITS 5.0 LA1 6.5.2.2.3- n % of Quatty Assurance 10 CFR 50.54(a) % of indivusuais perfomung Program Desenphon adsunstratve widependent safety (UFSAR Secton 17.3) deemis reviews ITS 5.0 LA1 6.5.2.2.4 Actons to be taken when QuainyAssurance 10 CFR 50.54(a) % of sunicient experkse does Program Desenpten adesustratwo not exist witun the NAS. (UFSAR Secton 17.3) details Also agows an indwidual -
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| to be 'a.g _^ - T in more Stan one W ITS"5.0 LA1 6.5.2.2.5 n h for QuainyAssurance 10 CFR 50.54(a)
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| % of induduals perfomung Program Descnphon admwustratwo revows of documents (UFSAR Secten 17.3) doteds sulmuned underTS hr*ari 6.52.3 ITS 5.0 LA1 6.5.2.2.6 M ~ _;_ e for QualityAssurance 10 CFR 50.54(a) Raiocahon of ,
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| 6 safety Program Descnplion admwustratwo f
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| reviews in NAS (UFSAR Sechon 17.3) details
| |
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| TABLE RL-RELOCATEDSPECFIC4TERIISATRIK page37af51 Doocription General Lacation Change Cherastertestion Cherastertention ITS & DOC CTS Centrods Type Reference Reference ITS 5.0 LA1 6.52.2.7 Requsement that the - Quality Assurance 10 CFR 50.54(a) % of Program Descnphon adnunstratwo procedures - NAS Independent Safety dotags Review Program be (UFSAR Secten 17.3) cordartart in accendance wish wntion - , .;d prem -
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| ITS 5.0 LA1 6.5.2.3 a-o Lishng ofitemsin wtuch QuattyAssurance 10 CFR 50.54(a) % of tw NAS shas perform Program Desenphon admuustratwo rewows (UFSAR W 17.3) dotats ITS 5.0 LA1 6.5.2.4 Whof Nudear Quatty Assurance 10 CFR 50.54(a) % of Assessment Sechon Program L7 . admuustratwo ,
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| dotags andependent safety (UFSAR Secten 17.3) renews shan tm .
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| documented and retened
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| * 6.2.1.e Requwement that tie UFSAR 10 CFR 50.50 Raiocahon of ITS 5.0 LA2 healet ptysses manager adesastratwo have -= to the . dotats overaB unit managerand the heeNh physacs technscian's *stop work" "g autionly e
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| 11
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| f TABLE IM.-IEELOCATE53SPECFIC4TBA 30ATfuK page 38 of 51 Doocription General Location Change Charactoriention Chasecterleablen ITS & DOC CTS Centrees Type Reference Reference ITS 5.0 LA3 6.2.3.h- Rosincton that muumum UFSAR 10 CFR 50.50 Relocahon of shift manrung admsustratne requsements cannot be desses used tojustry We shin compiament upon shift relief when a -
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| requwed memberis not avalatdo for rehof .
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| ITS 5.0 LA4 6.5.1.1.1.j' Reference to Regulatory QualdyAssurance 10 CFR 50.54(a) PW of Gusde 4.15. Dec.1977 Program Desenplen admrustraine with regard to the Qualdy (UFSAR Secten 17.3) doenEs Assurance Progam 4.4.3.a-h Requirement to perform TRM 10 CFR 50J50 Relocahon of ITS 5.0 LA6 seskaos teshng and estaiis ne of the Post concominD ,
| |
| Accident Recuculaten leseng Heat Removal System molhodology ,
| |
| and the applicable l
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| % entene.
| |
| Addeones requwement to perform repers as necessary to mentain leakage witun tw stated entene ITS 5.0 LA7 4.4.4.1 Requrement to inspect TRM 10 CFR 50.50 P % of contenment survoisance deines tendons concomm0 lostng
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| . . _ = - - = -
| |
| e
| |
| .e
| |
| ...a .. ,,, ,, . , , . . . . . _ _ _ _ _ _ , , _ . _ _ , _ _
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| - . . . I,,, . , .
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| ''-,=m- -
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| | |
| TABLE P!L-RELOCATE 5DSPECFIC4 TEM 30ATIWK page 3g of 51 ITs a poc CTS DescripHen GeneralLacetion Change CIseraetesteetten Chasmotestsamen h.s Reference Centrols 5 Type ITS 5.0 LA7 - 4.4.4.3.a Details descntung TRM 10 CFR 50.50 Relocahon d anstyses to be p "m .. I dateds on Contamment SurvesenceTendons concommg techng 3
| |
| /
| |
| nr-: _ A _-
| |
| ^
| |
| ITS 5.0 LAS 4.2.3 Requeement to perform inservice inspecton 10 CFR 50.50 % of
| |
| * reactorcooient pump Prognan deceds cono.mm.
| |
| #rahese mapectens
| |
| =-_---
| |
| 3 ITS 5.0 LA9 3.3.2.c Requesment that tio TRM 10 CFR 50.50. % of spent fuel buildmg and . details contomment buildng fiberlens shed be shoum to operate adhm 110%
| |
| cono.mme testag neelhodology 3
| |
| of m now ITS 5.0 LA9 4.15.d R ' _.ce Stat the - TRM 10 CFR 50.50 % of !
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| contros room sinramon detmas j system be tested assocsated wiNi !
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| fogounng any structural post mantenance on the fiber maintenance housangs or foBowing toshng to dodese poinhng, fire, orchenucos operabiety raisese in Sie Control Room enveloce 11
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| | |
| < TABLE RL-FELOCATEiRSPECFIC4 TEM RSATRDC page 40 of 51 ITS & DOC CTS Doomription General Location Change Characterimeteen Chesentenmoden Reference Reference Centrats Type ITS 5.0 LA9 4.15.f Requrement that the TRM 10 CFR 50.50 Relocahon of ConomiRoom Euraemn decads system be tested every concesvang 7 1a snonths techne
| |
| . r :45_ _- )
| |
| ITS 5.0 LA9 4.15.g Requemment that the TRM 10 CFR 50.50 % of Canarci Room libraten desaAs system IEPA filters be assocated wiSt easted aner composes or poet partet . _, t ._d and ' maintenance h test toshng to deciese condskons operabilier ITS 5.0 LA9 4.15.h Requrement that the TRM 10 CFR 50.50 Rotocahon of Control Room fibrahon dossies system charcoal Snors assoamend wist be tested aner eem poet Petalor complete snaintenance repiscoment and teohng to decesse m gest operabiter i
| |
| condibons &
| |
| ITS 5.0 LA9 4.12 Refusiing IWeer systems TRM 10 CFR 50.50 Resocahon of .'
| |
| Applicateter and desenphve E-f;; deenies 1
| |
| ITS 5.0 LA9 4.12.1 C, a.M that the TRM 10 CFR 50.50 Relocahon of Refueling FilterSystem descriperve be demonserseed deemds operable overy operahng evcs.
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| | |
| TABLE RL-RELOCATEiD SPECIFIC-ITEM MATRIX page41 or51 ITS & DOC CTS Description General Locahon Change Characterization Charactonastion Reference Reference Controis Type 4.12.2.a Requwement that the TRM 10 CFR 50.5g Relocaten of ITS 5.0 LA9 Refudng Feter System detaas be tested vvhany, and at concomme seast once per operahng testrva cycle priorto each methodology refuehng outage or aner 720 hours of system opershon whschever corres first ITS 5.0 LA9 4.12.2.l>e Detads concemog how TRM 10 CFR 50.59 Relocaten of the Refueling System dotads filtrabon system is to be concorrung tested and what tesis are teshng to be performed methodology
| |
| ^
| |
| 3.16.2.1 Restnchon on the TRM 10 CFR 50.5g PW of ITS 5.0 LA10 quantdy of radcachve details material contamed in the w -w.;c.g Ested tanks shall be methodology for ,
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| limited at ad times meshng ;
| |
| * *"'*" * ** l t
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| l 1
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| 1 I
| |
| | |
| !ABLE RL-RELOCATEiGSPECIFIC4TERI REATRIK pay 42 of51 CTS Doocription General Location Change Chpractoriestion Characterimmelen ITS & DOC Reference Reference Conkets Type
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| (
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| ITS 5.0 LA10 3.16.2.2 Requwement that when TRM 1C CFR 50.50 % of the quankly of details radioactwo masonalin concomme any hsted tank M rnatiodology for the kmit, suspend at mostrig asemens to the tank, and requimments take actens to reduce the amount of radioactwo materialin the tank to wittuilinuts wetten 48 hours ITS 5.0 t.A10 3.16.2.3 Requwoment thatif the . TRM 10 CFR 50.50 % of radmacewe content of reportng any of tie hated tanks requrements
| |
| . cannot be r=6w to witurilimits wsIhan 48 hours then tie NRC shat be notdied in accordance j with TS Section 6.6 l'
| |
| ITS 5.0 LA10 3.16.2.1.f DeAnsten of" Temporary TRM 10 CFR 50.50 % of Tank"as it apphes to TS desenpowe Sechon dotads 1
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| | |
| . TABLE RL - RELOCATED SPECIFIC-ITERE ISATRIK page 43 of51 Description General Location Change Charactertmetion Charactertmellen ITS & DOC CTS Reference Contrats Type Reference ITS 5.0 LA10 3.16.4.1 Resenciens on hydrogen TRM 10 CFR 50.50 % of and oxygen content'm dateded the Waste Gas Decay requsements .
| |
| Tanks reineng to systems not reqused for operabihty orto mentam sequesd times ITS 5.0 LA10 3.16.4.1.a Actens to be taken when TRM 10 CFR 50.50 % of osygen or hydrogen deemiled concentratenin the requirements Waste Gas DecayTanks retning to ,
| |
| - knuts systems not requesd for operatnety orto mentam requead 8""85 .
| |
| 3.16.4.1.b Actons to be taken when TRM 10 CFR 50.59 Relocanon of i ITS 5.01.A10 oxygen and hydrogen dateded 3
| |
| concentranon in the requnements Waste Gas DecayTanks rotatng to '
| |
| ==r==* limits systems not requesd for operabaity orto snamtem seqused tirruts b
| |
| ...._........._..)
| |
| ..i :..;......,......_........_...
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| | |
| .I TABLE RL-RELOCATESSPECIFIC-4 TEM MATRIK pese44d51 CTS Doocription General Lecasion Change Cheractertention Cherostertenden ITS & DOC Reference Centrols Type Reference ITS 5.0 LA10 3.16.4.2 ' Reportng i+swa. TRM 10 CFR 50.50 % of foroxygen andor reportne hydrogen bong out of regerernents W in the Waste Gas Decay Taws) for 2 48 hours ITS 5.0 LA10 3.16.4.3 Reportng requwements TRM 10 CFR 50.59 Relocahon of forcondson wohere reportng schons requwod to be requemments taken by TS do not result in retuming the hydrogen or omygen concentrabon in the Waste Gas Decay Tank (s) to s 6% wnIhm
| |
| . 24 hours ITS 5.0 LA10 3.16.5.1 Lirateten on the amount TRM 10 CFR 50.50 % of of r% metensi detailed ,
| |
| tiet may be stored in any requwements i one Wasta Gas Decay reichng to
| |
| * Tank shen be Irruled to systems not s 1.9 E+4 cunes noble requwed for -
| |
| gas (conadored as Xe- operabibly orto 133) mentem requesd snuts i~
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| I
| |
| | |
| TABLE RL-RE1OCATEDSPEQFIC-ITERI BEATRIX page 45 d51 ITS & DOC CTS Dmocription General LoceAlen Change Characterimetion Cherastertmedlen Reference Reference Centrols Type iTS 5.0 LA10 3.16.5.2 Requirement to suspend TRM 10 CFR 50.50 Raiocahon of as addihons to any desemed Waste Gas DecayTank requsements that M #se limitin relehng to TS Secemn 3.16.5.1 and systems not instun 48 hours reduce requesd for Wie tank contents to operabibly orto inqNiin luvuts mesitasiaquesd limes ITS 5.0 LA10 3.16.5.3_ Reporkng requirements if TRM 10 CFR 50.50 Relocahon of
| |
| :the Weste Gas Decay reporkng Tankcontents are not resperaments reduced toinathun luvuts instun the time penod asowed byTS Sechon
| |
| :3.16.5.2 4.20.2 Note speafyingimhch TRM Bases Control % of 7
| |
| ITS 5.0 LA10 tanks are to beincluded Prograrnin ITS system ;
| |
| inlinutshons dictated by Seckon 5.5.14 descnphon / ;
| |
| TS hr* art 4.20.2.1 details !
| |
| iTS 5.0 LA10 4.20.2.1 Requsement to venly Nie TRM 10 CFR 50.59 Raiocaten of r % masensi deemmed seehng content of tanks listed in requsements TS Sechon 3.16.2.1 by reistng to samptng systemsnot required for operahtly orto mesitsun requsett sinues 1
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| 1 l - - - -
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| | |
| : TABLE RL-RELOCATESSPECIFIC4TERIIAATMK page46or51 ITS & DOC CTS Dooeripelen General Loceben Change Cherastedsetion Chesastestmselon Reference Contrats Type Reference ITS 5.0 LA10 4.20.4.1. Requirement to venty tie TRM 10 CFR 50.50 % of hydrogen and caggen detaged testag concentrahon in tie requeements Weste Gas DecayTanks reistag to to te vneun limes by systerns not mondonng contents witi requesd for hydmoen and osygen operatelyorto niondors or sempiing niesnaam mquesd smes ITS 5.0 LA10 4.20.5.1 Requeement to sample TRM 10 CFR 50.50 % of tie contents of the deteRed testmg Weste Gas DecayTanks requeements every24 hours when reteens to Reactor Coolant Acamty is 2100 uCWml systems swt requesd for
| |
| ] .
| |
| operability or to mentem sequesd i Lauts !
| |
| ITS 5.0 LA11 6.g.1.4, m f formato of TRM 10 CFR 50.59 % of Montily Operahng Report reportng
| |
| .; _c ^.
| |
| 3 i ITS 5.0 LA12 6.5.3.1 U; ' c.~.4 to perform Quakty Assurance 10 CFR 50.54(a) % of certen types of Prognun Cs;^ -i -- adenoustratne assessments at a (UFSAR Secton 17.3) details frequency not to W 24 montis, by the NAS as listed in TS hrerwis j 6.5.3.1 a-h e
| |
| | |
| ,,.. ,i.,
| |
| g.".rg-TABLE RL-RELOCATEEFSPECRC4TERIISATIuK pese47or51-peecripelen GeneralLocation Change N Characterianden ITs a Doc cts Reference Reference Centrols Type ITS 5.0 LA12 6.5.3.2 Requeurnent for Wie NAS QuattyAssurance 10 CFR 50.54(a) Relocahon of -
| |
| to perfonn assessenents Program Descnphon adawneemswo in acconsance meh Sie (UFSAR W 17.3) detets Code of Federal Reguinhons speaGcagy in om areas of Emergency Preparedness,Secunty, and Radston PrW ITS 5.0 LA12 6.5.4.1 & Roqueernents for QuattyAssurance 10 CFR 50.54(a) % of 6.5.4.2 independent tre Program Doncnpton asenmeraens protecton and loss (UFSAR Secmon 17.3) detets pnwonton eispecton and auce -
| |
| Rouew i+; xL QuaktyAssurance 10 CFR 50.54(a) Relocaison of - [
| |
| ITS 5.0 LA1 6.6.1.b)& I h unes Program Desenpeson adounistrasme 6.6.2.b)
| |
| & events (UFSAR hetan 17.3) deteib i 10 CFR 50.50 Relocahon of ITS 5.01A13 6.9.1.1 Reporeng requeements ser piant mau, and
| |
| -es h.ri THRA
| |
| < reportne
| |
| .;= K :
| |
| ITS 5.0 LA14 6.9.1.3.7 Reporkng and appnwal ODCM 00CM in ITS - Raiocahon of requsements for Secton 5.5.1 reporang dienges to the requsements radioecews weste % of systems adeurustradwo detets
| |
| -. -.--..--l ,
| |
| - - - - . . _ --._.---..s.. - . .
| |
| mi . . . . , .
| |
| | |
| TABLE RL-RELOCATEDSPECRC4 TEN MATRIK page45d51 CTS Dessdpean General LaceMan Change Cherasendessen Chesasendention ITS & DOC Reference Centrets Type Reference ITS 5.0 LA14 6.17.1.1 Reporkng requsements ODCM OOCMin ITS % of formayor changes to em Sechon 5.5.1 reporkng r% kred. requimmenes L seous, or sosd wesse kee swit systems.
| |
| Include? aEowance West hcensee may sutuvut Wie iW informehon as part of #m next UFSAR LW ITS 5.0 LA14 6.17.1.2 Mapor changes to OOCM ODCMinITS Relocahon of radioactive weste Seckon 5.5.1 admuustrahvo process systems sheE details become esecewe upon reviewand approval ty Wie PNSC ;
| |
| ITS 5.0 LA15 6.9.3.3.b Lishng of TS COLR 10 CFR 50.50 Relocahon of ,
| |
| i+; u;_4. applicable admuustratwo to eachlisted deleds methodology as tiey .
| |
| j perten to determirung '
| |
| cese m limds iTS 5.0 LA16 6.9.3.2 Requsement to generate OOCM 10 CFR 50.50 % of wseen reports forthe repothng listed special radmiogmal requsements emuent reports essed and sutsut to the NRC wdhm 30 days of tie occunence or event
| |
| . . . . . . . .. ...v.
| |
| | |
| TABLE RL -RELOCATEDSPECIFIC-ITEM MATRIX page49 of 51 ITS & DOC CTS Descnption GeneralLra Geii Change Reference Reference Charactomation Charactemation Controls Typ.
| |
| ITS 5.0 LA17 1.15 Requirements for the TRM 10 CFR 50.59 Relocahon of Process Control Program MTa44ve (PCP) to assure details compliance with 10 CFR 20,10 CFR 17, and _
| |
| Federal and State regulatsons ITS 5.0 LA17 6.15.1 Requrement that the TRM 10 CFR 50.59 R&d% of PCP shall be approved by the NRC prior to admnustrative details r) implementation 6 ITS 5.0 LA17 6.152 Report.ng and approval TRM 10 CFR 50.59 Relocation of requaements for reporting e changes to the PCP requrements R&dian of d MTa-6L.iive '
| |
| details iTS 5.0 LA18 6.4.1 Requrements fora UFSAR ;
| |
| requahficatson and 10 CFR 50.59 Re: u41 of MTa-nbelive replacement trasrung detads '
| |
| program for the plant staff that shallmeet the requirements of Sec. 5.5 of ANSI N18.1-1971 and 10 CFR 55, Appendix A ITS 5.0 LA19 6.10.1.a-i Listing of facility records QualityAssurance 10 CFR 50.54{a) Re:- =t--i of that must be retained for Program Desenptson M i- 4 .L-s at least five years (UFSAR Section 17.3) details
| |
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| TABLE RL-RELOCATE 9SPEQFIC4 TEM MATRIK peec50of51 CTS Descripelen General Locessen Change Charactertsselon CharacterfamAlan Cs & DOC Type Reference Reference Centrees 6.10.2.a-m Lishng of factly records QuainyAssurance 10 CFR 50.54(a) Relocahon of ITS 54) LA19 that must be retamed for Program Descnphon adesumerstmo tie s sabon of the factty (UFSAR Sechon 17.3) dotarts m kanse ITS 5.0 LA20 6.11 Requsement that UFSAR 10 CFR 50.59 Relocation of PFXmdures for personnel a6nsustratwo ra6 sten protechon for details the Redskon Protecten Program tie prepared ~
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| v consestent with Sie requsements of10 CFR 20 and that they to
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| -;--c;;d, maintaned, and a:Niered to fora 5 I
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| - OPeratons snvohnng Personnel radekon em ITS 5.0 LA21 6.1.1, Detailed plant UFSAR 10 CFR 50.50 % of f 6.5.1.1.4, o p titles- admsustratwo l 6.5.1.2.3, details 6.2.1(b),
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| 6.2.3, 6.3.1, ,
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| 6.16.2, 6.13.1, and 6.132, With respect to deemied piant organ-e titles
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| ......,,:..-..-._--:..._.....s - _ _ . . _ _ . . . ..
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| TABLE RL-RELOCATED SPECIFIC 4 TEM MATRDC pese51 or51 C:: : _ ' ^_':-s General Location Change Characteriantion Charactortsstion ITS & DOC CTS Controis Type Reference Reference 6.9.1.2 Reportng requwements ODCM 10 CFR 50.59 P % of ITS 5.0 LA22 reportng 6.9.1.2.3, and for radelogeal emuents 6.9.1.3, With requwements regard to reporeng requrements for radelogmal emuents ITS 5.0 LA23 6.9.3.3.a With Mathematcal terms COLR 10 CFR 50.59 P % of utilmed in the COLR desenperve regard to dotaEs mathemaical terms utAzed in the COLR i
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| e-1 I
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| .f x . __ .. .
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| TABLE R - RELOCATED ITEttS 8%ATRIK page 1 of14 CTS C:: -; ^' - General Lace *ien Change Centrets ChesamterimeGen ,
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| 3.1.1.4.A Requsement Niet when the RCS temperature is TRM 10 CFR 50.50 Does not most 10
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| >2007 RCS vent paths from the reactor vessel head CFR 50.36 and pre-=uer steem space shen be operable cntene 3.1.1.4.B Requirement that when the RCS temperature is TRM 10 CFR 50.50 Does not snoet to
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| >2007 valves RC-571 and 572 shes be dosed wiWi CFR 50.36 cntene
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| ~
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| the agowance that Wie valves may be cycled A --
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| t'", in order to ' ;- n T .s. Wie vent system should Sto system pressunza due to
| |
| * root" valve leek-kr 3.1.1.4.C.1 "With the Reactor Vessel Hood went path inoperalde. TRM 10 CFR 50.50 Does not emost 10 restore the vent palh to operatde status wdhst 30 CFR 50.38 days or be in Hot Shutdowri witiin 6 hours and Cold cntone Shutdown witun the fogounna 30 hours
| |
| * 3.1.1.4.C.2 - Reportng requirement that wilh the Pressuruar TRM 10 CFR 50.50 Does not neset 10
| |
| - steem space vent inoperaldo, restore it to operable CFR 50.36 status witun 30 days or prepare and sutmet a specaal cntone report to Wie NRC within the % 14 days .
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| detaging the cause of the inoperatutty mid the acton bosna taken to restore -:---4_ ~":^; .
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| 3.1.6.1 "The concentrabon of ouygen in Sie reactor cooient TRM 10 CFR 50.59 Does not neset 10 shsE riot encoed 0.1 ppm when Wie reactor cooient CFR 50.36
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| ^
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| -., - -^ -e emmeds 2507." cntens 3.1.6.2 "The concentration of chiande in the reactor cooient TRM 10 CFR 50.59 Does not eneet 10 shot not ==r=ari O.15 ppm when Wie reactor cooient CFR 50.36 -
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| ^_. i.edre encoeds 250T
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| * cntene
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| TABLE R - IELOCMED ITEBBS ISAM page 2 of 13 C: : ~ ^~ - General Lacetsen C3eense Centrees Characteriumdien CTS Requsement West if out of C. me=a==i reactor TRM 10 CFR 50.59 Does not meet 10 3.1.6.3 coolant ostygen or Code concentraten cannot be CFR 50.36 restored to 6.sn W withwi24 hours Wie cntens unit 6 os placed in tie cold shutdovun condskon
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| : ang nonnel N ys-:M__ ;
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| "The e side of tie steem generator must not TRM 10 CFR 50.50 Does not meet 10 3.1.2.2 be pressunmod above 200 peig if tie temporaiure of CFR 50.36 the vesselis below 1207.* creene "The pressunzer shed neitier- caad a manomum TRM 10 CFR 50.50 Does not nimet to 3.1.2.3 heetup rate of1007Airnora W rate of '
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| CFR 50.36 2007 Air. The spray shed not be used if tie cntene temperatum deerence betuneen sie pressunter and the spray Guid is greater then 3207.*
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| Requsement that the egiapment listed in TS Table OOCM OOCMinITS Radiological 3.5.2.1 3.56 shes be operable with their alamenp seapoets Secesop 5.5.1 EfWuent Tectancef i
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| i setin accordance witiWie OOCM W (RETS) i relocation, does ,
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| not neset 10 CFR 4 50.36 creene ,
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| OOCM OOCM in iTS RETS relocahon, 3.5.2.2 Requwement that witi tie channel setpoint less .
| |
| conservative esen that requwed in TS Secton 3.5.2.1, Secton 5.5.1 does not nimet 10 immediately suspend releases wie the assocasted CFR 50.36 patsuusy and restore tie cfiannel setpoent to tant cntens required by tie OOCM or dociare sie channel
| |
| ;,-x-- A '-
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| OOCM OOCM in ITS RETS relocahon, 3.5.2.3 "With less 3:en the nunimum number of r%
| |
| hquid etRuont mondonng instrumentaban operable, Secton 5.5.1 does not neemt 10 take the acason shoven in Table 3.56.* CFR 50.36 cntens y
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| ..a''
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| _,p m
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| __...__,_.,,__...__....____i__
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| - ..,u._. . . _ .... ,.,, , . , . ,
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| | |
| ~
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| TABLE R - fELOCATED ITERBSIIATIWK page 3 of13 CTS ri ~ ^' "
| |
| General Location Change Centrees C8eeracterisation "The prowessons of tie W 3.0 are not OOCM OOCM in ITS RETS relocsisn, 3.5.2.4 appbcsMs." Secton 5.5.1 does not neset10 CFR 50.36 cntone Requwement that em equipment listed in TS Table OOCM OOCM in ITS RETS selocanon, 3.5.3.1 3.5-7 shat be operable with their alarmmnp seapoints Secton 5.5.1 does not neemt 10 setin accontence with #m OOCM CFR 50.36 cntone Requwement that with the channel setpoint less OOCM OOCMinITS RETS relocahon, 3.5.3.2 conservative tien that requwed in TS Secton 3.5.3.1, Section 5.5.1 does not meet 10 immediately suspend releases via the h CFR 50.36 pathway and restore the channel seapoint to stat cntens requesd by tie OOCM or dociere Wie channel
| |
| 'w" OOCMinITS RETS sufocahon, 3.5.3.3 M less than sie rninimum numberof r% OOCM gaseous ef9uent mondonng instrumeniston operable, Secton 5.5.1 does not nessi10 take sie achon shown in Table 3.5-6.* CFR 50.36 cntone OOCM OOCM in ITS RETS relocahon, 3.5.3.4 "The prowessons of the W 3.0 are not applicable." Secton 5.5.1 does notnuest10 CFR 50.36 cntone I
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| c .
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| TABLE R - RELOCNTED ITEMS NATfuK page 4 of 13 L
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| General Locassen Change Centrees Cherastostamalem r-z - f*: -
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| CTS "R% Liqued Efiluent Morntonne m ODCM in ITS RETS miocation, Tshis 3.5-6 insensnentahon,' wehsch lists tione monitors required Secton 5.5.1 does not snoet 10 to monnor em vanous nqwd r% reises. CFR 50.36 pattesys and tie requwed achons to be talen gehen catene sie mondanng channoiis inoperable. The table also prowdes the rm compensatory schon that must in taken it it is desired to mentam to release via Wie palhusey voitt Wie assocasted mondor iC "Radmacewe n==anase Elliuent Monsonng ODCM ODCMinITS RETS selocaten, Table 3.5 instrumentaten," vehich lists tese mondors requesd TRM Sachon 5.5.1 does not eneet 10 to mondor sie vanous gaseous r=diaar*ve release CFR 50.36 poenvoys and Wie requwed achons to be taken sehen creene Wie mondonne channel is inoperable. The table also 10 CFR 50.50 for provides Wie star ===ary compensatory acten that TRM must to taken it it is desmed to mentan the reisese via Wie pathmey voita tie ==*acamaad mondor '
| |
| iW Requwements for spent fuel rod voeter temporaews TRM 10 CFR 50.50 Does not meest to 3.8.3 CFR 50.36 catens Spent fuel cask hanssing crane requwements TRM 10 CFR 50.50 Does not meet 10 3.8.4 CFR 50.36 cntens 1
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| F 1
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| l
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| - , 1 l
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| TABLE R - N ITEROS BSATVWK page 5 of 13 General Location Change Centrets Cherasterimmelen CTS C:::" ^l n OOCM OOCMiniTS RETS relocamen, 3.9.1.1 .7:; _._% Stat Wie concentraten of radnoctwo ,
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| matonalinliquid amuonts th at any time from hemaa $11 does not snoet 10 CFR 50.36 Nie site to unresencted areas shen be limited to the concentratens W in 10 CFR 20, App. B. Table cntone II, Column 2 for radenuchdas cener tien dissolved or entnaned notdo gases. For dissolved or entraned noble gases, Wie concentraten shaE be limded to 2x10d uCdmltotalCli.
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| OOCM OOCMinITS RETS relocasion, 3.9.1.2 Requsement, wiIh the concentraten of lupad emuents in excess of that agowed by TS Secten 3.9.1.1, Secten 5.5.1 does not most 10 unthout doisy to restore tie concentraten to witun CFR 50.36 limits and notty Nie NRC in accordance with TS i cotone h eenst 6.6.
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| LM OOCMin ITS RETS selocation, 3.9.1.3 Requsement #tatin tie event tio . . ne of TS does not eneet 10 Secton 3.9.1.2 cannot be met sie unit shen be placed Secten 5.5.1
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| . CFR 50.36 in sie hot shutdown condihon.
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| astens OOCM OOCMin ITS RETS relocasion, 3.9.1.4 "The pnwisions of Specdcaten 3.0 are not Section 5.5.1 does not most 10 apphcable."
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| CFR 50.36 cntone OOCM OOCMinITS RETS relocahon, 3.9.2.1 Requsement Wist the dose commement at as times to a rnember of the public frorn r% matonais in Sechon 5.5.1 does not nimet 10 CFR 50.36 liquid emuents W to unresencted areas sher be cntens limded as stated in (a) and G>)~
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| .I ll
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| .1- - . .r. s -- --.. . .. . .. .
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| ....a.
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| __ . .ur
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| TABLE R . PR MAErED ITERBS IAATIWK page 6 of 13 General Location C3emage Centrees Chesaseostamelen CTS U 'J "Wish Wie cokadoted does commement fron- Wie OOCM OOCM ir= ITS RETS reloceben, 3.9.2.2 redence of radmachve snetonais in liqued emuents Section 5.5.1 does not noset 10
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| % any of tie luvuts prescritted by CFR 50.36 W 3.9.2.1 above, propero and sulmut a cntano report to the Commissson in accondence witi
| |
| - W 6.9.3.2."
| |
| Requwement test em dose rate at as trnes to a OOCM OOCMin ITS RETS relocahon, 3.9.3.1 member of tie pub:ic from r=rsiaar*ve instonets in Sechen 5.5.1 does not risest 10 gaseous eMuonts relemmed from tie ::h boundary CFR 50.36 shas be limded as =amaart in (a) and (b) cntone "Witi Wie dcae rate (s) encoedmg Wie above luvuts, OOCM OOCMinITS RETS relocaten, 3.9.3.2 weihout daimy decrease to reisese rate to udhri the Sechen 5.5.1 does not neset 10 above limits. In addition, a r% noust be riende CFR 50.36 to tio Commessson in accontence witt W cntone 6.6."
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| 3.9.3.3 Requeement tiet in tie event See requuements of TS OOCM OOCMin ITS RETS relocation. 8 Secten 3.9.3.2 cannot be rnet sie unit shes be pieced Secton 5.5.1 does not nuest 10 l in Wie hot shutdown condihon CFR 50.36 e catene I l
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| Requirement that the air dose commdment due to OOCM OOCMinITS RETS r=larmhnn,. ;
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| 3.9.4.1 radionable gases raisesed in gaseous emuents to Secton 5.5.1 does not meet 10 areas at and beyond tie site boundary shaE be Ernsted CFR 50.36 as amaaniin (a) and (b) cntone Requeement that witi the limits of TS Secton 3.9.4.1 OOCM OOCMin ITS RETS ruanc ene, 3.9.4.2-
| |
| ==raaniant, prepare and sutsut a report to tie NRC in Secton 5.5.1 does not nimet to aczonience witi TS Sechon 6.9.3.2 CFR 50.36 cneens i
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| l l
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| TABLE R - pra rir-stED ITEMS ISATfuK page 7of13 Dooe% , General Loestion Change Gentmis Cherasdordmedan CTS 3.9.5.1 Requemment Want sie does to Wie public froen I-131, I- 00CRA OOcaAinITS RETS scenesten.
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| 133, enhunt, and radioeceve motonals in partculate Secton 5.5.1 does not sonst 10 form, with hef-hwes greater Wien eight (8) days be -
| |
| CFR 50.36 lirruled in accordance witi lirnes stated in (a) and (b) creena Or244 OOCRAinITS RETS setocamen, 3.9.5.2 Requeement Stat witi tie linuts of TS Secton 3.9.5.1
| |
| ==r== dad, prepare and sutunut a report to tie NRC in Secton 5.5.1 does not meest10 accordance wiesTS Secton 6.9.3.2 CFR 50.36 cntone OOCM OOCRA in ITS RETS selocahon, 3.9.6.1 Requwement West '.he dose comnetment to any niember of Wie putshc, due to relemmes of licensed Secton 5.5.1 does not most 10 mateness and radismon, srorn uranann fusa cycss CFR 50.36 i
| |
| sources sheE be luvuted to s 25.trent to 9:e total cntone body or any organ except sie thynnd, whicit shed be limded to s 75 snreen over 12 consecutsve enonens OOCM OOCRA in ITS RETS solocamen, 3.9.6.2 Reportng and analyses requwements when any of tie limds amand in TS hr* arts 3.9.2.1.a or b,3.9.4.1.a or Secton 5.5.1 does not neset 10 b, or 3.9.5.1.a or b ars ==r== dad by a factor of 2 CFR 50.36 .
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| cntena OOCM OOCRAin ITS RETS N ,
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| 3.9.6.3 .* The prowessons of W 3.0 are not applicable." S echon 5.5.1 does not meet 10 CFR 50.36 cntone "A muumum of 15 total mermamNa Sumtdes and at TRM 10 CFR 50.50 Does not meest 10 3.11.1 least 2 per quadrant suNicsont enovable m-core CFR 50.36 detectors shag be operalde dunng recattwahon of tie cntene secore s. ..m onset detecnon svstem - l I
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| .. . . . .=
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| TABLE R - RELOCARED ITEMS MATRIX page 8 of 13 CTS Description General Location Change Controls Charactenzation
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| " Power shall be limited to 90% of rated power if TRM 10 CFR 50.59 Does not meet 10 3.11.2 recalibratior' requirements for the excore symmetrical CFR 50.36 offset detecuon system identified in Table 4.1-1 are enteria not met."
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| ODCM ODCM in ITS RETS relocaton, I 3.16.1.1 Requirement that the radioactive liquid waste system Secten 5.5.1 does not meet 10 l be utilized to minimize offsite doses due to releases cf!!qdd kdioactive effluents CFR 50.36 f l criteria l ODCM ODCM in ITS RETS relocahon, 3.16.1.2 Requirement that with liquid wastes being discharged without treatment while in excess of the limits in TS Sechon 5.5.1 does not meet 10 Section 3.16.1.1, prepare and submit a report to the .
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| CFR 50.36 NRC in accordance with TS Section 6.9.3.2.b criteria ODCM ODCM in ITS RETS rebcation, 3.16.3.1 Requirement that the radioactive gaseous waste system be utilized to minimize offsite doses due to Sechon 5.5.1 doe: not mest 10 releases of liquid radioactive effluents CFR 50.36 criteria ,
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| ODCM ODCM in ITS RETS relocation, 3.16.3.2 Requirement that with the gaseous waste treatment system inoperable and gaseous releases in excess of Sechon 5.5.1 does not meet 10 the limits in 3.16.3.1, prepare and submit a special TS CFR 50.36 ,
| |
| Section report to the NRC in accordance with TS criteria ;
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| Section 6.9.3.2.b "The Solid Radioactive System shall be used in TRM 10 CFR 50.59 RETS relocation, 3.16.6.1 accordance with a Process Control Program (PCP) to does not meet 10 process wet radioactive waste to meet shipping and CFR 50.36 burial ground requirements." criteria TRM 10 CFR 50.59 RETS relocahon, 3.16.6.2 "With the provisions of the PCP not satisfied.
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| suspend s.Sipments of defectively processed or does not meet 10 defectively packaged solid radioactive waste from the CFR 50.36 site." criteria
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| TABLE R - RELOCSIED ITEMS MATRIX page 9 of13 CTS DescrW General Locahon Change Controis Characteriastion Requrement that if a test specunen fails to verify TRM 10 CFR 50.59 RETS relocahon, 3.16.6.3 solidificaten, the solidification of the batch under test does not meet 10 shall be suspended until such time as addetonal test CFR 50.36 specunens can be obtamed, attemative solidification cntena parameters can be determmed in accordance with the PCP, and a sub=acient test verifies solidification "The Radiological Environmental Monitoring Program ODCM ODCM in ITS RETS relocahon, i 3.17.1.1 shall be conducted as speedied in Table 3.17-1." Secton 5.5.1 does not meet 10 CFR 50.36 criteria Actions to be taken when the Radiologecal ODCM ODCM in ITS RETS relocation, 3.17.1.2 Envwonmental Monitoring Program is not in Sechon 5.5.1 does not meet 10 accordance with TS Section 3.17-1 CFR 50.36 4 criteria ;
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| i Actions to be taken when the level of radioachvity in ODCM ODCM in ITS RETS relocahon, 3.17.1.3 plant effluents as indicated by envronmental Sechon 5.5.1 does not meet 10 -
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| samphng is greater than the reportog levels of TS CFR 50.36 Table 3.17-2 cntena Requirement to obtain replacement samples of milk ODCM ODCM in ITS RETS relocahon, 3.17.1.4 and leafy vegetables when the sample locations Sechon 5.5.1 does not meet 10 specified in TS Table 3.17-1 cannot be obtamed CFR 50.36 criteria
| |
| 'The provisions of Specification 3.0 are not ODCM ODCM in ITS RETS resocahon, 3.17.1.5 applicable." Sechon 5.5.1 does not meet 10 CFR 50.36 criteria l
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| l . .. . ..
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| t
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| l .
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| U l
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| TABLE R - RELOCMED ITEMS MATRIX page 10 of 13 Description General Location Change Controls Characterumbon CTS 3.17.1.6 Allowance for deviations from the required ODCM ODCM in ITS RETS reloc.Gon.
| |
| environmental sampling schedule Sechon 5.5.1 does not meet 10 CFR 50.36 cnteria ODCM ODCM in ITS RETS relocation, 3.17.2.1 Requirement to perform a land use census and related content Sechon 5.5.1 does not meet 10 CFR 50.36 criteria Reporting requirement for land use census that ODCM ODCM in ITS RETS relocMon, 3.17.2.2 identifies doses greater than the values currently Sechon 5.5.1 does not meet 10 being ca!culated in TS Sechon 4.10.4.1 CFR 50.36 criteria ODCM ODCM in ITS RETS relocatxxt, 3.17.2.3.a-c Actions to be taken when the land use census identifies a location which yields an annual calculated Sechon 5.5.1 does not meet 10 dose or dose commitment of a specific pathway CFR 50.36 which is 20% greater than that at a current sampling criteria j
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| location 3.17.3.1,2,3 Requirement for analyses supplied by U. S. ODCM ODCM in ITS RETS relocation.
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| Environmental Protection Agency (EPA) as a part of Sechon 5.5.1 does not meet 10 and 4 I
| |
| Interlaboratory Comparison Program CFR 50.36 l cnteria l
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| Table and associated notation describing the ODCM ODCM in ITS RETS relocabon, Table 3.17-1 Radio ogical Envitonmental Monitoring Program Sechon 5.5.1 does not meet 10 CFR 50.36 criteria Table describing reporting levels for radioactivity ODCM ODCM in iTS RETS relocation, Table 3.17-2 concentrations in environmental samples Sechon 5.5.1 does not meet 10 CFR 50.36 criteria
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| '-- A
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| n 7
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| TABLE R - RELOCMED ITEMS MATRDC page 11 of 1'l Genera! Location Change Controls Characterization CTS Desc e
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| ; ODCM ODCM in ITS RETSr % ,
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| Table 3.17-3 Table with mammum values for LLDs Secten 5.5.1 ' does not meet 10 WR 50.36 cntene Table 4.1-1, item Requrement for testeg high point vents TRM 10 GR 50.59 Does not meet 10 WR 50.36 45 cntens ODCM ODCMin ITS RETSr % ,
| |
| 4.10.1.1 Samping requrements for batch isqued releases h r*an 5.5.1 does not most 10 CFR 50.36 cntens ODCM ODCMin ITS RETS relocanon, 4.10.1.2' Analysis requrements for samples of batch hquid releases Secten 5.5.1 does not most 10 CFR 50.36 cntens Requwement that bquod batch samples be taken and ODCM ODCM in ITS RETSr % ,
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| 4.10.1.3 g analyzed in accordance with TS Table 4.10-1. Sechon 5.5.1 does not meet 10 i Requrement that the concentrabons at the point of . CFR 50.36 l.
| |
| release be withm the limits of TS Sechon 3.9.1.1 cntena l I
| |
| 4.10.2.1 Requrement for determmeng the dose rate due to ODCM ODCM in ITS RETSr % '
| |
| radmachve materials in gaseous effluents to be withm S echon 5.5.1 does not meet 10 -
| |
| the Irruts of TS Sechon 3.9.3.1 by perfommng CFR 50.36 e samping and analysis in accordance with Table 4.10- cntene 2
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| 4.10.3.1 "Cumulahve dose commstments for the commt ODCM ODCM in ITS RETSr %
| |
| calendar quarter and current calendar year shall be Section 5.5.1 does not meet 10 determmed in accordance with the ODCM once por CFR 50.36 31 C ." cntena I
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| ' ~
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| TABLE R - RELOCA7ED ITEMS MATRIX page 12 of 13 CTS W General Location Change Controls Characterization Requwement to determne cumulateve dose ODCM ODCM in ITS RETSr % ,
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| 4.10.4.1 contribubons for the cument quarter and current Sechon 5.5.1 does not meet 10 calendar year for 1-131,1-133, inhum, and CFR 50.36 rad onuchdes in particulate form with half lives greater , cntens than 8 days Requwement to determine cumulahve dose ODCM ODCM in ITS RETSr % ,
| |
| 4.10.5.1 contnbubons from hqued and gaseous emuents in Sechon 5.5.1 does not meet 10 accordance with TS Sechons 3.9.2.1, 3.9.4.1, and CFR 50.36 3.9.5.1 cntena Requwement to determine cumulative dose OOCM ODCM in ITS RETSth%,
| |
| 4.10.5.2 l
| |
| contnbubons from drect radiation from the reactor Sechon 5.5.1 does not meet 10 l
| |
| unit and from radwaste storage tanks as set forth in CFR 50.36 the @% of TS Section 3.9.6.2 cntena Table and associated notation desentung the ODCM ODCM in ITS RETS relocahon, Table 4.10-1 does not meet 10 ,4>
| |
| Radioachve Liquid Waste Samphng and Analysis Section 5.5.1 ,
| |
| Program CFR 50.36 ,.
| |
| * I Table and associated notahon desentnng the ODCM ODCM in ITS RETSr % , f Table 4.10-2 Radioactive Gaseous Waste Samphng and Analysis Sechon 5.5.1 does not most 10 ;
| |
| Program CFR 50.36 cnteria l
| |
| 4.16 Requwements for Radsoactive Source Leakage TRM 10 CFR 50.59 Does not most 10 Teshng CFR 50.36 cntens ODCM ODCM in ITS RETSr * =8 wi, 4.19.1.1 Requwement to perform radsoactive hqued effluent monitoring instrumentahon operatmhty surveillances in Sechon 5.5.1 does not meet 10 accordancewithTSTable 4.19-1 CFR 50.^G cntena i
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| l I
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| page 13 of13 l
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| TABLE R - RELOCATED ITEMS MATRIX 1
| |
| Description General Location Change Controls Characternation CTS ODCM ODCM in ITS RETS relocahon, j 4.19.2.1 Requirement to perform radioactive gaseous effluent monitoring instrumentation operability surveillances in Secbon 5.5.1 does not meet 10 !
| |
| i accordance with TS Table 4.19-2 CFR 50.36 criteria l l
| |
| Table and associated notation desenbing the ODCM ODCM in ITS RETS reim Gon, !
| |
| Table 4.19-1 radioactive liquid effluent monitoring instrumentation Sechon 5.5.1 does not meet 10 )
| |
| surveillance requirements CFR 50.36 l criteria l Table and associated notation describing the ODCM ODCM in ITS RETS relocahon, l Table 4.19-2 j
| |
| racioactive gaseous effluent monitoring Sechon 5.5.1 does not meet 10 l instrumentation surveillance requirements TRM 10 CFR 50.59 for CFR 50.36 l TRM criteria j j
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| ODCM ODCMin ITS RETS relocation, i 4.20.1.1 Requirements to perform projected dose commitments at least every 31 days to ensure the Secbon 5.5.1 does not meet 10 requirements of TS Secbon 3.16.1.1 are satisfied CFR 50.36 when the Liquid Radwaste Treatment System is not criteria ;
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| used j ODCM ODCM in ITS RETS relocation, 4.20.3.1 Requirements to perform projected dose commitments for gaseous releases at least every 31 Sechon 5.5.1 does not meet 10 days to ensure the requirements of TS Section CFR 50.36 criteria 3.16.3.1 are satisfied .
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| "The PCP shall be used to verify the solidification of TRM 10 CFR 50.59 RETS relocation, 4.20.6.1 '
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| one representative test specimen from every tenth does not meet 10 CFR 50.36 -
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| batch of wet radioactive waste."
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| criteria .
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| l Actiuns to be taken when a test specimen from a TRM 10 CFR 50.59 RETS relocation, 4.20.6.2 batch of waste fails to verify solidification ,
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| does not meet 10 CFR 50.36 cnteria
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| - , , , - , , , . _d
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| - -i- - -
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| I TABLE R - RELOCMED ITEMS MATRIX page 14 of 14 General Locatson Change Centrols Characterization CTS' E r M; ":2 Requrement to collect envronmental samoles in ODCM ODCM in ITS RETSr % ,
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| 4.21.1.1 does not meet 10 accordance with TS Table 3.17-1 and analyze them in Section 5.5.1 accordance with TS Tables 3.17-2 and CFR 50.36 3.17-3 cntens ODCM ODCM in ITS RETS relocaten, 4.21.2.1 Specdicahon of how the land use consus shaN be conducted Sechon 5.5.1 does not most 10 CFR 50.36 cneena 4.21.3.1 Requrement to perform analyses as part of the EPA - ODCM ODCM in ITS RETSr % ;
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| intertaboratory Companson Program Sechon 5.5.1 does not most 10 :
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| CFR 50.36 meena "Radioachve Effluent Releases" requirement to report ODCW ODCM inITS Does not most 10 TS Appendix B on a monthly basis the quankhes of radioachve Sochon 5.5.1 CFR 50.36 effluents released from the plant entens l
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| I i
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| D
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| W NT.C FORM EC (7 94)
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| NRCMD 3.57 COVER SHEET FOR CORRESPONDENCE USE ThiS COVER SHEET TO PROTECT ORIGINALS OF MULTI PAGE CORRESPONDENCE C
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| 1
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