ML20141A168
| ML20141A168 | |
| Person / Time | |
|---|---|
| Site: | Grand Gulf  |
| Issue date: | 05/07/1997 |
| From: | ENTERGY OPERATIONS, INC. |
| To: | |
| Shared Package | |
| ML20141A162 | List: |
| References | |
| NUDOCS 9705140173 | |
| Download: ML20141A168 (16) | |
Text
. , _ . . ._. - . _ , - . . - .._.
, eT
- Attachmtnt 3 to GNRO-97/00037 3
i a
ATTACHMENT 3 Mark-ups of Affected i Technical Specifications Pages Grand Gulf Nuclear Station i
l l
4 I
i 4
4 1
A I
i 9705140173 970507 PDR ADOCK 05000416 P PDR
~
\
- 'A RPS Instrumentation 3.3.1.1 l SURVEILLANCE REQUIREMENTS (continued)
, SURVEILLANCE FREQUENCY
' SR 3.3.1.1.11 Perform CHANNEL FUNCTIONAL TEST. 18 months
- I
- SR 3.3.1.1.12 ------------------NOTES------------------
- 1. Neutron detectors are excluded.
4
- 2. For IRMs, not required to be performed when entering MODE 2 from 1 MODE 1 untti 12 hours1.388889e-4 days <br />0.00333 hours <br />1.984127e-5 weeks <br />4.566e-6 months <br /> after entering
- j. MODE 2.
i Perform CHANNEL CALIBRATION. 18 months 1-i SR 3.3.1.1.13 Perform LOGIC SYSTEM FUNCTIONAL TEST. 18 months 1
3 SR 3.3.1.1.14 Verify Turbine Stop Valve Closure, Trip 18 months Oil Pressure-Low and Turbine Control Valve Fast Closure Trip 011 Pressure-Low i Functions are not bypassed when THERMAL POWER is a: 405 RTP.
i SR 3.3.1.1.15 -----.------------NOTES------------------
i 1. Neutron detectors are excluded, t
For Function 6, "n" equals 4 channels i
3 for the purpose of determining the j , STAGGERED TEST BASIS Frequency.
j Verify the RPS RESPONSE TIME is within 18 months on a i
limits. STAGGERED TEST BASIS 1
d W .w w ---m,- __ _ _ _ _ _
~
- a. Fos. Fwxficas 1,54, epd F !a Ta bie 3.3 l. )--l3 Yhe chame) se end.s, eeK be, exclyd4 l l GRAND GULF 3.3 5 Amendment No. 120 I
4 i
. . . . -- ~- ~ ~_ . - -. . .- . . . - - . . - -. . - - ..
< . . .\ ,
Primary Containment and Drywell Isolation Instrumentation 3.3.6.1 i
SURVEILLANCE REQUIREMENTS
.....................................N0TES------------------------------------
- 1. Refer to Table 3.3.6.1-1 to determine which SRs apply for each Function.
. 2. When a channel is placed in an inoperable status solely for performance of required Surveillances, entry into associated Conditions and Required Actions may be delayed for up to 6 hours6.944444e-5 days <br />0.00167 hours <br />9.920635e-6 weeks <br />2.283e-6 months <br />, provided the associated Function
- maintains isolation capability.
l SURVEILLANCE FREQUENCY SR 3.3.6.1.1 Perform CHANNEL CHECK. 12 hours1.388889e-4 days <br />0.00333 hours <br />1.984127e-5 weeks <br />4.566e-6 months <br /> i
I SR 3.3.6.1.2 Perform CHANNEL FUNCTIONAL TEST. 92 days 4
4 i SR 3.3.6.1.3 Calibrate the trip unit. 92 days i
)
SR 3.3.6.1.4 Perform CHANNEL CALIBRATION. 92 days t
SR 3.3.6.1.5 Perform CHANNEL CALIBRATION. 12 months 4
f SR 3.3.6.1.6 Perform CHANNEL CALIBRATION. 18 months SR 3.3.6.1.7 Perform LOGIC SYSTEM FUNCTIONAL TEST. 18 months SR 3.3.6.1.8 Verify the ISOLATION SYSTEM RESPONSE TIME 18 months on a for the Main Steam Isolation Valves is STAGGERED TEST within limits. BASIS j l if Y d $ I c.h 4 geofo me GRAND GULF CX cN dcd , .3-53 Amendment No. 120 1
j .
. .s
} . .
- y a - ECCS-Operating <
3.5.1 l i e e i
SURVEILLANCE REQUIREMENTS (continued) 4 SURVE!LLANCE FREQUENCY SR 3.5.1.5 -------------------NOTE--------------------
{ Vessel injection / spray may be excluded.
i 4
Verify each ECCS injection / spray subsystem 18 months j
actuates on an actual or simulated autcaatic initiation signal.
i i
--..--..-----.-----NOTE-------------------- !
! Valve act:ation may be excluded.
i Verify the ADS actuates on an actual or 18 months i
- simulated automatic initiation signal.
- t I
! 1 q
i
+
SR 3.5.1.7 -------------------NOTE--------------------
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 reactor steam pressure and flow are adequate to perform the test.
Verify each ADS valve opens when manually 18 months on a actuated. STAGGERED TEST BASIS for each !
i 3 valve solenoid 1
4 i
l; SR 3.5.1.8 Tferify the ECCS RESPONSE TINE for the HPCS 18 months' System is within limits. ; i I
4 I ~
k k h t f i
/ .
- ~ . . . .
.Q,., , .. --- - **
f E CCG AC N Q ig #.y W M V I5 MC
- j GRAND GULF 3,$.5 Amendment No. 120 i
1 1
i 1
v.. - -
, . .i
.i ECCS--Shutdown
. 3.5.2 1
4 SURVEILLANCE REQUIREMENTS- (continued) 1 SURVEILLANCE FREQUENCY SR 3.5.2.5 Verify each required ECCS pump develops the In accordance I specified flow rate with the specified with the
- total developed head. Inservice Testing Program
' TOTAL SYSTEM FLOW RATE DEVELOPED HEAD.
d
- LPCS' a: 7115 gpm , at 290 psid LPCI a 7450 gpm at125 psid HPCS at7115 gpm at 445 psid
}
, SR 3.5.2.6 -------------------NOTE--------------------
i Vessel injection / spray may be excluded.
Verify each required ECCS injection / spray 18 months subsystem actuates on an actual or i simulated automatic initiation signal.
i SR 3.5.2.7 Ver S RESPONSE TIME for the 18 months requiredHPCSSiit s within limits.
I
~
~% -% ,. ~ - A.
i i
)
GRAND GULF 3.5-9 Amendment No. 120 1
- . . . ~ _ _ _ - - . . . . . . . ~ . - . . . . ~ . . . - . - ~ . . - . . - . _ - - . - . . . - . . = - . . _ . . . --
i
. ,% l
- ' Attachmsnt 413 GNRO-97/00037 l l 1
i 1
i I
! l' i
i i 1 i l l
ATTACHMENT 4 4
2 Mark-ups of Affected Technical Specifications Bases Pages Grand Gulf Nuclear Station l
.J
- ,r a j . . .
o RPS Instrumentation 4
B 3.3.1.1 l BASES i
i SURVEILLANCE SR 3.3.1.1.15 -
4- REQUIREMENTS
, (continued) This SR ensures that the individual channel response times are less than or equal to the maximum values assumed in the i accident analysis. The RPS RESPONSE TIME acceptance l criteria are included in the applicable plant procedures.
! As noted, neutron detectors are excluded from RPS RESPONSE i
TIME testing because the principles of detector operation virtually ensure an instantaneous response time. ,
, RPS RESPONSE TIME tests are onducted on an 18 month g'gg l STAGGERED TEST BASIS. Note equires STAGGERED TEST BASIS Frequency to be determined based on 4 channels per trip i system, in lieu of the 8 channels specified in Table 1 .
3.3.1.1-1 for the MSIV Closure Function. This Frequency is i
based on the logic interrelationships of the various channels required to produce an RPS scram signal.
Therefore, staggered testing results in response time 1 .>erification of these devices every 18 months. This
! Frequency is consistent with the typical industry refueling cycle and is based upon plant operating experience, which
- shows that random failures of instrumentation components
- causing serious time degradation, but not channel failure, j are infrequent.
I j REFERENCES 1. UFSAR, Figure 7.2-1.
i 2. UFSAR, Section 5.2.2.
- 3. UFSAR, Section 6.3.3.
- 4. UFSAR, Chapter 15.
- 5. UFSAR, Section 15.4.1.
- 6. NEDO-23842, " Continuous Control Rod Withdrawal in the
. Startup Range," April 18, 1978.
- 7. UFSAR, Section 15.4.9.
(continued)
GRAND GULF B 3.3-29 Revision No. 0
+
Enclosure 1 for TS Bases 3.3.1.1.15 a.
Note 2 allows the channel sensors of Functions 3,4, and 5 to be excluded from specific RPS RESPONSE TIME testing. This allowance to not perform specific response time testing of the sensors is applicable when the alternate testing requirements and restriedons of Reference 10 are performed. As stated in Reference 10, analysis has demonstrated that other Technical Specification testing requirements (CHANNEL CALIBRATIONS, CIIANNEL CHECKS, CIIANNEL FUNCTIONAL TESTS, and LOGIC SYSTEM FUNCTIONAL TESTS) and actions taken in response to NRC Bulletin 90-01 Supplement 1 are sufficient to identify failure modes or degradation in instrument response times and assure operation of the analyzed instrument loops within acceptable limits. Reference 10 also identifies that there are no known channel sensor failure modes identified that can be detected by response time testing that cannot also be detected by other Technical Specification required surveillances. Therefore, when the requirements, including sensor types, of Reference 10 are complied with, adequate assurance of the response time of the sensors is provided. This assurance of the response time of the sensors when combined with the response time testing of the remainder of the channel ensures that the individual channel response times are less than or equal to the maximum values assumed in the accident analysis. If the alternate testing requirements of Reference 10 are not complied with, then the entire chennel will be response time tested including the sensors.
l t
\
RPS Instrumentation
, B 3.3.1.1
- 8ASES 4
!4 REFERENCES 8. Letter, P. Check (NRC) to G. Lainas (NRC), "8WR Scram i (continued) Discharge System Safety Evaluation," December 1, 1980, a
as attached to NRC Generic Letter dated Dece.aber 9 I 1980.
- 9. NED0-30851-P A, " Technical Specification Improvement
- Analyses for SWR Reactor Protection System,"
Narch 1988.
i L l -
_ =
- 10 tl E 90- 322' l- A) " SVh h 44 KS MS. El'M M i 0 l.
Seketd g.esoo cse Time Q e i
l Tcs.+;d3 Rtc;uitemedts;t l Och oW l'W i
1 C
l i
i i
4 i
i GRAND GULF 8 3.3-30 Revision No. 0 I
e
}
A
- 1 \
Primary Containment and Drywell Isolation Instrumentation
, B 3.3.6.1 BASES SURVEILLANCE SR 3.3.6.1.7 REQUIREMENTS (continued) The LOGIC SYSTEM FUNCTIONAL TEST demonstrates the OPERABILITY of the required isolation logic for a specific
- channel. The system functional testing performed on isolation valves in LCO 3.6.1.3 and LCO 3.6.5.3 overlaps this Surveillance to provide complete testing of the assumed safety function. The 18 month Frequency is based on the need to perform this Surveillance under the conditions that apply during a plant outage and the potential for an i unplanned transient if the Surveillance were performed with the reactor at power.
Operating experience has shown these components usually pass 4
the Surveillance when performed at the 18 month Frequency.
i b)% SR 3.3.6.1.8
! This SR ensures that the individual channel response times
'/ are less than or equal to the maximum values assumed in the accident analysis. Testing is performed only on channels plc OSM g where the assumed response time does not correspond to the diesel generator (DG) start time. For channels assumed to i
[ respond within the DG start time, sufficient margin exists
- <i I in the 10 second start time when compared to the typicalj ,
channel response time (milliseconds) so as to assure adequate response without a specific measurement test. ;
l Testing of the closure times of the MSIVs is not included in '
this Surveillance since the closure time of the MSIVs is k tested by SR 3.6.1.3.6. ISOLATION SYSTEM RESPONSE TIME 1 acceptance criteria for this instrumentation is included in l' ) the applicable plant procedures.
y f% ISOLATION SYSTEM RESPONSE TIME tests for this i
instrumentation are conducted on an 18 month STAGGERED TEST y BASIS. This test Frequency is consistent with the typical t !
industry refueling cycle and is based upon plant operating i 1 experience that shows that random failures of instrumentation components causing serious response time degradation, but not channel failure, are infrequent.
REFERENCES 1. UFSAR, Chapter 6.
- 2. UFSAR, Chapter 15.
(continued)
GRAND GULF B 3.3-170 Revision No. 0
rk
.. Enclosure 2 for TS Bases SR 3.3.6.1.8 As Noted, the channel sensor may be excluded from response time testing. This allowance to not perform specific response time testing of the sensors is applicable when the alternate testing requirements and restrictions of Reference 7 are performed. As stated in Reference 7, analysis has demonstrated that other Technical Specification testing requirements (CHANNEL CALIBRATIONS, CHANNEL CHECKS, CHANNEL FUNCTIONAL TESTS, and LOGIC SYSTEM FUNCTIONAL TESTS) and actions taken in response to NRC Bulletin 90-01 Supplement I are sufficient to identify failure modes or degradation in instrument response times and assure operation of the analyzed instrument loops within acceptable limits. Reference 7 also identifies that there are no known channel sensor failure modes identified that can be detected by response time testing that cannot also be detected by other Technical Specification required surveillances. Therefore, when the requirements, including sensor types, of Reference 7 are complied with, adequate assurance of the response time of the sensors is provided. This assurance of the response time of the sensors when combined with the response time testing of the remainder of the channel ensures that the individual channel response times are less than or equal to the maximum values assumed in the accident analysis. If the alternate testing requirements of Reference 7 are not complied with then the entire channel will be response time tested including the sensors.
I
.+
Pri:ary Containment and Drywell Isolation Instrumentation B 3.3.6.1 BASES i
1 l
REFERENCES 3. NEDO-31466, " Technical Specification Screening i (continued) Criteria Application and Risk Assessment," l November 19B7.
- 4. UFSAR, Section 9.3.5.
- 5. NEDC-31677-P-A, " Technical Specification Improvement Analysis for BWR Isolation Actuation Instrumentation,"
June 1989.
- 6. NEDC-30851-P-A, Supplement 2, " Technical Specifications Improvement Analysis for BWR Isolation Instrumentation Common to RPS and ECCS Instrumentation," March 1989.
=,
~
- 7. NEDO-32291-A, " System Analyses for Elimination of Selected Response Time Testing Requirements," October 1995
/
lI l
9 I'
GRAND GULF B 3.3-171 Revision No. O
i j ,.+
- 3 ECCS-Operating l , ,
B 3.5.1 l
i BASES i
l SURVEILLANCE SR 3.5.1.7 (continued)
- REQUIREMENTS alternately tested. The Frequency of the required l relief-mode actuator testing was developed based on the tests required by the ASME Boiler and Pressure Vessel Code, l Section XI as implemented by the Inservice Testing Program i of Specification 5.5.6. The testing Frequency required by i the Inservice Testing Program is based on operating '
experience and valve performance. Therefore, the Frequency was concluded to be acceptable from a reliability i~ standpoint. -
l SR 3.5.1.8 1
1 This SR ensures that the HPCS System response time is less )
i than or equal to the maximus value assumed in the accident
! analysis. Specific testing of the ECCS actuation j instrumentation inputs into the HPCS System ECCS SYSTEM i
RESPONSE TIME is not required by this SR. Specific response i time testing of this instrumentation is not required sinc P
! these actuation channels are only assumed to respond within i the diesel generator start time; therefore, sufficient l margin exists in the diesel generator 10 second start time j when compared to the typical channel response time .
- (milliseconds) so as to_asjure adequate response without a l specific measurement tesF7 The diesel generator starting j and any sequence loading delays along with the Reactor Vessel Water Level - Low Low, Level 2 confirmation delay j t 5 permissive must be added to the HPCS System equipment l [q kf [. k I, /* L I I
response times to obtain the HPCS System ECCS SYSTEM RESPONSE TIME. The acceptance criterion for the HPCS System j ( ECCS SYSTEM RESPONSE TIME is s 27 seconds.
I.
(continued) i GRAND GULF B 3.5-13a Revision No. 2 t _ _ . _
. . . - ~
=
79 q* ECCS-Operating 8 3.5.1 i
BASES
\ SURVEILLANCE SR 3.5.1.8 l
(continued)
REQUIREMENTS i
i HPCS System ECCS SYSTEM RESPONSE TIME tests are conducted every 18 months. This Frequency is consistent with the i typical industry refueling cycle and is based on industry operating experience, i
)
REFERENCES 1. UFSAR, Section 6.3.2.2.3.
- 2. UFSAR, Section 6.3.2.2.4.
- 3. UFSAR, Section 6.3.2.2.1.
- 4. UFSAR, Section 6.3.2.2.2. -
- 5. UFSAR, Section 15.6.6. 1
. 6. UFSAR, Section 15.6.4.
- 7. UFSAR, Section 15.6.5. m
- 9. UFSAR, Section 6.3.3.
- 10. 10 CFR 50.46.
- 11. UFSAR, Section 6.3.3.3.
- 12. Memorandum from R.L. Baer (NRC) to V. Stello, Jr.
(NRC), " Recommended Interim Revisions to LCO's for ECCS components," December 1,1975.
- 13. UFSAR, Section 6.3.3.7.8.
- 14. UFSAR, Sec' tion 7.3.1.1.1.4.2.
- 15. GNRI-96/00229, Amendment 130 to the Operating License.
l 16.
NEDO-32291-A," System Analyses for Elimination of Selected Response Time Testing Requirements," October 1995
. GRAND GULF B 3.5-14 Revision No. 2 ,
f h) #
e ECCS-Shutdown B 3.5.2 i
[ BASES i SURVEILLANCE SR 3.5.2.4 (continued)
REQUIREMENTS initiation signal is allowed to be in a nonaccident position i provided the valve will automatically reposition in the proper stroke time. This SR does not require any testing or
- valve manipulation; rather, it involves verification that those valves capable of potentially being mispositioned are l in the correct position. This SR does not apply to valves j that cannot be inadvertently misaligned, such as check
- valvas. The 31 day Frequency is appropriate because the
+
valves are operated under procedural control and the
! probability of their being mispositioned during this time j period is low. ,
In MODES 4 and 5, the RHR System may operate in the shutdown cooling mode, or be aligned to allow alternate means to remove decay heat and sensible heat from the reactor.
l Therefore, RHR valves that are required for LPCI subsystem 4
P operation may be aligned for decay heat removal. This SR is modified by a Note that allows one LPCI subsystem of the RHR i
System to be considered OPERABLE for the ECCS function if_ ,
all the required valves in the LPCI flow path can be "
manually realigned (remote or local) to allow injection into
! the RPV and the system is not otherwise inoperable. This i will ensure adequate core cooling if an inadvertent vessel j draindown should occur, f
3.5.2.7 I This nsures that the HPCS System response time is less i than or e to the maximum value assumed in the accident i analysis. Sp fic testing of the ECCS actuation I
l RESPONSE TIME is no equired by this SR. Specific response
} time testing of this i unentation is not required since q
! these actuation channels only assumed to respond within i l the diesel generator start t therefore, sufficient J margin exists in the diesel gen or 10 second start time l when compared to the typical channe esponse time j j (milliseconds) so as to assure adequa esponse without a 1 specific measurement test. The diesel ge aator starting l , and any sequence loading delays along with 4 Reactor Vessel Water Level - Low Low, Level 2 confirmat delay permissive must be added to the HPCS System equi i response times to obtain the HPCS System ECCS SYSTEM i I j
^ _ s A j (continued) i i
{ GRAND GULF B 3.5-19 Revision No. 2 1
l 4
s
- . _ - . - - - . _ . - . _ - -. . - . - .-. _ - - . _ . -. ..~- -._- - ..--. -..---.
4
- + .
f,h i
- ECCS-Shutdown
, B 3.5.2 i
BASES f
~ m- m~
i SURVEILLANCE M 2.7 (continued)
REQUIREMENTS f j
RESPONSE TIME. tance criterion for the HPCS System ECCS SYSTEM RESPONSE TI 27 seconds. HPCS System ECCS SYSTEM RESPONSE TIME tests a.. -- ' ted.every 18 months. This Frequency is consiste he typical I /
industry refueling cycle and is based _on indu rating i
experience. _._ _
, q REFERENCES 1. UFSAR, Section 6.3.3.4. ,
l l
h GRAND GULF B 3.5-20 Revision No. 2