ML20141C927
ML20141C927 | |
Person / Time | |
---|---|
Site: | Comanche Peak |
Issue date: | 05/15/1997 |
From: | Terry C TEXAS UTILITIES ELECTRIC CO. (TU ELECTRIC) |
To: | NRC OFFICE OF INFORMATION RESOURCES MANAGEMENT (IRM) |
Shared Package | |
ML20141C932 | List: |
References | |
RTR-NUREG-1431 TXX-97105, NUDOCS 9705190274 | |
Download: ML20141C927 (126) | |
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Log # TXX 97105 (7
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File # 10010 916 C C Ref. # 10CFR50.90 10CFR50.36a i illELECTRIC* l May 15, 1997 l C. Leace Terry Gnmp Mce PersWew U. S. Nuclear Regulatory Commission Attn: Document Control Desk Washington, D.C. 20555 1
SUBJECT:
COMANCHE PEAK STEAM ELECTRIC STATION (CPSES)
DOCKET NOS. 50 445 AND 50 446 LICENSE AMENDMENT REQUEST 97 001 TECHNICAL SPECIFICATION CONVERSION APPLICATION REF: 1) TU Electric letter logged TXX 95292 from C. L. Terry to the NRC dated March 4, 1994
- 2) NUREG 1431, " Standard Technical Specificationt Westinghouse Plants," Revision 1, April 1995 Gentlemen:
Pursuant to 10CFR50.90, TU Electric het d y requests an amendment to the CPSES Unit 1 facility operating license (NPF 87) and Unit 2 fac1.lity A
V operating license (NPF 89) by incorporating changes to the CPSES Units 1 and 2 Technical Specifications (TS) as provided in this license amendment request and by adding license conditions to address Surveillance Requirements not previously performed by existing requirements or tests.
The purpose of this request is to provide a subraittal pursuant to Reference 1 which dockets TU Electric's request for NRC approval of the full conversion of the CPSES Unit 1 and Unit 2 Technical Specifications from the ,
curreit Technical Specifications to a set of Technical Specifications based upo;. the improved Standard Technical Specifications (ISTS) [ Reference 2].
TU Electric has pre)ared this submittal to be consistent with 10CFR50.36a '
and requests that t1e proposed changes be incorporated into the Technical Specifications. Attachment 1 is an affidavit. Attachment 2 is a General description and assessment of the proposed full conversion (including pro)osed license condition). Attachment 3 contains a list of the changes wit 11n the submittal which are not directly related to the conversion process and a list of other pending or projected License Amendments Rep.Mts I (LARs) which could potentially impact the review of this conversion application. Attachments 4 through 18 provide the specific changes ano the justifications that support the acceptability of the changes and the evaluations that support the conclusion that these changes do not involve a significant hazard consideration. Attachments 19 and 20 provided the Improved Technical Specifications (the ISTS with the proposed changes incorporated) for CPSES. Attachment 19 is the ITS for the specifications andattachment20istheITSgses.
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() Page 2 of 3 TU Electric developed this conversion application in concert with three other utilities: Union Electric Company (UE), Wolf Creek Nuclear Operation Corporation (WCNOC), and Pacific Gas & Electric Company (PG&E). Two enclosures (enclosures 3B and 6B) in Attachments 4 through 18 to this submittal contain conversion comparison tables. These comparison tables reflect how the proposed changes are treated by each of the four utilities.
The tables are provided to assist the NRC in performing reviews of the individual submittals of each of these utilities. Only the information related to CPSES and TU Electric on these tables is considered to be part of this license amendment request. The information related to the other utilities is being provided for information only.
UE, WCNOC and PG&E are submitting parallel license amendment requests for their respective plants (Callaway, Wolf Creek Generating Station and Diablo Canyon). Because of the similarities in the attached license amendment request and the submittals of these other three licensees, it is requested that, to the extent possible, the NRC review these four submittals together in order to minimize the required NRC resources, reduce licensee costs and reduce overall review time. Don Wooolan of TV Electric is the chairman of the Joint Licensing Subcommittee, whic>1 includes members from each of the four utilities and which coordinated the joint development of the four full conversion applications. Mr. Woodlan (817 897 6887) is the lead utility contact to resolve matters which relate to the NRC's review of these four
,q packages.
V In accordance with 10CFR50.91(b). TU Electric is providing the State of Texas with a copy of this proposed amendment.
Because implementation of the Improved Technical Specifications involves significant training and revisions to implementing procedures. TU Electric will interfu e with the NRC during the review process to establish an appropriate implementation date or period.
Should you have any questions, please contact Mr. B.(Bob) S. Dacko at (817) 897 0122.
SincefAy, w
C. L. Terry DRW/grp ,
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TXX 97105 h Page 3 of 3 l I
Attachments: 1. Affidavit
- 2. General Description and Assessment
- 4. '
i
. 8. CTS Section 3/4.2 / ITS Section 3.2 l 9. CTS Section 3/4.3 / ITS Section 3.3
. 10. CTS Section 3/4.4 / ITS Section 3.4 .
i 12. CTS Section 3/4.6 / ITS Section 3.6 !
4 13. CTS Section 3/4.7 / ITS Section 3.7 ,
! 14. CTS Section 3/4.8 / ITS Section 3.8 l
- 16. CTS Section 3/4.10 / CTS Section 3/4.11 l 17 . CTS Section 5.0 / ITS Section 4.0 18 . CTS Section 6.0 / ITS Section 5.0 19 . ITS Specifications with proposed changes j i incorporated j
< 20 . ITS Bases with proposed changes incorporated r i c- Mr. E. W. Herschoff. Region IV i Mr. J. I. Tapia. Region IV ;
Resident Inspectors. CPSES Mr. T. J. Polich. NRR (4 copies)
Mr. Arthur C. Tate Bureau of Radiation Control Texas Department of Public Health -
- 1100 West 49th Street Austin. Texas 78704 a
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l lilPROVED TECHNICAL SPECIFICATIONS COMANCHEPEAK l STEAM El.ECTRIC STATION i
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- Attachment 1-to TXX 97105 Page 1Lof 1 UNITED STATES OF AMERICA NUCLEAR REGULATORY COMMISSION . .i
-1 In the Matter of )
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Texas Utilities Electric Company ) Docket Nos. -50 445- (
) 50 446 ,
(Comanche Peak Steam Electric Station. ) License Nos. NPF 87 t Units 1 & 2) ) NPF 89 j 5 AEFIDAVIT l i
C L. Terry being duly sworn, hereby deposes and says that he is Group Vice 1 President, Nuclear Production of TU Electric, the licensee herein: that he !
- ~ is duly authorized to' sign and file with the Nuclear Regulatory Commission . l
- this License Amendment Request 97 001: that he is familiar with the content i thereof; and that the matters set forth therein are true and correct to the !
' best of his knowledge, information and belief. -l t i i
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Mb w l C. L. Terry i 4[i
! Group Vice Pr dent, i V Nuclear Production !
STATE OF TEXAS ) !
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COUNTY OF.hure# )
a Subscribed and sworn to before me,~on this Z W / day o .
1997. () ;
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h otary Public A w ri d SUSAN C. GRAVATT NOTAftY PUBUC STATE OFTEXAS y l i
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Attachment 2 to TXX 97105 7q Page 1 of 9 Q.
GENERAL DESCRIPTION AND ASSESSMENT I. BACKGROUND The nuclear industry and the NRC have been working for several years to improve plant technical specifications. In September 1992, the NRC issued NUREG 1431 (and revision 1 in April of 1995)2 as the basis for the improved Standard Technical Specification (ISTS) for Westinghouse plants. The improved STS accomplishes the following:
- Provides a new Use and Applications section (Chapter 1) to provide a clear and detailed explanation for use of the improved STS (the format of the improved STS is completely revised to be more user friendly).
- Simplifies the technical specifications by relocating various specifications, surveillance requirements, and much of the current detail to other licensing basis documents.
- Incorporates improvements in the technical specifications such as eliminating unnecessary specifications, extending the time to perform required actions, and reducing the frequency of certain surveillance requirements.
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- Provides a greatly expanded Bases section which includes the basis of each Limiting Condition for Operation (LCO), action and surveillance requirement.
The NRC has been strongly encouraging the industry to adopt the NUREG 1431 format.
LP.SES Activity Since mid 1993. CPSES (Regulatory Affairs) has been working toward making a submittal by the end of 1996. In May 1995. CPSES management approved a plan to accelerate the conversion schedule with a new submittal date of April 1996.
A CPSES Tech Spec Conversion Project team was formed in June 1995. The team has been processing the submittal change packages (Licensing Document Change Requests LDCRs) since late June l'15. Each LDCR requires that changes to the current Technical Specifications (CTS) be identified and justified individually. The change packages go through extensive interdisciplinary technical reviews, culminating in approval by Station Operations Review Committee (SORC) and Operations Review Committee (ORC). The team relies extensively on -information contained in other plant ,submittals that preceded
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'Throughout this submittal, any reference to the ISTS or V NUREG 1431 specifically is a reference to the version of NUREG 1431 available on the_ NRC's bulletin board in April 1995.
p Attachment 2 to TXX 97105 V Page 2 of 9 CPSES (e.g., Vogtle). In addition, TU Electric is a member of the Westinghouse Owners Group Tech Spec Mini group which provides a forum for sharing information and arriving at a consensus for additional improvements that are generic in nature.
Joint Technical Soecification Conversion In October of 1995. TU Electric joined with Diablo Canyon (Pacific Gas and Electric). Wolf Creek (Wolf Creek Generating Station Nuclear Operating Corp.) and Callaway (Union Electric) in a joint effort to convert the CTS.
Mr. Don Woodlan is representing TV Electric and is the chairman of the Joint Licensing Subcommittee (JLS). A meeting was held with the Director of NRR and the NRC staff on November 14, 1995, to discuss the joint effort of those utilities in converting to the Improved STS. A working level meeting was held with the NRC on December 14, 1995. The first joint meeting to review a conversion package was held on January 15 and 16, 1996.
The Joint Licensing Subcommittee (JLS) is attempting to reduce the costs and approval times for the conversion application and for other License Amendmant Requests. It is also a goal of the four utilities to make the Improved Technical Specifications (ITS) for all four of the plants as similar as possible. Such commonality should enhance operations and reduce 3 costs in the future.
(G 1 The conversion application was producM in a cooperative effort involving TU !
Electric Pacific Gas and Electric Cot, any, Wolf Creek Nuclear Operating Corporation, and Union Electric Company (hereafter the " Group").
1 The NRC staff has stressed the value of licensees working together to I increase standardization and to reduce the NRC resources needed to act on licensing matters. In response to these recommendations and in recognition of the benefits that result, TU Electric chose to work jointly with the Group in the conversion of the CPSES Technical Specifications. TV Electric believes the benefits, both near term and long term, clearly justify this ,
action, l The Group jointly developed conversion applications based on NUREG 1431 l Retision 1 (reference 1). Submittals for all four utilities address the l generic features of the Group members' CTS in an identical fashion, include l comparison tables to correlate the Group members' conversion applications, and are being docketed at approximately the same time. The Group anticipates an approximate nine month review by the NRC with the resultant review cost savings for each utility as outlined at the previous meetings j between the Group and the NRC. This conversion process has been based on !
the following understandings reached with the NRC: l
- 1. Each plant may maintain its licensing basis as established by its CTS in the conversion process. With appropriate !
justification, a given utility may optimize their ITS based on '
v another Group member's CTS. The goal is to maximize i commonality. I
c Attachment 2 to TXX 97105 Page 3 of 9
- 2. Plant specific license amendment requests (LARs) will continue to receive timely consideration during the conversion process and especially during the NRC review cycle. The Group will screen and limit these to the extent possible, yet it must be recognized that LARs in support of reloads and LARs representing either safety issues or significant cost savings will receive ,
due consideration. Where possible LARs . submitted during the next 18 months wili be jointly developed and submitted by the Group to conserve NRC review resources.
- 3. The effective date for new Surveillance Requirements with a fuel cycle frequency, imposed as a result of the conversion, will be the next refueling outage occurring after the implementation of the individual plant's amendment. A specific license condition is proposed below to incorporate this item.
- 4. Given commitment to conversion, enforcement discretion will not be denied or delayed solely on the basis that a given plant has not yet converted, especially when the basis of the requested discretion is NUREG 1431 Revision 1. Each request for such discretion will be judged on its own merit. I
/N Conversion Aco11 cation '
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The proposed amendment represents a conversion from the current Technical l Specifications (TS) to a set of improved TS based on NUREG 1431, " Standard j Technical Specifications, Westinghouse Plants," Revision 1, dated April l 1995. As part of this submittal, the criteria contained in 10 CFR l 50.36(c)(2)(11) to the current TS and using NUREG 1431 as a basis, developed ;
a proposed set of improved TS (ITS).
Enclosure 5A of each attachment provides a list of applicable travelers for j that section of the ITS. The list identifies the traveler number (the Technical S)ecification Task Force (TSTF) number is provided if assigned, ,
otherwise t1e owners group number is used), the traveler's status with !
respect to that section (i.e., incorporated, not incorporated), the difference number (s) used to discuss the difference from NUREG-1431 Rev. 1, and comments. The comments are used to explain the manner in which the l traveler is being treated when such explanations are deemed to be beneficial, l
In general, the JLS members incorporated travelers as they become available.
Travelers may not have been incorporated for various reasons including: the traveler is disapproved by the NRC, the traveler is received too late to incorporate into the package, the traveler contains changes which are not consistent with the plant specific design or CTS etc. October 1996 was the cut off for travelers for this conversion effort. If a traveler has )
been approved by the Westinghouse Owners Group (WOG) Hini group (or higher) !
it was considered and addressed in the conversion application (see Enclosure 1 (n)
" 5A in each section). Later travelers were only considered if there was a safety impact or a significant operational impact.
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Attachment 2 to TXX 97105 (q/
f Page 4 of 9 In general travelers are designed to reflect a single change and it would not be appropriate to incorporate a portion of the traveler without incorporating the entire traveler. In a few cases, however, multiple changes were rolled into a single traveler. Some of those changes may be appropriate for a given plant while other changes may not. Since travelers are approved by a majority vote, a majority cf the owners group members may be served properly by the traveler but some individual plants may not.
Travelers were generally incorporated in their entirety or not at all but in a few rare cases, only portions of a traveler were incorporated.
The traveler process is dynamic. Travelers continue to be generated, changed, approved, denied and denied with comment. For those travelers which have change status (e.g., been revised, been denied by the HRC), the JLS members will work with the NRC to properly address the changed status in the conversion applications. It is anticipated that most travelers which are denied by the NRC will be backed out of the applications in a supplement to the applications.
The JLS members used the bulletin board version of NUREG 1431 Revision 1 as of April of 1995. When the NRC made corrections to the bulletin board version, these editorial corrections were incorporated into our conversion without justification.
O V In order to address new Surveillance Requirements imposed by the Technical l Specifications approved and issued as a result of this LAR, the following i license condition is proposed For Surveillance Requirements (SRs) not previously performed by )
existing SRs or other plant tests, the requirement will be 1 considered met on the implementation date and the next required test will be at the interval specified in the Technical Specifications as revised in Amendment No. [ ] for CPSES Unit 1 and Amendment No. [ ] for Unit 2. 1 l
i II. DESCRIPTION OF PROPOSED TECHNICAL SPECIFICATION REQUESTS l The overall format for the conversion application is as follows:
Cover letter Affidavit (Attachment 1)
General Description and Assessment (Attachment 2)
- Tables of changes not within the scope of full conversion to the ISTS and of pending or proposed LARs which could impact the conversion application review (Attachment 3) q j' - Specific change descriptions and evaluations (Attachments 4 through 18) i
cm Attachment 2 to TXX 97105
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Page 5 of 9
- Each of these attachments (4 though 18) includes the following:
o Cover sheet o Index of Enclosures o Enclosure 1 Cross Reference Tables o Enclosure 2 - Mark up of CTS [NUREG 1468]
o Enclosure 3A Description of changes to CTS o Enclosure 3B Conversion Comparison Table - CTS o Enclosure 4 NSHC o Enclosure SA Mark-up of NUREG 1431 Specifications o Enclosure 5B Mark up NUREG 1431 BASES o Enclosure 6A Differences from NUREG 1431 o Enclosure 6B - Conversion Comparison Table NUREG 1431
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ITS Specifications and Bases (with proposed changes to the ISTS incorporated) Attachments 19 and 20.
The conversion application does not contain a separate Criteria Application Report. As previously discussed with the NRC, the same information has been integrated into the application. There will be no matrix of the LCOs versus the 10 CFR 50.36 criteria. A separate Criteria Application Report is not necessary based on the degree to which each of the JLS members have already completed the " split" activity.
The methodologies used to mark up the CTS and the ISTS are explained in the appropriate enclosures of the attachments. These methodologies explain the techniques used and any abbreviations employed. As described in the methodology for Enclosure 2, the CTS has been marked up to denote the technical changes needed to convert the CTS to the ITS. The exceptions are the notes used to identify MODE change restrictions which are added to selected specifications. These notes retain reeded restrictions which are otherwise removed by the change in scope in LC0 3.0.4 from the CTS to the ITS. These notes are not included in the CTS markup for the affected specification but are listed in the "LCO 3.0.4 Evaluation Matrix" which is attached to LS 1 in Enclosure 4 to Attachment 6 (CTS Section 3/4.0 / ITS Section 3.0).
The conversion application iden+.ifies the material deleted from the Bases
,, via strikeout. Redline is used to show the material which wiil be added to (j the Bases. Identification numbers are not assigned and justifications are
c Attachment 2 to TXX 97105
( Page 6 of 9 not submitted for these changes. This approach had been discussed with the NRC during previous meetings.
The brackets are used in some descriptions, NSHC (No Significant Hazards Consideration) evaluations or justifications when brackets provide a clear, convenient means of denoting plant specific differences. This was determined to be the most efficient and effective way to identify such differences.
The movement of a requirement from one specification in the CTS to a different specification in the ITS is denoted through the use of an "A" item number and description along with the cross reference table.
In order to achieve as much consistency in the license requirements as possible, the JLS members adopted the following policy with respect to renumbering Limiting Conditions for Operation (LIMITING CONDITIONS FOR OPERATION (LCOS)), Conditions, Required Actions or Surveillances when converting from the ISTS to the ITS.
> In general. LIMITING CONDITIONS FOR OPERATION (LCOS) will not be renumbered if an LC0 is deleted. The JLS members felt that if licensees renumber the LIMITING CONDITIONS FOR OPERATION (LCOS), a strength of the p ISTS will be we_kened in that it will be more difficult to compare one plant to another. The JLS members may choose to renumber specifications if a
(-) traveler is approved by the NRC which does so. The JLS members will encourage the Westinghouse traveler review group to not include the renumbering of LIMITING CONDITIONS FOR OPERATION (LC05) in future travelers.
> In Conditions and Required Actions, the steps will be relettered. The JLS members felt that the use of "Not Used" for deleted steps was not conducive to clear understanding by the operator especially under the stress of ;
abnormal plant conditions. Specifications 3.3.1 and 3.3.2 are exceptions to this rule. The conditions in these two specifications are not being re-lettered even though some conditions may have been deleted for some plants.
> Surveillance Requirements (SRs) will not be renumbered. The numbers for deleted surveillances will be retained and labeled "Not used" in the specification. If the SR is the last one in the specification, it will be l deleted entirely.
III. ANALYSIS The proposed changes to the CTS have been categorized into five general groupings. These groupings can be characterized as administrative changes. I relocated changes, moved changes, more restrictive changes, and less i restrictive changes.
Nontechnical administrative changes ("A" changes) were intended to 1 O
d incorporate human factors principles into the form and structure of the improved TS so that they would be easier to use for plant operations i
c Attachment 2 to TXX 97105
! Page 7 of 9 personnel. Administrative changes are editorial in nature or involve the reorganization or reformatting of requirements without affecting technical content or operational requirements. The proposed changes include: (a) adopting the form and format of the ISTS and (b) reorganizing the specifications and the infors;;ation within the specifications in a manner consistent with the ISTS.
Relocated changes ("R" changes), those current TS requirements which do not satisfy or fall within any of the four criteria specified in 10 CFR 50.36(c)(2)(ii) may be relocated to appropriate " licensee controlled documents." In the attachments, the document to which requirements are being relocated is generally identified. The relocated limiting conditions :
for operation (LCO) portion of the CTS, which includes the system description, design limits, functional capabilities, and performance levels, will be relocated to a licensea controlled document. Changes to these licensee controlled documents will be made pursuant to 10 CFR 50.59 or other appropriate control mechanisms. These changes reduce the number of current TS requirements but the actual commitment to continue to perform the requirement will be unchanged upon implementation of ITS.
Material is relocated to the types of documents (licensee controlled documents) described below: l
/> \
b > Documents which have controls defined by regulations (e.g., the Quality Assurance Program (10 CFR 50.54(a)), the Security Plans (10 CFR 50.54(p)),
the Emergency Plan (10 CFR 50.54(q)), and the Final Safety Analysis Report 1 (FSAR) (10 CFR 50.59)).
> Documents which have controls established by License Conditions (e.g., the Fire Protection Report for most plants)
> Documents which have controls established by the Programs and Manuals section of Administrative Controls in the Technical Specifications (5.5 in 1 the ISTS). For example, the Offsite Dose Calculation Manual, Ventilation !
Filter Testing Program, and TS Bases are documents whose controls are established by the TS.
> Documents which are incorporated into the one of the documents above by reference and, as such, come under the same controls as the document into which it is incorporated (e.g., some licensees have specifically created a document, a Technical Requirements Manual, which contains relocated specifications removed from the technical specifications and which is incorporated into the FSAR by reference, thus falling under 10 CFR 50.59).
I Hoved changes ("LG" changes) are a subset of the relocated changes. Hoved changes are those current TS descriptions or details which do not establish requirements but do provide information on how requirements are satisfied.
, As such, moved changes do not satisfy or fall within any of the four l (qj criteria specified in 10 CFR 50.36(c)(2)(11) and may be relocated to l appropriate " licensee controlled documents." Changes to these licensee )
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controlled documents will be made pursuant to 10 CFR 50.59 or other appropriate control mechanisms. These changes reduce the complexity and :
detailed prescriptive nature of the TS but the commitment to satisfy these l moved descriptions and details will be unchanged upon implementation of the ITS. i Hore restrictive changes ("H" changes) are those which either are more i conservative than corresponding requirements in the CTS. or are additional restrictions which are contained in NUREG 1431 but are not contained in the CTS. Examples of more restrictive requirements include: planning an LC0 for plant equipment which is not required by the current TS to be operable: more restrictive requirements to restore inoperable equipment; and more restrictive Surveillance Requirements (SRS).
Less restrictive changes ("LS" and "TR" changes) are those where current requirements are relaxed or eliminated, or new flexibility is provided. The more significant "less restrictive" requirements are justified on a case by-case basis. When requirements have been shown to provide 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 (a) generic NRC actions, (b) new NRC staff positions that have evolved from technological advancements and operating l O experience, or (c) resolution of the Owners Groups' comments on the ISTS. )
V Generic relaxations contained in NUREG 1431 were reviewed by the staff and found to be acceptable because they are consistent with current licensing ,
practices and NRC regulations. The licensee's design was reviewed to !
determine if the specific design basis and licensing basis are consistent with the technical basis for the model requirements in NUREG 1431 and thus provides a basis for these revised TS. To be conservative, some items have been identified as "less restrictive" even though the revision could be considered compliant with the CTS. Making the item "less restrictive" is not intended to be an admission that the plants may not have been compliant with the CTS in the past but rather an attempt to avoid a potential area for unnecessary debate as the change can be properly addressed as a "less restrictive" change.
These administrative, relocated, moved, more restrictive and less restrictive changes to the requirements of the CTS do not result in operations that will alter assumptions relative to mitigation of an analyzed ,
accident or transient event. I In addition to the changes described above, the licensee proposed certain changes to the CTS that are both less restrictive and are not within the scope of application for conversion to the guidance of NUREG 1431. All of the differences will be reviewed by the NRC staff and a determination will be made regarding the approval or disapproval of each item as a part of this licensing action. Specifically, the licensee identifies the instances where their submittal varied for the provisions of NUREC 1431. See Attachment 3.
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Attachment 2 to TXX-97105 Page 9 of 9 IV. SIGNIFICANT HAZARDS CONSIDERATION DETERMINATION Separate enclosures have been provided in Attachments 4 through 18 to l provide "no significant hazards consideration" evaluations for the changes provided in the associated attachments. The conclusion of each of the evaluations is that a no significant hazard consideration determination is justified, IV. ENVIRONMENTAL EVALUATION I
An evaluation of the proposed changes has determined that these changes do not involve (1) a significant hazard consideration, (ii) a significant :
change in the types or significant increase in the amounts of any effluents that may be released offsite, or (iii) a significant increasing individual l or cumulative occupational radiation exposure. Accordingly, the proposed ;
changes meet the eligibility criterion for categorical exclusion set forth '
in 10CFR51.22(c)(9). Therefore, pursuant to 10CFR50.22(b), an environmental i assessment of the proposed changes is not required.
VI. REFERENCES !
- 1. NUREG 1431 " Standard Technical Specifications, Westinghouse Plants," Revision 1, April 1995. ;
- 2. NUREG 1366, " Improvements to Technical Specification Surveillance Requirements." ;
- 3. Generic Letter 93 05, "Line Item Technical Specification Improvements to Reduce Surveillance Requirements for Testing !
During Power Operation."
- 4. NRC letter from Mr. William T. Russell to Hessrs. Lee Bush, i Blair Wunderly, Brian Woods and Ray Barker dated October 25, !
1993.
- 5. NUREG 1024 " Technical Specification Enhancing the Safety Impact." i
- 6. NRC Administrative Letter 96 04, " Efficient Adoption of Improved Standard Technical Specifications." dated October 9,1996. l
- 7. Nuclear Energy Institute (NEI) 96 06, " Improved Technical Specifications Conversion Guidance," dated July 1996. ;
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Attachment 3 to TXX 97105 (qj Page 1 of 8 l TABLE OF CHANGES NOT WITHIN THE SCOPE OF FULL CONVERSION TO THE ISTS: l l
ITS Section Chance No. Eescriotion l l
3.3 3.3-27 Adosts manufacturer's recommendation for calibration i of lydrogen monitors.
3.3-132 Trip Setpoint for EDG start instrumentation moved to Bases per reviewers note for RTS and ESFAS.
3.6 3.6-13 A note is added to delete surveillance requirement to leak test containment ventilation isolation valves with resilient seals if the flow path is isolated by a leak tested blank flange.
3.7 3.7 11 The Required Actions for the Feedwater Isolation Valves is modified to incorporate the isolation capabilities of the Feedwater Control Valves and their associated bypasses. This is not in the CTS but is a plant specific attempt to modify the ISTS.
which assumes fully qualified Feedwater Control Valves to match the CPSES plant specific design, which has valves which are capable of isolation but are not fully qualified (proposed LCO 3.7.3) 3.7-32 The ISTS action for UHS regarding an inoperable cooling tower fan has been adapted to provide appropriate actions for SSI level less than required, because CPSES relies on an SSI rather than cooling towers.
3.7 39 An SR (w.7.12.6) is added to require verification that non ESF PPVS fans stop on actuation signal.
3.7-46 This changes the TS for Fuel Storage Area Water level from "23 feet over the top of irradiated fuel assemblies seated in the storage racks" to "23 feet over the top of the storage racks."
3.7 48 The UPS HVAC specification is provided in two ve>f si ons. 3.7.20 is the conversion of the CTS.
3.7.20P is the conversion of the proposed changes to this LC0 as submitted to the NRC in License Amendment Request 95 009.
' Changes to the ISTS except those which involve the incorporation of plant specific design information, which were developed as part of the o industry traveler process, which are editorial corrections, which correct
() inconsistencies between specifications or which incorporate CTS information; and changes to the CTS which do not merit a separate LAR.
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Attachment 3 to TXX-97105
- .Page 2 of 8 -i ITS Section Chanae No. Descriotion !
3.8 CTS 3/4.8- .
01 61-M ' Revised acce> table voltage range to match ISTS Bases j which says tle acceptable values should be based upon acce) table voltages for the class 1E loads ;
(rather t1an the design range for the EDG itself). l 3.8 10 The minimum fuel levels for the EDGs incorporates the proposed changes. in LAR 95 002. j 5.0 CTS 3/4.0 ,;
01 15 A (See ITS 5.5.9. c.4.a.8).) The definition of " Tube ;
Inspection" is clarified to eliminate potential misunderstanding with regard to the required point of entry. .l CTS 6.0.
.03-15 M Adds, to the COLR, the refueling boron concentration :
limits. l 5.5 6 Controls for the Technical Requirements Manual have !
been added to the Administrative Controls section of the ITS (proposed specification 5.5.16) 5.7 1 Radiation limits for High Radiation Areas are !
revised to reflect the requirements of revised 10 CFR 20 (proposed specification 5.7) ,
tf f
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I Attachment 3 to TXX 97105 Page 3 of 8 Eendino or Pro.iected (LARs) Which Could Potentially Imoact the Review of this Conversion Anolication i Pending LARs:
i i LAR Number Description Comment LAR 96 004 Addition of Fan Coil Units to UPS Duplicate markups HVAC System provided in Section :
3/4.7 LAR 95 002 Diesel Generator Fuel Oil Storage Incorporated in System Minimum Volume conversion application LAR 94 020 Main Steam Isolation Valves This change essentially adopted the ISTS.
Additional changes are proposed in the attached conversion LAR.
LAR 96 003 Increase in Allowed Outage Time for Not incorporated in a Charging Pump from 72 Hours to 7 conversion application.
Days LAR 96 003 Steam Line Pressure Low Allowable Not incorporated in i Value conversion application.
Projected LARs:
LAR Number Description Comment i
Not Change in frequency of slave relay No submittal schedule assigned testing.
Not Unit 2 Cycle specific changes Needed approved to assigned support startup after fall 1997 outage.
O i
a . - , ,
q Attachment 3 to TXX 97105 Q Page 4 of 8 ACRONYMS AND ABBREVIATIONS Below is provided a list of the more broadly used acronyms and abbreviation.
The list is not intended to be a complete. Acronyms of abbreviations which have only limited use and which are properly defined where used are not included in this list.
"[ ]" Brackets which are used in Enclosures 3A, 3B, 4, 6A and 6B to enclosure portions of the application which are specific to the conversion application in which the portions are contained. Other applications may have different in formation in that part of an otherwise generic part of the parallel conversion applications.
Empty brackets indicate that one or more of the other parallel applications have plant specific information in that location.
"A" Change code for an Administrative Change to the CTS AFD Axial Flux Difference AFW Auxiliary Feedwater A0T Allowed outage time APP APPLICABILITY ASP Alternate or Auxiliary Shutdown Panel n "B" Change code for " Bracketed" information in the ISTS which indicates that the bracketed information was adopted in U the ITS BDMS Boron Dilution Hitigation System "B PS" Change code for " Plant Specific" information which has been inserted in a " Bracketed" portion of the ISTS B0P Balance of plant BWOG Boiling Water Owners Group BWR Boiling Water Reactor CE0G Combustion Engineering Owners Group CFR Code of Fedvral Regulations CN Change number a number assigned to a change to the CTS or the ISTS in the conversion application COLR Core Operating Limits Report COT Channel Operational Test CPSES Comanche Peak Steam Electric Station CR Control Room CRC Corporate Review Committee generic term for the various corporate safety committees CTS Current Technical Specifications
,3
)
- . . - . - _ ._ . . ~ . . . . . . __-___ _._ _ _ _. _ _. _..
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s _
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4
- ~C -Attachment 3 t'o'.TXX 97105L i (g .Page 5.of 8- ,
ACRONYMS AND ABBREVIATIONS (cont.)
. /
j DBA Design Basis Accident as defined by the plant specific licensing basis ;
i .DC Diablo Canyon i DCPP Diablo Canyon Power Plant' '
DG(s) Diesel Generators- l
< ED" Change code used to identify " Editorial" changes made to i
- enc 1. Enclosure - .
.ESF - Engineered Safety Feature l
.ESFAS -Engineered Safety Feature Actuation System ,
FHA Fuel Handling Accident as defined by the plant specific licensing basis FSAR Updated Final Safety Analysis Report per 10 CFR 50.71(e) !
FW Feedwater i Group The four licenseen (PG&E, TU, UE, and WCNOC) which have !
joined together to convert the CTS and to produce parallel !
- conversion applications !
HSP Hot Shutdown Panel f
Improved STS ' Improved Standard Technical Specifications, NUREG 1431, '
Rev, 1. April 1995 Improved TS Improved Technical Specifications the proposed plant :
specific Technical Specifications developed from the ISTS l IR Intermediate Range- ;
ISTS Improved Standard Technical Specifications NUREG 1431,' i Rev. 1 April 1995 !
ITS Improved Technical Specifications the proposed plant .
specific Technical Specifications developed from the ISTS !
- . JCRC Joint Corporate Review Committee A subcommittee of the l CRCs for PG&E, TU, UE, and WCNOC organized to perform an
initial joint CRC review for the various licensees ~
JLS. Joint Licensing Subcommittee A working group composed of - ;
members from PG&E, TU, UE and WCNOC to share resources and !
[ to work together in common licensing matters
- ' LA . License Amendment !
LAR License Amendment Request O :
('
Attachment 3 to TXX 97105
-Page 6 of 8 ACRONYMS MD., ABBREVIATIONS (cont.)
LCD Licensee Controlled Document A plant specific document l which has change controls which include the change l criteria established by 10 CFR 50.59 (e.g. the FSAR), j similar regulatory requirements (e.g.,10 CFR 50.54a for ,
the QA Plan), or the Administrative Controls Section of '
LC0 Limiting Condition for Operation LDCR Licensing Document Change Request the document or form 1 to initiate changes to licensing documents such as the ;
FSAR, TS, etc. I LER Licensee Event Report "LG" Change code for a Less Restrictive Generic Change (moving technical or descriptive information to a licensee controlled document) to the CTS LOP Loss of Power "LS" Change code for a Less Restrictive change to the CTS LSSS Limiting Safety System Setting "M" Change code for an More Restrictive change to the CTS MFIV Main Feedwater " isolation Valve mini group WOG MERITS Mini Group the group of utilitios within the
- WOG that are acting on potential generic changes to the t ISTS MSIV Main Steam Isolation Valve MSSV Main Steam Safety Valve N/A Not applicable NA Not applicable !
NEI Nuclear Energy Institute Not Used Generic term use to hold a place in the numbering system for LCOs. SRs, etc to indicate a generic requirement which does not apply to that specific unit NRC U.S. Nuclear Regulatory Commission NSHC No Significant Hazards Consideration evaluation per 10 CFR 50.92 NSSS Nuclear Steam Supply System NUREG- Generic designator used to identify reports issued by the NRC or NRC contractors NUREG 1431 Improved Standard Technical Specifications, NUREG 1431.
Rev. 1. April 1995 ODCM Offsite Dose Calculation Manual OL Operating License 005 Out of Scope or beyond the scope of an ITS conversion
L Attachment 3 to TXX-97105 Page 7 of 8 ACRONYMS AND ABBREVIATIONS (cont.)
PAM Post Accident Monitoring ;
Post Accident Monitoring System
~
PAMS !
Para Paragraph
. PG&E Pacific Gas and Electric Co.
PR Power Range "PS" Change code for a Plant Specific change to the ISTS PWR Pressurized Water Reactor QA Quality Assurance OPTR Quadrant Power Tilt Ratio i
"R" Change code for a Relocation change (relocation to a licensee controlled document outside of TS) to the CTS RCP Reactor Coolant Pump ,
RCS Reactor Coolant System R0 Reactor Operator RSP Remote Shutdown Panel RTB Reactor Trip Breaker RTP Rated Thermal Power RTS Reactor Trip System l RWST Refueling Water Storage Tank
,O S^a SDM UPo tee r4# 1 S fetx ^# ixs4 aePert Per 1o cra so.71<e)
Shutdown Margin SE NRC issued Safety Evaluation SFDP Safety Function Determination Program SG Steam Generator SI Safety Injection SIS Safety Injection Signal SL Safety Limit SR Surveillance Requirement SR Source Range :
SRC Safety Review Committee - Generic term for the various -
safety committees for the participating licensees SR0 Senior Reactor Operator SSPS Solid State Protection System STA Shift Technical Advisor STB Staggered Test Basis STS Standard Technical Specifications TADOT Trip Actuating Device Operational Test TRM Technical Requirements Manual TS Technical Specifications TSTF Technical Specification Task Force TU TU Electric C) v ,
Attachment 3 to TXX 97105 Page 8 of 8 ACRONYMS AND ABBREVIATIONS (cont.)
UFSAR Updated Final Safety Analysis Report per 10 CFR 50.71(e)
Updated FSAR Updated Final Safety Analysis Report per 10 CFR 50.71(e)
USAR Updated Final Safety Analysis Report per 10 CFR 50.71(e)
UV Undervoltage "TR" Change code for a Technical Change (recurring - less restrictive) to the CTS UE Union Electric Co.
WC Wolf. Creek WCAP- Generic designator used to identify reports issued by Westinghouse WCNOC Wolf Creek Nuclear Operation Corp.
VFTP Ventilation Filter Testing Program WOG Westinghouse Owners Group O
O
!o RS CONVERSIONTO l INIPROVED TECilNICAl SPECIFICATIONS l
COMANCIIEPEAK i
i STEAM El.ECTRIC STATION i ATTACHMENT 4 l
l l CTS 1.0 -DEFINmONS l
iTsi.e -BSE AND APPLICATION lO l
- SM k
! E A ;
! i l
l !
l TUFI FClRIC" f
A()-
. IMPROVED TECHNICAL SPECIFICATIONS CONVERSION CURRENT TS SECTION 1.0 CONTENTS t
(
- ENCLOSURE 1 - CROSS-REFERENCE TABLES
(
k
- ENCLOSURE 2 - MARK-UP OF CU'RRENT TS ENCLOSURE 3A - DESCRIPTION OF CHANGES TO CURRENT TS !
ENCLOSURE 3B - CONVERSION COMPARISON TABLE - CURRENT TS ENCLOSURE 4 - NO SIGNIFICANT HAZARDS CONSIDERATIONS ENCLOSURE 5A - MARK-UP OF NUREG-1431 SPECIFICATIONS ENCLOSURE SB - MARK-UP OF NUREG-1431 BASES ENCLOSURE 6A - DIFFERENCES FROM NUREG-1431
- I ENCLOSURE 6B - CONVERSION COMPARISON TABLE - NUREG-1431 1
-m_ % L . --ae.d.w-- 4 _s- > de a a a4mm ,
O ENCLOSURE 1 CROSS-REFERENCE TABLES O
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CONVERSION CROSS-REFERENCE CONTENTS i CONVERSION TABLE SORTED BY CURRENT TS (2 Pages)
[
CONVERSION TABLE SORTED BY IMPROVED TS (1 Page) - ,
METIIODOLOGY (3 Pages) ;
i S
- O
J CROSS-REFERENCE TABLE 1 ,
4/24/97 Page 1 ( Sorted by Current TS ) .
Current TS Improved TS -l Item Code Para Ites Code Para I
. _1 2.1_ 1.1 -
J12 1.1 1.3 1.1 :
1.4 1.1 1.5 1.1 =
1.6 1.1 3.7 Not Used ;
Not Used 1
]),8 1.1 T
_1J0. 1.1
_1J1 Not Used
,JJ2 31 !
i J.13_ 1.1 l
1.14 1.1 ;
1.15_ Not Used i
_12 16 1,1 .
J417 l1 l
_1,18 Nat Used .'
O JJ9 5.5.1 V J.20 1.21 1.1 1.1 !
1.22 1.1 1.23 1.1 J,24 Not U_s.ed
_1_125 Relocated FSAR ,
1.26 Not Used New 1.1
.L 27 _1.1 J228 J.1 1.29 1.1 ;
JJO_ Not Used
't
_1J1 a J.1 L31 New 11 1
J132 Not Used ;
J 33 1.1 3234_ Not Used
{
JJS a 1.1 ,
J J5 b Not_Used JJ6 j .1_ .
_1J7 1.1 t lj j
.L 38 3 j 39 { NoLUsed l
l
CROSS-REFERENCE-TABLE 1
.4/24/97
" age 2 ( Sorted by Current TS )
Current TS Improved TS Item Code Para Item Code Para l
_1. 40 Not Used
_L41 Not Used
_ Table 1.1 Not Used ,
Table 1.2 Table 1.1 1 i
New 1.2 l l
New 1.3 !
I New 1.4 l O .
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CROSS-REFERENCE TABLE 1
.4/24/97 Page 1 ( Sorted by ITS )
Current ~- Improved TS Item Code Para Item Code Para
~
11 1.1
_1. 2 1.1 14 _11 1 1.5 _1,1 1.6 1.1 13 - 1.1 19 1.1 1.10 1 1.1 1.12 1.1 1
2 13 11 1 14 1.1
_6,832 a 1.1 1 16 1.1 1.17 1.1 1.20 1.1
_12.1 1 1.1 1.22 1.1 1 23 1.1 O _1.1 New 1.27 1.1 1.28 1.1 1 29 1.1
,j 1 31 a _111 l 1 31 i New 1.1 l 1.33 1.1 1 35 a 1.1 1.36 1.1 1 37 _1j 1 38 1.1 1
Table 12 2 Table 1.1 1 New _122 New 1.3 New 1.4 C
)
Methodology For Cross-Reference Tables The cross reference tables provide a guide to location of all current TS LCOs, Actions, Surve111ances, Tables and Figures in the improved TS. It also includes the location of items that have been located out of the improved TS.
The cross reference table contains the following columns:
Current TS1 LC0/SR number (item) -
This column lists the LC0 or SR number which applies as listed in the associated technical specification.
Requirement code (Code) -
This column identifies the portion of the specification affected using the following code:
LC0 The LC0 operability requirement APP The APPLICABILI1Y requirement CONDITION / ACTION The ACTION requirements
, SR The SURVEILLANCE REQUIREMENTS
! Note: The applicability of a current specification is assumed to transfer to the same improved specification as the LCO. The cross reference for the applicability for the specification is only identified in the table by a separate entry if the cross-l reference is not clear (e.g., several current specifications with different applicability are moved into the same specification in l
the improved TS. or a footnote in the applicability of the current TS is moved to a different portion of the specification in the improved TS).
i Paragraph (Eata) -
This column identifies the affected paragraph. In general, the numbering and lettering used in the current TS will be provided but in some cases it may be
. appropriate to provide a description. For example in specification 3/4.7.7.1, the actions are arranged by those that apply in Modes 1, 2. 3, & 4 and those that apply in Modes S, 6 and during movement of irradiated fuel assemblies.
Appropriate entries in this column for these respective actions might be ,
" Modes 1 4" and " Modes S. 6, etc." Hultiple paragraphs are not listed in the {
same row (e.g., "a and b"). '
Methodology l of3 S/15/97
Methodology for Cross Reference Tables q (Continued)
V :
New This item has been added to reflect a requirement in NUREG 1431 that is not eddressed in the current TS ,
NA This item is not in the current TS because it does not apply.
Note: When a single paragraph in the current TS crosses to multiple locations in the improved TS a new entry is made for each cross 4
reference. A single entry is not used to identify the multiple paragraphs in the improved TS. Since multiple paragraphs in the current TS may cross reference to the same paragraph in the improved TS. separate entries, each referencing the same location in the improved TS, are made for each such paragraph in the current TS.
Imoroved TS:
l LC0/SR number (Item) -
This column lists the LC0 or SR number which applies as listed in the associated specification or uses the following code:
Relocated This item is relocated to another licensee control ;
document outside the TS (See Code for specific reference location). -
Requirement code (Code) -
This column identifies the portion of the rpecification affected using the following code:
LCO The LCO operability requirement APP The APPLICABILITY requirement CONDITION / ACTION The ACTION requirements !
SR The SURVEILLANCE REQUIREMENTS In addition specific plant document acronyms are used to list the licensee ,
controlled documents where the item will be relocated to (e.g. ESAR. TRM. or !
plant procedures) ;
Note: The applicability of a current specification is assumed to ,
transfer to the same improved specification as the LCO. The ;
k hiethodology 2 of3 $/15/97 L
i
t Hethodology for Cross-Reference Tables (Continued)
- )
cross reference for the applicability for the specification is ,
only identified in the table by a separate entry if the cross- ;
reference is not clear (e.g., several current specifications with :
. different applicability are moved into the same specification in L
the improved TS, or a footnote in the applicability of the current TS is moved to a different portion of the specification ,
in the improved TS).
r 4
Paragraph (Para) -
L This column identifies the affected paragraph. In general the numbering and >
lettering used in the improved TS is provided but in sore cases it may be appropriate to provide a description. ,
New This item has been added to the improved TS and was not 4
addressed in the NUREG 1431. i Not Used This item will not be used in the improved TS, nor relocated to another document (e.g., requirements already l adequately addressed by regulations)
NA This item from NUREG 1431 is not included in the improved TS because it does not apply (e.g., specification unique [
to Ice Condenser Containments). ,
l Note: The paragraph is only identified to the extent necessary to ;
adequately describe the cross-reference. For example, if the :
cross reference applies to the entire condition, it is appropriate to list the " Requirement Code" as " CONDITION" and the ;'
" Paragraph" as "A", If the correct cross reference is only to the required action, an appropriate cross reference would be to ;
" Requirement Code" as "ACT" and " Paragraph" as "A.1." ,
Note: When a single paragraph in the current TS crosses to multiple locations in the improved TS, a new entry for each cross ,
reference is made. Since multiple paragraphs in the current TS may cross reference to the same paragraph in the improved TS, ,
separcte entries, each referencing the same location in the improved TS, is made for each such paragraph in the current TS.
Multiple paragraphs are not listed (e.g. "A.1.1 and A.1.2") -
although a " higher tier" number is be used to cover all sub-paragraphs (e.g... "A.1" is be used to identify all subparagraphs such as A.1.1 A.1.2, etc.). !
Methodology 3 of3 $/1587 l
O i
ENCLOSURE 2 .
4 4
MARK-UP OF CURRENT TS i
l i 4
Mark-up (13 Pages) l l Methodology (2 Pages) ,
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e - - - - - . - - - - - - - - - - - - - - - - <-------,----e .- , . m -
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l 4 l'.0"~; USEiAIS: APPLICATION 1.01 DEFINITIONS >
The defined terms of this section appear in capitalized type and are applicable !
1*l-^ .
i throughout these Technical Specifications and; Bases. ;
ACTION M ACTIONS shall be that part of a Technical- Specification whichtthat prescribes 1*l-^ ^
remedfel ;c:sures required Required;Actionsito'beltaken under designated .
econditions zwithinithe:specifiedicompletion.; Times.
ACTUATION LOGIC TEST M An ACTUATION LOGIC TEST shall be the application of various simulated or 141-^ -
actual input combinations in conjunction with each possible interlock logic state and verification of the required logic output. The ACTUATION LOGIC TEST shallCas a~ minimum l include a continuity check, as a minimum, of output devices.
i AMEOG CHANNEL OPERATIONAL TEST (C0TU M An ,'fi'iOC C".'f:NEL OPERATI0'"L TEST EC01 shall be the injection of a .
' 142-A
> simulated oriactual signal into the channel as close to the sensor as practicable to verify 0PERABILITY of including al_licomponentsjin;the: channel.rsuch:asIalarms. 1 n-A j interlocks, displays. and/or trip functions required;to;perfo_rmitheJpecified O safety; function (s). The:COTimay be: performed by;meansiofiany.serjes:of sequenti al ;novetl appi ng 'oritotal 7channelf steps 'so;that;theienti re!channellj s 1-30 A tes.t.ed.! The .'fi'100 C".'f NEL OPERATI0';"L TEST COTjshall include adjustments, as necessary, of the required alarm, interlock and/or Trip Setpoints such that the setpoints are within the required range and accuracy.
AXIAL FLUX DIFFERENCE (AFD M 4 AXIAL IL"X DIFFERENCE AFD shall be the difference in normalized flux signals !
' 141 ^ -
between the top and bottom halves of e four section an excore neutron detector.
CHANNEL CALIBRATION i
- M A CHANNEL CALIBRATION shall be the adjustment, as necessary, of the channel 4 such so that it responds within the required range and accuracy to known values of ,
input. The CHANNEL CALIBRATION shall encompass thosel components;the entire 1-n A ' ,
chanaci, including the required such;as; sensors, alarms. interlock, displays, and l
trip functionsTirequiredjto? perform;thelspecified; safety; functions (s)? -
1 **
Calibration olinstrument; channels;with' resistance temperatur.e;detectot:(RTD)!ot s
thermocouple 1 sensors:may consist:of'anMnplace:qualit.ative; assessment;ofJsenson behaviot;and normalicalibrationJof;the; remaining; adjustable: devices;in';the;channelI3 Whenever2a; sensing: element;1sireplaced,1the next; required 1CHANNELTCALIBRATIONishal] J jncludelan:jnplace:ctoss; calibration;that?. compares;the:other:sensingelements:witt}
thelrecentlyJjnstalJed; sensing el.ement:1The.CHANNELiCALIBRATI_0N end may be CPSES MarA-up of CTS- 1.0 1-1 5/15M7
- - N M
F, , >
li1' DEFINITIONS Y
1
- performed by any series of sequential, overlapping Cgjgt$tiatl, or total channel
- steps such that the entire channel is calibrated, o
CHANNEL CHECK l i
i
< h6 A CHANNEL CHECK shall be the, qualitative assessmentZ,),rAbstygjpg2 of
- channel behavior during operation by ;b ;rv; tier.. This determination shall Mi-* .
, include, where possible, comparison of the channel indication and/or status te w+th-other indications endor status derived from independent instrument channels -
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measuring the same parameter.
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1:1 DEFINITIONS CORE ALTERATIONS h9 CORE ALTERATIONS shall be the movement or manipulation of any fue]Esources]
QEteact1VitEcontrol components within the reactor picssure vessel with the Isis vessel head removed and fuel in the vessel. Suspension of CORE ALTERATIONS shall not preclude completion of novement of a component to a safe eenservative 3**
position.
CORE OPERATING LIMITS REPORT (COLR)
M0 The GORE-CPEPATING L4 HITS REPORT (COLR+ is the unit-specific document that provides cyclefspecific'lparamet;ec core operating limits for the current operating 1**
reload cycle. These cycle specific parametet core operating limits shall be determined for each reload cycle in accordance with Specification 6.9.1.6. Unit operation within these operating limits is addressed in individual specifications.
EICITAL CHANNEL OPEPsATIONAL TEST 1.11 A DICITAL C"'JlNEL OPERATIONAL TEET shall ccasist of exercising the digital comptttcr hardware-using-data base-manipulation and injecting simulated prccess 1**
p dete-to-ver+fy OPERA 0!LI"! of alerm-end/cr trip-functions.
DOSE EOUIVALENT I 131 1.12 DOSE EQUIVALENf I 131 shall be that concentration of I-131 (microcurie / gram) which alone would produce the same thyroid dose as the quantity and isotopic mixture of I 131, I 132,1 133,1-134, and I-135 actually present. The thyroid dose '
conversion factors used for this calculation shall be those listed in Table III of TID 14844, " Calculation of Distance Factors for Power and Test Reactor Sites" or Table E 7 of NRC Regulatory Guide 1.109, Revision 1, October 1977.
E - AVERAGE DISINTEGRATION ENERGY 1-13 I shall be the average (weighted in proportion to the concentration of each radionuclide in the reactor;; coolant:a,titheltime;oEtheZsampling semple) of the sum of the average beta and gamma energies per disintegration (irJ HeV/d) forlisotopes] 1**
otheGthanliodines! the-tedfonuclides with a halflife greater than ten (10) minutes maQng;uplat;1 east,.;95tiottne'totallnonfodiaCactivity in the coolant semple.
i 7
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LJ CPSES Mark-up of CTS- 1.0 1-3 S/158 7 l
fo 1;02pSEi#0;AP, PLICATION U J El DEFINITIONS ENGINEERED SAFETY FEATURES ESF) RESPONSE TIME
~ H 4 The ENCINEEREOA" ""TY TEAiljRES (ESF) RESPONSE TIME shall be that time interval from when the monitored parameter exceeds its ESF aActuation sSetpoint at 1"A the channel sensor until the ESF equipment is capable of performing its safety function (i.e., the valves travel to their required positions, pump discharge pressures reach their required values, etc.). Times shall include diesel generator starting and sequence loading delays where applicable. ThelresponseItime; Day;b6 veti fi edibyfmeans~oEany: series lloDeq0entialEoyerlappingZoEtotalistepsisolthat thelentirefresponse~ time;is;verjfied.
EBEO9ENGY-NOTAT40N 1.1S The ERE00ENCY NOTATION specified fcr the performence of Surveil +ence Requircacnts shell correspond to the intervals defined in Tabic 1.1. 1**
(NEW) 1 5 I]
Ihe; maximum 31] owableiprimary;contaj nsentJ eakage3 ate,Y L',Eshal))he!0;10Xof . ,,3g prjmary;contajnmentIajfrl.WejghtJpeCday3tithelcalculated peakicontaj_nmentjpItssure Q SP,n
-10EtHIIIED LEAKAGE LEAKAGE;shallbg
le. LEAKAGE Eeekege (except CONTROLLEO J L" EACE) into closed systcas, such asthatifrompumpsealiorvalvepackingfexceptIreactorlgoolant[p0mp IRCE)lse411WaterjnjectjMMlleakoff)J heks that JA are captured and
, conducteditoicollegtjon: systems;og a sump or collecting tanki-er 2b. LEAKAGE beekege into the containment atmosphere from sources that are both specifically located and known either not to interfere with the operation of -lEeakage d0etection sSystems or not to be pressure boundary 7RESSURE SOUNDA"J LEAKAGE (r or
. 3e. Reactor Coolant System (RCS) LEAKAGE 4eekege through a steam generator (SG) to the Secondary Ccciant System (-
f O
V CPSES Mark-up of CTS- 1.0 1-4 S/15/97
~'3 UOZUSE;AND; APP _LICATION i w/
1:1 DEFINITIONS LEAKAGEJ2(Continued),
b72fEUnidentified: LEAKAGE All~LEAKAGEI(except:RCP sea ~13aterlinjection:or;3eakoff)lthatlifnot identifie.d; LEAKAGE:
ckEPressure' Boundary LEAKAGE LEAKAGE :(except;SG; LEAKAGE)lt brough:a;nont sol abl elfaul tjnlan1RCSlcomponent body / pipe,walliior_yesserwall]
MSTER RELAY TEST M7 A MASTER RELAY TEST shall consistiot be-the energizinget4en of each master relay and verifyjngicatica the of OPERABILITY of each relay. The MASTER RELAY 341-^
TEST shall include a continuity check of each associated slave relay.
"OiOErsiS) OF EE PUBLIC
()
is' 1.10 "DiOEPs(S) Of EC PUCLIC mcons on individual in a contrciled or UNPsESEIL;La AREA. "cwcycr. on individual is aet a mcabcr of thc public during any pcriod in 1 12-A which the individual rcccivcs an cccupational dese.
OFFSITE-00SE CALCULATION "/J,"JAL 1.19 The OFFSITE DOSE CALCULATION MANUAL (00CM) shall contain the methodology and parameters used in the calculation of offsite doses resulting from radioactive l' 5^
gaseous and liquid effluents, in the calculation of gaseous and liquid effluent monitoring Alarm / Trip Setpoints, and in the conduct of the Environmental Radiological Monitcring Program. The ODCM shall also contain (1) the Radioactive Effluent Controls and Radiological Environmental Monitoring Programs required by Section 6.8.3 and (2) descriptions of the information that should be included in the Annual Radiological Environmental Operating and Annual Radioactive Effluent Release Reports required by Specifications 6.9.1.3 and 6.9.1.4.
~~
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CPSESMark-up of CTS- 1.0 1-5 5/15/97
(~'s; ,11020SE'AND,3PfLICAlION G
lil DEFINITIONS OPERABLE OPERABILITY h 20 A system, subsystem, train, component or device shall be OPERABLE or have OPERABILITY when it is capable of performing its specified safet2 function (s), and when all necessary attendant instrumentation, controls, normal;orftmergenc2 146^-
electrical power, cooling and er seal water. lubrication or other auxiliary equipment that are required for the system, subsystem, train, component. or device to perform itsispecifiedisafety function (s) are also capable of performing their related support function (s).
OPERATIONAL "00[ - H0DE het An OPERATIONAL MODE (i.c.. liODE) shall correspond to any one inclusive combination of core reactivity condition, power level, and average reactor coolant 1 l'^
temperatureEand:reac. tor:vessellheadig]osurg.boltitensioning specified in Table 1.2 Wi_ttCfuelj1n;the teaqtormvessel.
PHYSICS TESTS
-s h22 PHYSICS TESTS shall be those tests performed to measure the fundamental
( 141'A U) nuclear characteristics of the reactor core and related instrumentationb Ihe testslatel 4] W Ddescribed in Chapter 14.0 of the FSARIT b] W 4euthorized under the provisions of 10CFR50.59fT or c; W EITE0etherwise approved by the N0 clear;Regulatot2 Commission.
PRESSURE 00"NDARY LEAXACE 1.23 PRESSURE "OUNDA".Y LEAraCE shall be leakage-fexcept stcam generatcr tube 4cakagc' through a ncaisciabic fault in a "cactcr Ccciant System compcacnt body. 1-11'A pipc wall, cr vcssci well.
PRUiA"J P!)JU VENTILATION SYSTE" 1.24 A PRitiA",Y PLANT VENTILATION SYST[fi sheH bc any systc; desigacd and inst *Hed-tc reduce gasecus radicicdinc or radicactivc matcrial in particulate l~31'^
form in eff4ccats by passing ventilation or vent exhaust gascs through charccal edsorbcrs and/or " EPA fi4tsrs for the purpose of removing iodines or particulates from-the gaseous cxhaust strca; prior to th; release to th; cnvircr.xat. Such a '
systcm is-nct considcred to havc any cffect on acbic gas effluents.
t ;
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CPSESMark-up ofCTS- 1.0 1-6 5/158 7
s LO~ USE AND APPLICATION
/ ,
El DEFINITIONS PROCESS CONTROL PROCPJJi 1.25 The PROCCSS CONTROL PROCPJJi (PCP' shall contain th; curicnt formulas, semp H ng, analyscs. tests, and determinations to bc mad: to casure that processing l'2 "
end-peekeging of solid radicactive wastes based on dc= castrated processing of eetttal or simuleted wat solid wastcs will be accomplished in such a way as to assure ccepliance-with-10 CPR 20. 51. and 71 State regulations, burial ground regttirements. and other-requircacats governing th; disposal of solid radicactive weste-PURCE PURCINC 1.25 PURCC or FURCINC shall bc any contrclied process cf discharging air or ges fec a confincmcat to maintain tcmperaturc, pressurc, humidity, concentration or l'ISA ether cperat4ng ccaditica, in such a manner that replaccment air cr ges-ts regttired to purify the confinem{nt-(NEW)~ PRESSURE AND TEMPERATURE LIMITS REPORT (PTLR)
The PTLR;is the unit: specific' document.that provides the reactor vessel? pressure o and temperature limitsJincluding~heatup;.and.cooldown:ratesathe power, operated I'l7'A
( '
) relief valve (PORV);1ift settings and arming; temperature: associated with Low Temperature 0verpressurization Protection (LTOP) System,Jorithe1 current; reactor vessel _ fluence;periodCThese pressure and_. temperature.]imits shall,be; determined for,each fluenceJper.1od11n'accordance2with the: Administrative;Controisisectiond UnitToperationyithin:theseioperating 11mJts.is: addressed _in; individual.
specifications (
OUADRANT POWER TILT RATIO 4-N OUADRANT POWER TILT RATIO shall be the ratio of the maxinum upper half excore detector calibrated output to the average of the upper half excore detector l~ SA l
calibrated outputs, or the ratio of the maximum lower half excore detector calibrated output to the average of the lower half excore detector calibrated outputs, whichever is greater. With one excore detector inoperable and power s 75% of RTP, the remaining three detectors shall be used for computing the average.
With one'excore detector inoperable and power above 75% RTP or^with moreithanTone 129-ts inoperable excoreTdetector, the movable incore detectors shall be used to determine quadrant power and average power based on the relationship between incore and excore power using the most recent flux maps.
l
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] CPSES MarA-up of CTS- 1.0 1-7 5/15/97
(] MjIUSE1AlWRL.IC. AIION .
N.)
lil DEFINITIONS ^
RATED THERHAL POWER (RTPI i
'h00' RTE RATE" T!:CR"AL P^J' ER shall be a total reactor core heat transfer rate to the reictor coolant of 3411 Hwt. *^
REACTOR TRIP SYSTEM ~(RTS) RESPONSE TIME -
h29 The RIS "EACTOR EI" SYSTEM RESPONSE TIME shall be the time interval from when the monitored parameter exceeds its 8TE.tTrip sSetpoint at the channel sensor 2"A until loss of stationary gripper coil voltage. Thelresponse; time:may;be;yerified bKneansioC artEserj es T.onsequentialfEoyetlapping 2 on. total: stepsiso;_thatithelentire fespon.seitimeJsiverified!
RE"0RTA"LE E"E"T M^ A "CPORTASLC ["ENT shall be any of thcsc conditions specified in 10Cf"SO.73.
.1-19-A
.W MARGIN (SDN) hB1 SDM - - n ... MIN shall be the instantaneous amount of reactivity by which
[s') the reactor is subcritical or would be subcritical from its present condition !
V assuming all rod cluster poDtrol assemblies IRCCAsl (shutha and control' are fully 's-2m i
inserted except for the single RCC8 red cluster ass;i..Lly of highest reactivity l worth which is assumed to be fully withdrawn. !Withiany;RCCAInoticapableroE bejpg !
ful]Einserted,*ItheIreacti?jtf3iottKofithe;RC_CAlmustIbe accountedifotliA3he. )
determ10at_100iofiSDMGand l l
(NEWGIn.;MODESIEArid2,7the;. fuel!and;modetatoritempetatutesfarCchangedit~olthelh. of zero;powetitemperatutes?
SITE "A=Y !
1-24-A.. }
1.02 The SITC 000"0A"J shall be that linc as shca, in figure S.1-3. '
SLAVE RELAY TEST I
h33 A SLAVE RELAY TEST shall consjstlof be-the energizinget4en of each slave relay and verifyingication of OPERABILITY of each slaye relay. The SLAVE RELAY ~l'81-^
TEST shall include 2aslajnjahip a continuity check, as a minimum, of associated testable actuation devices.
.p LJ CPSESMark-up ofCTS- 1.0 1-8 5/15/97 l
1
110l!$E,fMRE1C6I, ION
- l'31 DEFINITIONS ,
b S0WRGE-EHEEK i
1.04 A S00"EE E"EEX shell be the qualitative a:;scssent of chenral respasc wtan , i-22 4 -
th; chenrel sca:;cr is capsed to e source of iraressed redicactivity. g F -STAGGERED TEST BASIS l i-35 A STAGGERED TEST BASIS shall consist oft theitestingiofione;ofJthe 1-23-A 1
- c. A test sctedule for a systems, subsystems, trefns channels, or other-designated components obtained by dividing tra :;pcified test interval into a aquel subintervals, end:duringithe21nterva]Ispecifjed;byLthe Surve111 ance 7recuencyEsoIthat"a11 EsystemsEsubsyst:;cs Echannel sEoE ,
othet; designated [ components l;areitested;during X Sutveillanceiftequency !
interval sawhereXi sitheltotannumberiefisystems 7fsubsystems? i phannplsCofothet;designaticomponents11Dithe associateldunc_tlon] '
- b. The testing of ene system, subsyste;;;, train, or other designated ce pnent et the beginning of each subinterval. '
THERHAL POWER 1-36 THERHAL POWER shall be the total core heat transfer rate to the reactor i coolant, 4
TRIP ACTUATING DEVICE OPERATIONAL TEST (TADOT) r 1-37 A J_ADDI "I" ACTJATI'40 DEVICE 0"C"ATI0'nt TEST shall consist of operating 141-A the tTrip Mctuating dBevice and verifying OPERABILITYsef-includingial]Icompo_nents jfGtheIchannemsuch!asIalarms, interlocks, displays, and/or trip functions 1-32-A ' 5 tequitedito petf_oEmitheIspecifjedJsafetyifunction(s). The; TAD 0Tinay;be: performed :
hYitiieanslofianylsetiesiof;sequentj a] floyerl appj ngloritotalichanne)? steps Tsolthat ; 1-30-A . t th!Eegtite3!1agge]i1 Gest _edJ The 1800I 1RI" ACTUATINC DEVICE 0"E"ATI0'nt TEST
~
shall include adjustment, as necessary, of the tTrip Mctuating Sevice sd such ;
that it actuates at the required setpoint within the required accuracy.
i IMIBE4fRFIE94EAKAGE i
1.0 UNIOEffTIEIED LC# FACE shell be all leekage which is not IDENTIEIED LEAPJ.CC cr CON"OLLEO LGAKAGE- -11 A i
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-.u? - APP.LIC.ATIO.N.
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,. i TL15MEMNJM TABLE 1.1 E Jdot))Jsed] l FREGUENGV-NOTAT40N i gg g ? 14-A / -
I S 't 1sest er.cc per 12 hours1.388889e-4 days <br />0.00333 hours <br />1.984127e-5 weeks <br />4.566e-6 months <br />.
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_ . _ __ _ . . ~ _ . . _ . - _ _ _ . . . _ _ . - _ - _ _ _ _ _ __ . _ _ _ _ _ .
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0.99
, > 5% E 050'r M ;
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- 3. HOT. STANDBY < 0.99 9M > 3502p
- 4. HOT SHlITDOWNN < 0.99 . 9M 3508f > Tm :
> 2002F
.5. COLD SHUTDOWN * .< 0.99 ' OM s 2002F 6.- REFUELING **"3 2-6-95 M 9M 2140'r M s
i 4
+
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- - 191 Excluding decay heat. l
. fuel ir, the reector vessel with the vessel h::d cissure hits less ther, fully i ter,sier.e4 er with the h::d rem i;ed. '
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CPSES Mark-up of CTS- 1.0 1-13 5/158 7 ;
l l
.\
i l
r Methodology For Mark-Up of Current TS l This enclosure contains the electronic (or hand written) mark-up of the current Technical Specifications (TS). The electronic (or hand written) mark up is performed in accordance with the following guidelines: l t
. The current specifications are marked up to reflect what they would look like when the substance of NUREG 1431 Revision 1 is incorporated.
. In general, only technical changes have been identified. However, some non- l technical changes have also been included when the changes cannot easily be determined to be non technical by a reviewer, or if an explanation is required to demonstrate that the change is non technical.
. Changes are identified by a change number in the right margin. A description / justification for each change is contained in Enclosure 3A. ;
There are four. types of changes:
- 1. Deletions Material is no longer in the specifications. (this includes !
material which is moved to the Bases of the TS). ;
'2. Additions This includes the addition of new requirements, restrictions, etc. to the specifications which are not in the current TS. -
CN 3. Modifications . This includes requirements which exist in the current TS U but are being revised in the improved TS. l
- 4. Administrative These are non technical changes to the TS. These include adopting the new format of the improved STS, moving the location of material within the specifications, etc.
The methodology of identifying the changes is :
Deletions - The portion of the specification which is being deleted is annotated using the strike-out feature of Wordperfect (or crossed out by hand). The deletion is identified by a change number or a change code in the adjacent right margin.
Additions - The information being added is inserted into the specification in
- the appropriate location and is annotated using the red line t~ '
feature of Wordperfect (or hand written / insert pages). The addition'is identified by a change number in the adjacent right margin.
Modifications - The information being revised is annotated in the current TS
.using the strike out feature of Wordperfect (or crossed out by hand) and the revised information is inserted into the A specification in the appropriate location and is annotated using d
Methodology I of 2 S/15/97
-1
Hethodology For Mark up of Current TS f')
v (continued) the red line feature of Wordperfect (or hand written / insert pages). The mcJification is identified by a change number in the adjacent right margin.
Administrative - The text of the current TS is not modified to reflect administrative changes. Where the administrative change might cause confusion to a reviewer, the change is identified by a change number in the right margin. For example, if a requirement is relocated to a specification in the improved TS which does not correspond with the specification in which that requirement is located in the current TS, a change number is provided in the markup of the current TS and an explanation is provided in enclosure 3A which explains where that requirement has been located in the improved TS.
CHANGE NUMBERS:
A change number, located in the right margin adjacent to a technical change mark up, provides an identifier for its corresponding description / justification and indicates the type of NSHC used. The change number is of the form 413-LS. The first number (i.e., 4 in this example) is a number assigned to each LC0 (or group of similar LCOs) such that it refers to the same specification for each member utility in the (n)
Joint Licensing Subcommittee (JLS) regardless of the actual TS number in their individual Technical Specifications. A table of the change number prefixes versus each plant's specification numbers is provided in enclosurc 3A. The next set of numbers (i.e., 13 in this example) is an assigned number to identify changes within a given specification (i.e., having the saine prefix number). As a result of differences between the individual JLS member current specifications and because of changes that may occur after initial number assignments, the numbers may not appear sequentially in the TS markup. The letter suffix (i.e.. LS in this example) indicates the type NSHC used (e.g., A H. LG, TR. LS, R).
In summary, changes may be annoted electronically or by using a hand mark up. For electronic mark up. " red line" is used to annotate new information, " strike out" is used to annotate deleted material (which includes material that is moved out of the specifications), and change numbers are used in the right margin to identify technical changes. All technical changes (i.e., " red line" or " strike out" items) require a change number. In addition, certain administrative changes (e.g.,
requirements moved to another specification) are also assigned a change number to provide additional clarification.
(~TI t
U Methodology 2 cf2 S/15/97
i l i
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4
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ENCLOSURE 3A l I
i l l
)
- DESCRIPTION OF '
, CHANGES TO CURRENT TS t
Description of Changes (6 Pages) lO t
1 1
4 at' ij~
4
. O r
4
+em-.r .- - , , . , ,, . .. - -
DESCRIPTION OF CHANGES TO CURRENT TS SECTION 1.0 This enclosure contains a brief description / justification for each marked-up change N to the current Technical Specifications. The changes are identified by change numbers contained in enclosure 2 (Mark-up of the current Technical Specifications).
In addition. the referenced No Significant Hazards Considerations (NSHCs) are contained in enclosure 4. Only technical changes are discussed: administrative changes (i.e., format, presentation, and editorial changes) made to conform to NUREG 1431 Revision 1 are not discussed. For enclosures 3A. 3B, 4, 6A and 68, text in brackets "[ ]" indicates the information is plant specific and is not common to all the Joint Licensing Subcommittee (JLS) plants. Empty brackets indicate that other JLS plants may have plant specific information in that location.
CHANGE NUMBER N2iG DESCRIPTION 1 01 A These definitions would be reworded to be consistent with NUREG 1431. The proposed rewording included in this category does not involve any changes of a technical nature.
1 02 A The definitions for Analog Channel Operational Test and Digital Channel Operational Test would be combined into a single definition of Channel Operational Test (C0T) to be consistent with NUREG 1431. Separate definitions would no longer be required for the improved STS. The combined definition allows use of actual as well as simulated h
D signals. The proposed rewording does not involve changes of a technical nature.
1 03 H The definition of channel calibration is reworded to be consistent with NUREG 1431. The revised wording provides additional detail concerning calibration of instrument l channels with RTD's or thermocouples. !
1 04 A This definition would no longer be used and the specifications in ITS Section 3.6 and Administrative Controls Section would be revised accordingly. The current TS definition for Containment Integrity would be deleted to be consistent with NUREG 1431. This definition is effectively incorporated into the NUREG 1431 Bases for the new Containment Limiting Condition for Operation (ITS 3.6.1) and the Administrative Controls Section for the Containment Leakage Testing Program [ ]. !
1 05 A The current definition for Controlled Leakage would be deleted to be consistent with NUREG 1431. This definition will no longer be required for the improved TS because new LCO 3.5.5 will be created to ensure that seal !
injection flow remains within limits. Therefore, this j A change is not technical and has been categorized as '
b administrative, l
l CPSES Description of Changes to CTS 1.0 1 5/1S/97
CHANGE p NUMBER N21C DESCRIPTION 1 06 LS 1 The current TS definition for Core Alterations would be modified consistent with NUREG 1431, to qualify a core alteration as movement of fuel, sources, or other reactivity control components. This proposed change is less restrictive since the current TS definition defines the movement of any component within the reactor vessel with fuel in the vessel as a Core Alteration. However, since the proposed definition would limit core alterations to those manipulations that could affect core reactivity, the proposed change is acceptable from the standpoint of the health and safety of the public.
1 07 A Not applicable to CPSES. See Conversion Comparison Table (enclosure 38).
1 08 A The current TS definitions for Engineered Safety Features Response Time and Reactor Trip System Response Time would be modified to be consistent with NUREG 1431. In addition, the term " measured" would be replaced by
" verified" to be consistent with the requirements of improved TS SR 3.3.1.16 and SR 3.3.2.10 to verify response time is within limits. The addition of the statement that
)
(V response time may be verified by means of any series of sequential, overlapping, or total steps so that the entire response time is verified. is administrative in nature.
This is consistent with the methodology presently described in the current TS Bases for demonstrating total channel response time.
1 09 A The current TS definition for Frequency Notation (and Table 1.1, Frequency Notation) would be deleted to be consistent with NUREG 1431. The acronyms defined in Table 1.1, Frequency Notation, are no longer used in NUREG-1431.
Surveillance frequencies are spelled out in NUREG 1431, thereby obviating the definition. This is a non technical change made to conform to NUREG 1431.
1 10 A The definition for maximum allowable primary containment leakage rate (L,) would be added to the improved TS to be consistent with NUREG 1431. This addition has been determined to be an administrative change on the basis that this definition has simply been [ moved] from [ CTS Administrative Controls 6.8.4.g] to the definitions.
1 11 A The current TS definitions for Identified Leakage, p Unidentified Leakage, and Pressure Boundary Leakage have U/ been merged into one definition for iGksgc. This is a nontechnical change since it will r,ot alter the manner in CPSES Description of Changes to CTS 1.0 2 5/15/97
1
-I CHANGE
_ PDBER giHC DESCRIPTION which leakage is accounted for and treated from present practice. The definition of unidentified leakage has been i expanded to include "except RCP seal water [ injection or] i
' leakoff", to be consistent with NUREG 1431.
1 12 A The current TS definition for Member of the Public, would i be deleted to be consistent with NUREG 1431. This ,
definition would be deleted on the basis that it is defined in 10 CFR 20.1003 and 40 CFR 190.
. 1-13 A The current TS definition of the Offsite Dose Calculath Manual (ODCM) [ ] would be [ ] incorporated into the Administrative Controls section of the ITS. This change is non technical because the definition of the 00CM [ ] '
will be [ ] moved to another section of the improved TS. !
1 1 14 A. The current TS definition for Operational Mode would be l revised to " Mode" and the wording would be revised to be !
consistent with NUREG 1431. The changes are nontechnical !'
since they will not affect current practice.
1 15 A The current TS definitions of HVAC systems and functions ;
would be deleted to be consistent with NUREG-1431. [ ] !
-( " Purge Purging" and " Venting", where used, do not !
require special definitions. I 1 16 LG The current TS definition of the Process Controls Program !
(PCP) would be moved outside of the TS along with the i Administrative Controls description of this program to be ;
consistent with NUREG 1431. The PCP definition and program description from Administrative Controls are moved into )
the FSAR. The PCP implements regulatory requirements and need not be restated in the TS. The requirement to comply '
with applicable Federal and State regulations for the j processing of radioactive waste provides sufficient i control of future changes to the PCP. )
1 17 A The definition of a Pressure Temperature Limits Report (PTLR) would be added to be consistent with NUREG-1431 and WOG 67, Rev 1. The definition will support the use of a PTLR. Adding the definition 1:; purely administrative in !
nature.
1 18 A The portion of the OPTR definition dealing with an
' inoperable excore detector is addressed in the Conditions and Surveillance Requirements of improved TS 3.2.4
- k.) ,
CPSES Description of Changes to CTS 1.0 3 5/158 7
CHANGE ,
NUPEER HSIE DESCRIPTION
,3 1 19' A' The current TS definition of Reportable Event is not used in the improved TS and would be deleted to be consistent with NUREG 1431. This definition would be deleted on the i basis that a reportable event is defined by 10 CFR 50.72 l and 50.73. This change is administrative in nature because it will have no effect on current reporting practices. ,
1 20 M The current TS definition of Shutdown Margin would be :
revised to be consistent with NUREG 1431. The ;
requirement to account for any RCCAs not capable of being ,
fully inserted was simply moved from current TS Action and Surveillance Requirements. The only substantive technical i change to this definition is the addition of the requirement that, in Modes 1 and 2, the fuel and moderator :
temperatures be changed to the hot zero power temperatures. This ensures that the power defect due to ;
e shutting the reactor down from Mode 1 or 2 is accounted for in the shutdown margin. While this requirement is consistent with current practice, it has not been !
specified in the existing definition. Consequently. it has been categorized as a more restrictive change.
j 1 21 Not used.
1 22 A The definition of Source Check can be deleted from the current TS in accordance with NUREG 1431. No surveillances in the improved TS require Source Checks, therefore, this is an administrative change. Where used I in licensee controlled documents it will be defined:
however it has not been used in the current TS since the implementation of NRC GL 09 01. ,
1 23 A The current TS definition for Staggered Test Basis would be revised to be consistent with NUREG 1431, but the test intervals for surveillance requirements throughout the improved TS that are to be performed on a staggered test l basis will be revised to be consistent with the new definition so that there will be no net change in current TS implementation of staggered test intervals. For example, under the current TS, if a parameter is monitored i by three channels of instrumentation, and the test i interval is quarterly, one channel would be tested each l' month during any giv%1 quarter by dividing the test interval into three equal subintervals. Under the new definition, the test interval for that same r o instrumentation in the improved TS would be specified as V monthly so that the net effect is the same. One channel would be tested each month during any given quarter.
l CPSES Description of Changes to CTS 1.0 4 5/1S/97
CHANGE
, ElgE8 HSIE DESCRIPTION 1 24 A The current TS definitions of Site Boundary and Unrestricted Area are deleted to be consistent with NUREG-1431. These definitions are deleted on the basis that they are defined in 10 CFR 20.1003.
1 25 LS 2 Table 1.2 of the current TS would become Table 1.11 in the improved TS. The following changes would be made to conform to NUREG 1431. In ITS table 1.11, the notation "NA" would replace "0" under
- Rated Thermal Power for Modes 3, 4, 5, and 6. This is a nontechnical change since with K,r, less than 0.99, thermal power would be zero anyway. For Mode 6 the temperature has been replaced with NA since there is no safety analysis basis for the value of 140 F specified in the current TS. Also for Mode 6, the reactivity condition has been designated NA since the value of 0.95 is specified in the Bases for improved TS 3.9.1. The temperatures for Modes 1 and 2 are designated as NA on the basis that temperature for these Modes is dictated by the minimum temperature for criticality and the operating program for reactor coolant system Tavg. A new note b has been added to Modes 4 and 5 stating that the required reactor vessel head closure bolts are fully tensioned, and a new note c replaces the (N
Ul note applied to Mode 6. The new note c states that the required reactor vessel head closure bolts are less than fully tensioned. The new note c no longer specifies that fuel is in the vessel because the condition of fuel in the vessel is addressed by the definition of the term Mode.
This definition stipulates that fuel be in the vessel in order to be in a " MODE." These changes are administrative, except for the new notes b and c, added per TSTF 88 and addressed in NSHC LS 2.
1 26 A New sections 1.2, 1.3, and 1.4 would be incorporated into the improved TS to be consistent with NUREG-1431. Section 1.2 provides specific examples of the use of the logical connectors A W and QB and the numbering sequence associated with their use in the improved TS. Section 1.3 deals with the proper use and interpretation of completion times, and specific examples are given that will aid the user in understanding completion times. Section 1.4 deals with the proper use and interpretation of surveillance frequencies. Specific examples are given that will aid the user in understanding surveillance frequencies as they will appear in the improved TS. The proposed changes are m administrative in nature and by themselves are not technical changes, incorporating travelers WOG-74 and WOG-90.
CPSES Description of Changes to CTS 1.0 S SM5/97 l
CHANGE g NUMBER HSHC DESCRIPTION t
'd 1 27 H Not applicable to CPSES. See Conversion Comparison Table (enclosure 3B).
1 28 LG Not applicable to CPSES. See Conversion Comparison Table (enclosure 38).
1 29 LS 3 This change revises the definition of QPTR to allow measuring QPTR with moveable incore detectors when one or more excore detector channels are inoperable. The change makes the CTS definition of QPTR consistent with ITS SR 3.2.4.2 as modified by TSTF 109.
1-30 A Consistent with TSTF 39 Rev.1, the definitions of Channel Operational Test (C0T), [ ] and TAD 0T are expanded to include the details of acceptable performance methodology.
Performance of these tests in a series of sequential, overlapping, or total channel steps provides the necessary assurance of appropriate operation of the entire channel.
This change also makes the COT. [ ] and TAD 0T definitions consistent with the current TS and the NUREG 1431 definition of channel calibration which already contains similar wording.
()
V 1 31 A Definitions of specific plant systems which are defined by the plant design are deleted consistent with NUREG 1431.
The definitions contained in ITS 1.0 are intended for definitions that are necessary for the understanding of the specifications and can be generically defined for most plants. Definitions of systems that are not used in the specifications, or are specific to a particular plant (or only a few plants) are no longer defined in this section.
Where necessary, such terms are defined in the Bases for the applicable specifications.
1-32 A The definitions of channel calibration, COT, [ ] and TADOT are reworded consistent with TSTF-64 to clarify the phrase
' entire channel" thus reducing the potential for inconsistent interpretation of the phrase as experienced i by a number of plants.
l 1 33 A This change revises the CTS definition of Core Alterations l to delete "or manipulation" and " conservative" consistent l with NUREG 1431. The words as used in the definition were l redundant and deleting the words does not alter the meaning of the definition. I g
V i
CPSES Description of Changes to CTS 1.0 j 6 5/]SM7 l
-i 1
1 j
- ENCLOSURE 3B ,
I I
.1 CONVERSION COMPARISON TABLE - CURRENT TS 4 W
Conversion Comparison Table (4 Pages) 6 t I
f t
1 j
i s
O ,
I a
l
9ONVERSION COMPARISON O TABLE - CURRENT Page 1 of 4 O 1.0 TS TECH SPEC CHANGE APPLICABILITY ,
NUPEER DESCRIPTION DIABLO CANYON COMANCHE PEAK WOLF CREEK calla RY 1-01 These definitions would be reworded to be consistent with Yes Yes Yes Yes A NUREG-1431. The propossi rewording included in this category does not involve any changes of a technical nature.
1-02 The CPSES definitions for Analog Channel Operational Test No - do not have Yes No - do not have No " Digital' is A~ and Digital Channel Operational Test would be co e ined the Digital Channel the Digital Channel not included in into a single definition of Channel Operational Test Operational test Operational test current TS.
(C0T). definition. definition.
1-03 The definition M thannel calibration is reworded. The Yes Yes Yes Yes M revised wording p avides additional detail concerning calibration of instrument channels with RTDs or thermocouples.
1-04 This definition would no longer be used and the Yes- Yes Yes Yes: See also A specifications in Section 3.6 would be revised improved TS 5.5.6 accordingly. The current TS definition for Containment and 5.5.16.
Integrity would be deleted.
1 05 The current TS definition for Controlled Leakage would be Yes Yes No. See Change No. See Change
- A deleted. Number 1-28-LG. Number 1-28 LG.
l
' 1-06 The current TS definition for Core Alterations would be No - Already in Yes Yes Yes LS-1 modified to qualify a core alteration as movement of CTS.
j fuel, sources or other reactivity control components.
1-07 The location of the thyroid dose conversion factors used Yes No - Already in No Already in No - Already in A for DOSE EQUIVALENT 1 131 have been added. C15. CTS. CTS.
1 08. The current TS definitions for Engineered Safety Features Yes Yes Yes Yes A. Response Time and Reactor Trip System Response Time would be modified. In addition, the term " measured" would be replace by " verified
- to be consistent with the requirements of improved TS SR 3.3.1.16 and SR 3.3.2.10 to verify response time is within limits.
CPSES Convenion Conparison Table - C15 1.0 5/15/97
t ONVERSION COMPARISON TABLE - CURRENT TS 1.0 Page 2 cf 4 i
TECH SPEC CHANGE APPLICABILITY !
IDBER DESCRIPTION DIABLO CANYON I COMANCHE PEAK WOLF CREEK CALLMAY
~
1-09 The current T5 definition for Frequency Notation (and Yes Yes Yes Yes A Table 1.1. Frequency Notation) would be deleted. The acronyms defined in Table 1.1. Frequency Notation, are no longer used in NUREG-1431.
1 10 A
The CTS Administrative Controls section definition for Yes Yes Yes Yes maximum allowable primary containment leakag= rate (L.)
would be added to the improved TS.
1 11 The current TS definitions for Identified Leakage. Yes Yes Yes Yes A Unidentified Leakage, and Pressure Boundary Leakage have been merged into one definition for Leakage and reworded.
1 12 The current T5 definition for Member of the Public would Yes Yes Yes Yes t A be deleted.
1-13 The current T5 definition of the Offsite Dose Calculation Yes Yes Yes Yes A
Manuti (DOCH) [ ] would be moved to the Administrative Controls section of the ITS.
1-14 The current TS definition of ' Operational Mode
- would be Yes Yes Yes Yes A revised to " Mode
- and reworded.
1-15 The current TS definitions of HVAC systems and functions Yes Yes Yes Yes A
would be deleted. [] ~ Purge - Purging" and " Venting",
where used, do not require special definitions.
1-15 The current TS definition of the Process Controls Program Yes - Moved to LG Yes - Hoved to Yes - Hoved to Yes - Moved to FSAR (PCP) would be moved outside of the T5 along with the FSAR. FSAR.
Administrative Controls description of this program.
USAR. Section 16.25.
1 17 The definition of a Pressure Tegerature Limits Repcrt Yes Yes Yes Yes A (PTLR) would be added to support the use of a PTLR.
1-18 The portion of the QPTR definition dealing with an Yes Yes Yes Yes A inoperable excore detector is addressed in the Conditions and Surveillance Requirements of improved TS 3.2.4.
CPSES Conversion Comparison Table - CTS 1.0 5/IS/97
O O 9ONVERSION COMPARISON TABLE - CURRENT TS vage 3 of 4 TECH SPEC CHANGE APPLICABILITY NUPEER DESCRIPTION DIABLd CANYON COMANCg PEAK WOLF CREEK CALLAWAY 1-19 The current TS definition of Reportable Event is not used Yes Yes Yes A in the i groved TS and is deleted. Yes 1 20 The current TS definition of Sht.tdown Margin is revised. Yes Yes Yes M The requirenent to account for any RCCAs not capable of Yes being fully inserted was simply moved from current TS Action and surveillance requirements. The only substantive technical change to this definition is the addition of the requirement that in Modes 1 and 2. the fuel and moderator temperatures be changed to the hot zero power tesperatures.
1-21 Not used. N/A N/A N/A N/A 1-22 The definition of Source Check is deleted. Yes Yes Yes A Yes 1-23 The current TS definition for Staggered Test Basis would Yes Yes Yes A be revised. The test intervals for surveillance Yes requirements throughout the improved TS that are to be performed on a staggered test basis will be revised to be consistent with the new definition.
1-24 The current TS definitions of Site Boundary and Yes Yes Yes A Unrestricted Area would be deleted. Yes 1-25 Table 1.2 of the current TS would become Table 1.11 in Yes Yes Yes LS-2 the improved TS. Several changes would be made to conform Yes to NUREG-1431 (e.g., ITS Table 1.1-1 the notation *NA*
would replace 'O' under
- Rated Thermal Power for Modes 3.
- 4. 5. and 6). Reactor vessel head closure bolt tensioning is revised per TSTF-88 and discussed further in NSHC LS-2.
1-26 New sections 1.2, 1.3, and 1.4 would be incorporated into Yes Yes Yes A the improved TS. Yes CPSES Conversion Comparison Table - CTS 1.0 S/l5/97 4.--_-_-.-___-m-_ _ _ - _ _ _ _ - ~_____-m - _ , . - . _...._-____..,__-.,_,_.r_,,m--..-.-,,,,._,m, - -
, , . ,. ,%- . , , , . _ , . _ , , , - . . ...,.___,w . _ . _ .
(s.,))
C)N
'y _
NVERSION-COMPARISON TABLE - CURRENT TS 1.0 Page 4 cf 4 TECH SPEC CHANGE APPLICABILITY NL9BER. DESCRIPTION DIABLO CANYON COMANCHE PEAK WOLF CREEK CALLAWAY 1-27 The definition of Restricted AFD Operation (REDO) is No No No H deleted. Yes - Definit 1or..
only in Callaway CTS.
1-28 The definition of CONTROLLED LEAKAGE is deleted. The RCP No - See change No. See Change Yes - Moved to LG seal water retura flow limit is moved to a licensee number 1-05-A.
Yes - Moved to controlled document. Ntsber 1-05-A. USAR Section 16. FSAR Section 16.4.
1-29 Allows measuring QPTR when one or more execre detector No LS.3 channels are inoperable with moveable incore detc-tors. Yes - Portion of No No definition being changed is only in CPSES CTS.
1 30 A
The definitions of Channel Operational Test (C0T). [ ] Yes Yes Yes Yes and TADOT are expanded to include the details of acceptable performance methodology. Performance of these tests in a series of sequential, f,verlapping, or total channel steps provides the necessary assurance of appropriate operation of the entiae channel.
1-31 Definitions of specific plant systems which are defined by Yes Yes A the plant design are deleted. No - Not in CTS. No Not in CTS.
1-32 A The definitions of channel calibration. COT [ ] and Yes Yes Yes Yes TADOT are reworded to be consistent with TSTF-64. The revised wording clarifies what is meant by " entire channel."
1 33 This change revises the CTS definition of Core Alterations Yes Yes Yes A to delete "or manipulation" and **onservative". Yes CPSES Conversion Comparison Table - CTS 1.0 5/15/97
a aa ,
1 i
ENCLOSURE 4 NO SIGNIFICANT IIAZARDS CONSIDERATIONS j
4 0
p
n N0 SIGNIFICANT HAZARDS CONSIDERATIONS (NSHC)
() CONTEMTS I. Organization ........................................ 2 II. Description of NSHC Evaluations . . . . . . . . . . . . . . . . . . . . . . 3 III. Generic No Significant Hazards Considerations "A" Administrative Changes......................... 5 "R" - Relocated Technical Speci fications. . . . . . . . . . . . . . ,'
"LG" Less Restrictive (Moving Information Out of the Technical Speci fications) . . . . . . . . . . . . . . . . . 10 "H" More Restrictive Requirements................. 12 IV. Specific No Significant Hazards Considerations "LS" LS 1................................................ 15 (p ,/ LS 2................................................ 17 LS 3................................................ 19 p
(p..
V-CPSES No Significant fla:ards Consideration - 1.0 1 5/15/97
I. NO SIGNIFICANT HAZARDS CONSIDERATIONS ORGANIZATION V(3 In accordance with the provisions of 10 CFR 50.90, this License Amendment Request proposes to revise the current Technical Specifications. The proposed revision includes converting the current Technical Specifications to the improved Standard Technical Specifications of NUREG-1431 Revision 1. The conversion to the improved Standard Technical Specifications (also referred to as the improved STS or ISTS) has generated a large number of changes. Evaluations pursuant to 10 CFR 50.92 showing that the proposed changes do not involve significant hazards considerations are provided for each Technical Specification (TS) chapter. However, due to the volume of changes, similar changes have been grouped in categories to facilitate the no significant hazards considerations (NSHCs) required by 10 CFR 50.92.
Generic NSHCs have been developed that correspond to each category of changes. In addition, since each TS chapter has been evaluated individually, chapters may contain chapter specific generic NSHCs. NSHCs for changes that cannot be grouped into a category have also been developed. Typically, less restrictive technical changes must be evaluated individually. Each TS chapter will therefore contain
" change specific" NSHCs for less restrictive technical changes as well as generic NSHCs.
Each change to the current Technical Specifications is marked up on the appropriate page and technical changes are assigned a change number. Obvious editorial or administrative changes are not marked up. The change number in the right margin of the marked up page is used in the Description of Change (enclosure 3A) which
(v provides a detailed basis for each change and a reference to the applicable NSHC.
For enclosures 3A 38, 4, 6A and 68, text in brackets [ ]" indicates the information is plant specific and is not common to all the Joint Licensing Subcommittee (JLS) plants. Empty brackets indicate that other JLS plants may have plant specific information in that location.
p, V !
l TPSES No Significant Ha:ards Consideration - 1.0 2 5/]5/97 l
II. DESCRIPTION OF NSHC EVALUATIONS GENERIC N0 SIGNIFICANT HAZARDS CONSIDERATIONS ;
- The following are brief descriptions of the generic NSHCs contained within this TS chapter. The reference symbols are used in the Discussion of Changes to index the applicable NSHC for each change described and are incorporated into the change numbers. i 1 Additional generic subcategories may be developed and till be referenced by adding a numeric designator to the existing alpha reference symbol (i.e., LG1, LG2, A1, A2, etc).
Administrative ,
l Reference symbol "A" (Administrative)
This' category consists of changes which are editorial in nature. involve the movement of requirements within the TS without affecting their technical content, simply reformat a requirement, or clarify the TS (such as deleting a footnote no -
longer applicable due to a technical change to a requirement). It also includes nontechnical changes made to conform to the Writer's Guide or the improved Standard Technical Specifications in NUREG 1431. Most administrative changes have not been marked up on the current TS, and thus are not specifically referenced to a i
, discussion of change or NSHC. If no discussion of change or NSHC is referenced for a change it is considered administrative in nature and this Generic NSHC applies. .
This NSHC may also be referenced in a discussion of change for an administrative ;
change that is not obvious and requires an explanation. t Relocation of Technical Soecification Reouirements t
Reference symbol "R" (Relocation) i This category applies to TS requirements that do not meet the criteria in 10CFR50.36(c)(2)(ii). TS requirements affected by the application of the criteria are annotated with an "R" in the description of the change (enclosure 3A). The "R" designation and the description of the relocation direct the reviewer to this NSHC for a description and evaluation of the change.
Movina information out of Technical Soecifications Reference symbol "LG" (Less restrictive, generic)
In some cases, information will be moved out of the TS while the underlying
- l l
l Q
V !
' PSESNo Significant Ha:ards Consideration - 1.0 V .1 5/15/97 l
5 II. DESCRIPTION OF NSHC EVALUATIONS i
GENERIC NO SIGNIFICANT HAZARDS CONSIDERATIONS (coitinued) requirement remains (e.g., the requirement for equipment operability is retained in '
the LCO but the definition of operability is moved to the Bases). The affected information maybe moved to the Bases, the FSAR, or other licensee controlled documents. This category of change is considered to be less restrictive (no longer controlled by TS) and usually involves moving information of a descriptive nature.
These changes are generally made in order to conform with NUREG 1431 format and content.
Technical chance. more restrictive Reference symbol "H" (More restrictive, generic)
This category consists of changes that add new requirements to the TS or revise existing requirements to be more stringent. These are changes are typically made to conform to applicable requirements of NUREG 1431.
SPECIFIC NO SIGNIFICANT HAZARDS CONSIDERATIONS Those TS changes that must be evaluated individually are typically the less ;
O restrictive technical changes. Each NSHC for less restrictive technical changes in this TS chapter will be numbered sequentially. The applicable NSHC for each less restrictive change will be referenced in the Description of Change (enclosure 3A) for this chapter. The Description of Change contains the basis for the change.
Technical chance. less restrictive ,
i f Reference symbol "LS" (Less restrictive, specific)
(
This category consists of changes which revise existing requirements such that more restoration time is provided, fewer compensatory measures are needed, or fewer or i less restrictive surveillance requirements are required. This would also include require,nents which are deleted from the TS (not relocated or moved to other :
documents).
Technical chanae. recurrina less restrictive Reference symbol "TR 1, 2, 3...." (technical recurring)
This category consists of the same kind of changes as LS above except that they are generic'to several specifications.
t
..i CPSES No Significant Hazards Consideration - 1.0 4 5/15/97 ,
1 III. GENERIC N0 SIGNIFICANT HAZARDS CONSIDERATIONS i
FN g .A. ,
l 10 CFR 50.92 EVALUATION !
FOR ADMINISTRATIVE REFORMATTING AND REWORDING This proposed TS revision includes reformatting and rewording the remaining !
requirements in accordance with the NUMARC Technical Specification Writer's Guide i and the improved Standard Technical Specifications in NUREG 1431. This is intended to make the TS more readily understandable to plant operators and other users. i Application of the Writer's Guide will also assure consistency between specifications. During this reformatting and rewording process, no technical 7
' changes (either actual or interpretational) were made to the TS unless they were identified and justified.
This proposed TS change has been evaluated and it has been determined that it !
involves no significant hazards consideration. This determination has been !
l performed in accordance with the criteria set forth in 10 CFR 50.92(c) as quoted below:
"The Cows!ssion may make a final determination, pursuant to the procedures in 50.91, that a proposed amendment to an operating license for a facility f licensed under 50.21(b) or 50.22 or for a testing facility involves no i
significant hazards consideratfon.1f operation of the facility in accordance with the croposed amend 71ent wuld not:
1 It <olve a significant increase in the probability or consequences of an t accident previously evaluated; or '
2, Create the possibility of a new or different kind of accident from any accident previously evaluated; or '
- 3. Involve a significant reduction in a margin of safety "
The following evaluation is provided for the three categories of the significant hazards consideration standards:
- 1. Does the change involve a significant increase in the probability or
- consequences of an accident previously evaluated?
The proposed change involves reformatting and rewording of the current Technical Specifications. The reformatting and rewording process involves no technical changes to the current Technical Specifications. As such, this 0
v
~
t CPSESNoSignificantHa:ards Consideration -1.0 $ S/15/97
III. GENERIC N0 SIGNIFICANT HAZARDS CONSIDERATIONS "A"
(continued) change is administrative in nature and does not impact initiators of analyzed events or assumed mitigation of accidents or transient events. Therefore, this change does not involve a significant increase in the probability or I consequences of an accident previously evaluated.
i
- 2. Does the change create the possibility of a new or different kind of accident from any accident previously evaluated? l The proposed change does not involve a physical alteration of the plant (no new or different type of equipment will be installed) or changes in controlling parameters . The proposed change will not impose any different '
requirements. Thus, this change does not create the possibility of a new or different kind of accident from any accident previously evaluated. ;
- 3. Does this change involve a significant reduction in a margin of safety?
The proposed change will not reduce a margin of safety because it has no impact on the design basis or safety analysis. This change is administrative in nature. As such, no question of safety is involved.
C\ '
V NO SIGNIFICANT HAZARDS CONSIDERATION DETERMINATION Based on the above evaluation, it is concluded that the activities associated with NSHC "A" resulting from the conversion to the improved TS format satisfy the no
, significant hazards consideration standards of 10 CFR 50.92(c); and accordingly, a no significant hazards consideration finding is justified.
e U
PSES No Significant Ha:ards Consideration - 1.0 6 S/]S/97
III. GENERIC N0 SIGNIFICANT HAZARDS CONSIDERATIONS h "R" 10 CFR 50,92 EVALUATION FOR
~
RELOCATING TECHNICAL SPECIFICATION REQUIREMENTS TO OTHER LICENSEE CONTROLLED DOCUMENTS i
This proposed TS revision includes relocating requirements, which do not meet the TS criteria to documents with established control programs. Rel' tion of these requirements allows the TS to be reserved only for those condr .ns or limitations upon reactor operation which are necessary to obviate the possibility of an abnormal
. situation or event giving rise to an immediate threat to the public health and safety thereby focusing the scope of the TS.
i Therefore, requirements which do not meet the TS criteria in 10CFR50.36(c)(2)(11) have been relocated to other licensee controlled documents. This regulation '
addresses the scope and purpose of TS. In doing so, it sets forth a specific set of objective criteria for determining which regulatory requirements and operating '
restrictions should be included in the TS. These criteria are as follows:
Criterion 1: Installed instrumentation that is used to detect, and indicate in the control room, a significant abnormal degradation of the p
Q reactor coolant pressure boundary:
Criterion 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 integrity of a fission product barrier:
Criterion 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 barrier; and Criterion 4: A structure, system, or component which operating experience or probabilistic safety assessment has shown to be significant to ;
public health and safety. l l
This proposed change has been evaluated and it is concluded that the change does not meet the criteria listed above. The Conversion Comparison Table (enclosure 3B) specifies the proposed location of these relocated requirements.
)
j CPSESNo Significant Hazards Consideration - 1.0 7 5/1S/97 i
-III. GENERIC N0 SIGNIFICANT HAZARDS CONSIDERATIONS
'C R" (continued) !
TS requirements that do not meet the NRC's criteria are being twocated to other licensee controlled documents. Some of these requirements will be relocated to documents that are subject to the provisions of 10 CFR 50.59. This will ch ure that -
- changes to these relocated requirements will be limited to those that do not involve an unreviewed safety question. Other requirements will be relocated to other licensee documents which have similar regulatory controls (e.g., the Quality '
Assurance Plan, as described in the FSAR. which is controlled by 10CFR50.54a). The remainder of the requirements that do not meet the NRC criteria will be relocated to programs that are controlled via the Administrative Controls section of the improved '
TS. This will ensure an appropriate level of control over changes to these .
requirements. The TS change to relocate requirements has been reviewed by a multi- t disciplinary group of responsible, technical supervisory personnel, including onsite ,
' operations personnel.
Compliance with the relocated requirements will not be affected by this proposed l change to the current Technical Specifications. The required periodic surveillances will continue to be performed to ensure that limits on parameters are maintained. ;
Therefore, relocation of these requirements will have no impact on system
- - operability or the maintenance of controlled parameters within limits.
This proposed TS change has been evaluated and it has been determined that it t involves no significant. hazards consideration. This determination has been performed in accordance with the criteria set forth in 10 CFR 50.92(c) as quoted below:
i "The Comission may make a final determination, pursuant to the procedures in 50.91, that a proposed amendnent to an operating license for a facility licensed under 50.21(b) or 50.22 or for a testing facility invokes no significant hazards consideration. if operation of the facility in accordance with the proposed amendment would not: ,
I. Involve a significant increase in the probability or consequences of an accident previously evaluated; or
- 2. Create the possibility of a new or different kind of accident frorn any scident previously evaluated; or
- 3. Involve a significant reduction in a margin of safety. "
The following evaluation is provided for the three categories of the significant hazards consideration standards:
CPSES No Significant Hazards Consideration - 1.0 3 S/15/97 l
III. GENERIC N0 SIGNIFICANT HAZARDS CONSIDERATIONS A , , , ,
(cont nued)
- 1. Does the change involve a significant increase in the probability or consequences of an accident previously evaluated?
The proposed change relocates requirements and surveillances for structures, systems, components or variables which did not meet the criteria for inclusion in the improved TS. The affected structures, systems, components or variables are not assumed to be initiators of analyzed events and are not assumed to mitigate accident or transient events. These relocated operability requirements and surveillances will continue to be maintained pursuant to 10 CFR 50.59, other regulatory requirements (as applicable for the document to which the requirement is relocated), and/or the Administrative Controls section of the improved TS. Therefore, this change does not involve a significant increase in the probability or consequences of an accident previously evaluated.
- 2. Does the change create the possibility of a new or different kind of accident from any accident previously evaluated?
The proposed change does not involve a physical alteration of the plant (no new or different type of equipment will be installed) or changes in OV controlling parameters . The proposed change wil; at impose any different requirements and adequate control of information will be maintained. Thus, this change does not create the possibility of a new or different kind of accident from any accident previously evaluated.
- 3. Does this change involve a significant reduction in a margin of safety?
The proposed change will not reduce a margin of safety because it has no impact on the design basis or safety analysis. In addition, the relocated requirements and surveillances for the affected structure, system, component or variables are the same as the current Technical Specifications. Since any future changes to these requirements and the associated surveillance procedares will be evaluated per the requirements of 10 CFR 50.59, other regulatory requirements (as applicable for the document to which the requirement is relocated), and/or the Administrative Controls section of the improved TS, proper controls are in place to maintain an appropriate margin of safety. Therefore, this change does not involve a significant reduction in a margin of safety.
NO SIGNIFICANT HAZARDS CONSIDERATION DETERMINATION Based on the above evaluation, it is concluded that the activities associated with NSHC "R' resulting from the conversion to the improved TS format satisfy the no p significant hazards consideration standards of 10 CFR 50.92(c); and accordingly, a no significant hazards consideration finding is justified.
v CPSES No Significant Ha:ards Consideration - 1.0 9 S/15/97
III. GENERIC NO SIGNIFICANT HAZARDS CONSIDERATIONS "LG" 10 CFR 50.92 EVALUATION FOR MOVING INFORMATION FROM TECHNICAL SPECIFICATIONS TO TECHNICAL SPECIFICATION BASES, FSAR OR OTHER LICENSEE CONTROLLED DOCUMENTS Some information that is descriptive in nature regarding the equipment, system (s),
actions or surveillances identified by the specification has been removed from the proposed specification and included in the proposed Bases FSAR, other licensee controlled document. The NRC has previously approved moving this type of detailed information or specific requirement to a licensee controlled document, maintained in accordance with applicable regulatory requirements, since its inclusion in the i= proved TS is not necessary to adequately protect the health and safety of the
'public. Therefore, the descriptive information that has been moved continues to be maintained in an appropriately controlled manner due to the controls which presently exist on the documents where the information is being moved.
This proposed TS change has been evaluated and it has been determined that it involves no significant hazards consideration. This determination has been performed in accordance with the criteria set forth in 10 CFR 50.92(c) as quoted below:
"The Comission may make a final determination pursuant to the procedures in 50.91, that a proposed amendnent to an operating license for a facility licensed under 50.21 (b) or 50.22 or for a testing facility involves no significant hazards consideration. If operation of the facility in accordance with the proposed amendment would not:
- 1. Involve a significant increase in the probability or consequences of an accident previously evaluated; or
- 2. Create the possibility of a new or different kind of accident from any accident previously evaluated; or
- 3. Involve a significant reduction in a margin of safety."
The followirg evaluation is provided for the three categories of the significant hazards consideration standards:
(~h U
CPSES No Significant Ha:ards Consideration - 1.0 10 $/15/97 1 .
III. GENERIC N0 SIGNIFICANT HAZARDS CONSIDERATIONS
'~') "LG" '
(continued)
- 1. Does the change involve a significant increase in the probability or consequence of an accident previously evaluated?
The proposa change moves requirements from the TS to the Bases, FSAR, other licensee controlled documents. The Bases. FSAR, or other licensee controlled documents containing the moved requirements will be maintained using the provisions of 10 CfR 50.59 or other appropriate controls.
Since any changes to the Bases FSAR, or other licensee controlled documents will be evaluated per the requirements of 10 CFR 50.59 or other appropriate regulatory controls, proper controls are in place to adequately limit the probability or consequences of an accident previously evaluated. There fore, this change does not involve a significant increase in the probability or consequences of an accident previously evaluated.
- 2. Does the change create the possibility of a new or different kind of accident from any accident previously evaluated?
The proposed change does not involve o physical alteration of the plant (no new or different type of equipment will be installed) or changes in controlling parameters . The proposed change will not impose any different (Vl requirements and adequate control of the information will be maintained.
Thus, this change does not create the possibility of a new or different kind of accident from any accident previously evaluated.
- 3. Does this change involve a significant reduction in a margin of safety?
The proposed change will not reduce a margin of safety because it has no impact on the design basis or safety analysis. In addition, the requirements to be transposed from the TS to the Bases. FSAR, or other licensee controlled documents are the same as the current TS. Since any future changes to these requirements in the Bases, FSAR, or other licensee controlled documents will be evaluated per the requirements of 10 CFR 50.59 or other appropriate regulatory controls, proper controls are in place to maintain an appropriate margin of safety Therefore, this change does not involve a significant reduction in a margin of safety.
NO SIGNIFICANT HAZARDS CONSIDERATION DETERMINATION Based on the above evaluation, it is concluded that the activities associated with NSHC "LG" resulting from the conversion to the improved TS format satisfy the no significant hazards consideration standards of 10 CFR 50.92(c): and accordingly, a no significant hazards consideration finding is justified.
O CPSES No Significant fla:ards Consideration - 1.0 11 5/15/97
i III. GENERIC NO SIGNIFICANT HAZARDS CONSIDERATIONS '
(h "H" 10 CFR 50.92 EVALUATION FOR
- TECHNICAL CHANGES THAT IMPOSE MORE RESTRICTIVE REQUIREMENTS WITHIN THE TECHNICAL SPECIFICATIONS This proposed revision involves modifying the current Technical Specifications to impose more stringent requirements and achieves consistency with the improved Standard Technical Specifications (NUREG 1431).
The current Technical Specifications have been modified in some areas to impose more stringent guidelines than previously required. These more restrictive modifications are being imposed to be consistent with the improved Standard Technical Specifications (NUREG 1431). Such changes have been made after ensuring the previously evaluated safety analysis was not affected. Also, other more restrictive technical changes have been made to achieve consistency, correct discrepancies, and remove ambiguities from the specification.
This proposed TS change has been evaluated and it has been determined that it '
involves no significant hazards censideration. This determination has been performed in accordance with the criteria set forth in 10 CFR 50.92(c) as quoted Delow:
"The Cwmission may make a final determination, pursuant to the procedures in 50.91, that a proposed amndment to an operating license for a facility licensed under 50.21 (b) or 50.22 or for a testing facility involves no significant hazards consideration, if operation of the facl11ty in accordance with the proposed amendnent would not: ,
- 1. Involve a significant increase in the probability or consequences of an accident previously evaluated; or
- 2. Create the possibility of a new or diflerent kind of accident from any accident previously evaluated; or ;
- 3. Involve a significant reduction ir a margin of safety. "
The following evaluation is provided for the three categories of the significant i hazards consideration standards: l
- 1. Does the change involve a significant increase in the probability or consequences of an accident previously evaluated?
/')
U PSESNo Significant Ha:ards Consideration - 1.0 12 5/]S/97
III. GENERIC NO SIGNIFICANT HAZARDS CONSIDERATIONS (o) v (continued)
The proposed change imposes more stringent requirements for the improved TS.
The change has been reviewed to ensure no previously evaluated accident has been adversely affected. The more stringent requirements are imposed to ensure process variables, structures, systems and components are maintained consistent with the safety analysis and licensing basis. Thcrefore, this change does not involve a significant increase in the probability or consequences of an accident previously evaluated.
- 2. Does the change create the possibility of a new or different kind of accident from any accident previously evaluated?
The proposed change does not involve a physical alteration of the plant (no new or different type of equipment will be installed) or changes in controlling parameters . The proposed change does impose different requirements. However, these changes are consistent with assumptions made in the safety analysis and licensing basis. Thus, this change does not create the possibility of a new or different kind of accident from any accident previously evaluated.
A
- 3. Does this change involve a significant reduction in a margin of safety?
The imposition of more stringent requirements either has no impact on or increases the margin of plant safety by:
a) Increasing the analytical or safety limit, i
b) Increasing the scope of the specification to include additional plant equipment or to add additional requirements, ,
l c) Increasing the applicability of the specification, I d) Providing additional actions, l
e) Decreasing restoration times, I
, f) Imposing new surveillances or g) Decreasing surveillance intervals.
The change is consistent with the safety analysis and licensing basis. Therefore, I this change does not involve a reduction in a margin of safety.
l
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fPSESN3 Significant11a:ards Consideration - 1.0 13 5/15/97 l
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III. GENERIC N0 SIGNIFICANT HAZARDS CONSIDERATIONS "H"
(continued)
NO SIGNIFICANT HAZARDS CONSIDERATION DETERMINATION
\
Based on the above evaluation, it is concluded that the activities associated with ;
NSHC "M" resulting from the conversion to the improved TS format satisfy the no ,
significant hazards consideration standards of 10 CFR 50.92(c): and accordingly, a no significant hazards consideration finding is justified. '
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<> i PSESNs Significant Hazards Consideration '- 1.0 14 S/]5/97
IV. SPECIFIC N0 SIGNIFICANT HAZARDS-CONSIDERATIONS NSHC LS 1 10 CFR 50.92 EVALUATION FOR TECHNICAL CHANGES THAT IMPOSE LESS RESTRICTIVE REQUIREMENTS WITHIN THE TECHNICAL SPECIFICATIONS The current TS definition of Core Alterations would be modified to conform to NUREG-1431 by qualifying a core alteration as a movement of fuel, sources, or other reactivity control components. Other reactivity control components include items such as shutdown and control rods and neutron absorbers. This would allow movement of other components within the reactor vessel (with fuel in the vessel) that would have no effect on core reactivity. The proposed change would continue to maintain the required level of safety while eliminating unnecessary restrictions on the movement of items such as cameras, etc.
This proposed TS change has been evaluated and it has been determined that it Linvolves no significant hazards consideration. This determination has been performed in accordance with the criteria set forth in 10 CFR 50.92(c) as quoted below:
"The Cornmission may make a final determination. pursuant to the procedures in
. 50.91, that a proposed amendrnent to an operating license for a facility licensed under 50.21 (b) or 50.22 or for a testing facility involves no O significant hazards consideration, if operation of the facility in accordance with the proposed amendnent would not:
i l
- 1. Involve a significant increase in the probability or consequences of an accident previously evaluated; or
- 2. Create the possibility of a new or different kind of accident from any accident previously evaluated; or i
- 3. Involve a significant reduction in a margin of safety." l The following evaluation is provided for the three categories of the significant ,
hazards consideration standards:
- 1. Does the change involve a significant increase in the probability or '
consequences of an accident previously evaluated?
The proposed change would continue to allow the application of appropriate j limits to' the movement of components that could affect core reactivity. The l proposed change would not affect the initiators of any analyzed events and !
will not alter assumptions relative to mitigation of accident or transient l events. The probability of any core reactivity accident is not increased .
since the proposed change ensures control of those components having the !
potential for impact on the accident analyses. Therefore, this change does
.b not involve a significant increase in the probability or consequences of an .
accident previously evaluated. l
[CPSESNoSignificantHa:ards Consideration -1.0 15 5/15/97 }
7 gg IV. SPECIFIC NO SIGNIFICANT HAZARDS CONSIDERATIONS V NSHC LS 1 (continued)
- 2. Does the change create the possibility of a new or different kind of i accident from any accident previously evaluated' ;
The proposed change does not necessitate a physical alteration of the plant (no new or different type of equipment will be installed) or changes in ;
parameters governing normal plant operation. The proposed change does impose l' different requirements. However, these changes are consistent with assumptions made in the safety analysis and licensing basis. Thus, this ,
change does not create the possibility of a new or different kind of accident [
from any accident previously evaluated.
- 3. Does this change involve a significant reduction in a margin of safety?
Since the proposed change will continue to allow the application of appropriate limits to the movement of components within the reactor vessel (with fuel in the vessel) that could affect core reactivity, the proposed change will not result in a significant reduction in a margin of safety. i NO SIGNIFICANT HAZARDS CONSIDERATION DETERMINATION ;
Based on the above evaluation. it is concluded that the activities associated with NSHC "LS 1" resulting from the conversion to the improved TS format satisfy the no significant hazards consideration standards of 10 CFR 50.92(c): and accordingly, a no significant hazards consideration finding is justified. l 1
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' CPSES No SignifIcant Hazards Consideration - 1.0 16 5/]5/97
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L IV. SPECIFIC N0 SIGNIFICANT HAZARDS CONSIDERATIONS a
NSHC LS 2 10 CFR 50.92 EVALUATION FOR TECHNICAL CHANGES THAT IMPOSE LESS RESTRICTIVE i REQUIREMENTS WITHIN THE TECHNICAL SPECIFICATIONS ,
Current TS Table 1.2 (improved TS Table 1.1-1) is revised such that the required reactor vessel head closure bolt requirements for H0 DES 4, 5 and 6 are clarified.
Currently a footnote applicable only to MODE 6 defines that Mode, in part, by reference to " vessel head closure bolts less than fully tensioned." That footnote does not specify the transition point between H0 DES 5 and 6 with regard to the ;
number of vessel head closure bolts that must be fully tensioned, leaving the issue open to interpretation. The proposed change provides the necessary clarification by adding a footnote to MODES 4 and 5, consistent with the approach used in NUREG 1431 Rev.1, to define those Modes as having the required number of reactor vessel head closure bolts fully tensioned. The transition point between H0 DES 5 and 6 would also be clarified as occurring when the required reactor vessel head closure bolts are less than fully tensioned. The required number of closure bolts, which may be less than the total number, is established by analysis that demonstrates adequate 0-ring compression to prevent leakage and ensures that ASHE Section III stress limits for affected components are not exceeded. This change is consistent with traveler TSTF 88.
/"~'N Q This proposed TS change has been evaluated and it has been determined that it involves no significant hazards consideration. This determination has been j
performed in accordance with the criteria set forth in 10 CFR 50.92(c) as quoted !
below:
"The Corimission may make a final determination, pursuant to the procedures in .
50.91. that a proposed amendnent to an operating license for a facility l licensed under 50.21 (b) or 50.22 or for a testing facility involves no l significant hazards consideration. if operation of the facility in accordance i with the proposed amendment would not:
- 1. Involve a significant increase in the probablisty or consequences of an accident previously evaluated; or
- 2. Create the possibility of a new or different kind of accident frorn any acc1 dent prevfously evaluated; or
- 3. Involve a significant reduction in a margin of safety."
The following evaluation is provided for the three categories of the significant hazards consideration standards:
- 1. Does the change involve a significant increase in the probability or consequences of an accident previously evaluated?
CPSESNo Significant Ha:ards Consideration - 1.0 17 5/15/97
IV. SPECIFIC N0 SIGNIFICANT HAZARDS CONSIDERATIONS g
Overall protection system performance will remain within the bounds of the accident analyses, since no hardware changes are proposed. The proposed change will not affect the probability of any event initiators nor will the proposed change affect the ability of any safety related equipment to perform its intended function. There will be no degradation in the performance of nor an increase in the number of challenges imposed on safety related equipment assumed to function during an accident situation. Therefore, the proposed change does not involve a significant increase in the probability or consequences of an accident previously evaluated.
- 2. Does the change create the possibility of a new or different kind of accident from any accident previously evaluated?
There are no hardware changes nor are there any changes in the method by which any safety related plant system performs its safety function. The method of plant operation is unafrected. Leakage would be precluded by the analysis:
however, if ler.Kage were to res alt from having less than the total number of closure bolts fully tensioned i', would be detected by an increase in the temperature on the leak off line from the annular space between the inner and O outer vessel htad 0 rings. That temperature increase would be detected by C installed temperature indicators and alarmed in the control room. Any leakage would be detected as an increase in RCS identified LEAKAGE. No new accident scenarios. tracsient precursors, failure mechanisms, or limiting single failures are introduced as a result of this change. Therefore, the proposed change does not create the possibility of a new or different kind of accident from any previously evaluated.
- 3. Does this change involve a significant reduction in a margin of safety?
The proposed change does not affect the acceptance criteria for any analyzed event. There will be no effect on the manner in which safety limits or limiting safety system settings are determined nor will there be any effect on those plant systems necessary to assure the accomplishment of protection functions. There will be no impact on any margin of safety.
N0 SIGNIFICANT HAZARDS CONSIDERATION DETERMINATION Based on the above evaluation, it is concluded that the activities associated with NSHC "LS 2" resulting from the conversion to the improved TS format satisfy the no significant hazards consideration standards of 10 CFR 50.92(c): and accordingly, a
,s no significant hazards consideration finding is justified.
( )
v CPSES No Significant Ha:ards Consideration - 1.0 18 S/15/97
IV. SDECIFIC N0 SIGNIFICANT HAZARDS CONSIDERATIONS 7-j NSHC LS 3 10 CFR 50.92 EVALUATION FOR TECHNICAL CHANGES THAT IMPOSE LESS RESTRICTIVE REQUIREMEWS WITHIN THE TECHNICAL SPECIFICATIONS The Quadrant Power Tilt Ratio (0PTR) is defined as the ratio of the maximum of the four excore detector calibrated output to the average of the four excore detector calibrated outputs for the upper half of the detectors and the lower half of the detectors. If, while above 75% Rated Thermal Power (RTP), one of the excore detector inputs to the OPTR calculation becomes inoperable, the current Technical Specifications allow the use of the movable incore detector system to determine an equivalent OPTR. The current Technical Specifications do not contain any provisions for determining OPTR with more than one inoperable input: thus LCO 3.0.3 would be entered and the plant would be shut down.
The proposed change would allow for the use of the Ueble incore detector system to determine an equivalent OPTR with one or more inoperable excore detector inputs to the OPTR calculation. If the movable incore detector system is used to determine an equivalent OPTR, the OPTR calculation is not based on information gained from any operable excore indications and, therefore, is independent of the number of operable excore detectors.
,y
) This proposed TS change has been evaluated and it has been determined that it
'~' involves no significant hazards consideration. This determination has been performed in accordance with the criteria set forth in 10 CFR 50.92(c) as quoted below:
"The Com11ssion may make a final determination, pursuant to the procedures in 50.91. that a proposed amendment to an operating license for a facility licensed under 50.21 (b) or 50.22 or for a testing facility involves no significant hazards consideration, if operation of the faci 1ity in accordance with the proposed amendnent kould not:
- 1. Involve a significant increase in the probability or consequences of an accident previously evaluated; or
- 2. Create the possibility of a new or different kind of accident from any accident previously evaluated; or
- 3. Involve a significant reduction in a margin of safety. "
The following evaluation is provided for the three categories of the significant hazards consideration standards:
J CPSES No Significant Hazards Consideration - 1.0 19 5/15/97
.__ = =-.
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IV. SPECIFIC NO SIGNIFICANT HAZARDS CONSIDERATIONS l
- 1. Does the change involve a significant increase in the probability or consequences of an accident previously evaluated? ;
The proposed change does not involve any new operating activities or hardware changes; thus, the proposed change has no effect on the probability of an accident.
This change makes available an option to ensure that continued plant operation (quadrant power tilt) is within the assumptions of the accident analyses without imposing an unnecessary transient on the plant. The limits on the quadrant power tilt ratio Limiting Conditions for Operation (LCO) are ,
unchanged. Because the accident analyses are initiated from within the conditions defined by the Technical Specification LCOs, and these LCOs are unchanged, the accident analyses are unaffected. Therefore, there will be no
- effect on any of the accident analysis assumptions and the consequences of the accident analyses are unaffected by this change. ,
- 2. Does the change create the possibility of a new or different kind of accident from any accident previously evaluated?
' The assumptions of the accident analyses are unaffected by the proposed change. No new permutations or event initiators are introduced by the proposed alternate method of determining an equivalent QPTR with more than one inoperable excore detector inputs. Therefore, there is no possibility for a ,
new or different kind of accident.
t
- 3. Does this change involve a significant reduction in a margin of safety?
The accident analyses are assurted to be initiated from conditions which are consistent with the Technical Specifications Limiting Conditions for '
Operation. The proposed change does not affect any LCO. Therefore, there is no change in the accident analyses and all relevant event acceptance criteria remain valid. Further, the proposed change has no affect on any actual or ,
regulated failure point which is protected by an event acceptance criterion. !
Because there is no change in any failure point nor in any event acceptance criteria, there is no reduction in a margin of safety.
Based upon the preceding information, it has been determined that the proposed change to the Technical Specification does not involve a significant increase in the i probability or consequences of an accident previously evaluated, create the possibility of a new or different kind of accident from any accident previously evaluated, or involve a significant reduction in a margin of safety. Therefore, it .
-is concluded that the proposed change meets the requirements of 10 CFR 50.92 (c) and
.(' does not involve a significant hazards consideration.
CPSESNoSignificantHa:ards Consideration -1.0 20 S/158 7
f..
l IV. SPECIFIC N0.SIGNIFICANT HAZARDS CONSIDERATIONS O NSHC LS 3 i
(continued)- -i i
NO SIGNIFICANT HAZARDS CONSIDERATION DETERMINATION l
Based on the above evaluation, it is concluded that the activities associated with j NSHC "LS 3" resulting from the conversion to the improved TS format satisfy the no 1 significant hazards consideration standards of 10 CFR 50.92(c): and accordingly, a no significant hazards consideration finding is justified. .
1
- 1'
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i CPSESNo Significant Hazards Consideration - 1.0 21 S/]St97 i
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4
, ENCLOSURE 5A J
i MARK-UP OF NUREG-1431 SPECIFICATIONS t
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MARK-UP OF NUREG-1431 SPECIFICATIONS CONTENTS Applicable Industry Traveler Information (1 Page)
NUREG-1431 Specifications which are not applicable (1 Page)
Mark-up:
SPECIFICATION PAGE 1.1.......................................................................................................l.1-1 1.2.......................................................................................................l.2-1 1.3.......................................................................................................l.3-1 1.4.......................................................................................................l.4-1 Methodology (2 Pages) i d
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INDUSTRY TRAVELERS APPLICABLE TO SECTION 1.0
(^N ' )
!\ T RAVELER # STATUS COMMENTS DIFFERENCE
{
H TSTF 19. Rev 1 Not NA Not NRC approved as of incorporated traveler cut off date.
TSTF 79. Rev 1 Incorporated 1.1 9 TSTF-64 Incorporated 1.1 1 TSTF 88 Incorporated 1.1 8 TSTF-111, Rev 1 Incorporated 1.1 5 l WOG-67, Rev 1 Incorporated 1.1 6 WOG-74, Rev 1 Incorporated 1.1 3 WOG-90; *1 Incorporated 1.1 11 i
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O NUREG-1431 SPECIFICATIONS THAT ARE NOT APPLICABLE None j
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Definitions '
1.1 1.0 USE AND APPLICATION 1.1 Definitions
..................................... NOTE --- -- '
The defined terms of this section appear in capitalized type and are applicable throughout these Technical Specifications and Bases. ;
Igtm Definition ;
ACTIONS ACTIONS shall be that part of a Specification that prescribes Required Actions to be taken under designated
- Conditions within specified Completion Times.
- ACTUATION LOGIC TEST An ACTUATION LOGIC TEST shall be the application of various .
simulated or actual input combinations in conjunction with each possible interlock logic state and the verification of '
the required logic output. The ACTUATION LOGIC TEST, as a minimum, shall include a continuity check of output -
devices.
AXIAL FLUX DIFFERENCE AFD shall be the difference in normalized flux B-PS-.
(AFD) signals between the top!andibottom'halveslof e O te section an excotemneuttonidetector.
V CHANNEL CALIBRATION A CHANNEL CALIBRATION shall be the adjustment, as '
necessary, of the channel so that it responds within the required range and accuracy to known input. The CHANNEL CALIBRATION shall encompass those. components 2 the entire chcnnci, including the required sucLas] sensors, alarms, ,
interlock, displays, and trip functionsZrequiredito 1.1-1 perform;thefspecified;safetyfunctions(s)y Calibration of ;
instrument channels with resistaace temperature detector :
(RTD) or thermocouple sensors may consist of an inplace qualitative assessment of sensor behavice and normal calibration of the remaining adjustable devices in the channel. Whenever a sensing element is replaced, the next required CHANNEL CALIBRATION shall include an inplace cross calibration that compares the other sensing elements with the recently installed sensing element. The CHANNEL CALIBRATION may be performed by means of any series of sequential, overlapping calibrations or total channel steps so that the entire channel is calibrated. l t
}
i (continued)
CPSESMark-up ofNUREG-lui1TS- LO 1.1-1 S/1587
Definitions 1.1 1.1 Definitions (continued)
[]
G CHANNEL CHECK A CHANNEL CHECK shall be the qualitative assessment, by observation, of channel behavior denng operation. This determination shall include, where passible, comparison of the channel indication and status to other indications or status derived from independent instrument channels measuring the same parameter. ,
CHANNEL OPERATIONAL A COT shall be the injection of a simulated or TEST (C0T) actual signal into the channel as close to the sensor as practicable to verify the OPERABILITY of required includiggiallicomponents]1n;thefchannelJ?such asialarms, 1.1-1 interlocks, displays, and trip functions required to ,
perform::the!speci fi ed isafetyf function (s) . The_.COTimay<be ,
1 1-9 performed lby means fofiany; series' of sequential,? overlapping orltotalf channell steps Tso1that;the1enti re;channe]Ei s tested l The COT shall include adjustments, as necessary, of the required alarm, interlock, and trip setpoints so that the setpoints are within the required range and accuracy.
CORE ALTERATION CORE ALTERATION shall be the movement of any fuel, sources, or reactivity control components, within the reactor vessel with the vessel head removed and fuel in the vessel.
Suspension of CORE ALTERATIONS shall not preclude completion of movement of a component to a safe position.
CORE OPERATING LIMITS The COLR is the unit specific document that REPORT (COLR) provides cycle specific parameter limits for the current reload cycle. These cycle specific parameter limits shall be determined for each reload cycle in accordance with Specification 5.6.5. Plant operation within these limits is addressed in individual Specifications.
DOSE EQUIVALENT I 131 DOSE EQUIVALENT I 131 shall be that concentration of I 131 (microcuries/ gram) that alone would produce the same thyroid dose as the quantity and isotopic mixture of I-131, 1 132, I 133. I 134, and I 135 actually present. The thyroid dose conversion factors used for this calculation ,
shall be those listed in TableIIII/;of3IDf14844? 'B ]
AEC.El%2,11 Cal culation:of;D.i stance factors;for;PoweCand Test Reactor 1Sitesmot;those: listed _in!. Table:EE7;of Regulatory; Guide 310109,58ev.I l,MNRC T 1977J,;r JC E 00; 1 SLWie. .;;.0,te 3rt;r3;;;; 192: 212, ;Tabl e _ ti tied. l
- Cva itted Oe;E Equjveler,t;jiLier.get _.Orger,3;;cr;Ti suesjet !
5tAGlMG3tUNC l I
O V (continued) l CPSES3iatK-up ofNUREG-1431ITS- 1.0 1.1-2 S/1587 i
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Definitions l 1.1 l 1.1 Definitions (continued)
O(3 E- AVEPAGE E shall be the average (weighted in proportion to DISINTEGRATION ENERGY the concentration of each radionuclide in the reactor .
coolant at the time of sampling) of the sum of the average beta and gamma energies per disintegration (in HeV) for isotopes, other than iodines, with half lives .B-psi
> H 10 minutes, making up at least 95% of the total <
noniodine activity in the coolant. ;
ENGINEERED hAETY The ESF RESPONSE TIME shall be that time FEATURE (ESF) RESPONSE interval from when the monitored parameter TIME exceeds its ESF actuation setpoint at the channel sensor until the ESF equipment is capable of performing its safety function (i.e., the valves travel to their required positions, pump discharge pressures reach their required values, etc.). Times shall include diesel generator starting and sequence loading delays, where applicable. 1 The response time may be =surd verified by means of any series of sequential, overlapping, or total steps so that the entire response time is measured verifled. 1 l'6 L. The maximum allowable primary containment leakage rate. L., :
shall be 0.10 % of primary containment air weight per day ,
w at the calculated peak containment pressure (P,).
LEAKAGE LEAKAGE shall be:
- a. Identified LEAKAGE ,
- 1. LEAKAGE, such as that from pump seals or valve packing (except reactor coolant pump (RCP) seal water injection or leakoff) that is captured and conducted to collection systems or a sump or collecting tank: ;
- 2. LEAKAGE into the containment atmosphere from sources that are both specifically located and known either not to interfere with the ;
operation of leakage detection systems or not to be pressure boundary LEAKAGE: or i
- 3. Reactor Coolant System (RCS) LEAKAGE through a steam generator (SG) to the Secondary ,
System:
l (continued)
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Definitions 1.1 l 1.1 Definitions- (continued) J J
LENE b. Unidentified LEAXAGE (continued)
All LEAKAGE (except RCP seal water injection or i
leakoff) that is not identified LEAKAGE:
L
- c. Pressure Boundary LEAKAGE LEAKAGE (except SG LEAKAGE) through a nonisolable fault in an RCS component body, pipe wall, or vessel wall.
MASTER RELAY TEST A MASTER RELAY TEST shall consist of energizing each master relay and verifying the OPERABILITY of each relay. The MASTER RELAY TEST shall include a s continuity check of each associated slave relay.
4 H0DE A MODE shall correspond to any one inclusive combination of core reactivity condition, power level, average reactor coolant temperature, and reactor vessel head closure bolt tensioning specified in Table 1.1-1 with fuel in the reactor vessel.
2 OPERABLE-0PERABILITY A system, subsystem, train, component, or device shall be OPERABLE or have OPERABILITY when it is capable of performing its specified safety function (s) and when '
l all necessary attendant instrumentation, controls, normal or emergency electrical power, cooling and seal water, lubrication, and other auxiliary equipment that are required for the system, subsystem, train, component, or device to perform its specified safety function (s) are also capable of performing their ;
related support function (s).
PHYSICS TESTS PHYSICS TESTS shall be those tests performed to measure the fundamental nuclear characteristics of the !
reactor core and related instrumentation. These tests are:
- a. Described in Chapter 1.4, Ir.itici Test Pr;;; rem of B-PS' the FSAR: j
- b. Authorized under the provisions of 10 CFR 50.59:
or
- c. Otherwise approved by the Nuclear Regulatory ,
Commission. ;
(continued) p LJ i CPSESMark-up ofNUREG-1431ITS-1.0 1.1-4 5/15/97
I Definitions i 1
1.1 n 1.1 Definitions (continued) .
PRESSURE AND The PTLR is the unit specific document that TEMPERATURE LIMITS provides the reactor vessel pressure and REPORT (PTLR) temperature limits, including heatup and cooldown rates ,[thelpokeCoperated; re].iefival ye3 PORV)I]i f t 1.1-6 settings [and arming;temperaturezassociatedlyith;the Low; Temperature 10yerptessurizationfrotectioni(LIOD System, for the current reactor vessel fluence period.
These pressure and temperature limits shall be determined for each fluence period in accordance with Specification 5.6.6. Plant operation within these cperating limits is addressed in Individual, specifications ~.7LCO 2.4.2. "RCS Pressurc and 1.1-6 Temperaturc (I/T) Limits," and LCO 3.4.12. " Low Temperature Ovcrpressurc Prctcction (LTOP) System."
OVADRANT POWER TILT QPTR shall be the ratio of the maximum upper RATIO (0PTR) excore detector calibrated output to the average of the upper excore detector calibrated outputs, or the ratio of the maximum lower excore detector calibrated output to the average of the lower excore detector calibrated outputs, whichever is greater.
. RATED THERMAL POWER RTP shall be a total reactor core heat transfer (RTP) rate to the reactor coolant of-2893 3411 MWt. B-PS REACTOR TRIP The RTS RESPONSE TIME shall be that time interval SYSTEM (RTS) RESPONSE from when the monitored parameter exceeds its RTS TIME trip setpoint at the channel sensor until loss of stationary gripper coil voltage. The response time may be mcasured yet111ed by means of any series of sequential, overlapping, or total steps so that the 1.1-5 entire response time is mcasured yetif,ied.
SHUTDOWN MARGIN (SDM) SDM shall be the instantaneous amount of reactivity by which the reactor is subcritical or would be subcritical from its present condition assuming:
- a. All rod cluster control assemblies (RCCAs) are fully inserted except for the single RCCA of highest reactivity worth, which is assumed to be fully withdrawn. With any RCCA not capable of being fully inserted, the reactivity worth of the RCCA must be accounted for in the determination of SDM: and
- b. In H0 DES 1 and 2, the fuel and moderator temperatures are changed to the nominal ccrc B-PS pcwcr design level ho_t'zero power [ temperatures.1 D
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l Definitions 1.1 i 1.1 Definitions (continued)
SLAVE RELAY TEST A SLAVE RELAY TEST shall consist of energizing each slave relay and verifying the OPERABILITY of each !
slave relay. The SLAVE RELAY TEST shall include, as a minimum, a continuity check of associated testable actuation devices.
STAGGERED TEST BASIS A STAGGERED TEST BASIS shall consist of the testing of one of the systems, subsystems, channels, or other designated components during the interval specified by the Surveillance Frequency, so that all systems, .
subsystems, channels, or other designated components are tested during n Surveillance Frequency intervals, where n is the total number of systems, subsystems, channels, or other designated components in the ,
associated function.
THERMAL POWER THERMAL POWER shall be the total reactor core heat transfer rate to the reactor coolant.
TRIP ACTUATING DEVICE A TAD 0T shall consist of operating the trip OPERATIONAL TEST actuating device and verifying the OPERABILITY ef y y~1 (TAD 0T) required includjng[all. componentslin;the: channel',[such f
\
asjalarms, interlocks, displays, and trip functions requi red itol perform"the:specifj edisa fetyifunction( s) . '
The; TAD 0T;mayl be ~ performed : by. neansioflany; series:' of sequenti al gover.1 appj ngloritotallchannellsteps; sol.that 1.1-9 thelentLte channelitsitested! The TADOT shall include adjustment, as necessary, of the trip actuating device so that it actuates at the required setpoint within the required accuracy.
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Definitions 1.1 L '! Table 1.1-1 (page 1 of 1) ,
MODES
- RATED AVERAGE REACTIVITY REACTOR COOLANT H00E TITLE CONDITION THQ POWER TEMPERATURE
( k,,,) (*F) 1 Power Operation 2 0.99 >5 NA 2 Startup 2 0.99 s5 NA 3 Hot Standby < 0.99 NA 21350j B 4 Hot Shutdown (b) < 0.99 NA 3.50 > T.., > 200 B 5 Cold shutdown (b) < 0.99 NA s 200 B
6 Refueling (c) NA NA NA
/~
f
\_ (a) Excluding decay heat.
(b) ALE 8eq0ltedJreactor vessel head closure bolts fully tensioned. 1.1-8 (c) One c.r ;rcrcReggfred reactor vessel head closure bolts less than fully l tensioned. i O
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Logical Connectors l 1.2 I
[)
J 1.0 USE AND APPLICATION l
1.2 Logical Connectors PURPOSE The purpose of this section is to explain the meaning of logical connectors.
Logical connectors are used in Technical . Specifications (TS) to discriminate I
between, and yet connect, discrete Conditions, Required Actions, Completion Times, Surveillances, and Frequencies. The only logical connectors that appear in TS are AND and 08. The physical arrangement of these connecurs constitutes logical conventions with specific meanings.
BACKGROUND Several levels of logic may be used to state Required Actions. These levels are identified by the placement (or nesting) of the logical connectors and by the number assigned to each Required Action. The first level of logic is identified by the first digit of the number assigned to a Required Action and the placement of the logical connector in the first level of nesting (i.e., left justified with the number of the Required Action). The successive levels of logic are identified by additional digits of the Required Action number and by successive indentations of the 1 ?ical connectors.
p Q When logical connectors are used to state a Condition Completion Time, Surveillance, or Frequency, only the first level of logic is used, and the j logical connector is left justified with the statement of the Condition. ,
Completion Time, Surveillance, or Frequency. l l
EXAMPLES The following examples illustrate the use of logical connectors.
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Logical Connectors i
'1.2
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('rh[ EXAMPLES EXAMPLE 1.2-1 (continued) ,
ACTIONS l CONDITION REQUIRED ACTION COMPLETION TIME ,
i A. LCO not met. A.1 Verify . . .
M A.2 Restore . . .
i In this example the logical connector E is used to indicate ;
that when in Condition A, both Required Actions A.1 and A.2 must be completed.
F O :
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i (continued) !
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Logical Connectors 1.2 ;
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() 1.2 Logical Connectors i
EXAMPLES- EXAMPLE 1.2 2 (continued)
ACTIONS CONDITION REQUIRED ACTION COMPLETION TIME ,
.A. LCO not met. A.1 Trip . . . l 2
A.2.1 Veri fy . . . :
t AtiQ A.2.2.1 Reduce . . .
m A.2.2.2 Perform . . . l O E A.3 Align . . .
This example represents a more complicated use of logical connectors. Required Actions A.1, A.2, and A.3 are alternative choices, only one of which must be perforined as indicated by the use of the logical connector E and the left justified placement.
Any one of these three Actions may be chosen. If A.2 is chosen, then both A.l!.1 end A.2.2 must be performed as indicated by the logical conne-tor AND. Required Action A.2.2 is met by '
performing e.1.?.1 or A.2.2.2. The indented position of the logical conim.t r Of3 indicates that A.2.2.1 and A.2.2.2 are alternative choices, only one of which must be performed.
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. Completion Times t 1.3 1.0. USE AND APPLICATION 1,3 Completion Times i
PURPOSE The purpose of this section is to establish the Completion Time convention and to provide guidance for its use. ;
P BACKGROUND Limiting Conditions for Operation (LCOs) specify minimum !
requirements for ensuring safe operation of the unit. The !'
ACTIONS associated with an LC0 state Conditions that typically describe the ways in which the requirements of the LCO can fail +
to be met. Specified with each stated Condition are Required .
Action (s) and Completion Time (s).
DESCRIPTION The Completion Time is the amount of time allowed for completing a Required Action. It is referenced to the time of discovery of a situation (e.g., inoperable equipment or variable not within limits) that requires entering an ACTIONS Condition unless i otherwise specified, providing the unit is in a H0DE or specified O- condition stated in the Applicability of the LCO. Required Actions must be completed prior to the expiration of the specified Completion Time. An ACTIONS Condition remains in effect and the Required Actions apply until the Condition no longer exists or the unit is not within the LCO Applicability. ;
If situations are discovered that require entry into more than one Condition at a time within a single LC0 (multiple i Conditions), the Required Actions for each Condition must be performed within the associated Completion Time. When in multiple Conditions, separate Completion Times are tracked for !
each Condition starting from the time of discovery of the situation that required entry into the Condition.
Once a Condition has been entered, subsequent trains, subsystems, i components, or variables expressed in the Condition, discovered .
. to be inoperable or not within limits, will mt result in j
. separate entry into the Condition, unless specifically stated.
~ The Required Actions of the Condition continue to apply to each l additional failure, with Completion Times based on initial entry into the Condition. ,
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Completion Times 1.3 1.3 Comoletion Times 'i DESCRIPTION However, when a subseauent train, subsystem, component, or (continued) variable expressed in the Condition is discovered to be inoperable or not within limits, the Completion Time (s) may be extended. To apply this Completion Time extension, two criteria must first be met. The subsequent inoperability:
i
- a. Must exist concurrent with the first inoperability: and
- b. Must remain inoperable or not within limits after the first inoperability is resolved.
The total Completion Time allowed for completing a Required Action to address the subsequent inoperability shall be limited to the more restrictive of either:
- a. The stated Completion Time, as measured from the initial entry into the Condition, plus an additional 24 hour2.777778e-4 days <br />0.00667 hours <br />3.968254e-5 weeks <br />9.132e-6 months <br />s: or
- b. The stated Completion Time as measured from discovery of
- the subsequent inoperability.
The above Completion Time extensions do not apply to those Specifications that have exceptions that allow completely separate re entry into the Condition (for each train, subsystem, ,
component, or variable expressed in the Condition) and separate tracking of Completion Times based on this re entry. These O. exceptions are stated in individual Specifications.
The above Completion Time extension does not apply to a Completion Time with a modified " time zero." This modified " time '
zero" may be expressed as a repetitive time (i.e., "once per 8 hours9.259259e-5 days <br />0.00222 hours <br />1.322751e-5 weeks <br />3.044e-6 months <br /> " where the Completion Time is referenced from a previous completion of the Required Action versus the time of Condition entry) or as a time modified by the phrase "from discovery . . ."
Example 1.3 3 illustrates one use of this type of Completion Time. The 10 day Completion Time specified for Conditions A and B in Example 1.3 3 may not be extended.
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t (continued)
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- Completion Times 1.3 i O 1.3 Completion Times (continued)
EXAMPLES The following examples illustrate the use of Completion Times with different types of Conditions and changing Conditions.
EXAMPLE 1.3-1 l ACTIONS !
CONDITION REQUIRED ACTION COMPLETION TIME i
B. Required B.1 Be in H0DE 3. 6 hours6.944444e-5 days <br />0.00167 hours <br />9.920635e-6 weeks <br />2.283e-6 months <br /> l Action and 6 associated 6ND Completion Time not met. B.2 Be in H0DE 5. 36 hours4.166667e-4 days <br />0.01 hours <br />5.952381e-5 weeks <br />1.3698e-5 months <br /> f,
Condition B has two Required Actions. Each Required Action has its own separate Completion Time. Each Completion Time is O- referenced to the time that Condition B is entered.
4 The Required Actions of Condition B are to be in H00E 3 within 6 hours6.944444e-5 days <br />0.00167 hours <br />9.920635e-6 weeks <br />2.283e-6 months <br /> ANQ in H0DE 5 within 36 hours4.166667e-4 days <br />0.01 hours <br />5.952381e-5 weeks <br />1.3698e-5 months <br />. A total of 6 hours6.944444e-5 days <br />0.00167 hours <br />9.920635e-6 weeks <br />2.283e-6 months <br /> is allowed for reaching H0DE 3 and a total of 36 hours4.166667e-4 days <br />0.01 hours <br />5.952381e-5 weeks <br />1.3698e-5 months <br /> (not 42 hours4.861111e-4 days <br />0.0117 hours <br />6.944444e-5 weeks <br />1.5981e-5 months <br />) is allowed for reaching MODE 5 from the time that Condition B was entered. If MODE 3 is reached within 3 hours3.472222e-5 days <br />8.333333e-4 hours <br />4.960317e-6 weeks <br />1.1415e-6 months <br />, ,
the time allowed for reaching H0DE 5 is the next 33 hours3.819444e-4 days <br />0.00917 hours <br />5.456349e-5 weeks <br />1.25565e-5 months <br /> because !
the total time allowed for reaching H0DE 5 is 36 hours4.166667e-4 days <br />0.01 hours <br />5.952381e-5 weeks <br />1.3698e-5 months <br />.
If Condition B is entered while in H00E 3. the time allowed for reaching H0DE 5 is the next 36 hours4.166667e-4 days <br />0.01 hours <br />5.952381e-5 weeks <br />1.3698e-5 months <br />, j l
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(Continued) l CPSESMarA-up ,fNUREG-1431ITS-1.0 1.3-3 5/15/97 l
Completion Times 1.3 7q 1.3 Completion Times EXAMPLES EXAMPLE 1.3 2 (continued)
ACTIONS CONDITION REQUIRED ACTION COMPLETION TIME A. One pump A.1 Restore pump to 7 days inoperable. OPERABLE status.
B. Required B.1 Be in MODE 3. 6 hours6.944444e-5 days <br />0.00167 hours <br />9.920635e-6 weeks <br />2.283e-6 months <br /> Action and associated SQ Completion Time not met. B.2 Be in H00E 5. 36 hours4.166667e-4 days <br />0.01 hours <br />5.952381e-5 weeks <br />1.3698e-5 months <br /> O
'd When a pump is declared inoperable, Condition A is entered. If the pump is not restored to OPERABLE status within 7 days, Condition B is also entered and the Completion Time clocks for Required Actions B.1 and B.2 start. If the inoperable pump is restored to OPERABLE status after Condition B is entered, Condition A and B are exited, and therefore, the Required Actions of Condition B may be terminated.
When a second pump is declared inoperable while the first pump is still inoperable. Condition A is not re entered for the second pump. LC0 3.0.3 is entered, since the ACTIONS do not include a Condition for more than one inoperable pump. The Completion Time clock for Condition A does not stop after LC0 3.0.3 is entered, but continues to be tracked from the time Condition A was initially entered. ;
While in LCO 3.0.3, if one of the inoperable pumps is restored to ;
OPERABLE status and the Completion Time for Condition A has not expired, LC0 3.0.3 may be exited and operation continued in accordance with Condition A.
While in LC0 3.0.3. if one of the inoperable pumps is restored to OPERABLE status and the Completion Time for (continued)
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~. . . _ . _ . . _ _ , _ . ... _ _ - _ . _ _ _ _ _ . . _ _ _ _ _
't' ~ Completion Times 1.3 -;
J 1.3 Completion Times EXAMPLES EXAMPLE 1.3d (continued) 1 Condition A has expired, LC0 3.0.3 may be. exited and operation ,
continued in accordance with Condition B. The Completion Time '
for Condition B is tracked from the time the Condition A <
Completion Time expired. l On restoring one of the pumps to OPERABLE status, the Condition A :
Completion Time is not reset, but continues from the time the
~
first pump was declared inoperable. This Completion Time may be extended if the pump restored to OPERABLE status was the first inoperable pump. A 24 hour2.777778e-4 days <br />0.00667 hours <br />3.968254e-5 weeks <br />9.132e-6 months <br /> extension to the. stated 7 days is allowed, provided this does not result in the second pump being inoperable for > 7 days.
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yletion Times
-1.3 i
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rL - 1.3 L Completion Times -
4 !
EXAMPLES EXAMPLE 1.3 3 t
(continued) .
ACTIONS l
' CONDITION. REQUIRED ACTION: COMPLETION TIME ~ {+
A.1 Restore Function'X 7 days j A. One 1 Function X- train to OPERABLE. .'
I train . status. AND inoperable.
- 10 days.from discovery of i ' failure to meet -;
the LC0- l
- - l r
B. One B.1 Restore Function Y 72 hours8.333333e-4 days <br />0.02 hours <br />1.190476e-4 weeks <br />2.7396e-5 months <br />.
Function Y train to OPERABLE .l train status. AND l O inoperable.
10 days from discovery of failure to meet i the LCO C. One C.1 Restore Function X 72 hours8.333333e-4 days <br />0.02 hours <br />1.190476e-4 weeks <br />2.7396e-5 months <br /> .
Function X train to OPERABLE }
train status, i inoperable.
08 :
AND :
C.2 Restore Function Y l One train to OPERABLE 72 hours8.333333e-4 days <br />0.02 hours <br />1.190476e-4 weeks <br />2.7396e-5 months <br /> i Function Y status, i train '
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'qf (continued)
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Completion Times 1.3 1.3 Completion Times l l
EXAMPLES EXAMPLE 1.3 3 (continued) 1 When one Function X train and one Function Y train are ;
inoperable. Condition A and Condition B are concurrently applicable. The Completion Times for Condition A and Condition B are tracked separately for each train starting from the time each i train was declared inoperable and the Condition was entered. A J separate Completion Time is established for Condition C and tracked from the time the second train was declared inoperable (i.e., the. time the situation described in Condition C was discovered).
If Required Action C.2 is completed within the specified Completion Time, Conditions B and C are exited. If the-Completion Time for Required Action A.1 has not expired, operation may continue in accordance with Condition A. The -
remaining Completion Time in Condition A is measured from the time the affected train was declared inoperable (i.e., initial ,
entry into Condition A). '
The Completion Times of Conditions A and B are modified by a logical connector with a separate 10 day Completion Time measured 1(p) from the time it was discovered the LCO was not met. In this example, without the separate Completion Time, it would be ;
possible to alternate between Conditions A, B, and C in such a '
manner that operation could continue indefinitely without ever-restoring systems to meet the LCO. The separate Completion Time '
modified by the phrase "from discovery of failure to meet the LC0" is designed to prevent indefinite continued operation while ,
not meeting the LCO. This Completion Time allows for an i exception to the normal " time zero" for beginning the Completion Time " clock". In this instance, the Completion Time " time zero" is specified as commencing at the time the LC0 was initially not met, instead of at the time the associated Condition was entered.
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1.3 l . .
'~ '1.3 Comp 1etion Times ,
EXAMPLES EXAMPLE 1.3 4 (continued)
ACTIONS CONDITION REQUIRED ACTION COMPLETION TIME ,
A. One or more A.1 Restore valve (s) 4 hours4.62963e-5 days <br />0.00111 hours <br />6.613757e-6 weeks <br />1.522e-6 months <br /> valves to OPERABLE inoperable. status. ;
B. Required B.1 Be in MODE 3. 6 hours6.944444e-5 days <br />0.00167 hours <br />9.920635e-6 weeks <br />2.283e-6 months <br /> Action and .
associated MD
' Completion Time not met. B.2 Be in MODE 4. 12 hours1.388889e-4 days <br />0.00333 hours <br />1.984127e-5 weeks <br />4.566e-6 months <br /> A single Completion Time is used for any number of valves inoperable at the same time. The Completion Time associated with Condition A is based on the initial entry into Condition A and is not tracked on a per valve basis. Declaring subsequent valves inoperable. while Condition A is still in effect. does not trigger the tracking of separate Completion Times.
Once one of the valves has been restored to OPERABLE status, the Condition A Completion Time is not reset, but continues from the time the first valve was declared inoperable. The Completion i Time may be extended if the valve restored to OPERABLE status was i the first inoperable valve. The Condition A Completion Time may ,
be extended for up to 4 hours4.62963e-5 days <br />0.00111 hours <br />6.613757e-6 weeks <br />1.522e-6 months <br /> provided this does not result in i any subsequent valve being inoperable for > 4 hours4.62963e-5 days <br />0.00111 hours <br />6.613757e-6 weeks <br />1.522e-6 months <br />. l If the Completion Time of 4 hours4.62963e-5 days <br />0.00111 hours <br />6.613757e-6 weeks <br />1.522e-6 months <br /> (including the extension) expires while one or more valves are still inoperable, Condition B is entered. -
I' (continued) !
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, ' Completion Times - ~ 'l
. 1,3 l I 1.3 ; Completion Times .
EXAMPLES EXAMPLEII35'
. (continued). .. . l
' ACTIONS l
............................N0TE Separate Condition entry is allowed for each inoperable valve. )
CONDITION- REQUIRED ACTION COMPLETION TIME l
i i
' A. ~ 0ne or more A.1' Restore valve to- 4 hours4.62963e-5 days <br />0.00111 hours <br />6.613757e-6 weeks <br />1.522e-6 months <br /> ~!
valves .
OPERABLE status, a
- inoperable. j i
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B. Required. B.1 Be in MODE 3. 6 hours6.944444e-5 days <br />0.00167 hours <br />9.920635e-6 weeks <br />2.283e-6 months <br /> :
Action and 1' associated atEl Completion ;
- O Time not met. B.? Be in MODE 4. 12 hours1.388889e-4 days <br />0.00333 hours <br />1.984127e-5 weeks <br />4.566e-6 months <br /> !
i The Note _ above the ACTIONS Table is a method of modifying how the i Completion Time is tracked. If this method of modifying how the :
Completion Time is tracked was applicable only to a specific :
Condition, the Note would appear in that Condition rather than at t the. top of the ACTIONS Table, j l
The Note allows Condition A to be entered separately for each j inoperable valve, and Completion Times tracked on a per valve ;
basis. When a valve is declared inoperable, Condition A is !
entered and its Completion Time starts. If subsequent valves are !
declared inoperable Condition A is entered for each valve and {
separate Completion Times start and are tracked for each valve. r
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,/ '1.3 Completion Times-EXAMPLES EXAMPLE 1.3 5 (continued) !
If the Completion Time associated with a valve in Condition A expires, Condition B is entered for that valve. If the ,
Completion Times associated with subsequent valves in Condition A :
expire, Condition B is entered separately for each valve and separate Completion Times start and are tracked for each valve.
.If a valve that caused entry into Condition B is restored to OPERABLE status, Condition B is exited for that valve. -
Since the Note in this example allows multiple Condition entry and tracking of separate Completion Times, Completion Time extensions do not apply.
EXAMPLE 1.3 6 ACTIONS CONDITION REQUIRED ACTION COMPLETION TIME r\
-Q A. One channel inoperable.
A.1 Perform SR 3.x.x.x.
Once per 8 hours9.259259e-5 days <br />0.00222 hours <br />1.322751e-5 weeks <br />3.044e-6 months <br /> i E i 8 hours9.259259e-5 days <br />0.00222 hours <br />1.322751e-5 weeks <br />3.044e-6 months <br /> A.2 Reduce THERHAL #
POWER to s 50% RTP.
1 i
B. Required B.1 Be in H0DE 3. 6 hours6.944444e-5 days <br />0.00167 hours <br />9.920635e-6 weeks <br />2.283e-6 months <br /> !
Action and l
associated Completion Time not met.
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[N (Continued) c).
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Completion Times 1.3
- 1.3 Completion Times
. EXAMPLES EXAMPLE 1.3 6 (continued) ,
Entry into Condition A offers a choice between Required Action A.1 or A.2. Required Action A.1 has a "once per*
Completion Time, which qualifies for the 25% extension. per i SR 3.0.2, to each performance after the initial performance. .The initial 8 hour9.259259e-5 days <br />0.00222 hours <br />1.322751e-5 weeks <br />3.044e-6 months <br /> interval of Required Action A.1 begins when Condition A is entered and the initial performance of Required Action A.1 must be complete within the first 0 iour interval. If Required Action A.1 is followed, and the Required Action is not met within the Ctapletion Time (plus the extension allowed by SR 3.0.2), Condition B is entered. If Required Action A.2 is followed and the Completion Time of 8 hours9.259259e-5 days <br />0.00222 hours <br />1.322751e-5 weeks <br />3.044e-6 months <br /> is not :
met, Condition B is entered. .
If after entry into Condition B. Required Action A.1 or A.2-is met, Condition B is exited and operation may then continue in Condition A.
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'O CPSESMarA-up ofNUREG-H31ITS-1.0 1.3-11 S/1S/97 l
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Completion Times 1.3 p' \
1,3 Completion Times
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EXAMPLES EXAMPLE 1.3-7 (continued)
ACTIONS CONDITION REQUIRED ACTION COMPLETION TIME A. One subsystem A.1 Verify affected 1 hour1.157407e-5 days <br />2.777778e-4 hours <br />1.653439e-6 weeks <br />3.805e-7 months <br /> inoperable. subsystem isolated. 680 Once per 8 hours9.259259e-5 days <br />0.00222 hours <br />1.322751e-5 weeks <br />3.044e-6 months <br /> thereafter 6tfD 72 hours8.333333e-4 days <br />0.02 hours <br />1.190476e-4 weeks <br />2.7396e-5 months <br /> A.2 Restore subsystem to OPERABLE status.
,o B. Required B.1 Be in H0DE 3. 6 hours6.944444e-5 days <br />0.00167 hours <br />9.920635e-6 weeks <br />2.283e-6 months <br /> Action and associated AliD Completion Time not met. B.2 Be in H0DE 5. 36 hours4.166667e-4 days <br />0.01 hours <br />5.952381e-5 weeks <br />1.3698e-5 months <br /> Required Action A.1 has two Completion Times. The 1 hour1.157407e-5 days <br />2.777778e-4 hours <br />1.653439e-6 weeks <br />3.805e-7 months <br /> Completion Time begins at the time the Condition is entered and each "Once per 8 hours9.259259e-5 days <br />0.00222 hours <br />1.322751e-5 weeks <br />3.044e-6 months <br /> thereafter" interval begins upon performance of Required Action A.1.
If after Condition A is entered, Required Action A.1 is not met within either the initial I hour or any subsequent 8 hour9.259259e-5 days <br />0.00222 hours <br />1.322751e-5 weeks <br />3.044e-6 months <br /> interval from the previous performance (plus the extension allowed by SR 3.0.2), Condition B is entered. The Completion Time clock for Condition A does not stop after Condition B is entered, but continues from the time
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CPSESMark-up ofNUREG-1431JTS-1.v 1.3-12 21S/97
t Completion T1mes 1.3 r 1.3 Completion Times i
EXAMPLES EXAMPLE 1.3 7 (continued)
I Condition A was initially entered. If Required Action A.1 is met after Condition B is entered, Condition B is exited and operation may continue in accordance with Condition A, provided the ,
Completion Time for Required Action A.2 has not expired.
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'IMMEDIATE When "Immediately" is used as a Completion Time, the
COMPLETION TIME Required Action should be pursued without delay and in a controlled manner.
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I Frequency 1.4
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-1.0 .USE AND APPLICATION 1.4 Frequency PURPOSE The purpose of this section is to define the proper use and application of Frequency requirements.
DESCRIPTION Each Surveillance Requirement (SR) has a specified Frequency in which the Surveillance must be met in order to meet the associated LCO. An understanding of the correct application of the specified Frequency is necessary for compliance with the SR.
The "specified Frequency" is referred to throughout this section and each of the Specifications of Section 3.0, Surveillance Requirement (SR) Applicability. The "specified Frequency" consists of the requirements of the Frequency column of each SR as well as certain Notes in the Surveillance column that modify performance requirements.
Situations where a Surveillance could be required (i.e., its Frequency could expire), but where it is not possible or not desired that it be performed until sometime after the associated O
V LC0 is within its Applicability, represent potential SR 3.0.4 conflicts. To avoid these conflicts, the SR (i.e., the Surveillance or the Frequency) is stated such that it is only
" required" when it can be and should be performed. With an SR satisfied, SR 3.0.4 imposes no restriction.
EXAMPLES The following examples illustrate the various ways that Frequencies are specified. In these examples, the Applicability of the LC0 (LCO not shown) is H0 DES 1, 2, and 3.
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Frequency !'
1.4 1.4 Freauency ;
7 EXAMPLES EXAMPLE 1.4 1 '
(continued)
SURVEILLANCE REQUIREMENTS SURVEILLANCE FREQUENCY Perform CHANNEL CHECK. 12 hours1.388889e-4 days <br />0.00333 hours <br />1.984127e-5 weeks <br />4.566e-6 months <br /> Example 1.41 contains the type of SR most often encountered in the Technical Specifications (TS). The Frequency specifies an interval (12 hours1.388889e-4 days <br />0.00333 hours <br />1.984127e-5 weeks <br />4.566e-6 months <br />) during which the associated Surveillance must be performed at least one time. Performance of the Surveillance
- initiates the subsequent interval. Although the Frequency is stated as 12 hours1.388889e-4 days <br />0.00333 hours <br />1.984127e-5 weeks <br />4.566e-6 months <br />. an extension of the time interval to 1.25 times the stated Frequency is allowed by SR 3.0.2 for operational flexibility. The measurement of this interval .
continues at all times, even when the SR is not required to be !
met per SR 3.0.1 (such as when the equipment is inoperable, a variable is outside specified limits, or the unit is outside the -
Applicability of the LCO). If the interval specified by SR 3.0.2 :
is exceeded while the unit is in a H00E or other specified condition in the Applicability of the LCO. and the performance of the Surveillance is not otherwise modified (refer to Example 1.4 3), then SR 3.0.3 becomes applicable.
If the interval as specified by SR 3.0.2 is exceeded while the unit is not in a H0DE or other specified condition in the Applicability of the LC0 for which performance of the SR is required, the Surveillance must be performed within the Frequency requirements of SR 3.0.2 prior to entry into the MODE or other specified condition. FaiDre to do so would result in a violation of SR 3.0.4.
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Frequency 1.4 1.4 Freauency [
EXAMPLES EXAMPLE 1.4 2 (continued)
SURVEILLANCE REQUIREMENTS SURVEILLANCE FREQUENCY Verify flow is within limits. Once within 12 hours1.388889e-4 days <br />0.00333 hours <br />1.984127e-5 weeks <br />4.566e-6 months <br /> after 2 25% RTP AND 24 hours2.777778e-4 days <br />0.00667 hours <br />3.968254e-5 weeks <br />9.132e-6 months <br /> thereafter i
Example 1.4 2 has two Frequencies. The first is a one time performance Frequency, and the second is of the type shown in Example 1.41. The logical connector "AND" indicates that both Frequency requirements must be met. Each time reactor power is increased from a power level < 25% RTP to a 25% RTP. the Surveillance must be performed within 12 hours1.388889e-4 days <br />0.00333 hours <br />1.984127e-5 weeks <br />4.566e-6 months <br />.
' The use of "once" indicates a single performance will satisfy the specified Frequency (assuming no other Frequencies are connected l by "AND"). This type of Frequency does not qualify for the 25% !
extension allowed by SR 3.0.2. "Thereafter" indicates future performances must be established per SR 3.0.2. but only after a 1
specified condition is first met (i.e., the "once" performance in this example). If reactor power decreases to < 25% RTP. the measurement of both intervals stops. New intervals start upon reactor power reaching 25% RTP.
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Frequency 1.4 1.4 Frecuency i
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EXAMPLES (continued)
EXAMPLE 1.4 3 j
SURVEILLANCE REQUIREMENTS l
SURVEILLANCE FREQUENCY
..................N0TE..................
Not required to be performed until 12 hours1.388889e-4 days <br />0.00333 hours <br />1.984127e-5 weeks <br />4.566e-6 months <br /> after 2 25% RTP.
Perform channel adjustment. 7 days The interval continues, whether or not the unit operation is
< 25% RTP between performances.
As the Note modifies the required perfomance of the Surveillance, it is construed to be part of the "specified Frequency." Should the 7 day interval be exceeded while operation is < 25% RTP, this Note allows 12 hours1.388889e-4 days <br />0.00333 hours <br />1.984127e-5 weeks <br />4.566e-6 months <br /> after power reaches a 25% RTP to perform the Surveillance. The Surveillance o is still considered to be performed within the "specified Frequency." Therefore, if the Surveillance were not performed
('~) within the 7 day (plus the extension allowed by SR 3.0.2) interval, but operation was < 25% RTP, it would not constitute a failure of the SR or failure to meet the LCO. Also, no violation of SR 3.0.4 occurs when changing MODES, even with the 7 day Frequency not met, provided operation does not exceed 12 hours1.388889e-4 days <br />0.00333 hours <br />1.984127e-5 weeks <br />4.566e-6 months <br /> with power 2 25% RTP.
Once the unit reaches 25% RTP,12 hours1.388889e-4 days <br />0.00333 hours <br />1.984127e-5 weeks <br />4.566e-6 months <br /> would be allowed for completing the Surveillance. If the Surveillance were not performed within this 12 hour1.388889e-4 days <br />0.00333 hours <br />1.984127e-5 weeks <br />4.566e-6 months <br /> interval, there would then be a failure to perform a Surveillance within the specified Frequency, and the provisions of SR 3.0.3 would apply.
Y CPSESMarA-up ofNUREG.1431ITS-1.0 1.4-4 S/15/97
Frequ:ncy 1.4' lis Frequency
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EXAff%S EXMFLE'1.4 4 3contiped! '
SURVEILLANCE REQUIRENENTS.
MEFTESLRVEILLANCE <_TFREQUENCO iPTEE9?HEEMNOTEgyF;-if-39.:..i .3 '1.1-3J Onlyfequired.toibe performed in MODEi1.
E s i l d ? f i3 & i s 9 k R i Li W R 2 h.*i P % 5 Rerform complete l cycle off the valve.: 7 days l TheTinterva17 continues;;whether:orlnot the unit operation 11siin !
' MODE 1;V2,~ ori3f(the assumed Applicability oflthe associated LCO), l l
between, performances; Aslthe' Note,nodifi_esitheffequired performance of. the Surve111anceEthe Note;istconstrued;to be part.ofcthe'"specified Ffeguency."3Should:the 7; day interyalibel exceeded while )'
operationiis;not"in MODEL17 this:noteiallowslentrylinto and operation.in' MODES.2"and;3;to perform the:Surve111ancecThe Surveillance;isistill?consideredto1belperformedwithin{the "specified Frequency";1f" completed. prior;to; entering .MODEllT3
! Therefore, iff theiSurve111ance were not' performed within1the17 day ;(plus;thelexte.nsion : allowed :by1SR,3.0.2Einterval ,t but eperation:was^nothin M00E11Eittwould!notl constitute alfa 11ur_e'of l
L the SR;or.ifailure .tol meet l;the LCOtyAlso,e no violationfof_SR 3.0.4. occurs;whenl changing,M00ESg even with:.the17.-day frequency normetEprovidedl. operation doesinotiresultnin entry;into MODEll]
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l Once; theluni t! reachesiM00E31,qthelrequi rement ; forithe Surveillanceito'be petformed withtWts:specified Frequency 3
applies'landwouldErequirethat~the;Surveillancehave;been performed.nIf;the:Sutve111ance;wereLnot. performed prior;to MODE 1*,%there;would then be alfa 11ureito perform a. Surveillance _within the specified Frequency,;;andlthel provisions;of;SR'3.0.3,.would apply 1(as well as having hadf al violation of_SR 3.0.4);. i I
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E_X M LES EXAMPLE 1:4 5 y'g Mcotitjpued),
SURVEILLANCE REQUIREMENTS m._ . .
SURVEILLANCE FREQUENCY ,
VerifyTeachicontainment isolation manual Prior to '
valve.is closed; entering MODE 4 from H0DE 5 if t not performe.d within.the '
previous _92 days.
In Example 1.4 5,.the'"specified Frequency";is measured fromfwhen the Surveillance _was last performed.MShould the, interval be exceeded, the. Surveillance.is not required:to be performed until, certain conditions,are' met, The. Surveillance is allowed to.be delayed until priorito: entering H0DE14;from. MODE 5:if the 92 day .
(specified frequency"ihas expired.j. Thel 92 day interval may be extended to l.25 times lthe: stated intervai as allowed by SRi 3.0.2 .
g for operational l flexibility. . Therefore,"if the Surveillance were not parformed'within the 92 day ~(plus the. extension allowed by,SR i 3.0.2) interval, butLoperation was not .transitioning from H00E 5 to1H00E 4,-it would.not constitute a failure of. the SRlor:a i failurefto meet the LC0J The.next time the' unit proceeds..from N0DE;5;to H0DEJ,' the;. surveillance wouldlbeirequired to be Performed prior to thel transition.
i The measurement of.this interval' continues' at all times, even when the SR is not . required to.be met per.SR 3.0.1;(such as;when the: equipment is inoperable,'a; variable.is outside, specified limits, or. the unit is'outside,the ' Applicability of the LC0}LlIf '
the conditions in;the Frequency are. met;and the . interval specified by SR'3.0.2l1s exceeded without .the Surveillance:having been performed and the performance of the^ surveil. lance is not otherwise modified .(re.fer to. . Example 1.4 3),1then SR 3.0.3 becomes' applicable;
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Methodology For Mark-up of NUREG-1431 Specifications Enclosure 5A contains an electronic (or hand written) mark-up of NUREG 1431 Revision :
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- 1. The purpose of the mark up is to identify those changes necessary to create a '
plant specific improved TS (by incorporating plant specific values in bracketed areas) and to identify any other changes with a cross reference to a justification or explanation for the change. Descriptions / justifications for changes are contained in Enclosure 6A. f There are four types of changes:
- 1. Deletions - Material which is removed from NUREG 1431, Rev.1. I
. 2. Additions This includes material which is added to NUREG 1431, i I
Rev. 1.
- 3. Modifications This includes material which exist in NUREG 1431, !
Rev. 1 but is being revised for the improved TS. ;
- 4. Bracket Inserts These changes involve the insertion of plant specific information which is presently located in the current TS into a l bracketed portion of NUREG 1431. Rev.1. ,
The methodology of identifying the changes is :
Deletions - The portion of the specification which is being deleted in non-O bracketed areas of NUREG 1431. Rev.1 is annotated using the
strike out feature of Wordperfect (or crossed out by hand). The '
deletions are identified by a change numbe or a change code in the adjacent right margin.
Additions - The information being added to the non bracketed portions of NUREG 1431, Rev.1 is inserted into the specification in the appropriate location and is annotated using the red line feature of Wordperfect (or hand written / insert pages). The addition is identified by a change number or a change code in the adjacent ,
right margin.
Modifications - The information being revised in the non bracketed portions of ,
NUREG 1431. Rev.1 is annotated using the strike out feature of Wordperfect (or crossed out by hand) and the revised information is inserted into the specification in the appropriate location and is annotated using the red line feature of Wordperfect (or ;
hand written / insert pages). The modification is identified by a ,
change number or a change code in the adjacent right margin. A i change code of "PS" indicates an obvious plant specific change i and is usually reserved for plant specific names of systems and components.
]
n Editorial Changes Changes / corrections which are obviously editorial are annotated Q using the redline / strike out feature of Wordperfect and ;
Mnhadology 1 of2 5/15/97 l I
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Methodology For Mark up of NUREG-1431 Specifications ,
(continued) identified by a change code of "Ed" in the adjacent margin. All i such changes will be submitted for incorporation into the generic .
traveler for editorial changes.
- Bracket Inserts - The plant specific information is entered into the bracketed area. If " generic" information had been provided in the ;
bracketed area and that information is not correct for this i plant, the " generic" information is " struck out" and the correct l informatin inserted using the " redline" feature. The brackets '
provided in NUREG 1431, Rev.1 are deleted. " Red line", " strike-
- out" and margin codes are as follows
- 1. If the bracketed wording or parameter values remain unchanged, the bracketed information is " red lined" and 'B' (for bracketed information) is used as the margin code.
- 2. If the bracketed wording or parameter values are changed to the plant specific wording / values in the current specifications. the old bracketed information is " struck out", the new information is
" red lined" and 'B PS' (for plant specific bracketed information) ,
is used as a margin code.
- 3. If the entire Condition, Action, or Surveillance is bracketed and ,
is aoolicable, the letter / number designator for the item is !
redlined. The text included within the brackets is DQ.t redlined unless plant specific changes are made. The 'B' or 'B PS' margin code is used depending on whether plant specific changes were made.
If the entirely bracketed Condition / Action / Surveillance is not ,
applicable, the entire contents are struck out, redlined words "Not Used" are inserted, and a 'B PS' margin code is used. .
Changes which have margin identifiers of letters instead of numbers (i.e., B, B PS, Ed or PS) do not have descriptions / justifications in enclosure 6A.
Note: All brackets are removed as part of the mark up process. Reviewer notes may be " struck out" or deleted as preferred.
In summary, in the non-bracketed portions of NUREG 1431, Rev.1, " red line" is used to annotate new material, " strike out" is used to annotate deleted material, and ;
change numbers or change codes are used in the right margin to identify these changes. All changes (i.e., " red line" or " strike out" items) have a change number or a change code.
Note. NUREG 1431. Rev.1 is used for all markups. Industry Travelers which are
/O incorporated are indicated using the " redlines", " strike outs" and margin codes l O discussed above.-
Methodology 2 of2 5/158 7
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1 ENCLOSURE 5B MARK-UP OF NUREG-1431 BASES ,
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6 DIFFERENCES FROM NUREG-1431 l
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Descriptions of NUREG-1431 Differences (3 Pages) {-
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JUSTIFICATIONS FOR DIFFERENCES FROM NUREG 1431 Section 1.0 This enclosure contains a brief discussion / justification for each marked up technical change to NUREG 1431, Revision 1, to make them plant-specific or to incorporate ,
generic changes resulting from the Industry /NRC generic change process. The change numbers are referenced directly from the NUREG 1431 mark ups. For enclosures 3A, 3B, l 4, 6A and 68, text in brackets "[ ]" indicates the information is plant specific and is not common to all the Joint Licensing Subcommittee (JLS) plants. Empty brackets :
I indicate that other JLS plants may have plant specific information in that location.
i CHANGE NUMBER JUSTIFICATION 1.1 1 The NUREG 1431 Rev. I definition of Channel Calibration states, "The CHANNEL CALIBRATION shall encompass the entire channel, including the required sensor, alarm, interlock, display, and trip functions." This change clarifies what encompasses the entire channel by rewording the definition to state, "The CHANNEL CALIBRATION shall encompass those components, such as sensors, alarms, displays, and trip functions, required to perform the specified safety function (s)." The Channel r Operational Test and Trip Actuating Device Operational Test definitions are similarly revised. This change is consistent with TSTF 64.
1.12 Not used.
1.1 3 Adds new example to ITS 1.4 to clarify meaning of SR notes of the type "Only required to be performed in H00E..." This change is consistent with traveler WOG 74, Rev 1.
1.14 Not used. ,
1.15 The definitions for ESF Response Time and RTS Response Time would be revised to substitute the word " verified" in lieu of " measured" ;
consistent with the requirements of NUREG 1431 SR 3.3.1.16 and SR 3.3.2.10. This change would ensure consistency between the definitions for Response Time and the requirements to periodically verify Response Time is within limits. This change is consistent with TSTF-111, ,
i Rev 1.
1.1 6 The definition of the Pressure and Temperature Limits Report would be revised to include the maximum allowable PORV lift settings and arming temperature associated with the [ Low Temperature Overpressurization Protection (LTOP)] System, and to be consistent with the COLR definition. Improved Technical Specification 3.4.12 states that the PORV lift settings are specified in the PTLR. The current definition for PTLR does not identify these lift settings as being contained in ;
the PTLR.
b The [LTOP] arming temperature was added to the PTLR, since changes in w the heatup/cooldown figures could change the arming temperature. '
This change corrects the PTLR definition to be consistent with all of
- CPSES IWferencesfrom NUREG-1431 -ITS 1.0 i S/1S/97
CHANGE h NUtBER ' JUSTIFICATION
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the requirements contained in the PTLR. Referenced methodologies for the PTLR would contain the methodology used to develop the heatup and ,
,- cooldown figures, as well as the methodology for developing the [LTOP] i setpoints. This change is consistent with Traveler WOG 67. Rev 1.
1.1 7 Not applicable to CPSES. See Conversion Comparison Table (enclosure 68).
1.1 8 The reactor vessel head closure bolt requirements for H0 DES 4, 5 and 6 are clarified. The proposed change revises footnote b for H0 DES 4 and 5 to refer to " Required reactor vessel head closure bolts fully tensioned" and note c for HODE 6 is revised to read " Required reactor !
vessel head closure bolts less than fully tensioned." The transition '
point between H0 DES 5 and 6 would also be clarified as occurring when the required reactor vessel head closure bolts are less than fully ,
tensioned. The required number of closure bolts, which may be less ;
than the total number, is established by analysis that demonstrates adequate 0 ring compression to prevent leakage ana ensures that ASME Section III stress limits for affected components are not exceeded.
This change is consistent with TSTF 88. ,
1.1 9 Consistent with TSTF 39 Rev.1., the definitions of Channel Operational r Test (C0T), [ ] and Trip Actuating Device Operational Test (TAD 0T) are Os expanded to include the details of acceptable performance methodology.
Performance of these tests in a series of sequential, overlapping, or ,
total channel steps provides the necessary assurance of appropriate operation of the entire channel. This change also makes the COT and TAD 0T definitions consistent with the definition of channel calibration which already contains similar wording. ;
1,1 10 Not applicable to CPSES. See conversion comparison table (enclosure 68).
1.1 11 Adds new example to ITS Section 1.4 to clarify surveillance frequencies that are contingent on both a specified frequency and plant conditions. .
The ITS contains many Surveillance Frequencies that are contingent on both a *specified Frequency" and plant conditions. For example, "Within 7 days prior to the initiation of Physics Tests," and " Prior to entering H0DE 4 from H0DE 5 if not performed within the previous 92 days." These Frequencies do not fall clearly under any of the existing Section 1.4 cxamples. The proposed example is needed to make clear that 1) the SR 3.0.2 extension of 1.25 times the specified frequency .
applies to the specified Frequency, and 2) that the interval allowed to l perform a missed Surveillance by SR 3.0.3 applies.
- - SR 3.0.2 is clear that the 1.25 extension may be applied to "the interval specified in the Frequency", so the proposed change does not >
change the intent of the Specifications. SR 3.0.2 applies if a CPSES Differencesfrom NUREG-H31 - ITS 1.0 2 S/lS/97 ;
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CHANGE
. NIABER JUSTIFICATION b Surveillance is not performed within the "specified Frequency". Again, the example does not change the intent of the Specifications but only
! makes clear the application of SR 3.0.2 and 3.0.3 to_ Surve111ances with frequencies tied to plant conditions. This change will eliminate confusion and misapplication of the ITS and will ensure consistent application of SR 3.0.2 and 3.0.3 to these types of Surveillance !
Frequencies. This change is consistent with traveler WOG 90.
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- ENCLOSURE 6B ,
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CONVERSION COMPARISON TABLE - NUREG-1431 ;
Conversion Comparison Table (2 Pages) 3 l
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CONVERSION COMPARISON TABLE FOR DIFFERENCES FROM NUREG-1431 - SECTION Page 1 of 1.0 2' .
DIFFERENCE FROM NUREG-1431 APPLICABILITY' NUPBER DESCRIPTION
{ DIABLO CANYON COMANCHE PEAK WOLF CREEK CALLAWAY -
1.1 1 This change would clarify what encogasses the Yes Yes Yes Yes entire channel by rewording the definition to state.
"The CHANesEL CALIBRATION shall enco g ass those c9gonents. such as sensors, alarms, displays and trip functions, required to perform the specified safety function (s)". The COT and TADOT definitions are similarly revised. _
1.1-2 Not used NA NA NA NA 1.1-3 Adds new example to ITS 1.4 to clarify meaning of SR Yes Yes Yes Yes notes of the type "Only required to be perf ro med in M00E..".
1.1-4 Not used N/A N/A N/A N/A 1.1 5 The definitions for ESF Response Time and RTS Yes Yes Yes Yes Response Time would be revised to substitue the word
" verified
1.1-6 The definition of the Pressure and Temperature Yes Yes Yes Yes Limits Report would be revised to include the maximum allowable PORV lift settings and the arming temperature associated with the system. and to be consistent with the COLR definition.
1.1-7 The definition of Channel Functional Test in the Yes No - Not part No - Not part No - Not part current TS will be retained in the i groved TS. This of current TS. of current TS. of current de'inition is not in NUREG-1431 Rev 1. TS.
CPSES Conversion Comparison Table - ITS1.0 5/15/97
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i,) , d-CONVERSION COMPARISON TAELE FOR NUREG-1431 DIFFERENCES SECTION IPage 2 of 2 '
IOSER DESCRIPTION DiABLO CANYON COMANCH PEAK WOLF CREEK CALLAWAY
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1.1-8 Note b is revised to refer to the ~ Required reactor Yes Yes Yes vessel head closure bolts fully tensioned" and note Yes-c is revised to read
- Required reactor vessel head closure bolts less than fully tensioned."
1.19- The definitions of Channel Operational Test (CDT). Yes
[ ] and Trip Actuating Device Operational Test Yes ies Yes
~ (tai,0T) are expanded to include the details of acceptable performance methodology. Performance of these tests in a series of sequential, overlapping, or total channel steps provides the necessary assurance of appropriate operation of the entire channel.
1.1-10 This change is based on the current TS definition of No - Not part No - Not part No - Yes CONTROLLED LEAKAGE. This change is a clarification of CTS. of CTS. Maintaining only and does not affect the way RCS water inventory ISTS wording.
balances are performed.
1.1-11 Adds new example to ITS Section 1.4 to clarify Yes Yes Yes Yes surveillance frequencies that are contingent on both specified frequency and plant conditions.
CPSES Conversion Comparison Table - ITS1.0 SM5197
__ . _ - _ _ . _ . . - . _ - _ . _ _ . . . - . __ ._ _ _ . _ . _ _ _ . . - .__ _ . . _ . _ _ . _ - .._ _ _______ -