NL-15-156, Sequoyah Nuclear Plants, Units 1 and 2 - Technical Specifications Conversion to NUREG-1431, Rev. 4.0 (SQN-TS-11-10) - Supplement 3. Part 2 of 9
Text
3.3.2 Insert Page 3.3.2-6 CTS INSERT 8 R. Required Action and associated Completion Time of Condition I not met. R.1 Be in MODE 3.
AND R.2 Be in MODE 4.
6 hours6.944444e-5 days <br />0.00167 hours <br />9.920635e-6 weeks <br />2.283e-6 months <br /> 12 hours S. One train inoperable. --------------------NOTE------------------- One train may be bypassed for up to 4 hours4.62963e-5 days <br />0.00111 hours <br />6.613757e-6 weeks <br />1.522e-6 months <br /> for surveillance testing
provided the other train is OPERABLE.
S.1 Be in MODE 3.
AND S.2 Be in MODE 5.
12 hours1.388889e-4 days <br />0.00333 hours <br />1.984127e-5 weeks <br />4.566e-6 months <br /> 42 hours M11 ACTION 15 2 ESFAS Instrumentation (Without Setpoint Control Program) 3.3.2 A Westinghouse STS 3.3.2 A-7 Rev. 4.0 SEQUOYAH UNIT 2 Amendment XXXCTS 1 1 2SURVEILLANCE REQUIREMENTS -------------------------------------------------------------NOTE----------------------------------------------------------
Refer to Table 3.3.2-1 to determine which SRs apply for each ESFAS Function.
SURVEILLANCE FREQUENCY
SR 3.3.2.1 Perform CHANNEL CHECK.
[ 12 hours1.388889e-4 days <br />0.00333 hours <br />1.984127e-5 weeks <br />4.566e-6 months <br /> OR In accordance
with the Surveillance Frequency
Control Program
]
SR 3.3.2.2 Perform ACTUATION LOGIC TEST.
[ 92 days o n a STAGGERED TEST BASIS OR In accordance
with the Surveillance Frequency
Control Program
]
SR 3.3.2.3 ------------------------------NOTE-------------------------------
The continuity check may be exclud ed. ---------------------------------------------------------------------
Perform ACTUATION LOGIC TEST.
[ 31 days on a STAGGERED TEST BASIS OR In accordance with the Surveillance Frequency Control Pr ogram ] 4.3.2.1.1 Table 4.3-2 Functional Units 1.c, 1.d, 1.f, 2.c, 3.b.3, 4.c, 4.d, 4.e, 5.a, 6.c.1, 6.c.2, 6.c.3, 6.c.4, and 9.a Table 4.3-2 Functional Units 1.b, 2.b, 3.b.2, 4.b, 5.b, 6.b, and 9.b 5 5 2 ESFAS Instrumentation (Without Setpoint Control Program) 3.3.2 A Westinghouse STS 3.3.2 A-8 Rev. 4.0 SEQUOYAH UNIT 2 Amendment XXXCTS 1 1 2SURVEILLANCE REQUIREMENTS (continued) SURVEILLANCE FREQUENCY
REVIEWER'S NOTE---------------------------------
The Frequency remains at 31 days on a STAGGERED TEST BASIS for plants with a Relay Protection System.
4 Perform MASTER RELAY TEST.
[ 92 days on a STAGGERED TEST BASIS OR In accordance with the Surveillance
Frequency Control Program
] SR 3.3.2.
5 Perform COT.
[ 184 days OR In accordance
with the Surveillance
Frequency
Control Program
] SR 3.3.2.
6 Perform SLAVE RELAY TEST.
[ [92] days OR In accordance
with the Surveillance
Frequency Control Program
] DOC M04 Table 4.3-2 Functional Units 1.c, 1.d, 1.f, 2.c, 3.b.3, 4.c, 4.d, 4.e, 5.a, 6.c.1, 6.c.2, 6.c.3, 6.c.4, and 9.a DOC M04 3 4 5 4 5 5 5 2 2 2 ESFAS Instrumentation (Without Setpoint Control Program) 3.3.2 A Westinghouse STS 3.3.2 A-9 Rev. 4.0 SEQUOYAH UNIT 2 Amendment XXXCTS 1 1 2SURVEILLANCE REQUIREMENTS (continued)
SURVEILLANCE FREQUENCY SR 3.3.2.
7 ------------------------------NOTE-------------------------------
Verification of relay setpoints not required. ---------------------------------------------------------------------
Perform TADOT.
[ [92] days OR In accordance
with the Surveillance Frequency
Control Program
]
8 ------------------------------NOTE-------------------------------
Verification of setpoint not required for manual initiation functions. ---------------------------------------------------------------------
Perform TADOT.
[ [18] months OR In accordance
with the Surveillance
Frequency
Control Program
] Table 4.3-2 Functional Units 1.a, 2.a, 3.a.1, 3.b.1, 4.a, and
6.f Table 4.3-2 Functional Unit 6.e.1 6 7 DOC A18 DOC A18 5 5 2 2 ESFAS Instrumentation (Without Setpoint Control Program) 3.3.2 A Westinghouse STS 3.3.2 A-10 Rev. 4.0 SEQUOYAH UNIT 2 Amendment XXXCTS 1 1 2SURVEILLANCE REQUIREMENTS (continued)
SURVEILLANCE FREQUENCY SR 3.3.2.
9 ------------------------------NOTE-------------------------------
This Surveillance shall include verification that the time constants are adjusted to the prescribed values. ---------------------------------------------------------------------
Perform CHANNEL CALIBRATION.
[ [18] months OR In accordance with the Surveillance
Frequency
Control Program
] SR 3.3.2.
10 ------------------------------NOTE------------------------------- Not required to be performed for the turbine driven AFW pump until
[24] hours after SG pressure is [1000] psig. ---------------------------------------------------------------------
Verify ESFAS RESPONSE TIMES are within limit.
[ [18] months on a STAGGERED TEST BASIS OR In accordance with the Surveillance
Frequency
Control Program
] SR 3.3.2.
11 ------------------------------NOTE------------------------------- Verification of setpoint not required. ---------------------------------------------------------------------
Perform TADOT.
Once per reactor trip breaker cycle 4.3.2.1.3 4.3.2.1.2 Table 4.3-2 Functional Units 1.c, 1.d, 1.f, 2.c, 3.b.3, 4.c, 4.d, 4.e, 5.a,6.c.1, 6.c.2, 6.c.3, 6.c.4, 6.e.1, 6.e.2, 6.g, 6.h, 8.a, and 9.a. Table 4.3-1 Functional Unit 22 DOC A20 DOC A19 8 9 10 DOC A18 842 3 5 5 2 2 2 ESFAS Instrumentation (Without Setpoint Control Program) 3.3.2 A Westinghouse STS 3.3.2 A-11 Rev. 4.0 SEQUOYAH UNIT 2 Amendment XXX 1 2CTS 1Table 3.3.2-1 (page 1 of 11) Engineered Safety Feature Actuation System Instrumentation FUNCTION APPLICABLE MODES OR OTHER SPECIFIED CONDITIONS REQUIRED CHANNELS CONDITIONSSURVEILLANCE REQUIREMENTS ALLOWABLE VALUE [NOMINAL (l) TRIP SETPOINT] 1.Safety Injectiona. Manual Initiation1,2,3,4 2 B SR 3.3.2.
8 NA NA b.AutomaticActuation Logicand ActuationRelays1,2,3,4 2 trains C SR 3.3.2.2
4 SR 3.3.2.
6 NA NA c.Containment Pressure -
High 1 1,2,3 3 D SR 3.3.2.1 SR 3.3.2.
5 (b)(c) SR 3.3.2.
9 (b)(c) SR 3.3.2.
10 [3.86] psig [3.6] psig d.PressurizerPressure - Low 1,2,3 (a) [3] D SR 3.3.2.1
5 (b)(c) SR 3.3.2.
9 (b)(c) SR 3.3.2.
10 [1839] psig [1850] psig e.Steam Line Pressure (1) Low 1,2,3 [(a)] 3 per steam line D SR 3.3.2.1 SR 3.3.2.
5 (b)(c) SR 3.3.2.
9 (b)(c) SR 3.3.2.
10 [635](d) psig [6 75](d) psig (2) High Differential Pressure Between Steam Lines 1,2,3 3 per steam line D [SR 3.3.2.1] SR 3.3.2.5 (b)(c) SR 3.3.2.9 (b)(c) SR 3.3.2.10 [106] psig
[97] psig (a) Above the P-11 (Pressurizer Pressure) interlock. (b) If the as-found channel setpoint is outside its predefined as-found tolerance, then the channel shall be evaluated to verify that it is functioning as required before returning the channel to service. (c) The instrument channel setpoint shall be reset to a value that is within the as-left tolerance around the Nominal Trip Setpoint (NTSP) at the completion of the surveillance; otherwise, the channel shall be declared inoperable. Setpoints more conservative than the NTSP are acceptable provided that the as-found and as-left tolerances apply to the actual setpoint implemented in the Surveillance procedures (field setting) to confirm channel performance. The NTS P and the methodologies used to determine the as-found and as-left tolerances are specified in
[insert the facility FSAR reference or the name of any document incorporated into the facility FSAR by reference]. (d) Time constants used in the lead/lag controller are t 1 [50] seconds and t 2 [5] seconds. -----------------------------------------------------------------------REVIEWER'S NOTE---------------------------------------------------------------------
(l) Unit specific implementations may contain only Allowable Value depending on Setpoint Study methodology used by the unit. ------------------------------------------------------------------------------------------------------------------------------------------------------------------------
- 1.6 1.54 1864.8 1870592.2 600 3.3.2.1, and ACTION 3.3.2.1, and ACTION 1.a 1.b 1.c 1.d 1.f Note # Table 3.3-3 Table 3.3-4 Note 1 7 3 5 9 9 9 4 4 8 8 4 8 4 3 3 3 3 3 2 2 2 2 3 2UFSAR Section 7.1.2 2 ESFAS Instrumentation (Without Setpoint Control Program) 3.3.2 A Westinghouse STS 3.3.2 A-12 Rev. 4.0 SEQUOYAH UNIT 2 Amendment XXX 1 2CTS 1Table 3.3.2-1 (page 2 of 11) Engineered Safety Feature Actuation System Instrumentation FUNCTION APPLICABLE MODES OR OTHER SPECIFIED CONDITIONS REQUIRED CHANNELS CONDITIONSSURVEILLANCE REQUIREMENTS ALLOWABLE VALUE [NOMINAL (l) TRIP SETPOINT] 1.Safety Injection f.High Steam Flowin Two Steam Lines 1,2,3 (e) 2 per steam line D SR 3.3.2.1 SR 3.3.2.5 (b)(c) SR 3.3.2.9 (b)(c) SR 3.3.2.10 (f)(g) Coincident with Tavg - Low Low 1,2,3 (e) 1 per loop D SR 3.3.2.1 SR 3.3.2.5 (b)(c) SR 3.3.2.9 (b)(c) SR 3.3.2.10 [550.6]°F [553]°F g.High Steam Flowin Two Steam Lines 1,2,3 (e) 2 per steam line D SR 3.3.2.1 SR 3.3.2.5 (b)(c) SR 3.3.2.9 (b)(c) SR 3.3.2.10 (f)(g) Coincident with Steam Line Pressure - Low 1,2,3 (e) 1 per steam line D SR 3.3.2.1 SR 3.3.2.5 (b)(c) SR 3.3.2.9 (b)(c) SR 3.3.2.10 [635](d) psig [675] psig 2.Containment Spraya.Manual Initiation1,2,3,4 2 per train, 2 trains B SR 3.3.2.
8 NA NA (b) If the as-found channel setpoint is outside its predefined a s-found tolerance, then the channel shall be evaluated to verify that it is functioning as required before returning the channel to service.
(c) The instrument channel setpoint shall be reset to a value that is within the as
-left tolerance around the Nominal Trip Setpoint (NTSP) at the completion of the surveillance; otherwise, the channel shall be declared inoperable. Setpoints more conservative than the NTSP are acceptable provided that the as
-found and as
-left tolerances apply to the actual setpoint implemented in the Surveillance procedures (field setting) to confirm channel performance. The NTS P and the methodologies used to determine the as
-found and as
-left tolerances are specified in [insert the facility FSAR reference or the name of any document incorporated into the facility FSAR by reference
]. (d) Time constants used in the lead/lag controller are t 1 [50] seconds and t 2 [5] seconds. (e) Above the P
-12 (Tavg - Low Low) interlock.
(f) Less than or equal to a function defined as P corresponding to [44]% full steam flow below [20]% load, and P increasing linearly from [44]% full steam flow at [20]%
load to [114]% full steam flow at [100]% load, and P corresponding to [114]% full steam flow above 100% load.
(g) Less than or equal to a function defined as P corresponding to [40]% full steam flow between [0]% and [20]% load and then a P increasing linearly from [40]% steam flow at [20]% load to [110]% full steam flow at [100]% load.
REVIEWER'S NOTE---------------------------------------------------------------------
(l) Unit specific implementations may contain only Allowable Value depending on Setpoint Study methodology used by the unit. -----------------------------------------------------------------------------------------------------------------------------
2.a Table 3.3-3 7 4 3 2 2 2 ESFAS Instrumentation (Without Setpoint Control Program) 3.3.2 A Westinghouse STS 3.3.2 A-13 Rev. 4.0 SEQUOYAH UNIT 2 Amendment XXX 1 2CTS 1Table 3.3.2-1 (page 3 of 11) Engineered Safety Feature Actuation System Instrumentation
FUNCTION APPLICABLE MODES OR OTHER SPECIFIED CONDITIONS REQUIRED CHANNELS
CONDITIONS
SURVEILLANCE REQUIREMENTS ALLOWABLE VALUE [NOMINAL (l) TRIP SETPOINT] 2. Containment Spray
- b. Automatic Actuation Logic and Actuation Relays 1,2,3,4 2 trains C SR 3.3.2.2 SR 3.3.2.
4 SR 3.3.2.
6 NA NA
- c. Containment Pressure High - 3 (High High) 1,2,3 4 E SR 3.3.2.1 SR 3.3.2.
5 (b)(c) SR 3.3.2.
9 (b)(c) SR3.3.2.10 [12.31] psig [12.05] psig
- d. Containment Pressure High
- 3 (Two Loop Plants) 1,2,3 [3] sets of
[2] E SR 3.3.2.1 SR 3.3.2.5 (b)(c) SR 3.3.2.9 (b)(c) SR 3.3.2.10 [12.31] psig [12.05] psig
- 3. Containment Isolation
- a. Phase A Isolation (1) Manual Initiation 1,2,3,4 2 B SR 3.3.2.
8 NA NA (2) Automatic Actuation Logic and Actuation Relays 1,2,3,4 2 trains C SR 3.3.2.2 SR 3.3.2.
4 SR 3.3.2.
6 NA NA (3) Safety Injection Refer to Function 1 (Safety Injection) for all initiation functions and requirements.
(b) If the as-found channel setpoint is outside its predefined as-found tolerance, then the channel shall be evaluated to verify that it is functioning as required before returning the channel to service.
(c) The instrument channel setpoint shall be reset to a value that is within the as-left tolerance around the Nominal Trip Setpoint (NTSP) at the completion of the surveillance; otherwise, the channel shall be declared inoperable. Setpoints more conservative than the NTSP are acceptable provided that the as-found and as-left tolerances apply to the actual setpoint implemented in the Surveillance procedures (field setting) to confirm channel performance. The NTS P and the methodologies used to determine the as-found and as-left tolerances are specified in [insert the facility FSAR reference or the name of any document incorporated into the facility FSAR by reference]. -----------------------------------------------------------------------REVIEWER'S NOTE---------------------------------------------------------------------
(l) Unit specific implementations may contain only Allowable Value depending on Setpoint Study methodology used by the unit. ------------------------------------------------------------------------------------------------------------------------------------------------------------------------
2.9 2.81 - 2.b 2.c 3.a 3.a.1) 3.a.2) Table 3.3-3 DOC M05 3.3.2.1, and ACTION 3.3.2.1, and ACTION 9 3 3 4 8 5 7 5 4 3 2 2 3 2 3 2UFSAR Section 7.1.2 ESFAS Instrumentation (Without Setpoint Control Program) 3.3.2 A Westinghouse STS 3.3.2 A-14 Rev. 4.0 SEQUOYAH UNIT 2 Amendment XXX 1 2CTS 1Table 3.3.2-1 (page 4 of 11) Engineered Safety Feature Actuation System Instrumentation FUNCTION APPLICABLE MODES OR OTHER SPECIFIED CONDITIONS REQUIRED CHANNELS CONDITIONSSURVEILLANCE REQUIREMENTS ALLOWABLE VALUE [NOMINAL (l) TRIP SETPOINT] 3.ContainmentIsolationb.Phase B Isolatio n (1) Manual Initiation 1,2,3,4 2 per train, 2 trains B SR 3.3.2.
8 NA NA (2) Automatic Actuation Logic and Actuation Relays 1,2,3,4 2 trains C SR 3.3.2.2 SR 3.3.2.
4 SR 3.3.2.
6 NA NA (3) Containment Pressure High - 3 (High High) 1,2,3 [4] E SR 3.3.2.1 SR 3.3.2.
5 (b)(c) SR 3.3.2.
9 (b)(c) SR3.3.2.10 [12.31] psig [12.05] psig 4.Steam Line Isolationa.Manual Initiation 1,2 (j),3 (j) 2 F SR 3.3.2.
8 NA NAb.AutomaticActuation Logic and ActuationRelays 1,2 (j),3 (j) 2 trains G SR 3.3.2.2 SR 3.3.2.
4 SR 3.3.2.
6 NA NAc.Containment Pressure - High 2 1,2 (j),3 (j) [4] D SR 3.3.2.1 SR 3.3.2.
5 (b)(c) SR 3.3.2.
9 (b)(c) SR 3.3.2.
10 [6.61] psig [6.35] psig (b) If the as-found channel setpoint is outside its predefined as-found tolerance, then the channel shall be evaluated to verify that it is functioning as required before returning the channel to service. (c) The instrument channel setpoint shall be reset to a value that is within the as-left tolerance around the Nominal Trip Setpoint (NTSP) at the completion of the surveillance; otherwise, the channel shall be declared inoperable. Setpoints more conservative than the NTSP are acceptable provided that the as-found and as-left tolerances apply to the actual setpoint implemented in the Surveillance procedures (field setting) to confirm channel performance. The NTS P and the methodologies used to determine the as-found and as-left tolerances are specified in [insert the facility FSAR reference or the name of any document incorporated into the facility FSAR by reference]. (j) Except when all MSIVs are closed and [de-activated]. -----------------------------------------------------------------------REVIEWER'S NOTE---------------------------------------------------------------------
(l) Unit specific implementations may contain only Allowable Value depending on Setpoint Study methodology used by the unit. ------------------------------------------------------------------------------------------------------------------------------------------------------------------------
1 per steam line-High 2.9 2.81 2.9 2.81 Table 3.3-3 3.b.1) 3.b.2) 3.b.3) 3.b. DOC L04 4.a 4.b 4.c E3.3.2.1, and ACTION 3.3.2.1, and ACTION 9 9 3 3 4 8 4 8 5 7 7 5 4 3 2 2 3 2 3 3 2UFSAR Section 7.1.2 H 3 e e e e ESFAS Instrumentation (Without Setpoint Control Program) 3.3.2 A Westinghouse STS 3.3.2 A-15 Rev. 4.0 SEQUOYAH UNIT 2 Amendment XXX 1 2CTS 1Table 3.3.2-1 (page 5 of 11) Engineered Safety Feature Actuation System Instrumentation FUNCTION APPLICABLE MODES OR OTHER SPECIFIED CONDITIONS REQUIRED CHANNELS CONDITIONSSURVEILLANCE REQUIREMENTSALLOWABLE VALUE [NOMINAL (l) TRIP SETPOINT] 4.Steam Line Isolationd.Steam Line Pressure (1) Low 1,2 (j),3 (j) (a) 3 per steam lineD SR 3.3.2.1 SR 3.3.2.
5 (b)(c)SR 3.3.2.
9 (b)(c)SR3.3.2.10 [635](d) psig [675](d) psig (2) Negative Rate - High 3 (h) (j) 3 per steam lineD SR 3.3.2.1 SR 3.3.2.
5 (b)(c)SR 3.3.2.
9 (b)(c)SR 3.3.2.
10 [121.6](i) psi [110](i) psi (a) Above the P
-11 (Pressurizer Pressure) in terlock. (b) If the as-found channel setpoint is outside its predefined as-found tolerance, then the channel shall be evaluated to verify that it is functioning as required before returning the channel to service. (c) The instrument channel setpoint shall be reset to a value that is within the as-left tolerance around the Nominal Trip Setpoint (NTSP) at the completion of the surveillance; otherwise, the channel shall be declared inoperable. Setpoints more conservative than the NTSP are acceptable provided that the as-found and as-left tolerances apply to the actual setpoint implemented in the Surveillance procedures (field setting) to confirm channel performance. The NTS P and the methodologies used to determine the as-found and as-left tolerances are specified in [insert the facility FSAR reference or the name of any document incorporated into the facility FSAR by reference]. (d) Time constants used in the lead/lag controller are t 1 [50] seconds and t 2 [5] seconds.
(h) Below the P
-11 (Pressurizer Pr essure) interlock. (i) Time constant utilized in the rate/lag controller is [50] seconds.
(j) Except when all MSIVs are closed and [de-activated]. -----------------------------------------------------------------------REVIEWER'S NOTE---------------------------------------------------------------------
(l) Unit specific implementations may contain only Allowable Value depending on Setpoint Study methodology used b y the unit. ------------------------------------------------------------------------------------------------------------------------------------------------------------------------
592.2 600 107.8 100.0Table 3.3-3 4.d 4.e 3.3.2.1, and ACTION 3.3.2.1, and ACTION Table 3.3-4 Note 1 Table 3.3-4 Note 2 DOC L04 Table 3.3-3 Note ## 9 9 4 8 4 8 4 3 2 3 3 3 3 3 3 2UFSAR Section 7.1.2 2 2Note # When Steam Line Isolationon Steam Line Pressure, Low is blocked When Steam Line Isolation on Steam Line Pressure, Negative Rate-High is blocked f f e e e g h g h ESFAS Instrumentation (Without Setpoint Control Program) 3.3.2 A Westinghouse STS 3.3.2 A-16 Rev. 4.0 SEQUOYAH UNIT 2 Amendment XXX 1 2CTS 1Table 3.3.2-1 (page 6 of 11) Engineered Safety Feature Actuation System Instrumentation
FUNCTION APPLICABLE MODES OR OTHER SPECIFIED CONDITIONS REQUIRED CHANNELS
CONDITIONS
SURVEILLANCE REQUIREMENTS ALLOWABLE VALUE [NOMINAL (l) TRIP SETPOINT] 4. Steam Line Isolation
- e. High Steam Flow in Two Steam Lines 1,2 (j), 3 (j) 2 per steam line D SR 3.3.2.1 SR 3.3.2.5 (b)(c) SR 3.3.2.9 (b)(c) SR 3.3.2.10 (f) (g)
Coincident with Tavg - Low Low 1,2 (j),3 (e) (j) 1 per loop D SR 3.3.2.1 SR 3.3.2.5 (b)(c) SR 3.3.2.9 (b)(c) SR 3.3.2.10 [550.6]°F [553]°F
- f. High Steam Flow in Two Steam Lines 1,2 (j),3 (j) 2 per steam line D SR 3.3.2.1 SR 3.3.2.5 (b)(c) SR 3.3.2.9 (b)(c) SR 3.3.2.10 (f) (g) Coincident with Steam Line Pressure - Low 1,2 (j), 3 (j) 1 per steam line D SR 3.3.2.1 SR 3.3.2.5 (b)(c) SR 3.3.2.9 (b)(c) SR 3.3.2.10 [635](d) psig [675](d) psig (b) If the as
-found channel setpoint is outside its predefined as
-found tolerance, then the channel shall be evaluated to verify that it is functioning as required before returning the channel to service.
(c) The instrument channel setpoint shall be reset to a value that is within the as
-left tolerance around the Nominal Trip Setpoint (NTSP) at the completion of the surveillance; otherwise, the channel shall be declared inoperable. Setpoints more conservative than the NTSP are acceptable provided that the as
-found and as
-left tolerances apply to the actual setpoint implemented in the Surveillance procedures (field setting) to confirm channel performance. The NTS P an d the methodologies used to determine the as
-found and as
-left tolerances are specified in [insert the facility FSAR reference or the name of any document incorporated into the facility FSAR by reference].
(d) Time constants used in the lead/lag controller are t 1 [50] seconds and t 2 [5] seconds.
(e) Above the P
-12 (Tavg - Low Low) interlock.
(f) Less than or equal to a function defined as P corresponding to [44]% full steam flow below [20]% load, and P increasing linearly from [44]% full steam flow at [20]%
load to [114]% full steam flow at [100]% load, and P corresponding to [114]% full steam flow above 100% load.
(g) Less than or equal to a function defined as P corresponding to [40]% full steam flow between [0]% and [20]% load and then a P increasing linearly from [40]% steam flow at [20]% load to [110]% full steam flow at [100]% load.
(j) Except when all MSIVs are closed and [de
-activated].
REVIEWER'S NOTE---------------------------------------------------------------------
(l) Unit specific implementations may contain only Allowable Value depending on Setpoint Study methodology used by the unit. ------------------------------------------------------------------------------------------------------------------------------------------------------------------------
Table 3.3-3 4 3 2 ESFAS Instrumentation (Without Setpoint Control Program) 3.3.2 A Westinghouse STS 3.3.2 A-17 Rev. 4.0 SEQUOYAH UNIT 2 Amendment XXX 1 2CTS 1Table 3.3.2-1 (page 7 of 11) Engineered Safety Feature Actuation System Instrumentation FUNCTION APPLICABLE MODES OR OTHER SPECIFIED CONDITIONS REQUIRED CHANNELS CONDITIONSSURVEILLANCE REQUIREMENTS ALLOWABLE VALUE [NOMINAL(l) TRIP SETPOINT] 4.Steam Line Isolation g.High Steam Flow 1,2 (j), 3 (j) 2 persteam line D SR 3.3.2.1 SR 3.3.2.5 (b)(c) SR 3.3.2.9 (b)(c) SR 3.3.2.10 [25]% of full steam flow at no load steam pressure [ ] full steam flow at no load steam pressure Coincident with Safety Injection Refer to Function 1 (Safety Injection) for all initiation functions and requirements.
and Coincident wit h Tavg - Low Low 1,2 (j),3 (e) (j) [2] per loop D SR 3.3.2.1 SR 3.3.2.5 (b)(c) SR 3.3.2.9 (b)(c) SR 3.3.2.10 [550.6]°F [553]°F h.High High SteamFlow 1,2 (j),3 (j) 2 persteam line D SR 3.3.2.1 SR 3.3.2.5 (b)(c) SR 3.3.2.9 (b)(c) SR 3.3.2.10 [130]% of full steam flow at full load steam pressure [ ] of full steam flow at full load steam pressure Coincident with Safety Injection Refer to Function 1 (Safety Injection) for all initiation functions and requirements.
(b) If the as
-found channel setpoint is outside its predefined as
-found tolerance, then the channel shall be evaluated to verify that it is functioning as required before returning the channel to service.
(c) The instrument channel setpoint shall be reset to a value that is within the as
-left tolerance around the Nominal Trip Setpoint (NTSP) at the completion of the surveillance; otherwise, the channel shall be declared inoperable. Setpoints more conservative than the NTSP are acceptable provided that the as
-found and a s-left tolerances apply to the actual setpoint implemented in the Surveillance procedures (field setting) to confirm channel performance. The NTS P and the methodologies used to determine the as
-found and as
-left tolerances are specified in [insert the facility FSAR reference or the name of any document incorporated into the facility FSAR by reference].
(e) Above the P
-12 (Tavg - Low Low) interlock.
(j) Except when all MSIVs are closed and [de
-activated].
REVIEWER'S NOTE---------------------------------------------------------------------
(l) Unit specific implementations may contain only Allowable Value depending on Setpoint Study methodology used by the unit. ------------------------------------------------------------------------------------------------------------------------------------------------------------------------
Table 3.3-3 4 3 2 ESFAS Instrumentation (Without Setpoint Control Program) 3.3.2 A Westinghouse STS 3.3.2 A-18 Rev. 4.0 SEQUOYAH UNIT 2 Amendment XXX 1 2CTS 1Table 3.3.2-1 (page 8 of 11) Engineered Safety Feature Actuation System Instrumentation FUNCTION APPLICABLE MODES OR OTHER SPECIFIED CONDITIONS REQUIRED CHANNELS CONDITIONSSURVEILLANCE REQUIREMENTS ALLOWABLE VALUE [NOMINAL(l) TRIP SETPOINT] 5.Turbine Trip andFeedwater Isolationa.Automatic Actuation Logicand ActuationRelays 1, 2 (k),[3] (k) 2 trains H
[G] SR 3.3.2.2 SR 3.3.2.
4 SR 3.3.2.
6 NA NAb.SG Water Level -High High (P-14) 1,2 (k),[3](k) [3] per SG I[D] SR 3.3.2.1 SR 3.3.2.
5 (b)(c) SR 3.3.2.
9 (b)(c) SR3.3.2.10 [84.2]% [82.4]% c.Safety InjectionRefer to Function 1 (Safety Injection) for all initiation functions and requirements. 6.Auxiliary Feedwatera.AutomaticActuation Logic and ActuationRelays (SolidState ProtectionSystem) 1,2,32 trains G SR 3.3.2.2 SR 3.3.2.
4 SR 3.3.2.
6 NA NA b.AutomaticActuation Logic and Actuation Relays (Balance of Plant ESFAS) 1,2,32 trains G SR 3.3.2.3 NA NA (b) If the as-found channel setpoint is outside its predefined as-found tolerance, then the channel shall be evaluated to verify that it is functioning as required before returning the channel to service. (c) The instrument channel setpoint shall be reset to a value that is within the as-left tolerance around the Nominal Trip Setpoint (NTSP) at the completion of the surveillance; otherwise, the channel shall be declared inoperable. Setpoints more conservative than the NTSP are acceptable provided that the as-found and as-left tolerances apply to the actual setpoint implemented in the Surveillance procedures (field setting) to confirm channel performance. The NTS P and the methodologies used to determine the as-found and as-left tolerances are specified in [insert the facility FSAR reference or the name of any document incorporated into the facility FSAR by reference]. (k) Except when all MFIVs, MFRVs, [and associated bypass valves
] are closed and [de-activated] [or isolated by a closed manual valve
]. ------------------------------------------------------------------
REVIEWER'S NOTE---------------------------------------------------------------------
(j) Unit specific implementations may contain only Allowable Value depending on Setpoint Study methodology used by the unit. ----------------------------------------------------------------------------------------------------------------------------------------------------------------------
-- 81.7 81 Table 3.3-3 5.b 5.a 6.b DOC L05 DOC A08 3.3.2.1, and ACTION 3.3.2.1, and ACTION 9 3 3 4 8 5 5 MFRV 4 3 3 2 2 2 3 3 3UFSAR Section 7.1.2 H i i i ESFAS Instrumentation (Without Setpoint Control Program) 3.3.2 A Westinghouse STS 3.3.2 A-19 Rev. 4.0 SEQUOYAH UNIT 2 Amendment XXX 1 2CTS 1Table 3.3.2-1 (page 9 of 11) Engineered Safety Feature Actuation System Instrumentation FUNCTION APPLICABLE MODES OR OTHER SPECIFIED CONDITIONS REQUIRED CHANNELS CONDITIONSSURVEILLANCE REQUIREMENTS ALLOWABLE VALUE [NOMINAL (l) TRIP SETPOINT] 6.Auxiliary Feedwater c.SG Water Level -
Low Low 1,2,3 [3] per SG D SR 3.3.2.1 SR 3.3.2.5 (b)(c) SR 3.3.2.9 (b)(c) SR 3.3.2.10 [30.4]% [32.2]% d.Safety Injection Refer to Function 1 (Safety Injection) for all initiation functions and requirements.
e.Loss of Offsite Power 1,2,3[3] per bus F SR 3.3.2.7 SR 3.3.2.9 (b)(c) SR 3.3.2.10 [2912] V with 0.8 sec time delay
[2975] V with 0.8 sec time delay f.UndervoltageReactor Coolant Pump 1,2 [3] per bus I SR 3.3.2.7 SR 3.3.2.9 (b)(c) SR 3.3.2.10 [69]% bus voltage [70]% bus voltage g.Trip of all Main Feedwater Pumps 1,2 [2] per pump J SR 3.3.2.
8 (b)(c) SR 3.3.2.9 (b)(c) SR 3.3.2.
10 [ ] psig [ ] psig h.Auxiliary Feedwater Pump Suction Transfer on Suction Pressure - Low 1,2,3 [2]F SR 3.3.2.1 SR 3.3.2.7 SR 3.3.2.
9 (b)(c) [20.53] [psia]
[ ] [psia] 7.AutomaticSwitchover to Containment Sumpa.AutomaticActuation Logicand ActuationRelays1,2,3,42 trains C SR 3.3.2.2 SR 3.3.2.
4 SR 3.3.2.
6 NA NA (b) If the as-found channel setpoint is outside its predefined as-found tolerance, then the channel shall be evaluated to verify that it is functioning as required before returning the channel to service. (c) The instrument channel setpoint shall be reset to a value that is within the as-left tolerance around the Nominal Trip Setpoint (NTSP) at the completion of the surveillance; otherwise, the channel shall be declared inoperable. Setpoints more conservative than the NTSP are acceptable provided that the as-found and as-left tolerances apply to the actual setpoint implemented in the Surveillance procedures (field setting) to confirm channel performance. The NTS P and the methodologies used to determine the as-found and as-left tolerances are specified in
[insert the facility FSAR reference or the name of any document incorporated into the facility FSAR by reference]. -----------------------------------------------------------------------REVIEWER'S NOTE---------------------------------------------------------------------
(l) Unit specific implementations may contain only Allowable Value depending on Setpoint Study methodology used by the unit. ------------------------------------------------------------------------------------------------------------------------------------------------------------------------
INSERT 9 INSERT 103 per pump 1 NA NA INSERT 12 INSERT 11INSERT 14 INSERT 13 e f (k) Table 3.3-3 Table 3.3-4 Table 4.3-2 6.c 6.d 6.e 6.f 6.g 9. 9.b 3.3.2.1, and ACTION 3.3.2.1, and ACTION 9 3 8 5 7 N b c d 4 3 3 2 3 3 2 2 2UFSAR Section 7.1.2 O 6 6 7 2 8 S 3.3.2 Insert Page 3.3.2-19a CTS INSERT 9 FUNCTION APPLICABLE MODES OR OTHER SPECIFIED CONDITIONS REQUIRED CHANNELS CONDITIONS
SURVEILLANCE REQUIREMENTS ALLOWABLE VALUE NOMINAL TRIP SETPOINT (1) Adverse 1,2,3 3 per SG I SR 3.3.2.1 SR 3.3.2.4(b)(c) SR 3.3.2.8(b)(c) SR 3.3.2.9 14.4% NR Span 15.0% NR Span Coincident with Containment Pressure (EAM) 1,2,3 4 J SR 3.3.2.1 SR 3.3.2.4(b)(c) SR 3.3.2.8(b)(c) 0.6 psig 0.5 psig and RCS Loop T 1,2,3 4 K SR 3.3.2.1 SR 3.3.2.4(b)(c) SR 3.3.2.8(b)(c) RCS Loop T variable input nominal trip setpoint + 2.5% RTP RCS Loop T variable input 50% RTP with Time Delay T S if one SG is
affected
(1.01)T s (Note 3 Table 3.3.1-1)
T S (Note 3 Table 3.3.1-1)
or Time Delay T m if two or more SGs are affected
(1.01)T m (Note 3 Table 3.3.1-1)
T m (Note 3 Table 3.3.1-1) Table 3.3-4 6.c.i Table 3.3-4 6.c.i 66.c.i.a 6.c.ii.a Table 3.3-3 Table 3.3-4 Table 4.3-2 6.c.i.d 6.c.ii.d 6.c.i.c 6.c.ii.c 3.3.2 Insert Page 3.3.2-19b CTS INSERT 10 FUNCTION APPLICABLE MODES OR OTHER SPECIFIED CONDITIONS REQUIRED CHANNELSCONDITIONSSURVEILLANCE REQUIREMENTS ALLOWABLE VALUE NOMINAL TRIP SETPOINT (2) EAM 1,2,3 3 per SG I SR 3.3.2.1 SR 3.3.2.4(b)(c) SR 3.3.2.8(b)(c) SR 3.3.2.9 10.1% NR Span 10.7% NR Span Coincident with RCS Loop T 1,2,3 4 K SR 3.3.2.1 SR 3.3.2.4(b)(c) SR 3.3.2.8(b)(c) RCS Loop T variable input nominal trip setpoint + 2.5% RTP RCS Loop T variable input 50% RTP with Time Delay T S if one SG is affected (1.01)T s (Note 3 Table 3.3.1-1)
T S (Note 3 Table 3.3.1-1) or Time Delay T m if two or more SGs are affected (1.01)T m (Note 3 Table 3.3.1-1)
T m (Note 3 Table 3.3.1-1)Table 3.3-4 6.c.i Table 3.3-4 6.c.i 66.c.i.b 6.c.ii.b 6.c.i.c 6.c.ii.c Table 3.3-3 Table 3.3-4 Table 4.3-2 3.3.2 Insert Page 3.3.2-19c CTS INSERT 11 FUNCTION APPLICABLE MODES OR OTHER SPECIFIED CONDITIONS REQUIRED CHANNELS CONDITIONS
SURVEILLANCE REQUIREMENTS ALLOWABLE VALUE NOMINAL TRIP SETPOINT (1) Voltage Sensors 1,2,3 3 per shutdown board (j) L,M SR 3.3.2.6 SR 3.3.2.8(b)(c) SR 3.3.2.9 Refer to Function 1 of Table 3.3.5-1 for setpoints and allowable values.
(2) Load Shed Timer 1,2,3 1 per shutdown board (j) M SR 3.3.2.8(b)(c) SR 3.3.2.9 Refer to Function 1 of Table 3.3.5-1 for setpoints and allowable values.
INSERT 12
Allowable Value Nominal Trip Setpoint 2.44 psig (motor driven pump) 3.21 psig (motor driven pump) 12 psig (turbine driven pump) 13.9 psig (turbine driven pump)
Table 3.3-3 Table 3.3-4 Table 4.3-2 7Table 3.3-4 6.g 3Table 3.3-3 6.e.1 Table 3.3-3 6.e.2 3.3.2 Insert Page 3.3.2-19d CTS INSERT 13 FUNCTION APPLICABLE MODES OR OTHER SPECIFIED CONDITIONS REQUIRED CHANNELSCONDITIONSSURVEILLANCE REQUIREMENTS ALLOWABLE VALUE NOMINAL TRIP SETPOINTg.Auxiliary Feedwater Suction TransferTime Delays (1) Motor-Driven Pump 1,2,3 1 per pump O SR 3.3.2.8(b)(c) 4.4 seconds and 3.6 seconds 4 seconds (2) Turbine-Driven Pump 1,2,3 2 per pump O SR 3.3.2.8(b)(c) 6.05 seconds and 4.95 seconds 5.5 seconds INSERT 14 (j) Unit 1[2] shutdown boards only. (k) When one or more Main Feedwater Pump(s) are supplying feedwater to steam generators. Table 3.3-3 6.h.1 Table 3.3-3 6.h.2 Table 3.3-3 6.h Table 3.3-3 Table 3.3-4 Table 4.3-2 2Table 3.3-3 Note ** Table 3.3-3 Note (b) 8 ESFAS Instrumentation (Without Setpoint Control Program) 3.3.2 A Westinghouse STS 3.3.2 A-20 Rev. 4.0 SEQUOYAH UNIT 2 Amendment XXX 1 2CTS 1Table 3.3.2-1 (page 10 of 11) Engineered Safety Feature Actuation System Instrumentation
FUNCTION APPLICABLE MODES OR OTHER SPECIFIED CONDITIONS REQUIRED CHANNELS
CONDITIONS
SURVEILLANCE REQUIREMENTS ALLOWABLE VALUE [NOMINAL (l) TRIP SETPOINT] 7. Automatic Switchover to Containment Sump
- b. Refueling Water Storage Tank (RWST) Level
- Low Low 1,2,3,4 4 K SR 3.3.2.1 SR 3.3.2.5 (b)(c) SR 3.3.2.9 (b)(c) SR 3.3.2.10 [15]% and [ ]% [ ]% and [ ]% Coincident with Safety Injection Refer to Function 1 (Safety Injection) for all initiation functions and requirements.
- c. RWST Level - Low Low 1,2,3,4 4 K SR 3.3.2.1 SR 3.3.2.
5 (b)(c) SR 3.3.2.
9 (b)(c) SR3.3.2.10 [15]% [18]% Coincident with Safety Injection Refer to Function 1 (Safety Injection) for all initiation functions and requirements.
and Coincident with Containment Sump Level - High 1,2,3,4 4 K SR 3.3.2.1 SR 3.3.2.
5 (b)(c) SR 3.3.2.
9 (b)(c) SR 3.3.2.
10 [30] in. above el.
[703] ft [ ] in. above el. [ ]ft (b) If the as-found channel setpoint is outside its predefined as-found tolerance, then the channel shall be evaluated to verify that it is functioning as required before returning the channel to service.
c) The instrument channel setpoint shall be reset to a value that is within the as-left tolerance around the Nominal Trip Setpoint (NTSP) at the completion of the surveillance; otherwise, the channel shall be declared inoperable. Setpoints more conservative than the NTSP are acceptable provided that the as-found and as-left tolerances apply to the actual setpoint implemented in the Surveillance procedures (field setting) to confirm channel performance. The NTS P and the methodologies used to determine the as-found and as-left tolerances are specified in [insert the facility FSAR reference or the name of any document incorporated into the facility FSAR by reference]. -----------------------------------------------------------------------REVIEWER'S NOTE---------------------------------------------------------------------
(l) Unit specific implementations may contain only Allowable Value depending on Setpoint Study methodology used by the unit. ------------------------------------------------------------------------------------------------------------------------------------------------------------------------
132.71" and 127.29" from tank base130" from tank base 31.68 in and 28.32 30 680 Table 3.3-3 Table 3.3-4 Table 4.3-2
- b. 9. 9.a. 3.3.2.1, and ACTION 3.3.2.1, and ACTION 9 9 4 8 4 8 P P 4 3 3 2 2 2 3 3UFSAR Section 7.1.2 ESFAS Instrumentation (Without Setpoint Control Program) 3.3.2 A Westinghouse STS 3.3.2 A-21 Rev. 4.0 SEQUOYAH UNIT 2 Amendment XXX 1 2CTS 1Table 3.3.2-1 (page 11 of 11) Engineered Safety Feature Actuation System Instrumentation FUNCTION APPLICABLE MODES OR OTHER SPECIFIED CONDITIONS
REQUIRED CHANNELS
CONDITIONS
SURVEILLANCE REQUIREMENTS ALLOWABLE VALUE [NOMINAL(l) TRIP SETPOINT] 8. ESFAS Interlocks
- a. Reactor Trip, P-4 1,2,3 1 per train, 2 trains F SR 3.3.2.
11 NA NA b. Pressurizer Pressure, P
-11 1,2,3 3 L SR 3.3.2.1 SR 3.3.2.5 SR 3.3.2.9 [1996] psig
[ ] psig c. Tavg - Low Low, P-12 1,2,3 [1] per loop L SR 3.3.2.1 SR 3.3.2.5 SR 3.3.2.9 [5 50.6]°F [553]° F
REVIEWER'S NOTE---------------------------------------------------------------------
(l) Unit specific implementations may contain only Allowable Value depending on Setpoint Study methodology used by the unit. ------------------------------------------------------------------------------------------------------------------------------------------------------------------------
INSERT 15 22.G. 10 4 3 2Table 3.3-1 Table 4.3-1 G
3.3.2 Insert Page 3.3.2-21 CTS INSERT 15 FUNCTION APPLICABLE MODES OR OTHER SPECIFIED CONDITIONS
REQUIRED CHANNELS CONDITIONS
SURVEILLANCE REQUIREMENTS ALLOWABLE VALUE NOMINAL TRIP SETPOINT b. Pressurizer Pressure, P-11/Not P-11 (1) Not P-11, Automatic Unblock of Safety Injection on Increasing Pressure 1,2,3 3 Q SR 3.3.2.8 1975.2 psig 1970 psig (2) P-11, Enable Manual Block of Safety Injection on Decreasing Pressure 1,2,3 3 Q SR 3.3.2.8 1956.8 psig 1962 psig Table 3.3-3 Table 3.3-4 Table 4.3-2 2Table 3.3-4, 8.a.2 Table 3.3-2, 8.a Table 4.3-2, 8.a Table 3.3-4, 8.a.1 JUSTIFICATION FOR DEVIATIONS ITS 3.3.2, ENGINEERED SAFETY FEATURE ACTUATION SYSTEM (ESFAS) INSTRUMENTATION Sequoyah Unit 1 and Unit 2 Page 1 of 2 1. NUREG 1431, Standard Technical Specificat ions - Westinghouse Plants, Revision 4.0 provides two sets of specifications for Section 3.3.2; one for adoption "Without a Setpoint Control Program," (3.3.2.A) the other for adoption "With a Setpoint Control Program," (3.3.2.B). This information is provided in NUREG-1431, Rev. 4.0, to assist in identifying the appropriate Specification to be used as a model for the plant specific ITS conversion, but serves no purpose in a plant specific implementation and is removed.
- 2. Changes are made (additions, deletions, and/or changes) to the ISTS that reflect the plant-specific nomenclature, number, reference, system description, analysis, or licensing basis description. Where a deletion has occurred, subsequent alpha-numeric designators have been changed for any applicable affected ACTIONS, SURVEILLANCE REQUIREMENTS, FUNCTIONS, and Footnotes.
- 3. The ISTS contains bracketed information and/or values that are generic to Westinghouse vintage plants. The brackets are removed and the proper plant specific information/value is inserted to reflect the current licensing basis.
- 4. The Reviewer's Note has been deleted. This information is for the NRC reviewer to be keyed into what is needed to meet this requirement. This Note is not meant to be retained in the final version of the plant specific submittal.
- 5. ISTS SR 3.3.2.1, ISTS SR 3.3.2.2, ISTS SR 3.3.2.4, ISTS SR 3.3.2.5, ISTS SR 3.3.2.6, ISTS SR 3.3.2.7, ISTS SR 3.3.2.8, ISTS SR 3.3.2.9, and SR 3.3.2.10, provide two options for controlling the Frequencies of Surveillance Requirements. SQN is proposing to control the Surveillance Frequencies under the Surveillance Frequency Control Program. Therefore, except for those frequencies that are event driven or related to specific conditions, the Frequencies for ITS SR 3.3.2.1, ITS SR 3.3.2.2, ITS SR 3.3.2.3, ITS SR 3.3.2.4, ITS SR 3.3.2.5, ITS SR 3.3.2.6, ITS SR 3.3.2.7, ITS SR 3.3.2.8, and ITS SR 3.3.2.9, are "In accordance with the Surveillance Frequency Control Program." 6. CTS Table 3.3-3, Table 4.3-2, and Table 3.3-4 include Functional Unit 6.c (Main Steam Generator Water Level-Low-Low).
ISTS includes a similar Function, ISTS Function 6 (Steam Generator (SG) Water Level - Low Low), but does not include the Environmental Allowance Modifier (EAM) or the Trip Time Delay (TTD) features.
Changes are made to present the CTS Functional Unit 6 in ISTS format.
- 7. CTS Table 3.3-3, Table 4.3-2, and Table 3.3-4 include Functional Unit 6.e.1 (Voltage Sensors) and Functional Unit 6.e.2 (Load Shed Timer). ISTS includes a similar Function, ISTS Function 6.e (Loss of Offsite Power), but does not include Voltage
Sensor and Load Shed Timer features. Changes are made to present CTS Functional Units 6.e.1 and 6.e.2 in ISTS format.
JUSTIFICATION FOR DEVIATIONS ITS 3.3.2, ENGINEERED SAFETY FEATURE ACTUATION SYSTEM (ESFAS) INSTRUMENTATION Sequoyah Unit 1 and Unit 2 Page 2 of 2 8. CTS Table 3.3-3 includes Notes modifying Functional Units 6.e.1 (Voltage Sensors) and Functional Unit 6.e.2 (Load Shed Timer) (CTS Table 3.3-3 Note **) and Functional Unit 6.f (Trip of Main Feedwater Pumps Start Motor-Driven Pumps and
Turbine Driven Pump) (Notes (a) and (b)).
ISTS includes similar Functions, ISTS Function 6.e (Loss of Offsite Power) and ISTS Function 6.g (Trip of all Main Feedwater Pumps ), but does not include these notes. Changes are made to present the CTS Notes in ISTS format.
Improved Standard Technical Specifications (ISTS) Bases Markup and Bases Justification for Deviations (JFDs)
Engineered Safety Feature Actuation System (ESFAS) Instrumentation (Without Setpoint Control Program)
B 3.3.2 A Westinghouse STS B 3.3.2 A-1 Rev. 4.0 SEQUOYAH UNIT 1 Revision XXX 1 1 2B 3.3 INSTRUMENTATION
B 3.3.2 A Engineered Safety Feature Actuation System (ESFAS) Instrumentation (Without Setpoint Control Program)
BASES
BACKGROUND The ESFAS initiates necessary safety systems, based on the values of selected unit parameters, to protect against violating core design limits and the Reactor Coolant System (RCS) pressure boundary, and to mitigate accidents. This is achieved by specifying limiting safety system settings (LSSS) in terms of parameters directly monitored by the ESFAS, as well as specifying LCOs on other reactor system parameters and equipment performance.
Technical Specifications are required by 10 CFR 50.36 to include LSSS for variables that have significant safety functions. LSSS are defined by the regulation as "Where a LSSS is specified for a variable on which a safety limit has been placed, the setting must be chosen so that automatic protective actions will correct the abnormal situation before a Safety Limit (SL) is exceeded." The Analytical Limit is the limit of the process variable at which a protective action is initiated, as established by the safety analysis, to ensure that a SL is not exceeded. Any automatic protection action that occurs on reaching the Analytical Limit therefore ensures that the SL is not exceeded. However, in practice, the actual settings for automatic protection channels must be chosen to be more conservative than the Analytical Limit to account for instrument loop uncertainties related to the setting at which the automatic protective action would actually occur.
REVIEWER'S NOTE ------------------------------------
T he term "[Limiting Trip Setpoint (LTS P)]" is generic terminology for the calculated field setting (setpoint) value calculated by means of the plant
-specific setpoint methodology documented in a document controlled under 10 CFR 50.59. The term [LTSP] indicates that no additional margin has been added between the Analytical Limit and the calculated trip setting.
For most Westinghouse plants the term
[Nominal Trip Setpoint (NTSP)
] is used in place of the term
[LTSP], and [NTSP] will replace
[LTSP] in the Bases descriptions. "Field setting" is the suggested terminology for the actual setpoint implemented in the plant surveillance procedures where margin has been added to the calculated field setting. The as
-found and as-left tolerances will apply to the field setting implemented in the Surveillance procedures to confirm channel performance.
INSERT 1 2 3 1 B 3.3.2 Insert Page B 3.3.2-1 INSERT 1 settings for automatic protective devices related to those variables having significant safety functions. The regulation also states,
2 Engineered Safety Feature Actuation System (ESFAS) Instrumentation (Without Setpoint Control Program)
B 3.3.2 A Westinghouse STS B 3.3.2 A-2 Rev. 4.0 SEQUOYAH UNIT 1 Revision XXX 1 1 2BASES
BACKGROUND (continued)
Licensees are to insert the name of the document(s) controlled under 10 CFR 50.59 that contain the methodology for calculating the as
-left and as-found tolerances, in N ote c of Table 3.3.2-1 for the phrase "[insert the name of a document controlled under 10 CFR 50.59 such as the Technical Requirements Manual or any document incorporated into the facility FSAR]" throughout these Bases.
Where the [NTSP] is not included in Table 3.3.2-1, the plant
-specific location for the
[NTS P] must be cited in Note c of Table 3.3.2-1. The brackets indicate plant
-specific terms may apply, as reviewed and approved by the NRC.
The [Nominal Trip Setpoint (NTSP)
] specified in Table 3.3.2-1 is a predetermined setting for a protection channel chosen to ensure automatic actuation prior to the process variable reaching the Analytical Limit and thus ensuring that the SL would not be exceeded. As such, the
[NTSP] accounts for uncertainties in setting the channel (e.g., calibration), uncertainties in how the channel might actually perform (e.g.,
repeatability), changes in the point of action of the channel over time (e.g., drift during surveillance intervals), and any other factors which may influence its actual performance (e.g., harsh accident environments). In this manner, the
[NTSP] ensures that SLs are not exceeded. Therefore, the [NTSP] meets the definition of an LSSS (Ref. 1).
Technical Specifications contain values related to the OPERABILITY of equipment required for safe operation of the facility. OPERABLE is defined in Technical Specifications as "...being capable of performing its safety functions(s)." Relying solely on the
[NTSP] to define OPERABILITY in Technical Specifications would be an overly restrictive requirement if it were applied as an OPERABILITY limit for the "as-found" value of a protection channel setting during a surveillance. This would result in Technical Specification compliance problems, as well as reports and corrective actions required by the rule, which are not necessary to ensure safety. For example, an automatic protection channel with a setting that has been found to be different from the
[NTSP] due to some drift of the setting may still be OPERABLE since drift is to be expected.
This expected drift would have been specifically accounted for in the setpoint methodology for calculating the
[NTSP] and thus the automatic protective action would still have ensured that the SL would not be exceeded with the "as-found" setting of the protection channel.
3 4 4 4 4 4 4 Engineered Safety Feature Actuation System (ESFAS) Instrumentation (Without Setpoint Control Program)
B 3.3.2 A Westinghouse STS B 3.3.2 A-3 Rev. 4.0 SEQUOYAH UNIT 1 Revision XXX 1 1 2BASES BACKGROUND (continued)
Therefore, the channel would still be OPERABLE since it would have performed its safety function and the only corrective action required would be to reset the channel within the established as-left tolerance around the
[NTSP] to account for further drift during the next surveillance interval.
[Note: Alternatively, a Technical Specification format incorporating an Allowable Value only column may be proposed by a licensee. In this case, the [NTSP] value and the methodologies u sed to calculate the as
-found and as
-left tolerances must be specified in [insert the name of a document controlled under 10 CFR 50.59 such as the Technical Requirements Manual or any document incorporated into the facility FSAR]. Changes to the actual plant trip setpoint or [NTSP] value would be controlled by 10 CFR 50.59 or administratively as appropriate, and adjusted per the setpoint methodology and applicable surveillance requirements.
During Anticipated Operational Occurrences (AOOs), which are those events expected to occur one or more times during the unit life, the acceptable limits are:
- 1. The Departure from Nucleate Boiling Ratio (DNBR) shall be maintained above the SL value to prevent departure from nucleate
boiling (DNB), 2. Fuel centerline melt shall not occur, and
[2735] psig shall not be exceeded.
Operation within the SLs of Specification 2.0, "Safety Limits (SLs)," also maintains the above values and assures that offsite dose will be within the 10 CFR 50 and 10 CFR 100 criteria during AOOs.
Accidents are events that are analyzed even though they are not expected to occur during the unit life. The acceptable limit during accidents is that offsite dose shall be maintained within an acceptable fraction of 10 CFR 100 limits. Different accident categories are allowed a different fraction of these limits, based on probability of occurrence.
Meeting the acceptable dose limit for an accident category is considered having acceptable consequences for that event.
The ESFAS instrumentation is segmented into three distinct but interconnected modules as identified below:
- Field transmitters or process sensors and instrumentation: provide a measurable electronic signal based on the physical characteristics of the parameter being measured, 3 4 4 Engineered Safety Feature Actuation System (ESFAS) Instrumentation (Without Setpoint Control Program)
B 3.3.2 A Westinghouse STS B 3.3.2 A-4 Rev. 4.0 SEQUOYAH UNIT 1 Revision XXX 1 1 2BASES
BACKGROUND (continued)
- Signal processing equipment including analog protection system, field contacts, and protection channel sets: provide signal conditioning, bistable setpoint comparison, process algorithm actuation, compatible electrical signal output to protection system channels, and control board/control room/miscellaneous indications, and
- Solid State Protection System (SSPS) including input, logic, and output bays: initiates the proper unit shutdown or engineered safety feature (ESF) actuation in accordance with the defined logic and based on the bistable outputs from the signal process control and protection system.
Field Transmitters or Sensors To meet the design demands for redundancy and reliability, more than one, and often as many as four, field transmitters or sensors are used to measure unit parameters. In many cases, field transmitters or sensors that input to the ESFAS are shared with the Reactor Trip System (RTS).
In some cases, the same channels also provide control system inputs. To account for calibration tolerances and instrument drift, which are assumed to occur between calibrations, statistical allowances are
provided in the
[NTSP] and Allowable Value. The OPERABILITY of each transmitter or sensor is determined by either "as-found" calibration data evaluated during the CHANNEL CALIBRATION or by qualitative assessment of field transmitter or sensor, as related to the channel behavior observed during performance of the CHANNEL CHECK.
Signal Processing Equipment Generally, three or four channels of process control equipment are used for the signal processing of unit parameters measured by the field instruments. The process control equipment provides signal conditioning, comparable output signals for instruments located on the main control
board, and comparison of measured input signals with
[NTSPs] derived from Analytical Limits established by the safety analyses. Analytical Limits are defined in FSAR, Chapter
[6] (Ref. 2), Chapter
[7] (Ref. 3), and Chapter [15] (Ref. 4). If the measured value of a unit parameter exceeds the predetermined setpoint, an output from a bistable is forwarded to the SSPS for decision evaluation. Channel separation is maintained up to and through the input bays. However, not all unit parameters require four channels of sensor measurement and signal processing. Some unit parameters provide input only to the SSPS, while others provide input to
the SSPS, the main control board, the unit computer, and one or more control systems. analog to digital conversion (Digital Protection System), , setpoint comparator, or contact 4 U 2 2 4 4 2 2Process , setpoint comparator, or contact 2
Engineered Safety Feature Actuation System (ESFAS) Instrumentation (Without Setpoint Control Program)
B 3.3.2 A Westinghouse STS B 3.3.2 A-5 Rev. 4.0 SEQUOYAH UNIT 1 Revision XXX 1 1 2BASES
BACKGROUND (continued)
Generally, if a parameter is used only for input to the protection circuits, three channels with a two-out-of-three logic are sufficient to provide the required reliability and redundancy. If one channel fails in a direction that would not result in a partial Function trip, the Function is still OPERABLE with a two-out-of-two logic. If one channel fails such that a partial Function trip occurs, a trip will not occur and the Function is still OPERABLE with a one-out-of-two logic.
Generally, if a parameter is used for input to the SSPS and a control function, four channels with a two-out-of-four logic are sufficient to provide the required reliability and redundancy. The circuit must be able to withstand both an input failure to the control system, which may then require the protection function actuation, and a single failure in the other channels providing the protection function actuation. Again, a single failure will neither cause nor prevent the protection function actuation.
These requirements are described in IEEE-279-1971 (Ref. 5). The actual number of channels required for each unit parameter is specified in
Reference 3.
[NTSPs] and ESFAS Setpoints
[Allowable Values
] The trip setpoints used in the bistables are based on the analytical limits stated in Reference 3. The calculation of the
[NTSPs] specified in Table 3.3.2-1 is such that adequate protection is provided when all sensor and processing time delays are taken into account. To allow for calibration tolerances, instrumentation uncertainties, instrument drift, and severe environment errors for those ESFAS channels that must function in harsh environments as defined by 10 CFR 50.49 (Ref. 6), the Allowable Values specified in Table 3.3.2-1 in the accompanying LCO are conservative with respect to the analytical limits. A detailed description of the methodology used to calculate the Allowable Values and ESFAS
[NTSPs] including their explicit uncertainties, is provided in the plant specific setpoint methodology study (Ref. 7) which incorporates all of the known uncertainties applicable to each channel. The as-left tolerance and as-found tolerance band methodology is provided in [insert the name of a document controlled under 10 CFR 50.59 such as the Techni cal Requirements Manual or any document incorporated into the facility FSAR]. The magnitudes of these uncertainties are factored into the determination of each ESFAS
[NTSP] and corresponding Allowable Value. The nominal ESFAS setpoint entered into the bi stable is more conservative than that specified by the
[NTSP] to account for measurement errors detectable by the CHANNEL OPERATIONAL TEST (COT). The Allowable Value serves as the as-found Technical Specification OPERABILITY limit for the purpose of the COT.
2 4 4 4 2 4 4Allowable Value 4UFSAR Section 7.1.2 , setpoint comparators, or contacts Engineered Safety Feature Actuation System (ESFAS) Instrumentation (Without Setpoint Control Program)
B 3.3.2 A Westinghouse STS B 3.3.2 A-6 Rev. 4.0 SEQUOYAH UNIT 1 Revision XXX 1 1 2BASES
BACKGROUND (continued)
The [NTSP] is the value at which the bistables are set and is the expected value to be achieved during calibration. The
[NTSP] value is the LSSS and ensures the safety analysis limits ar e met for the surveillance interval selected when a channel is adjusted based on stated channel uncertainties. Any bistable is considered to be properly adjusted when the "as-left" [NTSP] value is within the as-left tolerance for CHANNEL CALIBRATION uncertainty allowance (i.e., + rack calibration and comparator setting uncertainties). The
[NTSP] value is therefore considered a "nominal value" (i.e., expressed as a value without inequalities) for the purposes of the COT and CHANNEL CALIBRATION.
[Nominal Trip Setpoints
], in conjunction with the use of as-found and as-left tolerances together with the requirements of the Allowable Value ensure that the consequences of Design Basis Accidents (DBAs) will be acceptable, providing the unit is operated from within the LCOs at the onset of the DBA and the equipment functions as designed.
Note that the Allowable Values listed in Table 3.3.2-1 are the least conservative value of the as-found setpoint that a channel can have during a periodic CHANNEL CALIBRATION, COT, or a TADOT.
Each channel can be tested on line to verify that the signal processing equipment and setpoint accuracy is within the specified allowance requirements of Reference 3. Once a designated channel is taken out of service for testing, a simulated signal is injected in place of the field instrument signal. The process equipment for the channel in test is then tested, verified, and calibrated. SRs for the channels are specified in the SR section.
Solid State Protection System
The SSPS equipment is used for the decision logic processing of outputs from the signal processing equipment bistables. To meet the redundancy requirements, two trains of SSPS, each performing the same functions, are provided. If one train is taken out of service for maintenance or test purposes, the second train will provide ESF actuation for the unit. If both trains are taken out of service or placed in test, a reactor trip will result.
Each train is packaged in its own cabinet for physical and electrical separation to satisfy separation and independence requirements.
The SSPS performs the decision logic for most ESF equipment actuation; generates the electrical output signals that initiate the required actuation; and provides the status, permissive, and annunciator output signals to the main control room of the unit.
or set point com parators 2 4 4 o r set point com parator 4 4 2 4, setpoint comparators, or contacts 2
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BACKGROUND (continued)
The bistable outputs from the signal processing equipment are sensed by the SSPS equipment and combined into logic matrices that represent combinations indicative of various transients. If a required logic matrix combination is completed, the system will send actuation signals via master and slave relays to those components whose aggregate Function best serves to alleviate the condition and restore the unit to a safe condition. Examples are given in the Applicable Safety Analyses, LCO, and Applicability sections of this Bases.
Each SSPS train has a built in testing device that can automatically test the decision logic matrix functions and the actuation channels while the unit is at power. When any one train is taken out of service for testing, the other train is capable of providing unit monitoring and protection until the testing has been completed. The testing device is semiautomatic to
minimize testing time.
The actuation of ESF components is accomplished through master and slave relays. The SSPS energizes the master relays appropriate for the condition of the unit. Each master relay then energizes one or more slave relays, which then cause actuation of the end devices. The master and slave relays are routinely tested to ensure operation. The test of the master relays energizes the relay, which then operates the contacts and applies a low voltage to the associated slave relays. The low voltage is not sufficient to actuate the slave relays but only demonstrates signal path continuity. The SLAVE RELAY TEST actuates the devices if their operation will not interfere with continued unit operation. For the latter case, actual component operation is prevented by the SLAVE RELAY TEST circuit, and slave relay contact operation is verified by a continuity check of the circuit containing the slave relay.
REVIEWER'S NOTE------------------------------------------
No one unit ESFAS incorporates all of the Functions listed in Table 3.3.2-1. In some cases (e.g., Containment Pressure
- High 3, Function 2.c), the Table reflects several different implementations of the same Function. Typically, only one of these implementations are used at any specific unit.
APPLICABLE Each of the analyzed accidents can be detected by one or more ESFAS SAFETY Functions. One of the ESFAS Functions is the primary actuation signal ANALYSES, LCO, for that accident. An ESFAS Function may be the primary actuation and APPLICABILITY signal for more than one type of accident. An ESFAS Function may also be a secondary, or backup, actuation signal for one or more other accidents. For example, Pressurizer Pressure - Low is a primary 3, setpoint comparator, or contact 2
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APPLICABLE SAFETY ANALYSES, LCO, and APPLICABILITY (continued)
actuation signal for small loss of coolant accidents (LOCAs) and a backup actuation signal for steam line breaks (SLBs) outside containment.
Functions such as manual initiation, not specifically credited in the accident safety analysis, are implicitly credited in the safety analysis and the NRC staff approved licensing basis for the unit. These Functions may provide protection for conditions that do not require dynamic transient analysis to demonstrate Function performance. These Functions may also serve as backups to Functions that were credited in the accident
analysis (Ref. 4).
Permissive and interlock setpoints allow the blocking of trips during plant startups, and restoration of trips when the permissive conditions are not satisfied, but they are not explicitly modeled in the Safety Analyses.
These permissives and interlocks ensure that the starting conditions are consistent with the safety analysis, before preventive or mitigating actions occur. Because these permissives or interlocks are only one of multiple conservative starting assumptions for the accident analysis, they are generally considered as nominal values without regard to measurement accuracy.
The LCO requires all instrumentation performing an ESFAS Function, listed in Table 3.3.2-1 in the accompanying LCO, to be OPERABLE. The Allowable Value specified in Table 3.3.2-1 is the least conservative value of the as-found setpoint that the channel can have when tested, such that a channel is OPERABLE if the as-found setpoint is within the as-found tolerance and is conservative with respect to the Allowable Value during the CHANNEL CALIBRATION or COT. As such, the Allowable Value differs from the
[NTSP] by an amount
[greater than or
] equal to the expected instrument channel uncertainties, such as drift, during the surveillance interval. In this manner, the actual setting of the channel
[NTSP] will ensure that a SL is not exceeded at any given point of time as long as the channel has not drifted beyond expected tolerances during the surveillance interval. Note that, although the channel is OPERABLE under these circumstances, the trip setpoint must be left adjusted to a value within the as-left tolerance, in accordance with uncertainty assumptions stated in the referenced setpoint methodology (as-left criteria), and confirmed to be operating within the statistical allowances of the uncertainty terms assigned (as-found criteria).
If the actual setting of the channel is found to be conservative with respect to the Allowable Value but is beyond the as-found tolerance band, the channel is OPERABLE, but degraded. The degraded condition of the channel will be evaluated during performance of the SR. This evaluation will consist of resetting the channel setpoint to the
[NTSP] (within the 4 4 4 Engineered Safety Feature Actuation System (ESFAS) Instrumentation (Without Setpoint Control Program)
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APPLICABLE SAFETY ANALYSES, LCO, and APPLICABILITY (continued)
allowed tolerance) and evaluating the channel response. If the channel is functioning as required and expected to pass the next surveillance, then the channel can be restored to service at the completion of the surveillance.
A trip setpoint may be set more conservative than the
[NTSP] as necessary in response to plant conditions. However, in this case, the OPERABILITY of this instrument must be verified based on the
[field setting] and not the
[NTSP]. Failure of any instrument renders the affected channel(s) inoperable and reduces the reliability of the affected Functions.
The LCO generally requires OPERABILITY of four or three channels in each instrumentation function and two channels in each logic and manual initiation function. The two-out-of-three and the two-out-of-four configurations allow one channel to be tripped during maintenance or testing without causing an ESFAS initiation. Two logic or manual initiation channels are required to ensure no single random failure disables the ESFAS.
The required channels of ESFAS instrumentation provide unit protection in the event of any of the analyzed accidents. ESFAS protection functions are as follows:
- 1. Safety Injection Safety Injection (SI) provides two primary functions:
- 1. Primary side water addition to ensure maintenance or recovery of reactor vessel water level (coverage of the active fuel for heat removal, clad integrity, and for limiting peak clad temperature to
< 2200°F), and
- 2. Boration to ensure recovery and maintenance of SDM (k eff< 1.0).
These functions are necessary to mitigate the effects of high energy line breaks (HELBs) both inside and outside of containment. The SI signal is also used to initiate other Functions such as:
- Phase A Isolation,
- Containment Purge Isolation, 4 4Ventilation 2
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APPLICABLE SAFETY ANALYSES, LCO, and APPLICABILITY (continued)
- Feedwater Isolation,
- Start of motor driven auxiliary feedwater (AFW) pumps,
- Control room ventilation isolation, and
- Enabling automatic switchover of Emergency Core Cooling Systems (ECCS) suction to containment sump.
These other functions ensure:
- Isolation of nonessential systems through containment penetrations,
- Trip of the turbine and reactor to limit power generation,
- Start of AFW to ensure secondary side cooling capability,
- Isolation of the control room to ensure habitability, and
- Enabling ECCS suction from the refueling water storage tank (RWST) switchover on low low RWST level to ensure continued cooling via use of the containment sump.
- a. Safety Injection - Manual Initiation The LCO requires one channel per train to be OPERABLE. The operator can initiate SI at any time by using either of two switches in the control room. This action will cause actuation of all components in the same manner as any of the automatic actuation signals.
The LCO for the Manual Initiation Function ensures the proper amount of redundancy is maintained in the manual ESFAS actuation circuitry to ensure the operator has manual ESFAS initiation capability.
ERCW and CCS Pump Start and System Isolation 2
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APPLICABLE SAFETY ANALYSES, LCO, and APPLICABILITY (continued)
Each channel consists of one push button and the interconnecting wiring to the actuation logic cabinet. Each push button actuates both trains. This configuration does not allow testing at power.
- b. Safety Injection - Automatic Actuation Logic and Actuation Relays This LCO requires two trains to be OPERABLE. Actuation logic consists of all circuitry housed within the actuation subsystems, including the initiating relay contacts responsible for actuating the ESF equipment.
Manual and automatic initiation of SI must be OPERABLE in MODES 1, 2, and 3. In these MODES, there is sufficient energy
in the primary and secondary systems to warrant automatic initiation of ESF systems. Manual Initiation is also required in MODE 4 even though automatic actuation is not required. In this MODE, adequate time is available to manually actuate required
components in the event of a DBA, but because of the large number of components actuated on a SI, actuation is simplified by the use of the manual actuation push buttons. Automatic actuation logic and actuation relays must be OPERABLE in MODE 4 to support system level manual initiation.
These Functions are not required to be OPERABLE in MODES 5 and 6 because there is adequate time for the operator to evaluate unit conditions and respond by manually starting individual systems, pumps, and other equipment to mitigate the consequences of an abnormal condition or accident. Unit pressure and temperature are very low and many ESF components are administratively locked out or otherwise prevented from actuating to prevent inadvertent overpressurization of unit systems.
- c. Safety Injection - Containment Pressure - High 1 This signal provides protection against the following accidents:
- SLB inside containment,
- LOCA, and
- Feed line break inside containment.
hand switch hand switches an abnormal condition or accident The two trains are redundant such that only one is necessary to perform the ESFAS Function.
2 2 2 2 2 Engineered Safety Feature Actuation System (ESFAS) Instrumentation (Without Setpoint Control Program)
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APPLICABLE SAFETY ANALYSES, LCO, and APPLICABILITY (continued)
Containment Pressure - High 1 provides no input to any control functions. Thus, three OPERABLE channels are sufficient to satisfy protective requirements with a two-out-of-three logic.
The transmitters (d/p cells) and electronics are located outside of containment with the sensing line (high pressure side of the transmitter) located inside containment.
Thus, the high pressure Function will not experience any adverse environmental conditions and the
[NTSP] reflects only steady state instrument uncertainties.
Containment Pressure - High 1 must be OPERABLE in MODES 1, 2, and 3 when there is sufficient energy in the primary and secondary systems to pressurize the containment following a pipe break. In MODES 4, 5, and 6, there is insufficient energy in the primary or secondary systems to pressurize the containment.
- d. Safety Injection - Pressurizer Pressure - Low This signal provides protection against the following accidents:
- Inadvertent opening of a steam generator (SG) relief or safety valve,
- SLB,
- A spectrum of rod cluster control assembly ejection accidents (rod ejection),
- Inadvertent opening of a pressurizer relief or safety valve,
- LOCAs, and
- SG Tube Rupture.
At some units pressurizer pressure provides both control and protection functions: input to the Pressurizer Pressure Control System, reactor trip, and SI. Therefore, the actuation logic must be able to withstand both an input failure to control system, which may then require the protection function actuation, and a single failure in the other channels providing the protection function actuation. Thus, four OPERABLE channels are required 2 2 2 2INSERT 2 B 3.3.2 Insert Page B 3.3.2-12 INSERT 2 The transmitters and electronics are located inside the containment annulus, but outside containment, and experience more adverse environmental conditions than if they were located outside containment altogether. However, the environmental effects are less severe than if the transmitters were located inside containment.
The NTSP reflects the inclusion of both steady state instrument uncertainties and slightly more adverse environmental instrument uncertainties.
2 Engineered Safety Feature Actuation System (ESFAS) Instrumentation (Without Setpoint Control Program)
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APPLICABLE SAFETY ANALYSES, LCO, and APPLICABILITY (continued) to satisfy the requirements with a two
-out-of-four logic. For units that have dedicated protection and control channels, only three protection channels are necessary to satisfy the protective
requirements.
The transmitters are located inside containment, with the taps in the vapor space region of the pressurizer, and thus possibly experiencing adverse environmental conditions (LOCA, SLB inside containment, rod ejection). Therefore, the
[NTSP] reflects the inclusion of both steady state and adverse environmental instrument uncertainties.
This Function must be OPERABLE in MODES 1, 2, and 3 (above P-11) to mitigate the consequences of an HELB inside containment. This signal may be manually blocked by the operator below the P-11 setpoint. Automatic SI actuation below this pressure setpoint is then performed by the Containment Pressure - High 1 signal.
This Function is not required to be OPERABLE in MODE 3 below the P-11 setpoint. Other ESF functions are used to detect accident conditions and actuate the ESF systems in this MODE. In MODES 4, 5, and 6, this Function is not needed for accident detection and mitigation.
- e. Safety Injection - Steam Line Pressure (1) Steam Line Pressure - Low Steam Line Pressure - Low provides protection against the following accidents:
- SLB,
- Feed line break, and
- Inadvertent opening of an SG relief or an SG safety valve. Steam Line Pressure - Low provides no input to any control functions. Thus, three OPERABLE channels on each steam line are sufficient to satisfy the protective requirements with a two-out-of-three logic on each steam line.
with a two-out-of-three logic.
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APPLICABLE SAFETY ANALYSES, LCO, and APPLICABILITY (continued)
With the transmitters typically located inside the steam
tunnels, it is possible for them to experience adverse environmental conditions during a secondary side break.
Therefore, the
[NTSP] reflects both steady state and adverse environmental instrument uncertainties.
This Function is anticipatory in nature and has a typical lead/lag ratio of 50/5.
Steam Line Pressure - Low must be OPERABLE in MODES 1, 2, and 3 (above P-11) when a secondary side break or stuck open valve could result in the rapid depressurization of the steam lines. This signal may be
manually blocked by the operator below the P-11 setpoint.
Below P-11, feed line break is not a concern. Inside
containment SLB will be terminated by automatic SI actuation via Containment Pressure - High 1 , and outside containment SLB will be terminated by the Steam Line Pressure - Negative Rate - High signal for steam line isolation. This Function is not required to be OPERABLE in MODE 4, 5, or 6 because there is insufficient energy in the secondary side of the unit to cause an accident.
(2) Steam Line Pressure
- High Differential Pressure Between Steam Lines Steam Line Pressure
- High Differential Pressure Between Steam Lines provides protection against the following accidents:
- SLB,
- Feed line break, and
- High Differential Pressure Between Steam Lines provides no input to any control fu nctions. Thus, three OPERABLE channels on each steam line are sufficient to satisfy the requirements, with a two
-out-of-three logic on each steam line.
approximately 2 2 2 4valve vaults 2
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APPLICABLE SAFETY ANALYSES, LCO, and APPLICABILITY (continued)
With the transmitters typically located inside the steam tunnels, it is possible for them to experience adverse environmental conditions during a SLB event. Therefore, the [NTSP] reflects both steady state and adverse environmental instrument uncertainties. Steam line high differential pressure must be OPERABLE in MODES 1, 2, and 3 when a secondary side break or stuck open valve could result in the rapid depressurization of the steam line(s). This Function is not required to be OPERABLE in MODE 4, 5, or 6 because there is not sufficient energy in the secondary side of the unit to cause an accident.
f, g. Safety Injection
- High Steam Flow in Two Steam Lines Coincident With Tavg - Low Low or Coincident With Steam Line Pressure - Low These Functions (1.f and 1.g) provide protection against the following accidents:
- SLB, and
- the inadvertent opening of an SG relief or an SG safety valve. Two steam line flow channels per steam line are required OPERABLE for these Functions. The steam line flow channels are combined in a one
-out-o f-two logic to indicate high steam flow in one steam line. The steam flow transmitters provide control inputs, but the control function cannot cause the events that the Function must protect against. Therefore, two channels are sufficient to satisfy redu ndancy requirements. The one
-out-of-two configuration allows online testing because trip of one high steam flow channel is not sufficient to cause initiation. High steam flow in two steam lines is acceptable in the case of a single steam line fault due to the fact that the remaining intact steam lines will pick up the full turbine load. The increased steam flow in the remaining intact lines will actuate the required second high steam flow trip. Additional protection is provided by Function 1.e.(2), High Differential Pressure Between Steam Lines. One channel of Tavg per loop and one channel of low steam line pressure per steam line are required OPERABLE. For each parameter, the channels for all loops or steam lines are 2
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APPLICABLE SAFETY ANALYSES, LCO, and APPLICABILITY (continued)
combined in a logic such that two channels tripped will cause a trip for the parameter. For example, for three loop units, the low steam line pressure channels are combined in two
-out-of- three logic. Thus, the Function trips on one
-out-of-two high flow in any two-out-of-three steam lines if there is one
-out-of-one low low Tavg trip in any two
-out-of-three RCS loops, or if there is a one
-out-of-one low pressure trip in any two
-out-of-three steam lines.
Since the accidents that this event protects against cause both low steam line pressure and low low Tavg, provision of one channel per loop or steam line ensures no single random failure can disable both of these Functions. The steam line pressure channels provide no control inputs. The Tavg channels provide control inputs, but the control function cannot initiate events that the Function acts to mitigate.
The Allowable Value for high steam flow is a linear function that varies with power level. The function is a P corresponding to 44% of full steam flow between 0% and 20% load to 114% of full steam flow at 100% load. The nominal trip setpoint is similarly calculated.
With the transmitters typically located inside the containment (Tavg) or inside the steam tunnels (High Steam Flow), it is possible for them to experience adverse steady state environmental conditions during a SLB event. Therefore, the [NTSP] reflects both steady state and adverse environmental instrument uncertainties. The Steam Line Pressure
- Low signal was discussed previously under Function 1.e.(1). This Function must be OPERABLE in MODES 1, 2, and 3 (above P-12) when a secondary side break or stuck open valve could result in the rapid depressurization of the steam line(s). This signal may be manually blocked by the operator when below the P
-12 setpoint. Above P
-12, this Function is automatically unblocked. This Function is not required OPERABLE below P
-12 because the reactor is not critical, so feed line break is not a concern. SLB may be addressed by Containment Pressure High 1 (inside containment) or by High Steam Flow in Two Steam Lines coincident with Steam Line Pressure - Low, for Steam Line Isolation, followed by High Differential Pressure Between Two Steam Lines, for SI. This Function is not required to be OPERABLE in MODE 4, 5, or 6 because there is insufficient energy in the secondary side of the unit to cause an accident.
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APPLICABLE SAFETY ANALYSES, LCO, and APPLICABILITY (continued)
- 2. Containment Spray Containment Spray provides three primary functions: 1. Lower s containment pressure and temperature after an HELB in containment
, 2. Reduces the amount of radioactive iodine in the containment atmosphere, and
.
These function s are necessary to
- Ensure the pressure boundary integrity of the containment structure ,
- Limit the release of radioactive iodine to the environment in the event of a failure of the containment structure, and
- Minimize corrosion of the components and systems inside containment following a LOCA. The containment spray actuation signal starts the containment spray pumps and aligns the discharge of the pumps to the containment spray nozzle headers in the upper levels of containment. Water is initially drawn from the RWST by the containment spray pumps and mixed with a sodium hydroxide so lution from the spray additive tank. When the RWST reaches the low low level setpoint, the spray pump suctions are shifted to the containment sump if continued containment spray is required. Containment spray is actuated manually by Containment Pressure
- High 3 or Containment Pressure - High High.
- a. Containment Spray - Manual Initiation The operator can initiate containment spray at any time from the
control room by simultaneously turning two containment spray actuation switches in the same train. Because an inadvertent actuation of containment spray could have such serious consequences, two switches must be turned simultaneously to initiate containment spray. There are two sets of two switches each in the control room. Simultaneously turning the two to This is or automaticall y Phase B & Containment Ventilation Isolation 2 2 2 2 2-Engineered Safety Feature Actuation System (ESFAS) Instrumentation (Without Setpoint Control Program)
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APPLICABLE SAFETY ANALYSES, LCO, and APPLICABILITY (continued)
switches in either set will actuate containment spray in both trains in the same manner as the automatic actuation signal.
Two Manual Initiation switches in each train are required to be OPERABLE to ensure no single failure disables the Manual Initiation Function. Note that Manual Initiation of containment spray also actuates Phase B containment isolation.
- b. Containment Spray - Automatic Actuation Logic and Actuation Relays Automatic actuation logic and actuation relays consist of the same features and operate in the same manner as described for ESFAS Function 1.b.
Manual and automatic initiation of containment spray must be OPERABLE in MODES 1, 2, and 3 when there is a potential for an accident to occur, and sufficient energy in the primary or secondary systems to pose a threat to containment integrity due to overpressure conditions. Manual initiation is also required in MODE 4, even though automatic actuation is not required. In this MODE, adequate time is available to manually actuate required components in the event of a DBA. However, because of the large number of components actuated on a containment
spray, actuation is simplified by the use of the manual actuation push buttons. Automatic actuation logic and actuation relays must be OPERABLE in MODE 4 to support system level manual initiation. In MODES 5 and 6, there is insufficient energy in the primary and secondary systems to result in containment overpressure. In MODES 5 and 6, there is also adequate time for the operators to evaluate unit conditions and respond, to mitigate the consequences of abnormal conditions by manually starting individual components.
- c. Containment Spray - Containment Pressure This signal provides protection against a LOCA or a SLB inside containment. The transmitters (d/p cells) are located outside of containment with the sensing line (high pressure side of the transmitter) located inside containment. The transmitters and electronics are located outside of containment. Thus, they will not experience any adverse environmental conditions and the [NTSP] reflects only steady state instrument uncertainties.
switches 2 2 INSERT 3but does not close the Main Steam Isolation Valves B 3.3.2 Insert Page B 3.3.2-18 INSERT 3 The transmitters and electronics are located inside the containment annulus, but outside containment, and experience more adverse environmental conditions than if they were located outside containment altogether. However, the environmental effects are less severe than if the transmitters were located inside containment.
The NTSP reflects the inclusion of both steady state instrument uncertainties and slightly more adverse environmental instrument uncertainties.
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APPLICABLE SAFETY ANALYSES, LCO, and APPLICABILITY (continued)
This is one of the only Functions that requires the bistable output to energize to perform its required action. It is not desirable to have a loss of power actuate containment spray, since the consequences of an inadvertent actuation of containment spray could be serious. Note that this Function also has the inoperable channel placed in bypass rather than trip to decrease the probability of an inadvertent actuation.
Two different logic configurations are typically used. Three and four loop units use four channels in a two-out-of-four logic configuration. This configuration may be called the Containment Pressure - High 3 Setpoint for three and four loop units, and Containment Pressure
- High High Setpoint for other units. Some two loop units use three sets of two channels, each set combined in a one
-out-of-two configuration, with these outputs combined so that two
-out-of-three sets tripped initiates containment spray. This configuration is called Containment Pressure - High 3 Setpoint.
Since containment pressure is not used for control, both of the se arrangement s exceed the minimum redundancy requirements. Additional redundancy is warranted because this Function is energized to trip. Containment Pressure -
[High 3] [High High] must be OPERABLE in MODES 1, 2, and 3 when there is sufficient energy in the primary and secondary sides to pressurize the containment following a pipe break. In MODES 4, 5, and 6, there is insufficient energy in the primary and secondary sides to pressurize the containment and reach the Containment Pressure - High 3 (High High) setpoint s. 3. Containment Isolation Containment Isolation provides isolation of the containment atmosphere, and all process systems that penetrate containment, from the environment. This Function is necessary to prevent or limit the release of radioactivity to the environment in the event of a large
break LOCA.
There are two separate Containment Isolation signals, Phase A and Phase B. Phase A isolation isolates all automatically isolable process lines, except component cooling water (CCW), at a relatively low containment pressure indicative of primary or secondary system leaks. For these types of events, forced circulation cooling using the reactor coolant pumps (RCPs) and SGs is the preferred (but not required) method of decay heat removal. Since CCW is required to support RCP operation, not isolating CCW on the low pressure This function uses This , essential raw cooling water, and control air component cooling water 2 2 4 2 2 2 s - -
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APPLICABLE SAFETY ANALYSES, LCO, and APPLICABILITY (continued)
Phase A signal enhances unit safety by allowing operators to use forced RCS circulation to cool the unit. Isolating CCW on the low pressure signal may force the use of feed and bleed cooling, which could prove more difficult to control.
Phase A containment isolation is actuated automatically by SI, or manually via the automatic actuation logic. All process lines penetrating containment, with the exception of CCW , are isolated.
CCW is not isolated at this time to permit continued operation of the RCPs with cooling water flow to the thermal barrier heat exchangers and air or oil coolers. All process lines not equipped with remote operated isolation valves are manually closed, or otherwise isolated, prior to reaching MODE 4.
Manual Phase A Containment Isolati on is accomplished by either of two switches in the control room. Either switch actuates both trains.
Note that manual actuation of Phase A Containment Isolation also actuates Containment Purge and Exhaust Isolation.
The Phase B signal isolates CCW. This occurs at a relatively high containment pressure that is indicative of a large break LOCA or a SLB. For these events, forced circulation using the RCPs is no longer desirable. Isolating the CCW at the higher pressure does not pose a challenge to the containment boundary because the CCW System is a closed loop inside containment. Although some system components do not meet all of the ASME Code requirements applied to the containment itself, the system is continuously pressurized to a pressure greater than the Phase B setpoint. Thus, routine operation demonstrates the integrity of the system pressure boundary for pressures exceeding the Phase B setpoint. Furthermore, because system pressure exceeds the Phase B setpoint, any system leakage prior to initiation of Phase B isolation would be into containment.
Therefore, the combination of CCW System design and Phase B isolation ensures the CCW System is not a potential path for radioactive release from containment.
Phase B containment isolation is actuated by Containment Pressure -
High 3 or Containment Pressure
- High High, or manually, via the automatic actuation logic, as previously discussed. For containment pressure to reach a value high enough to actuate Containment
Pressure -
High 3 or Containment Pressure
- High High, a large break LOCA or SLB must have occurred and containment spray must component cooling water, essential raw cooling water, and control air component cooling water Component cooling water component cooling water Component Cooling Water component cooling water, essential raw cooling water , and control ai r Component Cooling Water 2 2 2 2 2 2 2 2- - Ventilation 2Phase A Engineered Safety Feature Actuation System (ESFAS) Instrumentation (Without Setpoint Control Program)
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APPLICABLE SAFETY ANALYSES, LCO, and APPLICABILITY (continued)
have been actuated. RCP operation will no longer be required and CCW to the RCPs is, therefore, no longer necessary. The RCPs can be operated with seal injection flow alone and without CCW flow to the thermal barrier heat exchanger.
Manual Phase B Containment Isolation is accomplished by the same switches that actuate Containment Spray. When the two switches in either set are turned simultaneously, Phase B Containment Isolation and Containment Spray will be actuated in both trains.
- a. Containment Isolation - Phase A Isolation (1) Phase A Isolation - Manual Initiation Manual Phase A Containment Isolation is actuated by either of two switches in the control room. Either switch actuates both trains. Note that manual initiation of Phase A Containment Isolation also actuates Containment Purge Isolation.
(2) Phase A Isolation - Automatic Actuation Logic and Actuation Relays Automatic Actuation Logic and Actuation Relays consist of the same features and operate in the same manner as described for ESFAS Function 1.b.
Manual and automatic initiation of Phase A Containment Isolation must be OPERABLE in MODES 1, 2, and 3, when there is a potential for an accident to occur. Manual initiation is also required in MODE 4 even though automatic actuation is not required. In this MODE, adequate time is available to manually actuate required components in the event of a DBA , but because of the large number of components actuated on a Phase A Containment Isolation, actuation is simplified by the use of the manual actuation push buttons. Automatic actuation logic and actuation relays must be OPERABLE in MODE 4 to support system level manual initiation. In MODES 5 and 6, there is insufficient energy in the primary or secondary systems to pressurize the containment to require Phase A Containment Isolation. There also is adequate time for the operator to evaluate unit conditions and manually actuate individual isolation valves in response to abnormal or accident conditions. component cooling water an accident switches 2 2 2Ventilation 2
Engineered Safety Feature Actuation System (ESFAS) Instrumentation (Without Setpoint Control Program)
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APPLICABLE SAFETY ANALYSES, LCO, and APPLICABILITY (continued)
(3) Phase A Isolation - Safety Injection Phase A Containment Isolation is also initiated by all Functions that initiate SI. The Phase A Containment Isolation requirements for these Functions are the same as the requirements for their SI function. Therefore, the requirements are not repeated in Table 3.3.2-1. Instead, Function 1, SI, is referenced for all initiating Functions and
requirements.
- b. Containment Isolation - Phase B Isolation Phase B Containment Isolation is accomplished by Manual Initiation, Automatic Actuation Logic and Actuation Relays, and by Containment Pressure channels (the same channels that
actuate Containment Spray, Function 2). The Containment Pressure trip of Phase B Containment Isolation is energized to trip in order to minimize the potential of spurious trips that may damage the RCPs.
(1) Phase B Isolation - Manual Initiation (2) Phase B Isolation - Automatic Actuation Logic and Actuation Relays Manual and automatic initiation of Phase B containment isolation must be OPERABLE in MODES 1, 2, and 3, when there is a potential for an accident to occur. Manual initiation is also required in MODE 4 even though automatic actuation is not required. In this MODE, adequate time is available to manually actuate required components in the
event of a DBA. However, because of the large number of components actuated on a Phase B containment isolation, actuation is simplified by the use of the manual actuation push buttons. Automatic actuation logic and actuation relays must be OPERABLE in MODE 4 to support system level manual initiation. In MODES 5 and 6, there is insufficient energy in the primary or secondary systems to pressurize the containment to require Phase B containment isolation. There also is adequate time for the operator to evaluate unit conditions and manually actuate individual isolation valves in response to abnormal or accident conditions.
an accident INSERT 4 hand switches 2 2 2 B 3.3.2 Insert Page B 3.3.2-22 INSERT 4 The operator can initiate Phase B containment isolation at any time from the control room by simultaneously turning two Phase B & Containment Ventilation Isolation switches in the same train. There are two sets of two switches each in the control room. Simultaneously turning the two switches in either set will actuate Phase B containment isolation in both trains in the same manner as the automatic actuation signal. Two Manual Initiation switches in each train are required to be OPERABLE to ensure no single failure disables the Manual Initiation Function. Note that Manual Initiation of Phase B containment isolation also actuates containment spray and containment vent isolation.
2 Engineered Safety Feature Actuation System (ESFAS) Instrumentation (Without Setpoint Control Program)
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APPLICABLE SAFETY ANALYSES, LCO, and APPLICABILITY (continued)
(3) Phase B Isolation - Containment Pressure The basis for containment pressure MODE applicability is as discussed for ESFAS Function 2.c above.
- 4. Steam Line Isolation Isolation of the main steam lines provides protection in the event of a SLB inside or outside containment. Rapid isolation of the steam lines will limit the steam break accident to the blowdown from one SG, at most. For a SLB upstream of the main steam isolation valves (MSIVs), inside or outside of containment, closure of the MSIVs limits the accident to the blowdown from only the affected SG. For a SLB downstream of the MSIVs, closure of the MSIVs terminates the accident as soon as the steam lines depressurize. For units that do not have steam line check valves, Steam Line Isolation also mitigates the effects of a feed line break and ensures a source of steam for the turbine driven AFW pump during a feed line break.
- a. Steam Line Isolation - Manual Initiation Manual initiation of Steam Line Isolation can be accomplished
from the control room. There are two switches in the control room and either switch can initiate action to immediately close all MSIV s. The LCO requires two channels to be OPERABLE.
- b. Steam Line Isolation - Automatic Actuation Logic and Actuation Relays Automatic actuation logic and actuation relays consist of the same features and operate in the same manner as described for ESFAS Function 1.b.
Manual and automatic initiation of steam line isolation must be OPERABLE in MODES 1, 2, and 3 when there is sufficient energy in the RCS and SGs to have a SLB or other accident.
This could result in the release of significant quantities of energy and cause a cooldown of the primary system. The Steam Line Isolation Function is required in MODES 2 and 3 unless all MSIVs are closed and [de-activated]. In MODES 4, 5, and 6, there is insufficient energy in the RCS and SGs to experience a SLB or other accident releasing significant quantities of energy.
four each s its associatedone channel per steam line 2 2 4 Engineered Safety Feature Actuation System (ESFAS) Instrumentation (Without Setpoint Control Program)
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APPLICABLE SAFETY ANALYSES, LCO, and APPLICABILITY (continued)
- c. Steam Line Isolation - Containment Pressure - High 2 This Function actuates closure of the MSIVs in the event of a LOCA or a SLB inside containment to maintain at least one unfaulted SG as a heat sink for the reactor, and to limit the mass and energy release to containment. The transmitters (d/p cells) are located outside containment with the sensing line (high pressure side of the transmitter) located inside containment.
Containment Pressure - High 2 provides no input to any control functions. Thus, three OPERABLE channels are sufficient to satisfy protective requirements with two-out-of-three logic. However, for enhanced reliability, this Function was designed with four channels and a two-out-of-four logic.
The transmitters and electronics are located outside of containment. Thus, they w ill not experience any adverse environmental conditions, and the [NTSP] reflects only steady state instrument uncertainties.
Containment Pressure - High 2 must be OPERABLE in MODES 1, 2, and 3, when there is sufficient energy in the primary and secondary side to pressurize the containment following a pipe break. This would cause a significant increase in the containment pressure, thus allowing detection and closure of the MSIVs. The Steam Line Isolation Function remains OPERABLE in MODES 2 and 3 unless all MSIVs are closed and [de-activated]. In MODES 4, 5, and 6, there is not enough energy in the primary and secondary sides to pressurize the containment to the Containment Pressure - High 2 setpoint.
- d. Steam Line Isolation - Steam Line Pressure (1) Steam Line Pressure - Low Steam Line Pressure - Low provides closure of the MSIVs in the event of a SLB to maintain at least one unfaulted SG as a heat sink for the reactor, and to limit the mass and energy release to containment. This Function provides closure of the MSIVs in the event of a feed line break to ensure a supply of steam for the turbine driven AFW pump. Steam Line Pressure - Low was discussed previously under SI Function 1.e.1.
Steam Line Pressure - Low Function must be OPERABLE in MODES 1, 2, and 3 (above P-11), with any main steam valve open, when a secondary side break or stuck open INSERT 5 -High-High-High-High 2 2 2 2 2 4when the Steam Line Isolation on Steam LinePressure, Negative Rate-High is blocked B 3.3.2 Insert Page B 3.3.2-24 INSERT 5 The transmitters and electronics are located inside the containment annulus, but outside containment, and experience more adverse environmental conditions than if they were located outside containment altogether. However, the environmental effects are less severe than if the transmitters were located inside containment.
The NTSP reflects the inclusion of both steady state instrument uncertainties and slightly more adverse environmental instrument uncertainties.
2 Engineered Safety Feature Actuation System (ESFAS) Instrumentation (Without Setpoint Control Program)
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APPLICABLE SAFETY ANALYSES, LCO, and APPLICABILITY (continued)
valve could result in the rapid depressurization of the steam lines. This signal may be manually blocked by the operator below the P-11 setpoint. Below P-11, an inside containment SLB will be terminated by automatic actuation via Containment Pressure - High
- 2. Stuck valve transients and outside containment SLBs will be terminated by the Steam Line Pressure - Negative Rate - High signal for Steam Line Isolation below P-11 when SI has been manually blocked.
The Steam Line Isolation Function is required in MODES 2
and 3 unless all MSIVs are closed and [de-activated]. This Function is not required to be OPERABLE in MODES 4, 5, and 6 because there is insufficient energy in the secondary side of the unit to have an accident.
(2) Steam Line Pressure - Negative Rate - High Steam Line Pressure - Negative Rate - High provides closure of the MSIVs for a SLB when less than the P-11 setpoint, to maintain at least one unfaulted SG as a heat sink for the reactor, and to limit the mass and energy
release to containment. When the operator manually blocks the Steam Line Pressure - Low main steam isolation signal when less than the P-11 setpoint, the Steam Line Pressure -
Negative Rate - High signal is automatically enabled.
Steam Line Pressure - Negative Rate - High provides no input to any control functions. Thus, three OPERABLE channels are sufficient to satisfy requirements with a two-out-of-three logic on each steam line.
Steam Line Pressure - Negative Rate - High must be OPERABLE in MODE 3 when less than the P-11 setpoint, when a secondary side break or stuck open valve could result in the rapid depressurization of the steam line(s). In MODES 1 and 2, and in MODE 3, when above the P-11 setpoint, this signal is automatically disabled and the Steam Line Pressure - Low signal is automatically enabled. The Steam Line Isolation Function is required to be OPERABLE in MODES 2 and 3 unless all MSIVs are closed and [de-activated]. In MODES 4, 5, and 6, there is insufficient energy in the primary and secondary sides to have a SLB or other accident that would result in a release of significant enough quantities of energy to cause a cooldown of the RCS. -High 2 4 4 2, and the Steam Line Isolation on Steam LinePressure, Low is blocked Engineered Safety Feature Actuation System (ESFAS) Instrumentation (Without Setpoint Control Program)
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APPLICABLE SAFETY ANALYSES, LCO, and APPLICABILITY (continued)
While the transmitters may experience elevated ambient temperatures due to a SLB, the trip function is based on rate of change, not the absolute accuracy of the indicated steam pressure. Therefore, the
[NTSP] reflects only steady state instrument uncertainties.
e, f. Steam Line Isolation
- High Steam Flow in Two Steam Lines Coincident with Tavg - Low Low or Coin cident With Steam Line Pressure - Low (Three and Four Loop Units)
These Functions (4.e and 4.f) provide closure of the MSIVs during a SLB or inadvertent opening of an SG relief or a safety valve, to maintain at least one unfaulted SG as a heat sink for the reactor and to limit the mass and energy release to containment.
These Functions were discussed previously as Functions 1.f. and 1.g. These Functions must be OPERABLE in MODES 1 and 2, and in MODE 3, when a secondary side break or stuck open valve could result in the rapid depressurization of the steam lines unless all MSIVs are closed and [de
-activated]. These Functions are not required to be OPERABLE in MODES 4, 5, and 6 because there is insufficient energy in the secondary side of the unit to have an accident.
- g. Steam Line Isolation
- High Steam Flow Coincident With Safety Injection and Coincident With Tavg - Low Low (Two Loop Units)
This Function provides closure of the MSIVs during a SLB or inadvertent opening of an SG relief or safety valve to ma intain at least one unfaulted SG as a heat sink for the reactor, and to limit the mass and energy release to containment.
Two steam line flow channels per steam line are required OPERABLE for this Function. These are combined in a one
-out-of-two logic to indicate high steam flow in one steam line. The steam flow transmitters provide control inputs, but the control function cannot cause the events that the function must protect against. Therefore, two channels are sufficient to satisfy redundancy require ments. The one
-out-of-two configuration allows online testing because trip of one high steam flow channel is not sufficient to cause initiation.
2 4 Engineered Safety Feature Actuation System (ESFAS) Instrumentation (Without Setpoint Control Program)
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APPLICABLE SAFETY ANALYSES, LCO, and APPLICABILITY (continued)
The High Steam Flow Allowable Valu e is a P corresponding to 25% of full steam flow at no load steam pressure. The Trip Setpoint is similarly calculated.
With the transmitters (d/p cells) typically located inside the steam tunnels, it is possible for them to experience adverse environmental conditions during a SLB event. Therefore, the
[NTSP] reflect both steady state and adverse environmental instrument uncertainties.
The main steam line isolates only if the high steam flow signal occurs coincident with a SI and low low RCS average temperature. The Main Steam Line Isolation Function requirements for the SI Functions are the same as the requirements for their SI function. Therefore, the requirements are not repeated in Table 3.3.2-1. Instead, Function 1, SI, is referenced for all initiating functions and requirements.
Two channels of Tavg per loop are required to be OPERABLE.
The Tavg channels are combined in a logic such that two channels tripped cause a trip for the parameter. The accidents that this Function protects against cause reduction of Tavg in the entire primary system. Therefore, the provision of two OPERABLE channels per loop in a two
-out-of-four configuration ensures no single random failure disables the T avg - Low Low Function. The Tavg channels provide control inputs, but the control function cannot initiate events that the Function acts to mitigate. Therefore, additional channels are not required to address control protection interaction issues.
With the Tavg resistance temperature detectors (RTDs) located inside the containment, it is possible for them to experience adverse environmental conditions during a SLB event.
Therefore, the
[NTSP] reflects both steady state and adverse environmental instrumental uncertainties.
This Function must be OPERABLE in MODES 1 and 2, and in MODE 3, when above the P
-12 setpoint, when a secondary side break or stuck open valve could result in rapid depressurization of the steam lines. Below P
-12 this Function is not required to be OPERABLE because the High High Steam Flow coincident with SI Function provides the required protection. The Steam Line Isolation Function is required to be OPERABLE in 2
Engineered Safety Feature Actuation System (ESFAS) Instrumentation (Without Setpoint Control Program)
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APPLICABLE SAFETY ANALYSES, LCO, and APPLICABILITY (continued)
MODES 2 and 3 unless all MSIVs are closed and [de
-activated].
This Function is not required to be OPERABLE in MODES 4, 5, and 6 because there is insufficient energy in the secondary side of the unit to have an accident.
- h. Steam Line Isolation
- High High Steam Flow Coincident With Safety Injection (Two Loop Units)
This Function provides closure of the MSIVs during a steam line break (or inadvertent opening of a relief or safety valve) to maintain at least one unfaulted SG as a heat sink for the reactor, and to limit the mass and energy release to containment.
Two steam line flow channels per steam line are required to be OPERABLE for this Function. These are combined in a one
-out-of-two logic to indicate high steam flow in one steam line. The steam flow transmitters provide control inputs, but the control function cannot cause the events that the Function must protect against. Therefore, two channels are sufficient to satisfy redundancy requirements.
The Allowable Value for high steam flow is a P, corresponding to 130% of full steam flow at full steam pressure. The Trip Setpoint is similarly calculated.
With the transmitters typically located inside the steam tunnels, it is possible for them to expe rience adverse environmental conditions during a SLB event. Therefore, the
[NTSP] reflects both steady state and adverse environmental instrument uncertainties.
The main steam lines isolate only if the high steam flow signal occurs coincident with a SI signal. The Main Steam Line Isolation Function requirements for the SI Functions are the same as the requirements for their SI function. Therefore, the requirements are not repeated in Table 3.3.2-1. Instead, Function 1, SI, is referenced for all initiating functions and requirements.
This Function must be OPERABLE in MODES 1, 2, and 3 when a secondary side break or stuck open valve could result in rapid depressurization of the steam lines unless all MSIVs are closed and [de-activated]. This Function is not required to be OPERABLE in MODES 4, 5, and 6 because there is insufficient energy in the secondary side of the unit to have an accident.
2 Engineered Safety Feature Actuation System (ESFAS) Instrumentation (Without Setpoint Control Program)
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APPLICABLE SAFETY ANALYSES, LCO, and APPLICABILITY (continued)
- 5. Turbine Trip and Feedwater Isolation The primary functions of the Turbine Trip and Feedwater Isolation signals are to prevent damage to the turbine due to water in the steam lines, and to stop the excessive flow of feedwater into the SGs. These Functions are necessary to mitigate the effects of a high water level in the SGs, which could result in carryover of water into the steam lines and excessive cooldown of the primary system. The SG high water level is due to excessive feedwater flows.
The Function is actuated when the level in any SG exceeds the high high setpoint, and performs the following functions:
- Trips the main turbine,
- Trips the MFW pumps,
- Initiates feedwater isolation, and
This Function is actuated by SG Water Level - High High, or by a SI signal. The RTS also initiates a turbine trip signal whenever a reactor trip (P-4) is generated. In the event of SI, the unit is taken off line and the turbine generator must be tripped. The MFW System is also taken out of operation and the AFW System is automatically started. The SI signal was discussed previously.
- a. Turbine Trip and Feedwater Isolation - Automatic Actuation Logic and Actuation Relays Automatic Actuation Logic and Actuation Relays consist of the same features and operate in the same manner as described for ESFAS Function 1.b.
- b. Turbine Trip and Feedwater Isolation - Steam Generator Water Level - High High (P-14)
This signal provides protection against excessive feedwater flow. The ESFAS SG water level instruments provide input to the SG Water Level Control System. Therefore, the actuation logic must be able to withstand both an input failure to the control system (which may then require the protection function actuation) and a The nominal trip setpoint and allowable value limits are a percentage of the narrow range instrument span for each steam generator.
2 Engineered Safety Feature Actuation System (ESFAS) Instrumentation (Without Setpoint Control Program)
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APPLICABLE SAFETY ANALYSES, LCO, and APPLICABILITY (continued)
single failure in the other channels providing the protection function actuation.
Thus, four OPERABLE channels are required to satisfy the requirem ents with a two
-out-of-four logic. For units that have dedicated protection and control channels, only three protection channels are necessary to satisfy the protective requirements. For other units that have only three channels, a median signal selector is provided or justification is provided in NUREG-1218 (Ref.
8). The transmitters (d/p cells) are located inside containment. However, the events that this Function protects against cannot cause a severe environment in containment. Therefore, the
[NTSP] reflects only steady state instrument uncertainties.
- c. Turbine Trip and Feedwater Isolation - Safety Injection Turbine Trip and Feedwater Isolation is also initiated by all Functions that initiate SI. The Feedwater Isolation Function requirements for these Functions are the same as the requirements for their SI function. Therefore, the requirements are not repeated in Table 3.3.2-1. Instead Function 1, SI, is referenced for all initiating functions and requirements.
Turbine Trip and Feedwater Isolation Functions must be OPERABLE in MODES 1 and 2
[and 3] except when all MFIVs, MFRVs, [and associated bypass valves
] are closed and [de-activated] [or isolated by a closed manual valve
] when the MFW System is in operation and the turbine generator may be in operation. In MODES
[3,] 4, 5, and 6, the MFW System and the turbine generator are not in service and this Function is not required to be OPERABLE.
- 6. Auxiliary Feedwater The AFW System is designed to provide a secondary side heat sink for the reactor in the event that the MFW System is not available.
The system has two motor driven pumps and a turbine driven pump, making it available during normal unit operation, during a loss of AC power, a loss of MFW, and during a Feedwater System pipe break. The normal source of water for the AFW System is the condensate storage tank (CST) (normally not safety related). A low level in the CST will automatically realign the pump suctions to the Essential Service Wate r (ESW) System (safety related). The AFW System is aligned so that upon a pump start, flow is initiated to the respective SGs immediately.
because Raw Cooling Water (ERCW) pressureAFW suction line , with a two-out-o f-three lo gic, 2 2 4 4MFRV Engineered Safety Feature Actuation System (ESFAS) Instrumentation (Without Setpoint Control Program)
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APPLICABLE SAFETY ANALYSES, LCO, and APPLICABILITY (continued)
- a. Auxiliary Feedwater - Automatic Actuation Logic and Actuation Relays (Solid State Protection System)
Automatic actuation logic and actuation relays consist of the same features and operate in the same manner as described for ESFAS Function 1.b.
- Automatic Actuation Logic and Actuation Relays (Balance of Plant ESFAS)
Automatic actuation logic and actuation relays consist of the same features and operate in the same manner as described for ESFAS Function 1.b. c. Auxiliary Feedwater - Steam Generator Water Level - Low Low SG Water Level - Low Low provides protection against a loss of heat sink. A feed line break, inside or outside of containment, or a loss of MFW, would result in a loss of SG water level. SG Water Level - Low Low provides input to the SG Level Control System. Therefore, the actuation logic must be able to withstand both an input failure to the control system which may then require a protection function actuation and a single failure in the other channels providing the protection function actuation. Thus, four OPERABLE channels are required to satisfy the requirements with two
-out-of-four logic. For units that have dedicated protection and control channels, only three protection channels are necessary to satisfy the protective requirements.
For other units that have only three channels, a median signal selector is provided or justification is provided in Reference
- 8.
With the transmitters (d/p cells) located inside containment and thus possibly experiencing adverse environmental conditions (feed line break), the [NTSP] reflects the inclusion of both steady state and adverse environmental instrument uncertainties.
- d. Auxiliary Feedwater - Safety Injection A SI signal starts the motor driven and turbine driven AFW
pumps. The AFW initiation functions are the same as the requirements for their SI function. Therefore, the requirements are not repeated in Table 3.3.2-1. Instead, Function 1, SI, is referenced for all initiating functions and requirements.
- b. INSERT 6 , with a two-out-of-three logic,c. 2 2 2due to a which results INSERT 7 2 2because B 3.3.2 Insert Page B 3.3.2-31a INSERT 6 With the transmitters located inside containment and thus possibly experiencing adverse environmental conditions (due to a feedline break), the Environmental Allowance Modifier (EAM) was devised. The EAM function (Containment Pressure (EAM) with a setpoint of < 0.5 psig) senses the presence of adverse containment conditions (elevated pressure) and enables the Steam Generator Water Level - Low-Low setpoint (Adverse) which reflects the increased transmitter uncertainties due to this environment. The EAM allows the use of a
lower Steam Generator Water Level - Low-Low (EAM) setpoint when these conditions are not present, thus allowing more margin for normal operating conditions. Additionally, the NTSP reflects the inclusion of both steady state and adverse environmental instrument uncertainties.
The Trip Time Delay (TTD) creates additional operational margin when the plant needs it most, during early escalation to power, by allowing the operator time to recover level when the primary side load is sufficiently small to allow such action. The TTD is based on continuous monitoring of primary side power through the use of RCS loop T. Two time delays are calculated, based on the number of steam generators indicating less than the Low-Low Level setpoint and the primary side power level. The magnitude of the delays decreases with increasing primary side power level, up to 50% RTP. Above 50% RTP there are no time delays for the Low-Low level trips.
In the event of failure of a Steam Generator Water Level channel, it is placed in the trip condition as input to the Solid State Protection System and does not affect either the EAM or TTD setpoint calculations for the remaining OPERABLE channels. Failure of the Containment Pressure (EAM) channel to a protection set also does not affect the EAM setpoint calculations. This results in the requirement that the operator adjust the affected Steam Generator Water Level -
Low-Low (EAM) trip setpoints to the same value as the Steam Generator Water Level - Low-Low (Adverse) trip setpoints or actuate the SG Water Level Low-Low setpoint. Failure of the RCS loop T channel input (failure of more than one T H resistance temperature detectors (RTD) or failure of a T C RTD) does not affect the TTD calculation for a protection set. This results in the requirement that the operator adjust the threshold power level for zero seconds time delay from 50%
RTP to 0% RTP, through the man-machine-interface (MMI) test cart.
There are three Steam Generator Water Level Low-Low channels per steam generator arranged in a two-out-of-three logic. These channels are arranged in four protection sets with each channel of the Containment Pressure (EAM) and
RCS Loop T inputting into its associated protection set.
2 B 3.3.2 Insert Page B 3.3.2-31b INSERT 7 With the transmitters (d/p cells) located inside containment and the accidents the channel provides protection for occurring outside containment, the NTSP reflects only steady state instrument uncertainties. Because the transmitters (d/p cells) are located inside containment, thus possi bly experiencing adverse environmental conditions during a feed line break inside containment, the SG Water Level-Low Low Trip Setpoint may not have sufficient margin to account for adverse environmental instrument uncertainties; in this case, AFW pump start will be provided by a Containment Pressure-High SI signal.
2 Engineered Safety Feature Actuation System (ESFAS) Instrumentation (Without Setpoint Control Program)
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APPLICABLE SAFETY ANALYSES, LCO, and APPLICABILITY (continued)
- e. Auxiliary Feedwater - Loss of Offsite Power A loss of offsite power to the service buses will be accompanied by a loss of reactor coolant pumping power and the subsequent need for some method of decay heat removal. The loss of offsite power is detected by a voltage drop on each service bus. Loss of power to either service bus will start the turbine driven AFW pump s to ensure that at least one SG contains enough water to serve as the heat sink for reactor decay heat and sensible heat removal following the reactor trip.
Functions 6.a through 6.
e must be OPERABLE in MODES 1, 2, and 3 to ensure that the SGs remain the heat sink for the reactor.
SG Water Level - Low Low in any operating SG will cause the motor
driven AFW pumps to start. The system is aligned so that upon a start of the pump, water immediately begins to flow to the SGs.
SG Water Level - Low Low in any two operating SGs will cause the
turbine driven pump s to start. These Functions do not have to be OPERABLE in MODES 5 and 6 because there is not enough heat being generated in the reactor to require the SGs as a heat sink. In MODE 4, AFW actuation does not need to be OPERABLE because either AFW or residual heat removal (RHR) will already be in operation to remove decay heat or sufficient time is available to manually place either system in operation.
- Undervoltage Reactor Coolant Pump A loss of power on the buses that provide power to the RCPs provides indication of a pending loss of RCP forced flow in the RCS. The Undervoltage RCP Function senses the voltage downstream of each RCP breaker. A loss of power, or an open RCP breaker, on two or more RCPs, will start the turbine driven AFW pump to ensure that at least one SG contains enough water to serve as the heat sink for reactor decay heat and sensible heat removal following the reactor trip.
- g. Auxiliary Feedwater - Trip of All Main Feedwater Pumps A Trip of all MFW pumps is an indication of a loss of MFW and the subsequent need for some method of decay heat and sensible heat removal to bring the reactor back to no load temperature and pressure. A turbine driven MFW pump is
equipped with two pressure switch es on the control ai r/oil line for the speed control system. A low pressure signal from either of these pressure switch es indicates a trip of that pump.
Motor 6.9 kV Unit-boards (RCP buses)6.9 kV shutdown board
- e. AFW one this d. INSERT 8 d. 2 2 2 5 2 2 2 2 2 2 B 3.3.2 Insert Page B 3.3.2-32 INSERT 8 The loss-of-voltage relaying on the 6.9 kV shutdown board uses three solid-state voltage sensors in a two-out-of-three voltage sensor logic (27T-S1A, S1B, &
S1C) for loss-of-power detection. A two-out-three logic from the voltage sensor channels energizes two parallel separate timing relays with a one-out-of-two logic scheme (LV1 and LV2). These voltage sensors and timing relays provide emergency diesel generator start, load-shed initiation, and subsequent turbine driven auxiliary feedwater (TDAFW) pump start through separate blackout relays (BOX and BOY). A footnote has been added to clarify that this requirement only applies to shutdown board instrumentation on the same unit. This clarification removes the potential to declare the AFW loss-of-power start instrumentation inoperable for a given unit when only the opposite unit's instrumentation is inoperable. The AFW turbine-driven pump is considered OPERABLE when one train of the AFW loss of power start function is declared inoperable, in accordance with technical specifications, because both 6.9 kilovolt shutdown board logic trains supply this function.
2 Engineered Safety Feature Actuation System (ESFAS) Instrumentation (Without Setpoint Control Program)
B 3.3.2 A Westinghouse STS B 3.3.2 A-33 Rev. 4.0 SEQUOYAH UNIT 1 Revision XXX 1 1 2BASES
APPLICABLE SAFETY ANALYSES, LCO, and APPLICABILITY (continued)
driven MFW pumps are equipped with a breaker position sensing channel. An open supply breaker indicates that the pump is not running. Two OPERABLE channels per pump satisfy redundancy requirements with one
-out-of-two taken twice logic.
A trip of all MFW pumps starts the motor driven and turbine driven AFW pumps to ensure that at least one SG is available with water to act as the heat sink for the reactor.
Function s 6.f and 6.g must be OPERABLE in MODES 1 and 2. This ensures that at least one SG is provided with water to serve as the heat sink to remove reactor decay heat and sensible heat in the event of an accident. In MODES 3, 4, and 5, the RCPs and MFW pumps may be normally shut down, and thus neither pump trip is indicative of a condition requiring automatic AFW initiation.
- h. Auxiliary Feedwater - Pump Suction Transfer on Suction Pressure - Low A low pressure signal in the AFW pump suction line protects the AFW pumps against a loss of the normal supply of water for the
pumps, the CST.
Two pressure switches are located on the AFW pump suction line from the CST. A low pressure signal
sensed by any one of the switches will cause the emergency supply of water for both pump s to be aligned, or cause the AFW pumps to stop until the emergency source of water is aligned. E SW (safety grade) is then lined up to supply the AFW pumps to ensure an adequate supply of water for the AFW System to maintain at least one of the SGs as the heat sink for reactor decay heat and sensible heat removal.
Since the detectors are located in an area not affected by HELBs or high radiation, they will not experience any adverse environmental conditions and the [NTSP] reflects only steady state instrument uncertainties.
This Function must be OPERABLE in MODES 1, 2, and 3 to ensure a safety grade supply of water for the AFW System to maintain the SGs as the heat sink for the reactor. This Function does not have to be OPERABLE in MODES 5 and 6 because there is not enough heat being generated in the reactor to require the SGs as a heat sink. In MODE 4, AFW automatic suction transfer does not need to be OPERABLE because RHR will already be in operation, or sufficient time is available to place RHR in operation, to remove decay heat.
- f. RC Three two of three the INSERT 9 INSERT 10 2 5 2 2 4 5 2 2 e however bothand adverse environmental 2
B 3.3.2 Insert Page B 3.3.2-33a INSERT 9 This Function includes two footnotes. The first footnote indicates that MODE 2 applicability is limited to operation when one or more MFW pumps are supplying feedwater to the steam generators (SGs), and the second footnote provides for delaying the entry into the action statement when starting or stopping MFW pumps in MODE 1. The first footnote limits the Applicability to require the auto-start logic to be operable in MODE 2 only when at least one MFW pump is in service supplying feedwater to the SGs. Because plant conditions at the time of entry into Mode 2 do not allow the MFW pumps to operate, without this footnote the channels would need to be tripped resulting in an AFW start signal, starting the turbine-driven pump in addition to the motor-driven AFW pumps, which is an undesirable situation. This resolves a conflict between the MODE applicability and plant design, which does not support MFW pump operation at the time of entry into MODE 2. Also, modifying the requirement for auto-start of the AFW pumps to be only required when the MFW pumps are in service limits the potential for inadvertent AFW actuations during normal plant startups and shutdowns that could lead to reactivity control issues due to over cooling transients. The second footnote delays entry into the Required Action for less than minimum channels operable for up to 4 hours4.62963e-5 days <br />0.00111 hours <br />6.613757e-6 weeks <br />1.522e-6 months <br />. During the time of starting and stopping a second MFW pump, when the pump is in reset, the auto-start function is inoperable. Starting and stopping MFW pumps during plant startup and shutdown is a normal evolution, which will normally be accomplished within a short time. This note is intended to prevent unnecessary entries into the Required Actions, which provides a timeframe to correct unplanned equipment failures. For the normal operating evolution of starting and stopping pumps, the footnote allows a delay of up to 4 hours4.62963e-5 days <br />0.00111 hours <br />6.613757e-6 weeks <br />1.522e-6 months <br /> before entering the Required Action.
The evolution should be completed in less time, but the 4 hours4.62963e-5 days <br />0.00111 hours <br />6.613757e-6 weeks <br />1.522e-6 months <br /> provides a reasonable allowance for operating contingencies. If the evolution takes longer than 4 hours4.62963e-5 days <br />0.00111 hours <br />6.613757e-6 weeks <br />1.522e-6 months <br />, it is probably indicative of an equipment problem and entering the Required Action is appropriate.
5 B 3.3.2 Insert Page B 3.3.2-33b INSERT 10 g. Auxiliary Feedwater Suction Transfer Time Delays A low pressure signal in the AFW pump suction line protects the AFW pumps against a loss of the normal supply of water for the pumps, the CST. The pressure switch setpoints and the logic time delays for the AFW pump suction switchover were determined to ensure that adequate net positive suction head (NPSH) for the AFW pumps is maintained during the pump suction transfer sequence.
The available NPSH for the pumps is calculated assuming a water level in the supply header that would not be reached until after the time delays are exceeded, even when accounting for the two TDAFW timers in series.
The TDAFW pump has two timers because this pump can be switched to either of the two trains in the ERCW system: one timer is for the transfer to one of the two trains. The timers operate in sequence to assure that the TDAFW pump is transferred to one of the ERCW trains.
This Function must be OPERABLE in MODES 1, 2, and 3 to ensure a safety grade supply of water for the AFW System to maintain the SGs as the heat sink for the reactor. This Function does not have to be OPERABLE in MODES 5 and 6 because there is not enough heat being generated in the reactor to require the SGs as a heat sink. In MODE 4, AFW automatic suction transfer does not need to be OPERABLE because RHR will already be in operation, or sufficient time is available to place RHR in operation, to remove decay heat.
2 Engineered Safety Feature Actuation System (ESFAS) Instrumentation (Without Setpoint Control Program)
B 3.3.2 A Westinghouse STS B 3.3.2 A-34 Rev. 4.0 SEQUOYAH UNIT 1 Revision XXX 1 1 2BASES
APPLICABLE SAFETY ANALYSES, LCO, and APPLICABILITY (continued)
- 7. Automatic Switchover to Containment Sump At the end of the injection phase of a LOCA, the RWST will be nearly empty. Continued cooling must be provided by the ECCS to remove decay heat. The source of water for the ECCS pumps is automatically switched to the containment recirculation sump. The low head residual heat removal (RHR) pumps and containment spray pumps draw the water from the containment recirculation sump, the RHR pumps pump the water through the RHR heat exchanger, inject the water back into the RCS, and supply the cooled water to the other ECCS pumps. Switchover from the RWST to the containment sump must occur before the RWST empties to prevent damage to the RHR pumps and a loss of core cooling capability. For similar reasons, switchover must not occur before there is sufficient water in the containment sump to support ESF pump suction. Furthermore, early switchover must not occur to ensure that sufficient borated water is injected from the RWST. This ensures the reactor remains shut down in the recirculation mode.
- a. Automatic Switchover to Containment Sump - Automatic Actuation Logic and Actuation Relays Automatic actuation logic and actuation relays consist of the same features and operate in the same manner as described for ESFAS Function 1.b.
b , c. Automatic Switchover to Containment Sump - Refueling Water Storage Tank (RWST) Level - Low Low Coincident With Safety Injection and Coincident With Containment Sump Level - High During the injection phase of a LOCA, the RWST is the source of water for all ECCS pumps. A low low level in the RWST coincident with a SI signal provides protection against a loss of water for the ECCS pumps and indicates the end of the injection phase of the LOCA. The RWST is equipped with four level transmitters. These transmitters provide no control functions.
Therefore, a two-out-of-four logic is adequate to initiate the protection function actuation. Although only three channels would be sufficient, a fourth channel has been added for increased reliability.
2 2 Engineered Safety Feature Actuation System (ESFAS) Instrumentation (Without Setpoint Control Program)
B 3.3.2 A Westinghouse STS B 3.3.2 A-35 Rev. 4.0 SEQUOYAH UNIT 1 Revision XXX 1 1 2BASES
APPLICABLE SAFETY ANALYSES, LCO, and APPLICABILITY (continued)
The RWST - Low Low Allowable Value
/Trip Setpoint has both upper and lower limits. The lower limit is selected to ensure switchover occurs before the RWST empties, to prevent ECCS pump damage. The upper limit is selected to ensure enough borated water is injected to ensure the reactor remains shut down. The high limit also ensures adequate water inventory in the containment sump to provide ECCS pump suction.
The transmitters are located in an area not affected by HELBs or post accident high radiation. Thus, they will not experience any adverse environmental conditions and the
[NTSP] reflects only steady state instrument uncertainties.
Automatic switchover occurs only if the RWST low low level signal is coincident with SI. This prevents accidental switchover during normal operation. Accidental switchover could damage ECCS pumps if they are attempting to take suction from an empty sump. The automatic switchover Function requirements for the SI Functions are the same as the requirements for their SI function. Therefore, the requirements are not repeated in Table 3.3.2-1. Instead, Function 1, SI, is referenced for all initiating Functions and requirements.
REVIEWER'S NOTE-------------------------------
In some units, additional protection from spurious switchover is provided by requiring a Containment Sump Level - High signal as well as RWST Level - Low Low and SI. This ensures sufficient water is available in containment to support the recirculation phase of the accident. A Containment Sump Level - High signal must be present, in addition to the SI signal and the RWST Level - Low Low signal, to transfer the suctions of the RHR pumps to the containment sump. The containment sump is equipped with four level transmitters. These transmitters provide no control functions. Therefore, a two-out-of-four logic is adequate to initiate the protection function actuation. Although only three channels would be sufficient, a fourth channel has been added for increased reliability. The containment sump level Trip Setpoint/Allowable Value is selected to
ensure enough borated water is injected to ensure the reactor remains shut down. The high limit also ensures adequate water inventory in the containment sump to provide ECCS pump suction. The transmitters are located inside containment and thus possibly experience adverse environmental conditions. Therefore, the
[NTSP] reflects the inclusion of both steady state and environmental instrument uncertainties.
Units only have one of the Functions, 7.b or 7.c. --------------------------------------------------------------------------------------------------
containment sump tall strainer submergence.
RWST level 2 2 2 2 2 2 2 3 3 4 4 2that automatic switchover is permitted before RWST level decreases below the RWST Level - Low setpoint. This ensures an adequate suction supply to the ECCS pumps by allowing sufficient time for completion of the switchover before vortexing occurs in the RWST.
Engineered Safety Feature Actuation System (ESFAS) Instrumentation (Without Setpoint Control Program)
B 3.3.2 A Westinghouse STS B 3.3.2 A-36 Rev. 4.0 SEQUOYAH UNIT 1 Revision XXX 1 1 2BASES
APPLICABLE SAFETY ANALYSES, LCO, and APPLICABILITY (continued)
These Functions must be OPERABLE in MODES 1, 2, 3, and 4 when there is a potential for a LOCA to occur, to ensure a continued supply of water for the ECCS pumps. These Functions are not required to be OPERABLE in MODES 5 and 6 because there is adequate time for the operator to evaluate unit conditions and respond by manually starting systems, pumps, and other equipment to mitigate the consequences of an
abnormal condition or accident. System pressure and temperature are very low and many ESF components are
administratively locked out or otherwise prevented from actuating to prevent inadvertent overpressurization of unit systems.
- 8. Engineered Safety Feature Actuation System Interlocks To allow some flexibility in unit operations, several interlocks are included as part of the ESFAS. These interlocks permit the operator to block some signals, automatically enable other signals, prevent some actions from occurring, and cause other actions to occur. The interlock Functions back up manual actions to ensure bypassable functions are in operation under the conditions assumed in the safety analyses.
- a. Engineered Safety Feature Actuation System Interlocks -
Reactor Trip, P-4 The P-4 interlock is enabled when a reactor trip breaker (RTB) and its associated bypass breaker is open. Once the P-4 interlock is enabled, automatic SI initiation is blocked after a
[ ] second time delay. This Function allows operators to take manual control of SI systems after the initial phase of injection is complete. Once SI is blocked, automatic actuation of SI cannot occur until the RTBs have been manually closed. The functions of the P-4 interlock are:
- Trip the main turbine,
- Isolate MFW with coincident low Tavg ,
- Transfer the steam dump from the load rejection contro ller to the unit trip controller, and
- Prevent opening of the MFW isolation valves if they were closed on SI or SG Water Level - High High.
60 may be 2 4 and 2 6 automatic 2reactor trip breakers 2 2 Engineered Safety Feature Actuation System (ESFAS) Instrumentation (Without Setpoint Control Program)
B 3.3.2 A Westinghouse STS B 3.3.2 A-37 Rev. 4.0 SEQUOYAH UNIT 1 Revision XXX 1 1 2BASES
APPLICABLE SAFETY ANALYSES, LCO, and APPLICABILITY (continued)
Each of the above Functions is interlocked with P-4 to avert or reduce the continued cooldown of the RCS following a reactor trip. An excessive cooldown of the RCS following a reactor trip could cause an insertion of positive reactivity with a subsequent increase in generated power. To avoid such a situation, the noted Functions have been interlocked with P-4 as part of the design of the unit control and protection system.
None of the noted Functions serves a mitigation function in the unit licensing basis safety analyses. Only the turbine trip Function is explicitly assumed since it is an immediate consequence of the reactor trip Function. Neither turbine trip, nor any of the other four Functions associated with the reactor trip signal, is required to show that the unit licensing basis safety analysis acceptance criteria are not exceeded.
The RTB position switches that provide input to the P-4 interlock only function to energize or de
-energize or open or close contacts. Therefore, this Function has no adjustable trip setpoint with which to associate a
[NTSP] and Allowable Value.
This Function must be OPERABLE in MODES 1, 2, and 3 when the reactor may be critical or approaching criticality. This Function does not have to be OPERABLE in MODE 4, 5, or 6 because the main turbine, the MFW System, and the Steam Dump System are not in operation.
- b. Engineered Safety Feature Actuation System Interlocks -
Pressurizer Pressure, P-11 The P-11 interlock permits a normal unit cooldown and depressurization without actuation of SI or main steam line isolation. With two-out-of-three pressurizer pressure channels (discussed previously) less than the P-11 setpoint, the operator can manually block the Pressurizer Pressure - Low and Steam Line Pressure - Low SI signals and the Steam Line Pressure -
Low steam line isolation signal (previously discussed). When the Steam Line Pressure - Low steam line isolation signal is manually blocked, a main steam isolation signal on Steam Line Pressure - Negative Rate - High is enabled. This provides protection for a SLB by closure of the MSIVs. With two-out-of-three pressurizer pressure channels above the P-11 setpoint, the Pressurizer Pressure - Low and Steam Line Pressure - Low SI signals and the Steam Line Pressure - Low steam line isolation signal are automatically enabled. The operator can also enable There are two P-4 channels arranged in a one-out-of-one logic per channel.
2 2 4three and 2 2 2indicate reactor trip breaker Engineered Safety Feature Actuation System (ESFAS) Instrumentation (Without Setpoint Control Program)
B 3.3.2 A Westinghouse STS B 3.3.2 A-38 Rev. 4.0 SEQUOYAH UNIT 1 Revision XXX 1 1 2BASES
APPLICABLE SAFETY ANALYSES, LCO, and APPLICABILITY (continued)
these trips by use of the respective manual reset buttons. When the Steam Line Pressure
- Low steam line isolation signal is enabled, the main steam isolation on Steam Line Pressure - Negative Rate - High is disabled. The
[NTSP] reflects only steady state instrument uncertainties.
This Function must be OPERABLE in MODES 1, 2, and 3 to allow an orderly cooldown and depressurization of the unit without the actuation of SI or main steam isolation. This Function does not have to be OPERABLE in MODE 4, 5, or 6 because system pressure must already be below the P-11 setpoint for the requirements of the heatup and cooldown curves
to be met.
- c. Engineered Safety Feature Actuation System Interlocks
- T avg -Low Low, P
-12 On increasing reactor coolant temperature, the P
-12 interlock reinstates SI on High Steam Flow Coincident With Steam Line Pressure - Low or Coincident With T av g - Low Low and provides an arming signal to the Steam Dump System. On decreasing reactor coolant temperature, the P
-12 interlock allows the operator to manually block SI on High Steam Flow Coincident With Steam Line Pressure
- Low or Coincident with Tavg - Low Low. On a decreasing temperature, the P
-12 interlock also removes the arming signal to the Steam Dump System to prevent an excessive cooldown of the RCS due to a malfunctioning Steam Dump System.
Since Tavg is used as an indication of bulk RCS tem perature, this Function meets redundancy requirements with one OPERABLE channel in each loop. In three loop units, these channels are used in two
-out-of-three logic. In four loop units, they are used in two-out-of-four logic.
This Function must be OPERA BLE in MODES 1, 2, and 3 when a secondary side break or stuck open valve could result in the rapid depressurization of the steam lines. This Function does not have to be OPERABLE in MODE 4, 5, or 6 because there is insufficient energy in the secondary side of the unit to have an accident. The ESFAS instrumentation satisfies Criterion 3 of 10 CFR 50.36(c)(2)(ii).
and 2 2 4 Engineered Safety Feature Actuation System (ESFAS) Instrumentation (Without Setpoint Control Program)
B 3.3.2 A Westinghouse STS B 3.3.2 A-39 Rev. 4.0 SEQUOYAH UNIT 1 Revision XXX 1 1 2BASES
ACTIONS ----------------------------REVIEWER'S NOTE------------------------------------------
In Table 3.3.2
-1, Functions 7.b and 7.c were not included in the generic evaluations approved in either WCAP
-10271, as supplemented, WCAP-15376 or WCAP
-14333. In order to apply the WCAP
-10271, as supplemented, and WCAP
-15376 or WCAP
-14333 TS relaxations to plant specific Functions not evaluated generically, licensees must submit plant specific evaluations for NRC review and approval.
A Note has been added in the ACTIONS to clarify the application of Completion Time rules. The Conditions of this Specification may be entered independently for each Function listed on Table 3.3.2-1.
In the event a channel's
[NTSP] is found nonconservative with respect to the Allowable Value, or the channel is not functioning as required, or the transmitter, instrument Loop, signal processing electronics, or bistable is found inoperable, then all affected Functions provided by that channel must be declared inoperable and the LCO Condition(s) entered for the protection Function(s) affected. When the Required Channels in Table 3.3.2-1 are specified (e.g., on a per steam line, per loop, per SG, etc., basis), then the Condition may be entered separately for each steam line, loop, SG, etc., as appropriate.
When the number of inoperable channels in a trip function exceed those specified in one or other related Conditions associated with a trip function, then the unit is outside the safety analysis. Therefore, LCO 3.0.3 should be immediately entered if applicable in the current MODE of operation.
REVIEWER'S NOTE------------------------------------------
Certain LCO Completion Times are based on approved topical reports. In order for a licensee to use these times, the licensee must justify the Completion Times as required by the staff Safety Evaluation Report (SER) for the topical report.
A.1 Condition A applies to all ESFAS protection functions.
Condition A addresses the situation where one or more channels or trains for one or more Functions are inoperable at the same time. The Required Action is to refer to Table 3.3.2-1 and to take the Required Actions for the protection functions affected. The Completion Times are those from the referenced Conditions and Required Actions.
on a "per" basis 3 4 3 2setpoint comparator output, contact output, 2 Engineered Safety Feature Actuation System (ESFAS) Instrumentation (Without Setpoint Control Program)
B 3.3.2 A Westinghouse STS B 3.3.2 A-40 Rev. 4.0 SEQUOYAH UNIT 1 Revision XXX 1 1 2BASES
ACTIONS (continued)
B.1, B.2.1, and B.2.2 Condition B applies to manual initiation of:
- SI,
- Phase A Isolation, and
- Phase B Isolation.
This action addresses the train orientation of the SSPS for the functions listed above. If a channel or train is inoperable, 24 hours2.777778e-4 days <br />0.00667 hours <br />3.968254e-5 weeks <br />9.132e-6 months <br /> is allowed to return it to an OPERABLE status. Note that for containment spray and Phase B isolation, failure of one or both channels in one train renders the train inoperable. Condition B, therefore, encompasses both situations.
The specified Completion Time is reasonable considering that there are two automatic actuation trains and another manual initiation train OPERABLE for each Function, and the low probability of an event occurring during this interval. If the train cannot be restored to OPERABLE status, the unit must be placed in a MODE in which the LCO does not apply. This is done by placing the unit in at least MODE 3 within an additional 6 hours6.944444e-5 days <br />0.00167 hours <br />9.920635e-6 weeks <br />2.283e-6 months <br /> (54 hours6.25e-4 days <br />0.015 hours <br />8.928571e-5 weeks <br />2.0547e-5 months <br /> total time) and in MODE 5 within an additional 30 hours3.472222e-4 days <br />0.00833 hours <br />4.960317e-5 weeks <br />1.1415e-5 months <br /> (84 hours9.722222e-4 days <br />0.0233 hours <br />1.388889e-4 weeks <br />3.1962e-5 months <br /> total time). The allowable Completion Times are reasonable, based on operating experience, to reach the required unit conditions from full power conditions in an orderly manner and without challenging unit systems.
C.1, C.2.1, and C.2.2
Condition C applies to the automatic actuation logic and actuation relays for the following functions:
- SI,
- Phase A Isolation,
- Phase B Isolation , and
- Automatic Switchover to Containment Sump
. 48 2 and Engineered Safety Feature Actuation System (ESFAS) Instrumentation (Without Setpoint Control Program)
B 3.3.2 A Westinghouse STS B 3.3.2 A-41 Rev. 4.0 SEQUOYAH UNIT 1 Revision XXX 1 1 2BASES
ACTIONS (continued)
This action addresses the train orientation of the SSPS and the master and slave relays. If one train is inoperable, 24 hours2.777778e-4 days <br />0.00667 hours <br />3.968254e-5 weeks <br />9.132e-6 months <br /> are allowed to restore the train to OPERABLE status. The 24 hours2.777778e-4 days <br />0.00667 hours <br />3.968254e-5 weeks <br />9.132e-6 months <br /> allowed for restoring the inoperable train to OPERABLE status is justified in Reference 9. The specified Completion Time is reasonable considering that there is another train OPERABLE, and the low probability of an event occurring during this interval. If the train cannot be restored to OPERABLE status, the unit must be placed in a MODE in which the LCO does not apply. This is done by placing the unit in at least MODE 3 within an additional 6 hours6.944444e-5 days <br />0.00167 hours <br />9.920635e-6 weeks <br />2.283e-6 months <br /> (30 hours3.472222e-4 days <br />0.00833 hours <br />4.960317e-5 weeks <br />1.1415e-5 months <br /> total time) and in MODE 5 within an additional 30 hours3.472222e-4 days <br />0.00833 hours <br />4.960317e-5 weeks <br />1.1415e-5 months <br /> (60 hours6.944444e-4 days <br />0.0167 hours <br />9.920635e-5 weeks <br />2.283e-5 months <br /> total time). The Completion Times are reasonable, based on operating experience, to reach the required unit conditions from full power conditions in an orderly manner and without challenging unit systems.
The Required Actions are modified by a Note that allows one train to be bypassed for up to
[4] hours for surveillance testing, provided the other train is OPERABLE. This allowance is based on the reliability analysis assumption of WCAP-10271-P-A (Ref. 10) that 4 hours4.62963e-5 days <br />0.00111 hours <br />6.613757e-6 weeks <br />1.522e-6 months <br /> is the average time required to perform train surveillance.
D.1, D.2.1, and D.2.2
Condition D applies to:
- Containment Pressure - High 1 ,
- Pressurizer Pressure - Low (two, three, and four loop units),
- Steam Line Pressure - Low,
- Steam Line Differential Pressure
- High,
- High Steam Flow in Two Steam Lines Coincident With Tavg - Low Low or Coincident With Steam Line Pressure
- Low ,
- Containment Pressure
- High 2 ,
- Steam Line Pressure - Negative Rate - High,
- High Steam Flow Coincident With Safety Injection Coincident With Tavg - Low Low , 2 2 2 2 4 Engineered Safety Feature Actuation System (ESFAS) Instrumentation (Without Setpoint Control Program)
B 3.3.2 A Westinghouse STS B 3.3.2 A-42 Rev. 4.0 SEQUOYAH UNIT 1 Revision XXX 1 1 2BASES
ACTIONS (continued)
- High High Steam Flow Coincident With Safety Injection,
- High Steam Flow in Two Steam Lines Coincident With Tavg - Low Low,
- SG Water level
- Low Low (two, three, and four loop units), and * [SG Water level - High High (P-14) (two, three, and four loop units). ]
If one channel is inoperable, 72 hours8.333333e-4 days <br />0.02 hours <br />1.190476e-4 weeks <br />2.7396e-5 months <br /> are allowed to restore the channel to OPERABLE status or to place it in the tripped condition. Generally this Condition applies to functions that operate on two-out-of-three logic.
Therefore, failure of one channel places the Function in a two-out-of-two configuration. One channel must be tripped to place the Function in a one-out-of-three configuration that satisfies redundancy requirements. The 72 hours8.333333e-4 days <br />0.02 hours <br />1.190476e-4 weeks <br />2.7396e-5 months <br /> allowed to restore the channel to OPERABLE status or to place it in the tripped condition is justified in Reference 9.
Failure to restore the inoperable channel to OPERABLE status or place it in the tripped condition within 72 hours8.333333e-4 days <br />0.02 hours <br />1.190476e-4 weeks <br />2.7396e-5 months <br /> requires the unit be placed in MODE 3 within the following 6 hours6.944444e-5 days <br />0.00167 hours <br />9.920635e-6 weeks <br />2.283e-6 months <br /> and MODE 4 within the next 6 hours6.944444e-5 days <br />0.00167 hours <br />9.920635e-6 weeks <br />2.283e-6 months <br />.
The allowed Completion Times are reasonable, based on operating experience, to reach the required unit conditions from full power conditions in an orderly manner and without challenging unit systems. In MODE 4, these Functions are no longer required OPERABLE.
[ The Required Actions are modified by a Note that allows the inoperable channel to be bypassed for up to 12 hours1.388889e-4 days <br />0.00333 hours <br />1.984127e-5 weeks <br />4.566e-6 months <br /> for surveillance testing of other channels. The 12 hours1.388889e-4 days <br />0.00333 hours <br />1.984127e-5 weeks <br />4.566e-6 months <br /> allowed for testing, are justified in Reference 9.
]
REVIEWER'S NOTE
The below text should be used for plants with installed bypass test capability:
The Required Actions are modified by a Note that allows placing one channel in bypass for up to 12 hours1.388889e-4 days <br />0.00333 hours <br />1.984127e-5 weeks <br />4.566e-6 months <br /> while performing routine surveillance testing. The 12 hour1.388889e-4 days <br />0.00333 hours <br />1.984127e-5 weeks <br />4.566e-6 months <br /> time limit is justified in Reference
- 9. --------------------------------------------------------------------------------------------------
two 3 2 2 4 4 4 Engineered Safety Feature Actuation System (ESFAS) Instrumentation (Without Setpoint Control Program)
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ACTIONS (continued)
E.1, E.2.1, and E.2.2 Condition E applies to:
- Containment Spray Containment Pressure -
High 3 (High , High) (two, three, and four loop units), and
- Containment Phase B Isolation Containment Pressure -
High 3 (High , High).
None of these signals has input to a control function. Thus, two-out-of-three logic is necessary to meet acceptable protective requirements.
However, a two-out-of-three design would require tripping a failed channel. This is undesirable because a single failure would then cause spurious containment spray initiation. Spurious spray actuation is undesirable because of the cleanup problems presented. Therefore, these channels are designed with two-out-of-four logic so that a failed channel may be bypassed rather than tripped. Note that one channel may be bypassed and still satisfy the single failure criterion. Furthermore, with one channel bypassed, a single instrumentation channel failure will not spuriously initiate containment spray.
To avoid the inadvertent actuation of containment spray and Phase B containment isolation, the inoperable channel should not be placed in the tripped condition. Instead it is bypassed. Restoring the channel to OPERABLE status, or placing the inoperable channel in the bypass condition within 72 hours8.333333e-4 days <br />0.02 hours <br />1.190476e-4 weeks <br />2.7396e-5 months <br />, is sufficient to assure that the Function remains OPERABLE and minimizes the time that the Function may be in a partial trip condition (assuming the inoperable channel has failed high). The Completion Time is further justified based on the low probability of an event occurring during this interval. Failure to restore the inoperable channel to OPERABLE status, or place it in the bypassed condition within 6 hours6.944444e-5 days <br />0.00167 hours <br />9.920635e-6 weeks <br />2.283e-6 months <br />, requires the unit be placed in MODE 3 within the following 6 hours6.944444e-5 days <br />0.00167 hours <br />9.920635e-6 weeks <br />2.283e-6 months <br /> and MODE 4 within the next 72 hours8.333333e-4 days <br />0.02 hours <br />1.190476e-4 weeks <br />2.7396e-5 months <br />. The allowed Completion Times are reasonable, based on operating experience, to reach the required unit conditions from full power conditions in an orderly manner and without challenging unit systems. In MODE 4, these Functions are no longer required OPERABLE.
[ The Required Actions are modified by a Note that allows one additional channel to be bypassed for up to 12 hours1.388889e-4 days <br />0.00333 hours <br />1.984127e-5 weeks <br />4.566e-6 months <br /> for surveillance testing. Placing a second channel in the bypass condition for up to 12 hours1.388889e-4 days <br />0.00333 hours <br />1.984127e-5 weeks <br />4.566e-6 months <br /> for testing purposes is acceptable based on the results of Reference 9.
] 72 6 2 2 4 4 Steam Line Isolation Containment Pressure - High-High - , and Engineered Safety Feature Actuation System (ESFAS) Instrumentation (Without Setpoint Control Program)
B 3.3.2 A Westinghouse STS B 3.3.2 A-44 Rev. 4.0 SEQUOYAH UNIT 1 Revision XXX 1 1 2BASES
ACTIONS (continued)
REVIEWER'S NOTE------------------------------------------
The below text should be used for plants with installed bypass test capability:
The Required Actions are modified by a Note that allows placing one channel in bypass for up to 12 hours1.388889e-4 days <br />0.00333 hours <br />1.984127e-5 weeks <br />4.566e-6 months <br /> while performing routine surveillance testing. The 12 hour1.388889e-4 days <br />0.00333 hours <br />1.984127e-5 weeks <br />4.566e-6 months <br /> time limit is justified in Reference 9.
F.1, F.2.1, and F.2.2 Condition F applies to
- Manual Initiation of Steam Line Isolation,
- Loss of Offsite Power,
- Auxiliary Feedwater Pump Suction Transfer on Suction Pressure
- Low, and
- P-4 Interlock.
For the Manual Initiation and the P-4 Interlock Function s, this action addresses the train orientation of the SSPS. For the Loss of Offsite Power Function, this action recognizes the lack of manual trip provision for a failed channel.
For the AFW System pump suction transfer channels, this action recognizes that placing a failed channel in trip during operation is not necessarily a conservative action. Spurious trip of this function could align the AFW System to a source that is not immediately capable of supporting pump suction. If a train or channel is inoperable, 48 hours5.555556e-4 days <br />0.0133 hours <br />7.936508e-5 weeks <br />1.8264e-5 months <br /> is allowed to return it to OPERABLE status. The specified Completion Time is reasonable considering the nature of the se Function s , the available redundancy, and the low probability of an event occurring during this interval. If the Function cannot be returned to OPERABLE status, the unit must be placed in MODE 3 within the next 6 hours6.944444e-5 days <br />0.00167 hours <br />9.920635e-6 weeks <br />2.283e-6 months <br /> and MODE 4 within the following 6 hours6.944444e-5 days <br />0.00167 hours <br />9.920635e-6 weeks <br />2.283e-6 months <br />. The allowed Completion Times are reasonable, based on operating experience, to reach the required unit conditions from full power in an orderly manner and without challenging unit systems. In MODE 4, the unit does not have any analyzed transients or conditions that require the explicit use of the protection functions noted
above.
3 2 2 2 2 INSERT 11 G G 2 2the B 3.3.2 Insert Page B 3.3.2-44 INSERT 11 F.1 and F.2
Condition F applies to the Steam Line Isolation, Manual Initiation ESFAS Function.
If a train or channel is inoperable, 48 hours5.555556e-4 days <br />0.0133 hours <br />7.936508e-5 weeks <br />1.8264e-5 months <br /> is allowed to return it to OPERABLE status. The specified Completion Time is reasonable considering the nature of this Function, the available redundancy, and the low probability of an event occurring during this interval. If the Function cannot be returned to OPERABLE status, the associate MSIV is declared inoperable and the associated Required Actions followed for an inoperable MSIV.
2 Engineered Safety Feature Actuation System (ESFAS) Instrumentation (Without Setpoint Control Program)
B 3.3.2 A Westinghouse STS B 3.3.2 A-45 Rev. 4.0 SEQUOYAH UNIT 1 Revision XXX 1 1 2BASES
ACTIONS (continued)
G.1, G.2.1, and G.2.2 Condition G applies to the automatic actuation logic and actuation relays for the Steam Line Isolation
[Turbine Trip and Feedwater Isolation,] and AFW actuation Functions.
The action addresses the train orientation of the SSPS and the master and slave relays for these functions. If one train is inoperable, 24 hours2.777778e-4 days <br />0.00667 hours <br />3.968254e-5 weeks <br />9.132e-6 months <br /> are allowed to restore the train to OPERABLE status. The 24 hours2.777778e-4 days <br />0.00667 hours <br />3.968254e-5 weeks <br />9.132e-6 months <br /> allowed for restoring the inoperable train to OPERABLE status is justified in Reference 9. The Completion Time for restoring a train to OPERABLE status is reasonable considering that there is another train OPERABLE, and the low probability of an event occurring during this interval. If the train cannot be returned to OPERABLE status, the unit must be brought to MODE 3 within the next 6 hours6.944444e-5 days <br />0.00167 hours <br />9.920635e-6 weeks <br />2.283e-6 months <br /> and MODE 4 within the following 6 hours6.944444e-5 days <br />0.00167 hours <br />9.920635e-6 weeks <br />2.283e-6 months <br />. The allowed Completion Times are reasonable, based on operating experience, to reach the required unit conditions from full power conditions in an orderly manner and without challenging unit systems. Placing the unit in MODE 4 removes all requirements for OPERABILITY of the protection channels and actuation functions. In this MODE, the unit does not have analyzed transients or conditions that require the explicit use of the protection functions noted above.
The Required Actions are modified by a Note that allows one train to be
bypassed for up to
[4] hours for surveillance testing provided the other train is OPERABLE. This allowance is based on the reliability analysis (Ref. 10) assumption that 4 hours4.62963e-5 days <br />0.00111 hours <br />6.613757e-6 weeks <br />1.522e-6 months <br /> is the average time required to perform channel surveillance.
[ H.1 and H.2 Condition H applies to the automatic actuation logic and actuation relays for the Turbine Trip and Feedwater Isolation Function.
This action addresses the train orientation of the SSPS and the master and slave relays for this Function. If one train is inoperable, 24 hours2.777778e-4 days <br />0.00667 hours <br />3.968254e-5 weeks <br />9.132e-6 months <br /> are allowed to restore the train to OPERABLE status or the unit must be placed in MODE 3 within the following 6 hours6.944444e-5 days <br />0.00167 hours <br />9.920635e-6 weeks <br />2.283e-6 months <br />. The 24 hours2.777778e-4 days <br />0.00667 hours <br />3.968254e-5 weeks <br />9.132e-6 months <br /> allowed for restoring the inoperable train to OPERABLE status is justified in Reference
- 9. The Completion Time for restoring a train to OPERABLE status is reasonable considering that there is another train OPERABLE, and the low probability of an event occurring during this interval. The allowed Completion Time of 6 hours6.944444e-5 days <br />0.00167 hours <br />9.920635e-6 weeks <br />2.283e-6 months <br /> is reasonable, based on operating experience, to reach MODE 3 from full power conditions in an orderly 2 4 4 H H 2 Engineered Safety Feature Actuation System (ESFAS) Instrumentation (Without Setpoint Control Program)
B 3.3.2 A Westinghouse STS B 3.3.2 A-46 Rev. 4.0 SEQUOYAH UNIT 1 Revision XXX 1 1 2BASES
ACTIONS (continued)
manner and without challenging unit systems. These Functions are no longer required in MODE
- 3. Placing the unit in MODE 3 removes all requirements for OPERABILITY of the protection channels and actuation functions. In this MODE, the unit does not have analyzed transients or conditions that require the explicit use of the protection functions noted above.
The Required Actions are modified by a Note that allows one train to be bypassed for up to [4]
hours for surveillance testing provided the other train is OPERABLE. This allowance is based on the reliability analysis (Ref. 10) assumption that 4 hours4.62963e-5 days <br />0.00111 hours <br />6.613757e-6 weeks <br />1.522e-6 months <br /> is the average time required to perform channel surveillance.
] I.1 and I.2 Condition I applies to:
- [ SG Water Level - High High (P
-14) (two, three, and four loop units), and ]
- Undervoltage Reactor Coolant Pump.
If one channel is inoperable, 72 hours8.333333e-4 days <br />0.02 hours <br />1.190476e-4 weeks <br />2.7396e-5 months <br /> are allowed to restore one channel to OPERABLE status or to place it in the tripped condition. If placed in the tripped condition, the Function is then in a partial trip condition where one-out-of-two or one
-out-of-three logic will result in actuation. Failure to restore the inoperable channel to OPERAB LE status or place it in the tripped condition within 72 hours8.333333e-4 days <br />0.02 hours <br />1.190476e-4 weeks <br />2.7396e-5 months <br /> requires the unit to be placed in MODE 3 within the following 6 hours6.944444e-5 days <br />0.00167 hours <br />9.920635e-6 weeks <br />2.283e-6 months <br />. The allowed Completion Time of 78 hours9.027778e-4 days <br />0.0217 hours <br />1.289683e-4 weeks <br />2.9679e-5 months <br /> is reasonable, based on operating experience, to reach MODE 3 from full power conditions in an orderly manner and without challenging unit system s. In MODE 3, these Functions are no longer required OPERABLE. [ The Required Actions are modified by a Note that allows the inoperable channel to be bypassed for up to [12]
hours for surveillance testing of other channels. The 72 hours8.333333e-4 days <br />0.02 hours <br />1.190476e-4 weeks <br />2.7396e-5 months <br /> allowed to place the inoperable channel in the tripped condition, and the 12 hours1.388889e-4 days <br />0.00333 hours <br />1.984127e-5 weeks <br />4.566e-6 months <br /> allowed for a second channel to be in the bypassed condition for testing, are justified in Reference
- 9. ] 2 Engineered Safety Feature Actuation System (ESFAS) Instrumentation (Without Setpoint Control Program)
B 3.3.2 A Westinghouse STS B 3.3.2 A-47 Rev. 4.0 SEQUOYAH UNIT 1 Revision XXX 1 1 2BASES
ACTIONS (continued)
REVIEWER'S NOTE------------------------------------------
The below text should be used for plants with installed bypass test capability:
The Required Actions are modified by a Note that allows placing one channel in bypass for up to 12 hours1.388889e-4 days <br />0.00333 hours <br />1.984127e-5 weeks <br />4.566e-6 months <br /> while performing routine surveillance testing. The 72 hours8.333333e-4 days <br />0.02 hours <br />1.190476e-4 weeks <br />2.7396e-5 months <br /> allowed to place the inoperable channel in the tripped condition, and the 12 hours1.388889e-4 days <br />0.00333 hours <br />1.984127e-5 weeks <br />4.566e-6 months <br /> allowed for a second channel to be in the bypassed condition for testing, are justified in Reference
- 9. --------------------------------------------------------------------------------------------------
J.1 and J.2 Condition J applies to the AFW pump start on trip of all MFW pumps.
This action addresses the train orientation of the SSPS for the auto start function of the AFW System on loss of all MFW pumps. The OPERABILITY of the AFW System must be assured by allowing automatic start of the AFW System pumps. If a channel is inoperable, 48 hours5.555556e-4 days <br />0.0133 hours <br />7.936508e-5 weeks <br />1.8264e-5 months <br /> are allowed to return it to an OPERABLE status. If the function cannot be returned to an OPERABLE status, 6 hours6.944444e-5 days <br />0.00167 hours <br />9.920635e-6 weeks <br />2.283e-6 months <br /> are allowed to place the unit in MODE 3. The allowed Completion Time of 6 hours6.944444e-5 days <br />0.00167 hours <br />9.920635e-6 weeks <br />2.283e-6 months <br /> is reasonable, based on operating experience, to reach MODE 3 from full power conditions in an orderly manner and without challenging unit systems. In MODE 3, the unit does not have any analyzed transients or conditions that require the explicit use of the protection function noted above. The allowance of 48 hours5.555556e-4 days <br />0.0133 hours <br />7.936508e-5 weeks <br />1.8264e-5 months <br /> to return the train to an OPERABLE status is justified in Reference 10.
K.1, K.2.1, and K.2.2 Condition K applies to
- RWST Level
- Low Low Coincident with Safety Injection, and
- RWST Level - Low Low Coincident with Safety Injection and Coincident with Containment Sump Level - High.
RWST Level - Low Low Coincident With SI and Coincident With Containment Sump Level - High provides actuation of switchover to the containment sump. Note that this Function requires the bistables to energize to perform their required action. The failure of up to two channels will not prevent the operation of this Function. However, placing N N P P 3 2 2 2 2 2 2 INSERT 12INSERT 13 INSERT 14 INSERT 15 INSERT 16 5 2 2comparators 2 the B 3.3.2 Insert Page B 3.3.2-47a INSERT 12 I.1 and I.2
Condition I applies to the following ESFAS Functions:
- Steam Generator Water Level--Low-Low (Adverse), and
- Steam Generator Water Level--Low-Low (EAM)
A known inoperable channel must be placed in the tripped condition within 6 hours6.944444e-5 days <br />0.00167 hours <br />9.920635e-6 weeks <br />2.283e-6 months <br />. Placing the channel in the tripped condition results in a partial trip condition requiring only one-out-of-two logic for actuation of the two-out-of-three trips.
In addition to placing the channel in the tripped condition, it is necessary to force the use of the shorter TTD by adjustment of the single steam generator time delay calculation (T S) to match the multiple steam generator time delay calculation (T M) for the affected protection set within 4 hours4.62963e-5 days <br />0.00111 hours <br />6.613757e-6 weeks <br />1.522e-6 months <br />.
The Required Actions have been modified by a Note that allows placing the inoperable channel in the bypassed condition for up to 4 hours4.62963e-5 days <br />0.00111 hours <br />6.613757e-6 weeks <br />1.522e-6 months <br /> while performing routine surveillance testing of the other channels.
2 B 3.3.2 Insert Page B 3.3.2-47b INSERT 13 J.1, J.2, J.3.1, and J.3.2 Condition J applies to the Containment Pressure (EAM) coincidence with Steam
Generator Water Level--Low-Low (Adverse) ESFAS Function.
Failure of the Containment Pressure (EAM) channel to a protection set does not affect the EAM setpoint calculations. A known inoperable Containment Pressure channel results in the requirement to adjust the affected Steam Generator Water Level - Low-Low (EAM) trip setpoints for the affected protection set to the same value as the Steam Generator Water Level - Low-Low (Adverse) trip setpoint within 6 hours6.944444e-5 days <br />0.00167 hours <br />9.920635e-6 weeks <br />2.283e-6 months <br />.
An alternative to adjusting the affected Steam Generator Water Level - Low-Low (EAM) trip setpoints to the same value as the Steam Generator Water Level -
Low-Low (Adverse) trip setpoints is to place the associated protection set's SG Water Level Low-Low channels in the tripped condition within 6 hours6.944444e-5 days <br />0.00167 hours <br />9.920635e-6 weeks <br />2.283e-6 months <br />.
If neither of the above Required Actions are completed within their associated Completion Time, then the unit must be placed in a MODE where these Functions are not required OPERABLE. This requires the unit be placed in MODE 3 within 12 hours1.388889e-4 days <br />0.00333 hours <br />1.984127e-5 weeks <br />4.566e-6 months <br /> and MODE 4 within 18 hours2.083333e-4 days <br />0.005 hours <br />2.97619e-5 weeks <br />6.849e-6 months <br />. The allowed Completion Times are reasonable to reach the required unit conditions from full power conditions in an orderly manner and without challenging unit systems. In MODE 4, these Functions are no longer required OPERABLE.
2 2 5 B 3.3.2 Insert Page B 3.3.2-47c INSERT 14 K.1, K.2, K.3.1, and K.3.2 Condition K applies to the RCS Loop T coincidence with SG Water Level - Low-Low.
Failure of the RCS loop T channel input (failure of more than one T H RTD or failure of a T C RTD) does not affect the TTD calculation for a protection set. This results in the requirement that the operator adjust the threshold power level for zero seconds time delay from 50% RTP to 0% RTP within 6 hours6.944444e-5 days <br />0.00167 hours <br />9.920635e-6 weeks <br />2.283e-6 months <br />. With the trip time delay adjusted to zero seconds the additional operational margin that allows the operator time to recover SG level is removed.
An alternative to adjusting the threshold power level for zero seconds time delay is to place the affected protection set's SG Water Level Low-Low level channels in the tripped condition within 6 hours6.944444e-5 days <br />0.00167 hours <br />9.920635e-6 weeks <br />2.283e-6 months <br />.
If neither of the above Required Actions can be completed within their associated Completion Times then the unit must be placed in a MODE where these Functions are not required OPERABLE. This requires the unit be placed in MODE 3 within 12 hours1.388889e-4 days <br />0.00333 hours <br />1.984127e-5 weeks <br />4.566e-6 months <br /> and MODE 4 within 18 hours2.083333e-4 days <br />0.005 hours <br />2.97619e-5 weeks <br />6.849e-6 months <br />. The allowed Completion Times are reasonable to reach the required unit conditions from full power conditions in an orderly manner and without challenging unit systems. In MODE 4, these Functions are no longer required OPERABLE.
2 5 B 3.3.2 Insert Page B 3.3.2-47d INSERT 15 L.1 and L.2
Condition L applies to the Loss of Voltage sensors associated with the Loss of Power AFW pump start ESFAS Function. These are the same sensors for the DG loss of Voltage start.
This function is provided by voltage sensors for each train arranged in a two-out-of-three logic scheme. If a sensor is inoperable, 6 hours6.944444e-5 days <br />0.00167 hours <br />9.920635e-6 weeks <br />2.283e-6 months <br /> is allowed to return it to OPERABLE status.
If the inoperable sensor cannot be restored to OPERABLE status within the specified Completion Time, the associated AFW pump must be declared inoperable. The TDAFW pump is considered OPERABLE when at least one train of the AFW loss of power start function is OPERABLE because both 6.9 kV shutdown board logic trains supply this function.
M.1.1, M.1.2, and M.2 Condition M applies to the Loss of Voltage sensors and load shed timers associated with the Loss of Power AFW pump start ESFAS Function. These are the same sensors and timers for the DG loss of Voltage start.
This function is provided by voltage sensors for each train arranged in a two-out-of-three logic scheme with associated load shed timers arranged in a one-out-of-two logic. If two or more voltage sensors or one required load shed timer are inoperable, 1 hour1.157407e-5 days <br />2.777778e-4 hours <br />1.653439e-6 weeks <br />3.805e-7 months <br /> is allowed to return the inoperable channel(s) to OPERABLE status. If the inoperable sensors cannot be made OPERABLE such that only one sensor is inoperable or one required load shed timer cannot be made OPERABLE within the specified Completion Time, the associated auxiliary feedwater pump must be declared inoperable. The AFW turbine-driven pump is considered OPERABLE when at least one train of the AFW loss of power start function is OPERABLE because both 6.9 kV shutdown board logic trains supply this function.
2 B 3.3.2 Insert Page B 3.3.2-47e INSERT 16 The Required Actions are modified by a not e delaying the entry into the Required Action statement when starting or stopping MFW pumps. Starting and stopping MFW pumps during plant startup and shutdown is a normal evolution, which will normally be accomplished within a short time. It was not intended to result in unnecessary entries into the Required Actions, which provides a timeframe to correct unplanned equipment failures. The 4 hours4.62963e-5 days <br />0.00111 hours <br />6.613757e-6 weeks <br />1.522e-6 months <br /> is consistent with similar allowances in other SQN TSs.
O.1 Condition O applies to the following ESFAS Functions:
- Auxiliary Feedwater Pump Suction Transfer on Suction Pressure - Low,*Auxiliary Feedwater Suction Transfer Time Delays, Motor-Driven Pump, and*Auxiliary Feedwater Suction Transfe r Time Delays, Turbine-Driven Pump.
These functions are provided by three pressure sensors located on the suction of each AFW pump arranged in a two-out-of-three logic scheme. The motor driven AFW pumps have one time delay, while the TDAFW pump has two. The motor driven and the first TDAFW pump time delays prevent spurious transfer. The TDAFW Pump second time delay ensures ERCW Train A valves stroke open sufficiently. If a pressure sensor channel or a time delay channel is inoperable, the associated AFW pump must be declared inoperable immediately.
7 2 Engineered Safety Feature Actuation System (ESFAS) Instrumentation (Without Setpoint Control Program)
B 3.3.2 A Westinghouse STS B 3.3.2 A-48 Rev. 4.0 SEQUOYAH UNIT 1 Revision XXX 1 1 2BASES ACTIONS (continued) a failed channel in the tripped condition could result in a premature switchover to the sump, prior to the injection of the minimum volume from the RWST. Placing the inoperable channel in bypass results in a two-out-of-three logic configuration, which satisfies the requirement to allow another failure without disabling actuation of the switchover when required. Restoring the channel to OPERABLE status or placing the inoperable channel in the bypass condition within
[6] hours is sufficient to ensure that the Function remains OPERABLE, and minimizes the time that the Function may be in a partial trip condition (assuming the inoperable channel has failed high). The
[6] hour Completion Time is justified in Reference 11. If the channel cannot be returned to OPERABLE status or placed in the bypass condition within 6 hours6.944444e-5 days <br />0.00167 hours <br />9.920635e-6 weeks <br />2.283e-6 months <br />, the unit must be brought to MODE 3 within the following
[6] hours and MODE 5 within the next 30 hours3.472222e-4 days <br />0.00833 hours <br />4.960317e-5 weeks <br />1.1415e-5 months <br />. The allowed Completion Times are reasonable, based on operating experience, to reach the required unit conditions from full power conditions in an orderly manner and without challenging unit systems. In MODE 5, the unit does not have any analyzed transients or conditions that require the explicit use of the protection functions noted above.
[ The Required Actions are modified by a Note that allows placing a second channel in the bypass condition for up to
[4] hours for surveillance testing. The total of
[12] hours to reach MODE 3 and
[4] hours for a second channel to be bypassed is acceptable based on the results of Reference 11.
] ----------------------------REVIEWER'S NOTE------------------------------------------ The below text should be used for plants with installed bypass test capability:
The Required Actions are modified by a Note that allows placing one channel in bypass for up to 12 hours1.388889e-4 days <br />0.00333 hours <br />1.984127e-5 weeks <br />4.566e-6 months <br /> while performing routine surveillance testing. The channel to be tested can be tested in bypass with the inoperable channel also in bypass. The total of [12]
hours to reach MODE 3 and [4] hours for a second channel to be bypassed is acceptable based on the results of Reference 1 1. --------------------------------------------------------------------------------------------------
L.1, L.2.1, and L.2.2 Condition L applies to the P-11 and P-12 [and P-14] interlock
- s.
With one or more channels inoperable, the operator must verify that the interlock is in the required state for the existing unit condition. This action manually accomplishes the function of the interlock. Determination must be made within 1 hour1.157407e-5 days <br />2.777778e-4 hours <br />1.653439e-6 weeks <br />3.805e-7 months <br />. The 1 hour1.157407e-5 days <br />2.777778e-4 hours <br />1.653439e-6 weeks <br />3.805e-7 months <br /> Completion Time is equal to the time Q Q 3 2 2 4 4 4 4 4 4 Engineered Safety Feature Actuation System (ESFAS) Instrumentation (Without Setpoint Control Program)
B 3.3.2 A Westinghouse STS B 3.3.2 A-49 Rev. 4.0 SEQUOYAH UNIT 1 Revision XXX 1 1 2BASES ACTIONS (continued) allowed by LCO 3.0.3 to initiate shutdown actions in the event of a complete loss of ESFAS function. If the interlock is not in the required state (or placed in the required state) for the existing unit condition, the unit must be placed in MODE 3 within the next 6 hours6.944444e-5 days <br />0.00167 hours <br />9.920635e-6 weeks <br />2.283e-6 months <br /> and MODE 4 within the following 6 hours6.944444e-5 days <br />0.00167 hours <br />9.920635e-6 weeks <br />2.283e-6 months <br />. The allowed Completion Times are reasonable, based on operating experience, to reach the required unit conditions from full power conditions in an orderly manner and without challenging unit systems. Placing the unit in MODE 4 removes all requirements for OPERABILITY of these interlocks.
SURVEILLANCE ----------------------------REVIEWER'S NOTE------------------------------------------
REQUIREMENTS In Table 3.3.2
-1, Functions 7.b and 7.c were not included in the generic evaluations approved in either WCAP
-10271, as supplemented, or WCAP-14333. In order to apply the WCAP
-10271, as supplemented, and WCAP-14333 TS relaxations to plant specific Functions not evaluated generically, licensees must submit plant specific evaluations for NRC review and approval.
REVIEWER'S NOTE------------------------------------------
Notes b and c are applied to the setpoint verification Surveillances for all Engineered Safety Feature Actuation System (ESFAS) Instrumentation Function in Table 3.3.2-1 unless one or more of the following exclusions apply: 1. Manual actuation circuits, automatic actuation logic circuits or instrument functions that derive input from contacts which have no associated sensor or adjustable device, e.g., limit switches, breaker position switches, manual actuation switches, float switches, proximity detectors, etc. are excluded.
In addition, those permissives and interlocks that derive input from a sensor or adjustable device that is tested as part of another TS function are excluded.
- 2. Settings associated with safety relief valves are excluded. The performance of these components is already controlled (i.e., trended with as-left and as
-found limits) under the ASME Code for Operation and Maintenance of Nuclear Power Plants testing program.
- 3. Functions and Surveillance Requirements which test only digital components are normally excluded. There is no expected change in result between SR performances for these components. Where separate as
-left and as
-found tolerance is established for digital component SRs, the requirements would apply.
3 3 INSERT 17 5 B 3.3.2 Insert Page B 3.3.2-49 INSERT 17 R.1 and R.2 If the inoperable channel cannot be placed in the tripped condition or the TTD of the single steam generator time delay calculation (T S) adjusted to match the multiple steam generator time delay calculation (T M) for the affected protection set within the specified Completion Time, the unit must be placed in a MODE where these Functions are not required OPERABLE. This requires the unit placed in MODE 3 within 6 hours6.944444e-5 days <br />0.00167 hours <br />9.920635e-6 weeks <br />2.283e-6 months <br /> and MODE 4 within 12 hours1.388889e-4 days <br />0.00333 hours <br />1.984127e-5 weeks <br />4.566e-6 months <br />. The allowed Completion Times are reasonable to reach the required unit conditions from full power conditions in an orderly manner and without challenging unit systems. In MODE 4, these Functions are no longer required OPERABLE.
S.1 and S.2
Condition S applies to the automatic actuation logic and actuation relays for the Automatic Switchover to Containment Sump.
This action addresses the train orientation of the SSPS and the master and slave relays. If one train is inoperable the unit must be placed in a MODE in which the LCO does not apply. This is done by placing the unit in at least MODE 3 within 12 hours1.388889e-4 days <br />0.00333 hours <br />1.984127e-5 weeks <br />4.566e-6 months <br /> and in MODE 5 within an additional 30 hours3.472222e-4 days <br />0.00833 hours <br />4.960317e-5 weeks <br />1.1415e-5 months <br /> (42 hours4.861111e-4 days <br />0.0117 hours <br />6.944444e-5 weeks <br />1.5981e-5 months <br /> total time). The Completion Times are reasonable to reach the required unit conditions from full power conditions in an orderly manner and without challenging unit systems.
The Required Actions are modified by a Note that allows one train to be bypassed for up to 4 hours4.62963e-5 days <br />0.00111 hours <br />6.613757e-6 weeks <br />1.522e-6 months <br /> for surveillance testing, provided the other train is OPERABLE.
5 Engineered Safety Feature Actuation System (ESFAS) Instrumentation (Without Setpoint Control Program)
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SURVEILLANCE REQUIREMENTS (continued)
The SRs for each ESFAS Function are identified by the SRs column of Table 3.3.2-1.
A Note has been added to the SR Table to clarify that Table 3.3.2-1 determines which SRs apply to which ESFAS Functions.
Note that each channel of process protection supplies both trains of the ESFAS. When testing channel I, train A and train B must be examined.
Similarly, train A and train B must be examined when testing channel II, channel III, and channel IV (if applicable). The CHANNEL CALIBRATION and COTs are performed in a manner that is consistent with the assumptions used in analytically calculating the required channel accuracies.
REVIEWER'S NOTE-----------------------------------------
Certain Frequencies are based on approved topical reports. In order for a licensee to use these times, the licensee must justify the Frequencies a s required by the staff SER for the topical report.
SR 3.3.2.1 Performance of the CHANNEL CHECK ensures that a gross failure of instrumentation has not occurred. A CHANNEL CHECK is normally a comparison of the parameter indicated on one channel to a similar parameter on other channels. It is based on the assumption that instrument channels monitoring the same parameter should read approximately the same value. Significant deviations between the two instrument channels could be an indication of excessive instrument drift in one of the channels or of something even more serious. A CHANNEL CHECK will detect gross channel failure; thus, it is key to verifying the instrumentation continues to operate properly between each CHANNEL CALIBRATION.
Agreement criteria are determined by the unit staff, based on a combination of the channel instrument uncertainties, including indication and reliability. If a channel is outside the criteria, it may be an indication that the sensor or the signal processing equipment has drifted outside its limit.
[ The Frequency of 12 hours1.388889e-4 days <br />0.00333 hours <br />1.984127e-5 weeks <br />4.566e-6 months <br /> is based on operating experience that demonstrates channel failure is rare. The CHANNEL CHECK supplements less formal, but more frequent, checks of channels during 3 8 Engineered Safety Feature Actuation System (ESFAS) Instrumentation (Without Setpoint Control Program)
B 3.3.2 A Westinghouse STS B 3.3.2 A-51 Rev. 4.0 SEQUOYAH UNIT 1 Revision XXX 1 1 2BASES
SURVEILLANCE REQUIREMENTS (continued) normal operational use of the displays associated with the LCO required channels.
OR The Surveillance Frequency is controlled under the Surveillance Frequency Control Program.
REVIEWER'S NOTE-----------------------------------
Plants controlling Surveillance Frequencies under a Surveillance Frequency Control Program should utilize the appropriate Frequency description, given above, and the appropriate choice of Frequency in the Surveillance Requirement.
]
SR 3.3.2.2 SR 3.3.2.2 is the performance of an ACTUATION LOGIC TEST using the semiautomatic tester. The train being tested is placed in the bypass condition, thus preventing inadvertent actuation. Through the semiautomatic tester, all possible logic combinations, with and without applicable permissives, are tested for each protection function. In addition, the master relay coil is pulse tested for continuity. This verifies that the logic modules are OPERABLE and that there is an intact voltage signal path to the master relay coils.
[ The Frequency of every 92 days on a STAGGERED TEST BASIS is justified in Reference 1
- 2.
OR The Surveillance Frequency is controlled under the Surveillance Frequency Control Program.
REVIEWER'S NOTE-----------------------------------
Plants controlling Surveillance Frequencies under a Surveillance Frequency Control Program should utilize the appropriate Frequency description, given above, and the appropriate choice of Frequency in the Surveillance Requirement.
]
SR 3.3.2.3 SR 3.3.2.3 is the performance of an ACTUATION LOGIC TEST as described in SR 3.3.2.2, except that the semiautomatic tester is not used 3 3 2 8 8 Engineered Safety Feature Actuation System (ESFAS) Instrumentation (Without Setpoint Control Program)
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SURVEILLANCE REQUIREMENTS (continued)
and the continuity check does not have to be performed, as explained in the Note. This SR is applied to the balance of plant actuation logic and relays that do not have the SSPS test circuits installed to utilize the semiautomatic tester or perform the continuity check.
[ This test is also performed every 31 days on a STAGGERED TEST BASIS. The Frequency is adequate based on industry operating experience, considering instrument reliabil ity and operating history data.
OR The Surveillance Frequency is controlled under the Surveillance Frequency Control Program.
REVIEWER'S NOTE-----------------------------------
Plants controlling Surveillance Frequencies under a Surveillance Frequency Control Program should utilize the appropriate Frequency description, given above, and the appropriate choice of Frequency in the Surveillance Requirement.
]
4 SR 3.3.2.4 is the performance of a MASTER RELAY TEST. The MASTER RELAY TEST is the energizing of the master relay, verifying contact operation and a low voltage continuity check of the slave relay coil. Upon master relay contact operation, a low voltage is injected to the slave relay coil. This voltage is insufficient to pick up the slave relay, but large enough to demonstrate signal path continuity. The time allowed for the testing on a STAGGERED TEST BASIS (4 hours4.62963e-5 days <br />0.00111 hours <br />6.613757e-6 weeks <br />1.522e-6 months <br />) is justified in
Reference 12.
[ The Frequency of 92 days is justified in Reference
- 10. OR The Surveillance Frequency is controlled under the Surveillance Frequency Control Program.
REVIEWER'S NOTE-----------------------------------
Plants controlling Surveillance Frequencies under a Surveillance Frequency Control Program should utilize the appropriate Frequency description, given above, and the appropriate choice of Frequency in the Surveillance Requirement.
]
3 3 3 3 2 2 8 Engineered Safety Feature Actuation System (ESFAS) Instrumentation (Without Setpoint Control Program)
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SURVEILLANCE REQUIREMENTS (continued)
5 SR 3.3.2.5 is the performance of a COT.
A COT is performed on each required channel to ensure the entire channel will perform the intended Function. Setpoints must be found conservative with respect to the Allowable Values specified in Table 3.3.2-1. A successful test of the required contact(s) of a channel relay may be performed by the verification of the change of state of a single contact of the relay. This clarifies what is an acceptable COT of a relay. This is acceptable because all of the other required contacts of the relay are verified by other Technical Specifications and non-Technical Specifications tests at least once per refueling interval with applicable extensions.
The difference between the current "as-found" values and the previous test "as left" values must be consistent with the drift allowance used in the setpoint methodology. The setpoint shall be left set consistent with the assumptions of the current unit specific setpoint methodology.
The "as-found" and "as-left" values must also be recorded and reviewed for consistency with the assumptions of Reference 7.
[ The Frequency of 184 days is justified in Reference 1 2.
OR The Surveillance Frequency is controlled under the Surveillance Frequency Control Program.
REVIEWER'S NOTE-----------------------------------
Plants controlling Surveillance Frequencies under a Surveillance Frequency Control Program should utilize the appropriate Frequency description, given above, and the appropriate choice of Frequency in the Surveillance Requirement.
]
SR 3.3.2.5 is modified by two Notes as identified in Table 3.3.2-1. The first Note requires evaluation of channel performance for the condition where the as-found setting for the channel setpoint is outside its as-found tolerance but conservative with respect to the Allowable Value.
Evaluation of channel performance will verify that the channel will continue to behave in accordance with safety analysis assumptions and the channel performance assumptions in the setpoint methodology. The purpose of the assessment is to ensure confidence in the channel 4 4 4 3 2 2 8 Engineered Safety Feature Actuation System (ESFAS) Instrumentation (Without Setpoint Control Program)
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SURVEILLANCE REQUIREMENTS (continued)
performance prior to returning the channel to service. For channels determined to be OPERABLE but degraded, after returning the channel to service the performance of these channels will be evaluated under the plant Corrective Action Program. Entry into the Corrective Action Program will ensure required review and documentation of the condition. The second Note requires that the as-left setting for the channel be returned to within the as-left tolerance of the
[NTSP]. Where a setpoint more conservative than the
[NTSP] is used in the plant surveillance procedures (field setting), the as-left and as-found tolerances, as applicable, will be applied to the surveillance procedure setpoint. This will ensure that sufficient margin to the Safety Limit and/or Analytical Limit is maintained. If the as-left channel setting cannot be returned to a setting
within the as-left tolerance of the
[NTSP], then the channel shall be declared inoperable.
REVIEWER'S NOTE-----------------------------------
The bracketed section '[NTSP and the]'
of the sentence in Note (c) in Table 3.3.2-1 is not required in plant
-specific Technical Specifications which include a [Nominal Trip Setpoint] column in Table 3.3.2-1. -------------------------------------------------------------------------------------------------- The second Note also requires that the [NTSP and the] methodologies for calculating the as-left and the as-found tolerances be in [insert the facility FSAR reference or the name of any document incorporated into the facility FSAR by reference]. SR 3.3.2.
6 SR 3.3.2.6 is the performance of a SLAVE RELAY TEST. The SLAVE RELAY TEST is the energizing of the slave relays. Contact operation is verified in one of two ways. Actuation equipment that may be operated in the design mitigation MODE is either allowed to function, or is placed in a condition where the relay contact operation can be verified without operation of the equipment. Actuation equipment that may not be operated in the design mitigation MODE is prevented from operation by the SLAVE RELAY TEST circuit. For this latter case, contact operation is verified by a continuity check of the circuit containing the slave relay.
[ The Frequency of 92 days is adequate, based on industry operating experience, considering instrument relia bility and operating history data.
OR The Surveillance Frequency is controlled under the Surveillance Frequency Control Program.
5 5 3 2 4 4 4 8UFSAR Section 7.1.2 Engineered Safety Feature Actuation System (ESFAS) Instrumentation (Without Setpoint Control Program)
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SURVEILLANCE REQUIREMENTS (continued)
REVIEWER'S NOTE-----------------------------------
Plants controlling Surveillance Frequencies under a Surveillance Frequency Control Program should utilize the appropriate Frequency description, given above, and the appropriate choice of Frequency in the Surveillance Requirement.
]
7 SR 3.3.2.7 is the performance of a TADOT. This test is a check of the Loss of Offsite Power
, Undervoltage RCP , and AFW Pump Suction Transfer on Suc tion Pressure
- Low Function s. Each Function is tested up to, and including, the master transfer relay coils. A successful test of the required contact(s) of a channel relay may be performed by the verification of the change of state of a single contact of the relay. This clarifies what is an acceptable TADOT of a relay. This is acceptable because all of the other required contacts of the relay are verified by other Technical Specifications and non-Technical Specifications tests at least once per refueling interval with applicable extensions.
The test also includes trip channels that provide actuation signals directly to the SSPS. The SR is modified by a Note that excludes verification of setpoints for relays. Relay setpoints require elaborate bench calibration and are verified during CHANNEL CALIBRATION.
[ The Frequency of 92 days is adequate. It is based on industry operating experience, considering instrument reliability and operating history data.
OR The Surveillance Frequency is controlled under the Surveillance Frequency Control Program.
REVIEWER'S NOTE-----------------------------------
Plants controlling Surveillance Frequencies under a Surveillance Frequency Control Program should utilize the appropriate Frequency description, given above, and the appropriate choice of Frequency in the Surveillance Requirement.
] 6 6 3 3 2 8 Engineered Safety Feature Actuation System (ESFAS) Instrumentation (Without Setpoint Control Program)
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SURVEILLANCE REQUIREMENTS (continued)
8 SR 3.3.2.8 is the performance of a TADOT. This test is a check of the Manual Actuation Functions and AFW pump start on trip of all MFW pumps. Each Manual Actuation Function is tested up to, and including, the master relay coils. A successful test of the required contact(s) of a channel relay may be performed by the verification of the change of state of a single contact of the relay. This clarifies what is an acceptable TADOT of a relay. This is acceptable because all of the other required contacts of the relay are verified by other Technical Specifications and non-Technical Specifications tests at least once per refueling interval with applicable extensions. In some instances, the test includes actuation of
the end device (i.e., pump starts, valve cycles, etc.).
[ The Frequency of 18 months is adequate, based on industry operating experience and is consistent with the typical refueling cycle.
OR The Surveillance Frequency is controlled under the Surveillance Frequency Control Program.
REVIEWER'S NOTE-----------------------------------
Plants controlling Surveillance Frequencies under a Surveillance Frequency Control Program should utilize the appropriate Frequency description, given above, and the appropriate choice of Frequency in the Surveillance Requirement.
] SR 3.3.2.8 is modified by two Notes as identified in Table 3.3.2-1. The first Note requires evaluation of channel performance for the condition where the as
-found setting for the channel setpoint is outside its as
-found tolerance but conservative with respect to the Allowable Value. Evaluation of channel performance will verify that the channel will continue to behave in accordance with safety analysis assumptions and the channel performance assumptions in the setpoint methodology. The purpose of the assessment is to ensure confidence in the channel performance prior to returning the channel to service. For channels determined to be OPERABLE but degraded, after returning the channel to service the performance of these channels will be evaluated under the plant Corrective Action Program. Entry into the Corrective Action Program will ensure required review and documentation of the condition. The second Note requires that the as
-left setting for the channel be returned to within the as
-left tolerance of the [NTSP]. Where a setpoint more conservative than the [NTSP] is used in the plant surveillance 7 7 3 2 2 8 Engineered Safety Feature Actuation System (ESFAS) Instrumentation (Without Setpoint Control Program)
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SURVEILLANCE REQUIREMENTS (continued)
procedures (field setting), the as
-left and as
-found tolerances, as applicable, will be applied to the surveillance procedure setpoint. This will ensure that sufficient margin to the Safety Limit and/or Analytical Limit is maintained. If the as
-left channel setting cannot be returned to a setting within the as
-left tolerance of the [NTSP], then the channel shall be declared inoperable.
REVIEWER'S NOTE-----------------------------------
The bracketed section '[NTSP and the]'
of the sentence in Note (c) in Table 3.3.2
-1 is not required in plant
-specific Technical Specifications which include a [Nominal Trip Setpoint] column in Table 3.3.2
-1. --------------------------------------------------------------------------------------------------
The second Note also requires that the [NTSP and the] methodologies for calculating the as
-left and the as
-found tolerances be in [insert the facility FSAR reference or the name of any document incorporated into the facility FSAR by reference].
The SR is modified by a Note that excludes verification of setpoints during the TADOT for manual initiation Functions. The manual initiation Functions have no associated setpoints.
9 SR 3.3.2.9 is the performance of a CHANNEL CALIBRATION.
CHANNEL CALIBRATION is a complete check of the instrument loop, including the sensor. The test verifies that the channel responds to measured parameter within the necessary range and accuracy.
CHANNEL CALIBRATIONS must be performed consistent with the assumptions of the unit specific setpoint methodology. The difference between the current "as-found" values and the previous test "as-left" values must be consistent with the drift allowance used in the setpoint methodology.
[ The Frequency of [18]
months is based on the assumption of an
[18] month calibration interval in the determination of the magnitude of equipment drift in the setpoint methodo logy.
OR The Surveillance Frequency is controlled under the Surveillance Frequency Control Program.
8 8 3 2 2 2 8 Engineered Safety Feature Actuation System (ESFAS) Instrumentation (Without Setpoint Control Program)
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SURVEILLANCE REQUIREMENTS (continued)
REVIEWER'S NOTE-----------------------------------
Plants controlling Surveillance Frequencies under a Surveillance Frequency Control Program should utilize the appropriate Frequency description, given above, and the appropriate choice of Frequency in the Surveillance Requirement.
] This SR is modified by a Note stating that this test should include verification that the time constants are adjusted to the prescribed values where applicable.
SR 3.3.2.9 is modified by two Notes as identified in Table 3.3.2-1. The first Note requires evaluation of channel performance for the condition where the as-found setting for the channel setpoint is outside its as-found tolerance but conservative with respect to the Allowable Value.
Evaluation of channel performance will verify that the channel will continue to behave in accordance with safety analysis assumptions and the channel performance assumptions in the setpoint methodology. The purpose of the assessment is to ensure confidence in the channel performance prior to returning the channel to service. For channels determined to be OPERABLE but degraded, after returning the channel to service the performance of these channels will be evaluated under the plant Corrective Action Program. Entry into the Corrective Action Program will ensure required review and documentation of the condition.
The second Note requires that the as-left setting for the channel be
returned to within the as-left tolerance of the
[NTSP]. Where a setpoint more conservative than the
[NTSP] is used in the plant surveillance procedures (field setting), the as-left and as-found tolerances, as applicable, will be applied to the surveillance procedure setpoint. This will ensure that sufficient margin to the Safety Limit and/or Analytical Limit is maintained. If the as-left channel setting cannot be returned to a setting
within the as-left tolerance of the
[NTSP], then the channel shall be declared inoperable.
REVIEWER'S NOTE
The bracketed section '[NTSP and the]'
of the sentence in Note (c) in Table 3.3.2-1 is not required in plant
-specific Technical Specifications which include a [Nominal Trip Setpoint] column in Table 3.3.2-1. --------------------------------------------------------------------------------------------------
The second Note also requires that the [NTSP and the] methodologies for calculating the as-left and the as-found tolerances be in [insert the facility FSAR reference or the name of any document incorporated into the facility FSAR by reference]. 8 3 3 2 4 4 4 4UFSAR Section 7.1.2 Engineered Safety Feature Actuation System (ESFAS) Instrumentation (Without Setpoint Control Program)
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SURVEILLANCE REQUIREMENTS (continued)
10 This SR ensures the individual channel ESF RESPONSE TIMES are less than or equal to the maximum values assumed in the accident analysis.
Response Time testing acceptance criteria are included in the Technical Requirements Manual , Section 15 (Ref. 13). Individual component response times are not modeled in the analyses. The analyses model the overall or total elapsed time, from the point at which the parameter exceeds the Trip Setpoint value at the sensor, to the point at which the equipment in both trains reaches the required functional state (e.g., pumps at rated discharge pressure, valves in full open or closed position).
For channels that include dynamic transfer functions (e.g., lag, lead/lag, rate/lag, etc.), the response time test may be performed with the transfer functions set to one with the resulting measured response time compared to the appropriate FSAR response time. Alternately, the response time test can be performed with the time constants set to their nominal value provided the required response time is analytically calculated assuming the time constants are set at their nominal values. The response time may be measured by a series of overlapping tests such that the entire
response time is measured.
REVIEWER'S NOTE-----------------------------------------
Applicable portions of the following Bases are applicable for plants adopting WCAP
-13632-P-A (Ref. 1 4). and/or WCAP
-14036-P (Ref. 1 5). --------------------------------------------------------------------------------------------------
Response time may be verified by actual response time tests in any series of sequential, overlapping or total channel measurements, or by the summation of allocated sensor, signal processing and actuation logic response times with actual response time tests on the remainder of the channel. Allocations for sensor response times may be obtained from: (1) historical records based on acceptable response time tests (hydraulic, noise, or power interrupt tests), (2) in place, onsite, or offsite (e.g.,
vendor) test measurements, or (3) utilizing vendor engineering specifications. WCAP-13632-P-A, Revision 2, "Elimination of Pressure Sensor Response Time Testing Requirements," (Ref. 14) dated January 1996, provides the basis and methodology for using allocated sensor response times in the overall verification of the channel response time for specific sensors identified in the WCAP. Response time verification for other sensor types must be demonstrated by test.
9Updated Final Safety Analysis Report, Section7.3 U 3 2 2 2 Engineered Safety Feature Actuation System (ESFAS) Instrumentation (Without Setpoint Control Program)
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SURVEILLANCE REQUIREMENTS (continued)
WCAP-14036-P, Revision 1, "Elimination of Periodic Protection Channel Response Time Tests," (Ref. 15) provides the basis and methodology for using allocated signal processing and actuation logic response times in the overall verification of the protection system channel response time.
The allocations for sensor, signal conditioning, and actuation logic response times must be verified prior to placing the component in operational service and re-verified following maintenance that may adversely affect response time. In general, electrical repair work does not impact response time provided the parts used for repair are of the same type and value. Specific components identified in the WCAP may be replaced without verification testing. One example where response time could be affected is replacing the sensing assembly of a transmitter.
[ ESF RESPONSE TIME tests are conducted on an [18]
month STAGGERED TEST BASIS. Testing of the final actuation devices, which make up the bulk of the response time, is included in the testing of each channel. The final actuation device in one train is tested with each channel. Therefore, staggered testing results in response time verification of these devices every [18]
months. The [18]
month Frequency is consistent with the typical refueling cycle and is based on unit operating experience, which shows that random failures of instrumentation components causing serious response time degradation, but not channel failure, are infrequent occurrences.
OR The Surveillance Frequency is controlled under the Surveillance Frequency Control Program.
REVIEWER'S NOTE-----------------------------------
Plants controlling Surveillance Frequencies under a Surveillance Frequency Control Program should utilize the appropriate Frequency description, given above, and the appropriate choice of Frequency in the Surveillance Requirement.
]
This SR is modified by a Note that clarifies that the turbine driven AFW pump is tested within 24 hours2.777778e-4 days <br />0.00667 hours <br />3.968254e-5 weeks <br />9.132e-6 months <br /> after reaching
[1000] psig in the SGs.
11 SR 3.3.2.11 is the performance of a TADOT as described in SR 3.3.2.
8 , except that it is performed for the P-4 Reactor Trip Interlock, and the 10 10 7 3 2 4 842 8 Engineered Safety Feature Actuation System (ESFAS) Instrumentation (Without Setpoint Control Program)
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SURVEILLANCE REQUIREMENTS (continued)
Frequency is once per RTB cycle. A successful test of the required contact(s) of a channel relay may be performed by the verification of the change of state of a single contact of the relay. This clarifies what is an acceptable TADOT of a relay. This is acceptable because all of the other required contacts of the relay are verified by other Technical Specifications and non
-Technical Specifications tests at least once per refueling interval with applicable extensions. This Frequency is based on operating experience demonstrating that undetected failure of the P-4 interlock sometimes occurs when the RTB is cycled.
The SR is modified by a Note that excludes verification of setpoints during the TADOT. The Function tested has no associated setpoint.
REFERENCES 1. Regulatory Guide 1.105, "Setpoint for Safety Related Instrumentation," Revision 3.
- 2. FSAR, Chapter
[6]. 3. FSAR, Chapter
[7].
- 4. FSAR, Chapter
[15].
- 5. IEEE-279-1971.
- 6. 10 CFR 50.49.
- 7. Plant-specific setpoint methodology study.
- 8. NUREG-1218, April 1988.
- 9. WCAP-14333-P-A, Rev. 1, October 1998.
- 10. WCAP-10271-P-A, Supplement 2, Rev. 1, June 1990.
- 11. [Plant specific evaluation reference.]
- 12. WCAP-15376, Rev. 0. October 2000.
- 13. Technical Requirements Manual, Section 15, "Response Times." 14. WCAP-13632-P-A, Revision 2, "Elimination of Pressure Sensor Response Time Testing Requirements," January 1996.
- 15. WCAP-14036-P, Revision 1, "Elimination of Periodic Protection Channel Response Time Tests," December 1995. UFSAR, Section 7.3 Calculation SQN-EEB-PL&S, Precautions, Limitations, and Setpoints for NSSS SEQUOYAH UNIT 1 Revision XXX 2 2 2 4 4 4 4 U U 2 2 2License Amendment dated June 13, 1995, Issuance of Amendments to Technical Specifications - Sequoyah Nuclear Plant, Units 1 and 2 (TAC NOS. M91990 and 91991) (ML013320052)
U reactor trip breaker reactor trip breaker Engineered Safety Feature Actuation System (ESFAS) Instrumentation (Without Setpoint Control Program)
B 3.3.2 A Westinghouse STS B 3.3.2 A-1 Rev. 4.0 SEQUOYAH UNIT 2 Revision XXX 1 1 2B 3.3 INSTRUMENTATION
B 3.3.2 A Engineered Safety Feature Actuation System (ESFAS) Instrumentation (Without Setpoint Control Program)
BASES
BACKGROUND The ESFAS initiates necessary safety systems, based on the values of selected unit parameters, to protect against violating core design limits and the Reactor Coolant System (RCS) pressure boundary, and to mitigate accidents. This is achieved by specifying limiting safety system settings (LSSS) in terms of parameters directly monitored by the ESFAS, as well as specifying LCOs on other reactor system parameters and equipment performance.
Technical Specifications are required by 10 CFR 50.36 to include LSSS for variables that have significant safety functions. LSSS are defined by the regulation as "Where a LSSS is specified for a variable on which a safety limit has been placed, the setting must be chosen so that automatic protective actions will correct the abnormal situation before a Safety Limit (SL) is exceeded." The Analytical Limit is the limit of the process variable at which a protective action is initiated, as established by the safety analysis, to ensure that a SL is not exceeded. Any automatic protection action that occurs on reaching the Analytical Limit therefore ensures that the SL is not exceeded. However, in practice, the actual settings for automatic protection channels must be chosen to be more conservative than the Analytical Limit to account for instrument loop uncertainties related to the setting at which the automatic protective action would actually occur.
REVIEWER'S NOTE ------------------------------------
T he term "[Limiting Trip Setpoint (LTS P)]" is generic terminology for the calculated field setting (setpoint) value calculated by means of the plant
-specific setpoint methodology documented in a document controlled under 10 CFR 50.59. The term [LTSP] indicates that no additional margin has been added between the Analytical Limit and the calculated trip setting.
For most Westinghouse plants the term
[Nominal Trip Setpoint (NTSP)
] is used in place of the term
[LTSP], and [NTSP] will replace
[LTSP] in the Bases descriptions. "Field setting" is the suggested terminology for the actual setpoint implemented in the plant surveillance procedures where margin has been added to the calculated field setting. The as
-found and as-left tolerances will apply to the field setting implemented in the Surveillance procedures to confirm channel performance.
INSERT 1 2 3 1 B 3.3.2 Insert Page B 3.3.2-1 INSERT 1 settings for automatic protective devices related to those variables having significant safety functions. The regulation also states,
2 Engineered Safety Feature Actuation System (ESFAS) Instrumentation (Without Setpoint Control Program)
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BACKGROUND (continued)
Licensees are to insert the name of the document(s) controlled under 10 CFR 50.59 that contain the methodology for calculating the as
-left and as-found tolerances, in N ote c of Table 3.3.2-1 for the phrase "[insert the name of a document controlled under 10 CFR 50.59 such as the Technical Requirements Manual or any document incorporated into the facility FSAR]" throughout these Bases.
Where the [NTSP] is not included in Table 3.3.2-1, the plant
-specific location for the
[NTS P] must be cited in Note c of Table 3.3.2-1. The brackets indicate plant
-specific terms may apply, as reviewed and approved by the NRC.
The [Nominal Trip Setpoint (NTSP)
] specified in Table 3.3.2-1 is a predetermined setting for a protection channel chosen to ensure automatic actuation prior to the process variable reaching the Analytical Limit and thus ensuring that the SL would not be exceeded. As such, the
[NTSP] accounts for uncertainties in setting the channel (e.g., calibration), uncertainties in how the channel might actually perform (e.g.,
repeatability), changes in the point of action of the channel over time (e.g., drift during surveillance intervals), and any other factors which may influence its actual performance (e.g., harsh accident environments). In this manner, the
[NTSP] ensures that SLs are not exceeded. Therefore, the [NTSP] meets the definition of an LSSS (Ref. 1).
Technical Specifications contain values related to the OPERABILITY of equipment required for safe operation of the facility. OPERABLE is defined in Technical Specifications as "...being capable of performing its safety functions(s)." Relying solely on the
[NTSP] to define OPERABILITY in Technical Specifications would be an overly restrictive requirement if it were applied as an OPERABILITY limit for the "as-found" value of a protection channel setting during a surveillance. This would result in Technical Specification compliance problems, as well as reports and corrective actions required by the rule, which are not necessary to ensure safety. For example, an automatic protection channel with a setting that has been found to be different from the
[NTSP] due to some drift of the setting may still be OPERABLE since drift is to be expected.
This expected drift would have been specifically accounted for in the setpoint methodology for calculating the
[NTSP] and thus the automatic protective action would still have ensured that the SL would not be exceeded with the "as-found" setting of the protection channel.
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Therefore, the channel would still be OPERABLE since it would have performed its safety function and the only corrective action required would be to reset the channel within the established as-left tolerance around the
[NTSP] to account for further drift during the next surveillance interval.
[Note: Alternatively, a Technical Specification format incorporating an Allowable Value only column may be proposed by a licensee. In this case, the [NTSP] value and the methodologies u sed to calculate the as
-found and as
-left tolerances must be specified in [insert the name of a document controlled under 10 CFR 50.59 such as the Technical Requirements Manual or any document incorporated into the facility FSAR]. Changes to the actual plant trip setpoint or [NTSP] value would be controlled by 10 CFR 50.59 or administratively as appropriate, and adjusted per the setpoint methodology and applicable surveillance requirements.
During Anticipated Operational Occurrences (AOOs), which are those events expected to occur one or more times during the unit life, the acceptable limits are:
- 1. The Departure from Nucleate Boiling Ratio (DNBR) shall be maintained above the SL value to prevent departure from nucleate
boiling (DNB), 2. Fuel centerline melt shall not occur, and
[2735] psig shall not be exceeded.
Operation within the SLs of Specification 2.0, "Safety Limits (SLs)," also maintains the above values and assures that offsite dose will be within the 10 CFR 50 and 10 CFR 100 criteria during AOOs.
Accidents are events that are analyzed even though they are not expected to occur during the unit life. The acceptable limit during accidents is that offsite dose shall be maintained within an acceptable fraction of 10 CFR 100 limits. Different accident categories are allowed a different fraction of these limits, based on probability of occurrence.
Meeting the acceptable dose limit for an accident category is considered having acceptable consequences for that event.
The ESFAS instrumentation is segmented into three distinct but interconnected modules as identified below:
- Field transmitters or process sensors and instrumentation: provide a measurable electronic signal based on the physical characteristics of the parameter being measured, 3 4 4 Engineered Safety Feature Actuation System (ESFAS) Instrumentation (Without Setpoint Control Program)
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BACKGROUND (continued)
- Signal processing equipment including analog protection system, field contacts, and protection channel sets: provide signal conditioning, bistable setpoint comparison, process algorithm actuation, compatible electrical signal output to protection system channels, and control board/control room/miscellaneous indications, and
- Solid State Protection System (SSPS) including input, logic, and output bays: initiates the proper unit shutdown or engineered safety feature (ESF) actuation in accordance with the defined logic and based on the bistable outputs from the signal process control and protection system.
Field Transmitters or Sensors To meet the design demands for redundancy and reliability, more than one, and often as many as four, field transmitters or sensors are used to measure unit parameters. In many cases, field transmitters or sensors that input to the ESFAS are shared with the Reactor Trip System (RTS).
In some cases, the same channels also provide control system inputs. To account for calibration tolerances and instrument drift, which are assumed to occur between calibrations, statistical allowances are
provided in the
[NTSP] and Allowable Value. The OPERABILITY of each transmitter or sensor is determined by either "as-found" calibration data evaluated during the CHANNEL CALIBRATION or by qualitative assessment of field transmitter or sensor, as related to the channel behavior observed during performance of the CHANNEL CHECK.
Signal Processing Equipment Generally, three or four channels of process control equipment are used for the signal processing of unit parameters measured by the field instruments. The process control equipment provides signal conditioning, comparable output signals for instruments located on the main control
board, and comparison of measured input signals with
[NTSPs] derived from Analytical Limits established by the safety analyses. Analytical Limits are defined in FSAR, Chapter
[6] (Ref. 2), Chapter
[7] (Ref. 3), and Chapter [15] (Ref. 4). If the measured value of a unit parameter exceeds the predetermined setpoint, an output from a bistable is forwarded to the SSPS for decision evaluation. Channel separation is maintained up to and through the input bays. However, not all unit parameters require four channels of sensor measurement and signal processing. Some unit parameters provide input only to the SSPS, while others provide input to
the SSPS, the main control board, the unit computer, and one or more control systems. analog to digital conversion (Digital Protection System), , setpoint comparator, or contact 4 U 2 2 4 4 2 2Process , setpoint comparator, or contact 2
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BACKGROUND (continued)
Generally, if a parameter is used only for input to the protection circuits, three channels with a two-out-of-three logic are sufficient to provide the required reliability and redundancy. If one channel fails in a direction that would not result in a partial Function trip, the Function is still OPERABLE with a two-out-of-two logic. If one channel fails such that a partial Function trip occurs, a trip will not occur and the Function is still OPERABLE with a one-out-of-two logic.
Generally, if a parameter is used for input to the SSPS and a control function, four channels with a two-out-of-four logic are sufficient to provide the required reliability and redundancy. The circuit must be able to withstand both an input failure to the control system, which may then require the protection function actuation, and a single failure in the other channels providing the protection function actuation. Again, a single failure will neither cause nor prevent the protection function actuation.
These requirements are described in IEEE-279-1971 (Ref. 5). The actual number of channels required for each unit parameter is specified in
Reference 3.
[NTSPs] and ESFAS Setpoints
[Allowable Values
] The trip setpoints used in the bistables are based on the analytical limits stated in Reference 3. The calculation of the
[NTSPs] specified in Table 3.3.2-1 is such that adequate protection is provided when all sensor and processing time delays are taken into account. To allow for calibration tolerances, instrumentation uncertainties, instrument drift, and severe environment errors for those ESFAS channels that must function in harsh environments as defined by 10 CFR 50.49 (Ref. 6), the Allowable Values specified in Table 3.3.2-1 in the accompanying LCO are conservative with respect to the analytical limits. A detailed description of the methodology used to calculate the Allowable Values and ESFAS
[NTSPs] including their explicit uncertainties, is provided in the plant specific setpoint methodology study (Ref. 7) which incorporates all of the known uncertainties applicable to each channel. The as-left tolerance and as-found tolerance band methodology is provided in [insert the name of a document controlled under 10 CFR 50.59 such as the Techni cal Requirements Manual or any document incorporated into the facility FSAR]. The magnitudes of these uncertainties are factored into the determination of each ESFAS
[NTSP] and corresponding Allowable Value. The nominal ESFAS setpoint entered into the bi stable is more conservative than that specified by the
[NTSP] to account for measurement errors detectable by the CHANNEL OPERATIONAL TEST (COT). The Allowable Value serves as the as-found Technical Specification OPERABILITY limit for the purpose of the COT.
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BACKGROUND (continued)
The [NTSP] is the value at which the bistables are set and is the expected value to be achieved during calibration. The
[NTSP] value is the LSSS and ensures the safety analysis limits ar e met for the surveillance interval selected when a channel is adjusted based on stated channel uncertainties. Any bistable is considered to be properly adjusted when the "as-left" [NTSP] value is within the as-left tolerance for CHANNEL CALIBRATION uncertainty allowance (i.e., + rack calibration and comparator setting uncertainties). The
[NTSP] value is therefore considered a "nominal value" (i.e., expressed as a value without inequalities) for the purposes of the COT and CHANNEL CALIBRATION.
[Nominal Trip Setpoints
], in conjunction with the use of as-found and as-left tolerances together with the requirements of the Allowable Value ensure that the consequences of Design Basis Accidents (DBAs) will be acceptable, providing the unit is operated from within the LCOs at the onset of the DBA and the equipment functions as designed.
Note that the Allowable Values listed in Table 3.3.2-1 are the least conservative value of the as-found setpoint that a channel can have during a periodic CHANNEL CALIBRATION, COT, or a TADOT.
Each channel can be tested on line to verify that the signal processing equipment and setpoint accuracy is within the specified allowance requirements of Reference 3. Once a designated channel is taken out of service for testing, a simulated signal is injected in place of the field instrument signal. The process equipment for the channel in test is then tested, verified, and calibrated. SRs for the channels are specified in the SR section.
Solid State Protection System
The SSPS equipment is used for the decision logic processing of outputs from the signal processing equipment bistables. To meet the redundancy requirements, two trains of SSPS, each performing the same functions, are provided. If one train is taken out of service for maintenance or test purposes, the second train will provide ESF actuation for the unit. If both trains are taken out of service or placed in test, a reactor trip will result.
Each train is packaged in its own cabinet for physical and electrical separation to satisfy separation and independence requirements.
The SSPS performs the decision logic for most ESF equipment actuation; generates the electrical output signals that initiate the required actuation; and provides the status, permissive, and annunciator output signals to the main control room of the unit.
or set point com parators 2 4 4 o r set point com parator 4 4 2 4, setpoint comparators, or contacts 2
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BACKGROUND (continued)
The bistable outputs from the signal processing equipment are sensed by the SSPS equipment and combined into logic matrices that represent combinations indicative of various transients. If a required logic matrix combination is completed, the system will send actuation signals via master and slave relays to those components whose aggregate Function best serves to alleviate the condition and restore the unit to a safe condition. Examples are given in the Applicable Safety Analyses, LCO, and Applicability sections of this Bases.
Each SSPS train has a built in testing device that can automatically test the decision logic matrix functions and the actuation channels while the unit is at power. When any one train is taken out of service for testing, the other train is capable of providing unit monitoring and protection until the testing has been completed. The testing device is semiautomatic to
minimize testing time.
The actuation of ESF components is accomplished through master and slave relays. The SSPS energizes the master relays appropriate for the condition of the unit. Each master relay then energizes one or more slave relays, which then cause actuation of the end devices. The master and slave relays are routinely tested to ensure operation. The test of the master relays energizes the relay, which then operates the contacts and applies a low voltage to the associated slave relays. The low voltage is not sufficient to actuate the slave relays but only demonstrates signal path continuity. The SLAVE RELAY TEST actuates the devices if their operation will not interfere with continued unit operation. For the latter case, actual component operation is prevented by the SLAVE RELAY TEST circuit, and slave relay contact operation is verified by a continuity check of the circuit containing the slave relay.
REVIEWER'S NOTE------------------------------------------
No one unit ESFAS incorporates all of the Functions listed in Table 3.3.2-1. In some cases (e.g., Containment Pressure
- High 3, Function 2.c), the Table reflects several different implementations of the same Function. Typically, only one of these implementations are used at any specific unit.
APPLICABLE Each of the analyzed accidents can be detected by one or more ESFAS SAFETY Functions. One of the ESFAS Functions is the primary actuation signal ANALYSES, LCO, for that accident. An ESFAS Function may be the primary actuation and APPLICABILITY signal for more than one type of accident. An ESFAS Function may also be a secondary, or backup, actuation signal for one or more other accidents. For example, Pressurizer Pressure - Low is a primary 3, setpoint comparator, or contact 2
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APPLICABLE SAFETY ANALYSES, LCO, and APPLICABILITY (continued)
actuation signal for small loss of coolant accidents (LOCAs) and a backup actuation signal for steam line breaks (SLBs) outside containment.
Functions such as manual initiation, not specifically credited in the accident safety analysis, are implicitly credited in the safety analysis and the NRC staff approved licensing basis for the unit. These Functions may provide protection for conditions that do not require dynamic transient analysis to demonstrate Function performance. These Functions may also serve as backups to Functions that were credited in the accident
analysis (Ref. 4).
Permissive and interlock setpoints allow the blocking of trips during plant startups, and restoration of trips when the permissive conditions are not satisfied, but they are not explicitly modeled in the Safety Analyses.
These permissives and interlocks ensure that the starting conditions are consistent with the safety analysis, before preventive or mitigating actions occur. Because these permissives or interlocks are only one of multiple conservative starting assumptions for the accident analysis, they are generally considered as nominal values without regard to measurement accuracy.
The LCO requires all instrumentation performing an ESFAS Function, listed in Table 3.3.2-1 in the accompanying LCO, to be OPERABLE. The Allowable Value specified in Table 3.3.2-1 is the least conservative value of the as-found setpoint that the channel can have when tested, such that a channel is OPERABLE if the as-found setpoint is within the as-found tolerance and is conservative with respect to the Allowable Value during the CHANNEL CALIBRATION or COT. As such, the Allowable Value differs from the
[NTSP] by an amount
[greater than or
] equal to the expected instrument channel uncertainties, such as drift, during the surveillance interval. In this manner, the actual setting of the channel
[NTSP] will ensure that a SL is not exceeded at any given point of time as long as the channel has not drifted beyond expected tolerances during the surveillance interval. Note that, although the channel is OPERABLE under these circumstances, the trip setpoint must be left adjusted to a value within the as-left tolerance, in accordance with uncertainty assumptions stated in the referenced setpoint methodology (as-left criteria), and confirmed to be operating within the statistical allowances of the uncertainty terms assigned (as-found criteria).
If the actual setting of the channel is found to be conservative with respect to the Allowable Value but is beyond the as-found tolerance band, the channel is OPERABLE, but degraded. The degraded condition of the channel will be evaluated during performance of the SR. This evaluation will consist of resetting the channel setpoint to the
[NTSP] (within the 4 4 4 Engineered Safety Feature Actuation System (ESFAS) Instrumentation (Without Setpoint Control Program)
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APPLICABLE SAFETY ANALYSES, LCO, and APPLICABILITY (continued)
allowed tolerance) and evaluating the channel response. If the channel is functioning as required and expected to pass the next surveillance, then the channel can be restored to service at the completion of the surveillance.
A trip setpoint may be set more conservative than the
[NTSP] as necessary in response to plant conditions. However, in this case, the OPERABILITY of this instrument must be verified based on the
[field setting] and not the
[NTSP]. Failure of any instrument renders the affected channel(s) inoperable and reduces the reliability of the affected Functions.
The LCO generally requires OPERABILITY of four or three channels in each instrumentation function and two channels in each logic and manual initiation function. The two-out-of-three and the two-out-of-four configurations allow one channel to be tripped during maintenance or testing without causing an ESFAS initiation. Two logic or manual initiation channels are required to ensure no single random failure disables the ESFAS.
The required channels of ESFAS instrumentation provide unit protection in the event of any of the analyzed accidents. ESFAS protection functions are as follows:
- 1. Safety Injection Safety Injection (SI) provides two primary functions:
- 1. Primary side water addition to ensure maintenance or recovery of reactor vessel water level (coverage of the active fuel for heat removal, clad integrity, and for limiting peak clad temperature to
< 2200°F), and
- 2. Boration to ensure recovery and maintenance of SDM (k eff< 1.0).
These functions are necessary to mitigate the effects of high energy line breaks (HELBs) both inside and outside of containment. The SI signal is also used to initiate other Functions such as:
- Phase A Isolation,
- Containment Purge Isolation, 4 4Ventilation 2
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APPLICABLE SAFETY ANALYSES, LCO, and APPLICABILITY (continued)
- Feedwater Isolation,
- Start of motor driven auxiliary feedwater (AFW) pumps,
- Control room ventilation isolation, and
- Enabling automatic switchover of Emergency Core Cooling Systems (ECCS) suction to containment sump.
These other functions ensure:
- Isolation of nonessential systems through containment penetrations,
- Trip of the turbine and reactor to limit power generation,
- Start of AFW to ensure secondary side cooling capability,
- Isolation of the control room to ensure habitability, and
- Enabling ECCS suction from the refueling water storage tank (RWST) switchover on low low RWST level to ensure continued cooling via use of the containment sump.
- a. Safety Injection - Manual Initiation The LCO requires one channel per train to be OPERABLE. The operator can initiate SI at any time by using either of two switches in the control room. This action will cause actuation of all components in the same manner as any of the automatic actuation signals.
The LCO for the Manual Initiation Function ensures the proper amount of redundancy is maintained in the manual ESFAS actuation circuitry to ensure the operator has manual ESFAS initiation capability.
ERCW and CCS Pump Start and System Isolation 2
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APPLICABLE SAFETY ANALYSES, LCO, and APPLICABILITY (continued)
Each channel consists of one push button and the interconnecting wiring to the actuation logic cabinet. Each push button actuates both trains. This configuration does not allow testing at power.
- b. Safety Injection - Automatic Actuation Logic and Actuation Relays This LCO requires two trains to be OPERABLE. Actuation logic consists of all circuitry housed within the actuation subsystems, including the initiating relay contacts responsible for actuating the ESF equipment.
Manual and automatic initiation of SI must be OPERABLE in MODES 1, 2, and 3. In these MODES, there is sufficient energy
in the primary and secondary systems to warrant automatic initiation of ESF systems. Manual Initiation is also required in MODE 4 even though automatic actuation is not required. In this MODE, adequate time is available to manually actuate required
components in the event of a DBA, but because of the large number of components actuated on a SI, actuation is simplified by the use of the manual actuation push buttons. Automatic actuation logic and actuation relays must be OPERABLE in MODE 4 to support system level manual initiation.
These Functions are not required to be OPERABLE in MODES 5 and 6 because there is adequate time for the operator to evaluate unit conditions and respond by manually starting individual systems, pumps, and other equipment to mitigate the consequences of an abnormal condition or accident. Unit pressure and temperature are very low and many ESF components are administratively locked out or otherwise prevented from actuating to prevent inadvertent overpressurization of unit systems.
- c. Safety Injection - Containment Pressure - High 1 This signal provides protection against the following accidents:
- SLB inside containment,
- LOCA, and
- Feed line break inside containment.
hand switch hand switches an abnormal condition or accident The two trains are redundant such that only one is necessary to perform the ESFAS Function.
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APPLICABLE SAFETY ANALYSES, LCO, and APPLICABILITY (continued)
Containment Pressure - High 1 provides no input to any control functions. Thus, three OPERABLE channels are sufficient to satisfy protective requirements with a two-out-of-three logic.
The transmitters (d/p cells) and electronics are located outside of containment with the sensing line (high pressure side of the transmitter) located inside containment.
Thus, the high pressure Function will not experience any adverse environmental conditions and the
[NTSP] reflects only steady state instrument uncertainties.
Containment Pressure - High 1 must be OPERABLE in MODES 1, 2, and 3 when there is sufficient energy in the primary and secondary systems to pressurize the containment following a pipe break. In MODES 4, 5, and 6, there is insufficient energy in the primary or secondary systems to pressurize the containment.
- d. Safety Injection - Pressurizer Pressure - Low This signal provides protection against the following accidents:
- Inadvertent opening of a steam generator (SG) relief or safety valve,
- SLB,
- A spectrum of rod cluster control assembly ejection accidents (rod ejection),
- Inadvertent opening of a pressurizer relief or safety valve,
- LOCAs, and
- SG Tube Rupture.
At some units pressurizer pressure provides both control and protection functions: input to the Pressurizer Pressure Control System, reactor trip, and SI. Therefore, the actuation logic must be able to withstand both an input failure to control system, which may then require the protection function actuation, and a single failure in the other channels providing the protection function actuation. Thus, four OPERABLE channels are required 2 2 2 2INSERT 2 B 3.3.2 Insert Page B 3.3.2-12 INSERT 2 The transmitters and electronics are located inside the containment annulus, but outside containment, and experience more adverse environmental conditions than if they were located outside containment altogether. However, the environmental effects are less severe than if the transmitters were located inside containment.
The NTSP reflects the inclusion of both steady state instrument uncertainties and slightly more adverse environmental instrument uncertainties.
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APPLICABLE SAFETY ANALYSES, LCO, and APPLICABILITY (continued) to satisfy the requirements with a two
-out-of-four logic. For units that have dedicated protection and control channels, only three protection channels are necessary to satisfy the protective
requirements.
The transmitters are located inside containment, with the taps in the vapor space region of the pressurizer, and thus possibly experiencing adverse environmental conditions (LOCA, SLB inside containment, rod ejection). Therefore, the
[NTSP] reflects the inclusion of both steady state and adverse environmental instrument uncertainties.
This Function must be OPERABLE in MODES 1, 2, and 3 (above P-11) to mitigate the consequences of an HELB inside containment. This signal may be manually blocked by the operator below the P-11 setpoint. Automatic SI actuation below this pressure setpoint is then performed by the Containment Pressure - High 1 signal.
This Function is not required to be OPERABLE in MODE 3 below the P-11 setpoint. Other ESF functions are used to detect accident conditions and actuate the ESF systems in this MODE. In MODES 4, 5, and 6, this Function is not needed for accident detection and mitigation.
- e. Safety Injection - Steam Line Pressure (1) Steam Line Pressure - Low Steam Line Pressure - Low provides protection against the following accidents:
- SLB,
- Feed line break, and
- Inadvertent opening of an SG relief or an SG safety valve. Steam Line Pressure - Low provides no input to any control functions. Thus, three OPERABLE channels on each steam line are sufficient to satisfy the protective requirements with a two-out-of-three logic on each steam line.
with a two-out-of-three logic.
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APPLICABLE SAFETY ANALYSES, LCO, and APPLICABILITY (continued)
With the transmitters typically located inside the steam
tunnels, it is possible for them to experience adverse environmental conditions during a secondary side break.
Therefore, the
[NTSP] reflects both steady state and adverse environmental instrument uncertainties.
This Function is anticipatory in nature and has a typical lead/lag ratio of 50/5.
Steam Line Pressure - Low must be OPERABLE in MODES 1, 2, and 3 (above P-11) when a secondary side break or stuck open valve could result in the rapid depressurization of the steam lines. This signal may be
manually blocked by the operator below the P-11 setpoint.
Below P-11, feed line break is not a concern. Inside
containment SLB will be terminated by automatic SI actuation via Containment Pressure - High 1 , and outside containment SLB will be terminated by the Steam Line Pressure - Negative Rate - High signal for steam line isolation. This Function is not required to be OPERABLE in MODE 4, 5, or 6 because there is insufficient energy in the secondary side of the unit to cause an accident.
(2) Steam Line Pressure
- High Differential Pressure Between Steam Lines Steam Line Pressure
- High Differential Pressure Between Steam Lines provides protection against the following accidents:
- SLB,
- Feed line break, and
- High Differential Pressure Between Steam Lines provides no input to any control fu nctions. Thus, three OPERABLE channels on each steam line are sufficient to satisfy the requirements, with a two
-out-of-three logic on each steam line.
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APPLICABLE SAFETY ANALYSES, LCO, and APPLICABILITY (continued)
With the transmitters typically located inside the steam tunnels, it is possible for them to experience adverse environmental conditions during a SLB event. Therefore, the [NTSP] reflects both steady state and adverse environmental instrument uncertainties. Steam line high differential pressure must be OPERABLE in MODES 1, 2, and 3 when a secondary side break or stuck open valve could result in the rapid depressurization of the steam line(s). This Function is not required to be OPERABLE in MODE 4, 5, or 6 because there is not sufficient energy in the secondary side of the unit to cause an accident.
f, g. Safety Injection
- High Steam Flow in Two Steam Lines Coincident With Tavg - Low Low or Coincident With Steam Line Pressure - Low These Functions (1.f and 1.g) provide protection against the following accidents:
- SLB, and
- the inadvertent opening of an SG relief or an SG safety valve. Two steam line flow channels per steam line are required OPERABLE for these Functions. The steam line flow channels are combined in a one
-out-o f-two logic to indicate high steam flow in one steam line. The steam flow transmitters provide control inputs, but the control function cannot cause the events that the Function must protect against. Therefore, two channels are sufficient to satisfy redu ndancy requirements. The one
-out-of-two configuration allows online testing because trip of one high steam flow channel is not sufficient to cause initiation. High steam flow in two steam lines is acceptable in the case of a single steam line fault due to the fact that the remaining intact steam lines will pick up the full turbine load. The increased steam flow in the remaining intact lines will actuate the required second high steam flow trip. Additional protection is provided by Function 1.e.(2), High Differential Pressure Between Steam Lines. One channel of Tavg per loop and one channel of low steam line pressure per steam line are required OPERABLE. For each parameter, the channels for all loops or steam lines are 2
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APPLICABLE SAFETY ANALYSES, LCO, and APPLICABILITY (continued)
combined in a logic such that two channels tripped will cause a trip for the parameter. For example, for three loop units, the low steam line pressure channels are combined in two
-out-of- three logic. Thus, the Function trips on one
-out-of-two high flow in any two-out-of-three steam lines if there is one
-out-of-one low low Tavg trip in any two
-out-of-three RCS loops, or if there is a one
-out-of-one low pressure trip in any two
-out-of-three steam lines.
Since the accidents that this event protects against cause both low steam line pressure and low low Tavg, provision of one channel per loop or steam line ensures no single random failure can disable both of these Functions. The steam line pressure channels provide no control inputs. The Tavg channels provide control inputs, but the control function cannot initiate events that the Function acts to mitigate.
The Allowable Value for high steam flow is a linear function that varies with power level. The function is a P corresponding to 44% of full steam flow between 0% and 20% load to 114% of full steam flow at 100% load. The nominal trip setpoint is similarly calculated.
With the transmitters typically located inside the containment (Tavg) or inside the steam tunnels (High Steam Flow), it is possible for them to experience adverse steady state environmental conditions during a SLB event. Therefore, the [NTSP] reflects both steady state and adverse environmental instrument uncertainties. The Steam Line Pressure
- Low signal was discussed previously under Function 1.e.(1). This Function must be OPERABLE in MODES 1, 2, and 3 (above P-12) when a secondary side break or stuck open valve could result in the rapid depressurization of the steam line(s). This signal may be manually blocked by the operator when below the P
-12 setpoint. Above P
-12, this Function is automatically unblocked. This Function is not required OPERABLE below P
-12 because the reactor is not critical, so feed line break is not a concern. SLB may be addressed by Containment Pressure High 1 (inside containment) or by High Steam Flow in Two Steam Lines coincident with Steam Line Pressure - Low, for Steam Line Isolation, followed by High Differential Pressure Between Two Steam Lines, for SI. This Function is not required to be OPERABLE in MODE 4, 5, or 6 because there is insufficient energy in the secondary side of the unit to cause an accident.
2 Engineered Safety Feature Actuation System (ESFAS) Instrumentation (Without Setpoint Control Program)
B 3.3.2 A Westinghouse STS B 3.3.2 A-17 Rev. 4.0 SEQUOYAH UNIT 2 Revision XXX 1 1 2BASES
APPLICABLE SAFETY ANALYSES, LCO, and APPLICABILITY (continued)
- 2. Containment Spray Containment Spray provides three primary functions: 1. Lower s containment pressure and temperature after an HELB in containment
, 2. Reduces the amount of radioactive iodine in the containment atmosphere, and
.
These function s are necessary to
- Ensure the pressure boundary integrity of the containment structure ,
- Limit the release of radioactive iodine to the environment in the event of a failure of the containment structure, and
- Minimize corrosion of the components and systems inside containment following a LOCA. The containment spray actuation signal starts the containment spray pumps and aligns the discharge of the pumps to the containment spray nozzle headers in the upper levels of containment. Water is initially drawn from the RWST by the containment spray pumps and mixed with a sodium hydroxide so lution from the spray additive tank. When the RWST reaches the low low level setpoint, the spray pump suctions are shifted to the containment sump if continued containment spray is required. Containment spray is actuated manually by Containment Pressure
- High 3 or Containment Pressure - High High.
- a. Containment Spray - Manual Initiation The operator can initiate containment spray at any time from the
control room by simultaneously turning two containment spray actuation switches in the same train. Because an inadvertent actuation of containment spray could have such serious consequences, two switches must be turned simultaneously to initiate containment spray. There are two sets of two switches each in the control room. Simultaneously turning the two to This is or automaticall y Phase B & Containment Ventilation Isolation 2 2 2 2 2-Engineered Safety Feature Actuation System (ESFAS) Instrumentation (Without Setpoint Control Program)
B 3.3.2 A Westinghouse STS B 3.3.2 A-18 Rev. 4.0 SEQUOYAH UNIT 2 Revision XXX 1 1 2 BASES
APPLICABLE SAFETY ANALYSES, LCO, and APPLICABILITY (continued)
switches in either set will actuate containment spray in both trains in the same manner as the automatic actuation signal.
Two Manual Initiation switches in each train are required to be OPERABLE to ensure no single failure disables the Manual Initiation Function. Note that Manual Initiation of containment spray also actuates Phase B containment isolation.
- b. Containment Spray - Automatic Actuation Logic and Actuation Relays Automatic actuation logic and actuation relays consist of the same features and operate in the same manner as described for ESFAS Function 1.b.
Manual and automatic initiation of containment spray must be OPERABLE in MODES 1, 2, and 3 when there is a potential for an accident to occur, and sufficient energy in the primary or secondary systems to pose a threat to containment integrity due to overpressure conditions. Manual initiation is also required in MODE 4, even though automatic actuation is not required. In this MODE, adequate time is available to manually actuate required components in the event of a DBA. However, because of the large number of components actuated on a containment
spray, actuation is simplified by the use of the manual actuation push buttons. Automatic actuation logic and actuation relays must be OPERABLE in MODE 4 to support system level manual initiation. In MODES 5 and 6, there is insufficient energy in the primary and secondary systems to result in containment overpressure. In MODES 5 and 6, there is also adequate time for the operators to evaluate unit conditions and respond, to mitigate the consequences of abnormal conditions by manually starting individual components.
- c. Containment Spray - Containment Pressure This signal provides protection against a LOCA or a SLB inside containment. The transmitters (d/p cells) are located outside of containment with the sensing line (high pressure side of the transmitter) located inside containment. The transmitters and electronics are located outside of containment. Thus, they will not experience any adverse environmental conditions and the [NTSP] reflects only steady state instrument uncertainties.
switches 2 2 INSERT 3but does not close the Main Steam Isolation Valves B 3.3.2 Insert Page B 3.3.2-18 INSERT 3 The transmitters and electronics are located inside the containment annulus, but outside containment, and experience more adverse environmental conditions than if they were located outside containment altogether. However, the environmental effects are less severe than if the transmitters were located inside containment.
The NTSP reflects the inclusion of both steady state instrument uncertainties and slightly more adverse environmental instrument uncertainties.
2 Engineered Safety Feature Actuation System (ESFAS) Instrumentation (Without Setpoint Control Program)
B 3.3.2 A Westinghouse STS B 3.3.2 A-19 Rev. 4.0 SEQUOYAH UNIT 2 Revision XXX 1 1 2BASES
APPLICABLE SAFETY ANALYSES, LCO, and APPLICABILITY (continued)
This is one of the only Functions that requires the bistable output to energize to perform its required action. It is not desirable to have a loss of power actuate containment spray, since the consequences of an inadvertent actuation of containment spray could be serious. Note that this Function also has the inoperable channel placed in bypass rather than trip to decrease the probability of an inadvertent actuation.
Two different logic configurations are typically used. Three and four loop units use four channels in a two-out-of-four logic configuration. This configuration may be called the Containment Pressure - High 3 Setpoint for three and four loop units, and Containment Pressure
- High High Setpoint for other units. Some two loop units use three sets of two channels, each set combined in a one
-out-of-two configuration, with these outputs combined so that two
-out-of-three sets tripped initiates containment spray. This configuration is called Containment Pressure - High 3 Setpoint.
Since containment pressure is not used for control, both of the se arrangement s exceed the minimum redundancy requirements. Additional redundancy is warranted because this Function is energized to trip. Containment Pressure -
[High 3] [High High] must be OPERABLE in MODES 1, 2, and 3 when there is sufficient energy in the primary and secondary sides to pressurize the containment following a pipe break. In MODES 4, 5, and 6, there is insufficient energy in the primary and secondary sides to pressurize the containment and reach the Containment Pressure - High 3 (High High) setpoint s. 3. Containment Isolation Containment Isolation provides isolation of the containment atmosphere, and all process systems that penetrate containment, from the environment. This Function is necessary to prevent or limit the release of radioactivity to the environment in the event of a large
break LOCA.
There are two separate Containment Isolation signals, Phase A and Phase B. Phase A isolation isolates all automatically isolable process lines, except component cooling water (CCW), at a relatively low containment pressure indicative of primary or secondary system leaks. For these types of events, forced circulation cooling using the reactor coolant pumps (RCPs) and SGs is the preferred (but not required) method of decay heat removal. Since CCW is required to support RCP operation, not isolating CCW on the low pressure This function uses This , essential raw cooling water, and control air component cooling water 2 2 4 2 2 2 s - -
Engineered Safety Feature Actuation System (ESFAS) Instrumentation (Without Setpoint Control Program)
B 3.3.2 A Westinghouse STS B 3.3.2 A-20 Rev. 4.0 SEQUOYAH UNIT 2 Revision XXX 1 1 2BASES
APPLICABLE SAFETY ANALYSES, LCO, and APPLICABILITY (continued)
Phase A signal enhances unit safety by allowing operators to use forced RCS circulation to cool the unit. Isolating CCW on the low pressure signal may force the use of feed and bleed cooling, which could prove more difficult to control.
Phase A containment isolation is actuated automatically by SI, or manually via the automatic actuation logic. All process lines penetrating containment, with the exception of CCW , are isolated.
CCW is not isolated at this time to permit continued operation of the RCPs with cooling water flow to the thermal barrier heat exchangers and air or oil coolers. All process lines not equipped with remote operated isolation valves are manually closed, or otherwise isolated, prior to reaching MODE 4.
Manual Phase A Containment Isolati on is accomplished by either of two switches in the control room. Either switch actuates both trains.
Note that manual actuation of Phase A Containment Isolation also actuates Containment Purge and Exhaust Isolation.
The Phase B signal isolates CCW. This occurs at a relatively high containment pressure that is indicative of a large break LOCA or a SLB. For these events, forced circulation using the RCPs is no longer desirable. Isolating the CCW at the higher pressure does not pose a challenge to the containment boundary because the CCW System is a closed loop inside containment. Although some system components do not meet all of the ASME Code requirements applied to the containment itself, the system is continuously pressurized to a pressure greater than the Phase B setpoint. Thus, routine operation demonstrates the integrity of the system pressure boundary for pressures exceeding the Phase B setpoint. Furthermore, because system pressure exceeds the Phase B setpoint, any system leakage prior to initiation of Phase B isolation would be into containment.
Therefore, the combination of CCW System design and Phase B isolation ensures the CCW System is not a potential path for radioactive release from containment.
Phase B containment isolation is actuated by Containment Pressure -
High 3 or Containment Pressure
- High High, or manually, via the automatic actuation logic, as previously discussed. For containment pressure to reach a value high enough to actuate Containment
Pressure -
High 3 or Containment Pressure
- High High, a large break LOCA or SLB must have occurred and containment spray must component cooling water, essential raw cooling water, and control air component cooling water Component cooling water component cooling water Component Cooling Water component cooling water, essential raw cooling water , and control ai r Component Cooling Water 2 2 2 2 2 2 2 2- - Ventilation 2Phase A Engineered Safety Feature Actuation System (ESFAS) Instrumentation (Without Setpoint Control Program)
B 3.3.2 A Westinghouse STS B 3.3.2 A-21 Rev. 4.0 SEQUOYAH UNIT 2 Revision XXX 1 1 2BASES
APPLICABLE SAFETY ANALYSES, LCO, and APPLICABILITY (continued)
have been actuated. RCP operation will no longer be required and CCW to the RCPs is, therefore, no longer necessary. The RCPs can be operated with seal injection flow alone and without CCW flow to the thermal barrier heat exchanger.
Manual Phase B Containment Isolation is accomplished by the same switches that actuate Containment Spray. When the two switches in either set are turned simultaneously, Phase B Containment Isolation and Containment Spray will be actuated in both trains.
- a. Containment Isolation - Phase A Isolation (1) Phase A Isolation - Manual Initiation Manual Phase A Containment Isolation is actuated by either of two switches in the control room. Either switch actuates both trains. Note that manual initiation of Phase A Containment Isolation also actuates Containment Purge Isolation.
(2) Phase A Isolation - Automatic Actuation Logic and Actuation Relays Automatic Actuation Logic and Actuation Relays consist of the same features and operate in the same manner as described for ESFAS Function 1.b.
Manual and automatic initiation of Phase A Containment Isolation must be OPERABLE in MODES 1, 2, and 3, when there is a potential for an accident to occur. Manual initiation is also required in MODE 4 even though automatic actuation is not required. In this MODE, adequate time is available to manually actuate required components in the event of a DBA , but because of the large number of components actuated on a Phase A Containment Isolation, actuation is simplified by the use of the manual actuation push buttons. Automatic actuation logic and actuation relays must be OPERABLE in MODE 4 to support system level manual initiation. In MODES 5 and 6, there is insufficient energy in the primary or secondary systems to pressurize the containment to require Phase A Containment Isolation. There also is adequate time for the operator to evaluate unit conditions and manually actuate individual isolation valves in response to abnormal or accident conditions. component cooling water an accident switches 2 2 2Ventilation 2
Engineered Safety Feature Actuation System (ESFAS) Instrumentation (Without Setpoint Control Program)
B 3.3.2 A Westinghouse STS B 3.3.2 A-22 Rev. 4.0 SEQUOYAH UNIT 2 Revision XXX 1 1 2BASES
APPLICABLE SAFETY ANALYSES, LCO, and APPLICABILITY (continued)
(3) Phase A Isolation - Safety Injection Phase A Containment Isolation is also initiated by all Functions that initiate SI. The Phase A Containment Isolation requirements for these Functions are the same as the requirements for their SI function. Therefore, the requirements are not repeated in Table 3.3.2-1. Instead, Function 1, SI, is referenced for all initiating Functions and
requirements.
- b. Containment Isolation - Phase B Isolation Phase B Containment Isolation is accomplished by Manual Initiation, Automatic Actuation Logic and Actuation Relays, and by Containment Pressure channels (the same channels that
actuate Containment Spray, Function 2). The Containment Pressure trip of Phase B Containment Isolation is energized to trip in order to minimize the potential of spurious trips that may damage the RCPs.
(1) Phase B Isolation - Manual Initiation (2) Phase B Isolation - Automatic Actuation Logic and Actuation Relays Manual and automatic initiation of Phase B containment isolation must be OPERABLE in MODES 1, 2, and 3, when there is a potential for an accident to occur. Manual initiation is also required in MODE 4 even though automatic actuation is not required. In this MODE, adequate time is available to manually actuate required components in the
event of a DBA. However, because of the large number of components actuated on a Phase B containment isolation, actuation is simplified by the use of the manual actuation push buttons. Automatic actuation logic and actuation relays must be OPERABLE in MODE 4 to support system level manual initiation. In MODES 5 and 6, there is insufficient energy in the primary or secondary systems to pressurize the containment to require Phase B containment isolation. There also is adequate time for the operator to evaluate unit conditions and manually actuate individual isolation valves in response to abnormal or accident conditions.
an accident INSERT 4 hand switches 2 2 2 B 3.3.2 Insert Page B 3.3.2-22 INSERT 4 The operator can initiate Phase B containment isolation at any time from the control room by simultaneously turning two Phase B & Containment Ventilation Isolation switches in the same train. There are two sets of two switches each in the control room. Simultaneously turning the two switches in either set will actuate Phase B containment isolation in both trains in the same manner as the automatic actuation signal. Two Manual Initiation switches in each train are required to be OPERABLE to ensure no single failure disables the Manual Initiation Function. Note that Manual Initiation of Phase B containment isolation also actuates containment spray and containment vent isolation.
2 Engineered Safety Feature Actuation System (ESFAS) Instrumentation (Without Setpoint Control Program)
B 3.3.2 A Westinghouse STS B 3.3.2 A-23 Rev. 4.0 SEQUOYAH UNIT 2 Revision XXX 1 1 2BASES
APPLICABLE SAFETY ANALYSES, LCO, and APPLICABILITY (continued)
(3) Phase B Isolation - Containment Pressure The basis for containment pressure MODE applicability is as discussed for ESFAS Function 2.c above.
- 4. Steam Line Isolation Isolation of the main steam lines provides protection in the event of a SLB inside or outside containment. Rapid isolation of the steam lines will limit the steam break accident to the blowdown from one SG, at most. For a SLB upstream of the main steam isolation valves (MSIVs), inside or outside of containment, closure of the MSIVs limits the accident to the blowdown from only the affected SG. For a SLB downstream of the MSIVs, closure of the MSIVs terminates the accident as soon as the steam lines depressurize. For units that do not have steam line check valves, Steam Line Isolation also mitigates the effects of a feed line break and ensures a source of steam for the turbine driven AFW pump during a feed line break.
- a. Steam Line Isolation - Manual Initiation Manual initiation of Steam Line Isolation can be accomplished
from the control room. There are two switches in the control room and either switch can initiate action to immediately close all MSIV s. The LCO requires two channels to be OPERABLE.
- b. Steam Line Isolation - Automatic Actuation Logic and Actuation Relays Automatic actuation logic and actuation relays consist of the same features and operate in the same manner as described for ESFAS Function 1.b.
Manual and automatic initiation of steam line isolation must be OPERABLE in MODES 1, 2, and 3 when there is sufficient energy in the RCS and SGs to have a SLB or other accident.
This could result in the release of significant quantities of energy and cause a cooldown of the primary system. The Steam Line Isolation Function is required in MODES 2 and 3 unless all MSIVs are closed and [de-activated]. In MODES 4, 5, and 6, there is insufficient energy in the RCS and SGs to experience a SLB or other accident releasing significant quantities of energy.
four each s its associatedone channel per steam line 2 2 4 Engineered Safety Feature Actuation System (ESFAS) Instrumentation (Without Setpoint Control Program)
B 3.3.2 A Westinghouse STS B 3.3.2 A-24 Rev. 4.0 SEQUOYAH UNIT 2 Revision XXX 1 1 2BASES
APPLICABLE SAFETY ANALYSES, LCO, and APPLICABILITY (continued)
- c. Steam Line Isolation - Containment Pressure - High 2 This Function actuates closure of the MSIVs in the event of a LOCA or a SLB inside containment to maintain at least one unfaulted SG as a heat sink for the reactor, and to limit the mass and energy release to containment. The transmitters (d/p cells) are located outside containment with the sensing line (high pressure side of the transmitter) located inside containment.
Containment Pressure - High 2 provides no input to any control functions. Thus, three OPERABLE channels are sufficient to satisfy protective requirements with two-out-of-three logic. However, for enhanced reliability, this Function was designed with four channels and a two-out-of-four logic.
The transmitters and electronics are located outside of containment. Thus, they w ill not experience any adverse environmental conditions, and the [NTSP] reflects only steady state instrument uncertainties.
Containment Pressure - High 2 must be OPERABLE in MODES 1, 2, and 3, when there is sufficient energy in the primary and secondary side to pressurize the containment following a pipe break. This would cause a significant increase in the containment pressure, thus allowing detection and closure of the MSIVs. The Steam Line Isolation Function remains OPERABLE in MODES 2 and 3 unless all MSIVs are closed and [de-activated]. In MODES 4, 5, and 6, there is not enough energy in the primary and secondary sides to pressurize the containment to the Containment Pressure - High 2 setpoint.
- d. Steam Line Isolation - Steam Line Pressure (1) Steam Line Pressure - Low Steam Line Pressure - Low provides closure of the MSIVs in the event of a SLB to maintain at least one unfaulted SG as a heat sink for the reactor, and to limit the mass and energy release to containment. This Function provides closure of the MSIVs in the event of a feed line break to ensure a supply of steam for the turbine driven AFW pump. Steam Line Pressure - Low was discussed previously under SI Function 1.e.1.
Steam Line Pressure - Low Function must be OPERABLE in MODES 1, 2, and 3 (above P-11), with any main steam valve open, when a secondary side break or stuck open INSERT 5 -High-High-High-High 2 2 2 2 2 4when the Steam Line Isolation on Steam LinePressure, Negative Rate-High is blocked B 3.3.2 Insert Page B 3.3.2-24 INSERT 5 The transmitters and electronics are located inside the containment annulus, but outside containment, and experience more adverse environmental conditions than if they were located outside containment altogether. However, the environmental effects are less severe than if the transmitters were located inside containment.
The NTSP reflects the inclusion of both steady state instrument uncertainties and slightly more adverse environmental instrument uncertainties.
2 Engineered Safety Feature Actuation System (ESFAS) Instrumentation (Without Setpoint Control Program)
B 3.3.2 A Westinghouse STS B 3.3.2 A-25 Rev. 4.0 SEQUOYAH UNIT 2 Revision XXX 1 1 2BASES
APPLICABLE SAFETY ANALYSES, LCO, and APPLICABILITY (continued)
valve could result in the rapid depressurization of the steam lines. This signal may be manually blocked by the operator below the P-11 setpoint. Below P-11, an inside containment SLB will be terminated by automatic actuation via Containment Pressure - High
- 2. Stuck valve transients and outside containment SLBs will be terminated by the Steam Line Pressure - Negative Rate - High signal for Steam Line Isolation below P-11 when SI has been manually blocked.
The Steam Line Isolation Function is required in MODES 2
and 3 unless all MSIVs are closed and [de-activated]. This Function is not required to be OPERABLE in MODES 4, 5, and 6 because there is insufficient energy in the secondary side of the unit to have an accident.
(2) Steam Line Pressure - Negative Rate - High Steam Line Pressure - Negative Rate - High provides closure of the MSIVs for a SLB when less than the P-11 setpoint, to maintain at least one unfaulted SG as a heat sink for the reactor, and to limit the mass and energy
release to containment. When the operator manually blocks the Steam Line Pressure - Low main steam isolation signal when less than the P-11 setpoint, the Steam Line Pressure -
Negative Rate - High signal is automatically enabled.
Steam Line Pressure - Negative Rate - High provides no input to any control functions. Thus, three OPERABLE channels are sufficient to satisfy requirements with a two-out-of-three logic on each steam line.
Steam Line Pressure - Negative Rate - High must be OPERABLE in MODE 3 when less than the P-11 setpoint, when a secondary side break or stuck open valve could result in the rapid depressurization of the steam line(s). In MODES 1 and 2, and in MODE 3, when above the P-11 setpoint, this signal is automatically disabled and the Steam Line Pressure - Low signal is automatically enabled. The Steam Line Isolation Function is required to be OPERABLE in MODES 2 and 3 unless all MSIVs are closed and [de-activated]. In MODES 4, 5, and 6, there is insufficient energy in the primary and secondary sides to have a SLB or other accident that would result in a release of significant enough quantities of energy to cause a cooldown of the RCS. -High 2 4 4 2, and the Steam Line Isolation on Steam LinePressure, Low is blocked Engineered Safety Feature Actuation System (ESFAS) Instrumentation (Without Setpoint Control Program)
B 3.3.2 A Westinghouse STS B 3.3.2 A-26 Rev. 4.0 SEQUOYAH UNIT 2 Revision XXX 1 1 2BASES
APPLICABLE SAFETY ANALYSES, LCO, and APPLICABILITY (continued)
While the transmitters may experience elevated ambient temperatures due to a SLB, the trip function is based on rate of change, not the absolute accuracy of the indicated steam pressure. Therefore, the
[NTSP] reflects only steady state instrument uncertainties.
e, f. Steam Line Isolation
- High Steam Flow in Two Steam Lines Coincident with Tavg - Low Low or Coin cident With Steam Line Pressure - Low (Three and Four Loop Units)
These Functions (4.e and 4.f) provide closure of the MSIVs during a SLB or inadvertent opening of an SG relief or a safety valve, to maintain at least one unfaulted SG as a heat sink for the reactor and to limit the mass and energy release to containment.
These Functions were discussed previously as Functions 1.f. and 1.g. These Functions must be OPERABLE in MODES 1 and 2, and in MODE 3, when a secondary side break or stuck open valve could result in the rapid depressurization of the steam lines unless all MSIVs are closed and [de
-activated]. These Functions are not required to be OPERABLE in MODES 4, 5, and 6 because there is insufficient energy in the secondary side of the unit to have an accident.
- g. Steam Line Isolation
- High Steam Flow Coincident With Safety Injection and Coincident With Tavg - Low Low (Two Loop Units)
This Function provides closure of the MSIVs during a SLB or inadvertent opening of an SG relief or safety valve to ma intain at least one unfaulted SG as a heat sink for the reactor, and to limit the mass and energy release to containment.
Two steam line flow channels per steam line are required OPERABLE for this Function. These are combined in a one
-out-of-two logic to indicate high steam flow in one steam line. The steam flow transmitters provide control inputs, but the control function cannot cause the events that the function must protect against. Therefore, two channels are sufficient to satisfy redundancy require ments. The one
-out-of-two configuration allows online testing because trip of one high steam flow channel is not sufficient to cause initiation.
2 4 Engineered Safety Feature Actuation System (ESFAS) Instrumentation (Without Setpoint Control Program)
B 3.3.2 A Westinghouse STS B 3.3.2 A-27 Rev. 4.0 SEQUOYAH UNIT 2 Revision XXX 1 1 2BASES
APPLICABLE SAFETY ANALYSES, LCO, and APPLICABILITY (continued)
The High Steam Flow Allowable Valu e is a P corresponding to 25% of full steam flow at no load steam pressure. The Trip Setpoint is similarly calculated.
With the transmitters (d/p cells) typically located inside the steam tunnels, it is possible for them to experience adverse environmental conditions during a SLB event. Therefore, the
[NTSP] reflect both steady state and adverse environmental instrument uncertainties.
The main steam line isolates only if the high steam flow signal occurs coincident with a SI and low low RCS average temperature. The Main Steam Line Isolation Function requirements for the SI Functions are the same as the requirements for their SI function. Therefore, the requirements are not repeated in Table 3.3.2-1. Instead, Function 1, SI, is referenced for all initiating functions and requirements.
Two channels of Tavg per loop are required to be OPERABLE.
The Tavg channels are combined in a logic such that two channels tripped cause a trip for the parameter. The accidents that this Function protects against cause reduction of Tavg in the entire primary system. Therefore, the provision of two OPERABLE channels per loop in a two
-out-of-four configuration ensures no single random failure disables the T avg - Low Low Function. The Tavg channels provide control inputs, but the control function cannot initiate events that the Function acts to mitigate. Therefore, additional channels are not required to address control protection interaction issues.
With the Tavg resistance temperature detectors (RTDs) located inside the containment, it is possible for them to experience adverse environmental conditions during a SLB event.
Therefore, the
[NTSP] reflects both steady state and adverse environmental instrumental uncertainties.
This Function must be OPERABLE in MODES 1 and 2, and in MODE 3, when above the P
-12 setpoint, when a secondary side break or stuck open valve could result in rapid depressurization of the steam lines. Below P
-12 this Function is not required to be OPERABLE because the High High Steam Flow coincident with SI Function provides the required protection. The Steam Line Isolation Function is required to be OPERABLE in 2
Engineered Safety Feature Actuation System (ESFAS) Instrumentation (Without Setpoint Control Program)
B 3.3.2 A Westinghouse STS B 3.3.2 A-28 Rev. 4.0 SEQUOYAH UNIT 2 Revision XXX 1 1 2BASES
APPLICABLE SAFETY ANALYSES, LCO, and APPLICABILITY (continued)
MODES 2 and 3 unless all MSIVs are closed and [de
-activated].
This Function is not required to be OPERABLE in MODES 4, 5, and 6 because there is insufficient energy in the secondary side of the unit to have an accident.
- h. Steam Line Isolation
- High High Steam Flow Coincident With Safety Injection (Two Loop Units)
This Function provides closure of the MSIVs during a steam line break (or inadvertent opening of a relief or safety valve) to maintain at least one unfaulted SG as a heat sink for the reactor, and to limit the mass and energy release to containment.
Two steam line flow channels per steam line are required to be OPERABLE for this Function. These are combined in a one
-out-of-two logic to indicate high steam flow in one steam line. The steam flow transmitters provide control inputs, but the control function cannot cause the events that the Function must protect against. Therefore, two channels are sufficient to satisfy redundancy requirements.
The Allowable Value for high steam flow is a P, corresponding to 130% of full steam flow at full steam pressure. The Trip Setpoint is similarly calculated.
With the transmitters typically located inside the steam tunnels, it is possible for them to expe rience adverse environmental conditions during a SLB event. Therefore, the
[NTSP] reflects both steady state and adverse environmental instrument uncertainties.
The main steam lines isolate only if the high steam flow signal occurs coincident with a SI signal. The Main Steam Line Isolation Function requirements for the SI Functions are the same as the requirements for their SI function. Therefore, the requirements are not repeated in Table 3.3.2-1. Instead, Function 1, SI, is referenced for all initiating functions and requirements.
This Function must be OPERABLE in MODES 1, 2, and 3 when a secondary side break or stuck open valve could result in rapid depressurization of the steam lines unless all MSIVs are closed and [de-activated]. This Function is not required to be OPERABLE in MODES 4, 5, and 6 because there is insufficient energy in the secondary side of the unit to have an accident.
2 Engineered Safety Feature Actuation System (ESFAS) Instrumentation (Without Setpoint Control Program)
B 3.3.2 A Westinghouse STS B 3.3.2 A-29 Rev. 4.0 SEQUOYAH UNIT 2 Revision XXX 1 1 2BASES
APPLICABLE SAFETY ANALYSES, LCO, and APPLICABILITY (continued)
- 5. Turbine Trip and Feedwater Isolation The primary functions of the Turbine Trip and Feedwater Isolation signals are to prevent damage to the turbine due to water in the steam lines, and to stop the excessive flow of feedwater into the SGs. These Functions are necessary to mitigate the effects of a high water level in the SGs, which could result in carryover of water into the steam lines and excessive cooldown of the primary system. The SG high water level is due to excessive feedwater flows.
The Function is actuated when the level in any SG exceeds the high high setpoint, and performs the following functions:
- Trips the main turbine,
- Trips the MFW pumps,
- Initiates feedwater isolation, and
This Function is actuated by SG Water Level - High High, or by a SI signal. The RTS also initiates a turbine trip signal whenever a reactor trip (P-4) is generated. In the event of SI, the unit is taken off line and the turbine generator must be tripped. The MFW System is also taken out of operation and the AFW System is automatically started. The SI signal was discussed previously.
- a. Turbine Trip and Feedwater Isolation - Automatic Actuation Logic and Actuation Relays Automatic Actuation Logic and Actuation Relays consist of the same features and operate in the same manner as described for ESFAS Function 1.b.
- b. Turbine Trip and Feedwater Isolation - Steam Generator Water Level - High High (P-14)
This signal provides protection against excessive feedwater flow. The ESFAS SG water level instruments provide input to the SG Water Level Control System. Therefore, the actuation logic must be able to withstand both an input failure to the control system (which may then require the protection function actuation) and a The nominal trip setpoint and allowable value limits are a percentage of the narrow range instrument span for each steam generator.
2 Engineered Safety Feature Actuation System (ESFAS) Instrumentation (Without Setpoint Control Program)
B 3.3.2 A Westinghouse STS B 3.3.2 A-30 Rev. 4.0 SEQUOYAH UNIT 2 Revision XXX 1 1 2BASES
APPLICABLE SAFETY ANALYSES, LCO, and APPLICABILITY (continued)
single failure in the other channels providing the protection function actuation.
Thus, four OPERABLE channels are required to satisfy the requirem ents with a two
-out-of-four logic. For units that have dedicated protection and control channels, only three protection channels are necessary to satisfy the protective requirements. For other units that have only three channels, a median signal selector is provided or justification is provided in NUREG-1218 (Ref.
8). The transmitters (d/p cells) are located inside containment. However, the events that this Function protects against cannot cause a severe environment in containment. Therefore, the
[NTSP] reflects only steady state instrument uncertainties.
- c. Turbine Trip and Feedwater Isolation - Safety Injection Turbine Trip and Feedwater Isolation is also initiated by all Functions that initiate SI. The Feedwater Isolation Function requirements for these Functions are the same as the requirements for their SI function. Therefore, the requirements are not repeated in Table 3.3.2-1. Instead Function 1, SI, is referenced for all initiating functions and requirements.
Turbine Trip and Feedwater Isolation Functions must be OPERABLE in MODES 1 and 2
[and 3] except when all MFIVs, MFRVs, [and associated bypass valves
] are closed and [de-activated] [or isolated by a closed manual valve
] when the MFW System is in operation and the turbine generator may be in operation. In MODES
[3,] 4, 5, and 6, the MFW System and the turbine generator are not in service and this Function is not required to be OPERABLE.
- 6. Auxiliary Feedwater The AFW System is designed to provide a secondary side heat sink for the reactor in the event that the MFW System is not available.
The system has two motor driven pumps and a turbine driven pump, making it available during normal unit operation, during a loss of AC power, a loss of MFW, and during a Feedwater System pipe break. The normal source of water for the AFW System is the condensate storage tank (CST) (normally not safety related). A low level in the CST will automatically realign the pump suctions to the Essential Service Wate r (ESW) System (safety related). The AFW System is aligned so that upon a pump start, flow is initiated to the respective SGs immediately.
because Raw Cooling Water (ERCW) pressureAFW suction line , with a two-out-o f-three lo gic, 2 2 4 4MFRV Engineered Safety Feature Actuation System (ESFAS) Instrumentation (Without Setpoint Control Program)
B 3.3.2 A Westinghouse STS B 3.3.2 A-31 Rev. 4.0 SEQUOYAH UNIT 2 Revision XXX 1 1 2BASES
APPLICABLE SAFETY ANALYSES, LCO, and APPLICABILITY (continued)
- a. Auxiliary Feedwater - Automatic Actuation Logic and Actuation Relays (Solid State Protection System)
Automatic actuation logic and actuation relays consist of the same features and operate in the same manner as described for ESFAS Function 1.b.
- Automatic Actuation Logic and Actuation Relays (Balance of Plant ESFAS)
Automatic actuation logic and actuation relays consist of the same features and operate in the same manner as described for ESFAS Function 1.b. c. Auxiliary Feedwater - Steam Generator Water Level - Low Low SG Water Level - Low Low provides protection against a loss of heat sink. A feed line break, inside or outside of containment, or a loss of MFW, would result in a loss of SG water level. SG Water Level - Low Low provides input to the SG Level Control System. Therefore, the actuation logic must be able to withstand both an input failure to the control system which may then require a protection function actuation and a single failure in the other channels providing the protection function actuation. Thus, four OPERABLE channels are required to satisfy the requirements with two
-out-of-four logic. For units that have dedicated protection and control channels, only three protection channels are necessary to satisfy the protective requirements.
For other units that have only three channels, a median signal selector is provided or justification is provided in Reference
- 8.
With the transmitters (d/p cells) located inside containment and thus possibly experiencing adverse environmental conditions (feed line break), the [NTSP] reflects the inclusion of both steady state and adverse environmental instrument uncertainties.
- d. Auxiliary Feedwater - Safety Injection A SI signal starts the motor driven and turbine driven AFW
pumps. The AFW initiation functions are the same as the requirements for their SI function. Therefore, the requirements are not repeated in Table 3.3.2-1. Instead, Function 1, SI, is referenced for all initiating functions and requirements.
- b. INSERT 6 , with a two-out-of-three logic,c. 2 2 2due to a which results INSERT 7 2 2because B 3.3.2 Insert Page B 3.3.2-31a INSERT 6 With the transmitters located inside containment and thus possibly experiencing adverse environmental conditions (due to a feedline break), the Environmental Allowance Modifier (EAM) was devised. The EAM function (Containment Pressure (EAM) with a setpoint of < 0.5 psig) senses the presence of adverse containment conditions (elevated pressure) and enables the Steam Generator Water Level - Low-Low setpoint (Adverse) which reflects the increased transmitter uncertainties due to this environment. The EAM allows the use of a
lower Steam Generator Water Level - Low-Low (EAM) setpoint when these conditions are not present, thus allowing more margin for normal operating conditions. Additionally, the NTSP reflects the inclusion of both steady state and adverse environmental instrument uncertainties.
The Trip Time Delay (TTD) creates additional operational margin when the plant needs it most, during early escalation to power, by allowing the operator time to recover level when the primary side load is sufficiently small to allow such action. The TTD is based on continuous monitoring of primary side power through the use of RCS loop T. Two time delays are calculated, based on the number of steam generators indicating less than the Low-Low Level setpoint and the primary side power level. The magnitude of the delays decreases with increasing primary side power level, up to 50% RTP. Above 50% RTP there are no time delays for the Low-Low level trips.
In the event of failure of a Steam Generator Water Level channel, it is placed in the trip condition as input to the Solid State Protection System and does not affect either the EAM or TTD setpoint calculations for the remaining OPERABLE channels. Failure of the Containment Pressure (EAM) channel to a protection set also does not affect the EAM setpoint calculations. This results in the requirement that the operator adjust the affected Steam Generator Water Level -
Low-Low (EAM) trip setpoints to the same value as the Steam Generator Water Level - Low-Low (Adverse) trip setpoints or actuate the SG Water Level Low-Low setpoint. Failure of the RCS loop T channel input (failure of more than one T H resistance temperature detectors (RTD) or failure of a T C RTD) does not affect the TTD calculation for a protection set. This results in the requirement that the operator adjust the threshold power level for zero seconds time delay from 50%
RTP to 0% RTP, through the man-machine-interface (MMI) test cart.
There are three Steam Generator Water Level Low-Low channels per steam generator arranged in a two-out-of-three logic. These channels are arranged in four protection sets with each channel of the Containment Pressure (EAM) and
RCS Loop T inputting into its associated protection set.
2 B 3.3.2 Insert Page B 3.3.2-31b INSERT 7 With the transmitters (d/p cells) located inside containment and the accidents the channel provides protection for occurring outside containment, the NTSP reflects only steady state instrument uncertainties. Because the transmitters (d/p cells) are located inside containment, thus possi bly experiencing adverse environmental conditions during a feed line break inside containment, the SG Water Level-Low Low Trip Setpoint may not have sufficient margin to account for adverse environmental instrument uncertainties; in this case, AFW pump start will be provided by a Containment Pressure-High SI signal.
2 Engineered Safety Feature Actuation System (ESFAS) Instrumentation (Without Setpoint Control Program)
B 3.3.2 A Westinghouse STS B 3.3.2 A-32 Rev. 4.0 SEQUOYAH UNIT 2 Revision XXX 1 1 2BASES
APPLICABLE SAFETY ANALYSES, LCO, and APPLICABILITY (continued)
- e. Auxiliary Feedwater - Loss of Offsite Power A loss of offsite power to the service buses will be accompanied by a loss of reactor coolant pumping power and the subsequent need for some method of decay heat removal. The loss of offsite power is detected by a voltage drop on each service bus. Loss of power to either service bus will start the turbine driven AFW pump s to ensure that at least one SG contains enough water to serve as the heat sink for reactor decay heat and sensible heat removal following the reactor trip.
Functions 6.a through 6.
e must be OPERABLE in MODES 1, 2, and 3 to ensure that the SGs remain the heat sink for the reactor.
SG Water Level - Low Low in any operating SG will cause the motor
driven AFW pumps to start. The system is aligned so that upon a start of the pump, water immediately begins to flow to the SGs.
SG Water Level - Low Low in any two operating SGs will cause the
turbine driven pump s to start. These Functions do not have to be OPERABLE in MODES 5 and 6 because there is not enough heat being generated in the reactor to require the SGs as a heat sink. In MODE 4, AFW actuation does not need to be OPERABLE because either AFW or residual heat removal (RHR) will already be in operation to remove decay heat or sufficient time is available to manually place either system in operation.
- Undervoltage Reactor Coolant Pump A loss of power on the buses that provide power to the RCPs provides indication of a pending loss of RCP forced flow in the RCS. The Undervoltage RCP Function senses the voltage downstream of each RCP breaker. A loss of power, or an open RCP breaker, on two or more RCPs, will start the turbine driven AFW pump to ensure that at least one SG contains enough water to serve as the heat sink for reactor decay heat and sensible heat removal following the reactor trip.
- g. Auxiliary Feedwater - Trip of All Main Feedwater Pumps A Trip of all MFW pumps is an indication of a loss of MFW and the subsequent need for some method of decay heat and sensible heat removal to bring the reactor back to no load temperature and pressure. A turbine driven MFW pump is
equipped with two pressure switch es on the control ai r/oil line for the speed control system. A low pressure signal from either of these pressure switch es indicates a trip of that pump.
Motor 6.9 kV Unit-boards (RCP buses)6.9 kV shutdown board
- e. AFW one this d. INSERT 8 d. 2 2 2 5 2 2 2 2 2 2 B 3.3.2 Insert Page B 3.3.2-32 INSERT 8 The loss-of-voltage relaying on the 6.9 kV shutdown board uses three solid-state voltage sensors in a two-out-of-three voltage sensor logic (27T-S1A, S1B, &
S1C) for loss-of-power detection. A two-out-three logic from the voltage sensor channels energizes two parallel separate timing relays with a one-out-of-two logic scheme (LV1 and LV2). These voltage sensors and timing relays provide emergency diesel generator start, load-shed initiation, and subsequent turbine driven auxiliary feedwater (TDAFW) pump start through separate blackout relays (BOX and BOY). A footnote has been added to clarify that this requirement only applies to shutdown board instrumentation on the same unit. This clarification removes the potential to declare the AFW loss-of-power start instrumentation inoperable for a given unit when only the opposite unit's instrumentation is inoperable. The AFW turbine-driven pump is considered OPERABLE when one train of the AFW loss of power start function is declared inoperable, in accordance with technical specifications, because both 6.9 kilovolt shutdown board logic trains supply this function.
2 Engineered Safety Feature Actuation System (ESFAS) Instrumentation (Without Setpoint Control Program)
B 3.3.2 A Westinghouse STS B 3.3.2 A-33 Rev. 4.0 SEQUOYAH UNIT 2 Revision XXX 1 1 2BASES
APPLICABLE SAFETY ANALYSES, LCO, and APPLICABILITY (continued)
driven MFW pumps are equipped with a breaker position sensing channel. An open supply breaker indicates that the pump is not running. Two OPERABLE channels per pump satisfy redundancy requirements with one
-out-of-two taken twice logic.
A trip of all MFW pumps starts the motor driven and turbine driven AFW pumps to ensure that at least one SG is available with water to act as the heat sink for the reactor.
Function s 6.f and 6.g must be OPERABLE in MODES 1 and 2. This ensures that at least one SG is provided with water to serve as the heat sink to remove reactor decay heat and sensible heat in the event of an accident. In MODES 3, 4, and 5, the RCPs and MFW pumps may be normally shut down, and thus neither pump trip is indicative of a condition requiring automatic AFW initiation.
- h. Auxiliary Feedwater - Pump Suction Transfer on Suction Pressure - Low A low pressure signal in the AFW pump suction line protects the AFW pumps against a loss of the normal supply of water for the
pumps, the CST.
Two pressure switches are located on the AFW pump suction line from the CST. A low pressure signal
sensed by any one of the switches will cause the emergency supply of water for both pump s to be aligned, or cause the AFW pumps to stop until the emergency source of water is aligned. E SW (safety grade) is then lined up to supply the AFW pumps to ensure an adequate supply of water for the AFW System to maintain at least one of the SGs as the heat sink for reactor decay heat and sensible heat removal.
Since the detectors are located in an area not affected by HELBs or high radiation, they will not experience any adverse environmental conditions and the [NTSP] reflects only steady state instrument uncertainties.
This Function must be OPERABLE in MODES 1, 2, and 3 to ensure a safety grade supply of water for the AFW System to maintain the SGs as the heat sink for the reactor. This Function does not have to be OPERABLE in MODES 5 and 6 because there is not enough heat being generated in the reactor to require the SGs as a heat sink. In MODE 4, AFW automatic suction transfer does not need to be OPERABLE because RHR will already be in operation, or sufficient time is available to place RHR in operation, to remove decay heat.
- f. RC Three two of three the INSERT 9 INSERT 10 2 5 2 2 4 5 2 2 e however bothand adverse environmental 2
B 3.3.2 Insert Page B 3.3.2-33a INSERT 9 This Function includes two footnotes. The first footnote indicates that MODE 2 applicability is limited to operation when one or more MFW pumps are supplying feedwater to the steam generators (SGs), and the second footnote provides for delaying the entry into the action statement when starting or stopping MFW pumps in MODE 1. The first footnote limits the Applicability to require the auto-start logic to be operable in MODE 2 only when at least one MFW pump is in service supplying feedwater to the SGs. Because plant conditions at the time of entry into Mode 2 do not allow the MFW pumps to operate, without this footnote the channels would need to be tripped resulting in an AFW start signal, starting the turbine-driven pump in addition to the motor-driven AFW pumps, which is an undesirable situation. This resolves a conflict between the MODE applicability and plant design, which does not support MFW pump operation at the time of entry into MODE 2. Also, modifying the requirement for auto-start of the AFW pumps to be only required when the MFW pumps are in service limits the potential for inadvertent AFW actuations during normal plant startups and shutdowns that could lead to reactivity control issues due to over cooling transients. The second footnote delays entry into the Required Action for less than minimum channels operable for up to 4 hours4.62963e-5 days <br />0.00111 hours <br />6.613757e-6 weeks <br />1.522e-6 months <br />. During the time of starting and stopping a second MFW pump, when the pump is in reset, the auto-start function is inoperable. Starting and stopping MFW pumps during plant startup and shutdown is a normal evolution, which will normally be accomplished within a short time. This note is intended to prevent unnecessary entries into the Required Actions, which provides a timeframe to correct unplanned equipment failures. For the normal operating evolution of starting and stopping pumps, the footnote allows a delay of up to 4 hours4.62963e-5 days <br />0.00111 hours <br />6.613757e-6 weeks <br />1.522e-6 months <br /> before entering the Required Action.
The evolution should be completed in less time, but the 4 hours4.62963e-5 days <br />0.00111 hours <br />6.613757e-6 weeks <br />1.522e-6 months <br /> provides a reasonable allowance for operating contingencies. If the evolution takes longer than 4 hours4.62963e-5 days <br />0.00111 hours <br />6.613757e-6 weeks <br />1.522e-6 months <br />, it is probably indicative of an equipment problem and entering the Required Action is appropriate.
5 B 3.3.2 Insert Page B 3.3.2-33b INSERT 10 g. Auxiliary Feedwater Suction Transfer Time Delays A low pressure signal in the AFW pump suction line protects the AFW pumps against a loss of the normal supply of water for the pumps, the CST. The pressure switch setpoints and the logic time delays for the AFW pump suction switchover were determined to ensure that adequate net positive suction head (NPSH) for the AFW pumps is maintained during the pump suction transfer sequence.
The available NPSH for the pumps is calculated assuming a water level in the supply header that would not be reached until after the time delays are exceeded, even when accounting for the two TDAFW timers in series.
The TDAFW pump has two timers because this pump can be switched to either of the two trains in the ERCW system: one timer is for the transfer to one of the two trains. The timers operate in sequence to assure that the TDAFW pump is transferred to one of the ERCW trains.
This Function must be OPERABLE in MODES 1, 2, and 3 to ensure a safety grade supply of water for the AFW System to maintain the SGs as the heat sink for the reactor. This Function does not have to be OPERABLE in MODES 5 and 6 because there is not enough heat being generated in the reactor to require the SGs as a heat sink. In MODE 4, AFW automatic suction transfer does not need to be OPERABLE because RHR will already be in operation, or sufficient time is available to place RHR in operation, to remove decay heat.
2 Engineered Safety Feature Actuation System (ESFAS) Instrumentation (Without Setpoint Control Program)
B 3.3.2 A Westinghouse STS B 3.3.2 A-34 Rev. 4.0 SEQUOYAH UNIT 2 Revision XXX 1 1 2BASES
APPLICABLE SAFETY ANALYSES, LCO, and APPLICABILITY (continued)
- 7. Automatic Switchover to Containment Sump At the end of the injection phase of a LOCA, the RWST will be nearly empty. Continued cooling must be provided by the ECCS to remove decay heat. The source of water for the ECCS pumps is automatically switched to the containment recirculation sump. The low head residual heat removal (RHR) pumps and containment spray pumps draw the water from the containment recirculation sump, the RHR pumps pump the water through the RHR heat exchanger, inject the water back into the RCS, and supply the cooled water to the other ECCS pumps. Switchover from the RWST to the containment sump must occur before the RWST empties to prevent damage to the RHR pumps and a loss of core cooling capability. For similar reasons, switchover must not occur before there is sufficient water in the containment sump to support ESF pump suction. Furthermore, early switchover must not occur to ensure that sufficient borated water is injected from the RWST. This ensures the reactor remains shut down in the recirculation mode.
- a. Automatic Switchover to Containment Sump - Automatic Actuation Logic and Actuation Relays Automatic actuation logic and actuation relays consist of the same features and operate in the same manner as described for ESFAS Function 1.b.
b , c. Automatic Switchover to Containment Sump - Refueling Water Storage Tank (RWST) Level - Low Low Coincident With Safety Injection and Coincident With Containment Sump Level - High During the injection phase of a LOCA, the RWST is the source of water for all ECCS pumps. A low low level in the RWST coincident with a SI signal provides protection against a loss of water for the ECCS pumps and indicates the end of the injection phase of the LOCA. The RWST is equipped with four level transmitters. These transmitters provide no control functions.
Therefore, a two-out-of-four logic is adequate to initiate the protection function actuation. Although only three channels would be sufficient, a fourth channel has been added for increased reliability.
2 2 Engineered Safety Feature Actuation System (ESFAS) Instrumentation (Without Setpoint Control Program)
B 3.3.2 A Westinghouse STS B 3.3.2 A-35 Rev. 4.0 SEQUOYAH UNIT 2 Revision XXX 1 1 2BASES
APPLICABLE SAFETY ANALYSES, LCO, and APPLICABILITY (continued)
The RWST - Low Low Allowable Value
/Trip Setpoint has both upper and lower limits. The lower limit is selected to ensure switchover occurs before the RWST empties, to prevent ECCS pump damage. The upper limit is selected to ensure enough borated water is injected to ensure the reactor remains shut down. The high limit also ensures adequate water inventory in the containment sump to provide ECCS pump suction.
The transmitters are located in an area not affected by HELBs or post accident high radiation. Thus, they will not experience any adverse environmental conditions and the
[NTSP] reflects only steady state instrument uncertainties.
Automatic switchover occurs only if the RWST low low level signal is coincident with SI. This prevents accidental switchover during normal operation. Accidental switchover could damage ECCS pumps if they are attempting to take suction from an empty sump. The automatic switchover Function requirements for the SI Functions are the same as the requirements for their SI function. Therefore, the requirements are not repeated in Table 3.3.2-1. Instead, Function 1, SI, is referenced for all initiating Functions and requirements.
REVIEWER'S NOTE-------------------------------
In some units, additional protection from spurious switchover is provided by requiring a Containment Sump Level - High signal as well as RWST Level - Low Low and SI. This ensures sufficient water is available in containment to support the recirculation phase of the accident. A Containment Sump Level - High signal must be present, in addition to the SI signal and the RWST Level - Low Low signal, to transfer the suctions of the RHR pumps to the containment sump. The containment sump is equipped with four level transmitters. These transmitters provide no control functions. Therefore, a two-out-of-four logic is adequate to initiate the protection function actuation. Although only three channels would be sufficient, a fourth channel has been added for increased reliability. The containment sump level Trip Setpoint/Allowable Value is selected to
ensure enough borated water is injected to ensure the reactor remains shut down. The high limit also ensures adequate water inventory in the containment sump to provide ECCS pump suction. The transmitters are located inside containment and thus possibly experience adverse environmental conditions. Therefore, the
[NTSP] reflects the inclusion of both steady state and environmental instrument uncertainties.
Units only have one of the Functions, 7.b or 7.c. --------------------------------------------------------------------------------------------------
containment sump tall strainer submergence.
RWST level 2 2 2 2 2 2 2 3 3 4 4 2that automatic switchover is permitted before RWST level decreases below the RWST Level - Low setpoint. This ensures an adequate suction supply to the ECCS pumps by allowing sufficient time for completion of the switchover before vortexing occurs in the RWST.
Engineered Safety Feature Actuation System (ESFAS) Instrumentation (Without Setpoint Control Program)
B 3.3.2 A Westinghouse STS B 3.3.2 A-36 Rev. 4.0 SEQUOYAH UNIT 2 Revision XXX 1 1 2BASES
APPLICABLE SAFETY ANALYSES, LCO, and APPLICABILITY (continued)
These Functions must be OPERABLE in MODES 1, 2, 3, and 4 when there is a potential for a LOCA to occur, to ensure a continued supply of water for the ECCS pumps. These Functions are not required to be OPERABLE in MODES 5 and 6 because there is adequate time for the operator to evaluate unit conditions and respond by manually starting systems, pumps, and other equipment to mitigate the consequences of an
abnormal condition or accident. System pressure and temperature are very low and many ESF components are
administratively locked out or otherwise prevented from actuating to prevent inadvertent overpressurization of unit systems.
- 8. Engineered Safety Feature Actuation System Interlocks To allow some flexibility in unit operations, several interlocks are included as part of the ESFAS. These interlocks permit the operator to block some signals, automatically enable other signals, prevent some actions from occurring, and cause other actions to occur. The interlock Functions back up manual actions to ensure bypassable functions are in operation under the conditions assumed in the safety analyses.
- a. Engineered Safety Feature Actuation System Interlocks -
Reactor Trip, P-4 The P-4 interlock is enabled when a reactor trip breaker (RTB) and its associated bypass breaker is open. Once the P-4 interlock is enabled, automatic SI initiation is blocked after a
[ ] second time delay. This Function allows operators to take manual control of SI systems after the initial phase of injection is complete. Once SI is blocked, automatic actuation of SI cannot occur until the RTBs have been manually closed. The functions of the P-4 interlock are:
- Trip the main turbine,
- Isolate MFW with coincident low Tavg ,
- Transfer the steam dump from the load rejection contro ller to the unit trip controller, and
- Prevent opening of the MFW isolation valves if they were closed on SI or SG Water Level - High High.
60 may be 2 4 and 2 6 automatic 2reactor trip breakers 2 2 Engineered Safety Feature Actuation System (ESFAS) Instrumentation (Without Setpoint Control Program)
B 3.3.2 A Westinghouse STS B 3.3.2 A-37 Rev. 4.0 SEQUOYAH UNIT 2 Revision XXX 1 1 2BASES
APPLICABLE SAFETY ANALYSES, LCO, and APPLICABILITY (continued)
Each of the above Functions is interlocked with P-4 to avert or reduce the continued cooldown of the RCS following a reactor trip. An excessive cooldown of the RCS following a reactor trip could cause an insertion of positive reactivity with a subsequent increase in generated power. To avoid such a situation, the noted Functions have been interlocked with P-4 as part of the design of the unit control and protection system.
None of the noted Functions serves a mitigation function in the unit licensing basis safety analyses. Only the turbine trip Function is explicitly assumed since it is an immediate consequence of the reactor trip Function. Neither turbine trip, nor any of the other four Functions associated with the reactor trip signal, is required to show that the unit licensing basis safety analysis acceptance criteria are not exceeded.
The RTB position switches that provide input to the P-4 interlock only function to energize or de
-energize or open or close contacts. Therefore, this Function has no adjustable trip setpoint with which to associate a
[NTSP] and Allowable Value.
This Function must be OPERABLE in MODES 1, 2, and 3 when the reactor may be critical or approaching criticality. This Function does not have to be OPERABLE in MODE 4, 5, or 6 because the main turbine, the MFW System, and the Steam Dump System are not in operation.
- b. Engineered Safety Feature Actuation System Interlocks -
Pressurizer Pressure, P-11 The P-11 interlock permits a normal unit cooldown and depressurization without actuation of SI or main steam line isolation. With two-out-of-three pressurizer pressure channels (discussed previously) less than the P-11 setpoint, the operator can manually block the Pressurizer Pressure - Low and Steam Line Pressure - Low SI signals and the Steam Line Pressure -
Low steam line isolation signal (previously discussed). When the Steam Line Pressure - Low steam line isolation signal is manually blocked, a main steam isolation signal on Steam Line Pressure - Negative Rate - High is enabled. This provides protection for a SLB by closure of the MSIVs. With two-out-of-three pressurizer pressure channels above the P-11 setpoint, the Pressurizer Pressure - Low and Steam Line Pressure - Low SI signals and the Steam Line Pressure - Low steam line isolation signal are automatically enabled. The operator can also enable There are two P-4 channels arranged in a one-out-of-one logic per channel.
2 2 4three and 2 2 2indicate reactor trip breaker Engineered Safety Feature Actuation System (ESFAS) Instrumentation (Without Setpoint Control Program)
B 3.3.2 A Westinghouse STS B 3.3.2 A-38 Rev. 4.0 SEQUOYAH UNIT 2 Revision XXX 1 1 2BASES
APPLICABLE SAFETY ANALYSES, LCO, and APPLICABILITY (continued)
these trips by use of the respective manual reset buttons. When the Steam Line Pressure
- Low steam line isolation signal is enabled, the main steam isolation on Steam Line Pressure - Negative Rate - High is disabled. The
[NTSP] reflects only steady state instrument uncertainties.
This Function must be OPERABLE in MODES 1, 2, and 3 to allow an orderly cooldown and depressurization of the unit without the actuation of SI or main steam isolation. This Function does not have to be OPERABLE in MODE 4, 5, or 6 because system pressure must already be below the P-11 setpoint for the requirements of the heatup and cooldown curves
to be met.
- c. Engineered Safety Feature Actuation System Interlocks
- T avg -Low Low, P
-12 On increasing reactor coolant temperature, the P
-12 interlock reinstates SI on High Steam Flow Coincident With Steam Line Pressure - Low or Coincident With T av g - Low Low and provides an arming signal to the Steam Dump System. On decreasing reactor coolant temperature, the P
-12 interlock allows the operator to manually block SI on High Steam Flow Coincident With Steam Line Pressure
- Low or Coincident with Tavg - Low Low. On a decreasing temperature, the P
-12 interlock also removes the arming signal to the Steam Dump System to prevent an excessive cooldown of the RCS due to a malfunctioning Steam Dump System.
Since Tavg is used as an indication of bulk RCS tem perature, this Function meets redundancy requirements with one OPERABLE channel in each loop. In three loop units, these channels are used in two
-out-of-three logic. In four loop units, they are used in two-out-of-four logic.
This Function must be OPERA BLE in MODES 1, 2, and 3 when a secondary side break or stuck open valve could result in the rapid depressurization of the steam lines. This Function does not have to be OPERABLE in MODE 4, 5, or 6 because there is insufficient energy in the secondary side of the unit to have an accident. The ESFAS instrumentation satisfies Criterion 3 of 10 CFR 50.36(c)(2)(ii).
and 2 2 4 Engineered Safety Feature Actuation System (ESFAS) Instrumentation (Without Setpoint Control Program)
B 3.3.2 A Westinghouse STS B 3.3.2 A-39 Rev. 4.0 SEQUOYAH UNIT 2 Revision XXX 1 1 2BASES
ACTIONS ----------------------------REVIEWER'S NOTE------------------------------------------
In Table 3.3.2
-1, Functions 7.b and 7.c were not included in the generic evaluations approved in either WCAP
-10271, as supplemented, WCAP-15376 or WCAP
-14333. In order to apply the WCAP
-10271, as supplemented, and WCAP
-15376 or WCAP
-14333 TS relaxations to plant specific Functions not evaluated generically, licensees must submit plant specific evaluations for NRC review and approval.
A Note has been added in the ACTIONS to clarify the application of Completion Time rules. The Conditions of this Specification may be entered independently for each Function listed on Table 3.3.2-1.
In the event a channel's
[NTSP] is found nonconservative with respect to the Allowable Value, or the channel is not functioning as required, or the transmitter, instrument Loop, signal processing electronics, or bistable is found inoperable, then all affected Functions provided by that channel must be declared inoperable and the LCO Condition(s) entered for the protection Function(s) affected. When the Required Channels in Table 3.3.2-1 are specified (e.g., on a per steam line, per loop, per SG, etc., basis), then the Condition may be entered separately for each steam line, loop, SG, etc., as appropriate.
When the number of inoperable channels in a trip function exceed those specified in one or other related Conditions associated with a trip function, then the unit is outside the safety analysis. Therefore, LCO 3.0.3 should be immediately entered if applicable in the current MODE of operation.
REVIEWER'S NOTE------------------------------------------
Certain LCO Completion Times are based on approved topical reports. In order for a licensee to use these times, the licensee must justify the Completion Times as required by the staff Safety Evaluation Report (SER) for the topical report.
A.1 Condition A applies to all ESFAS protection functions.
Condition A addresses the situation where one or more channels or trains for one or more Functions are inoperable at the same time. The Required Action is to refer to Table 3.3.2-1 and to take the Required Actions for the protection functions affected. The Completion Times are those from the referenced Conditions and Required Actions.
on a "per" basis 3 4 3 2setpoint comparator output, contact output, 2 Engineered Safety Feature Actuation System (ESFAS) Instrumentation (Without Setpoint Control Program)
B 3.3.2 A Westinghouse STS B 3.3.2 A-40 Rev. 4.0 SEQUOYAH UNIT 2 Revision XXX 1 1 2BASES
ACTIONS (continued)
B.1, B.2.1, and B.2.2 Condition B applies to manual initiation of:
- SI,
- Phase A Isolation, and
- Phase B Isolation.
This action addresses the train orientation of the SSPS for the functions listed above. If a channel or train is inoperable, 24 hours2.777778e-4 days <br />0.00667 hours <br />3.968254e-5 weeks <br />9.132e-6 months <br /> is allowed to return it to an OPERABLE status. Note that for containment spray and Phase B isolation, failure of one or both channels in one train renders the train inoperable. Condition B, therefore, encompasses both situations.
The specified Completion Time is reasonable considering that there are two automatic actuation trains and another manual initiation train OPERABLE for each Function, and the low probability of an event occurring during this interval. If the train cannot be restored to OPERABLE status, the unit must be placed in a MODE in which the LCO does not apply. This is done by placing the unit in at least MODE 3 within an additional 6 hours6.944444e-5 days <br />0.00167 hours <br />9.920635e-6 weeks <br />2.283e-6 months <br /> (54 hours6.25e-4 days <br />0.015 hours <br />8.928571e-5 weeks <br />2.0547e-5 months <br /> total time) and in MODE 5 within an additional 30 hours3.472222e-4 days <br />0.00833 hours <br />4.960317e-5 weeks <br />1.1415e-5 months <br /> (84 hours9.722222e-4 days <br />0.0233 hours <br />1.388889e-4 weeks <br />3.1962e-5 months <br /> total time). The allowable Completion Times are reasonable, based on operating experience, to reach the required unit conditions from full power conditions in an orderly manner and without challenging unit systems.
C.1, C.2.1, and C.2.2
Condition C applies to the automatic actuation logic and actuation relays for the following functions:
- SI,
- Phase A Isolation,
- Phase B Isolation , and
- Automatic Switchover to Containment Sump
. 48 2 and Engineered Safety Feature Actuation System (ESFAS) Instrumentation (Without Setpoint Control Program)
B 3.3.2 A Westinghouse STS B 3.3.2 A-41 Rev. 4.0 SEQUOYAH UNIT 2 Revision XXX 1 1 2BASES
ACTIONS (continued)
This action addresses the train orientation of the SSPS and the master and slave relays. If one train is inoperable, 24 hours2.777778e-4 days <br />0.00667 hours <br />3.968254e-5 weeks <br />9.132e-6 months <br /> are allowed to restore the train to OPERABLE status. The 24 hours2.777778e-4 days <br />0.00667 hours <br />3.968254e-5 weeks <br />9.132e-6 months <br /> allowed for restoring the inoperable train to OPERABLE status is justified in Reference 9. The specified Completion Time is reasonable considering that there is another train OPERABLE, and the low probability of an event occurring during this interval. If the train cannot be restored to OPERABLE status, the unit must be placed in a MODE in which the LCO does not apply. This is done by placing the unit in at least MODE 3 within an additional 6 hours6.944444e-5 days <br />0.00167 hours <br />9.920635e-6 weeks <br />2.283e-6 months <br /> (30 hours3.472222e-4 days <br />0.00833 hours <br />4.960317e-5 weeks <br />1.1415e-5 months <br /> total time) and in MODE 5 within an additional 30 hours3.472222e-4 days <br />0.00833 hours <br />4.960317e-5 weeks <br />1.1415e-5 months <br /> (60 hours6.944444e-4 days <br />0.0167 hours <br />9.920635e-5 weeks <br />2.283e-5 months <br /> total time). The Completion Times are reasonable, based on operating experience, to reach the required unit conditions from full power conditions in an orderly manner and without challenging unit systems.
The Required Actions are modified by a Note that allows one train to be bypassed for up to
[4] hours for surveillance testing, provided the other train is OPERABLE. This allowance is based on the reliability analysis assumption of WCAP-10271-P-A (Ref. 10) that 4 hours4.62963e-5 days <br />0.00111 hours <br />6.613757e-6 weeks <br />1.522e-6 months <br /> is the average time required to perform train surveillance.
D.1, D.2.1, and D.2.2
Condition D applies to:
- Containment Pressure - High 1 ,
- Pressurizer Pressure - Low (two, three, and four loop units),
- Steam Line Pressure - Low,
- Steam Line Differential Pressure
- High,
- High Steam Flow in Two Steam Lines Coincident With Tavg - Low Low or Coincident With Steam Line Pressure
- Low ,
- Containment Pressure
- High 2 ,
- Steam Line Pressure - Negative Rate - High,
- High Steam Flow Coincident With Safety Injection Coincident With Tavg - Low Low , 2 2 2 2 4 Engineered Safety Feature Actuation System (ESFAS) Instrumentation (Without Setpoint Control Program)
B 3.3.2 A Westinghouse STS B 3.3.2 A-42 Rev. 4.0 SEQUOYAH UNIT 2 Revision XXX 1 1 2BASES
ACTIONS (continued)
- High High Steam Flow Coincident With Safety Injection,
- High Steam Flow in Two Steam Lines Coincident With Tavg - Low Low,
- SG Water level
- Low Low (two, three, and four loop units), and * [SG Water level - High High (P-14) (two, three, and four loop units). ]
If one channel is inoperable, 72 hours8.333333e-4 days <br />0.02 hours <br />1.190476e-4 weeks <br />2.7396e-5 months <br /> are allowed to restore the channel to OPERABLE status or to place it in the tripped condition. Generally this Condition applies to functions that operate on two-out-of-three logic.
Therefore, failure of one channel places the Function in a two-out-of-two configuration. One channel must be tripped to place the Function in a one-out-of-three configuration that satisfies redundancy requirements. The 72 hours8.333333e-4 days <br />0.02 hours <br />1.190476e-4 weeks <br />2.7396e-5 months <br /> allowed to restore the channel to OPERABLE status or to place it in the tripped condition is justified in Reference 9.
Failure to restore the inoperable channel to OPERABLE status or place it in the tripped condition within 72 hours8.333333e-4 days <br />0.02 hours <br />1.190476e-4 weeks <br />2.7396e-5 months <br /> requires the unit be placed in MODE 3 within the following 6 hours6.944444e-5 days <br />0.00167 hours <br />9.920635e-6 weeks <br />2.283e-6 months <br /> and MODE 4 within the next 6 hours6.944444e-5 days <br />0.00167 hours <br />9.920635e-6 weeks <br />2.283e-6 months <br />.
The allowed Completion Times are reasonable, based on operating experience, to reach the required unit conditions from full power conditions in an orderly manner and without challenging unit systems. In MODE 4, these Functions are no longer required OPERABLE.
[ The Required Actions are modified by a Note that allows the inoperable channel to be bypassed for up to 12 hours1.388889e-4 days <br />0.00333 hours <br />1.984127e-5 weeks <br />4.566e-6 months <br /> for surveillance testing of other channels. The 12 hours1.388889e-4 days <br />0.00333 hours <br />1.984127e-5 weeks <br />4.566e-6 months <br /> allowed for testing, are justified in Reference 9.
]
REVIEWER'S NOTE
The below text should be used for plants with installed bypass test capability:
The Required Actions are modified by a Note that allows placing one channel in bypass for up to 12 hours1.388889e-4 days <br />0.00333 hours <br />1.984127e-5 weeks <br />4.566e-6 months <br /> while performing routine surveillance testing. The 12 hour1.388889e-4 days <br />0.00333 hours <br />1.984127e-5 weeks <br />4.566e-6 months <br /> time limit is justified in Reference
- 9. --------------------------------------------------------------------------------------------------
two 3 2 2 4 4 4 Engineered Safety Feature Actuation System (ESFAS) Instrumentation (Without Setpoint Control Program)
B 3.3.2 A Westinghouse STS B 3.3.2 A-43 Rev. 4.0 SEQUOYAH UNIT 2 Revision XXX 1 1 2BASES
ACTIONS (continued)
E.1, E.2.1, and E.2.2 Condition E applies to:
- Containment Spray Containment Pressure -
High 3 (High , High) (two, three, and four loop units), and
- Containment Phase B Isolation Containment Pressure -
High 3 (High , High).
None of these signals has input to a control function. Thus, two-out-of-three logic is necessary to meet acceptable protective requirements.
However, a two-out-of-three design would require tripping a failed channel. This is undesirable because a single failure would then cause spurious containment spray initiation. Spurious spray actuation is undesirable because of the cleanup problems presented. Therefore, these channels are designed with two-out-of-four logic so that a failed channel may be bypassed rather than tripped. Note that one channel may be bypassed and still satisfy the single failure criterion. Furthermore, with one channel bypassed, a single instrumentation channel failure will not spuriously initiate containment spray.
To avoid the inadvertent actuation of containment spray and Phase B containment isolation, the inoperable channel should not be placed in the tripped condition. Instead it is bypassed. Restoring the channel to OPERABLE status, or placing the inoperable channel in the bypass condition within 72 hours8.333333e-4 days <br />0.02 hours <br />1.190476e-4 weeks <br />2.7396e-5 months <br />, is sufficient to assure that the Function remains OPERABLE and minimizes the time that the Function may be in a partial trip condition (assuming the inoperable channel has failed high). The Completion Time is further justified based on the low probability of an event occurring during this interval. Failure to restore the inoperable channel to OPERABLE status, or place it in the bypassed condition within 6 hours6.944444e-5 days <br />0.00167 hours <br />9.920635e-6 weeks <br />2.283e-6 months <br />, requires the unit be placed in MODE 3 within the following 6 hours6.944444e-5 days <br />0.00167 hours <br />9.920635e-6 weeks <br />2.283e-6 months <br /> and MODE 4 within the next 72 hours8.333333e-4 days <br />0.02 hours <br />1.190476e-4 weeks <br />2.7396e-5 months <br />. The allowed Completion Times are reasonable, based on operating experience, to reach the required unit conditions from full power conditions in an orderly manner and without challenging unit systems. In MODE 4, these Functions are no longer required OPERABLE.
[ The Required Actions are modified by a Note that allows one additional channel to be bypassed for up to 12 hours1.388889e-4 days <br />0.00333 hours <br />1.984127e-5 weeks <br />4.566e-6 months <br /> for surveillance testing. Placing a second channel in the bypass condition for up to 12 hours1.388889e-4 days <br />0.00333 hours <br />1.984127e-5 weeks <br />4.566e-6 months <br /> for testing purposes is acceptable based on the results of Reference 9.
] 72 6 2 2 4 4 Steam Line Isolation Containment Pressure - High-High - , and Engineered Safety Feature Actuation System (ESFAS) Instrumentation (Without Setpoint Control Program)
B 3.3.2 A Westinghouse STS B 3.3.2 A-44 Rev. 4.0 SEQUOYAH UNIT 2 Revision XXX 1 1 2BASES
ACTIONS (continued)
REVIEWER'S NOTE------------------------------------------
The below text should be used for plants with installed bypass test capability:
The Required Actions are modified by a Note that allows placing one channel in bypass for up to 12 hours1.388889e-4 days <br />0.00333 hours <br />1.984127e-5 weeks <br />4.566e-6 months <br /> while performing routine surveillance testing. The 12 hour1.388889e-4 days <br />0.00333 hours <br />1.984127e-5 weeks <br />4.566e-6 months <br /> time limit is justified in Reference 9.
F.1, F.2.1, and F.2.2 Condition F applies to
- Manual Initiation of Steam Line Isolation,
- Loss of Offsite Power,
- Auxiliary Feedwater Pump Suction Transfer on Suction Pressure
- Low, and
- P-4 Interlock.
For the Manual Initiation and the P-4 Interlock Function s, this action addresses the train orientation of the SSPS. For the Loss of Offsite Power Function, this action recognizes the lack of manual trip provision for a failed channel.
For the AFW System pump suction transfer channels, this action recognizes that placing a failed channel in trip during operation is not necessarily a conservative action. Spurious trip of this function could align the AFW System to a source that is not immediately capable of supporting pump suction. If a train or channel is inoperable, 48 hours5.555556e-4 days <br />0.0133 hours <br />7.936508e-5 weeks <br />1.8264e-5 months <br /> is allowed to return it to OPERABLE status. The specified Completion Time is reasonable considering the nature of the se Function s , the available redundancy, and the low probability of an event occurring during this interval. If the Function cannot be returned to OPERABLE status, the unit must be placed in MODE 3 within the next 6 hours6.944444e-5 days <br />0.00167 hours <br />9.920635e-6 weeks <br />2.283e-6 months <br /> and MODE 4 within the following 6 hours6.944444e-5 days <br />0.00167 hours <br />9.920635e-6 weeks <br />2.283e-6 months <br />. The allowed Completion Times are reasonable, based on operating experience, to reach the required unit conditions from full power in an orderly manner and without challenging unit systems. In MODE 4, the unit does not have any analyzed transients or conditions that require the explicit use of the protection functions noted
above.
3 2 2 2 2 INSERT 11 G G 2 2the B 3.3.2 Insert Page B 3.3.2-44 INSERT 11 F.1 and F.2
Condition F applies to the Steam Line Isolation, Manual Initiation ESFAS Function.
If a train or channel is inoperable, 48 hours5.555556e-4 days <br />0.0133 hours <br />7.936508e-5 weeks <br />1.8264e-5 months <br /> is allowed to return it to OPERABLE status. The specified Completion Time is reasonable considering the nature of this Function, the available redundancy, and the low probability of an event occurring during this interval. If the Function cannot be returned to OPERABLE status, the associate MSIV is declared inoperable and the associated Required Actions followed for an inoperable MSIV.
2 Engineered Safety Feature Actuation System (ESFAS) Instrumentation (Without Setpoint Control Program)
B 3.3.2 A Westinghouse STS B 3.3.2 A-45 Rev. 4.0 SEQUOYAH UNIT 2 Revision XXX 1 1 2BASES
ACTIONS (continued)
G.1, G.2.1, and G.2.2 Condition G applies to the automatic actuation logic and actuation relays for the Steam Line Isolation
[Turbine Trip and Feedwater Isolation,] and AFW actuation Functions.
The action addresses the train orientation of the SSPS and the master and slave relays for these functions. If one train is inoperable, 24 hours2.777778e-4 days <br />0.00667 hours <br />3.968254e-5 weeks <br />9.132e-6 months <br /> are allowed to restore the train to OPERABLE status. The 24 hours2.777778e-4 days <br />0.00667 hours <br />3.968254e-5 weeks <br />9.132e-6 months <br /> allowed for restoring the inoperable train to OPERABLE status is justified in Reference 9. The Completion Time for restoring a train to OPERABLE status is reasonable considering that there is another train OPERABLE, and the low probability of an event occurring during this interval. If the train cannot be returned to OPERABLE status, the unit must be brought to MODE 3 within the next 6 hours6.944444e-5 days <br />0.00167 hours <br />9.920635e-6 weeks <br />2.283e-6 months <br /> and MODE 4 within the following 6 hours6.944444e-5 days <br />0.00167 hours <br />9.920635e-6 weeks <br />2.283e-6 months <br />. The allowed Completion Times are reasonable, based on operating experience, to reach the required unit conditions from full power conditions in an orderly manner and without challenging unit systems. Placing the unit in MODE 4 removes all requirements for OPERABILITY of the protection channels and actuation functions. In this MODE, the unit does not have analyzed transients or conditions that require the explicit use of the protection functions noted above.
The Required Actions are modified by a Note that allows one train to be
bypassed for up to
[4] hours for surveillance testing provided the other train is OPERABLE. This allowance is based on the reliability analysis (Ref. 10) assumption that 4 hours4.62963e-5 days <br />0.00111 hours <br />6.613757e-6 weeks <br />1.522e-6 months <br /> is the average time required to perform channel surveillance.
[ H.1 and H.2 Condition H applies to the automatic actuation logic and actuation relays for the Turbine Trip and Feedwater Isolation Function.
This action addresses the train orientation of the SSPS and the master and slave relays for this Function. If one train is inoperable, 24 hours2.777778e-4 days <br />0.00667 hours <br />3.968254e-5 weeks <br />9.132e-6 months <br /> are allowed to restore the train to OPERABLE status or the unit must be placed in MODE 3 within the following 6 hours6.944444e-5 days <br />0.00167 hours <br />9.920635e-6 weeks <br />2.283e-6 months <br />. The 24 hours2.777778e-4 days <br />0.00667 hours <br />3.968254e-5 weeks <br />9.132e-6 months <br /> allowed for restoring the inoperable train to OPERABLE status is justified in Reference
- 9. The Completion Time for restoring a train to OPERABLE status is reasonable considering that there is another train OPERABLE, and the low probability of an event occurring during this interval. The allowed Completion Time of 6 hours6.944444e-5 days <br />0.00167 hours <br />9.920635e-6 weeks <br />2.283e-6 months <br /> is reasonable, based on operating experience, to reach MODE 3 from full power conditions in an orderly 2 4 4 H H 2 Engineered Safety Feature Actuation System (ESFAS) Instrumentation (Without Setpoint Control Program)
B 3.3.2 A Westinghouse STS B 3.3.2 A-46 Rev. 4.0 SEQUOYAH UNIT 2 Revision XXX 1 1 2BASES
ACTIONS (continued)
manner and without challenging unit systems. These Functions are no longer required in MODE
- 3. Placing the unit in MODE 3 removes all requirements for OPERABILITY of the protection channels and actuation functions. In this MODE, the unit does not have analyzed transients or conditions that require the explicit use of the protection functions noted above.
The Required Actions are modified by a Note that allows one train to be bypassed for up to [4]
hours for surveillance testing provided the other train is OPERABLE. This allowance is based on the reliability analysis (Ref. 10) assumption that 4 hours4.62963e-5 days <br />0.00111 hours <br />6.613757e-6 weeks <br />1.522e-6 months <br /> is the average time required to perform channel surveillance.
] I.1 and I.2 Condition I applies to:
- [ SG Water Level - High High (P
-14) (two, three, and four loop units), and ]
- Undervoltage Reactor Coolant Pump.
If one channel is inoperable, 72 hours8.333333e-4 days <br />0.02 hours <br />1.190476e-4 weeks <br />2.7396e-5 months <br /> are allowed to restore one channel to OPERABLE status or to place it in the tripped condition. If placed in the tripped condition, the Function is then in a partial trip condition where one-out-of-two or one
-out-of-three logic will result in actuation. Failure to restore the inoperable channel to OPERAB LE status or place it in the tripped condition within 72 hours8.333333e-4 days <br />0.02 hours <br />1.190476e-4 weeks <br />2.7396e-5 months <br /> requires the unit to be placed in MODE 3 within the following 6 hours6.944444e-5 days <br />0.00167 hours <br />9.920635e-6 weeks <br />2.283e-6 months <br />. The allowed Completion Time of 78 hours9.027778e-4 days <br />0.0217 hours <br />1.289683e-4 weeks <br />2.9679e-5 months <br /> is reasonable, based on operating experience, to reach MODE 3 from full power conditions in an orderly manner and without challenging unit system s. In MODE 3, these Functions are no longer required OPERABLE. [ The Required Actions are modified by a Note that allows the inoperable channel to be bypassed for up to [12]
hours for surveillance testing of other channels. The 72 hours8.333333e-4 days <br />0.02 hours <br />1.190476e-4 weeks <br />2.7396e-5 months <br /> allowed to place the inoperable channel in the tripped condition, and the 12 hours1.388889e-4 days <br />0.00333 hours <br />1.984127e-5 weeks <br />4.566e-6 months <br /> allowed for a second channel to be in the bypassed condition for testing, are justified in Reference
- 9. ] 2 Engineered Safety Feature Actuation System (ESFAS) Instrumentation (Without Setpoint Control Program)
B 3.3.2 A Westinghouse STS B 3.3.2 A-47 Rev. 4.0 SEQUOYAH UNIT 2 Revision XXX 1 1 2BASES
ACTIONS (continued)
REVIEWER'S NOTE------------------------------------------
The below text should be used for plants with installed bypass test capability:
The Required Actions are modified by a Note that allows placing one channel in bypass for up to 12 hours1.388889e-4 days <br />0.00333 hours <br />1.984127e-5 weeks <br />4.566e-6 months <br /> while performing routine surveillance testing. The 72 hours8.333333e-4 days <br />0.02 hours <br />1.190476e-4 weeks <br />2.7396e-5 months <br /> allowed to place the inoperable channel in the tripped condition, and the 12 hours1.388889e-4 days <br />0.00333 hours <br />1.984127e-5 weeks <br />4.566e-6 months <br /> allowed for a second channel to be in the bypassed condition for testing, are justified in Reference
- 9. --------------------------------------------------------------------------------------------------
J.1 and J.2 Condition J applies to the AFW pump start on trip of all MFW pumps.
This action addresses the train orientation of the SSPS for the auto start function of the AFW System on loss of all MFW pumps. The OPERABILITY of the AFW System must be assured by allowing automatic start of the AFW System pumps. If a channel is inoperable, 48 hours5.555556e-4 days <br />0.0133 hours <br />7.936508e-5 weeks <br />1.8264e-5 months <br /> are allowed to return it to an OPERABLE status. If the function cannot be returned to an OPERABLE status, 6 hours6.944444e-5 days <br />0.00167 hours <br />9.920635e-6 weeks <br />2.283e-6 months <br /> are allowed to place the unit in MODE 3. The allowed Completion Time of 6 hours6.944444e-5 days <br />0.00167 hours <br />9.920635e-6 weeks <br />2.283e-6 months <br /> is reasonable, based on operating experience, to reach MODE 3 from full power conditions in an orderly manner and without challenging unit systems. In MODE 3, the unit does not have any analyzed transients or conditions that require the explicit use of the protection function noted above. The allowance of 48 hours5.555556e-4 days <br />0.0133 hours <br />7.936508e-5 weeks <br />1.8264e-5 months <br /> to return the train to an OPERABLE status is justified in Reference 10.
K.1, K.2.1, and K.2.2 Condition K applies to
- RWST Level
- Low Low Coincident with Safety Injection, and
- RWST Level - Low Low Coincident with Safety Injection and Coincident with Containment Sump Level - High.
RWST Level - Low Low Coincident With SI and Coincident With Containment Sump Level - High provides actuation of switchover to the containment sump. Note that this Function requires the bistables to energize to perform their required action. The failure of up to two channels will not prevent the operation of this Function. However, placing N N P P 3 2 2 2 2 2 2 INSERT 12INSERT 13 INSERT 14 INSERT 15 INSERT 16 5 2 2comparators 2 the B 3.3.2 Insert Page B 3.3.2-47a INSERT 12 I.1 and I.2
Condition I applies to the following ESFAS Functions:
- Steam Generator Water Level--Low-Low (Adverse), and
- Steam Generator Water Level--Low-Low (EAM)
A known inoperable channel must be placed in the tripped condition within 6 hours6.944444e-5 days <br />0.00167 hours <br />9.920635e-6 weeks <br />2.283e-6 months <br />. Placing the channel in the tripped condition results in a partial trip condition requiring only one-out-of-two logic for actuation of the two-out-of-three trips.
In addition to placing the channel in the tripped condition, it is necessary to force the use of the shorter TTD by adjustment of the single steam generator time delay calculation (T S) to match the multiple steam generator time delay calculation (T M) for the affected protection set within 4 hours4.62963e-5 days <br />0.00111 hours <br />6.613757e-6 weeks <br />1.522e-6 months <br />.
The Required Actions have been modified by a Note that allows placing the inoperable channel in the bypassed condition for up to 4 hours4.62963e-5 days <br />0.00111 hours <br />6.613757e-6 weeks <br />1.522e-6 months <br /> while performing routine surveillance testing of the other channels.
2 B 3.3.2 Insert Page B 3.3.2-47b INSERT 13 J.1, J.2, J.3.1, and J.3.2 Condition J applies to the Containment Pressure (EAM) coincidence with Steam
Generator Water Level--Low-Low (Adverse) ESFAS Function.
Failure of the Containment Pressure (EAM) channel to a protection set does not affect the EAM setpoint calculations. A known inoperable Containment Pressure channel results in the requirement to adjust the affected Steam Generator Water Level - Low-Low (EAM) trip setpoints for the affected protection set to the same value as the Steam Generator Water Level - Low-Low (Adverse) trip setpoint within 6 hours6.944444e-5 days <br />0.00167 hours <br />9.920635e-6 weeks <br />2.283e-6 months <br />.
An alternative to adjusting the affected Steam Generator Water Level - Low-Low (EAM) trip setpoints to the same value as the Steam Generator Water Level -
Low-Low (Adverse) trip setpoints is to place the associated protection set's SG Water Level Low-Low channels in the tripped condition within 6 hours6.944444e-5 days <br />0.00167 hours <br />9.920635e-6 weeks <br />2.283e-6 months <br />.
If neither of the above Required Actions are completed within their associated Completion Time, then the unit must be placed in a MODE where these Functions are not required OPERABLE. This requires the unit be placed in MODE 3 within 12 hours1.388889e-4 days <br />0.00333 hours <br />1.984127e-5 weeks <br />4.566e-6 months <br /> and MODE 4 within 18 hours2.083333e-4 days <br />0.005 hours <br />2.97619e-5 weeks <br />6.849e-6 months <br />. The allowed Completion Times are reasonable to reach the required unit conditions from full power conditions in an orderly manner and without challenging unit systems. In MODE 4, these Functions are no longer required OPERABLE.
2 2 5 B 3.3.2 Insert Page B 3.3.2-47c INSERT 14 K.1, K.2, K.3.1, and K.3.2 Condition K applies to the RCS Loop T coincidence with SG Water Level - Low-Low.
Failure of the RCS loop T channel input (failure of more than one T H RTD or failure of a T C RTD) does not affect the TTD calculation for a protection set. This results in the requirement that the operator adjust the threshold power level for zero seconds time delay from 50% RTP to 0% RTP within 6 hours6.944444e-5 days <br />0.00167 hours <br />9.920635e-6 weeks <br />2.283e-6 months <br />. With the trip time delay adjusted to zero seconds the additional operational margin that allows the operator time to recover SG level is removed.
An alternative to adjusting the threshold power level for zero seconds time delay is to place the affected protection set's SG Water Level Low-Low level channels in the tripped condition within 6 hours6.944444e-5 days <br />0.00167 hours <br />9.920635e-6 weeks <br />2.283e-6 months <br />.
If neither of the above Required Actions can be completed within their associated Completion Times then the unit must be placed in a MODE where these Functions are not required OPERABLE. This requires the unit be placed in MODE 3 within 12 hours1.388889e-4 days <br />0.00333 hours <br />1.984127e-5 weeks <br />4.566e-6 months <br /> and MODE 4 within 18 hours2.083333e-4 days <br />0.005 hours <br />2.97619e-5 weeks <br />6.849e-6 months <br />. The allowed Completion Times are reasonable to reach the required unit conditions from full power conditions in an orderly manner and without challenging unit systems. In MODE 4, these Functions are no longer required OPERABLE.
2 5 B 3.3.2 Insert Page B 3.3.2-47d INSERT 15 L.1 and L.2
Condition L applies to the Loss of Voltage sensors associated with the Loss of Power AFW pump start ESFAS Function. These are the same sensors for the DG loss of Voltage start.
This function is provided by voltage sensors for each train arranged in a two-out-of-three logic scheme. If a sensor is inoperable, 6 hours6.944444e-5 days <br />0.00167 hours <br />9.920635e-6 weeks <br />2.283e-6 months <br /> is allowed to return it to OPERABLE status.
If the inoperable sensor cannot be restored to OPERABLE status within the specified Completion Time, the associated AFW pump must be declared inoperable. The TDAFW pump is considered OPERABLE when at least one train of the AFW loss of power start function is OPERABLE because both 6.9 kV shutdown board logic trains supply this function.
M.1.1, M.1.2, and M.2 Condition M applies to the Loss of Voltage sensors and load shed timers associated with the Loss of Power AFW pump start ESFAS Function. These are the same sensors and timers for the DG loss of Voltage start.
This function is provided by voltage sensors for each train arranged in a two-out-of-three logic scheme with associated load shed timers arranged in a one-out-of-two logic. If two or more voltage sensors or one required load shed timer are inoperable, 1 hour1.157407e-5 days <br />2.777778e-4 hours <br />1.653439e-6 weeks <br />3.805e-7 months <br /> is allowed to return the inoperable channel(s) to OPERABLE status. If the inoperable sensors cannot be made OPERABLE such that only one sensor is inoperable or one required load shed timer cannot be made OPERABLE within the specified Completion Time, the associated auxiliary feedwater pump must be declared inoperable. The AFW turbine-driven pump is considered OPERABLE when at least one train of the AFW loss of power start function is OPERABLE because both 6.9 kV shutdown board logic trains supply this function.
2 B 3.3.2 Insert Page B 3.3.2-47e INSERT 16 The Required Actions are modified by a not e delaying the entry into the Required Action statement when starting or stopping MFW pumps. Starting and stopping MFW pumps during plant startup and shutdown is a normal evolution, which will normally be accomplished within a short time. It was not intended to result in unnecessary entries into the Required Actions, which provides a timeframe to correct unplanned equipment failures. The 4 hours4.62963e-5 days <br />0.00111 hours <br />6.613757e-6 weeks <br />1.522e-6 months <br /> is consistent with similar allowances in other SQN TSs.
O.1 Condition O applies to the following ESFAS Functions:
- Auxiliary Feedwater Pump Suction Transfer on Suction Pressure - Low,*Auxiliary Feedwater Suction Transfer Time Delays, Motor-Driven Pump, and*Auxiliary Feedwater Suction Transfe r Time Delays, Turbine-Driven Pump.
These functions are provided by three pressure sensors located on the suction of each AFW pump arranged in a two-out-of-three logic scheme. The motor driven AFW pumps have one time delay, while the TDAFW pump has two. The motor driven and the first TDAFW pump time delays prevent spurious transfer. The TDAFW Pump second time delay ensures ERCW Train A valves stroke open sufficiently. If a pressure sensor channel or a time delay channel is inoperable, the associated AFW pump must be declared inoperable immediately.
7 2 Engineered Safety Feature Actuation System (ESFAS) Instrumentation (Without Setpoint Control Program)
B 3.3.2 A Westinghouse STS B 3.3.2 A-48 Rev. 4.0 SEQUOYAH UNIT 2 Revision XXX 1 1 2BASES ACTIONS (continued) a failed channel in the tripped condition could result in a premature switchover to the sump, prior to the injection of the minimum volume from the RWST. Placing the inoperable channel in bypass results in a two-out-of-three logic configuration, which satisfies the requirement to allow another failure without disabling actuation of the switchover when required. Restoring the channel to OPERABLE status or placing the inoperable channel in the bypass condition within
[6] hours is sufficient to ensure that the Function remains OPERABLE, and minimizes the time that the Function may be in a partial trip condition (assuming the inoperable channel has failed high). The
[6] hour Completion Time is justified in Reference 11. If the channel cannot be returned to OPERABLE status or placed in the bypass condition within 6 hours6.944444e-5 days <br />0.00167 hours <br />9.920635e-6 weeks <br />2.283e-6 months <br />, the unit must be brought to MODE 3 within the following
[6] hours and MODE 5 within the next 30 hours3.472222e-4 days <br />0.00833 hours <br />4.960317e-5 weeks <br />1.1415e-5 months <br />. The allowed Completion Times are reasonable, based on operating experience, to reach the required unit conditions from full power conditions in an orderly manner and without challenging unit systems. In MODE 5, the unit does not have any analyzed transients or conditions that require the explicit use of the protection functions noted above.
[ The Required Actions are modified by a Note that allows placing a second channel in the bypass condition for up to
[4] hours for surveillance testing. The total of
[12] hours to reach MODE 3 and
[4] hours for a second channel to be bypassed is acceptable based on the results of Reference 11.
] ----------------------------REVIEWER'S NOTE------------------------------------------ The below text should be used for plants with installed bypass test capability:
The Required Actions are modified by a Note that allows placing one channel in bypass for up to 12 hours1.388889e-4 days <br />0.00333 hours <br />1.984127e-5 weeks <br />4.566e-6 months <br /> while performing routine surveillance testing. The channel to be tested can be tested in bypass with the inoperable channel also in bypass. The total of [12]
hours to reach MODE 3 and [4] hours for a second channel to be bypassed is acceptable based on the results of Reference 1 1. --------------------------------------------------------------------------------------------------
L.1, L.2.1, and L.2.2 Condition L applies to the P-11 and P-12 [and P-14] interlock
- s.
With one or more channels inoperable, the operator must verify that the interlock is in the required state for the existing unit condition. This action manually accomplishes the function of the interlock. Determination must be made within 1 hour1.157407e-5 days <br />2.777778e-4 hours <br />1.653439e-6 weeks <br />3.805e-7 months <br />. The 1 hour1.157407e-5 days <br />2.777778e-4 hours <br />1.653439e-6 weeks <br />3.805e-7 months <br /> Completion Time is equal to the time Q Q 3 2 2 4 4 4 4 4 4 Engineered Safety Feature Actuation System (ESFAS) Instrumentation (Without Setpoint Control Program)
B 3.3.2 A Westinghouse STS B 3.3.2 A-49 Rev. 4.0 SEQUOYAH UNIT 2 Revision XXX 1 1 2BASES ACTIONS (continued) allowed by LCO 3.0.3 to initiate shutdown actions in the event of a complete loss of ESFAS function. If the interlock is not in the required state (or placed in the required state) for the existing unit condition, the unit must be placed in MODE 3 within the next 6 hours6.944444e-5 days <br />0.00167 hours <br />9.920635e-6 weeks <br />2.283e-6 months <br /> and MODE 4 within the following 6 hours6.944444e-5 days <br />0.00167 hours <br />9.920635e-6 weeks <br />2.283e-6 months <br />. The allowed Completion Times are reasonable, based on operating experience, to reach the required unit conditions from full power conditions in an orderly manner and without challenging unit systems. Placing the unit in MODE 4 removes all requirements for OPERABILITY of these interlocks.
SURVEILLANCE ----------------------------REVIEWER'S NOTE------------------------------------------
REQUIREMENTS In Table 3.3.2
-1, Functions 7.b and 7.c were not included in the generic evaluations approved in either WCAP
-10271, as supplemented, or WCAP-14333. In order to apply the WCAP
-10271, as supplemented, and WCAP-14333 TS relaxations to plant specific Functions not evaluated generically, licensees must submit plant specific evaluations for NRC review and approval.
REVIEWER'S NOTE------------------------------------------
Notes b and c are applied to the setpoint verification Surveillances for all Engineered Safety Feature Actuation System (ESFAS) Instrumentation Function in Table 3.3.2-1 unless one or more of the following exclusions apply: 1. Manual actuation circuits, automatic actuation logic circuits or instrument functions that derive input from contacts which have no associated sensor or adjustable device, e.g., limit switches, breaker position switches, manual actuation switches, float switches, proximity detectors, etc. are excluded.
In addition, those permissives and interlocks that derive input from a sensor or adjustable device that is tested as part of another TS function are excluded.
- 2. Settings associated with safety relief valves are excluded. The performance of these components is already controlled (i.e., trended with as-left and as
-found limits) under the ASME Code for Operation and Maintenance of Nuclear Power Plants testing program.
- 3. Functions and Surveillance Requirements which test only digital components are normally excluded. There is no expected change in result between SR performances for these components. Where separate as
-left and as
-found tolerance is established for digital component SRs, the requirements would apply.
3 3 INSERT 17 5 B 3.3.2 Insert Page B 3.3.2-49 INSERT 17 R.1 and R.2 If the inoperable channel cannot be placed in the tripped condition or the TTD of the single steam generator time delay calculation (T S) adjusted to match the multiple steam generator time delay calculation (T M) for the affected protection set within the specified Completion Time, the unit must be placed in a MODE where these Functions are not required OPERABLE. This requires the unit placed in MODE 3 within 6 hours6.944444e-5 days <br />0.00167 hours <br />9.920635e-6 weeks <br />2.283e-6 months <br /> and MODE 4 within 12 hours1.388889e-4 days <br />0.00333 hours <br />1.984127e-5 weeks <br />4.566e-6 months <br />. The allowed Completion Times are reasonable to reach the required unit conditions from full power conditions in an orderly manner and without challenging unit systems. In MODE 4, these Functions are no longer required OPERABLE.
S.1 and S.2
Condition S applies to the automatic actuation logic and actuation relays for the Automatic Switchover to Containment Sump.
This action addresses the train orientation of the SSPS and the master and slave relays. If one train is inoperable the unit must be placed in a MODE in which the LCO does not apply. This is done by placing the unit in at least MODE 3 within 12 hours1.388889e-4 days <br />0.00333 hours <br />1.984127e-5 weeks <br />4.566e-6 months <br /> and in MODE 5 within an additional 30 hours3.472222e-4 days <br />0.00833 hours <br />4.960317e-5 weeks <br />1.1415e-5 months <br /> (42 hours4.861111e-4 days <br />0.0117 hours <br />6.944444e-5 weeks <br />1.5981e-5 months <br /> total time). The Completion Times are reasonable to reach the required unit conditions from full power conditions in an orderly manner and without challenging unit systems.
The Required Actions are modified by a Note that allows one train to be bypassed for up to 4 hours4.62963e-5 days <br />0.00111 hours <br />6.613757e-6 weeks <br />1.522e-6 months <br /> for surveillance testing, provided the other train is OPERABLE.
5 Engineered Safety Feature Actuation System (ESFAS) Instrumentation (Without Setpoint Control Program)
B 3.3.2 A Westinghouse STS B 3.3.2 A-50 Rev. 4.0 SEQUOYAH UNIT 2 Revision XXX 1 1 2BASES
SURVEILLANCE REQUIREMENTS (continued)
The SRs for each ESFAS Function are identified by the SRs column of Table 3.3.2-1.
A Note has been added to the SR Table to clarify that Table 3.3.2-1 determines which SRs apply to which ESFAS Functions.
Note that each channel of process protection supplies both trains of the ESFAS. When testing channel I, train A and train B must be examined.
Similarly, train A and train B must be examined when testing channel II, channel III, and channel IV (if applicable). The CHANNEL CALIBRATION and COTs are performed in a manner that is consistent with the assumptions used in analytically calculating the required channel accuracies.
REVIEWER'S NOTE-----------------------------------------
Certain Frequencies are based on approved topical reports. In order for a licensee to use these times, the licensee must justify the Frequencies a s required by the staff SER for the topical report.
SR 3.3.2.1 Performance of the CHANNEL CHECK ensures that a gross failure of instrumentation has not occurred. A CHANNEL CHECK is normally a comparison of the parameter indicated on one channel to a similar parameter on other channels. It is based on the assumption that instrument channels monitoring the same parameter should read approximately the same value. Significant deviations between the two instrument channels could be an indication of excessive instrument drift in one of the channels or of something even more serious. A CHANNEL CHECK will detect gross channel failure; thus, it is key to verifying the instrumentation continues to operate properly between each CHANNEL CALIBRATION.
Agreement criteria are determined by the unit staff, based on a combination of the channel instrument uncertainties, including indication and reliability. If a channel is outside the criteria, it may be an indication that the sensor or the signal processing equipment has drifted outside its limit.
[ The Frequency of 12 hours1.388889e-4 days <br />0.00333 hours <br />1.984127e-5 weeks <br />4.566e-6 months <br /> is based on operating experience that demonstrates channel failure is rare. The CHANNEL CHECK supplements less formal, but more frequent, checks of channels during 3 8 Engineered Safety Feature Actuation System (ESFAS) Instrumentation (Without Setpoint Control Program)
B 3.3.2 A Westinghouse STS B 3.3.2 A-51 Rev. 4.0 SEQUOYAH UNIT 2 Revision XXX 1 1 2BASES
SURVEILLANCE REQUIREMENTS (continued) normal operational use of the displays associated with the LCO required channels.
OR The Surveillance Frequency is controlled under the Surveillance Frequency Control Program.
REVIEWER'S NOTE-----------------------------------
Plants controlling Surveillance Frequencies under a Surveillance Frequency Control Program should utilize the appropriate Frequency description, given above, and the appropriate choice of Frequency in the Surveillance Requirement.
]
SR 3.3.2.2 SR 3.3.2.2 is the performance of an ACTUATION LOGIC TEST using the semiautomatic tester. The train being tested is placed in the bypass condition, thus preventing inadvertent actuation. Through the semiautomatic tester, all possible logic combinations, with and without applicable permissives, are tested for each protection function. In addition, the master relay coil is pulse tested for continuity. This verifies that the logic modules are OPERABLE and that there is an intact voltage signal path to the master relay coils.
[ The Frequency of every 92 days on a STAGGERED TEST BASIS is justified in Reference 1
- 2.
OR The Surveillance Frequency is controlled under the Surveillance Frequency Control Program.
REVIEWER'S NOTE-----------------------------------
Plants controlling Surveillance Frequencies under a Surveillance Frequency Control Program should utilize the appropriate Frequency description, given above, and the appropriate choice of Frequency in the Surveillance Requirement.
]
SR 3.3.2.3 SR 3.3.2.3 is the performance of an ACTUATION LOGIC TEST as described in SR 3.3.2.2, except that the semiautomatic tester is not used 3 3 2 8 8 Engineered Safety Feature Actuation System (ESFAS) Instrumentation (Without Setpoint Control Program)
B 3.3.2 A Westinghouse STS B 3.3.2 A-52 Rev. 4.0 SEQUOYAH UNIT 2 Revision XXX 1 1 2BASES
SURVEILLANCE REQUIREMENTS (continued)
and the continuity check does not have to be performed, as explained in the Note. This SR is applied to the balance of plant actuation logic and relays that do not have the SSPS test circuits installed to utilize the semiautomatic tester or perform the continuity check.
[ This test is also performed every 31 days on a STAGGERED TEST BASIS. The Frequency is adequate based on industry operating experience, considering instrument reliabil ity and operating history data.
OR The Surveillance Frequency is controlled under the Surveillance Frequency Control Program.
REVIEWER'S NOTE-----------------------------------
Plants controlling Surveillance Frequencies under a Surveillance Frequency Control Program should utilize the appropriate Frequency description, given above, and the appropriate choice of Frequency in the Surveillance Requirement.
]
4 SR 3.3.2.4 is the performance of a MASTER RELAY TEST. The MASTER RELAY TEST is the energizing of the master relay, verifying contact operation and a low voltage continuity check of the slave relay coil. Upon master relay contact operation, a low voltage is injected to the slave relay coil. This voltage is insufficient to pick up the slave relay, but large enough to demonstrate signal path continuity. The time allowed for the testing on a STAGGERED TEST BASIS (4 hours4.62963e-5 days <br />0.00111 hours <br />6.613757e-6 weeks <br />1.522e-6 months <br />) is justified in
Reference 12.
[ The Frequency of 92 days is justified in Reference
- 10. OR The Surveillance Frequency is controlled under the Surveillance Frequency Control Program.
REVIEWER'S NOTE-----------------------------------
Plants controlling Surveillance Frequencies under a Surveillance Frequency Control Program should utilize the appropriate Frequency description, given above, and the appropriate choice of Frequency in the Surveillance Requirement.
]
3 3 3 3 2 2 8 Engineered Safety Feature Actuation System (ESFAS) Instrumentation (Without Setpoint Control Program)
B 3.3.2 A Westinghouse STS B 3.3.2 A-53 Rev. 4.0 SEQUOYAH UNIT 2 Revision XXX 1 1 2BASES
SURVEILLANCE REQUIREMENTS (continued)
5 SR 3.3.2.5 is the performance of a COT.
A COT is performed on each required channel to ensure the entire channel will perform the intended Function. Setpoints must be found conservative with respect to the Allowable Values specified in Table 3.3.2-1. A successful test of the required contact(s) of a channel relay may be performed by the verification of the change of state of a single contact of the relay. This clarifies what is an acceptable COT of a relay. This is acceptable because all of the other required contacts of the relay are verified by other Technical Specifications and non-Technical Specifications tests at least once per refueling interval with applicable extensions.
The difference between the current "as-found" values and the previous test "as left" values must be consistent with the drift allowance used in the setpoint methodology. The setpoint shall be left set consistent with the assumptions of the current unit specific setpoint methodology.
The "as-found" and "as-left" values must also be recorded and reviewed for consistency with the assumptions of Reference 7.
[ The Frequency of 184 days is justified in Reference 1 2.
OR The Surveillance Frequency is controlled under the Surveillance Frequency Control Program.
REVIEWER'S NOTE-----------------------------------
Plants controlling Surveillance Frequencies under a Surveillance Frequency Control Program should utilize the appropriate Frequency description, given above, and the appropriate choice of Frequency in the Surveillance Requirement.
]
SR 3.3.2.5 is modified by two Notes as identified in Table 3.3.2-1. The first Note requires evaluation of channel performance for the condition where the as-found setting for the channel setpoint is outside its as-found tolerance but conservative with respect to the Allowable Value.
Evaluation of channel performance will verify that the channel will continue to behave in accordance with safety analysis assumptions and the channel performance assumptions in the setpoint methodology. The purpose of the assessment is to ensure confidence in the channel 4 4 4 3 2 2 8 Engineered Safety Feature Actuation System (ESFAS) Instrumentation (Without Setpoint Control Program)
B 3.3.2 A Westinghouse STS B 3.3.2 A-54 Rev. 4.0 SEQUOYAH UNIT 2 Revision XXX 1 1 2BASES
SURVEILLANCE REQUIREMENTS (continued)
performance prior to returning the channel to service. For channels determined to be OPERABLE but degraded, after returning the channel to service the performance of these channels will be evaluated under the plant Corrective Action Program. Entry into the Corrective Action Program will ensure required review and documentation of the condition. The second Note requires that the as-left setting for the channel be returned to within the as-left tolerance of the
[NTSP]. Where a setpoint more conservative than the
[NTSP] is used in the plant surveillance procedures (field setting), the as-left and as-found tolerances, as applicable, will be applied to the surveillance procedure setpoint. This will ensure that sufficient margin to the Safety Limit and/or Analytical Limit is maintained. If the as-left channel setting cannot be returned to a setting
within the as-left tolerance of the
[NTSP], then the channel shall be declared inoperable.
REVIEWER'S NOTE-----------------------------------
The bracketed section '[NTSP and the]'
of the sentence in Note (c) in Table 3.3.2-1 is not required in plant
-specific Technical Specifications which include a [Nominal Trip Setpoint] column in Table 3.3.2-1. -------------------------------------------------------------------------------------------------- The second Note also requires that the [NTSP and the] methodologies for calculating the as-left and the as-found tolerances be in [insert the facility FSAR reference or the name of any document incorporated into the facility FSAR by reference]. SR 3.3.2.
6 SR 3.3.2.6 is the performance of a SLAVE RELAY TEST. The SLAVE RELAY TEST is the energizing of the slave relays. Contact operation is verified in one of two ways. Actuation equipment that may be operated in the design mitigation MODE is either allowed to function, or is placed in a condition where the relay contact operation can be verified without operation of the equipment. Actuation equipment that may not be operated in the design mitigation MODE is prevented from operation by the SLAVE RELAY TEST circuit. For this latter case, contact operation is verified by a continuity check of the circuit containing the slave relay.
[ The Frequency of 92 days is adequate, based on industry operating experience, considering instrument relia bility and operating history data.
OR The Surveillance Frequency is controlled under the Surveillance Frequency Control Program.
5 5 3 2 4 4 4 8UFSAR Section 7.1.2 Engineered Safety Feature Actuation System (ESFAS) Instrumentation (Without Setpoint Control Program)
B 3.3.2 A Westinghouse STS B 3.3.2 A-55 Rev. 4.0 SEQUOYAH UNIT 2 Revision XXX 1 1 2BASES
SURVEILLANCE REQUIREMENTS (continued)
REVIEWER'S NOTE-----------------------------------
Plants controlling Surveillance Frequencies under a Surveillance Frequency Control Program should utilize the appropriate Frequency description, given above, and the appropriate choice of Frequency in the Surveillance Requirement.
]
7 SR 3.3.2.7 is the performance of a TADOT. This test is a check of the Loss of Offsite Power
, Undervoltage RCP , and AFW Pump Suction Transfer on Suc tion Pressure
- Low Function s. Each Function is tested up to, and including, the master transfer relay coils. A successful test of the required contact(s) of a channel relay may be performed by the verification of the change of state of a single contact of the relay. This clarifies what is an acceptable TADOT of a relay. This is acceptable because all of the other required contacts of the relay are verified by other Technical Specifications and non-Technical Specifications tests at least once per refueling interval with applicable extensions.
The test also includes trip channels that provide actuation signals directly to the SSPS. The SR is modified by a Note that excludes verification of setpoints for relays. Relay setpoints require elaborate bench calibration and are verified during CHANNEL CALIBRATION.
[ The Frequency of 92 days is adequate. It is based on industry operating experience, considering instrument reliability and operating history data.
OR The Surveillance Frequency is controlled under the Surveillance Frequency Control Program.
REVIEWER'S NOTE-----------------------------------
Plants controlling Surveillance Frequencies under a Surveillance Frequency Control Program should utilize the appropriate Frequency description, given above, and the appropriate choice of Frequency in the Surveillance Requirement.
] 6 6 3 3 2 8 Engineered Safety Feature Actuation System (ESFAS) Instrumentation (Without Setpoint Control Program)
B 3.3.2 A Westinghouse STS B 3.3.2 A-56 Rev. 4.0 SEQUOYAH UNIT 2 Revision XXX 1 1 2BASES
SURVEILLANCE REQUIREMENTS (continued)
8 SR 3.3.2.8 is the performance of a TADOT. This test is a check of the Manual Actuation Functions and AFW pump start on trip of all MFW pumps. Each Manual Actuation Function is tested up to, and including, the master relay coils. A successful test of the required contact(s) of a channel relay may be performed by the verification of the change of state of a single contact of the relay. This clarifies what is an acceptable TADOT of a relay. This is acceptable because all of the other required contacts of the relay are verified by other Technical Specifications and non-Technical Specifications tests at least once per refueling interval with applicable extensions. In some instances, the test includes actuation of
the end device (i.e., pump starts, valve cycles, etc.).
[ The Frequency of 18 months is adequate, based on industry operating experience and is consistent with the typical refueling cycle.
OR The Surveillance Frequency is controlled under the Surveillance Frequency Control Program.
REVIEWER'S NOTE-----------------------------------
Plants controlling Surveillance Frequencies under a Surveillance Frequency Control Program should utilize the appropriate Frequency description, given above, and the appropriate choice of Frequency in the Surveillance Requirement.
] SR 3.3.2.8 is modified by two Notes as identified in Table 3.3.2-1. The first Note requires evaluation of channel performance for the condition where the as
-found setting for the channel setpoint is outside its as
-found tolerance but conservative with respect to the Allowable Value. Evaluation of channel performance will verify that the channel will continue to behave in accordance with safety analysis assumptions and the channel performance assumptions in the setpoint methodology. The purpose of the assessment is to ensure confidence in the channel performance prior to returning the channel to service. For channels determined to be OPERABLE but degraded, after returning the channel to service the performance of these channels will be evaluated under the plant Corrective Action Program. Entry into the Corrective Action Program will ensure required review and documentation of the condition. The second Note requires that the as
-left setting for the channel be returned to within the as
-left tolerance of the [NTSP]. Where a setpoint more conservative than the [NTSP] is used in the plant surveillance 7 7 3 2 2 8 Engineered Safety Feature Actuation System (ESFAS) Instrumentation (Without Setpoint Control Program)
B 3.3.2 A Westinghouse STS B 3.3.2 A-57 Rev. 4.0 SEQUOYAH UNIT 2 Revision XXX 1 1 2BASES
SURVEILLANCE REQUIREMENTS (continued)
procedures (field setting), the as
-left and as
-found tolerances, as applicable, will be applied to the surveillance procedure setpoint. This will ensure that sufficient margin to the Safety Limit and/or Analytical Limit is maintained. If the as
-left channel setting cannot be returned to a setting within the as
-left tolerance of the [NTSP], then the channel shall be declared inoperable.
REVIEWER'S NOTE-----------------------------------
The bracketed section '[NTSP and the]'
of the sentence in Note (c) in Table 3.3.2
-1 is not required in plant
-specific Technical Specifications which include a [Nominal Trip Setpoint] column in Table 3.3.2
-1. --------------------------------------------------------------------------------------------------
The second Note also requires that the [NTSP and the] methodologies for calculating the as
-left and the as
-found tolerances be in [insert the facility FSAR reference or the name of any document incorporated into the facility FSAR by reference].
The SR is modified by a Note that excludes verification of setpoints during the TADOT for manual initiation Functions. The manual initiation Functions have no associated setpoints.
9 SR 3.3.2.9 is the performance of a CHANNEL CALIBRATION.
CHANNEL CALIBRATION is a complete check of the instrument loop, including the sensor. The test verifies that the channel responds to measured parameter within the necessary range and accuracy.
CHANNEL CALIBRATIONS must be performed consistent with the assumptions of the unit specific setpoint methodology. The difference between the current "as-found" values and the previous test "as-left" values must be consistent with the drift allowance used in the setpoint methodology.
[ The Frequency of [18]
months is based on the assumption of an
[18] month calibration interval in the determination of the magnitude of equipment drift in the setpoint methodo logy.
OR The Surveillance Frequency is controlled under the Surveillance Frequency Control Program.
8 8 3 2 2 2 8 Engineered Safety Feature Actuation System (ESFAS) Instrumentation (Without Setpoint Control Program)
B 3.3.2 A Westinghouse STS B 3.3.2 A-58 Rev. 4.0 SEQUOYAH UNIT 2 Revision XXX 1 1 2BASES
SURVEILLANCE REQUIREMENTS (continued)
REVIEWER'S NOTE-----------------------------------
Plants controlling Surveillance Frequencies under a Surveillance Frequency Control Program should utilize the appropriate Frequency description, given above, and the appropriate choice of Frequency in the Surveillance Requirement.
] This SR is modified by a Note stating that this test should include verification that the time constants are adjusted to the prescribed values where applicable.
SR 3.3.2.9 is modified by two Notes as identified in Table 3.3.2-1. The first Note requires evaluation of channel performance for the condition where the as-found setting for the channel setpoint is outside its as-found tolerance but conservative with respect to the Allowable Value.
Evaluation of channel performance will verify that the channel will continue to behave in accordance with safety analysis assumptions and the channel performance assumptions in the setpoint methodology. The purpose of the assessment is to ensure confidence in the channel performance prior to returning the channel to service. For channels determined to be OPERABLE but degraded, after returning the channel to service the performance of these channels will be evaluated under the plant Corrective Action Program. Entry into the Corrective Action Program will ensure required review and documentation of the condition.
The second Note requires that the as-left setting for the channel be
returned to within the as-left tolerance of the
[NTSP]. Where a setpoint more conservative than the
[NTSP] is used in the plant surveillance procedures (field setting), the as-left and as-found tolerances, as applicable, will be applied to the surveillance procedure setpoint. This will ensure that sufficient margin to the Safety Limit and/or Analytical Limit is maintained. If the as-left channel setting cannot be returned to a setting
within the as-left tolerance of the
[NTSP], then the channel shall be declared inoperable.
REVIEWER'S NOTE
The bracketed section '[NTSP and the]'
of the sentence in Note (c) in Table 3.3.2-1 is not required in plant
-specific Technical Specifications which include a [Nominal Trip Setpoint] column in Table 3.3.2-1. --------------------------------------------------------------------------------------------------
The second Note also requires that the [NTSP and the] methodologies for calculating the as-left and the as-found tolerances be in [insert the facility FSAR reference or the name of any document incorporated into the facility FSAR by reference]. 8 3 3 2 4 4 4 4UFSAR Section 7.1.2 Engineered Safety Feature Actuation System (ESFAS) Instrumentation (Without Setpoint Control Program)
B 3.3.2 A Westinghouse STS B 3.3.2 A-59 Rev. 4.0 SEQUOYAH UNIT 2 Revision XXX 1 1 2BASES
SURVEILLANCE REQUIREMENTS (continued)
10 This SR ensures the individual channel ESF RESPONSE TIMES are less than or equal to the maximum values assumed in the accident analysis.
Response Time testing acceptance criteria are included in the Technical Requirements Manual , Section 15 (Ref. 13). Individual component response times are not modeled in the analyses. The analyses model the overall or total elapsed time, from the point at which the parameter exceeds the Trip Setpoint value at the sensor, to the point at which the equipment in both trains reaches the required functional state (e.g., pumps at rated discharge pressure, valves in full open or closed position).
For channels that include dynamic transfer functions (e.g., lag, lead/lag, rate/lag, etc.), the response time test may be performed with the transfer functions set to one with the resulting measured response time compared to the appropriate FSAR response time. Alternately, the response time test can be performed with the time constants set to their nominal value provided the required response time is analytically calculated assuming the time constants are set at their nominal values. The response time may be measured by a series of overlapping tests such that the entire
response time is measured.
REVIEWER'S NOTE-----------------------------------------
Applicable portions of the following Bases are applicable for plants adopting WCAP
-13632-P-A (Ref. 1 4). and/or WCAP
-14036-P (Ref. 1 5). --------------------------------------------------------------------------------------------------
Response time may be verified by actual response time tests in any series of sequential, overlapping or total channel measurements, or by the summation of allocated sensor, signal processing and actuation logic response times with actual response time tests on the remainder of the channel. Allocations for sensor response times may be obtained from: (1) historical records based on acceptable response time tests (hydraulic, noise, or power interrupt tests), (2) in place, onsite, or offsite (e.g.,
vendor) test measurements, or (3) utilizing vendor engineering specifications. WCAP-13632-P-A, Revision 2, "Elimination of Pressure Sensor Response Time Testing Requirements," (Ref. 14) dated January 1996, provides the basis and methodology for using allocated sensor response times in the overall verification of the channel response time for specific sensors identified in the WCAP. Response time verification for other sensor types must be demonstrated by test.
9Updated Final Safety Analysis Report, Section7.3 U 3 2 2 2 Engineered Safety Feature Actuation System (ESFAS) Instrumentation (Without Setpoint Control Program)
B 3.3.2 A Westinghouse STS B 3.3.2 A-60 Rev. 4.0 SEQUOYAH UNIT 2 Revision XXX 1 1 2BASES
SURVEILLANCE REQUIREMENTS (continued)
WCAP-14036-P, Revision 1, "Elimination of Periodic Protection Channel Response Time Tests," (Ref. 15) provides the basis and methodology for using allocated signal processing and actuation logic response times in the overall verification of the protection system channel response time.
The allocations for sensor, signal conditioning, and actuation logic response times must be verified prior to placing the component in operational service and re-verified following maintenance that may adversely affect response time. In general, electrical repair work does not impact response time provided the parts used for repair are of the same type and value. Specific components identified in the WCAP may be replaced without verification testing. One example where response time could be affected is replacing the sensing assembly of a transmitter.
[ ESF RESPONSE TIME tests are conducted on an [18]
month STAGGERED TEST BASIS. Testing of the final actuation devices, which make up the bulk of the response time, is included in the testing of each channel. The final actuation device in one train is tested with each channel. Therefore, staggered testing results in response time verification of these devices every [18]
months. The [18]
month Frequency is consistent with the typical refueling cycle and is based on unit operating experience, which shows that random failures of instrumentation components causing serious response time degradation, but not channel failure, are infrequent occurrences.
OR The Surveillance Frequency is controlled under the Surveillance Frequency Control Program.
REVIEWER'S NOTE-----------------------------------
Plants controlling Surveillance Frequencies under a Surveillance Frequency Control Program should utilize the appropriate Frequency description, given above, and the appropriate choice of Frequency in the Surveillance Requirement.
]
This SR is modified by a Note that clarifies that the turbine driven AFW pump is tested within 24 hours2.777778e-4 days <br />0.00667 hours <br />3.968254e-5 weeks <br />9.132e-6 months <br /> after reaching
[1000] psig in the SGs.
11 SR 3.3.2.11 is the performance of a TADOT as described in SR 3.3.2.
8 , except that it is performed for the P-4 Reactor Trip Interlock, and the 10 10 7 3 2 4 842 8 Engineered Safety Feature Actuation System (ESFAS) Instrumentation (Without Setpoint Control Program)
B 3.3.2 A Westinghouse STS B 3.3.2 A-61 Rev. 4.0 1 1 2BASES
SURVEILLANCE REQUIREMENTS (continued)
Frequency is once per RTB cycle. A successful test of the required contact(s) of a channel relay may be performed by the verification of the change of state of a single contact of the relay. This clarifies what is an acceptable TADOT of a relay. This is acceptable because all of the other required contacts of the relay are verified by other Technical Specifications and non
-Technical Specifications tests at least once per refueling interval with applicable extensions. This Frequency is based on operating experience demonstrating that undetected failure of the P-4 interlock sometimes occurs when the RTB is cycled.
The SR is modified by a Note that excludes verification of setpoints during the TADOT. The Function tested has no associated setpoint.
REFERENCES 1. Regulatory Guide 1.105, "Setpoint for Safety Related Instrumentation," Revision 3.
- 2. FSAR, Chapter
[6]. 3. FSAR, Chapter
[7].
- 4. FSAR, Chapter
[15].
- 5. IEEE-279-1971.
- 6. 10 CFR 50.49.
- 7. Plant-specific setpoint methodology study.
- 8. NUREG-1218, April 1988.
- 9. WCAP-14333-P-A, Rev. 1, October 1998.
- 10. WCAP-10271-P-A, Supplement 2, Rev. 1, June 1990.
- 11. [Plant specific evaluation reference.]
- 12. WCAP-15376, Rev. 0. October 2000.
- 13. Technical Requirements Manual, Section 15, "Response Times." 14. WCAP-13632-P-A, Revision 2, "Elimination of Pressure Sensor Response Time Testing Requirements," January 1996.
- 15. WCAP-14036-P, Revision 1, "Elimination of Periodic Protection Channel Response Time Tests," December 1995. UFSAR, Section 7.3 Calculation SQN-EEB-PL&S, Precautions, Limitations, and Setpoints for NSSS SEQUOYAH UNIT 2 Revision XXX 2 2 2 4 4 4 4 U U 2 2 2License Amendment dated June 13, 1995, Issuance of Amendments to Technical Specifications - Sequoyah Nuclear Plant, Units 1 and 2 (TAC NOS. M91990 and 91991) (ML013320052)
U reactor trip breaker reactor trip breaker JUSTIFICATION FOR DEVIATIONS ITS 3.3.2 BASES, ENGINEERED SAFETY FEATURE ACTUATION SYSTEM (ESFAS) INSTRUMENTATION Sequoyah Unit 1 and Unit 2 Page 1 of 1 1.NUREG 1431, Standard Technical Specificat ions - Westinghouse Plants, Revision 4.0 provides two sets of specification for Section 3.3.2; one for adoption " Without a Setpoint Control Program," (3.3.2.A) the other fo r adoption " With a Setpoint Control Program," (3.3.2.B). This information is provided in NUREG-1431, Rev.
4.0, to assist in identifying the appropriate Specification to be used as a model for the plant specific ITS conversion, but serves no purpose in a plant specific implementation and is removed.
2.Changes are made (additions, deletions, and/or changes) to the ISTS Bases that reflect the plant specific nomenclature, number, reference, system description, analysis, or licensing basis descriptio
- n. Where a deletion has occurred, subsequent alpha-numeric designators have been changed for any applicable affect ed ACTIONS, SURVEILLANCE REQUIREMENTS, FUNCTIO NS, and Footnotes.
3.The Reviewer's Note has been deleted. Thi s information is for the NRC reviewer to be keyed into what is needed to meet this requirement. This Note is not meant to be retained in the final version of the plant specific submittal.
4.The ISTS contains bracketed information and/or values that ar e generic to Westinghouse vintage plants. The brackets are removed and the proper plant specific information/value is inserted to reflect th e current licensing basis.
5.Changes are made to be consistent with changes made to the Specifica tion.6.Editorial changes are made for clarity
.7.Changes made to explain the basis for the Note added to the Required Actions consistent with NRC app roval contained in SQN License Amendment 319/312, reference ADAMS Accession Nos.
ML082401385 and ML082401446.
8.ISTS SR 3.3.2.1 through ISTS 3.3.2.11 (ITS SR 3.3.2.1 thro ugh ITS 3.3.2.10) provide two options for controlling th e Frequencies of Surveillance Requi rements.SQN is proposing to control the Surveillance Frequencies un der the Surveillance Frequency Control Program. Therefore, the Frequency for ITS SR 3.3.
2.1 through
ITS 3.3.2.10 is "In accordance with the Surveillance Freque ncy Control Program."
Specific No Significant Haza rds Considerations (NSHCs)
DETERMINATION OF NO SIGNIFICANT HAZARDS CONSIDERATIONS ITS 3.3.2, ENGINEERED SAFETY FEATURE ACTUATION SYSTEM (ESFAS) INSTRUMENTATION Sequoyah Unit 1 and 2 Page 1 of 4 10 CFR 50.92 EVALUATION FOR LESS RESTRICTIVE CHANGE L12 and L13 SQN is converting to the Improved Techni cal Specifications (ITS) as outlined in NUREG-1431, "Standard Technical Specifications, West inghouse Plants." Most changes to the SQN current Technical Specifications (CTS) incorporate industry changes made to NUREG-1431 and are covered by generic No Significant Hazards
Considerations. Proposed chang es that are not considered included in the conversion to NUREG-1431 are outside of the generic evaluation and require separate evaluation, as is the case with these less restrict ive changes (L12 and L13). The proposed change involves making the Current Technical Specific ations (CTS) less restrictive. Below are the descriptions of these less restrict ive changes and the determination of No Significant Hazards Considerations for conversion to NUREG-1431.
CTS Table 3.3-3 ACTION 37 requires that with the number of OPERABLE channels one less than the Total Number of Channels, STARTUP and POWER OPERATION
may proceed provided that within 6 hours6.944444e-5 days <br />0.00167 hours <br />9.920635e-6 weeks <br />2.283e-6 months <br />, for the affected protection set, the Trip Time Delays (T S and T M) threshold power level for zero se conds time delay is adjusted to 0% RTP. This action is applicable to CTS T able 3.3-3 Functional Unit 6.c.i.c (Auxiliary Feedwater, Main Stm. Gen Water Level - Low-Low, Start Motor-Driven Pumps, RCS Loop T) and Functional Unit 6.c.ii.c (Auxiliary Feedwater, Main Stm. Gen Water Level - Low-Low, Start Turbine-Driven Pump, RCS Loop T). ITS 3.3.2 Re quired Action K.2 allows an alternative of placing the Steam Generator Water Level -- Low-Low channel in trip instead of adjusting the Trip Time Delays (T S and T M) threshold power level for zero seconds time delay to 0% RTP with the same Completion Time. This changes the CTS by adding an alternative to adjusting the TTD threshold power level for zero seconds.
The purpose of CTS Table 3.3-3 ACTION 37 is to limit the maximum time allowed for
maintenance activities, in which the channel is unavailable prior to adjusting the affected protection set's Trip Time Delays (T S and T M) threshold power level for zero seconds time delay to 0% RTP. With the trip time delay adjusted to zero seconds the additional operational margin that allows the operator ti me to recover SG Wa ter level is removed and the associated SG Water level channel is re turned to OPERABLE.
If the threshold power level for zero seconds time delay is not adjusted from 50% RTP to 0% RTP within the specified Completion Time this proposed change allows placing the affected protection sets SG Water Level Low-Low c hannels in the tripped condition. Once the channel is placed in the tripped condition the RCS T TTD circuitry is removed from the active portion of the Steam Generator Low-Low Level channel, reference UFSAR Figure 7.2.1-1, Sheets 17 through 20 and this action is no longer necessary. The action of tripping the channel provides the protection sets input to the 2/3 logic gates located on
UFSAR Figure 7.2.1-1 Sheet
- 19. The ITS Required Action K.2 Completion Time of 6 hours6.944444e-5 days <br />0.00167 hours <br />9.920635e-6 weeks <br />2.283e-6 months <br /> is consistent with CTS TABLE 3.3-3 ACTION 37 and the proposed ITS Required Action K.1. This change is designated as less restrictive because less stringent Required Actions are being applied in ITS than were applied in CTS.
DETERMINATION OF NO SIGNIFICANT HAZARDS CONSIDERATIONS ITS 3.3.2, ENGINEERED SAFETY FEATURE ACTUATION SYSTEM (ESFAS) INSTRUMENTATION Sequoyah Unit 1 and 2 Page 2 of 4 CTS Table 3.3-3 ACTION 38 requires that with the number of OPERABLE channels one less than the Total Number of Channels, STARTUP and POWER OPERATION
may proceed provided that within 6 hours6.944444e-5 days <br />0.00167 hours <br />9.920635e-6 weeks <br />2.283e-6 months <br />, for the affected protection set, the Steam
Generator Water Level -Low-Low (EAM) channels trip setpoint is adjusted to the same value as Steam Generator Wate r Level - Low-Low (Adverse).
This action is applicable to CTS Functional Unit 6.c.i.d (Auxiliary Feedwater, Main Stm. Gen Water Level - Low-Low, Start Motor-Driven Pumps, Containment Pressure (EAM)) and Functional Unit 6.c.ii.d (Auxiliary Feedwater, Main Stm.
Gen Water Level - Low-Low, Start Turbine-Driven Pump, Containment Pressu re (EAM)). ITS 3.3.2 Requi red Action J.2 allows an alternative of placing the Steam Generator Water Level
-- Low-Low channel in trip instead of adjusting the Steam Generator Water Level -- Low-Low (EAM) channels trip
setpoint to the same value as Steam Gener ator Water Level -- Low-Low (Adverse) with
the same Completion Time for placing the channel in trip. This changes the CTS by adding an alternative to adjusting the Steam Generator Water Level -- Low-Low (EAM) channels trip setpoint to the same value as Steam Generator Wa ter Level -- Low-Low (Adverse).
The purpose of CTS Table 3.3-3 ACTION 38 is to limit the maximum time allowed for maintenance activities, in which the channel is unavailable prior to adjusting the Steam
Generator Water Level -Low-Low (EAM) channels trip setpoint to the same value as Steam Generator Water Level -- Low-Low (Adv erse). If the Steam Generator Water Level -Low-Low (EAM) channels trip setpoint is not adjusted to the same value as Steam Generator Water Level -- Low-Low (A dverse) within the specified Completion Time this proposed change allows placing the a ffected protection sets SG Water Level -- Low-Low level channels in the tripped condit ion. Once the channel is placed in the tripped condition the Steam G enerator Water Level -- Low-Low EAM/Adverse circuitry is removed from the active portion of the Steam Generator Water Level -- Low-Low channel, reference UFSAR Fi gure 7.2.1-1, Sheets 17 thr ough 20, and these actions are no longer necessary. The action of tripping the channel provides the protection sets input to the 2/3 logic gates located on UFSAR Figure 7.2.1-1 Sheet 19. The ITS Required Action J.2 Completion Time of 6 h ours is consistent with CTS TABLE 3.3-3 ACTION 38 and the proposed ITS Required Action J.1. This change is designated as less restrictive because less stringent Required Actions are being applied in ITS than were applied in CTS.
Tennessee Valley Authority (TVA) has evaluated whether or not a significant hazards consideration is involved wit h these proposed Technical Specification changes by focusing on the three standards set forth in 10 CFR 50.92, "Issuance of amendment,"
as discussed below:
- 1. Does the proposed change involve a significant increase in the probability or consequences of any accident previously evaluated?
DETERMINATION OF NO SIGNIFICANT HAZARDS CONSIDERATIONS ITS 3.3.2, ENGINEERED SAFETY FEATURE ACTUATION SYSTEM (ESFAS) INSTRUMENTATION Sequoyah Unit 1 and 2 Page 3 of 4 Response: No.
The proposed change relaxes the Required Actions for the Engineered Safety Feature Actuation System (ESFAS) Instru mentation, Auxiliary Feedwater Main Steam Generator Water Lev el-Low-Low, when an RCS Loop T or a Containment Pressure (EAM) channel is inoperable. Placing the affected Auxiliary Feedwater Main Steam Generat or Water Level-Low-Low channels in trip uses installed equipment designed specific ally for placing the channels in trip.
This change will not affect the probability of an accident, because the OPERABLE Auxiliary Feedwater Main Steam Generator Water Level-Low-Low channels will continue to perform the sa fety function the instrumentation is required to perform. The Auxiliary Feedwater Main Steam Generator Water Level-Low-Low channels are not initiators of any accident sequence analyzed in the Updated Final Safety Analysis Report (UFSAR).
Rather, Auxiliary Feedwater Main Steam Generator Water Level-Low-Low channels are used to mitigate accidents. The consequences of an analyzed accident will not be significantly increased since the minimum requirements for Auxiliary Feedwater
Main Steam Generator Water Level-Low-Low channels will be maintained to ensure the availability of the required instrumentat ion to mitigate accidents assumed in the UFSAR. Operation in accordance with the proposed TS will ensure that sufficient Auxi liary Feedwater Main Steam Generator Water Level-Low-Low channels are OPERABLE as requi red to support the unit's required features. Therefore, th e mitigating functions s upported by the Auxiliary Feedwater Main Steam Generator Wate r Level-Low-Low instrumentation will continue to provide the protection assumed by the accident analysis. The integrity of fission product barriers, plant configuration, and operating procedures as described in the UFSAR will not be affected by the proposed changes. Thus, the consequences of previously analyzed accidents will not be significantly increased by implementing these changes.
Therefore, the proposed changes do not involve a significant increase in the probability or consequences of an accident previously evaluated.
- 2. Does the proposed change create the possibility of a new or different kind of accident from any previously evaluated?
Response: No
The proposed change relaxes the Required Actions for the ESFAS Auxiliary Feedwater Main Steam Generator Wa ter Level-Low-Low channels. The remaining Auxiliary Feedwater Main Steam Generator Water Level-Low-Low channels are required to be OPERABLE to support the associated unit's required features. This change will not physically al ter the plant (no new or different type of equipment will be installed). The proposed changes will maintain the minimum
requirements for Auxiliary Feedwater Main Steam Generator Water Level-Low-Low channels to ensure the availability of the equipment required to mitigate DETERMINATION OF NO SIGNIFICANT HAZARDS CONSIDERATIONS ITS 3.3.2, ENGINEERED SAFETY FEATURE ACTUATION SYSTEM (ESFAS) INSTRUMENTATION Sequoyah Unit 1 and 2 Page 4 of 4 accidents assumed in the UFSAR. Ther efore, operation of the facility in accordance with this proposed change will not create the possibility of a new or different kind of accident from any accident previously evaluated. 3.Does the proposed change involve a significant reduction in the margin of safety?Response: No. The proposed change relaxes the Required Actions for the ESFAS Auxiliary Feedwater Main Steam Generator Wa ter Level-Low-Low channels. The remaining Auxiliary Feedwater Main Steam Generator Water Level-Low-Low channels are required to be OPERABLE to support the associated unit's required features. The margin of safety is not affected by this change because the minimum requirements for Auxiliary F eedwater Main Steam Generator Water Level-Low-Low channels will be maintained to ensure the availability of the required Auxiliary Feedwater Main Steam Generator Water Level-Low-Low
instrumentation to shutdown the reactor and maintain it in a safe shutdown condition after an abnormal operational transient or postulated design basis
accident. Therefore, the proposed changes do not involve a significant reduction in a margin of safety.
ATTACHMENT 3 ITS 3.3.3, POST ACCIDENT MONITORING (PAM)
INSTRUMENTATION
Current Technical Specification (CTS) Markup and Discussion of Changes (DOCs)
ITS A01 ITS 3.3.3INSTRUMENTATION ACCIDENT MONITORING INSTRUMENTATION LIMITING CONDITION FOR OPERATION 3.3.3.7 The accident monitoring instrumentation channels shown in Table 3.3-10 shall be OPERABLE.
APPLICABILITY: MODES 1, 2 and 3.
ACTION: As shown in Table 3.3-10 SURVEILLANCE REQUIREMENTS 4.3.3.7 Each accident monitoring instrumentation channel shall be demonstrated OPERABLE:
a.Every 31 days by performance of a CHANNEL CHE CK, and b.Every 18 months by performance of a CHANNEL CALIBRATION.*____________
- For Containment Area Radiation Monitors, a CHANNEL CALIBRATION may consist of an electron ic calibration of the channel, not including the detector, for range decades above 10R/h and a single calibration check of the detector below 10R/h with either an installed or portable gamma source. December 07, 1990 SEQUOYAH - UNIT 1 3/4 3-55 Amendment No. 40, 112, 149 LCO 3.3.3 Applicabilit y SR 3.3.3.1 SR 3.3.3.2 Add proposed ACTIONS Note A02 SR Note ACTIONS SR 3.3.3.2 Note 2 Add proposed SR 3.3.3.2 Note 1Add proposed ACTION B L01 L02In accordance with the Surveillance Frequency Control Program LA01 Page 1 of 20 LA02 ITS ITS 3.3.3 A01 TABLE 3.3-10 ACCIDENT MONITORING INSTRUMENTATION INSTRUMENT TOTAL NO.
OF CHANNE LS MINIMUM CHANNELS REQUIRED ACTION 1.Reactor Coolant T HOT (Wide Ran ge)(Instrument Loops68-001,-024,-043,-065)4(1/RCS Loop) 4 (1/RCS Loop) 1 2.Reactor Coolant T COLD (Wide Range
)(Instrument Loops68-018,-041,-060,-083)4(1/RCS Loop) 4 (1/RCS Loop) 1 3.Containment Pressure (Wide Range
)(Instrument Loops30-310,-311)2 2 1 4.Containment Pressure (Narrow Rang e)(Instrument Loops30-044,-045)2 2 1 5.Refueling Water Storage Tank Le vel (Instrument Loops63-050,-051)2 2 1 6.Reactor Coolant Pressure (Wide Range
)(Instrument Loops68-062,-0 66,-069)3 3 2 7.Pressurizer Level (Wide Range
)(Instrument Loops68-320,-335,-339)3 3 2 8.Steam Line Pressure(Instrument Loops 1
-002A,-002B,-009A,-009B,-020A,-020B,-027A,-027B)2/steam line 2/steam line 1 9.Steam Generator Level - (Wide Ran ge)(Instrument Loops 3-043,-056,-098,-111)4(1/steam generator) 4 (1/s team generator) 1 10.Steam Generator Level - (Narrow Rang e)(Instrument Loops 3-039,-042,-052,-055,-094,-097,-107,-110) 2/steam generator 2/steam generator 1 11.Auxiliary Feedwatera.Flow Rate (Instrument Loops 3-163,-155,-147,-170)1/steam generator 1/steam generator 5 b.Valve Position Indication(Instrument Loops 3
-164,-164A,-172,-156, -156A,-173,-148,-148A,-174,-171,-171A,-175) 3/steam generator 3/steam generator 5 July 9, 1992 SEQUOYAH - UNIT 1 3/4 3-56 Amendment No. 46, 114, 149, 159 1 Table 3.3.3-1 2 3 4 5 6 7 8 9 11 10 ITS ACTION A, B, C, and H A, B, C, and H A, B, C, and H A, B, C, and H A, B, C, and H A, B, C, and H A, B, C, and H A, B, C, and H A, B, C, D, and H A, B, C, D, and H A, B, E, and H A, B, E, and H LA03 LA04 LA04 Page 2 of 20 LA05 1 A03 ITS ITS 3.3.3 A01 TABLE 3.3-10 (Continued) ACCIDENT MONITORING INSTRUMENTATION INSTRUMENT TOTAL NO OF CHANNELS MINIMUM CHANNELS REQUIRED ACTION 12.Reactor Cool ant System Subcooling Margi n Monit or (Instrument Loops 94
-101,-102) 2 2 1 13.Containment Water Level (Wide Ran ge)(Instrument Loops63-178,-179)2 2 1 14.Incore Thermocouples 65 a.Core Quadrant (1
)2 (1/Train) 1 b.Core Quadrant (2
)2 (1/Train) 1 c.Core Quadrant (3
)2 (1/Train) 1 d.Core Quadrant (4
)2 (1/Train) 1 15.Reactor Ve ssel Level Instrumentation 6 a.Dynamic Range (Instrument Loop s68-367, 370)2 1 b.Lower Range (Instrument Loops 68
-368, 371)2 1 c.Upper Range (Instrument Loops 68
-369, 372)2 1 16.Containment Area Radiatio n Monitorsa.Upper Compartment (Ins trumentLoops90-271,-272)2 1 4 b.Lower Compartment (Ins trumentLoops90-273,-274)2 1 4 October 4, 1995 SEQUOYAH - UNIT 1 3/4 3-56a Amendment No. 112, 149, 159, 213 12 13 14 15 16 A, B, C, and H A, B, C, and H A, B, C, and H A, B, C, and H A, B, C, and H A, B, C, and H A, B, C, and H A, B, C, and H A, B, C, and H LA03Table 3.3.3-1 ITS ACTIONF and I F and I Page 3 of 20 LA05(c) Add proposed Table 3.3.3-1 Footnote (c)
A04 LA04 A04 ITS ITS 3.3.3 A01 TABLE 3.3-10 (Continued) ACCIDENT MONITORING INSTRUMENTATION INSTRUMENT TOTAL NO. OF CHANNELS MINIMUM CHANNELS REQUIRED ACTION 17.Neutron Flux a.Source Rang e (Instrument Loops 92
-5001,-5002) 2 2#1 b.Intermediate Range (Instrument Loops 92
-5003,-5004) 2 2 1 18.ERCW to AFW Valve Posi tion a.Motor Driven Pumps (Instrument Loops 3
-116A, -116B, -126A, -126B) 1/Train/Pump (2 Valves/Train) 1/Train/Pump (2 Valves/Train) 1 b.Turbine Driven Pumps (Instrument Loops 3
-136A, -136B, -179A, -179B) 2 Trains (2 Valves/Train) 2 Trains (2 Valves/Train) 1 19.Contai nment IsolationValve Posi tion (Panels T R-A XX-55-6K& TR-B XX-55-6L)1/Valve 1/Valve## 3 _____________ #Source Range outputs may be disabled above the P-6 (Block of Source Range Reactor Trip) setpoint. ##Not required for isolation valves that are closed and deactivated.
July 9, 1992 SEQUOYAH - UNIT 1 3/4 3-56b Amendment No. 112, 149, 159 Table 3.3.3-1 Footnote (a) Table 3.3.3-1
Footnote (d) whose associated penetration is isolated b y at least one automatic valve, closed manual valve, blind flange, or check valve with flow through the
v a lv e secu r ed.L03(b) Only one position indication channel is required for penetration flow paths with only one installed control room indication channel. 2 per penetration flow path A06 17 18 19 A, B, C, and H A, B, C, and H A, B, C, and H A, B, C, and H A, C, and H LA03Table 3.3.3-1 ITS ACTION Page 4 of 20 (b)A06 A06 LA05 2 A05 2 LA04 ITS ITS 3.3.3 A01 TABLE 3.3-10 (Continued) ACTION STATEMENTS ACTION 1 -
NOTE: Also refer to the applicable action requirements from Tables 3.3-1 and 3.3-3, and LCO 3.3.3.5 since they may contain more restrictive actions.
a.With the number of channels one less than the minimum channels require d, restore the inoperable channel to OPERABLE status within 30 days or be in at least HOT STANDBY within the next 6 hours6.944444e-5 days <br />0.00167 hours <br />9.920635e-6 weeks <br />2.283e-6 months <br />, and in HOT SHUT DOWN within the next 6 hours6.944444e-5 days <br />0.00167 hours <br />9.920635e-6 weeks <br />2.283e-6 months <br />.
b.With the number of channels two less than the minimum channels require d, restore at least one inoperable channel to OPERABLE status within 7 days, or be in HOT STANDBY within the next 6 hours6.944444e-5 days <br />0.00167 hours <br />9.920635e-6 weeks <br />2.283e-6 months <br /> and in HOT SHUTDOWN within the next 6 hours6.944444e-5 days <br />0.00167 hours <br />9.920635e-6 weeks <br />2.283e-6 months <br />.
ACTION 2 - NOTE: Also refer to the applicable action requirements from Tables 3.3
-1 since it may contain more restrictive actions.
a.With the number of channels one less than the minimum channels require d, restore the inoperable channel to OPERABLE status within 30 days or be in atleast HOT STANDBY within the next 6 hours6.944444e-5 days <br />0.00167 hours <br />9.920635e-6 weeks <br />2.283e-6 months <br /> and in HOT SHUTDOWN within the next 6 hours6.944444e-5 days <br />0.00167 hours <br />9.920635e-6 weeks <br />2.283e-6 months <br />.
b.With the number of channels two less than the minimum channels require d, restore at least one inoperable channel to OPERABLE status within 7 days or be in at least HOT STANDBY within the next 6 hours6.944444e-5 days <br />0.00167 hours <br />9.920635e-6 weeks <br />2.283e-6 months <br /> and in HOT SHUTDOWN within the next 6 hours6.944444e-5 days <br />0.00167 hours <br />9.920635e-6 weeks <br />2.283e-6 months <br />.
c.With the number of channels three less than the minimum channels req uired, restore one channel to OPERABLE status within 48 hours5.555556e-4 days <br />0.0133 hours <br />7.936508e-5 weeks <br />1.8264e-5 months <br /> or be in at least HOT STANDBY within the next 6 hours6.944444e-5 days <br />0.00167 hours <br />9.920635e-6 weeks <br />2.283e-6 months <br /> and in HOT SHUTDOWN within the next 6 hours6.944444e-5 days <br />0.00167 hours <br />9.920635e-6 weeks <br />2.283e-6 months <br />.
ACTION 3 - NOTE: Also refer to the applicable action requirements from LCO 3.6.3 since it may contain more restrictive actions.
- a. With the accident monitoring indication for one of the penetration inboard or outboard valve (s) inoperable, restore the inoperable valve(s) accident indication to OPERABLE status within 30 days, or isolate each affected penetration within 30 days by use of at least one deactivated automatic valve secured in the isolated position, or isolate each April 11, 2005 SEQUOYAH - UNIT 1 3/4 3-57 Amendment No. 46, 149, 159, 301 ACTION A ACTION A ACTION C ACTION C ACTION H ACTION B ACTION H ACTION B ACTION H ACTION A Initiate action in accordance with Specification 5.6.5 L01Initiate action in accordance with Specification 5.6.5 L01 A07 A07 A07 ACTION D A06 Page 5 of 20 Table 3.3.3-1 Footnote (a)
ITS ITS 3.3.3 A01 TABLE 3.3-10 (Continued) ACTION STATEMENTS (Continued) affected penetration within 30 days by use of at least one closed manual valve or blind flange, or be in at least HOT STANDBY within the next 6 hours6.944444e-5 days <br />0.00167 hours <br />9.920635e-6 weeks <br />2.283e-6 months <br /> and HOT SHUTDOWN within the next 6 hours6.944444e-5 days <br />0.00167 hours <br />9.920635e-6 weeks <br />2.283e-6 months <br />. ### b. With the accident monitoring indication for both an inboard and outboard valve (s) on the same penetration inoperable, restore at least the inboard or outboard inoperable valve(s) indication to OPERABLE status within 7 days, or isolate each affected penetration within 7 days by use of at least one deactivated automatic valve secured in the isolated position, or isolate each affected penetration within 7 days by use of at least one closed manual valve or blind flange, or be in at least HOT STANDBY within the next 6 hours6.944444e-5 days <br />0.00167 hours <br />9.920635e-6 weeks <br />2.283e-6 months <br /> and HOT SHUTDOWN within the next 6 hours6.944444e-5 days <br />0.00167 hours <br />9.920635e-6 weeks <br />2.283e-6 months <br />. ### On a penetration where accident indication is declared INOPERABLE on a valve but on the opposite side of the penetration an accident indication valve does not exist (such as with a closed system or a check valve), only ACTION 3(a) must be entered.
However, valves FCV 158 & -172 are both inboard penetration valves, but if both valves have inoperable accident indication, ACTION 3(b) must be entered until at least one of the valve's accident indication is restored to OPERABLE status. Valves FCV 46 & VLV-30-571, FCV-30-47 & VLV-30-572, and FCV 48 & VLV-30-573 are all outboard penetration valves, but if both valves have inoperable accident indication, ACTION 3(b) must be entered until at least one of the valve's accident indication is restored to OPERABLE status.
April 11, 2005 SEQUOYAH - UNIT 1 3/4 3-57a Amendment No. 159, 301 ACTION H ACTION C Table 3.3.3-1 Footnote (b)
ACTION B two A06 Page 6 of 20 LA06Table 3.3.3-1 Footnote (a) Table 3.3.3-1 Footnote (a)
A06Initiate action in accordance with Specification 5.6.5 L01 ITS ITS 3.3.3 A01 TABLE 3.3-10 (Continued) ACTION STATEMENTS (Continued) ACTION 4 - With the number of channels less than the minimum channels required, initiate an alternate method of monitoring containment area radiation within 72 hours8.333333e-4 days <br />0.02 hours <br />1.190476e-4 weeks <br />2.7396e-5 months <br /> and either restore the inoperable channel(s) to OPERABLE status within 30 days, or prepare and submit a special report to the Commission pursuant to Specification 6.9.2.1 within the next 14 days that provides actions taken, cause of the inoperability, and plans and schedule for restoring the channels to OPERABLE s tatus. ACTION 5 - NOTE: Also refer to the applicable action requirements from LCO 3.3.3.5 since it may contain more restrictive actions.
a.With the number of channels on one or more steam generators le ss than the minimum channels required for either flow rate or valve position, restore th e inoperable channel to OPERABLE status within 30 days or be in at least HOTSTANDBY within the next 6 hours6.944444e-5 days <br />0.00167 hours <br />9.920635e-6 weeks <br />2.283e-6 months <br /> and in HOT SHUTDOWN within the next 6 hours6.944444e-5 days <br />0.00167 hours <br />9.920635e-6 weeks <br />2.283e-6 months <br />. b.With the number of channels on one or more steam generators le ss than the minimum channels required for flow rate and valve position, restore the inoperable channel(s) to OPERABLE status within 7 days or be in at least HOT STANDBY within the next 6 hours6.944444e-5 days <br />0.00167 hours <br />9.920635e-6 weeks <br />2.283e-6 months <br /> and in HOT SHUTDOWN within the next 6 hours6.944444e-5 days <br />0.00167 hours <br />9.920635e-6 weeks <br />2.283e-6 months <br />.
April 11, 200 5 SEQUOYAH - UNIT 1 3/4 3-57b Amendment No. 112, 149, 159, 301 ACTION H ACTION B ACTION I ACTION F ACTION A ACTION E See ITS 5.6.5 Initiate action in accordance with Specification 5.6.5 L01 A07 Page 7 of 20 ITS ITS 3.3.3 A01 INSTRUMENTATION FIRE DETECTION INSTRUMENTATION LIMITING CONDITION FOR OPERATION 3.3.3.8 This Specification is deleted. August 12, 1997 SEQUOYAH - UNIT 1 3/4 3-58 Amendment No. 36, 227 Page 8 of 20 ITS ITS 3.3.3 A01 TABLE 3.3-11 FIRE DETECTION INSTRUMENTS This Table is deleted. (Pages 3/4 3-59 through 3/4 3-69 deleted) August 12, 1997 SEQUOYAH - UNIT 1 3/4 3-59 Amendment No. 12, 37, 97, 109, 142, 148, 181, 227 Page 9 of 20 ITS ITS 3.3.3 A01INSTRUMENTATION DELETED LIMITING CONDITION FOR OPERATION 3.3.3.9 This Specification is deleted. The Tables 3.3-12 and 4.3-8 are also deleted. November 16, 1990 SEQUOYAH - UNIT 1 3/4 3-70 Amendment Nos. 13, 42, 57, 81, 114, 125, 148 Page 10 of 20 ITS A01 ITS 3.3.3INSTRUMENTATION ACCIDENT MONITORING INSTRUMENTATION LIMITING CONDITION FOR OPERATION 3.3.3.7 The accident monitoring instrumentation channels shown in Table 3.3-10 shall be OPERABLE.
APPLICABILITY: MODES 1, 2 and 3.
ACTION: As shown in Table 3.3-10 SURVEILLANCE REQUIREMENTS 4.3.3.7 Each accident monitoring instrumentation channel shall be demonstrated OPERABLE:
- a. Every 31 days by performance of a CHANNEL CHE CK, and b. Every 18 months by performance of a CHANNEL CALIBRATION.*
- For Containment Area Radiation Monitors, a CHANNEL CALIBRATION may consist of an electroni c calibration of the channel, not including the detector, for range decades above 10R/h and a si nglepoint calibration of the detector below 10R/h with either an installed or portable gamma source
.December 7, 1990 SEQUOYAH - UNIT 2 3/4 3-56 Amendment No. 32, 102, 135 LCO 3.3.3 Applicabilit y ACTIONS SR Note SR 3.3.3.1 SR 3.3.3.2 Add proposed ACTIONS Note A02Add proposed ACTION B L01Add proposed SR 3.3.3.2 Note 1 L02In accordance with the Surveillance Frequency Control Program LA01SR 3.3.3.2 Note 2 Page 11 of 20 LA02 ITS A01 ITS 3.3.3 TABLE 3.3-10 ACCIDENT MONITORING INSTRUMENTATION INSTRUMENT TOTAL NO.
OF CHANNELS MINIMUM CHANNELS REQUIRED A CTION 1.Reactor Coolant T HOT (Wide Ran ge)(Instrument Loops 68
-001,-024,-043,-065)4(1/RCS Loop) 4 (1/RCS Loop) 12.Reactor Coolant T COLD (Wide Range
)(Instrument Loops 68
-018,-041,-060,-083)4(1/RCS Loop) 4 (1/RCS Loop) 1 3.Containment Pressure (Wide Range
)(Instrument Loo p s30-310,-311)2 2 1 4.Containment Pressure (Narrow Rang e)(Instrument Loops30-044,-045)2 2 1 5.Refueling Water Storage Tank Le vel (Instrument Loops 63
-050,-051)2 2 1 6.Reactor Coolant Pressure (Wide Range
)(Instrument Loo p s68-062,-066,-069)3 3 2 7.Pressurizer Level (Wide Range
)(Instrument Loops 68
-320,-335,-339)3 3 2 8.Steam Line Pressu re (Instrument Loops 1-002A,-002B,-009A,-009B,-020A,-020B,-027A,-027B)2/steam line2/steam line 1 9.Steam Generator Level - (Wide Ran ge)(Instrument Loops 3
-043,-056,-098,-111)4(1/steam generator)4(1/steam generator) 1 10.Steam Generator Level - (Narrow Rang e)(Instrument Loops 3-039,-042,-052,-055,-094, -097,-107,-110) 2/steam generator 2/steam generator 1 11.A uxiliar y Feedwater a.Flow Rate (Instrument Loops 3
-163,-155, -147,-170)1/steam generator 1/steam generator 5 b.Valve Position Indication(Instrument Loops 3
-164,-164A,-172,-156,-156A,-173,-148,-148A,-174,-171,-171A,-175)3/steam generator 3/steam generator 5 July 9, 1992 SEQUOYAH - UNIT 2 3/4 3-57 Amendment Nos. 38, 104, 135, 149 Page 12 of 20Table 3.3.3-1 ITS ACTION LA03 LA04 LA04 1 11 2 3 4 5 6 7 8 9 10 A, B, C, and H A, B, C, and H A, B, C, and H A, B, C, and H A, B, C, and H A, B, C, and H A, B, C, and H A, B, C, and H A, B, C, D, and H A, B, C, D, and H A, B, E, and H A, B, E, and H LA05 1 A03 ITS A01 ITS 3.3.3 TABLE 3.3-10 (Continued) ACCIDENT MONITORING INSTRUMENTATION INSTRUMENT TOTAL NO. OF CHANNELS MINIMUM CHANNELS REQUIRED ACTION 12.Reactor Coolant System Subcooling Ma rgin Monitor (Instrument Loops 94
-101,-102)2 2 1 13.Containment Water Level (Wide Ran ge)(Instrument Loo p s63-178,-179)2 2 1 14.Incore Thermocouples 65 a.Core Quadrant (1
)2 (1/Train)1 b.Core Quadrant (2
)2 (1/Train)1 c.Core Quadrant (3
)2 (1/Train)1 d.Core Quadrant (4
)2 (1/Train)1 15.Reactor Ve ssel Level Instrumentation S y st em 6 a.Dynamic Range (Instrument Loops 68
- 367, 370)2 1 b.Lower Range (Instrument Loops 68
-368, 371)2 1 c.Upper Ran ge (Instrument Loops 68
-369, 372)2 1 16.Containment Area Radiation Monitors a.Upper Comp artment (Instrument Loops 90
-271,-272)2 1 4 b.Lower Comp artment (Instrument Loops 90
-273,-274)2 1 4 October 4, 1995 SEQUOYAH - UNIT 2 3/4 3-57a Amendment No. 102, 135, 149, 203 Page 13 of 20 LA03Table 3.3.3-1 ITS ACTION 12 13 14 15 16 A, B, C, and H A, B, C, and H A, B, C, and H A, B, C, and H A, B, C, and H A, B, C, and H A, B, C, and H A, B, C, and H A, B, C, and HF and I F and I (c) A04 LA04 LA05Add proposed Table 3.3.3-1 Footnote (c)
A04 ITS A01 ITS 3.3.3 TABLE 3.3-10 (Continued) ACCIDENT MONITORING INSTRUMENTATION INSTRUMENT TOTAL NO. OF CHANNELS MINIMUM CHANNELS REQUIRED ACTION 17.Neutron Flu x a.Source Rang e (Instrument Loo p s 92-5001,-5002)2 2# 1 b.Intermediate Ran ge (Instrument Loops 92
-5003,-5004)2 2 1 18.ERCW to AFW Valve Posi tion a)Motor Driven Pumps(Instrument Loops 3
-116A, -116B, -126A, -126B) 1/Train/Pump (2 Valves/Train) 1/Train/Pump (2 Valves/Train) 1 b)Turbine Driven Pumps(Instrument Loops 3
-136A, -136B, -179A, -179B) 2 Trains (2 Valves/Train) 2 Trains (2 Valves/Train) 1 19.Containment Isolation Valv e Position (Panel s TR-A XX-55-6K& TR-B XX-55-6L)1/Valve 1/Valve##3 # Source Range outputs may be disabled above the P-6 (Block of Source Range Reactor Trip) setpoint. ## Not required for isolation valves that are closed and deactivated. July 9, 1992 SEQUOYAH - UNIT 2 3/4 3-57b Amendment Nos. 102, 135, 149 Page 14 of 20 LA03Table 3.3.3-1 ITS ACTION 17 18 19 Table 3.3.3-1 Footnote (d) Table 3.3.3-1
Footnote (a) (b) A062 per penetration flow path A06whose associated penetration is isolated b y at least one automatic valve, closed manual valve, blind flange, or check valve with flow through the
v a lv e secu r ed.L03(b) Only one position indication channel is required for penetration flow paths with only one installed control room indication channel.
A06 A, B, C, and H A, B, C, and H A, B, C, and H A, B, C, and H A, C, and H LA05 2 A05 2 LA04 ITS A01 ITS 3.3.3 TABLE 3.3-10 (Continued) ACTION STATEMENTS ACTION 1 -
NOTE: Also refer to the applicable action requirements from Tables 3.3
-1 and 3.3-3, and LCO 3.3.3.5 since they may contain more restrictive actions. a.With the number of channels one less than the minimum channels require d, restore the inoperable channel to OPERABLE status within 30 days or be in atleast HOT STANDBY within the next 6 hours6.944444e-5 days <br />0.00167 hours <br />9.920635e-6 weeks <br />2.283e-6 months <br /> and in HOT SHUTDOWN within th e next 6 hours6.944444e-5 days <br />0.00167 hours <br />9.920635e-6 weeks <br />2.283e-6 months <br />. b.With the number of channels two less than the minimum channels require d, restore at least one inoperable channel to OPERABLE status within 7 days or bein HOT STANDBY within the next 6 hours6.944444e-5 days <br />0.00167 hours <br />9.920635e-6 weeks <br />2.283e-6 months <br /> and in HOT SHUTDO WN within the next 6 hours6.944444e-5 days <br />0.00167 hours <br />9.920635e-6 weeks <br />2.283e-6 months <br />.
ACTION 2 - NOTE: Also refer to the applicable action requirements from Tables 3.3
-1 since it may contain more restrictive actions.
a.With the number of channels one less than the minimum channels require d, restore the inoperable channel to OPERABLE status within 30 days or be in atleast HOT STANDBY within the next 6 hours6.944444e-5 days <br />0.00167 hours <br />9.920635e-6 weeks <br />2.283e-6 months <br /> and in HOT SHUTDOWN within th e next 6 hours6.944444e-5 days <br />0.00167 hours <br />9.920635e-6 weeks <br />2.283e-6 months <br />. b.With the number of channels two less than the minimum channels require d, restore at least one inoperable channel to OPERABLE status within 7 days or bein at least HOT STANDBY within the next 6 hours6.944444e-5 days <br />0.00167 hours <br />9.920635e-6 weeks <br />2.283e-6 months <br /> and in HOT SHUTDO WN within the nex t 6 hours6.944444e-5 days <br />0.00167 hours <br />9.920635e-6 weeks <br />2.283e-6 months <br />.
c.With the number of channels three less than the minimum channels req uired, restore one channel to OPERABLE status within 48 hours5.555556e-4 days <br />0.0133 hours <br />7.936508e-5 weeks <br />1.8264e-5 months <br /> or be in at least HO T STANDBY within the next 6 hours6.944444e-5 days <br />0.00167 hours <br />9.920635e-6 weeks <br />2.283e-6 months <br /> and in HOT SHUTDOWN within the next 6 hours6.944444e-5 days <br />0.00167 hours <br />9.920635e-6 weeks <br />2.283e-6 months <br />.ACTION 3 - NOTE: Also refer to the applicable action requirements from LCO 3.6.3 since it may contain more restrictive actions.
- a.With the accident monitoring indication for one of the penetration inboard oroutboard valve (s) inoperable, restore the inoperable valve(s) accident indicationto OPERABLE status within 30 days, or isolate each affected pene tration within 30 days by use of at least one deactivated automatic valve secure d in the isolated position, or isol ate each April 11, 200 5 SEQUOYAH - UNIT 2 3/4 3-58 Amendment Nos. 38, 135, 149, 290 Page 15 of 20 ACTION A ACTION B ACTION C ACTION H ACTION A ACTION B ACTION C ACTION H ACTION D ACTION H ACTION A A07 A07 A07 A06Initiate action in accordance with Specification 5.6.5 L01Initiate action in accordance with Specification 5.6.5 L01Table 3.3.3-1 Footnote (a)
ITS A01 ITS 3.3.3 TABLE 3.3-10 (Continued) ACTION STATEMENTS (Continued) affected penetration within 30 days by use of at least one closed manual valve or blind flange, or be in at least HOT STANDBY within the next 6 hours6.944444e-5 days <br />0.00167 hours <br />9.920635e-6 weeks <br />2.283e-6 months <br /> and HOT SHUTDOWN within the next 6 hours6.944444e-5 days <br />0.00167 hours <br />9.920635e-6 weeks <br />2.283e-6 months <br />. ### b. With the accident monitoring indication for both an inboard and outboard valve (s) on the same penetration inoperable, restore at least the inboard or outboard inoperable valve(s) indication to OPERABLE status within 7 days, or isolate each affected penetration within 7 days by use of at least one deactivated automatic valve secured in the isolated position, or isolate each affected penetration within 7 days by use of at least one closed manual valve or blind flange, or be in at least HOT STANDBY within the next 6 hours6.944444e-5 days <br />0.00167 hours <br />9.920635e-6 weeks <br />2.283e-6 months <br /> and HOT SHUTDOWN within the
next 6 hours6.944444e-5 days <br />0.00167 hours <br />9.920635e-6 weeks <br />2.283e-6 months <br />.
- On a penetration where accident indication is declared INOPERABLE on a valve but on the opposite side of the penetration an accident indication valve does not exist (such as with a closed system or a check valve), only ACTION 3(a) must be entered. However, valves FCV 158 & -172 are both inboard penetration valves, but if both valves have inoperable accident indication, ACTION 3(b) must be entered until at least one of the valve's accident indication is restored to OPERABLE status. Valves FCV 46 & VLV-30-571, FCV-30-47 & VLV-30-572, and FCV 48 & VLV-30-573 are all outboard penetration valves, but if both valves have inoperable accident indication, ACTION 3(b) must be entered until at least one of the valve's accident indication is restored to OPERABLE status.
April 11, 2005 SEQUOYAH - UNIT 2 3/4 3-58a Amendment No. 149, 290 Page 16 of 20 ACTION B ACTION C ACTION H LA06two A06Table 3.3.3-1 Footnote (a) Table 3.3.3-1 Footnote (a) Table 3.3.3-1 Footnote (b)
A06Initiate action in accordance with Specification 5.6.5 L01 ITS A01 ITS 3.3.3 TABLE 3.3-10 (Continued) ACTION STATEMENTS (Continued) ACTION 4 - With the number of channels less than the minimum channels required, initiate an alternate method of monitoring containment area radiation within 72 hours8.333333e-4 days <br />0.02 hours <br />1.190476e-4 weeks <br />2.7396e-5 months <br /> and either restore the inoperable channel(s) to OPERABLE status within 30 days, or prepare and submit a special report to the Commission pursuant to Specification 6.9.2.1 within 14 days that provides actions taken, cause of the inoperability, and plans and schedule for restoring the channels to OPERABLE status. ACTION 5 - NOTE: Also refer to the applicable action requirements from LCO 3.3.3.5 since it may contain more restrictive actions.
a.With the number of channels on one or more steam generators le ss than the minimum channels required for either flow rate or valve position, restore th e inoperable channel to OPERABLE status within 30 days or be in at least HOTSTANDBY within the next 6 hours6.944444e-5 days <br />0.00167 hours <br />9.920635e-6 weeks <br />2.283e-6 months <br /> and in HOT SHUTDOWN within the next 6 hours6.944444e-5 days <br />0.00167 hours <br />9.920635e-6 weeks <br />2.283e-6 months <br />. b.With the number of channels on one or more steam generators le ss than the minimum channels required for flow rate and valve position, restore the inoperable channel(s) to OPERABLE status within 7 days or be in at least HO T STANDBY within the next 6 hours6.944444e-5 days <br />0.00167 hours <br />9.920635e-6 weeks <br />2.283e-6 months <br /> and in HOT SHUTDOWN within the next 6 hours6.944444e-5 days <br />0.00167 hours <br />9.920635e-6 weeks <br />2.283e-6 months <br />.April 11, 200 5 SEQUOYAH - UNIT 2 3/4 3-58b Amendment Nos. 102, 135, 149, 290 Page 17 of 20 ACTION F ACTION I ACTION A ACTION B ACTION E ACTION H Initiate action in accordance with Specification 5.6.5 L01 A07 See ITS 5.6.5 ITS A01 ITS 3.3.3INSTRUMENTATION FIRE DETECTION INSTRUMENTATION LIMITING CONDITION FOR OPERATION 3.3.3.8 This Specification is deleted. August 12, 1997 SEQUOYAH - UNIT 2 3/4 3-59 Amendment No. 28, 218 Page 18 of 20 ITS A01 ITS 3.3.3 TABLE 3.3-11 FIRE DETECTION INSTRUMENTS This Table is deleted. (Pages 3/4 3-60 through 3/4 3-67a) August 12, 1997 SEQUOYAH - UNIT 2 3/4 3-60 Amendment No. 32, 86, 137, 173, 218 Page 19 of 20 ITS A01 ITS 3.3.3INSTRUMENTATION DELETED LIMITING CONDITION FOR OPERATION 3.3.3.9 This Specification is deleted. The Tables 3.3-12 and 4.3-8 are also deleted. November 16, 1990 SEQUOYAH - UNIT 2 3/4 3-68 Amendment Nos. 4, 34, 49, 72, 114, 134 Page 20 of 20 DISCUSSION OF CHANGES ITS 3.3.3, POST ACCIDENT MONITORING (PAM) INSTRUMENTATION Sequoyah Unit 1 and Unit 2 Page 1 of 10 ADMINISTRATIVE CHANGES A01 In the conversion of the Sequoyah Nuclear Plant (SQN) Current Technical Specifications (CTS) to the plant specific Improved Technical Specifications (ITS), certain changes (wording preferences, editorial changes, reformatting, revised numbering, etc.) are made to obtain consistency with NUREG-1431, Rev. 4.0, "Standard Technical Specifications-Westinghouse Plants" (ISTS) and additional Technical Specification Task Force (TSTF) travelers included in this
submittal. These changes are designated as administrative changes and are acceptable because they do not result in technical changes to the CTS. A02 CTS 3.3.3.7 ACTIONS, as shown in CTS Table 3.3-10, provide the compensatory actions to take when PAM instrumentation is inoperable. ITS 3.3.3 ACTIONS provide the compensatory actions for inoperable PAM Instrumentation. The ITS 3.3.3 ACTIONS include a Note that allows separate Condition entry for each Function. In addition, separate Condition entry is allowed within a Function on a "per" bases as listed for Functions 8 (Steam Line
Pressure (per steam line)), 10 (Steam Generator Level (Narrow Range) (per steam generator)) 11 (Auxiliary Feedwater (per steam generator)), and 19 (Containment Isolation Valve Position (per penetration flowpath)). This modifies the CTS by providing a specific allowance to enter the Action for each inoperable PAM instrumentation Function and for certain Functions on a "per" steam line, steam generator, or penetration flowpath basis. This change is acceptable because it clearly states the current requirement. The CTS considers each PAM instrumentation Function to be separate and independent from the others. In addition, the channels associated with Functions 8, 10, 11, and 19 are allowed separate Condition entry on a steam line, steam generator, or penetration flowpath basis, which is consistent with the intent of the CTS. This change is designated as administrative because it does not result in technical changes to the CTS. A03 CTS Table 3.3-10 Instrument 11.b (Auxiliary Feedwater (Valve Position Indication)) "Minimum Channels Required" column states that the minimum channels required is 3/steam generator. ITS Table 3.3.3-1 Function 11.b (Auxiliary Feedwater (Valve Position Indication)) "Required Channels" column requires one channel per steam generator (consisting of 3 valve position indications). This changes the CTS by simplifying the presentation of the requirements for Auxiliary Feedwater (Valve Position Indication) instrumentation
by requiring one channel per steam generator. The purpose of CTS Table 3.3-10 "Minimum Channels Required" column is to list the number of channels required to be OPERABLE for the associated instrument per steam generator. CTS Table 3.3-10 "Minimum Required Channels" column lists "3/steam generator" as the minimum required channels for Instrument 11.b (Auxiliary Feedwater (Valve Position Indication)). At SQN a channel consists of
three valves per steam generator, two from the motor driven auxiliary feedwater pump and one from the turbine driven auxilia ry feedwater pump. Therefore, to fulfill the "Minimum Required Channels" requirement for Instrument 11.b DISCUSSION OF CHANGES ITS 3.3.3, POST ACCIDENT MONITORING (PAM) INSTRUMENTATION Sequoyah Unit 1 and Unit 2 Page 2 of 10 requiring one channel per steam generator, all three valves position indication must be OPERABLE. This change is acceptable because the requirements contained in ITS are the same as in CTS when a required auxiliary feedwater valve position indicator is inoperable. This change is designated as administrative because it does not result in technical changes to the CTS. A04 CTS Table 3.3-10 Instrument 14 (Incore Thermocouples) "Minimum Channels Required" column states, in part, that the minimum channels required is 2 (1 per train) in each of the four core quadrants. ITS Table 3.3.3-1 Function 14 (Incore Thermocouples) "Required Channel" column also requires two channels in each of the four core quadrants and is modified by Footnote (c). ITS Table 3.3.3-1 Footnote (c) states, "A channel consists of one incore thermocouple. The required channels in each quadrant shall be in different trains." This changes the CTS by explicitly stating the number of incore thermocouples included in a channel. The purpose of CTS Table 3.3-10 "Minimum Channels Required" column is to list the number of channels required to be OPERABLE for the associated instrument.
CTS Table 3.3-10 "Minimum Required Channels" column lists "2(1/train)" as the minimum required channels for Instrument 14 (Incore Thermocouples) in each core quadrant. At SQN a channel consists of one incore thermocouple, therefore to fulfill the "Minimum Required Channels" requirement for Instrument 14 requires two incore thermocouples in each core quadrant, one from each train, to be OPERABLE. ITS Table 3.3.3-1 "Required Channel" column for Function 14 (Incore Thermocouples) requires two channels to be OPERABLE in each of the four core quadrants and is modified by Footnote (c). ITS Table 3.3.3-1 Footnote (c) states that a channel consists of one incore thermocouple from different trains. The addition of Footnote (c) explicitly states the channel requirement of CTS. This change is designated as administrative because it does not result in technical changes to the CTS. A05 CTS Table 3.3-10 Instrument 18.a (ERCW to AFW Valve Position (Motor Driven Pumps)), "Minimum Channels Required" column states, in part, that the minimum channels required are 1/Train/Pump (2 Valves/Train). ITS Table 3.3.3-1 Function 18.a (ERCW to AFW Valve Position (Motor Driv en Pumps)), "Required Channel" column requires 2 channels. CTS Table 3.3-10 Instrument 18.b (ERCW to AFW Valve Position (Turbine Driven Pump)), "Minimum Channels Required" column states that the minimum channels required are 2 Trains (2 Valves/Train). ITS Table 3.3.3-1 Function 18.b (ERCW to AFW Valve Position (Turbine Driven Pump)), "Required Channel" column requires 2 channels. This changes the CTS by simplifying the presentation of the channel requirements for ERCW to AFW Valve Position for the Motor Driven Pumps and the Turbine Driven Pump. The purpose of CTS Table 3.3-10 "Minimum Channels Required" column is to designate the number of channels required to be OPERABLE for the associated instrument. CTS Table 3.3-10 "Minimum Required Channels" column lists "1/Train/Pump (2 Valves/Train)" as the minimum required channels for Instrument 18.a (ERCW to AFW Valve Position (Motor Driven Pumps,)). At SQN
there are two motor driven auxiliary feedwater pumps. Each motor driven pump has two valves in series between the AFW pump and the ERCW supply. CTS Table 3.3-10 lists them as 3-116A and 3-116B, which are in the ERCW supply DISCUSSION OF CHANGES ITS 3.3.3, POST ACCIDENT MONITORING (PAM) INSTRUMENTATION Sequoyah Unit 1 and Unit 2 Page 3 of 10 line to the 1A-A AFW Pump, and 3-126A and 3-126B, which are in the ERCW supply line to the 1B-B AFW pump. The ITS Bases defines a channel as consisting of these two valves in series in the ERCW to AFW flow path for each motor driven pump, therefore 2 channels are required. CTS Table 3.3-10 "Minimum Required Channels" column lists "2 Trains (2 Valves/Train)" as the minimum required channels for Instrument 18.b (ERCW to AFW Valve Position (Turbine Driven Pump,)). At SQN there is one turbine driven auxiliary feedwater pump. The turbine driven pump has two supply lines from ERCW, one from each train with two valves in series between the AFW pump and the ERCW supply.
CTS Table 3.3-10 lists them as 3-136A and 3-136B, which are in the ERCW supply line from the 1A ERCW header to the turbine driven AFW Pump, and 3-179A and 3-179B, which are in the ERCW supply line from the 1B ERCW header to the turbine driven AFW pump. The ITS Bases defines a channel as two valves in series for each ERCW supply line to the turbine driven AFW pump, therefore 2 channels are required. This change is acceptable because the requirements contained in ITS are the same as in CTS when an ERCW to AFW Valve Position channel is inoperable. This change is designated as administrative because it does not result in technical changes to the CTS. A06 CTS Table 3.3-10 Instrument 19 (Containment Isolation Valve Position) "Minimum Channels Required" column requires one valve position indication channel OPERABLE per valve and lists ACTION 3 as the ACTION to follow if one channel per valve is inoperable. CTS Table 3.3-10 ACTION 3.a provides the required ACTIONS for one of the penetration inboard or outboard valve(s) inoperable (i.e., one channel inoperable per penetration) one part of which is restoring the inoperable valve(s) accident indication to OPERABLE status within 30 days. CTS Table 3.3-10 ACTION 3.b provides the required ACTIONS for both an inboard and outboard valve(s) on the same penetration inoperable (i.e., two channels inoperable per penetration) one part of which is restoring at least the inboard or outboard inoperable valve(s) indication to OPERABLE status within 7 days. ITS LCO 3.3.3 ACTION A, applicable to Function 19 (Containment Isolation Valve Position), states that with one or more Functions with one required channel inoperable restore required channel to OPERABLE status within 30 days. ITS LCO 3.3.3 ACTION C, applicable to Function 19 (Containment Isolation Valve Position), states that with one or more Functions with two required channels inoperable to restore one channel to OPERABLE status within 7 days. CTS Table 3.3-10 Note ### states, in part, that on a penetration where accident indication is declared inoperable on a valve but on the opposite side of the penetration an accident indication valve does not exist (such as with a closed system or a check valve), only ACTION 3(a) must be entered. ITS Table 3.3.3-1 Function 19 (Containment Isolation Valve Position)
"Required Channels" column requires two channels to be OPERABLE per penetration and is modified by Footnote (b) which states that only one position indication channel is required for penetration flow paths with only one installed control room indication channel. CTS Table 3.3-10 ACTION 3.a references an inboard or outboard valve. CTS Table 3.3-10 ACTION 3.b references both an inboard and outboard valve(s). CTS Table 3.3-10 Note ###, in part, references penetrations whose valves are either both inboard (FCV 63-158 and FCV 63-
172) or both outboard (FCV 30-46 and VLV 30-571, FCV 30-47 and VLV 30-572, FCV 30-48 and VLV 30-573) and states that if both valves (two) have inoperable accident indication, ACTION 3(b) must be entered until at least one of the valve's DISCUSSION OF CHANGES ITS 3.3.3, POST ACCIDENT MONITORING (PAM) INSTRUMENTATION Sequoyah Unit 1 and Unit 2 Page 4 of 10 accident indication is restored to OPERABLE status. ITS LCO 3.3.3 ACTION C, applicable to Function 19 (Containment Isolation Valve Position), states that with one or more Functions with two required channels inoperable to restore one channel to OPERABLE status within 7 days, similar to CTS Table 3.3-10 ACTION 3.b. This changes the CTS by simplifying the presentation of the
requirements for Containment Isolation Valve Position instrumentation by requiring two channels per penetration, except where ITS Table 3.3.3-1 Footnote (b) is applicable for those penetration flow paths with only one installed control room indication channel, and eliminating reference to inboard and outboard valve
combinations.
The purpose of CTS Table 3.3-10 is to provide requirements for Post-Accident Monitoring instruments. One of these instruments is Containment Isolation Valve Position. CTS requires one position indication channel per valve to be OPERABLE where normally there are two valves per penetration. Similarly, ITS requires two channels per penetration. CTS Note ###, in part, states that on a penetration where accident indication is declared INOPERABLE on a valve but on the opposite side of the penetration an accident indication valve does not exist (such as with a closed system or a check valve), only ACTION 3(a) must be entered. ITS Table 3.3.3-1 Footnote (b) similarly states that only one position indication channel is required for penetration flow paths with only one installed control room indication channel. CTS Table 3.3-10 Note ###, in part, requires entry into ACTION 3.b when two required valve position indicators per penetration are inoperable because ACTION 3.b entry condition is when both an inboard and outboard valve(s) on the same penetration inoperable (i.e., two position indicator per penetration). ITS LCO 3.3.3 ACTION C condition entry is when one or more Functions have two required channels inoperable, similar to CTS. This change is acceptable because the requirements contained in ITS are the same as in CTS when Containment Isolation Valve Position channel are inoperable for penetrations with two isolation valves per penetration and penetrations with one isolation valve per penetration. This change is designated as administrative because it does not result in technical changes to the CTS. A07 CTS Table 3.3-10 ACTION 1, ACTION 2, ACTION 3, and ACTION 5 contain a Note referring to applicable action requirements from reference LCOs that may contain more restrictive actions. ITS Table 3.3.3-1 does not retain this information. This changes the CTS by not including the information referring to other potentially applicable action requirements to the Bases. The purpose of CTS Table 3.3-10 ACTION 1, ACTION 2, ACTION 3, and ACTION 5 Note is to reference potentially associated Technical Specifications. It is an ITS convention to not include these types of notes or cross-references.
This change is designated as administrative change because it does not result in technical changes to the CTS. MORE RESTRICTIVE CHANGES None DISCUSSION OF CHANGES ITS 3.3.3, POST ACCIDENT MONITORING (PAM) INSTRUMENTATION Sequoyah Unit 1 and Unit 2 Page 5 of 10 RELOCATED SPECIFICATIONS None REMOVED DETAIL CHANGES LA01 (Type 5 - Removal of SR Frequency to the Surveillance Frequency Control Program) CTS 4.3.3.7.a requires performance of a CHANNEL CHECK every 31 days. CTS 4.3.3.7.b requires performance of a CHANNEL CALIBRATION every 18 months. ITS SR 3.3.3.1 (CHANNEL CHECK) and SR 3.3.3.2 (CHANNEL CALIBRATION) require similar Surveillances and specify the periodic Frequency as, "In accordance with the Surveillance Frequency Control Program." This changes the CTS by moving the specified Frequencies for these SRs and associated Bases to the Surveillance Frequency Control Program. The removal of these details related to Surveillance Requirement Frequencies from the Technical Specifications is acceptable, because this type of information is not necessary to be included in the Technical Specifications to provide adequate protection of public health and safety. The existing Surveillance Frequencies are removed from Technical Specifications and placed under licensee control pursuant to the methodology described in NEI 04-10. A new program (Surveillance Frequency Control Program) is being added to the Administrative Controls section of the Technical Specifications describing the control of Surveillance Frequencies. The surveillance test requirements remain in the Technical Specifications. The control of changes to the Surveillance Frequencies will be in accordance with the Surveillance Frequency Control Program. The Program shall ensure that Surveillance Requirements specified in the Technical Specifications are performed at intervals sufficient to assure the associated Limiting Conditions for Operation are met. This change is designated as a less restrictive removal of detail change, because the Surveillance Frequencies are being removed from the Technical Specifications.
LA02 (Type 3 - Removing Procedural Details for Meeting TS Requirements or Reporting Requirements) CTS 4.3.3.7 b Footnote
- states, for Containment Area Radiation Monitors, a CHANNEL CALIBRATION may consist of an electronic calibration of the channel, not including the detector, for range decades above 10R/h and a single calibration check of the detector below 10R/h with either an installed or portable gamma source. ITS SR 3.3.3.2 Note 2 states, for Containment Area Radiation Monitors, radiation detectors are excluded from a CHANNEL CALIBRATION for decade ranges above 10R/hour. This changes the CTS by moving the type of calibration required "a single calibration check" below 10R/h and the type of source, "installed or portable gamma source," to the Bases.
DISCUSSION OF CHANGES ITS 3.3.3, POST ACCIDENT MONITORING (PAM) INSTRUMENTATION Sequoyah Unit 1 and Unit 2 Page 6 of 10 The removal of these details for performing Surveillance Requirements from the Technical Specifications, is acceptable because this type of information is not necessary to be included in the Technical Specifications to provide adequate protection of public health and safety. The ITS still retains the requirement for the OPERABLE Containment Area Radiation Monitors and ensures the Containment Area Radiation Monitors are capable of performing their safety function. This change is acceptable because these types of procedural details will be adequately controlled in the ITS Bases. Changes to the Bases are controlled by the Technical Specification Bases Control Program in Chapter 5.
This program provides for the evaluation of changes to ensure the Bases are properly controlled. This change is designated as a less restrictive removal of detail change because information relating to system design is being removed from the Technical Specifications.
LA03 (Type 1 - Removing Details of System Design and System Description, Including Design Limits) CTS Table 3.3-10 for Accident Monitoring Instrumentation has two columns stating various requirements for each instrument. These columns are labeled, "TOTAL NO. OF CHANNELS," and "MINIMUM CHANNELS REQUIRED." ITS Table 3.3.3-1 does not retain the "TOTAL NO. OF CHANNELS" column. This changes the CTS by moving the information of the "TOTAL NO. OF CHANNELS" column to the Bases. The removal of these details, which are related to system design, from the Technical Specifications, is acceptable because this type of information is not necessary to be included in the Technical Specifications to provide adequate protection of public health and safety. The ITS still retains the requirement for the number of required channels and the appropriate Condition to enter if a required channel becomes inoperable. Also, this change is acceptable because the removed information will be adequately controlled in the ITS Bases.
Changes to the Bases are controlled by the Technical Specification Bases Control Program in Chapter 5. This program provides for the evaluation of changes to ensure the Bases are properly controlled. This change is designated as a less restrictive removal of detail change because information relating to system design is being removed from the Technical Specifications.
LA04 (Type 1 - Removing Details of System Design and System Description, Including Design Limits)
CTS Table 3.3-10 Instruments 1 (Reactor Coolant T HOT (Wide Range), 2 (Reactor Coolant T COLD (Wide Range)), 9 (Steam Generator Level - (Wide Range)), 14 (Incore Thermocouples), 18.a (ERCW to AFW Valve Position (Motor Driven Pumps)), and 18.b (ERCW to AFW Valve Position (Turbine Driven Pumps)) "Minimum Channels Required" column contains information associated with the total number of channels required for each instrument along with the number of channels required on a per loop, per steam generator, per train or valves per train basis. ITS does not contain this information in the "Required Column" only the required number of channels per Function. This changes the CTS by moving the information associated with the number per loop, per steam generator totals, per train, or valves per train to the Bases. The removal of these details, which are related to system design, from the Technical Specifications, is acceptable because this type of information is not DISCUSSION OF CHANGES ITS 3.3.3, POST ACCIDENT MONITORING (PAM) INSTRUMENTATION Sequoyah Unit 1 and Unit 2 Page 7 of 10 necessary to be included in the Technical Specifications to provide adequate protection of public health and safety. The ITS still retains the requirement for the number of required channels and the appropriate Condition to enter if a required channel becomes inoperable. Also, this change is acceptable because the removed information will be adequately controlled in the ITS Bases.
Changes to the Bases are controlled by the Technical Specification Bases Control Program in Chapter 5. This program provides for the evaluation of changes to ensure the Bases are properly controlled. This change is designated as a less restrictive removal of detail change because information relating to system design is being removed from the Technical Specifications.
LA05 (Type 1 - Removing Details of System Design and System Description, Including Design Limits) CTS Table 3.3-10 contains information associated with the specific instrument loops associated with Instruments 1 (Reactor Coolant T HOT (Wide Range), 2 (Reactor Coolant T COLD (Wide Range)), 3 (Containment Pressure (Wide Range)), 4 (Containment Pressure (Narrow Range)), 5 (Refueling Water Storage Tank Level), 6 (Reactor Coolant Pressure (Wide Range)), 7 (Pressurizer Level (Wide Range)), 8 (Steam Line Pressure), 9 (Steam Generator Level - (Wide Range)), 10 (Steam Generator Level - (Narrow Range)),
11.a (Auxiliary Feedwater-Flow Rate), 11.
b (Auxiliary Feedwater-Valve Po sition Indication), 12 (Reactor Coolant System Subcooling Margin Monitor), 13 (Containment Water Level (Wide Range)), 15.a (Reactor Vessel Level Instrumentation-Dynamic Range), 15.b (R eactor Vessel Level Instrumentation-Lower Range), 15.c (Reactor Vessel Level Instrumentation-Upper Range), 16.a (Containment Area Radiation Monitors-Upper Compartment), 16.b (Containment
Area Radiation Monitors-Lower Compartment), 17.a (Neutron Flux-Source
Range), 17.b (Neutron Flux-Intermediate Range), 18.a (ERCW to AFW Valve Position-Motor Driven Pumps), 18.b (ERCW to AFW Valve Position-Turbine Driven Pumps), and 19 (Containment Isolation Valve Position). ITS does not contain this specific instrument loop information. This changes the CTS by moving the instrument loop information associated with the required instruments
to the ITS bases.
The removal of these details, which are related to system design, from the Technical Specifications, is acceptable because this type of information is not necessary to be included in the Technical Specifications to provide adequate protection of public health and safety. The ITS still retains the requirement for the number of required channels and the appropriate Condition to enter if a required channel becomes inoperable. Also, this change is acceptable because the removed information will be adequately controlled in the ITS Bases.
Changes to the Bases are controlled by the Technical Specification Bases Control Program in Chapter 5. This program provides for the evaluation of changes to ensure the Bases are properly controlled. This change is designated as a less restrictive removal of detail change because information relating to system design is being removed from the Technical Specifications.
LA06 (Type 1 - Removing Details of System Design and System Description, Including Design Limits) CTS Table 3.3-10 ACTION 3.a references an inboard or outboard valve. CTS Table 3.3-10 ACTION 3.b references both an inboard and outboard valve(s). CTS Table 3.3-10 Note ###, in part, references penetrations whose valves are either both inboard (FCV 63-158 and FCV 63-172) or both outboard DISCUSSION OF CHANGES ITS 3.3.3, POST ACCIDENT MONITORING (PAM) INSTRUMENTATION Sequoyah Unit 1 and Unit 2 Page 8 of 10 (FCV 30-46 and VLV 30-571, FCV 30-47 and VLV 30-572, FCV 30-48 and VLV 30-573) and states that if both valves (two) have inoperable accident indication, ACTION 3(b) must be entered until at least one of the valve's accident indication is restored to OPERABLE status. ITS does not contain this specific valve information. This changes the CTS by moving the valve information associated with the containment isolation valve position to the ITS bases.
The removal of these details, which are related to system design, from the Technical Specifications, is acceptable because this type of information is not necessary to be included in the Technical Specifications to provide adequate protection of public health and safety. The ITS still retains the requirement for the number of required containment isolation valve position channels and the appropriate Condition to enter if a required channel becomes inoperable. Also, this change is acceptable because the removed information will be adequately controlled in the ITS Bases. Changes to the Bases are controlled by the Technical Specification Bases Control Program in Chapter 5. This program provides for the evaluation of changes to ensure the Bases are properly controlled. This change is designated as a less restrictive removal of detail change because information relating to system design is being removed from the Technical Specifications. LESS RESTRICTIVE CHANGES L01 (Category 3 - Relaxation of Completion Time) Unit 1 CTS 3.3.3.7 ACTION requires actions be performed as required by CTS Table 3.3-10. CTS Table 3.3-10 ACTION 1.a, ACTION 2.a, ACTION 3.a, and ACTION 5.a require the plant be in at least HOT STANDBY within the next 6 hours6.944444e-5 days <br />0.00167 hours <br />9.920635e-6 weeks <br />2.283e-6 months <br /> and in HOT SHUTDOWN within the next 6 hours6.944444e-5 days <br />0.00167 hours <br />9.920635e-6 weeks <br />2.283e-6 months <br /> if an inoperable channel cannot be restored to OPERABLE status within 30 days when the number of OPERABLE channels is one less than the minimum channels required or when one or more steam generators have less than the minimum channels required for either flow rate or valve position. ITS 3.3.3 ACTION B, which is applicable when the required action and associated Completion Time of Condition A is not met, requires initiation of action in accordance with ITS Specification 5.6.5. ITS 3.3.3 Condition A is entered when one or more Functions have one required channel inoperable and requires returning the channel to an OPERABLE status within 30 days.
Therefore, in ITS with one or more Functions with one inoperable channel for all Functions except Function 16, Condition B requires initiation of a report to the NRC in accordance with ITS 5.6.5 if one inoperable channel is not made OPERABLE within 30 days. This changes the CTS by deleting the requirements for the unit to be in HOT STANDBY or HOT SHUTDOWN with one of the required channels inoperable and not restored within the allowed outage time, and instead requiring a report to be made in accordance with ITS 5.6.5.
The purpose of these shutdown requirements is to limit unit operation in the MODES of Applicability when required equipment is inoperable. This change is acceptable due to the passive function of these instruments and the operator's ability to respond to an accident utilizing redundant or alternate instruments and methods for monitoring. The change is also considered acceptable since the probability of an event requiring the operator to utilize this instrumentation to DISCUSSION OF CHANGES ITS 3.3.3, POST ACCIDENT MONITORING (PAM) INSTRUMENTATION Sequoyah Unit 1 and Unit 2 Page 9 of 10 respond to the event is low. The addition of a report is acceptable because it advises the NRC of the cause of the inoperability and the plans and schedule for restoring the instrumentation channel to OPERABLE status. This change is designated as less restrictive because additional time is allowed to restore instrument channels to OPERABLE status than was allowed in the CTS.
L02 (Category 6 - Relaxation of Surveillance Requirement Acceptance Criteria)
CTS 4.3.3.7.b requires that each accident monitoring instrument be demonstrated OPERABLE by performance of a CHANNEL CALIBRATION every 18 months. ITS 3.3.3.2 requires performance of a CHANNEL CALIBRATION also but is modified by a Note stating, "Neutron detectors are excluded from CHANNEL CALIBRATION." This changes the CTS by excluding Neutron detectors from the Source and Intermediate Range CHANNEL CALIBRATIONS. The purpose of a CHANNEL CALIBRATION is to ensure that the channel responds within the necessary range and accuracy to known values of the parameter that the channel monitors. Thus, to perform a channel calibration of a neutron flux channel would require including the neutron flux detector in the calibration. Inclusion of neutron flux detectors in the CHANNEL CALIBRATION process is impractical in power reactor applications because to do so would require subjecting the detectors to known neutron fluxes. Because of the hazards associated with exposing the neutron detectors, CTS Table 4.3-1 Note (6) excludes these detectors from CHANNEL CALIBRATION. The detectors excluded from CHANNEL CALIBRATION in CTS Table 4.3-1 are the same channels used to satisfy CTS Table 3.3-10. This proposed change is consistent
with historical and current NRC staff requirem ents as reflected in ISTS. Explicitly stating the neutron detectors are excluded from CHANNEL CALIBRATION reiterates the allowance found in CTS Table 4.3-1. This change is designated as less restrictive because less stringent Surveillance Requirements are being applied in the ITS than were applied in the CTS.
L03 (Category 1 - Relaxation of LCO Requirements)
CTS Table 3.3-10 Note ## is associated with Instrument 19 (Containment Isolation Valve Position) Minimum Required Channels and states, "Not required for isolation valves that are closed and deactivated." ITS includes a similar Footnote for Function 19 (Containment Isolation Valve Position) that states, "Not required for isolation valves whose associated penetration is isolated by at least one closed and deactivated automatic valve, closed manual valve, blind flange, or check valve with flow through the valve secured." This changes the CTS by reducing the conditions under which the isolation valves indication must be OPERABLE by including exceptions of when the penetration is isolated by a closed manual valve, blind flange, or check valve with flow through the valve secured. The purpose of CTS Table 3.3-10, Instrument 19 (Containment Isolation Valve Position) is for verification of containment isolation using the ability to monitor containment penetration isolation valve status through valve position indication.
A closed and deactivated isolation valve provides evidence that the penetration is isolated and the requirement to provide indication of the valve position is no longer necessary. Similarly by isolating the penetration using a manual valve, blind flange, or check valve with the flow through it secured provides evidence that the penetration is isolated and the requirement to provide indication of the DISCUSSION OF CHANGES ITS 3.3.3, POST ACCIDENT MONITORING (PAM) INSTRUMENTATION Sequoyah Unit 1 and Unit 2 Page 10 of 10 valve position is no longer necessary. This change is designated as less restrictive because the containment isolation position indication channels are required to be OPERABLE under fewer conditions in ITS than were required in CTS.
Improved Standard Technical Specifications (ISTS) Markup and Justification for Deviations (JFDs)
PAM Instrumentation 3.3.3 Westinghouse STS 3.3.3-1 Rev. 4.0, SEQUOYAH UNIT 1 Amendment XXXCTS 13.3 INSTRUMENTATION 3.3.3 Post Accident Monitoring (PAM) Instrumentation LCO 3.3.3 The PAM instrumentation for each Function in Table 3.3.3-1 shall be OPERABLE. APPLICABILITY: MODES 1, 2, and 3. ACTIONS ----------------------------------------------------------NOTE------------------------------------------------------------ Separate Condition entry is allowed for each Function. -------------------------------------------------------------------------------------------------------------------------------
CONDITION REQUIRED ACTION COMPLETION TIME A. One or more Functions with one required channel inoperable. A.1 Restore required channel to OPERABLE status.
30 days B. Required Action and associated Completion
Time of Condition A not met. B.1 Initiate action in accordance with Specification 5.6.5.
Immediately C. One or more Functions with two required channels inoperable. C.1 Restore one channel to OPERABLE status.
7 days D. Required Action and associated Completion
Time of Condition C not met. D.1 Enter the Condition referenced in Table 3.3.3-1 for the channel.
Immediately G G3.3.3.7 Applicabilit y DOC A02 ACTION 1.a ACTION 2.a ACTION 3.a ACTION 5.a DOC L01 ACTION 1.b ACTION 2.b ACTION 2.c ACTION 3.a ACTION 3.b ACTION 4 ACTION 5.b ACTION 1.b ACTION 2.b ACTION 3.b INSERT 1 Conditions C, D, E, or, F INSERT 2 1 1 1 1 ITS 3.3.3 ITS Insert Page 3.3.3-1 CTS INSERT 1 -------------------------------NOTE------------------------
Not applicable to Function 16.
INSERT 2 ------------NOTE----------
Only applicable to Functions 6 and 7. ----------------------------- D. One or more Functions with three required
channels inoperable. D.1 Restore one channel to OPERABLE status. 48 hours5.555556e-4 days <br />0.0133 hours <br />7.936508e-5 weeks <br />1.8264e-5 months <br /> E. One or more steam generators with one Auxiliary
Feedwater (AFW) flow rate channel and one AFW
valve position indication channel
on the same
steam generator inoperable. E.1 Restore one channel to OPERABLE status. 7 days F. One or more Containment Area Radiation Monitors
with one required channel inoperable. F.1 Initiate an alternate method of monitoring containment area radiation.
AND F.2 Restore the inoperable channel(s) to OPERABLE status.
72 hours8.333333e-4 days <br />0.02 hours <br />1.190476e-4 weeks <br />2.7396e-5 months <br /> 30 days ACTION 2.c ACTION 4 1 1Table 3.3-10 Functions 6 and 7 Action 2 ACTION 5.b ACTION 4 PAM Instrumentation 3.3.3 Westinghouse STS 3.3.3-2 Rev. 4.0, SEQUOYAH UNIT 1 Amendment XXXCTS 1ACTIONS (continued)
CONDITION REQUIRED ACTION COMPLETION TIME E. As required by Required Action D.1 and referenced in Table 3.3.3-1.
E.1 Be in MODE 3.
AND E.2 Be in MODE 4.
6 hours6.944444e-5 days <br />0.00167 hours <br />9.920635e-6 weeks <br />2.283e-6 months <br /> 12 hours F. As required by Required Action D.1 and referenced in Table 3.3.3-1.
F.1 Initiate action in accordance with Specification 5.6.5.
Immediately SURVEILLANCE REQUIREMENTS ------------------------------------------------------------NOTE-----------------------------------------------------------
SR 3.3.3.1 and SR 3.3.3.2 apply to each PAM instrumentation Function in Table 3.3.3-1. -------------------------------------------------------------------------------------------------------------------------------
SURVEILLANCE FREQUENCY SR 3.3.3.1 Perform CHANNEL CHECK for each required instrumentation channel that is normally energized.
[ 31 days OR In accordance with the Surveillance
Frequency
Control Program
] H I I H H ACTION 1.b ACTION 2,b ACTION 2.c ACTION 3.b ACTION 5.b These SRs 4.3.3.7 ACTION 4 4.3.3.7.a G 1 1 1 1 2 G PAM Instrumentation 3.3.3 Westinghouse STS 3.3.3-3 Rev. 4.0, SEQUOYAH UNIT 1 Amendment XXXCTS 1SURVEILLANCE REQUIREMENTS (continued) SURVEILLANCE FREQUENCY SR 3.3.3.2 -------------------------------NOTE------------------------------ Neutron detectors are excluded from CHANNEL CALIBRATION.
Perform CHANNEL CALIBRATION.
[ [18] months OR In accordance with the Surveillance
Frequency
Control Program
] INSERT 3 1. 4.3.3.7.b 2 1 1 DOC L02 S ITS 3.3.3 ITS Insert Page 3.3.3-3 CTS INSERT 3 2.For Containment Area Radiation Monito rs, radiation detect ors are excluded from a CHANNEL CALIBRATION for decade ranges above 10 R/h r.14.3.3.7.b Note
- PAM Instrumentation 3.3.3 Westinghouse STS 3.3.3-4 Rev. 4.0, SEQUOYAH UNIT 1 Amendment XXXCTS 1Table 3.3.3-1 (page 1 of 1) Post Accident Monitoring Instrumentation FUNCTION REQUIRED CHANNELS CONDITION REFERENCED FROM REQUIRED ACTION D.1 1.Power Ran ge Neutron Flux 2 E 2.Source Ran ge Neutron Flux 2 E 3.Reactor Coolant System (RCS) Hot LegTemperature 2 per loop E 4.RCS Cold Le g Temperature2 per loop E 5.RCS Pressure (Wide Ran g e)2 E 6.Reactor Vessel Water Level 2 F 7.Containment Sump Water Level (Wide Ran g e)2 E 8.Containment Pressure (Wide Ran g e)2 E 9.Penetration Flow Path Containment Isolation Valve Position 2 per penetration flow path (a)(b)E 10.Containment Area Radiation (Hi gh Ran g e)2 F 11.Pressurizer Level 2 E 12.Steam Generator Water Level (Wide Ran g e)2 per steam generato r E 13.Condensate Stora ge Tank Level 2 E 14.Core Exit Temperature
- Quadrant [1]2 (c)E 15.Core Exit Temperature
- Quadrant [2]2 (c)E 16.Core Exit Temperature
- Quadrant [3]2 (c)E 17.Core Exit Temperature
- Quadrant [4]2 (c)E 18.Auxiliary Feedwater Flow 2 E (a) Not required for isolation valves whose associated penetration is isolated by at least one closed and deactivated automatic valve, closed manual valve, blind flange, or check valve with flow through the valve secured. (b) Only one position indication channel is required for penetration flow paths with only one installed control room indication channel. (c) A channel consists of two core exit thermocouple s (CETs). ----------------------------------------------------------------REVIEWER'S NOTE----------------------------------------------------------------
Table 3.3.3-1 shall be amended for each unit as necessary to list:
1.All Regulatory Guide 1.97, Type A instruments and 2.All Regulatory Guide 1.97, Category I, non-Type A instruments in accordance with the unit's Regulatory Guide 1.97, Safety Evaluation Report.------------------------------------------------------------------------------------------------------------------------------------------------------------
INSERT 4(d) Source Range outputs may be disabled above the P-6 (Block of Source Range Reactor Trip) setpoint.
Gone incore 1 1 1 3Note ## ACTION 3.a ACTION 3.b Note ### Table 3.3-10 DOC A03 Note # 1The required channels in each quadrant shall be in different trains.
ITS 3.3.3 ITS Insert Page 3.3.3-4a CTS INSERT 4 FUNCTION REQUIRED CHANNELS CONDITION REFERENCED FROM REQUIRED ACTION G.1 1.Reactor Coolant THOT (Wide Range) 4 H2.Reactor Coolant TCOLD (Wide Range) 4 H3.Containment Pressure (Wide Range) 2 H 4.Containment Pressure (Narrow Range) 2 H 5.Refueling Water Storage Tank Level 2 H 6.Reactor Coolant Pressure (Wide Range) 3 H 7.Pressurizer Level (Wide Range) 3 H 8.Steam Line Pressure2 per steam line H 9.Steam Generator Level - (Wide Range) 4 H 10.Steam Generator Level - (Narrow Range)2 per steam generator H 11.Auxiliary Feedwatera.Flow Rate1 per steam generator H b.Valve Position Indication1 per steam generator H 1Table 3.3-10 1 2 3 4 5 6 7 8 9 10 11 ITS 3.3.3 ITS Insert Page 3.3.3-4b CTS INSERT 4 continued FUNCTION REQUIRED CHANNELS CONDITION REFERENCED FROM REQUIRED ACTION G.1 12.Reactor Coolant System Subcooling Margin Monitor 2 H 13.Containment Water Level (Wide Range) 2 H 14.Incore Thermocouplesa.Core Quadrant (1) 2 (c) H b.Core Quadrant (2) 2 (c) H c.Core Quadrant (3) 2 (c) H d.Core Quadrant (4) 2 (c) H 15.Reactor Vessel Level Instrumentationa.Dynamic Range 2 H b.Lower Range 2 H c.Upper Range 2 H 16.Containment Area Radiation Monitorsa.Upper Compartment 1 I b.Lower Compartment 1 I 17.Neutron Fluxa.Source Range 2(d)H b.Intermediate Range 2 H 18.ERCW to AFW Valve Positiona.Motor Driven Pumps 2 H b.Turbine Driven Pump 2 H 19.Containment Isolation Valve Position2 per penetration flowpath(a)(b) H 1Table 3.3-10 12 13 14 15 16 17 18 19 PAM Instrumentation 3.3.3 Westinghouse STS 3.3.3-1 Rev. 4.0, SEQUOYAH UNIT 2 Amendment XXXCTS 13.3 INSTRUMENTATION
3.3.3 Post Accident Monitoring (PAM) Instrumentation
LCO 3.3.3 The PAM instrumentation for each Function in Table 3.3.3-1 shall be OPERABLE.
APPLICABILITY: MODES 1, 2, and 3.
ACTIONS
NOTE------------------------------------------------------------ Separate Condition entry is allowed for each Function. -------------------------------------------------------------------------------------------------------------------------------
CONDITION REQUIRED ACTION COMPLETION TIME
A. One or more Functions with one required channel inoperable.
A.1 Restore required channel to OPERABLE status.
30 days B. Required Action and associated Completion
Time of Condition A not met. B.1 Initiate action in accordance with Specification 5.6.5.
Immediately
C. One or more Functions with two required channels inoperable.
C.1 Restore one channel to OPERABLE status.
7 days D. Required Action and associated Completion
Time of Condition C not met.
D.1 Enter the Condition referenced in Table 3.3.3-1 for the channel.
Immediately G G3.3.3.7 Applicabilit y DOC A02 ACTION 1.a ACTION 2.a ACTION 3.a ACTION 5.a DOC L01 ACTION 1.b ACTION 2.b ACTION 2.c ACTION 3.a ACTION 3.b ACTION 4 ACTION 5.b ACTION 1.b ACTION 2.b ACTION 3.b INSERT 1 Conditions C, D, E, or, F INSERT 2 1 1 1 1 ITS 3.3.3 ITS Insert Page 3.3.3-1 CTS INSERT 1 -------------------------------NOTE------------------------------ Not applicable to Function 16. ---------------------------------------------------------------------
INSERT 2
NOTE----------
Only applicable to Functions 6 and 7. -----------------------------
D. One or more Functions with three required
channels inoperable.
D.1 Restore one channel to OPERABLE status.
48 hours5.555556e-4 days <br />0.0133 hours <br />7.936508e-5 weeks <br />1.8264e-5 months <br /> E. One or more steam generators
with one Auxiliary
Feedwater (AFW) flow rate channel and one AFW
valve position indication channel
on the same
steam generator inoperable.
E.1 Restore one channel to OPERABLE status.
7 days F. One or more Containment Area
Radiation Monitors
with one required channel inoperable.
F.1 Initiate an alternate method of monitoring containment area radiation.
AND F.2 Restore the inoperable channel(s) to OPERABLE status.
72 hours8.333333e-4 days <br />0.02 hours <br />1.190476e-4 weeks <br />2.7396e-5 months <br />
30 days ACTION 2.c ACTION 4 1 1Table 3.3-10 Functions 6 and 7 Action 2 ACTION 5.b ACTION 4 PAM Instrumentation 3.3.3 Westinghouse STS 3.3.3-2 Rev. 4.0, SEQUOYAH UNIT 2 Amendment XXXCTS 1ACTIONS (continued)
CONDITION REQUIRED ACTION COMPLETION TIME E. As required by Required Action D.1 and referenced in Table 3.3.3-1.
E.1 Be in MODE 3.
AND E.2 Be in MODE 4.
6 hours6.944444e-5 days <br />0.00167 hours <br />9.920635e-6 weeks <br />2.283e-6 months <br />
12 hours1.388889e-4 days <br />0.00333 hours <br />1.984127e-5 weeks <br />4.566e-6 months <br /> F. As required by Required Action D.1 and referenced in Table 3.3.3-1.
F.1 Initiate action in accordance with Specification 5.6.5.
Immediately
SURVEILLANCE REQUIREMENTS ------------------------------------------------------------NOTE-----------------------------------------------------------
SR 3.3.3.1 and SR 3.3.3.2 apply to each PAM instrumentation Function in Table 3.3.3-1. -------------------------------------------------------------------------------------------------------------------------------
SURVEILLANCE FREQUENCY
SR 3.3.3.1 Perform CHANNEL CHECK for each required instrumentation channel that is normally energized.
[ 31 days OR In accordance with the Surveillance
Frequency
Control Program
] H I I H H ACTION 1.b ACTION 2,b ACTION 2.c ACTION 3.b ACTION 5.b These SRs 4.3.3.7 ACTION 4 4.3.3.7.a G 1 1 1 1 2 G PAM Instrumentation 3.3.3 Westinghouse STS 3.3.3-3 Rev. 4.0, SEQUOYAH UNIT 2 Amendment XXXCTS 1SURVEILLANCE REQUIREMENTS (continued)
SURVEILLANCE FREQUENCY SR 3.3.3.2 -------------------------------NOTE------------------------------
Neutron detectors are excluded from CHANNEL CALIBRATION. ---------------------------------------------------------------------
Perform CHANNEL CALIBRATION.
[ [18] months OR In accordance with the Surveillance
Frequency
Control Program
] INSERT 3 1. 4.3.3.7.b 2 1 1 DOC L02 S ITS 3.3.3 ITS Insert Page 3.3.3-3 CTS INSERT 3 2. For Containment Area Radiation Monitors, radiation detectors are excluded from a CHANNEL CALIBRATION for decade ranges above 10 R/hr.
14.3.3.7.b Note
- PAM Instrumentation 3.3.3 Westinghouse STS 3.3.3-4 Rev. 4.0, SEQUOYAH UNIT 2 Amendment XXXCTS 1Table 3.3.3-1 (page 1 of 1) Post Accident Monitoring Instrumentation FUNCTION REQUIRED CHANNELS CONDITION REFERENCED FROM REQUIRED ACTION D.1 1.Power Ran ge Neutron Flux 2 E 2.Source Ran ge Neutron Flux 2 E 3.Reactor Coolant System (RCS) Hot LegTemperature 2 per loop E 4.RCS Cold Le g Temperature 2 per lo op E 5.RCS Pressure (Wide Ran g e)2 E 6.Reactor Vessel Water Level 2 F 7.Containment Sump Water Level (Wide Ran g e)2 E 8.Containment Pressure (Wide Ran g e)2 E 9.Penetration Flow Path Containment Isolation Valve Position 2 per penetration flow path (a)(b)E 10.Containment Area Radiation (Hi gh Ran g e)2 F 11.Pressurizer Level 2 E 12.Steam Generator Water Level (Wide Ran g e)2 per steam generato r E 13.Condensate Stora ge Tank Level 2 E 14.Core Exit Temperature
- Quadrant [1]2 (c)E 15.Core Exit Temperature
- Quadrant [2]2 (c)E 16.Core Exit Temperature
- Quadrant [3]2 (c)E 17.Core Exit Temperature
- Quadrant [4]2 (c)E 18.Auxiliary Feedwater Flow 2 E (a) Not required for isolation valves whose associated penetration is isolated by at least one closed and deactivated automatic valve, closed manual valve, blind flange, or check valve with flow through the valve secured. (b) Only one position indication channel is required for penetration flow paths with only one installed control room indication channel. (c) A channel consists of two core exit thermocouple s (CETs). ----------------------------------------------------------------REVIEWER'S NOTE----------------------------------------------------------------
Table 3.3.3-1 shall be amended for each unit as necessary to list:
1.All Regulatory Guide 1.97, Type A instruments and 2.All Regulatory Guide 1.97, Category I, non-Type A instruments in accordance with the unit's Regulatory Guide 1.97, Safety Evaluation Report.
INSERT 4(d) Source Range outputs may be disabled above the P-6 (Block of Source Range Reactor Trip) setpoint.
Gone incore 1 1 1 3Note ## ACTION 3.a ACTION 3.b Note ### Table 3.3-10 DOC A03 Note # 1The required channels in each quadrant shall be in different trains.
ITS 3.3.3 ITS Insert Page 3.3.3-4a CTS INSERT 4 FUNCTION REQUIRED CHANNELS CONDITION REFERENCED FROM REQUIRED ACTION G.1 1.Reactor Coolant THOT (Wide Range) 4 H2.Reactor Coolant TCOLD (Wide Range) 4 H3.Containment Pressure (Wide Range) 2 H 4.Containment Pressure (Narrow Range) 2 H 5.Refueling Water Storage Tank Level 2 H 6.Reactor Coolant Pressure (Wide Range) 3 H 7.Pressurizer Level (Wide Range) 3 H 8.Steam Line Pressure2 per steam line H 9.Steam Generator Level - (Wide Range) 4 H 10.Steam Generator Level - (Narrow Range)2 per steam generator H 11.Auxiliary Feedwatera.Flow Rate1 per steam generator H b.Valve Position Indication1 per steam generator H 1Table 3.3-10 1 2 3 4 5 6 7 8 9 10 11 ITS 3.3.3 ITS Insert Page 3.3.3-4b CTS INSERT 4 continued FUNCTION REQUIRED CHANNELS CONDITION REFERENCED FROM REQUIRED ACTION G.1 12.Reactor Coolant System Subcooling Margin Monitor 2 H 13.Containment Water Level (Wide Range) 2 H 14.Incore Thermocouplesa.Core Quadrant (1) 2 (c) H b.Core Quadrant (2) 2 (c) H c.Core Quadrant (3) 2 (c) H d.Core Quadrant (4) 2 (c) H 15.Reactor Vessel Level Instrumentationa.Dynamic Range 2 H b.Lower Range 2 H c.Upper Range 2 H 16.Containment Area Radiation Monitorsa.Upper Compartment 1 I b.Lower Compartment 1 I 17.Neutron Fluxa.Source Range 2(d)H b.Intermediate Range 2 H 18.ERCW to AFW Valve Positiona.Motor Driven Pumps 2 H b.Turbine Driven Pump 2 H 19.Containment Isolation Valve Position2 per penetration flowpath(a)(b) H 1Table 3.3-10 12 13 14 15 16 17 18 19 JUSTIFICATION FOR DEVIATIONS ITS 3.3.3, POST ACCIDENT MONITORING (PAM) INSTRUMENTATION Sequoyah Unit 1 and Unit 2 Page 1 of 1 1.Changes are made (additions, deletions, and/or changes) to the ISTS that reflect theplant-specific nomenclature, number, refer ence, system description, analysis, or licensing ba sis description.
2.ISTS SR 3.3.3.1 and ISTS SR 3.3.3.2 provide two options for controlling t he Frequencies of Surveillance Requirements. SQN is proposi ng to control the Surveillance Frequencie s under the Surveillance Frequency Control Program.
Therefore, the Frequency for ITS SR 3.3.3.1 and SR 3.3.3.2 is "In accor dance with the Surveillance Freque ncy Control Program." 3.The Reviewer's Note has been deleted. Thi s information is for the NRC reviewer to be keyed into what is needed to meet this requirement. This Note is not meant to be retained in the final version of the plant specific submittal.
Improved Standard Technical Specifications (ISTS) Bases Markup and Bases Justification for Deviations (JFDs)
PAM Instrumentation B 3.3.3 Westinghouse STS B 3.3.3-1 Rev. 4.0 SEQUOYAH UNIT 1 Revision XXX 1B 3.3 INSTRUMENTATION
B 3.3.3 Post Accident Monitoring (PAM) Instrumentation
BASES BACKGROUND The primary purpose of the PAM instrumentation is to display unit variables that provide information required by the control room operators during accident situations. This information provides the necessary support for the operator to take the manual actions for which no automatic control is provided and that are required for safety systems to accomplish their safety functions for Design Basis Accidents (DBAs).
The OPERABILITY of the accident monitoring instrumentation ensures that there is sufficient information available on selected unit parameters to monitor and to assess unit status and behavior following an accident.
The availability of accident monitoring instrumentation is important so that responses to corrective actions can be observed and the need for, and magnitude of, further actions can be determined. These essential instruments are identified by unit specific documents (Ref. 1) addressing the recommendations of Regulatory Guide 1.97 (Ref. 2) as required by Supplement 1 to NUREG-0737 (Ref. 3).
The instrument channels required to be OPERABLE by this LCO include two classes of parameters identified during unit specific implementation of
Regulatory Guide 1.97 as Type A and Category I variables.
Type A variables are included in this LCO because they provide the
primary information required for the cont rol room operator to take specific manually controlled actions for which no automatic control is provided, and that are required for safety systems to accomplish their safety functions for DBAs. Because the list of Type A variables differs widely between units, Table 3.3.3-1 in the accompan ying LCO contains no examples of Type A variables, except for those that may also be Category I variables.
Category I variables are the key variables deemed risk significant because they are needed to:
- Determine whether other systems im portant to safety are performing their intended functions,
- Provide information to the operators that will enable them to determine the likelihood of a gross breach of the barriers to radioactivity release
, and 1 1
- Monitor the process of accomplishing or maintaining critical safety functions, and and to determine if a gross breach of a barrier has occurred.
- Permit the operator to take preplanned manual actions to accomplish safe plant shutdown.
2 1 2 1 1 1 PAM Instrumentation B 3.3.3 Westinghouse STS B 3.3.3-2 Rev. 4.0 SEQUOYAH UNIT 1 Revision XXX 1BASES BACKGROUND (continued)
- Provide information regarding the release of radioactive materials to allow for early indication of the need to initiate action necessary to protect the public, and to estimate the magnitude of any impending threat.
These key variables are identified by the unit specific Regulatory
Guide 1.97 analyses (Ref. 1). These analyses identify the unit specific Type A and Category I variables and provide justification for deviating from the NRC proposed list of Category I variables.
REVIEWER'S NOTE-----------------------------------
Table 3.3.3-1 provides a list of variables typical of those identified by the unit specific Regulatory Guide 1.97 analyses. Table 3.3.3-1 in unit specific Technical Specifications (TS) shall list all Type A and Category I variables identified by the unit specific Regulatory Guide 1.97 analyses, as amended by the NRC's Safety Evaluation Report (SER).
The specific instrument Functions listed in Table 3.3.3-1 are discussed in the LCO section.
APPLICABLE The PAM instrumentation ensures the operability of Regulatory SAFETY Guide 1.97 Type A and Category I variables so that the control room ANALYSES operating staff can:
- Perform the diagnosis specified in the emergency operating procedures (these variables are restricted to preplanned actions for the primary success path of DBAs), e.g., loss of coolant accident (LOCA),
- Take the specified, pre-planned, manually controlled actions, for which no automatic control is provided, and that are required for safety systems to accomplish their safety function,
- Determine whether systems important to safety are performing their intended functions,
- Determine the likelihood of a gross breach of the barriers to radioactivity release,
- Determine if a gross breach of a barrier has occurred , and 1 1
- Monitor the process of accomplishing or maintaining critical safety functions, and 1 2 3 1 1 1 4 4 PAM Instrumentation B 3.3.3 Westinghouse STS B 3.3.3-3 Rev. 4.0 SEQUOYAH UNIT 1 Revision XXX 1BASES
APPLICABLE SAFETY ANALYSES (continued)
- Initiate action necessary to protect the public and to estimate the magnitude of any impending threat
. PAM instrumentation that meets the definition of Type A in Regulatory Guide 1.97 satisfies Criterion 3 of 10 CFR 50.36(c)(2)(ii). Category I , non-Type A, instrumentation must be retained in TS because it is intended to assist operators in minimizing the consequences of accidents.
Therefore, Category I, non-Type A, variables are important for reducing public risk.
LCO The PAM instrumentation LCO provides OPERABILITY requirements for Regulatory Guide 1.97 Type A monitors, which provide information required by the control room operators to perform certain manual actions specified in the unit Emergency Operating Procedures. These manual actions ensure that a system can accomplish its safety function, and are credited in the safety analyses. Additionally, this LCO addresses Regulatory Guide 1.97 instruments that have been designated Category I , non-Type A.
The OPERABILITY of the PAM instrumentation ensures there is sufficient information available on selected unit parameters to monitor and assess unit status following an accident. This capability is consistent with the recommendations of Reference
- 1. LCO 3.3.3 requires two OPERABLE channels for most Functions. Two OPERABLE channels ensure no single failure prevents operators from getting the information necessary for them to determine the safety status of the unit, and to bring the unit to and maintain it in a safe condition following an accident.
Furthermore, OPERABILITY of two channels allows a CHANNEL CHECK during the post accident phase to confirm the validity of displayed information. More than two channels may be required at some units if the unit specific Regulatory Guide 1.97 analyses (Ref. 1) determined that failure of one accident monitoring channel results in information ambiguity (that is, the redundant displays disagree) that could lead operators to defeat or fail to accomplish a required safety function.
The exception to the two channel requirement is Penetration Flow Path Containment Isolation Valve (CIV) Position. In this case, the important information is the status of the containment penetrations. The LCO requires one position indicator for each active CIV. This is sufficient to redundantly verify the isolation status of each isolable penetration either via indicated status of the active valve and prior knowledge of a passive 1 1 1 2 1 2 2 2 1 5 PAM Instrumentation B 3.3.3 Westinghouse STS B 3.3.3-4 Rev. 4.0 SEQUOYAH UNIT 1 Revision XXX 1BASES LCO (continued) valve, or via system boundary status. If a normally active CIV is known to be closed and deactivated, position indication is not needed to determine status. Therefore, the position indication for valves in this state is not required to be OPERABLE.
Table 3.3.3-1 provides a list of variables typical of those identified by the unit specific Regulatory Guide 1.97 (Ref.
- 1) analyses. Table 3.3.3-1 in unit specific TS should list all Type A and Category I variables identified by the unit specific Regulatory Guide 1.97 analyses, as amended by the NRC's SER.
Type A and Category I variables are required to meet Regulatory Guide 1.97 Category I (Ref. 2) design and qualification requirements for seismic and environmental qualification, single failure criterion, utilization of emergency standby power, immediately accessible display, continuous readout, and recording of display. Listed below are discussions of the specified instrument Functions listed in Table 3.3.3-1. These discussions are intended as examples of what should be provided for each Function when the unit specific list is prepared. 1, 2. Power Range and Source Range Neutron Flux Power Range and Source Range Neutron Flux indication is provided to verify reactor shutdown. The two ranges are necessary to cover the full range of flux that may occur post accident.
Neutron flux is used for accident diagnosis, verification of subcriticality, and diagnosis of positive reactivity insertion.
3, 4. Reactor Coolant System (RCS) Hot an d Cold Le g Temperatures RCS Hot and Cold Leg Temperatures are Category I variables provided for verification of core cooling and long term surveillance. RCS hot and cold leg temperatures are used to determine RCS subcooling margin. RCS subcooling margin will allow termination of safety injection (SI), if still in progress, or reinitiation of SI if it has been stopped.
RCS subcooling margin is also used for unit stabilization and cooldown control.
1 1 2 2 11, 2. 1 2 THOT and Reactor Coolant TCOLD (Wide Range)Reactor Coolant T HOT and Reactor Coolant TCOLD (Wide Range)Reactor Coolant T HOT and Reactor Coolant TCOLD Reactor coolantreactor coolant PAM Instrumentation B 3.3.3 Westinghouse STS B 3.3.3-5 Rev. 4.0 SEQUOYAH UNIT 1 Revision XXX 1BASES
LCO (continued)
In addition, RCS cold leg temperature is used in conjunction with RCS hot leg temperature to verify the unit conditions necessary to establish natural circulation in the RCS.
Reactor outlet temperature inputs to the Reactor Protection System are provided by two fast response resistance elements and associated transmitters in each loop. The channels provide indication over a range of 32°F to 700°F.
- 5. Reactor Coolant System Pressure (Wide Range)
RCS wide range pressure is a Category I variable provided for verification of core cooling and RCS integrity long term surveillance.
RCS pressure is used to verify delivery of SI flow to RCS from at least one train when the RCS pressure is below the pump shutoff head. RCS pressure is also used to verify closure of man ually closed spray line valves and pressurizer power operated relief valves (PORVs).
In addition to these verifications, RCS pressure is used for determining RCS subcooling margin. RCS subcooling margin will allow termination of SI, if still in progress, or reinitiation of SI if it has been stopped. RCS pressure can also be used:
- to manually restart low head SI,
- as react or coolant pump (RCP) trip criteria, and
- to make a determination on the nature of the accident in progress and where to go next in the procedure.
RCS subcooling margin is also used for unit stabilization and cooldown control.
INSERT 1 1 0 1 B 3.3.3 Insert Page B 3.3.3-5a INSERT 1 1, 2. continued There are a total of four Reactor Coolant System (RCS) Hot and Cold Leg Temperature channels each. One RCS Hot leg temperature channel per loop and one Cold Leg temperature channel per loop.
The instrument loops associated with RCS T HOT are 68-001, -024, -043, and -065. The instrument loops associated with RCS T COLD are 68-018,68-041, 68-060, and 68-083.
- 3. Containment Pressure (Wide Range)
Containment Pressure (Wide Range) is provided for determination of potential for containment breach.
The channels provide indication over a range of -5 to 60 psig. There are a total of two Containment Pressure (Wide Range) channels. The instrument loops associated with Containment Pressure (Wide
Range) are 30-310 and 30-311.
- 4. Containment Pressure (Narrow Range)
Containment Pressure (Narrow Range) is provided for determination of an actual containment breach and if a break is inside or outside
containment. Additionally it is provided to monitor containment conditions following a break inside containment and verifying the accident is properly controlled.
The channels provide indication over a range of -1 to 15 psig. There are a total of two Containment Pressure (Narrow Range) channels.
The instrument loops associated with Containment Pressure (Narrow
Range)30-044 and 30-045.
- 5. Refueling Water Storage Tank Level Refueling Water Storage Tank Level is provided to verify a water source to emergency core cooling systems and containment spray system, determine the time for initiation of cold leg recirculation following a loss of coolant accident, and for event diagnosis.
The channels provide indication over a range of 0% to 100%. There are a total of two Refueling Water Storage Tank Level channels. The instrument loops associated with Refueling Water Storage Tank Level are 63-050 and 63-051.
1 B 3.3.3 Insert Page B 3.3.3-5b INSERT 1 continued
- 6. Reactor Coolant Pressure (Wide Range)
Reactor Coolant Pressure (Wide Range) is provided to determine if the plant is in safe shutdown condition. It is also used for maintaining the proper relationship between RCS pressure and temperature, verifying vessel nondestructive testing criteria, maintain primary inventory subcooled (particularly with loss of offsite power), establish correct conditions for residual heat removal operation, determine whether reactor coolant pump operation should be continued, and determine whether high-head SI should be terminated or reinitiated.
The channels provide indication over a range of 0 to 3000 psig. There are a total of three Reactor Coolant Pressure (Wide Range) channels.
The instrument loops associated with Reactor Coolant Pressure (Wide Range) are 68-062,68-066, and 68-069.
- 7. Pressurizer Level (Wide Range)
Pressurizer Level (Wide Range) is provided to confirm if plant is in a safe shutdown condition. It is also provided to monitor RCS inventory, maintain pressurizer water level, and determine whether SI should be terminated or reinitiated.
The channels provide indication over a range of 0% to 100%. There are a total of three Pressurizer Level (Wide Range) channels. The instrument loops associated with Pressurizer Level (Wide Range) are 68-320,68-335, and 68-339.
- 8. Steam Line Pressure Steam Line Pressure is provided to determine if a high-energy
secondary line rupture occurred. It is also provided to maintain an adequate reactor heat sink and verify auxiliary feedwater to steam generator associated with pipe rupture is isolated. It can be used to monitor secondary side pressure to: (1) verify operation of pressure control steam dump system, (2) maintain plant in safe shutdown condition, and (3) monitor RCS cooldown rate. It is diverse to T cold for natural circulation determination. In addition, it can be used for identification of steam generator tube rupture and determination that faulted steam generator is isolated.
The channels provide indication over a range of 0 to 1200 psig. There are a total of eight Steam Line Pressure channels, two per loop. The instrument loops associated with Steam Line Pressure are 1-002A, 1-002B, 1-009A, 1-009B, 1-020A, 1-020B, 1-027A, and 1-027B 1
B 3.3.3 Insert Page B 3.3.3-5c INSERT 1 continued
- 9. Steam Generator Level - (Wide Range)
Steam Generator Level (Wide Range) is provided to determine if heat sink is being maintained and is used for SI termination for secondary break outside containment.
The channels provide indication over a range of 0 to 100 percent.
There are a total of four Steam Generator Level - (Wide Range) channels, one per steam generator. The instrument loops associated with Steam Generator Level - (Wide Range) are 3-043, 3-056, 3-098, and 3-111.
- 10. Steam Generator Level - (Narrow Range)
Steam Generator Level (Narrow Range) is provided to monitor heat
sink, maintain steam generator water level, determine whether SI should be terminated, and determine which loop has SG tube rupture.
The channels provide indication over a range of 0 to 100 percent.
There are a total of eight Steam Generator Level - (Narrow Range) channels, two per steam generator. The instrument loops associated with Steam Generator Level - (Narrow Range) are 3-039, 3-042, 3-052, 3-055, 3-094, 3-097, 3-107, and 3-110.
- 11. Auxiliary Feedwater Auxiliary Feedwater (AFW) flow is provided to determine if sufficient flow exists to maintain heat sink and for SI termination. The channels provide indication over a range of 0 to 440 gpm. The redundant channel capability for AFW flow consists of a single AFW flow channel for each Steam Generator (four total, one per steam generator) with a diverse channel consisting of three AFW valve position indicators (two
level control valves for the motor driven AFW flowpath and one level control valve for the turbine driven AFW flowpath) for each steam generator (12 total).
The instrument loops associated with AFW flow are 3-163, 3-155, 3-147, and 3-170. The instrument loops associated with AFW valve position indication are 3-164, 3-164A, 3-174, 3-156, 3-156A, 3-173, 3-148, 3-148A, 3-172, 3-171, 3-171A, and 3-175.
1 B 3.3.3 Insert Page B 3.3.3-5d INSERT 1 continued
- 12. Reactor Coolant System Subcooling Margin Monitor Reactor Coolant System Subcooling is provided for SI termination or reinitiation and maintenance of subcooling during depressurization.
The channels provide indication over a range of 200°F subcooled to 35°F superheat. There are a total of two Reactor Coolant System Subcooling Margin Monitor channels. The instrument loops associated with Reactor Coolant System Subcooling Margin Monitor
are 94-101 and 94-102.
- 13. Containment Water Level (Wide Range)
Containment Water Level (Wide Range) is provided to verify water source for recirculation mode cooling, determine whether high energy line rupture has occurred inside or outside containment, and determine potential for containment breach caused by very high water
levels.
The channels provide indication over a range of 0% to 100%. There are a total of two Containment Water Level (Wide Range) channels. The instrument loops associated with Containment Water Level (Wide
Range) are 63-178 and 63-179.
- 14. Incore Thermocouples Incore thermocouples are provided to verify that the core is being adequately cooled, verify that RCS remains subcooled, and for monitoring the potential for fuel clad breach.
The channels provide indication over a range of 200°F to 2300°F. There are a total of 65 Incore Thermocouples. Each channel consists of one incore thermocouple. The minimum number of channels required is two channels per quadrant, eight per core, one/core quadrant/train. The two required channels in each quadrant shall be in different trains.
1 B 3.3.3 Insert Page B 3.3.3-5e INSERT 1 continued
- 15. Reactor Vessel Level Instrumentation Reactor Vessel Level indication is provided for determination of core cooling. It is considered to be a more direct and less ambiguous indication of core cooling.
The channels provide indication over a range of 0% to 120% (dynamic range), 0% to 70% (lower range), and 64% to 120% (upper range).
There are a total of six Reactor Vessel Level Instrument channels.
The instrument loops associated with Reactor Vessel Level Dynamic Range are 68-367 and 68- 370. The instrument loops associated with Reactor Vessel Level Lower Range are 68-368 and 68-371. The instrument loops associated with Reactor Vessel Level Upper Range
are 68-369 and 68-372.
- 16. Containment Area Radiation Monitors Containment area radiation monitors are provided for accident diagnosis and SI Termination/Reinitiation.
The channels provide indication over a range of 10 0 to 10 8 R/hr. There are a total of four Containment Area Radiation Monitors. The instrument loops associated with Containment Area Radiation Monitors Upper Compartment are 90-271 and 90-272. The instrument loops associated with Containment Area Radiation Monitors Lower Compartment are 90-273 and 90-274.
- 17. Neutron Flux The Intermediate Range and Source Range Neutron Flux are provided for monitoring reactivity control, determining if plant is subcritical, and to diagnose positive reactivity insertion.
The channels provide indication over a range of 1 to 10 6 CPS (Source Range) and 10
-8 to 200% RTP (Intermediate Range). There are a total of two Source Range channels and two Intermediate Range channels. The instrument loops associated with the Source Range are 92-5001 and 92-5002. The instrument loops associated with the
Intermediate Range are 92-5003 and 92-5004.
1 B 3.3.3 Insert Page B 3.3.3-5f INSERT 1 continued
- 18. ERCW to AFW Valve Position The ERCW to AFW valve position is provided for verification of heat sink availability. There is a total of four motor driven pump instrument loops. For the turbine driven AFW pump there is a total of four instrument loops. Each ERCW to AFW suction line contains two in-series isolation valves, each with its own position indication. Thus, position indication on both valves on a suction line is necessary.
Each channel consists of the two valve position indications associated with the in-series valves in a single suction line.
The instrument loops associated with ERCW to AFW valve position for the Motor Driven Pumps are 3-116A, 3-116B, 3-126A, and 3-126B.
The instrument loops associated with ERCW to AFW valve position
for the Turbine Driven Pump are 3-136A, 3-136B, 3-179A, and 3-179B.
- 19. Containment Isolation Valve Position Containment Isolation valve position is provided for verification of containment isolation. There is one position indication instrument per isolation valve. The Containment Isolation valve position indications are located on Panels TR-A XX-55-6K and TR-B XX-55-6L
1 PAM Instrumentation B 3.3.3 Westinghouse STS B 3.3.3-6 Rev. 4.0 SEQUOYAH UNIT 1 Revision XXX 1BASES
LCO (continued)
RCS pressure is also related to three decisions about depressurization. They are:
- to determine whether to proceed with primary system depressurization,
- to verify termination of depressurization, and
- to determine whether to close accumulator isolation v alves during a controlled cooldown/depressurization.
A final use of RCS pressure is to determine whether to operate the pressurizer heaters.
In some units, RCS pressure is a Type A variable because the operator uses this indication to monitor the cooldo wn of the RCS following a steam generator tube rupture (SGTR) or small break LOCA. Operator actions to maintain a controlled cooldown, such as adjusting steam generator (SG) pressure or level, would use this indication. Furthermore, RCS pressure is one factor that may be used in decisions to terminate RCP operation.
- 6. Reactor Vessel Water Level Reactor Vessel Water Level is provided for verification and long term surveillance of core cooling. It is also used for accident diagnosis and to determine reactor coolant inventory adequacy.
The Reactor Vessel Water Level Monitoring System provides a direct measurement of the collapsed liquid level above the fuel alignment plate. The collapsed level represents the amount of liquid mass that is in the reactor vessel above the core. Measurement of the collapsed water level is selected because it is a direct indication of the water inventory.
- 7. Containment Sump Water Level (Wide Range)
Containment Sump Water Level is provided for verification and long term surveillance of RCS integrity.
Containment Sump Water Level is used to determine:
- containment sump level accident diagnosis, 1 PAM Instrumentation B 3.3.3 Westinghouse STS B 3.3.3-7 Rev. 4.0 SEQUOYAH UNIT 1 Revision XXX 1BASES
LCO (continued)
- when to begin the recirculation procedure, and
- whether to terminate SI, if still in progress.
- 8. Containment Pressure (Wide Range)
Containment Pressure (Wide Range) is provided for verification of RCS and containment OPERABILITY.
Containment pressure is used to verify closure of main steam isolation valves (MSIVs), and containment spray Phase B isola tion when High-3 containment pressure is reached.
- 9. Penetration Flow Path Containment Isolation Valve Position Penetration Flow Path CIV Position is provided for verification of Containment OPERABILITY, and Phase A and Phase B isolation.
When used to verify Phase A and Phase B isolation, the important information is the isolation status of the containment penetrations. The LCO requires one channel of valve position indication in the control room to be OPERABLE for each active CIV in a containment penetration flow path, i.e., two total channels of CIV position indication for a penetration flow path with two active valves. For containment penetrations with only one active CIV having control room indication, Note (b) requires a single channel of valve p osition indication to be OPERABLE. This is sufficient to redundantly verify the isolation status of each isolable penetration either via indicated status of the active valve, as applicable, and prior knowledge of a passive valve, or via system boundary status. If a normally active CIV is known to be closed and deactivated, position indication is not needed to determine status. Therefore, the position indication for valves in this state is not required to be OPERABLE. Note (a) to the Required Channels states that the Function is not required for isolation valves whose associated penetration is isolated by at least one closed and deactivated automatic valve, closed manual valve, blind flange, or check valve with flow through the valve secured.
Each penetration is treated separately and each penetration flow path is considered a separate function. Therefore, separate Condition entry is allowed for each inoperable penetration flow path.
1 PAM Instrumentation B 3.3.3 Westinghouse STS B 3.3.3-8 Rev. 4.0 SEQUOYAH UNIT 1 Revision XXX 1BASES
LCO (continued)
- 10. Containment Area Radiation (High Rang e) Containment Area Radiation is provided to monitor for the potential of significant radiation releases and to provide release assessment for use by operators in determining the need to invoke site emergency plans. Containment radiation level is used to determine if a high energy line break (HELB) has occurred, and whether the event is inside or outside of containment.
- 11. Pressurizer Level Pressurizer Level is used to determine whether to terminate SI, if still in progress, or to reinitiate SI if it has been stopped. Knowledge of pressurizer water level is also used to verify the unit conditions necessary to establish natural circulation in the RCS and to verify that the unit is maintained in a safe shutdown condition.
- 12. Steam Generator Water Leve l (Wide Range)
SG Water Level is provided to monitor operation of decay heat removal via the SGs. The Category I indication of SG level is the extended startup range level instrumentat ion. The extended startup range level covers a span of 6 inches to 394 inches above the lower tubesheet. The measured differential pressure is displayed in inches of water at 68°F.
Temperature compensation of this indication is performed manually by the operator. Redundant monitoring capability is provided by two trains of instrumentation. The uncompensated level signal is input to the unit computer, a control room indicator, and the Emergency Feedwater Control System.
SG Water Level (Wide Range) is used to:
- identify the faulted SG following a tube rupture,
- verify that the intact SGs are an adequate heat sink for the reactor,
- determine the nature of the accident in progress (e.g., verify an SGTR), and
- verify unit conditions for termination of S I during secondary unit HELBs outside containment.
1 PAM Instrumentation B 3.3.3 Westinghouse STS B 3.3.3-9 Rev. 4.0 SEQUOYAH UNIT 1 Revision XXX 1BASES
LCO (continued)
At some units, operator action is based on the control room indication of SG level. The RCS response during a design basis small break LOCA depends on the break size. For a certain range of break sizes, the boiler condenser mode of heat transfer is necessary to remove decay heat. Extended startup range level is a Type A variable because the operator must manually raise and control SG level to establish boiler condenser heat tr ansfer. Operator action is initiated on a loss of subcooled margin. Feedwater flow is increased until the indicated extended startup range level reaches the boiler condenser setpoint. 13. Condensate Storage Tank (CST) Level CST Level is provided to en sure water supply for auxiliary feedwater (AFW). The CST provides the ensured safety grade water supply for the AFW System. The CST consists of two identical tanks connected by a common outlet header. Inventory is monitored by a 0 inch to 144 inch level indication for each tank. CST Level is displayed on a control room indicator, strip chart recorder, and unit computer. In addition, a control room annunciator alarms on low level.
At some units, CST Level is considered a Type A variable because the control room meter and annunciator are considered the primary indication used by the operator.
The DBAs that require AFW are the loss of electric power, steam line break (SLB), and small break LOCA.
The CST is the initial source of water for the AFW System. However, as the CST is depleted, manual operator action is necessary to replenish the CST or align suction to the AFW pumps from the hotwell. 14, 15, 16, 17.
Core Exit Temperature Core Exit Temperature is provided for verification and long term surveillance of core cooling.
An evaluation was made of the minimum number of valid core exit thermocouples (CET) necessary for measuring core cooling. The evaluation determined the reduced complement of CETs necessary to detect initial core recovery and trend the ensuing core heatup. The evaluations account for core nonuniformities, including incore effects of the radial decay power distribution, excore effects of condensate runback in the hot legs, and nonuniform inlet 1
PAM Instrumentation B 3.3.3 Westinghouse STS B 3.3.3-10 Rev. 4.0 SEQUOYAH UNIT 1 Revision XXX 1BASES
LCO (continued)
temperatures. Based on these evaluations, adequate core cooling is ensured with two valid Core Exit Temperature channels per quadrant with two CETs per required channel. The CET pair are oriented radially to permit evaluation of core radial decay p ower distribution. Core Exit Temperature is used to determine whether to terminate SI, if still in progress, or to reinitiate SI if it has been stopped. Core Exit Temperature is also used for unit stabilization and cooldown control.
Two OPERABLE channels of Core Exit Temperature are required in each quadrant to provide indication of radial distribution of the coolant temperature rise across representative regions of the core. Power distribution symmetry was considered in determining the specific number and locations provided for diagnosis of local core problems. Therefore, two randomly selected thermocouples are not sufficient to meet the two thermocouples per channel requirement in any quadrant. The two thermocouples in each channel must meet the additional requirement that one is located near the center of the core and the other near the core perimeter, such that the pair of Core Exit Temperatures indicate the radial temperature gradient across their core quadrant. Unit specific evaluations in respo nse to Item II.F.2 of NUREG
-0737 (Ref.
- 3) should have identified the thermocouple pairings that satisfy these requirements. Two sets of two thermocouples ensure a single failure will not disable the ability to determine the radial temperature gradient.
- 18. Auxiliary Feedwater Flow AFW Flow is provided to monitor operation of decay heat removal via the SGs.
The AFW Flow to each SG is determined from a differential pressure measurement calibrated for a range of 0 gpm to 1200 gpm. Redundant monitoring capability is provided by two independent trains of instrumentation for each SG. Each differential pressure transmitter provides an input to a control room indicator and the unit computer. Since the primary indication used by the operator during an accident is the control room indicator, the PAM specification deals specifically with this portion of the instrument channel.
AFW flow is used three ways:
- to determine whether to terminate SI if still in progress, in conjunction with SG water level (narrow range), and 1
PAM Instrumentation B 3.3.3 Westinghouse STS B 3.3.3-11 Rev. 4.0 SEQUOYAH UNIT 1 Revision XXX 1BASES
LCO (continued)
At some units, AFW flow is a Type A variable because operator action is required to throttle flow during an SLB accident to prevent the AFW pumps from operating in runout conditions. AFW flow is also used by the operator to verify that the AFW System is delivering the correct flow to each SG. However, the primary indication used by the operator to ensure an adequate i nventory is SG level.
APPLICABILITY The PAM instrumentation LCO is applicable in MODES 1, 2, and 3. These variables are related to the diagnosis and pre-planned actions required to mitigate DBAs. The applicable DBAs are assumed to occur in MODES 1, 2, and 3. In MODES 4, 5, and 6, unit conditions are such that the likelihood of an event that would require PAM instrumentation is low; therefore, the PAM instrumentation is not required to be OPERABLE in
these MODES.
ACTIONS A Note has been added in the ACTIONS to clarify the application of Completion Time rules. The Conditions of this Specification may be entered independently for each Function listed on Table 3.3.3-1. The Completion Time(s) of the inoperable channel(s) of a Function will be tracked separately for each Function starting from the time the Condition was entered for that Function.
A.1 Condition A applies when one or more Functions have one required channel that is inoperable. Required Action A.1 requires restoring the inoperable channel to OPERABLE status within 30 days. The 30 day Completion Time is based on operating experience and takes into account the remaining OPERABLE channel (or in the case of a Function that has only one required channel, other non-Regulatory Guide 1.97 instrument channels to monitor the Function), the passive nature of the instrument (no critical automatic action is assumed to occur from these instruments), and the low probability of an event requiring PAM instrumentation during this interval.
A Note is added stating that this ACTION is not applicable to Function 16, which has its own ACTION for one channel inoperable.
1 5INSERT 2 B 3.3.3 Insert Page B 3.3.3-11 INSERT 2 On a penetration where the position indication is declared inoperable on a valve but on the opposite side of the penetration a required containment isolation valve does not exist (such as with a closed system or a check valve), only Condition A must be entered. However, valves FCV-63-158 & -172 are both inboard penetration valves, but if both valves have inoperable position indication, Condition C must be entered until at least one of the valve's position indication is restored to OPERABLE status. Valves FCV-30-46 & VLV-30-571, FCV-30-47 &
VLV-30-572, and FCV-30-48 & VLV-30-573 are all outboard penetration valves, but if both valves have inoperable position indication, Condition C must be entered until at least one of the valve's position indication is restored to OPERABLE status.
1 PAM Instrumentation B 3.3.3 Westinghouse STS B 3.3.3-12 Rev. 4.0 SEQUOYAH UNIT 1 Revision XXX 1BASES
ACTIONS (continued)
B.1 Condition B applies when the Required Action and associated Completion Time for Condition A are not met. This Required Action specifies initiation of actions in Specification 5.6.5, which requires a written report to be submitted to the NRC immediately. This report discusses the results of the root cause evaluation of the inoperability and identifies proposed restorative actions. This action is appropriate in lieu of a shutdown requirement since alternative actions are identified before loss of functional capability, and given the likelihood of unit conditions that would require information provided by this instrumentation.
C.1 Condition C applies when one or more Functions have two inoperable required channels (i.e., two channels inoperable in the same Function). Required Action C.1 requires restoring one channel in the Function(s) to OPERABLE status within 7 days. The Completion Time of 7 days is based on the relatively low probability of an event requiring PAM instrument operation and the availability of alternate means to obtain the required information. Continuous operation with two required channels inoperable in a Function is not acceptable because the alternate indications may not fully meet all performance qualification requirements applied to the PAM instrumentation. Therefore, requiring restoration of one inoperable channel of the Function limits the risk that the PAM Function will be in a degraded condition should an accident occur.
D.1 Condition D applies when the Required Action and associated Completion Time of Condition C is not met. Required Action D.1 requires entering the appropriate Condition referenced in Table 3.3.3-1 for the channel immediately. The applicable Condition referenced in the Table is Function dependent. Each time an inoperable channel has not met the
Required Action of Condition C, and the associated Completion Time has expired, Condition D is entered for that channel and provides for transfer to the appropriate subsequent Condition.
G GConditions C, D, E, or F are GCondition C, D, E, or F G INSERT 3 5 5 B 3.3.3 Insert Page B 3.3.3-12 INSERT 3 D.1 Condition D applies when one or more Functions have three required channels that are inoperable. A Note is included that states that this ACTION is only applicable to Functions 6 and 7. Required Action D.1 requires restoring one inoperable channel to OPERABLE status within 48 hours5.555556e-4 days <br />0.0133 hours <br />7.936508e-5 weeks <br />1.8264e-5 months <br />.
E.1 Condition E applies when one or more steam generators have one AFW flow rate channel and one AFW valve position channel on the same steam generator inoperable. Required Action E.1 requires restoring one inoperable channel to OPERABLE status within 7 days.
F.1 and F.2
Condition F applies when one or more Containment Area Radiation Monitors have one required channel inoperable. Required Action F.1 requires initiating an alternate method of monitoring containment area radiation within 72 hours8.333333e-4 days <br />0.02 hours <br />1.190476e-4 weeks <br />2.7396e-5 months <br />. Required Action F.2 requires restoring the inoperable channel(s) to OPERABLE status within 30 days.
5 PAM Instrumentation B 3.3.3 Westinghouse STS B 3.3.3-13 Rev. 4.0 SEQUOYAH UNIT 1 Revision XXX 1BASES
ACTIONS (continued)
E.1 and E.2 If the Required Action and associated Completion Time of Condition C is not met and Table 3.3.3-1 directs entry into Condition E, the unit must be brought to a MODE where the requirements of this LCO do not apply. To achieve this status, the unit must be brought to at least MODE 3 within 6 hours6.944444e-5 days <br />0.00167 hours <br />9.920635e-6 weeks <br />2.283e-6 months <br /> and MODE 4 within 12 hours1.388889e-4 days <br />0.00333 hours <br />1.984127e-5 weeks <br />4.566e-6 months <br />.
The allowed Completion Times are reasonable, based on operating experience, to reach the required unit conditions from full power conditions in an orderly manner and without challenging unit systems.
F.1 At this unit, alternate means of monitoring Reactor Vessel Water Level and Containment Area Radiation have be en developed and tested. These alternate means may be temporarily installed if the normal PAM channel cannot be restored to OPERABLE status within the allotted time.
If these alternate means are used, the Required Action is not to shut down the unit but rather to follow the directions of Specification 5.6.5, in the Administrative Controls section of the TS. The report provided to the NRC should discuss the alternate means used, describe the degree to which the alternate means are equivalent to the installed PAM channels, justify the areas in which they are not equivalent, and provide a schedule for restoring the normal PAM channels.
SURVEILLANCE A Note has been added to the SR Table to clarify that SR 3.3.3.1 and REQUIREMENTS SR 3.3.3.
3 apply to each PAM instrumentation Function in Table 3.3.3-1.
Performance of the CHANNEL CHECK ensures that a gross instrumentation failure has not occurred. A CHANNEL CHECK is normally a comparison of the parameter indicated on one channel to a similar parameter on other channels. It is based on the assumption that instrument channels monitoring the same parameter should read approximately the same value. Significant deviations between the two instrument channels could be an indication of excessive instrument drift in one of the channels or of something even more serious. A CHANNEL CHECK will detect gross channel failure; thus, it is key to verifying the instrumentation continues to operate properly between each CHANNEL CALIBRATION. The high radiation instrumentation should be compared to similar unit instruments located throughout the unit.
H I H 5 5 5 1, D, E, or F 2 5Condition F requires initiation of PAM Instrumentation B 3.3.3 Westinghouse STS B 3.3.3-14 Rev. 4.0 SEQUOYAH UNIT 1 Revision XXXBASES
SURVEILLANCE REQUIREMENTS (continued)
Agreement criteria are determined by the unit staff, based on a combination of the channel instrument uncertainties, including isolation, indication, and readability. If a channel is outside the criteria, it may be an indication that the sensor or the signal processing equipment has drifted outside its limit. If the channels are within the criteria, it is an indication that the channels are OPERABLE.
As specified in the SR, a CHANNEL CHECK is only required for those channels that are normally energized.
[ The Frequency of 31 days is based on operating experience that demonstrates that channel failure is rare. The CHANNEL CHECK supplements less formal, but more frequent, checks of channels during normal operational use of the displays associated with the LCO required channels.
OR The Surveillance Frequency is controlled under the Surveillance Frequency Control Program.
REVIEWER'S NOTE-----------------------------------
Plants controlling Surveillance Frequencies under a Surveillance Frequency Control Program should utilize the appropriate Frequency description, given above, and the appropriate choice of Frequency in the Surveillance Requirement.
CHANNEL CALIBRATION is a complete check of the instrument loop, including the sensor. The test verifies that the channel responds to measured parameter with the necessary range and accuracy. This SR is modified by a Note that excludes neutron detectors. The calibration method for neutron detectors is specified in the Bases of LCO 3.3.1, "Reactor Trip System (RTS) Instrumentation." Whenever a sensing element is replaced, the next required CHANNEL CALIBRATION of the
Core Exit thermocouple sensors is accomplished by an inplace cross calibration that compares the other sensing elements with the recently installed sensing element.
[ The Frequency of 18 months is based on operating experience and consistency with the typical industry refueling cycle. 6 3 6two Notes. The first INSERT 4 5 5Incore 1 B 3.3.3 Insert Page B 3.3.3-14 INSERT 4 The second Note excludes the Containment Area Radiation Monitors detectors from a CHANNEL CALIBRATION for decade ranges above 10R/h. A CHANNEL CALIBRATION for the Containment Area Radiation Monitors detectors for decade ranges below 10R/h is performed by a single calibration check with either an installed or portable gamma source.
1 PAM Instrumentation B 3.3.3 Westinghouse STS B 3.3.3-15 Rev. 4.0 BASES
SURVEILLANCE REQUIREMENTS (continued)
OR The Surveillance Frequency is controlled under the Surveillance Frequency Control Program.
REVIEWER'S NOTE-----------------------------------
Plants controlling Surveillance Frequencies under a Surveillance Frequency Control Program should utilize the appropriate Frequency description, given above, and the appropriate choice of Frequency in the Surveillance Requirement.
]
REFERENCES
[ 1. Unit specific document (e.g., FSAR, NRC Regulatory Guide 1.97 SER letter)
. ]
- 2. Regulatory Guide 1.97, [date]. 3. NUREG-0737, Supplement 1, "TMI Action Items." Revision 2, December 1980 3 6 1SEQUOYAH UNIT 1 Revision XXX 1SQN-EEB-PS-PAM-0001, PAM Variable QA Data - Base PAM Instrumentation B 3.3.3 Westinghouse STS B 3.3.3-1 Rev. 4.0 SEQUOYAH UNIT 2 Revision XXX 1B 3.3 INSTRUMENTATION
B 3.3.3 Post Accident Monitoring (PAM) Instrumentation
BASES BACKGROUND The primary purpose of the PAM instrumentation is to display unit variables that provide information required by the control room operators during accident situations. This information provides the necessary support for the operator to take the manual actions for which no automatic control is provided and that are required for safety systems to accomplish their safety functions for Design Basis Accidents (DBAs).
The OPERABILITY of the accident monitoring instrumentation ensures that there is sufficient information available on selected unit parameters to monitor and to assess unit status and behavior following an accident.
The availability of accident monitoring instrumentation is important so that responses to corrective actions can be observed and the need for, and magnitude of, further actions can be determined. These essential instruments are identified by unit specific documents (Ref. 1) addressing the recommendations of Regulatory Guide 1.97 (Ref. 2) as required by Supplement 1 to NUREG-0737 (Ref. 3).
The instrument channels required to be OPERABLE by this LCO include two classes of parameters identified during unit specific implementation of
Regulatory Guide 1.97 as Type A and Category I variables.
Type A variables are included in this LCO because they provide the
primary information required for the cont rol room operator to take specific manually controlled actions for which no automatic control is provided, and that are required for safety systems to accomplish their safety functions for DBAs. Because the list of Type A variables differs widely between units, Table 3.3.3-1 in the accompan ying LCO contains no examples of Type A variables, except for those that may also be Category I variables.
Category I variables are the key variables deemed risk significant because they are needed to:
- Determine whether other systems im portant to safety are performing their intended functions,
- Provide information to the operators that will enable them to determine the likelihood of a gross breach of the barriers to radioactivity release
, and 1 1
- Monitor the process of accomplishing or maintaining critical safety functions, and and to determine if a gross breach of a barrier has occurred.
- Permit the operator to take preplanned manual actions to accomplish safe plant shutdown.
2 1 2 1 1 1 PAM Instrumentation B 3.3.3 Westinghouse STS B 3.3.3-2 Rev. 4.0 SEQUOYAH UNIT 2 Revision XXX 1BASES BACKGROUND (continued)
- Provide information regarding the release of radioactive materials to allow for early indication of the need to initiate action necessary to protect the public, and to estimate the magnitude of any impending threat.
These key variables are identified by the unit specific Regulatory
Guide 1.97 analyses (Ref. 1). These analyses identify the unit specific Type A and Category I variables and provide justification for deviating from the NRC proposed list of Category I variables.
REVIEWER'S NOTE-----------------------------------
Table 3.3.3-1 provides a list of variables typical of those identified by the unit specific Regulatory Guide 1.97 analyses. Table 3.3.3-1 in unit specific Technical Specifications (TS) shall list all Type A and Category I variables identified by the unit specific Regulatory Guide 1.97 analyses, as amended by the NRC's Safety Evaluation Report (SER).
The specific instrument Functions listed in Table 3.3.3-1 are discussed in the LCO section.
APPLICABLE The PAM instrumentation ensures the operability of Regulatory SAFETY Guide 1.97 Type A and Category I variables so that the control room ANALYSES operating staff can:
- Perform the diagnosis specified in the emergency operating procedures (these variables are restricted to preplanned actions for the primary success path of DBAs), e.g., loss of coolant accident (LOCA),
- Take the specified, pre-planned, manually controlled actions, for which no automatic control is provided, and that are required for safety systems to accomplish their safety function,
- Determine whether systems important to safety are performing their intended functions,
- Determine the likelihood of a gross breach of the barriers to radioactivity release,
- Determine if a gross breach of a barrier has occurred , and 1 1
- Monitor the process of accomplishing or maintaining critical safety functions, and 1 2 3 1 1 1 4 4 PAM Instrumentation B 3.3.3 Westinghouse STS B 3.3.3-3 Rev. 4.0 SEQUOYAH UNIT 2 Revision XXX 1BASES APPLICABLE SAFETY ANALYSES (continued)
- Initiate action necessary to protect the public and to estimate themagnitude of any impending threat
.PAM instrumentation that meets the definition of Type A in Regulatory Guide 1.97 satisfies Criterion 3 of 10 CFR 50.36(c)(2)(ii). Category I , non-Type A, instrumentation must be retained in TS because it is intended to assist operators in minimizing the consequences of accidents.
Therefore, Category I, non-Type A, variables are important for reducing public risk.
LCO The PAM instrumentation LCO provides OPERABILITY requirements for Regulatory Guide 1.97 Type A monitors, which provide information required by the control room operators to perform certain manual actions specified in the unit Emergency Operating Procedures. These manual actions ensure that a system can accomplish its safety function, and are credited in the safety analyses. Additionally, this LCO addresses Regulatory Guide 1.97 instruments that have been designated Category I , non-Type A. The OPERABILITY of the PAM instrumentation ensures there is sufficient information available on selected unit parameters to monitor and assess unit status following an accident. This capability is consistent with the recommendations of Reference
- 1. LCO 3.3.3 requires two OPERABLE channels for most Functions. Two OPERABLE channels ensure no single failure prevents operators from getting the information necessary for them to determine the safety status of the unit, and to bring the unit to and maintain it in a safe condition following an accident. Furthermore, OPERABILITY of two channels allows a CHANNEL CHECK during the post accident phase to confirm the validity of displayed information. More than two channels may be required at some units if the unit specific Regulatory Guide 1.97 analyses (Ref. 1) determined that failure of one accident monitoring channel results in information ambiguity (that is, the redundant displays disagree) that could lead operators to defeat or fail to accomplish a required safety function. The exception to the two channel requirement is Penetration Flow Path Containment Isolation Valve (CIV) Position. In this case, the important information is the status of the containment penetrations. The LCO requires one position indicator for each active CIV. This is sufficient to redundantly verify the isolation status of each isolable penetration either via indicated status of the active valve and prior knowledge of a passive 1 1 1 2 1 2 2 2 1 5 PAM Instrumentation B 3.3.3 Westinghouse STS B 3.3.3-4 Rev. 4.0 SEQUOYAH UNIT 2 Revision XXX 1BASES LCO (continued) valve, or via system boundary status. If a normally active CIV is known to be closed and deactivated, position indication is not needed to determine status. Therefore, the position indication for valves in this state is not required to be OPERABLE.
Table 3.3.3-1 provides a list of variables typical of those identified by the unit specific Regulatory Guide 1.97 (Ref.
- 1) analyses. Table 3.3.3-1 in unit specific TS should list all Type A and Category I variables identified by the unit specific Regulatory Guide 1.97 analyses, as amended by the NRC's SER.
Type A and Category I variables are required to meet Regulatory Guide 1.97 Category I (Ref. 2) design and qualification requirements for seismic and environmental qualification, single failure criterion, utilization of emergency standby power, immediately accessible display, continuous readout, and recording of display. Listed below are discussions of the specified instrument Functions listed in Table 3.3.3-1. These discussions are intended as examples of what should be provided for each Function when the unit specific list is prepared. 1, 2. Power Range and Source Range Neutron Flux Power Range and Source Range Neutron Flux indication is provided to verify reactor shutdown. The two ranges are necessary to cover the full range of flux that may occur post accident.
Neutron flux is used for accident diagnosis, verification of subcriticality, and diagnosis of positive reactivity insertion.
3, 4. Reactor Coolant System (RCS) Hot an d Cold Le g Temperatures RCS Hot and Cold Leg Temperatures are Category I variables provided for verification of core cooling and long term surveillance. RCS hot and cold leg temperatures are used to determine RCS subcooling margin. RCS subcooling margin will allow termination of safety injection (SI), if still in progress, or reinitiation of SI if it has been stopped.
RCS subcooling margin is also used for unit stabilization and cooldown control.
1 1 2 2 11, 2. 1 2 THOT and Reactor Coolant TCOLD (Wide Range)Reactor Coolant T HOT and Reactor Coolant TCOLD (Wide Range)Reactor Coolant T HOT and Reactor Coolant TCOLD Reactor coolantreactor coolant PAM Instrumentation B 3.3.3 Westinghouse STS B 3.3.3-5 Rev. 4.0 SEQUOYAH UNIT 2 Revision XXX 1BASES
LCO (continued)
In addition, RCS cold leg temperature is used in conjunction with RCS hot leg temperature to verify the unit conditions necessary to establish natural circulation in the RCS.
Reactor outlet temperature inputs to the Reactor Protection System are provided by two fast response resistance elements and associated transmitters in each loop. The channels provide indication over a range of 32°F to 700°F.
- 5. Reactor Coolant System Pressure (Wide Range)
RCS wide range pressure is a Category I variable provided for verification of core cooling and RCS integrity long term surveillance.
RCS pressure is used to verify delivery of SI flow to RCS from at least one train when the RCS pressure is below the pump shutoff head. RCS pressure is also used to verify closure of man ually closed spray line valves and pressurizer power operated relief valves (PORVs).
In addition to these verifications, RCS pressure is used for determining RCS subcooling margin. RCS subcooling margin will allow termination of SI, if still in progress, or reinitiation of SI if it has been stopped. RCS pressure can also be used:
- to manually restart low head SI,
- as react or coolant pump (RCP) trip criteria, and
- to make a determination on the nature of the accident in progress and where to go next in the procedure.
RCS subcooling margin is also used for unit stabilization and cooldown control.
INSERT 1 1 0 1 B 3.3.3 Insert Page B 3.3.3-5a INSERT 1 1, 2. continued There are a total of four Reactor Coolant System (RCS) Hot and Cold Leg Temperature channels each. One RCS Hot leg temperature channel per loop and one Cold Leg temperature channel per loop.
The instrument loops associated with RCS T HOT are 68-001, -024, -043, and -065. The instrument loops associated with RCS T COLD are 68-018,68-041, 68-060, and 68-083.
- 3. Containment Pressure (Wide Range)
Containment Pressure (Wide Range) is provided for determination of potential for containment breach.
The channels provide indication over a range of -5 to 60 psig. There are a total of two Containment Pressure (Wide Range) channels. The instrument loops associated with Containment Pressure (Wide
Range) are 30-310 and 30-311.
- 4. Containment Pressure (Narrow Range)
Containment Pressure (Narrow Range) is provided for determination of an actual containment breach and if a break is inside or outside
containment. Additionally it is provided to monitor containment conditions following a break inside containment and verifying the accident is properly controlled.
The channels provide indication over a range of -1 to 15 psig. There are a total of two Containment Pressure (Narrow Range) channels.
The instrument loops associated with Containment Pressure (Narrow
Range)30-044 and 30-045.
- 5. Refueling Water Storage Tank Level Refueling Water Storage Tank Level is provided to verify a water source to emergency core cooling systems and containment spray system, determine the time for initiation of cold leg recirculation following a loss of coolant accident, and for event diagnosis.
The channels provide indication over a range of 0% to 100%. There are a total of two Refueling Water Storage Tank Level channels. The instrument loops associated with Refueling Water Storage Tank Level are 63-050 and 63-051.
1 B 3.3.3 Insert Page B 3.3.3-5b INSERT 1 continued
- 6. Reactor Coolant Pressure (Wide Range)
Reactor Coolant Pressure (Wide Range) is provided to determine if the plant is in safe shutdown condition. It is also used for maintaining the proper relationship between RCS pressure and temperature, verifying vessel nondestructive testing criteria, maintain primary inventory subcooled (particularly with loss of offsite power), establish correct conditions for residual heat removal operation, determine whether reactor coolant pump operation should be continued, and determine whether high-head SI should be terminated or reinitiated.
The channels provide indication over a range of 0 to 3000 psig. There are a total of three Reactor Coolant Pressure (Wide Range) channels.
The instrument loops associated with Reactor Coolant Pressure (Wide Range) are 68-062,68-066, and 68-069.
- 7. Pressurizer Level (Wide Range)
Pressurizer Level (Wide Range) is provided to confirm if plant is in a safe shutdown condition. It is also provided to monitor RCS inventory, maintain pressurizer water level, and determine whether SI should be terminated or reinitiated.
The channels provide indication over a range of 0% to 100%. There are a total of three Pressurizer Level (Wide Range) channels. The instrument loops associated with Pressurizer Level (Wide Range) are 68-320,68-335, and 68-339.
- 8. Steam Line Pressure Steam Line Pressure is provided to determine if a high-energy
secondary line rupture occurred. It is also provided to maintain an adequate reactor heat sink and verify auxiliary feedwater to steam generator associated with pipe rupture is isolated. It can be used to monitor secondary side pressure to: (1) verify operation of pressure control steam dump system, (2) maintain plant in safe shutdown condition, and (3) monitor RCS cooldown rate. It is diverse to T cold for natural circulation determination. In addition, it can be used for identification of steam generator tube rupture and determination that faulted steam generator is isolated.
The channels provide indication over a range of 0 to 1200 psig. There are a total of eight Steam Line Pressure channels, two per loop. The instrument loops associated with Steam Line Pressure are 1-002A, 1-002B, 1-009A, 1-009B, 1-020A, 1-020B, 1-027A, and 1-027B 1
B 3.3.3 Insert Page B 3.3.3-5c INSERT 1 continued
- 9. Steam Generator Level - (Wide Range)
Steam Generator Level (Wide Range) is provided to determine if heat sink is being maintained and is used for SI termination for secondary break outside containment.
The channels provide indication over a range of 0 to 100 percent.
There are a total of four Steam Generator Level - (Wide Range) channels, one per steam generator. The instrument loops associated with Steam Generator Level - (Wide Range) are 3-043, 3-056, 3-098, and 3-111.
- 10. Steam Generator Level - (Narrow Range)
Steam Generator Level (Narrow Range) is provided to monitor heat
sink, maintain steam generator water level, determine whether SI should be terminated, and determine which loop has SG tube rupture.
The channels provide indication over a range of 0 to 100 percent.
There are a total of eight Steam Generator Level - (Narrow Range) channels, two per steam generator. The instrument loops associated with Steam Generator Level - (Narrow Range) are 3-039, 3-042, 3-052, 3-055, 3-094, 3-097, 3-107, and 3-110.
- 11. Auxiliary Feedwater Auxiliary Feedwater (AFW) flow is provided to determine if sufficient flow exists to maintain heat sink and for SI termination. The channels provide indication over a range of 0 to 440 gpm. The redundant channel capability for AFW flow consists of a single AFW flow channel for each Steam Generator (four total, one per steam generator) with a diverse channel consisting of three AFW valve position indicators (two
level control valves for the motor driven AFW flowpath and one level control valve for the turbine driven AFW flowpath) for each steam generator (12 total).
The instrument loops associated with AFW flow are 3-163, 3-155, 3-147, and 3-170. The instrument loops associated with AFW valve position indication are 3-164, 3-164A, 3-174, 3-156, 3-156A, 3-173, 3-148, 3-148A, 3-172, 3-171, 3-171A, and 3-175.
1 B3.3.3 Insert Page B 3.3.3-5d INSERT 1 c ontinued 12.Reactor Coolant System Subcooling Margin Monitor Reactor Coolant System Subcooling is provide d for SI termination or reinitiation and maintenance of subcooling during depressurization.The channels provide indication over a range of 200°F subcooled to 35°F superheat. There are a total of two Reactor Coolant System Subcooling Margin Monitor channels. The instru ment loops associat ed with Reactor Coolant System Subcooling Margin Monitor are 94-101 and 94-102.
13.Containment Water Level (Wide Range)
Containmen t Water Level (Wide Range) is provided to verify water source for recirculation mode cooling, determine whether high energy line rupture has occurred inside or outside contai nment, and determine potential for containment breach caused by very h i gh water levels.The channels provide indication over a range of 0% to 100%. There are a total of two Containment Water Level (Wide Range) channels.
The instrument loops associated wit h Containment Water Level (Wide Range) are 63-178 and 63-179.14.Incore Thermocouples Incore thermocouples are provided to verify that the core is being adequately cooled, verify that RCS remains subcooled, and for monitoring the potential for fuel clad breach.The channels provide indication over a range of 200°F to 2300°F.
There are a total of 65 Incore Thermocouples. Each channel consistsof one incore thermocouple. The minimum number of chann els required is two channels per quadrant, eight per core, one/co re quadrant/train. The two required cha nnels in ea ch quadrant shall be in different tr ains.1 B 3.3.3 Insert Page B 3.3.3-5e INSERT 1 continued
- 15. Reactor Vessel Level Instrumentation Reactor Vessel Level indication is provided for determination of core cooling. It is considered to be a more direct and less ambiguous indication of core cooling.
The channels provide indication over a range of 0% to 120% (dynamic range), 0% to 70% (lower range), and 64% to 120% (upper range).
There are a total of six Reactor Vessel Level Instrument channels.
The instrument loops associated with Reactor Vessel Level Dynamic Range are 68-367 and 68- 370. The instrument loops associated with Reactor Vessel Level Lower Range are 68-368 and 68-371. The instrument loops associated with Reactor Vessel Level Upper Range
are 68-369 and 68-372.
- 16. Containment Area Radiation Monitors Containment area radiation monitors are provided for accident diagnosis and SI Termination/Reinitiation.
The channels provide indication over a range of 10 0 to 10 8 R/hr. There are a total of four Containment Area Radiation Monitors. The instrument loops associated with Containment Area Radiation Monitors Upper Compartment are 90-271 and 90-272. The instrument loops associated with Containment Area Radiation Monitors Lower Compartment are 90-273 and 90-274.
- 17. Neutron Flux The Intermediate Range and Source Range Neutron Flux are provided for monitoring reactivity control, determining if plant is subcritical, and to diagnose positive reactivity insertion.
The channels provide indication over a range of 1 to 10 6 CPS (Source Range) and 10
-8 to 200% RTP (Intermediate Range). There are a total of two Source Range channels and two Intermediate Range channels. The instrument loops associated with the Source Range are 92-5001 and 92-5002. The instrument loops associated with the
Intermediate Range are 92-5003 and 92-5004.
1 B 3.3.3 Insert Page B 3.3.3-5f INSERT 1 continued
- 18. ERCW to AFW Valve Position The ERCW to AFW valve position is provided for verification of heat sink availability. There is a total of four motor driven pump instrument loops. For the turbine driven AFW pump there is a total of four instrument loops. Each ERCW to AFW suction line contains two in-series isolation valves, each with its own position indication. Thus, position indication on both valves on a suction line is necessary.
Each channel consists of the two valve position indications associated with the in-series valves in a single suction line.
The instrument loops associated with ERCW to AFW valve position for the Motor Driven Pumps are 3-116A, 3-116B, 3-126A, and 3-126B.
The instrument loops associated with ERCW to AFW valve position
for the Turbine Driven Pump are 3-136A, 3-136B, 3-179A, and 3-179B.
- 19. Containment Isolation Valve Position Containment Isolation valve position is provided for verification of containment isolation. There is one position indication instrument per isolation valve. The Containment Isolation valve position indications are located on Panels TR-A XX-55-6K and TR-B XX-55-6L
1 PAM Instrumentation B 3.3.3 Westinghouse STS B 3.3.3-6 Rev. 4.0 SEQUOYAH UNIT 2 Revision XXX 1BASES
LCO (continued)
RCS pressure is also related to three decisions about depressurization. They are:
- to determine whether to proceed with primary system depressurization,
- to verify termination of depressurization, and
- to determine whether to close accumulator isolation v alves during a controlled cooldown/depressurization.
A final use of RCS pressure is to determine whether to operate the pressurizer heaters.
In some units, RCS pressure is a Type A variable because the operator uses this indication to monitor the cooldo wn of the RCS following a steam generator tube rupture (SGTR) or small break LOCA. Operator actions to maintain a controlled cooldown, such as adjusting steam generator (SG) pressure or level, would use this indication. Furthermore, RCS pressure is one factor that may be used in decisions to terminate RCP operation.
- 6. Reactor Vessel Water Level Reactor Vessel Water Level is provided for verification and long term surveillance of core cooling. It is also used for accident diagnosis and to determine reactor coolant inventory adequacy.
The Reactor Vessel Water Level Monitoring System provides a direct measurement of the collapsed liquid level above the fuel alignment plate. The collapsed level represents the amount of liquid mass that is in the reactor vessel above the core. Measurement of the collapsed water level is selected because it is a direct indication of the water inventory.
- 7. Containment Sump Water Level (Wide Range)
Containment Sump Water Level is provided for verification and long term surveillance of RCS integrity.
Containment Sump Water Level is used to determine:
- containment sump level accident diagnosis, 1 PAM Instrumentation B 3.3.3 Westinghouse STS B 3.3.3-7 Rev. 4.0 SEQUOYAH UNIT 2 Revision XXX 1BASES
LCO (continued)
- when to begin the recirculation procedure, and
- whether to terminate SI, if still in progress.
- 8. Containment Pressure (Wide Range)
Containment Pressure (Wide Range) is provided for verification of RCS and containment OPERABILITY.
Containment pressure is used to verify closure of main steam isolation valves (MSIVs), and containment spray Phase B isola tion when High-3 containment pressure is reached.
- 9. Penetration Flow Path Containment Isolation Valve Position Penetration Flow Path CIV Position is provided for verification of Containment OPERABILITY, and Phase A and Phase B isolation.
When used to verify Phase A and Phase B isolation, the important information is the isolation status of the containment penetrations. The LCO requires one channel of valve position indication in the control room to be OPERABLE for each active CIV in a containment penetration flow path, i.e., two total channels of CIV position indication for a penetration flow path with two active valves. For containment penetrations with only one active CIV having control room indication, Note (b) requires a single channel of valve p osition indication to be OPERABLE. This is sufficient to redundantly verify the isolation status of each isolable penetration either via indicated status of the active valve, as applicable, and prior knowledge of a passive valve, or via system boundary status. If a normally active CIV is known to be closed and deactivated, position indication is not needed to determine status. Therefore, the position indication for valves in this state is not required to be OPERABLE. Note (a) to the Required Channels states that the Function is not required for isolation valves whose associated penetration is isolated by at least one closed and deactivated automatic valve, closed manual valve, blind flange, or check valve with flow through the valve secured.
Each penetration is treated separately and each penetration flow path is considered a separate function. Therefore, separate Condition entry is allowed for each inoperable penetration flow path.
1 PAM Instrumentation B 3.3.3 Westinghouse STS B 3.3.3-8 Rev. 4.0 SEQUOYAH UNIT 2 Revision XXX 1BASES
LCO (continued)
- 10. Containment Area Radiation (High Rang e) Containment Area Radiation is provided to monitor for the potential of significant radiation releases and to provide release assessment for use by operators in determining the need to invoke site emergency plans. Containment radiation level is used to determine if a high energy line break (HELB) has occurred, and whether the event is inside or outside of containment.
- 11. Pressurizer Level Pressurizer Level is used to determine whether to terminate SI, if still in progress, or to reinitiate SI if it has been stopped. Knowledge of pressurizer water level is also used to verify the unit conditions necessary to establish natural circulation in the RCS and to verify that the unit is maintained in a safe shutdown condition.
- 12. Steam Generator Water Leve l (Wide Range)
SG Water Level is provided to monitor operation of decay heat removal via the SGs. The Category I indication of SG level is the extended startup range level instrumentat ion. The extended startup range level covers a span of 6 inches to 394 inches above the lower tubesheet. The measured differential pressure is displayed in inches of water at 68°F.
Temperature compensation of this indication is performed manually by the operator. Redundant monitoring capability is provided by two trains of instrumentation. The uncompensated level signal is input to the unit computer, a control room indicator, and the Emergency Feedwater Control System.
SG Water Level (Wide Range) is used to:
- identify the faulted SG following a tube rupture,
- verify that the intact SGs are an adequate heat sink for the reactor,
- determine the nature of the accident in progress (e.g., verify an SGTR), and
- verify unit conditions for termination of S I during secondary unit HELBs outside containment.
1 PAM Instrumentation B 3.3.3 Westinghouse STS B 3.3.3-9 Rev. 4.0 SEQUOYAH UNIT 2 Revision XXX 1BASES
LCO (continued)
At some units, operator action is based on the control room indication of SG level. The RCS response during a design basis small break LOCA depends on the break size. For a certain range of break sizes, the boiler condenser mode of heat transfer is necessary to remove decay heat. Extended startup range level is a Type A variable because the operator must manually raise and control SG level to establish boiler condenser heat tr ansfer. Operator action is initiated on a loss of subcooled margin. Feedwater flow is increased until the indicated extended startup range level reaches the boiler condenser setpoint. 13. Condensate Storage Tank (CST) Level CST Level is provided to en sure water supply for auxiliary feedwater (AFW). The CST provides the ensured safety grade water supply for the AFW System. The CST consists of two identical tanks connected by a common outlet header. Inventory is monitored by a 0 inch to 144 inch level indication for each tank. CST Level is displayed on a control room indicator, strip chart recorder, and unit computer. In addition, a control room annunciator alarms on low level.
At some units, CST Level is considered a Type A variable because the control room meter and annunciator are considered the primary indication used by the operator.
The DBAs that require AFW are the loss of electric power, steam line break (SLB), and small break LOCA.
The CST is the initial source of water for the AFW System. However, as the CST is depleted, manual operator action is necessary to replenish the CST or align suction to the AFW pumps from the hotwell. 14, 15, 16, 17.
Core Exit Temperature Core Exit Temperature is provided for verification and long term surveillance of core cooling.
An evaluation was made of the minimum number of valid core exit thermocouples (CET) necessary for measuring core cooling. The evaluation determined the reduced complement of CETs necessary to detect initial core recovery and trend the ensuing core heatup. The evaluations account for core nonuniformities, including incore effects of the radial decay power distribution, excore effects of condensate runback in the hot legs, and nonuniform inlet 1
PAM Instrumentation B 3.3.3 Westinghouse STS B 3.3.3-10 Rev. 4.0 SEQUOYAH UNIT 2 Revision XXX 1BASES
LCO (continued)
temperatures. Based on these evaluations, adequate core cooling is ensured with two valid Core Exit Temperature channels per quadrant with two CETs per required channel. The CET pair are oriented radially to permit evaluation of core radial decay p ower distribution. Core Exit Temperature is used to determine whether to terminate SI, if still in progress, or to reinitiate SI if it has been stopped. Core Exit Temperature is also used for unit stabilization and cooldown control.
Two OPERABLE channels of Core Exit Temperature are required in each quadrant to provide indication of radial distribution of the coolant temperature rise across representative regions of the core. Power distribution symmetry was considered in determining the specific number and locations provided for diagnosis of local core problems. Therefore, two randomly selected thermocouples are not sufficient to meet the two thermocouples per channel requirement in any quadrant. The two thermocouples in each channel must meet the additional requirement that one is located near the center of the core and the other near the core perimeter, such that the pair of Core Exit Temperatures indicate the radial temperature gradient across their core quadrant. Unit specific evaluations in respo nse to Item II.F.2 of NUREG
-0737 (Ref.
- 3) should have identified the thermocouple pairings that satisfy these requirements. Two sets of two thermocouples ensure a single failure will not disable the ability to determine the radial temperature gradient.
- 18. Auxiliary Feedwater Flow AFW Flow is provided to monitor operation of decay heat removal via the SGs.
The AFW Flow to each SG is determined from a differential pressure measurement calibrated for a range of 0 gpm to 1200 gpm. Redundant monitoring capability is provided by two independent trains of instrumentation for each SG. Each differential pressure transmitter provides an input to a control room indicator and the unit computer. Since the primary indication used by the operator during an accident is the control room indicator, the PAM specification deals specifically with this portion of the instrument channel.
AFW flow is used three ways:
- to determine whether to terminate SI if still in progress, in conjunction with SG water level (narrow range), and 1
PAM Instrumentation B 3.3.3 Westinghouse STS B 3.3.3-11 Rev. 4.0 SEQUOYAH UNIT 2 Revision XXX 1BASES
LCO (continued)
At some units, AFW flow is a Type A variable because operator action is required to throttle flow during an SLB accident to prevent the AFW pumps from operating in runout conditions. AFW flow is also used by the operator to verify that the AFW System is delivering the correct flow to each SG. However, the primary indication used by the operator to ensure an adequate i nventory is SG level.
APPLICABILITY The PAM instrumentation LCO is applicable in MODES 1, 2, and 3. These variables are related to the diagnosis and pre-planned actions required to mitigate DBAs. The applicable DBAs are assumed to occur in MODES 1, 2, and 3. In MODES 4, 5, and 6, unit conditions are such that the likelihood of an event that would require PAM instrumentation is low; therefore, the PAM instrumentation is not required to be OPERABLE in
these MODES.
ACTIONS A Note has been added in the ACTIONS to clarify the application of Completion Time rules. The Conditions of this Specification may be entered independently for each Function listed on Table 3.3.3-1. The Completion Time(s) of the inoperable channel(s) of a Function will be tracked separately for each Function starting from the time the Condition was entered for that Function.
A.1 Condition A applies when one or more Functions have one required channel that is inoperable. Required Action A.1 requires restoring the inoperable channel to OPERABLE status within 30 days. The 30 day Completion Time is based on operating experience and takes into account the remaining OPERABLE channel (or in the case of a Function that has only one required channel, other non-Regulatory Guide 1.97 instrument channels to monitor the Function), the passive nature of the instrument (no critical automatic action is assumed to occur from these instruments), and the low probability of an event requiring PAM instrumentation during this interval.
A Note is added stating that this ACTION is not applicable to Function 16, which has its own ACTION for one channel inoperable.
1 5INSERT 2 B 3.3.3 Insert Page B 3.3.3-11 INSERT 2 On a penetration where the position indication is declared inoperable on a valve but on the opposite side of the penetration a required containment isolation valve does not exist (such as with a closed system or a check valve), only Condition A must be entered. However, valves FCV-63-158 & -172 are both inboard penetration valves, but if both valves have inoperable position indication, Condition C must be entered until at least one of the valve's position indication is restored to OPERABLE status. Valves FCV-30-46 & VLV-30-571, FCV-30-47 &
VLV-30-572, and FCV-30-48 & VLV-30-573 are all outboard penetration valves, but if both valves have inoperable position indication, Condition C must be entered until at least one of the valve's position indication is restored to OPERABLE status.
1 PAM Instrumentation B 3.3.3 Westinghouse STS B 3.3.3-12 Rev. 4.0 SEQUOYAH UNIT 2 Revision XXX 1BASES ACTIONS (continued)
B.1 Condition B applies when the Required Action and associated Completion Time for Condition A are not met. This Required Action specifies initiation of actions in Specification 5.6.5, which requires a written report to be submitted to the NRC immediately. This report discusses the results of the root cause evaluation of the inoperability and identifies proposed restorative actions. This action is appropriate in lieu of a shutdown requirement since alternative actions are identified before loss of functional capability, and given the likelihood of unit conditions that would require information provided by this instrumentation.
C.1 Condition C applies when one or more Functions have two inoperable required channels (i.e., two channels inoperable in the same Function). Required Action C.1 requires restoring one channel in the Function(s) to OPERABLE status within 7 days. The Completion Time of 7 days is based on the relatively low probability of an event requiring PAM instrument operation and the availability of alternate means to obtain the required information. Continuous operation with two required channels inoperable in a Function is not acceptable because the alternate indications may not fully meet all performance qualification requirements applied to the PAM instrumentation. Therefore, requiring restoration of one inoperable channel of the Function limits the risk that the PAM Function will be in a degraded condition should an accident occur.
D.1 Condition D applies when the Required Action and associated Completion Time of Condition C is not met. Required Action D.1 requires entering the appropriate Condition referenced in Table 3.3.3-1 for the channel immediately. The applicable Condition referenced in the Table is Function dependent. Each time an inoperable channel has not met the
Required Action of Condition C, and the associated Completion Time has expired, Condition D is entered for that channel and provides for transfer to the appropriate subsequent Condition.
G GConditions C, D, E, or F are GCondition C, D, E, or F G INSERT 3 5 5 B 3.3.3 Insert Page B 3.3.3-12 INSERT 3 D.1 Condition D applies when one or more Functions have three required channels that are inoperable. A Note is included that states that this ACTION is only applicable to Functions 6 and 7. Required Action D.1 requires restoring one inoperable channel to OPERABLE status within 48 hours5.555556e-4 days <br />0.0133 hours <br />7.936508e-5 weeks <br />1.8264e-5 months <br />.
E.1 Condition E applies when one or more steam generators have one AFW flow rate channel and one AFW valve position channel on the same steam generator inoperable. Required Action E.1 requires restoring one inoperable channel to OPERABLE status within 7 days.
F.1 and F.2
Condition F applies when one or more Containment Area Radiation Monitors have one required channel inoperable. Required Action F.1 requires initiating an alternate method of monitoring containment area radiation within 72 hours8.333333e-4 days <br />0.02 hours <br />1.190476e-4 weeks <br />2.7396e-5 months <br />. Required Action F.2 requires restoring the inoperable channel(s) to OPERABLE status within 30 days.
5 PAM Instrumentation B 3.3.3 Westinghouse STS B 3.3.3-13 Rev. 4.0 SEQUOYAH UNIT 2 Revision XXX 1BASES
ACTIONS (continued)
E.1 and E.2 If the Required Action and associated Completion Time of Condition C is not met and Table 3.3.3-1 directs entry into Condition E, the unit must be brought to a MODE where the requirements of this LCO do not apply. To achieve this status, the unit must be brought to at least MODE 3 within 6 hours6.944444e-5 days <br />0.00167 hours <br />9.920635e-6 weeks <br />2.283e-6 months <br /> and MODE 4 within 12 hours1.388889e-4 days <br />0.00333 hours <br />1.984127e-5 weeks <br />4.566e-6 months <br />.
The allowed Completion Times are reasonable, based on operating experience, to reach the required unit conditions from full power conditions in an orderly manner and without challenging unit systems.
F.1 At this unit, alternate means of monitoring Reactor Vessel Water Level and Containment Area Radiation have be en developed and tested. These alternate means may be temporarily installed if the normal PAM channel cannot be restored to OPERABLE status within the allotted time.
If these alternate means are used, the Required Action is not to shut down the unit but rather to follow the directions of Specification 5.6.5, in the Administrative Controls section of the TS. The report provided to the NRC should discuss the alternate means used, describe the degree to which the alternate means are equivalent to the installed PAM channels, justify the areas in which they are not equivalent, and provide a schedule for restoring the normal PAM channels.
SURVEILLANCE A Note has been added to the SR Table to clarify that SR 3.3.3.1 and REQUIREMENTS SR 3.3.3.
3 apply to each PAM instrumentation Function in Table 3.3.3-1.
Performance of the CHANNEL CHECK ensures that a gross instrumentation failure has not occurred. A CHANNEL CHECK is normally a comparison of the parameter indicated on one channel to a similar parameter on other channels. It is based on the assumption that instrument channels monitoring the same parameter should read approximately the same value. Significant deviations between the two instrument channels could be an indication of excessive instrument drift in one of the channels or of something even more serious. A CHANNEL CHECK will detect gross channel failure; thus, it is key to verifying the instrumentation continues to operate properly between each CHANNEL CALIBRATION. The high radiation instrumentation should be compared to similar unit instruments located throughout the unit.
H I H 5 5 5 1, D, E, or F 2 5Condition F requires initiation of PAM Instrumentation B 3.3.3 Westinghouse STS B 3.3.3-14 Rev. 4.0 SEQUOYAH UNIT 2 Revision XXXBASES
SURVEILLANCE REQUIREMENTS (continued)
Agreement criteria are determined by the unit staff, based on a combination of the channel instrument uncertainties, including isolation, indication, and readability. If a channel is outside the criteria, it may be an indication that the sensor or the signal processing equipment has drifted outside its limit. If the channels are within the criteria, it is an indication that the channels are OPERABLE.
As specified in the SR, a CHANNEL CHECK is only required for those channels that are normally energized.
[ The Frequency of 31 days is based on operating experience that demonstrates that channel failure is rare. The CHANNEL CHECK supplements less formal, but more frequent, checks of channels during normal operational use of the displays associated with the LCO required channels.
OR The Surveillance Frequency is controlled under the Surveillance Frequency Control Program.
REVIEWER'S NOTE-----------------------------------
Plants controlling Surveillance Frequencies under a Surveillance Frequency Control Program should utilize the appropriate Frequency description, given above, and the appropriate choice of Frequency in the Surveillance Requirement.
CHANNEL CALIBRATION is a complete check of the instrument loop, including the sensor. The test verifies that the channel responds to measured parameter with the necessary range and accuracy. This SR is modified by a Note that excludes neutron detectors. The calibration method for neutron detectors is specified in the Bases of LCO 3.3.1, "Reactor Trip System (RTS) Instrumentation." Whenever a sensing element is replaced, the next required CHANNEL CALIBRATION of the
Core Exit thermocouple sensors is accomplished by an inplace cross calibration that compares the other sensing elements with the recently installed sensing element.
[ The Frequency of 18 months is based on operating experience and consistency with the typical industry refueling cycle. 6 3 6two Notes. The first INSERT 4 5 5Incore 1 B 3.3.3 Insert Page B 3.3.3-14 INSERT 4 The second Note excludes the Containment Area Radiation Monitors detectors from a CHANNEL CALIBRATION for decade ranges above 10R/h. A CHANNEL CALIBRATION for the Containment Area Radiation Monitors detectors for decade ranges below 10R/h is performed by a single calibration check with either an installed or portable gamma source.
1 PAM Instrumentation B 3.3.3 Westinghouse STS B 3.3.3-15 Rev. 4.0 BASES
SURVEILLANCE REQUIREMENTS (continued)
OR The Surveillance Frequency is controlled under the Surveillance Frequency Control Program.
REVIEWER'S NOTE-----------------------------------
Plants controlling Surveillance Frequencies under a Surveillance Frequency Control Program should utilize the appropriate Frequency description, given above, and the appropriate choice of Frequency in the Surveillance Requirement.
]
REFERENCES
[ 1. Unit specific document (e.g., FSAR, NRC Regulatory Guide 1.97 SER letter)
. ]
- 2. Regulatory Guide 1.97, [date]. 3. NUREG-0737, Supplement 1, "TMI Action Items." Revision 2, December 1980 3 6 1SEQUOYAH UNIT 2 Revision XXX 1SQN-EEB-PS-PAM-0001, PAM Variable QA Data - Base JUSTIFICATION FOR DEVIATIONS ITS 3.3.3 BASES, POST ACCIDENT MONITORING (PAM) INSTRUMENTATION Sequoyah Unit 1 and Unit 2 Page 1 of 1 1. Changes are made (additions, deletions, and/or changes) to the ISTS Bases that reflect the plant specific nomenclature, number, reference, system description, analysis, or licensing basis description.
- 2. Regulatory Guide (RG) 1.97, Instrumentation for Light-Water-Cooled Nuclear Power Plants to Assess Plant and Environs Conditions During and Following an Accident, Revision 2, (RG 1.97-R2) identifies categories that provide a graded approach to requirements depending on the importance to safety of the measurement of a specific variable, designating them as either Category 1, 2, or 3 variables. Changes are made to the ITS Bases to conform to the RG 1.97-R2 convention for identifying the different categories.
- 3. The Reviewer's Note has been deleted. This information is for the NRC reviewer to be keyed into what is needed to meet this requirement. This Note is not meant to be retained in the final version of the plant specific submittal.
- 4. Editorial changes made for enhanced clarity.
- 5. Changes are made to be consistent with changes made to the Specification.
- 6. ISTS SR 3.3.3.1 and SR 3.3.3.2 (ITS SR 3.3.3.1 and SR 3.3.3.2) provide two options for controlling the Frequencies of Surveillance Requirements. SQN is proposing to control the Surveillance Frequencies under the Surveillance Frequency Control Program. Therefore, the Frequency for ITS SR 3.3.3.1 and ITS SR 3.3.3.2 are "In accordance with the Surveillance Frequency Control Program."
Specific No Significant Haza rds Considerations (NSHCs)
DETERMINATION OF NO SIGNIFICANT HAZARDS CONSIDERATIONS ITS 3.3.3, POST ACCIDENT MONITORING (PAM) INSTRUMENTATION Sequoyah Unit 1 and 2 Page 1 of 1 There are no specific No Significant Hazards Considerations for this Specification.
ATTACHMENT 4 ITS 3.3.4, REMOTE SHUTDOWN MONITORING INSTRUMENTATION
Current Technical Specification (CTS) Markup and Discussion of Changes (DOCs)
A01ITS ITS 3.3.4 INSTRUMENTATION REMOTE SHUTDOWN INSTRUMENTATION LIMITING CONDITION FOR OPERATION 3.3.3.5 The remote shutdown monitoring instrumentation channels shown in Table 3.3-9 shall be OPERABLE with readouts displayed external to the control room.
APPLICABILITY
- MODES 1, 2 and 3.
ACTION: With the number of OPERABLE remote shutdown monitoring channels less than required by Table 3.3-9, restore the inoperable channel(s) to OPERABLE status within 7 days, or be in HOT SHUTDOWN within the next 12 hours1.388889e-4 days <br />0.00333 hours <br />1.984127e-5 weeks <br />4.566e-6 months <br />.
SURVEILLANCE REQUIREMENTS 4.3.3.5 Each remote shutdown monitoring instrumentation channel shall be demonstrated OPERABLE by performance of the CHANNEL CHECK and CHANNEL CALIBRATION operations at the frequencies shown in Table 4.3-6.
April 11, 2005 SEQUOYAH - UNIT 1 3/4 3-50 Amendment No. 301 Page 1 of 10 LA01 LA01LCO 3.3.4 Applicabilit y SR 3.3.4.1, SR 3.3.4.2 ACTION A ACTION B Add proposed ACTIONS Note A02Add proposed Required Action B.1 M01Add proposed SR 3.3.4.2 Note 1 L03 L01for each required instrumentation channel that is normally energized L02 30 A01ITS ITS 3.3.4 TABLE 3.3-9 REMOTE SHUTDOWN MONITORING INSTRUMENTATION INSTRUMENT
READOUT LOCATION MEASUREMENT RANGE MINIMUM CHANNELS OPERABLE
- 1.
Source Range Nuclear Flux NOTE 1 1 to 1 x 10 6 cps 1
- 2.
Reactor Trip Breaker Indication at trip switchgear OPEN-CLOSE 1/trip breaker
- 3.
Reactor Coolant Temperature
- Hot Leg NOTE 1 0-650°F 1/loop
- 4.
Pressurizer Pressure NOTE 1 0-3000 psig 1 5.
Pressurizer Leve1 NOTE 1 0-100% 1
- 6.
Steam Generator Pressure NOTE 1 0-1200 psig 1/steam generator
- 7.
Steam Generator Leve1 NOTE 2 or near Auxilary F. W. Pump 0-100% 1/steam generator
- 8.
Deleted 9.
RHR Flow Rate NOTE 1 0-4500 gpm 1
- 10.
RHR Temperature NOTE 1 50-400°F 1
- 11.
Auxiliary Feedwater Flow Rate NOTE 1 0-440 gpm 1/steam generator
May 4, 1989 SEQUOYAH - UNIT 1 3/4 3-51 Amendment No. 113
Page 2 of 10 LA01 A01ITS ITS 3.3.4 TABLE 3.3-9 (Continued)
REMOTE SHUTDOWN MONITORING INSTRUMENTATION
INSTRUMENT READOUT LOCATION MEASUREMENT RANGE MINIMUM CHANNELS OPERABLE
- 12. Pressurizer Relief Tank Pressure NOTE 1 0-100 psig 1 13. Containment Pressure NOTE 1 -1 to +15 psig 1 NOTE 1: Auxiliary Control Room Panel 1-L-10 NOTE 2: Auxiliary Control Room Panels 1-L-11A and 1-L-11B
August 3, 1982 SEQUOYAH - UNIT 1 3/4 3-52 Amendment No. 15
Page 3 of 10 LA01 A01ITS ITS 3.3.4 TABLE 4.3-6 REMOTE SHUTDOWN MONITORING INSTRUMENTATION SURVEILLANCE REQUIREMENTS INSTRUMENT CHANNEL CHECK CHANNEL CALIBRATION
- 1. Source Range Nuclear Flux M R 2. Reactor Trip Breaker Indication M N.A. 3. Reactor Coolant Temperature
- Hot Leg M R
- 4. Pressurizer Pressure M R 5. Pressurizer Leve1 M R 6. Steam Generator Pressure M R
- 7. Steam Generator Leve1 M R
- 8. Deleted
- 11. Auxiliary Feedwater Flow Rate M R 12. Pressurizer Relief Tank Pressure M R 13. Containment Pressure M R
May 4, 1989 SEQUOYAH - UNIT 1 3/4 3-53 Amendment No. 15, 113 LA02In accordance with the Surveillance Frequency Control Program SR 3.3.4.1 SR 3.3.4.2 LA01SR 3.3.4.2 Note 2 Page 4 of 10 A01ITS ITS 3.3.4 CHLORINE DETECTION SYSTEMS LIMITING CONDITION FOR OPERATION
This specification deleted.
October 30, 1987 SEQUOYAH - UNIT 1 3/4 3-54 Amendment No. 62 Page 5 of 10 A01ITS ITS 3.3.4 INSTRUMENTATION REMOTE SHUTDOWN INSTRUMENTATION LIMITING CONDITION FOR OPERATION 3.3.3.5 The remote shutdown monitoring instrumentation channels shown in Table 3.3-9 shall be OPERABLE with readouts displayed external to the control room.
APPLICABILITY
- MODES 1, 2 and 3.
ACTION: With the number of OPERABLE remote shutdown monitoring channels less than required by Table 3.3-9 , restore the inoperable channel(s) to OPERABLE status within 7 days, or be in HOT SHUTDOWN within the next 12 hours1.388889e-4 days <br />0.00333 hours <br />1.984127e-5 weeks <br />4.566e-6 months <br />.
SURVEILLANCE REQUIREMENTS 4.3.3.5 Each remote shutdown monitoring instrumentation channel shall be demonstrated OPERABLE by performance of the CHANNEL CHECK and CHANNEL CALIBRATION operations at the frequencies shown in Table 4.3-6.
April 11, 2005 SEQUOYAH - UNIT 2 3/4 3-51 Amendment No. 290 Page 6 of 10 LA01 LA01LCO 3.3.4 Applicabilit y SR 3.3.4.1, SR 3.3.4.2 ACTION A ACTION B Add proposed ACTIONS Note.
A02Add proposed Required Action B.1.
M01 L03Add proposed SR 3.3.4.2 Note 1.
L01for each required instrumentation channel that is normally energized L02 30 A01ITS ITS 3.3.4 TABLE 3.3-9 REMOTE SHUTDOWN MONITORING INSTRUMENTATION INSTRUMENT READOUT LOCATIO N MEASUREMENT RANGE MINIMUM CHANNELS OPERABLE 1.Source Range Nuclea r Flux NOTE 1 1 to 1 x 10 6 cps 1 2.Reactor Trip Brea kerIndication at trip switchgear OPEN-CLOSE 1/trip breaker 3.Reactor Cool antTemperature
- Hot Leg NOTE 1 0-650 o F 1/loop 4.Pressurizer Pressure NOTE 1 0-3000 psig 1 5.Pressurizer Level NOTE 1 0-100%1 6.Steam Gene ratorPressure NOTE 1 0-1200 psig 1/steam generator 7.Steam Generator Level NOTE 2 or near Auxila ry F. W. Pump 0-100%1/steam generator 8.Deleted 9.RHR Flow Rate NOTE 1 0-4500 gpm 1 10.RHR Temperature NOTE 1 50-400 o F 1 11.Auxiliary Feedwater Flow Rate NOTE 1 0-440 gpm 1/steam generator May 4, 1989 SEQUOYAH - UNIT 2 3/4 3-52 Amendment No. 67, 103 Page 7 of 10 LA01 A01ITS ITS 3.3.4 TABLE 3.3-9 (Continued)
REMOTE SHUTDOWN MONITORING INSTRUMENTATION
INSTRUMENT READOUT LOCATION MEASUREMENT RANGE MINIMUM CHANNELS OPERABLE 12. Pressurizer Relief Tank Pressure NOTE 1 0-100 psig 1 13. Containment Pressure NOTE 1 -1 to +15 psig 1 NOTE 1: Auxiliary Control Room Panel 2-L-10 NOTE 2: Auxiliary Control Room Panels 2-L-11A and 2-L-11B
August 3, 1982 SEQUOYAH - UNIT 2 3/4 3-53 Amendment No. 6
Page 8 of 10 LA01 A01ITS ITS 3.3.4 TABLE 4.3-6 REMOTE SHUTDOWN MONITORING INSTRUMENTATION SURVEILLANCE REQUIREMENTS
INSTRUMENT CHANNEL CHECK CHANNEL CALIBRATION
- 1. Source Range Nuclear Flux M R 2. Reactor Trip Breaker Indication M N.A. 3. Reactor Coolant Temperature
- Hot Leg M R 4. Pressurizer Pressure M R 5. Pressurizer Level M R 6. Steam Generator Pressure M R 7. Steam Generator Level M R 8. Deleted 9. RHR Flow Rate M R 10. RHR Temperature M R 11. Auxiliary Feedwater Flow Rate M R 12. Pressurizer Relief Tank Pressure M R 13. Containment Pressure M R
May 4, 1989 SEQUOYAH - UNIT 2 3/4 3-54 Amendment No. 20, 103 LA02In accordance with the Surveillance Frequency Control Program SR 3.3.4.1 SR 3.3.4.2 LA01Page 9 of 10 SR 3.3.4.2 Note 2 A01ITS ITS 3.3.4 INSTRUMENTATION CHLORINE DETECTION SYSTEMS LIMITING CONDITION FOR OPERATION This specification deleted.
October 30, 1987 SEQUOYAH - UNIT 2 3/4 3-55 Amendment No. 54
Page 10 of 10 DISCUSSION OF CHANGES ITS 3.3.4, REMOTE SHUTDOWN MONITORING INSTRUMENTATION Sequoyah Unit 1 and Unit 2 Page 1 of 4 ADMINISTRATIVE CHANGES A01 In the conversion of the Sequoyah Nuclear Plant (SQN) Current Technical Specifications (CTS) to the plant specific Improved Technical Specifications (ITS), certain changes (wording preferences, editorial changes, reformatting, revised numbering, etc.) are made to obtain consistency with NUREG-1431, Rev. 4.0, "Standard Technical Specifications-Westinghouse Plants" (ISTS) and additional Technical Specification Task Force (TSTF) travelers included in this
submittal. These changes are designated as administrative changes and are acceptable because they do not result in technical changes to the CTS. A02 CTS 3.3.3.5 ACTION provides the compensatory actions to take when a remote shutdown monitoring channel is inoperable. ITS 3.3.4 ACTIONS provide the compensatory actions to take for inoperable remote shutdown monitoring instrumentation functions. ITS 3.3.4 ACTIONS contain a NOTE that allows separate Condition entry for each Function. This modifies the CTS by providing a specific allowance to enter the ACTION(s) for each remote shutdown monitoring instrumentation Function that is inoperable. This change is acceptable because it clearly states the current requirement. The CTS considers each remote shutdown monitoring instrument Function to be separate and independent from the others. This change is designated as administrative because it does not result in a technical change to the CTS. MORE RESTRICTIVE CHANGES M01 CTS 3.3.3.5 ACTION requires that if the remote shutdown monitoring channel cannot be restored to OPERABLE status within 7 days, to be in HOT SHUTDOWN within the next 12 hours1.388889e-4 days <br />0.00333 hours <br />1.984127e-5 weeks <br />4.566e-6 months <br />. ITS 3.3.4 ACTION B requires that if the required channel cannot be restored to OPERABLE status within 30 days, then be in MODE 3 within 6 hours6.944444e-5 days <br />0.00167 hours <br />9.920635e-6 weeks <br />2.283e-6 months <br /> and in MODE 4 within 12 hours1.388889e-4 days <br />0.00333 hours <br />1.984127e-5 weeks <br />4.566e-6 months <br />. (See DOC L01 for a discussion of restoring the remote shutdown monitoring channel to OPERABLE status from 7 days to 30 days.) This changes the CTS by requiring the unit to be in MODE 3 within 6 hours6.944444e-5 days <br />0.00167 hours <br />9.920635e-6 weeks <br />2.283e-6 months <br />. The purpose of ITS 3.3.4 Required Action B.1 is to specify an acceptable Completion Time to shut down the unit from full power to MODE 3. This change is acceptable because the proposed Completion Time is sufficient to allow an operator to reduce power from full power to MODE 3 in a controlled manner without challenging unit safety systems. The six hour Completion Time provided to reach MODE 3 from full power is consistent with the time provided in similar Actions in both the CTS and ITS. The change has been designated as more restrictive because it specifies the amount of time allocated to place the unit in MODE 3.
DISCUSSION OF CHANGES ITS 3.3.4, REMOTE SHUTDOWN MONITORING INSTRUMENTATION Sequoyah Unit 1 and Unit 2 Page 2 of 4 RELOCATED SPECIFICATIONS None
REMOVED DETAIL CHANGES LA01 (Type 1 - Removing Details of System Design and System Description, Including Design Limits) CTS 3.3.3.5 requires the remote shutdown monitoring instrumentation channels in Table 3.3-9 to be OPERABLE with the readouts displayed external to the control room. CTS Table 3.3-9 lists each of the required remote shutdown monitoring instruments, the readout location, measurement range, and the minimum number of channels required for each instrument. CTS Table 4.3-6 lists the required remote shutdown monitoring instrumentation and their associated Surveillance Requirements. ITS LCO 3.3.4 states that the Remote Shutdown Monitoring Instrumentation Functions shall be OPERABLE. This changes the CTS by moving the details in CTS 3.3.3.5, Table 3.3-9, and Table 4.3-6, with the exception of the Surveillance Requirements, from the Technical Specifications to the ITS Bases.
The removal of these details, which are related to system design, from the Technical Specifications, is acceptable because this type of information is not necessary to be included in the Technical Specifications to provide adequate protection of public health and safety. The ITS still retains the requirements for the remote shutdown monitoring instrumentation to be OPERABLE. Also, this change is acceptable because the removed information will be adequately controlled in the ITS Bases. Changes to the Bases are controlled by the Technical Specification Bases Control Program in Chapter 5. This program provides for the evaluation of changes to ensure the Bases are properly controlled. This change is designated as a less restrictive removal of detail change because information relating to system design is being removed from the Technical Specifications.
LA02 (Type 5 - Removal of SR Frequency to the Surveillance Frequency Control Program) CTS 4.3.3.5 and Table 4.3-6 require that the remote shutdown monitoring instrumentation channels be demonstrated OPERABLE at least once per month by a CHANNEL CHECK and once every 18 months by CHANNEL CALIBRATION. ITS SR 3.3.4.1 and SR 3.3.4.2 require similar Surveillances, but specify the periodic Frequency as, "In accordance with the Surveillance Frequency Control Program." This changes the CTS by moving the specified Frequencies for these SRs and the associated Bases to the Surveillance Frequency Control Program.
The removal of these details related to Surveillance Requirement Frequencies from the Technical Specifications is acceptable, because this type of information is not necessary to be included in the Technical Specifications to provide adequate protection of public health and safety. The existing Surveillance Frequencies are removed from Technical Specifications and placed under licensee control pursuant to the methodology described in NEI 04-10. A new program (Surveillance Frequency Control Program) is being added to the Administrative Controls section of the Technical Specifications describing the control of Surveillance Frequencies. The surveillance test requirements remain DISCUSSION OF CHANGES ITS 3.3.4, REMOTE SHUTDOWN MONITORING INSTRUMENTATION Sequoyah Unit 1 and Unit 2 Page 3 of 4 in the Technical Specifications. The control of changes to the Surveillance Frequencies will be in accordance with the Surveillance Frequency Control Program. The Program shall ensure that Surveillance Requirements specified in the Technical Specifications are performed at intervals sufficient to assure the associated Limiting Conditions for Operation are met. This change is designated as a less restrictive removal of detail change, because the Surveillance Frequencies are being removed from the Technical Specifications.
LESS RESTRICTIVE CHANGES L01 (Category 3 - Relaxation of Completion Time) CTS 3.3.3.5 ACTION requires, in part, to restore the inoperable channel(s) to OPERABLE status within 7 days or be in HOT SHUTDOWN within the next 12 hours1.388889e-4 days <br />0.00333 hours <br />1.984127e-5 weeks <br />4.566e-6 months <br />. ITS 3.3.4 Required Action A.1 requires the restoration of the channel to OPERABLE status in 30 days. This changes the CTS by extending the time allowed to restore the inoperable channel to OPERABLE status from 7 days to 30 days.
The purpose of the CTS 3.3.3.5 ACTIONS is to ensure that the inoperable channels are restored to OPERABLE status in a reasonable amount of time. The ITS 3.3.4 Required Action A.1 30 day Completion Time is based on operating
experience and the low probability of an event that would require evacuation of the control room. This change is acceptable because the Completion Time is consistent with safe operation under the specified Condition, considering the OPERABLE status of the redundant systems or features. This includes the capacity and capability of remaining systems or features, a reasonable time for repairs or replacement, and the low probability of an event requiring control room evacuation occurring during the allowed Completion Time. This change is designated as less restrictive, because ITS allows additional time to restore the inoperable remote shutdown monitoring instrumentation channels to an OPERABLE status than was allowed in CTS.
L02 (Category 7 - Relaxation of Surveillance Frequency) CTS 4.3.3.5 states, in part that each remote shutdown monitoring instrumentation channel shall be demonstrated OPERABLE by performance of a CHANNEL CHECK. ITS SR 3.3.4.1 requires the performance of a CHANNEL CHECK for each required instrumentation channel that is normally energized. This changes the CTS by not requiring a CHANNEL CHECK on normally deenergized instrument channels.
The purpose of CTS 4.3.3.5 is a less formal, but more frequent, check of instrumentation channels during normal operation. CTS 4.3.3.5 requires a CHANNEL CHECK on all instruments either deenergize or energized. ITS SR 3.3.4.1 requires a CHANNEL CHECK on instrumentation channels that are normally energized. These checks ensure a gross failure of instrumentation has not occurred. For those instruments not normally energized, such as the Source Range Neutron Flux, a check of this nature is not required. Additionally, the 18 month CHANNEL CALIBRATION will ensure that the instrument is periodically tested to ensure it responds within the necessary range and accuracy. This change is acceptable because this relaxation has been evaluated to ensure that it provides an acceptable level of equipment reliability. This change is designated as less restrictive because CHANNEL CHECKS on deenergized DISCUSSION OF CHANGES ITS 3.3.4, REMOTE SHUTDOWN MONITORING INSTRUMENTATION Sequoyah Unit 1 and Unit 2 Page 4 of 4 instrumentation channels will be performed less frequently under the ITS than under the CTS.
L03 (Category 6 - Relaxation of Surveillance Requirement Acceptance Criteria)
CTS Table 4.3-6 requires the performance of a Source Range Neutron Flux CHANNEL CALIBRATION. ITS SR 3.3.4.2 contains a similar Surveillance requirement; however, the Surveillance includes a Note (Note 1) that excludes the neutron detectors from the calibration. This changes the CTS by excluding the source range neutron flux neutron detectors from the CHANNEL CALIBRATION Surveillance.
The purpose of ITS SR 3.3.4.2 Note 1 is to exclude the neutron detectors from the CHANNEL CALIBRATION. This change is acceptable because it has been determined that the relaxed Surveillance Requirement acceptance criteria are not necessary to demonstrate that the equipment used to meet the LCO can perform its required function. This change is acceptable because the neutron detectors are passive devices and because of the difficulty in generating an appropriate detector input signal. This change is designated less restrictive because less stringent surveillance requirements are applied in the ITS than in the CTS.
Improved Standard Technical Specifications (ISTS) Markup and Justification for Deviations (JFDs)
Remote Shutdown System 3.3.4 Westinghouse STS 3.3.4-1 Rev. 4.0 CTS Monitoring Instrumentation Amendment XXX SEQUOYAH UNIT 1 1 43.3 INSTRUMENTATION
3.3.4 Remote Shutdown System LCO 3.3.4 The Remote Shutdown System Functions shall be OPERABLE.
APPLICABILITY: MODES 1, 2, and 3.
ACTIONS
NOTE-----------------------------------------------------------
Separate Condition entry is allowed for each Function. -------------------------------------------------------------------------------------------------------------------------------
CONDITION REQUIRED ACTION COMPLETION TIME A. One or more required Functions inoperable.
A.1 Restore required Function to OPERABLE status.
30 days B. Required Action and associated Completion Time not met.
B.1 Be in MODE 3.
AND B.2 Be in MODE 4.
6 hours6.944444e-5 days <br />0.00167 hours <br />9.920635e-6 weeks <br />2.283e-6 months <br />
12 hours1.388889e-4 days <br />0.00333 hours <br />1.984127e-5 weeks <br />4.566e-6 months <br />
SURVEILLANCE REQUIREMENTS SURVEILLANCE FREQUENCY
[ Perform CHANNEL CHECK for each required instrumentation channel that is normally energized.
[ 31 days OR In accordance with the Surveillance
Frequency
Control Program ] ] 3.3.3.5 Applicabilit y DOC A02 ACTION, DOC M01 4.3.3.5, Table 4.3-6 DOC L02 Monitoring Instrumentation Monitoring Instrumentation 1 1 2 3 2 3 ACTION (s)
Remote Shutdown System 3.3.4 Westinghouse STS 3.3.4-2 Rev. 4.0 CTS Monitoring Instrumentation Amendment XXX SEQUOYAH UNIT 1 1 4SURVEILLANCE REQUIREMENTS (continued)
SR 3.3.4.2 Verify each required control circuit and transfer switch is capable of performing the intended function.
[ [18] months OR In accordance with the Surveillance Frequency Control Program ]
3 -------------------------------NOTE------------------------------
Neutron detectors are excluded from CHANNEL CALIBRATION. ---------------------------------------------------------------------
Perform CHANNEL CALIBRATION for each required instrumentation channel.
[ [18] months OR In accordance
with the Surveillance
Frequency Control Program
] SR 3.3.4.4 [ Perform TADOT of the reactor trip breaker open/closed indication.
[ 18 months OR In accordance with the Surveillance Frequency Control Program ] ] 4.3.3.5, Table 4.3-6, 2 7 3 3 5 5 DOC L03 1. 2. Reactor trip breaker indication is excluded from CHANNEL CALIBRATION.
6 S Remote Shutdown System 3.3.4 Westinghouse STS 3.3.4-1 Rev. 4.0 CTS Monitoring Instrumentation Amendment XXX SEQUOYAH UNIT 2 1 43.3 INSTRUMENTATION
3.3.4 Remote Shutdown System LCO 3.3.4 The Remote Shutdown System Functions shall be OPERABLE.
APPLICABILITY: MODES 1, 2, and 3.
ACTIONS
NOTE-----------------------------------------------------------
Separate Condition entry is allowed for each Function. -------------------------------------------------------------------------------------------------------------------------------
CONDITION REQUIRED ACTION COMPLETION TIME A. One or more required Functions inoperable.
A.1 Restore required Function to OPERABLE status.
30 days B. Required Action and associated Completion Time not met.
B.1 Be in MODE 3.
AND B.2 Be in MODE 4.
6 hours6.944444e-5 days <br />0.00167 hours <br />9.920635e-6 weeks <br />2.283e-6 months <br />
12 hours1.388889e-4 days <br />0.00333 hours <br />1.984127e-5 weeks <br />4.566e-6 months <br />
SURVEILLANCE REQUIREMENTS SURVEILLANCE FREQUENCY
[ Perform CHANNEL CHECK for each required instrumentation channel that is normally energized.
[ 31 days OR In accordance with the Surveillance
Frequency
Control Program ] ] 3.3.3.5 Applicabilit y DOC A02 ACTION, DOC M01 4.3.3.5, Table 4.3-6 DOC L02 Monitoring Instrumentation Monitoring Instrumentation 1 1 2 3 2 3 ACTION (s)
Remote Shutdown System 3.3.4 Westinghouse STS 3.3.4-2 Rev. 4.0 CTS Monitoring Instrumentation Amendment XXX SEQUOYAH UNIT 2 1 4SURVEILLANCE REQUIREMENTS (continued)
SR 3.3.4.2 Verify each required control circuit and transfer switch is capable of performing the intended function. [ [18] months OR In accordance with the Surveillance Frequency Control Program ]
3 -------------------------------NOTE------------------------------ Neutron detectors are excluded from CHANNEL CALIBRATION.
Perform CHANNEL CALIBRATION for each required instrumentation channel.
[ [18] months OR In accordance with the Surveillance
Frequency Control Program
] SR 3.3.4.4 [ Perform TADOT of the reactor trip breaker open/closed indication.
[ 18 months OR In accordance with the Surveillance Frequency Control Program ] ] 4.3.3.5, Table 4.3-6, 2 7 3 3 5 5 DOC L03 1. 2. Reactor trip breaker indication is excluded from CHANNEL CALIBRATION.
6 S JUSTIFICATION FOR DEVIATIONS ITS 3.3.4, REMOTE SHUTDOWN MONITORING INSTRUMENTATION Sequoyah Unit 1 and Unit 2 Page 1 of 1 1. ISTS 3.3.4 requires Remote Shutdown System Functions to be OPERABLE. As stated in the ISTS 3.3.4 Bases, these Functions include not only instrumentation to monitor plant parameters, but also control switches and circuits to operate equipment necessary to shutdown and maintain the plant in MODE 3. The requirements of ITS 3.3.4 only include the instrumentation necessary to monitor the prompt shut down to MODE 3, including the necessary instrumentation to support maintaining the unit in a safe condition in MODE 3. This change is consistent with the current licensing basis for the Remote Shutdown Instrumentation in CTS 3.3.3.5. As a result of this change, the Specification title and LCO statement have been changed from "Remote Shutdown System" to "Remote Shutdown Monitoring Instrumentation." 2. The ISTS contains bracketed information and/or values that are generic to Westinghouse vintage plants. The brackets are removed and the proper plant specific information/value is inserted to reflect the current licensing basis.
- 3. ISTS SR 3.3.4.1 and SR 3.3.4.3 (ITS SR 3.3.4.1 and SR 3.3.4.2, respectively) provide two options for controlling the Frequencies of Surveillance Requirements. SQN is proposing to control the Surveillance Frequencies under the Surveillance Frequency Control Program.
- 4. Changes are made (additions, deletions, and/or changes) to the ISTS that reflect the plant specific nomenclature, number, reference, system description, analysis, or licensing basis description.
- 5. ISTS SR 3.3.4.2 requires verification that each required control circuit and transfer switch is capable of performing its intended function. ITS 3.3.4 does not contain this Surveillance Requirements since remote shutdown monitoring instrumentation does not contain control circuits or transfer switches. This change is consistent with the current licensing bases. Additionally, since ISTS SR 3.3.4.2 has been deleted, subsequent Surveillances have been renumbered.
- 6. This change is made to be consistent with existing requirements in CTS Table 4.3-6.
- 7. ISTS SR 3.3.4.4 requires performance of a TADOT of the reactor trip breaker open/closed indication. This requirement has not been included in the SQN ITS. CTS 3.3.3.5 does not contain this requirement. Thus, this deviation from the ISTS has been made to retain the SQN current licensing basis.
Improved Standard Technical Specifications (ISTS) Bases Markup and Bases Justification for Deviations (JFDs)
Remote Shutdown System B 3.3.4 Westinghouse STS B 3.3.4-1 Rev. 4.0 Monitoring Instrumentation 2SEQUOYAH UNIT 1 Revision XXX 1B 3.3 INSTRUMENTATION
B 3.3.4 Remote Shutdown System BASES BACKGROUND The Remote Shutdown System provides the control room operator with sufficient instrumentation and controls to place and maintain the unit in a safe shutdown condition from a location other than the control room. This capability is necessary to protect against the possibility that the control room becomes inaccessible. A safe shutdown condition is defined as MODE 3. With the unit in MODE 3, the Auxiliary Feedwater (AFW)
System and the steam generator (SG) safety valves or the SG atmospheric dump valves (ADVs) can be used to remove core decay heat and meet all safety requirements. The long term supply of water for the AFW System and the ability to borate the Reactor Coolant System (RCS) from outside the control room allows extended operation in MODE 3.
If the control room becomes inaccessible, the operators can establish control at the remote shutdown panel, and place and maintain the unit in MODE 3. Not all controls and necessary transfer switches are located at the remote shutdown panel. Some controls and transfer switches will have to be operated locally at the switchgear, motor control panels, or other local stations. The unit automatically reaches MODE 3 following a unit shutdown and can be maintained safely in MODE 3 for an extended period of time.
The OPERABILITY of the remote shutdown control and instrumentation functions ensures there is sufficient information available on selected unit
parameters to place and maintain the unit in MODE 3 should the control room become inaccessible.
APPLICABLE The Remote Shutdown System is required to provide equipment at SAFETY appropriate locations outside the control room with a capability to ANALYSES promptly shut down and maintain the unit in a safe condition in MODE 3.
The criteria governing the design and specific system requirements of the Remote Shutdown System are located in 10 CFR 50, Appendix A, GDC 19 (Ref. 1).
The Remote Shutdown Sys tem satisfies Criterion 4 of 10 CFR 50.36(c)(2)(ii).
Monitoring InstrumentationMonitoring Instrumentationsupport placing maintaining relief ARVs Main Steam Safety Valves (MSSV) monitor the status of the reactorlocations shown on Table B 3.3.4-1 monitoring support placing maintaining support placingmaintaining Monitoring InstrumentationMonitoring Instrumentation 1 1 2 2 2 1 2 1 1 2 Remote Shutdown System B 3.3.4 Westinghouse STS B 3.3.4-2 Rev. 4.0 Monitoring Instrumentation 2SEQUOYAH UNIT 1 Revision XXX 1BASES
LCO The Remote Shutdown System LCO provides the OPERABILITY requirements of the instrumentation and controls necessary to place and maintain the unit in MODE 3 from a location other than the control room.
The instrumentation and controls required are listed in Table B 3.3.4-1.
The controls, instrumentation, and transfer switches are required for:
- Core reactivity control (initial and long term)
,
- RCS pressure control
,
- Decay heat removal via the AFW System and the SG safety valves or SG ADVs,
- RCS inventory control via charging flow, and
- Safety support systems for the above Functions, including service water, component cooling water, and onsite power, including the diesel generators.
A Function of a Remote Shutdown System is OPERABLE if all instrument and control channels needed to support the Remote Shutdown System Function are OPERABLE. In some cases, Table B 3.3.4-1 may indicate that the required information or control capability is available from several alternate sources. In these cases, the Function is OPERABLE as long as one channel of any of the alternate information or control sources is OPERABLE.
The remote shutdown instrument and control circuits covered by this LCO do not need to be energized to be considered OPERABLE. This LCO is intended to ensure the instruments and control circuits will be OPERABLE if unit conditions require that the Remote Shutdown System be placed in operation.
APPLICABILITY The Remote Shutdown System LCO is applicable in MODES 1, 2, and 3. This is required so that the unit can be placed and maintained in MODE 3 for an extended period of time from a location other than the control room.
This LCO is not applicable in MODE 4, 5, or 6. In these MODES, the facility is already subcritical and in a condition of reduced RCS energy. Under these conditions, considerable time is available to restore
necessary instrument control functions if control room instruments or controls become unavailable. Monitoring Instrumentationsupport placing maintaining monitoring isReactor ; and; ;makeup.monitoring instrumentation is each For Function 7, this case monitoring instrumentationMonitoring InstrumentationMonitoring Instrumentation 1 1 2 1 1 1 2 2 3 3 3monitoring instrumentationchannels the es 3 Remote Shutdown System B 3.3.4 Westinghouse STS B 3.3.4-3 Rev. 4.0 Monitoring Instrumentation 2SEQUOYAH UNIT 1 Revision XXX 1BASES
ACTIONS A Remote Shutdown System division is inoperable when each function is not accomplished by at least one designated Remote Shutdown System channel that satisfies the OPERABILITY criteria for the channel's Function. These criteria are outlined in the LCO section of the Bases.
A Note has been added to the ACTIONS to clarify the application of Completion Time rules. Separate Condition entry is allowed for each Function. The Completion Time(s) of the inoperable channel(s)
/train(s) of a Function will be tracked separately for each Function starting from the time the Condition was entered for that Function.
A.1 Condition A addresses the situation where one or more required Functions of the Remote Shutdown System are inoperable.
This includes the control and transfer switches for any required Function.
The Required Action is to restore the required Function to OPERABLE status within 30 days. The Completion Time is based on operating experience and the low probability of an event that would require evacuation of the control room.
B.1 and B.2 If the Required Action and associated Completion Time of Condition A is not met, the unit must be brought to a MODE in which the LCO does not apply. To achieve this status, the unit must be brought to at least MODE 3 within 6 hours6.944444e-5 days <br />0.00167 hours <br />9.920635e-6 weeks <br />2.283e-6 months <br /> and to MODE 4 within 12 hours1.388889e-4 days <br />0.00333 hours <br />1.984127e-5 weeks <br />4.566e-6 months <br />. The allowed Completion Times are reasonable, based on operating experience, to reach the required unit conditions from full power conditions in an orderly manner and without challenging unit systems.
SURVEILLANCE SR 3.3.4.1 REQUIREMENTS Performance of the CHANNEL CHECK ensures that a gross failure of instrumentation has not occurred. A CHANNEL CHECK is normally a comparison of the parameter indicated on one channel to a similar parameter on other channels. It is based on the assumption that instrument channels monitoring the same parameter should read approximately the same value. Significant deviations between the two instrument channels could be an indication of excessive instrument drift in one of the channels or of something even more serious. CHANNEL CHECK will detect gross channel failure; thus, it is key to verifying that the instrumentation continues to operate properly between each CHANNEL CALIBRATION. Monitoring Instrumentation LCO is not met Monitoring Instrumentation 1 2 1 2 The any required does not satisfy its Remote Shutdown System B 3.3.4 Westinghouse STS B 3.3.4-4 Rev. 4.0 Monitoring Instrumentation 2SEQUOYAH UNIT 1 Revision XXX 1BASES
SURVEILLANCE REQUIREMENTS (continued)
Agreement criteria are determined by the unit staff, based on a combination of the channel instrument uncertainties, including indication and readability. If the channels are within the criteria, it is an indication that the channels are OPERABLE. If a channel is outside the criteria, it may be an indication that the sensor or the signal processing equipment has drifted outside its limit.
As specified in the Surveillance, a CHANNEL CHECK is only required for those channels which are normally energized.
[ The Frequency of 31 days is based upon operating experience which demonstrates that channel failure is rare. The CHANNEL CHECK supplements less formal, but more frequent, checks of channels during normal operational use of the displays associated with the LCO required channels.
OR The Surveillance Frequency is controlled under the Surveillance Frequency Control Program.
REVIEWER'S NOTE-----------------------------------
Plants controlling Surveillance Frequencies under a Surveillance Frequency Control Program should utilize the appropriate Frequency description, given above, and the appropriate choice of Frequency in the Surveillance Requirement.
] SR 3.3.4.2 SR 3.3.4.2 verifies each required Remote Shutdown System control circuit and transfer switch performs the intended function. This verification is performed from the remote shutdown panel and locally, as appropriate. Operation of the equipment from the re mote shutdown panel is not necessary. The Surveillance can be satisfied by performance of a continuity check. This will ensure that if the control room becomes inaccessible, the unit can be placed and maintained in MODE 3 from the remote shutdown panel and the local control stations.
[ 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 5 6 4 Remote Shutdown System B 3.3.4 Westinghouse STS B 3.3.4-5 Rev. 4.0 Monitoring Instrumentation 2SEQUOYAH UNIT 1 Revision XXX 1BASES
SURVEILLANCE REQUIREMENTS (continued)
unplanned transient if the Surveillance were performed with the reactor at power. (However, this Surveillance is not required to be performed only during a unit outage.) Operating experience demonstrates that remote shutdown control channels usually pass the Surveillance test when performed at the [18]
month Frequency.
OR The Surveillance Frequency is controlled under the Surveillance Frequency Control Program.
REVIEWER'S NOTE-----------------------------------
Plants controlling Surveillance Frequencies under a Surveillance Frequency Control Program should utilize the appropriate Frequency description, given above, and the appropriate choice of Frequency in the Surveillance Requirement.
]
3 CHANNEL CALIBRATION is a complete check of the instrument loop and the sensor. The test verifies that the channel responds to a measured parameter within the necessary range and accuracy.
Whenever a sensing element is replaced, the next required CHANNEL CALIBRATION of the resistance temperature detectors (RTD) sensors is accomplished by an inplace cross calibration that compares the other sensing elements with the recently installed sensing element.
[ The Frequency of [18]
months is based upon operating experience and consistency with the typical industry refueling cycle.
OR The Surveillance Frequency is controlled under the Surveillance Frequency Control Program.
4 4 5 2 temperature INSERT 1 7 2 B 3.3.4 Insert Page 3.3.4-5 INSERT 1 This SR is modified by two Notes, Note 1 excludes the neutron detectors and Note 2 excludes the reactor trip breaker indication from the CHANNEL CALIBRATION.
7 Remote Shutdown System B 3.3.4 Westinghouse STS B 3.3.4-6 Rev. 4.0 Monitoring Instrumentation 1BASES
SURVEILLANCE REQUIREMENTS (continued)
REVIEWER'S NOTE-----------------------------------
Plants controlling Surveillance Frequencies under a Surveillance Frequency Control Program should utilize the appropriate Frequency description, given above, and the appropriate choice of Frequency in the Surveillance Requirement.
]
[ SR 3.3.4.4 SR 3.3.4.4 is the performance of a TADOT. This test should verify the OPERABILITY of the reactor trip breakers (RTBs) open and closed indication on the remote shutdown panel, by actuating the RTBs. A successful test of the required contact(s) of a channe l relay may be performed by the verification of the change of state of a single contact of the relay. This clarifies what is an acceptable TADOT of a relay. This is acceptable because all of the other required contacts of the relay are verified by other Technical Specifications and non
-Technical Specifications tests at least once per refueling interval with applicable extensions.
[ The Frequency of 18 months is based upon operating experience and consistency with the typical industry refueling outage.
OR The Surveillance Frequency is controlled under the Surveillance Frequency Control Program.
REVIEWER'S NOTE-----------------------------------
Plants controlling Surveillance Frequencies under a Surveillance Frequency Control Program should utilize the appropriate Frequency description, given above, and the appropriate choice of Frequency in the Surveillance Requirement.
] ]
REFERENCES 1. 10 CFR 50, Appendix A, GDC 19.
6 4 1SEQUOYAH UNIT 1 Revision XXX Remote Shutdown System B 3.3.4 Westinghouse STS B 3.3.4-7 Rev. 4.0 Monitoring Instrumentation 1 Table B 3.3.4-1 (page 1 of 1) Remote Shutdown System Instrumentation and Controls
FUNCTION/INSTRUMENT OR CONTROL PARAMETER REQUIRED NUMBER OF FUNCTIONS
- 1. Reactivity Control
- a. Source Range Neutron Flux
[1]
- b. Reactor Trip Breaker Position
[1 per trip breaker]
[2]
- 2. Reactor Coolant System (RCS) Pressure Control
- a. Pressurizer Pressure or RCS Wide Range Pressure
[1]
- b. Pressurizer Power Operated Relief Valve (PORV) Control and Block Valve Control
[1, controls must be for PORV & block valves on same line] 3. Decay Heat Removal via Steam Generators (SGs)
- a. RCS Hot Leg Temperature
[1 per loop]
- b. RCS Cold Leg Temperature
[1 per loop]
[1 per SG]
- 4. RCS Inventory Control
- a. Pressurizer Level
[1]
- b. Charging Pump Controls
[1] ---------------------------------------------------------------REVIEWER'S NOTE-----------------------------------------------------------------
For channels that fulfill GDC 19 requirements, the number of OPERABLE channels required depends upon the unit licensing basis as described in the NRC unit specific Safety Evaluation Report (SER). Generally, two divisions are required OPERABLE. However, only one channel per a given Function is required if the unit has justi fied such a design, and NRC's SER accepted the justification.
REVIEWER'S NOTE-----------------------------------------------------------------
This Table is for illustration purposes only. It does not attempt to encompass every Function used at every unit, but does contain the types of Functions commonly found.
INSERT 2 2 6 6 1SEQUOYAH UNIT 1 Revision XXX Monitoring 1
B 3.3.4 Insert Page 3.3.4-7 INSERT 2 FUNCTION READOUT LOCATION MEASUREMENT RANGE REQUIRED NUMBER OF CHANNELS
- 1. Source Range Nuclear Flux Auxiliary Control Room Panel 1-L-10 1 to 1 x 10 6 cps 1
- 2. Reactor Trip Breaker Indication at trip switchgear OPEN-CLOSE 1/trip breaker
- 3. Reactor Coolant Temperature - Hot Leg Auxiliary Control Room Panel 1-L-10 0-650°F 1/loop
- 4. Pressurizer Pressure Auxiliary Control Room Panel 1-L-10 0-3000 psig 1
- 5. Pressurizer Level
Auxiliary Control Room Panel 1-L-10 0-100% 1
- 6. Steam Generator Pressure Auxiliary Control Room Panel 1-L-10 0-1200 psig 1/steam generator
- 7. Steam Generator Level Auxiliary Control Room Panels 1-L-11A and 1-L-11B or near Auxiliary Feedwater Pump 0-100% 1/steam generator
- 8. RHR Flow Rate Auxiliary Control Room Panel 1-L-10 0-4500 gpm 1
- 9. RHR Temperature Auxiliary Control Room Panel 1-L-10 50-400°F 1
- 10. Auxiliary Feedwater Flow Rate
Auxiliary Control Room Panel 1-L-10 0-440 gpm 1/steam generator
- 11. Pressurizer Relief Tank Pressure Auxiliary Control Room Panel 1-L-10 0-100 psig 1 12. Containment Pressure Auxiliary Control Room Panel 1-L-10
-1 to +15 psig 1 2 Remote Shutdown System B 3.3.4 Westinghouse STS B 3.3.4-1 Rev. 4.0 Monitoring Instrumentation 2SEQUOYAH UNIT 2 Revision XXX 1B 3.3 INSTRUMENTATION
B 3.3.4 Remote Shutdown System BASES BACKGROUND The Remote Shutdown System provides the control room operator with sufficient instrumentation and controls to place and maintain the unit in a safe shutdown condition from a location other than the control room. This capability is necessary to protect against the possibility that the control room becomes inaccessible. A safe shutdown condition is defined as MODE 3. With the unit in MODE 3, the Auxiliary Feedwater (AFW)
System and the steam generator (SG) safety valves or the SG atmospheric dump valves (ADVs) can be used to remove core decay heat and meet all safety requirements. The long term supply of water for the AFW System and the ability to borate the Reactor Coolant System (RCS) from outside the control room allows extended operation in MODE 3.
If the control room becomes inaccessible, the operators can establish control at the remote shutdown panel, and place and maintain the unit in MODE 3. Not all controls and necessary transfer switches are located at the remote shutdown panel. Some controls and transfer switches will have to be operated locally at the switchgear, motor control panels, or other local stations. The unit automatically reaches MODE 3 following a unit shutdown and can be maintained safely in MODE 3 for an extended period of time.
The OPERABILITY of the remote shutdown control and instrumentation functions ensures there is sufficient information available on selected unit
parameters to place and maintain the unit in MODE 3 should the control room become inaccessible.
APPLICABLE The Remote Shutdown System is required to provide equipment at SAFETY appropriate locations outside the control room with a capability to ANALYSES promptly shut down and maintain the unit in a safe condition in MODE 3.
The criteria governing the design and specific system requirements of the Remote Shutdown System are located in 10 CFR 50, Appendix A, GDC 19 (Ref. 1).
The Remote Shutdown Sys tem satisfies Criterion 4 of 10 CFR 50.36(c)(2)(ii).
Monitoring InstrumentationMonitoring Instrumentationsupport placing maintaining relief ARVs Main Steam Safety Valves (MSSV) monitor the status of the reactorlocations shown on Table B 3.3.4-1 monitoring support placing maintaining support placingmaintaining Monitoring InstrumentationMonitoring Instrumentation 1 1 2 2 2 1 2 1 1 2 Remote Shutdown System B 3.3.4 Westinghouse STS B 3.3.4-2 Rev. 4.0 Monitoring Instrumentation 2SEQUOYAH UNIT 2 Revision XXX 1BASES
LCO The Remote Shutdown System LCO provides the OPERABILITY requirements of the instrumentation and controls necessary to place and maintain the unit in MODE 3 from a location other than the control room.
The instrumentation and controls required are listed in Table B 3.3.4-1.
The controls, instrumentation, and transfer switches are required for:
- Core reactivity control (initial and long term)
,
- RCS pressure control
,
- Decay heat removal via the AFW System and the SG safety valves or SG ADVs,
- RCS inventory control via charging flow, and
- Safety support systems for the above Functions, including service water, component cooling water, and onsite power, including the diesel generators.
A Function of a Remote Shutdown System is OPERABLE if all instrument and control channels needed to support the Remote Shutdown System Function are OPERABLE. In some cases, Table B 3.3.4-1 may indicate that the required information or control capability is available from several alternate sources. In these cases, the Function is OPERABLE as long as one channel of any of the alternate information or control sources is OPERABLE.
The remote shutdown instrument and control circuits covered by this LCO do not need to be energized to be considered OPERABLE. This LCO is intended to ensure the instruments and control circuits will be OPERABLE if unit conditions require that the Remote Shutdown System be placed in operation.
APPLICABILITY The Remote Shutdown System LCO is applicable in MODES 1, 2, and 3. This is required so that the unit can be placed and maintained in MODE 3 for an extended period of time from a location other than the control room.
This LCO is not applicable in MODE 4, 5, or 6. In these MODES, the facility is already subcritical and in a condition of reduced RCS energy. Under these conditions, considerable time is available to restore
necessary instrument control functions if control room instruments or controls become unavailable. Monitoring Instrumentationsupport placing maintaining monitoring isReactor ; and; ;makeup.monitoring instrumentation is each For Function 7, this case monitoring instrumentationMonitoring InstrumentationMonitoring Instrumentation 1 1 2 1 1 1 2 2 3 3 3monitoring instrumentationchannels the es 3 Remote Shutdown System B 3.3.4 Westinghouse STS B 3.3.4-3 Rev. 4.0 Monitoring Instrumentation 2SEQUOYAH UNIT 2 Revision XXX 1BASES
ACTIONS A Remote Shutdown System division is inoperable when each function is not accomplished by at least one designated Remote Shutdown System channel that satisfies the OPERABILITY criteria for the channel's Function. These criteria are outlined in the LCO section of the Bases.
A Note has been added to the ACTIONS to clarify the application of Completion Time rules. Separate Condition entry is allowed for each Function. The Completion Time(s) of the inoperable channel(s)
/train(s) of a Function will be tracked separately for each Function starting from the time the Condition was entered for that Function.
A.1 Condition A addresses the situation where one or more required Functions of the Remote Shutdown System are inoperable. This includes the control and transfer switches for any required Function.
The Required Action is to restore the required Function to OPERABLE status within 30 days. The Completion Time is based on operating experience and the low probability of an event that would require evacuation of the control room.
B.1 and B.2 If the Required Action and associated Completion Time of Condition A is not met, the unit must be brought to a MODE in which the LCO does not apply. To achieve this status, the unit must be brought to at least MODE 3 within 6 hours6.944444e-5 days <br />0.00167 hours <br />9.920635e-6 weeks <br />2.283e-6 months <br /> and to MODE 4 within 12 hours1.388889e-4 days <br />0.00333 hours <br />1.984127e-5 weeks <br />4.566e-6 months <br />. The allowed Completion Times are reasonable, based on operating experience, to reach the required unit conditions from full power conditions in an orderly manner and without challenging unit systems.
SURVEILLANCE SR 3.3.4.1 REQUIREMENTS Performance of the CHANNEL CHECK ensures that a gross failure of instrumentation has not occurred. A CHANNEL CHECK is normally a comparison of the parameter indicated on one channel to a similar parameter on other channels. It is based on the assumption that instrument channels monitoring the same parameter should read approximately the same value. Significant deviations between the two instrument channels could be an indication of excessive instrument drift in one of the channels or of something even more serious. CHANNEL CHECK will detect gross channel failure; thus, it is key to verifying that the instrumentation continues to operate properly between each CHANNEL CALIBRATION. Monitoring Instrumentation LCO is not met Monitoring Instrumentation 1 2 1 2 The any required does not satisfy its Remote Shutdown System B 3.3.4 Westinghouse STS B 3.3.4-4 Rev. 4.0 Monitoring Instrumentation 2SEQUOYAH UNIT 2 Revision XXX 1BASES SURVEILLANCE REQUIREMENTS (continued) Agreement criteria are determined by the unit staff, based on a combination of the channel instrument uncertainties, including indication and readability. If the channels are within the criteria, it is an indication that the channels are OPERABLE. If a channel is outside the criteria, it may be an indication that the sensor or the signal processing equipment has drifted outside its limit. As specified in the Surveillance, a CHANNEL CHECK is only required for those channels which are normally energized.
[ The Frequency of 31 days is based upon operating experience which demonstrates that channel failure is rare. The CHANNEL CHECK supplements less formal, but more frequent, checks of channels during normal operational use of the displays associated with the LCO required channels. OR The Surveillance Frequency is controlled under the Surveillance Frequency Control Program. -----------------------------------REVIEWER'S NOTE-----------------------------------
Plants controlling Surveillance Frequencies under a Surveillance Frequency Control Program should utilize the appropriate Frequency description, given above, and the appropriate choice of Frequency in the Surveillance Requirement.
] SR 3.3.4.2 SR 3.3.4.2 verifies each required Remote Shutdown System control circuit and transfer switch performs the intended function. This verification is performed from the remote shutdown panel and locally, as appropriate. Operation of the equipment from the re mote shutdown panel is not necessary. The Surveillance can be satisfied by performance of a continuity check. This will ensure that if the control room becomes inaccessible, the unit can be placed and maintained in MODE 3 from the remote shutdown panel and the local control stations.
[ 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 5 6 4 Remote Shutdown System B 3.3.4 Westinghouse STS B 3.3.4-5 Rev. 4.0 Monitoring Instrumentation 2SEQUOYAH UNIT 2 Revision XXX 1BASES
SURVEILLANCE REQUIREMENTS (continued)
unplanned transient if the Surveillance were performed with the reactor at power. (However, this Surveillance is not required to be performed only during a unit outage.) Operating experience demonstrates that remote shutdown control channels usually pass the Surveillance test when performed at the [18]
month Frequency.
OR The Surveillance Frequency is controlled under the Surveillance Frequency Control Program.
REVIEWER'S NOTE-----------------------------------
Plants controlling Surveillance Frequencies under a Surveillance Frequency Control Program should utilize the appropriate Frequency description, given above, and the appropriate choice of Frequency in the Surveillance Requirement.
]
3 CHANNEL CALIBRATION is a complete check of the instrument loop and the sensor. The test verifies that the channel responds to a measured parameter within the necessary range and accuracy.
Whenever a sensing element is replaced, the next required CHANNEL CALIBRATION of the resistance temperature detectors (RTD) sensors is accomplished by an inplace cross calibration that compares the other sensing elements with the recently installed sensing element.
[ The Frequency of [18]
months is based upon operating experience and consistency with the typical industry refueling cycle.
OR The Surveillance Frequency is controlled under the Surveillance Frequency Control Program.
4 4 5 2 temperature INSERT 1 7 2 B 3.3.4 Insert Page 3.3.4-5 INSERT 1 This SR is modified by two Notes, Note 1 excludes the neutron detectors and Note 2 excludes the reactor trip breaker indication from the CHANNEL CALIBRATION.
7 Remote Shutdown System B 3.3.4 Westinghouse STS B 3.3.4-6 Rev. 4.0 Monitoring Instrumentation 1BASES
SURVEILLANCE REQUIREMENTS (continued)
REVIEWER'S NOTE-----------------------------------
Plants controlling Surveillance Frequencies under a Surveillance Frequency Control Program should utilize the appropriate Frequency description, given above, and the appropriate choice of Frequency in the Surveillance Requirement.
]
[ SR 3.3.4.4 SR 3.3.4.4 is the performance of a TADOT. This test should verify the OPERABILITY of the reactor trip breakers (RTBs) open and closed indication on the remote shutdown panel, by actuating the RTBs. A successful test of the required contact(s) of a channe l relay may be performed by the verification of the change of state of a single contact of the relay. This clarifies what is an acceptable TADOT of a relay. This is acceptable because all of the other required contacts of the relay are verified by other Technical Specifications and non
-Technical Specifications tests at least once per refueling interval with applicable extensions.
[ The Frequency of 18 months is based upon operating experience and consistency with the typical industry refueling outage.
OR The Surveillance Frequency is controlled under the Surveillance Frequency Control Program.
REVIEWER'S NOTE-----------------------------------
Plants controlling Surveillance Frequencies under a Surveillance Frequency Control Program should utilize the appropriate Frequency description, given above, and the appropriate choice of Frequency in the Surveillance Requirement.
] ]
REFERENCES 1. 10 CFR 50, Appendix A, GDC 19.
6 4 1SEQUOYAH UNIT 2 Revision XXX Remote Shutdown System B 3.3.4 Westinghouse STS B 3.3.4-7 Rev. 4.0 Monitoring Instrumentation 1 Table B 3.3.4-1 (page 1 of 1) Remote Shutdown System Instrumentation and Controls
FUNCTION/INSTRUMENT OR CONTROL PARAMETER REQUIRED NUMBER OF FUNCTIONS
- 1. Reactivity Control
- a. Source Range Neutron Flux
[1]
- b. Reactor Trip Breaker Position
[1 per trip breaker]
[2]
Pressure Control
- a. Pressurizer Pressure or RCS Wide Range Pressure
[1]
- b. Pressurizer Power Operated Relief Valve (PORV) Control and Block Valve Control
[1, controls must be for PORV & block valves on same line] 3. Decay Heat Removal via Steam Generators (SGs)
- a. RCS Hot Leg Temperature
[1 per loop]
- b. RCS Cold Leg Temperature
[1 per loop]
[1 per SG]
- 4. RCS Inventory Control
- a. Pressurizer Level [1]
- b. Charging Pump Controls
[1] ---------------------------------------------------------------REVIEWER'S NOTE-----------------------------------------------------------------
For channels that fulfill GDC 19 requirements, the number of OPERABLE channels required depends upon the unit licensing basis as described in the NRC unit specific Safety Evaluation Report (SER). Generally, two divisions are required OPERABLE. However, only one channel per a given Function is required if the unit has justified such a design, and NRC's SER accepted the justification.
REVIEWER'S NOTE-----------------------------------------------------------------
This Table is for illustration purposes only. It does not attempt to encompass every Function used at every unit, but does contain the types of Functions commonly found.
INSERT 2 2 6 6 1SEQUOYAH UNIT 2 Revision XXX Monitoring 1
B 3.3.4 Insert Page 3.3.4-7 INSERT 2 FUNCTION READOUT LOCATION MEASUREMENT RANGE REQUIRED NUMBER OF CHANNELS
- 1. Source Range Nuclear Flux Auxiliary Control Room Panel 2-L-10 1 to 1 x 10 6 cps 1
- 2. Reactor Trip Breaker Indication
at trip switchgear OPEN-CLOSE 1/trip breaker
- 3. Reactor Coolant Temperature - Hot Leg Auxiliary Control Room Panel 2-L-10 0-650°F 1/loop
- 4. Pressurizer Pressure
Auxiliary Control Room Panel 2-L-10 0-3000 psig 1
- 5. Pressurizer Level Auxiliary Control Room Panel 2-L-10 0-100% 1
- 6. Steam Generator Pressure Auxiliary Control Room Panel 2-L-10 0-1200 psig 1/steam generator
- 7. Steam Generator Level
Auxiliary Control Room Panels 2-L-11A and 2-L-11B or near Auxiliary Feedwater Pump 0-100% 1/steam generator
- 8. RHR Flow Rate
Auxiliary Control Room Panel 2-L-10 0-4500 gpm 1
- 9. RHR Temperature
Auxiliary Control Room Panel 2-L-10 50-400°F 1
- 10. Auxiliary Feedwater Flow Rate Auxiliary Control Room Panel 2-L-10 0-440 gpm 1/steam generator
- 11. Pressurizer Relief Tank Pressure Auxiliary Control Room Panel 2-L-10 0-100 psig 1
- 12. Containment Pressure Auxiliary Control Room Panel 2-L-10
-1 to +15 psig 1 2 JUSTIFICATION FOR DEVIATIONS ITS 3.3.4 BASES, REMOTE SHUTDOWN MONITORING INSTRUMENTATION Sequoyah Unit 1 and Unit 2 Page 1 of 1 1. ISTS B 3.3.4 Bases have been changed to reflect that the instruments in Table B 3.3.4-1 are for remote shutdown monitoring. Therefore, the words "Remote Shutdown System" have been changed to "Remote Shutdown Monitoring Instrumentation" throughout the Bases.
- 2. Changes are made (additions, deletions, and/or changes) to the ISTS Bases that reflect the plant specific nomenclature, number, reference, system description, analysis, or licensing basis description.
- 3. These punctuation corrections have been made consistent with the Writer's Guide for the Improved Technical Specifications, TSTF-GG-05-01, Section 5.1.3.
- 4. Changes are made to be consistent with changes made to the Specification.
- 5. ISTS SR 3.3.4.1 and SR 3.3.4.3 (ITS SR 3.3.4.1 and SR 3.3.4.2, respectively) Bases provide two options for controlling the Frequencies of Surveillance Requirements. SQN is proposing to control the Surveillance Frequencies under the Surveillance Frequency Control Program. Additionally, the Frequency description which is being removed will be included in the Surveillance Frequency Control Program.
- 6. The Reviewer's Note has been deleted. This information is for the NRC reviewer to be keyed into what is needed to meet this requirement. This Note is not meant to be retained in the final version of the plant specific submittal.
- 7. ITS SR 3.3.4.2 contains two NOTES t hat provide an allowance to exclude neutron detectors and the reactor trip breaker indication from the calibration requirements of this surveillance. The associated ISTS SR 3.3.4.3 Bases do not contain information associated with these allowances. Therefore, information associated with the allowances has been added.
Specific No Significant Haza rds Considerations (NSHCs)
DETERMINATION OF NO SIGNIFICANT HAZARDS CONSIDERATIONS ITS 3.3.4, REMOTE SHUTDOWN MONITORING INSTRUMENTATION Sequoyah Unit 1 and 2 Page 1 of 1 There are no specific No Significant Hazards Considerations for this Specification.
ATTACHMENT 5 ITS 3.3.5, LOSS OF POWER (L OP) DIESEL GENERATOR (DG)
START INSTRUMENTATION
Current Technical Specification (CTS) Markup and Discussion of Changes (DOCs)
A01ITS ITS 3.3.5 INSTRUMENTATION LOSS OF POWER (LOP) DIESEL GENERATOR (DG) START INSTRUMENTATION LIMITING CONDITION FOR OPERATION 3.3.3.11 The LOP DG start instrumentation for each function in Table 3.3-14 shall be OPERABLE.
APPLICABILITY: MODES 1, 2, 3, and 4, When associated DG is required to be OPERABLE by LCO 3.8.1.2, "AC Sources -
Shutdown."
ACTION: a. With the number of OPERABLE channels one less than the Required Channels for voltage sensors, restore the inoperable channel to OPERABLE status within 6 hours6.944444e-5 days <br />0.00167 hours <br />9.920635e-6 weeks <br />2.283e-6 months <br /> or enter applicable Limiting Condition(s) For Operation and Action(s) for the associated DG set made inoperable by the channel.
- b. With the number of OPERABLE channels less than the Required Channels by more than one for voltage sensors or with the number of OPERABLE channels one less than the Required Channels for timers, restore all but one channel of voltage sensors and at least one timer for each function to OPERABLE status within 1 hour1.157407e-5 days <br />2.777778e-4 hours <br />1.653439e-6 weeks <br />3.805e-7 months <br /> or enter applicable Limiting Condition(s) For Operation and Action(s) for the associated DG set made inoperable by the channels.
- c. Separate entry is allowed for each function.
- d. Enter applicable Actions of LCO 3.3.2, "Engineered Safety Feature Actuation System Instrumentation," for Auxiliary Feedwater Loss of Power Start Instrumentation made inoperable by LOP DG Start Instrumentation.
SURVEILLANCE REQUIREMENTS 4.3.3.11.1 Each LOP DG Start Instrumentation channel shall be demonstrated OPERABLE by the performance of the CHANNEL C HECK, CHANNEL CALIBRATION, and CHANNEL FUNCTIONAL TEST operations for the MODES and at the frequencies shown in Table 4.3-10.
4.3.3.11.2 The ENGINEERED SAFETY FEATURES RESPONSE TIME of each LOP DG Start Instrumentation function shall be verified to be within the limit at least once per 18 months. Each verification shall include at least one train such that both trains are verified at least once per 36 months and one channel per function such that all channels are verified at least once every N times 18 months where N is the total number of redundant channels.
September 14, 2006 SEQUOYAH - UNIT 1 3/4 3-76 Amendment No. 311 LCO 3.3.5 Applicabilit y ACTION A ACTION C ACTION B ACTION C ACTION Note TADOT A04SR Note L01 Page 1 of 6 A02 A03SR 3.3.5.1 SR 3.3.5.2 Add SR 3.3.5.1 Note A04 A01ITS ITS 3.3.5 TABLE 3.3-14 LOSS OF POWER DIESEL GENERATOR START INSTRUMENTATION FUNCTIONAL UNIT APPLICABLE MODES OR CONDITIONS REQUIRED CHANNELS NOMINAL TRIP SETPOINT ALLOWABLE VALUES 1. 6.9 kv Shutdown Board -
Loss of Voltage
- a. Voltage Sensors
1, 2, 3, 4, #
3/Shutdown Board
5520 5331 volts and 5688 volts
- b. Diesel Generator Start and Load Shed Timer 1, 2, 3, 4, #
1/Shutdown Board 1.25 seconds 1.00 seconds and 1.50 seconds
- 2. 6.9 kv Shutdown Board -Degraded Voltage
- a. Voltage Sensors 1, 2, 3, 4, #
3/Shutdown Board
6456 volts
6403.5 volts and 6522.5 volts
- b. Diesel Generator Start and Load Shed Timer 1, 2, 3, 4, #
1/Shutdown Board 300 seconds 218.6 seconds and 370 seconds
- c. SI/Degraded Voltage Logic Enable Timer 1, 2, 3, 4 1/Shutdown Board 9.5 seconds 7.5 seconds and 11.5 seconds
- When associated DG is required to be OPERABLE by LCO 3.8.1.2, "AC Sources - Shutdown."
September 14, 2006 SEQUOYAH - UNIT 1 3/4 3-77 Amendment No. 311 Table 3.3.5-1 Function 1 Function 1.a Function 1.b Function 2 Function 2.a Function 2.b Function 2.c Footnote a Page 2 of 6 A01ITS ITS 3.3.5 TABLE 4.3-10 LOSS OF POWER DIESEL GENERATOR START INSTRUMENTATION SURVEILLANCE REQUIREMENTS FUNCTIONAL UNIT CHANNEL CHECK CHANNEL CALIBRATION CHANNEL FUNCTIONAL TEST MODES FOR WHICH SURVEILLANCE REQUIRED 1. 6.9 kv Shutdown Board - Loss of Voltage
- a. Voltage Sensors
N.A.
R M
1, 2, 3, 4, #
- b. Diesel Generator Start and Load Shed Timer N.A. R N.A. 1, 2, 3, 4, #
2 . 6.9 kv Shutdown Board -Degraded Voltage
- a. Voltage Sensors N.A.
R M
1, 2, 3, 4, #
- b. Diesel Generators Start and Load Shed Timer N.A. R N.A. 1, 2, 3, 4, #
- c. SI/Degraded Voltage Logic Enable Timer N.A. R N.A. 1, 2, 3, 4
- When associated DG is required to be OPERABLE by LCO 3.8.1.2, "AC Sources - Shutdown."
September 14, 2006 SEQUOYAH - UNIT 1 3/4 3-78 Amendment No. 311 Table 3.3.5-1 Function 1 Function 1.a Function 1.b Function 2 Function 2.a Function 2.b Function 2.c Footnote a In accordance with the Surveillance Frequency Control Program In accordance with the Surveillance Frequency Control Program LA01 LA01 TADOT A04SR 3.3.5.1SR 3.3.5.2 Page 3 of 6 ITS A01 ITS 3.3.5INSTRUMENTATION LOSS OF POWER (LOP) DIESEL GENERATOR (DG) START INSTRUMENTATION LIMITING CONDITION FOR OPERATION 3.3.3.11 The LOP DG start instrumentation for each function in Table 3.3-14 shall be OPERABLE.
APPLICABILITY: MODES 1, 2, 3, and 4, When associated DG is required to be OPERABLE by LCO 3.8.1.2, "AC Sources -
Shutdown."
ACTION: a. With the number of OPERABLE channels one less than the Required Channels for voltage sensors, restore the inoperable channel to OPERABLE status within 6 hours6.944444e-5 days <br />0.00167 hours <br />9.920635e-6 weeks <br />2.283e-6 months <br /> or enter applicable Limiting Condition(s) For Operation and Action(s) for the associated DG set made inoperable by the channel.
- b. With the number of OPERABLE channels less than the Required Channels by more than one for voltage sensors or with the number of OPERABLE channels one less than the Required Channels for timers, restore all but one channel of voltage sensors and at least one timer for each function to OPERABLE status within 1 hour1.157407e-5 days <br />2.777778e-4 hours <br />1.653439e-6 weeks <br />3.805e-7 months <br /> or enter applicable Limiting Condition(s) For Operation and Action(s) for the associated DG set made inoperable by the channels.
- c. Separate entry is allowed for each function.
- d. Enter applicable Actions of LCO 3.3.2, "Engineered Safety Feature Actuation System Instrumentation," for Auxiliary Feedwater Loss of Power Start Instrumentation made inoperable by LOP DG Start Instrumentation.
SURVEILLANCE REQUIREMENTS 4.3.3.11.1 Each LOP DG Start Instrumentation channel shall be demonstrated OPERABLE by the performance of the CHANNEL CHECK, CHANNEL CALIBRATION, and CHANNEL FUNCTIONAL TEST operations for the MODES and at the frequencies shown in Table 4.3-10.
4.3.3.11.2 The ENGINEERED SAFETY FEATURES RESPONSE TIME of each LOP DG Start Instrumentation function shall be verified to be within the limit at least once per 18 months. Each verification shall include at least one train such that both trains are verified at least once per 36 months and one channel per function such that all channels are verified at least once every N times 18 months where N is the total number of redundant channels.
September 14, 2006 SEQUOYAH - UNIT 2 3/4 3-74 Amendment No. 300 LCO 3.3.5 Applicabilit y ACTION A ACTION C ACTION B ACTION C ACTION Note TADOT A04SR Note L01 Page 4 of 6 A02 A03SR 3.3.5.1 SR 3.3.5.2 Add SR 3.3.5.1 Note A04 ITS A01 ITS 3.3.5 TABLE 3.3-14 LOSS OF POWER DIESEL GENERATOR START INSTRUMENTATION FUNCTIONAL UNIT APPLICABLE MODES OR CONDITIONS REQUIRED CHANNELS NOMINAL TRIP SETPOINT ALLOWABLE VALUES 1. 6.9 kv Shutdown Board -
Loss of Voltage
- a. Voltage Sensors
1, 2, 3, 4, #
3/Shutdown Board 5520 5331 volts and 5688 volts
- b. Diesel Generator Start and Load Shed Timer 1, 2, 3, 4, #
1/Shutdown Board 1.25 seconds 1.00 seconds and 1.50 seconds
- 2. 6.9 kv Shutdown Board -Degraded Voltage
- a. Voltage Sensors
1, 2, 3, 4, #
3/Shutdown Board 6456 volts
6403.5 volts and 6522.5 volts
- b. Diesel Generator Start and Load Shed
Timer 1, 2, 3, 4, #
1/Shutdown Board 300 seconds 218.6 seconds and 370 seconds
- c. SI/Degraded Voltage Logic Enable Timer 1, 2, 3, 4 1/Shutdown Board 9.5 seconds 7.5 seconds and 11.5 seconds
- When associated DG is required to be OPERABLE by LCO 3.8.1.2, "AC Sources - Shutdown."
September 14, 2006 SEQUOYAH - UNIT 2 3/4 3-75 Amendment No. 300 Table 3.3.5-1 Function 1 Function 1.a Function 1.b Function 2 Function 2.a Function 2.b Function 2.c Footnote a Page 5 of 6 ITS A01 ITS 3.3.5 TABLE 4.3-10 LOSS OF POWER DIESEL GENERATOR START INSTRUMENTATION SURVEILLANCE REQUIREMENTS FUNCTIONAL UNIT CHANNEL CHECK CHANNEL CALIBRATION CHANNEL FUNCTIONAL TEST MODES FOR WHICH SURVEILLANCE REQUIRED 1. 6.9 kv Shutdown Board - Loss of Voltage
- a. Voltage Sensors
N.A.
R M
1, 2, 3, 4, #
- b. Diesel Generator Start and Load Shed Timer N.A. R N.A. 1, 2, 3, 4, #
2 . 6.9 kv Shutdown Board -Degraded Voltage
- a. Voltage Sensors N.A.
R M
1, 2, 3, 4, #
- b. Diesel Generators Start and Load Shed Timer N.A. R N.A. 1, 2, 3, 4, #
- c. SI/Degraded Voltage Logic Enable Timer N.A. R N.A. 1, 2, 3, 4
- When associated DG is required to be OPERABLE by LCO 3.8.1.2, "AC Sources - Shutdown."
September 14, 2006 SEQUOYAH - UNIT 2 3/4 3-76 Amendment No. 300 Table 3.3.5-1 Function 1 Function 1.a Function 1.b Function 2 Function 2.a Function 2.b Function 2.c Footnote a In accordance with the Surveillance Frequency Control Program In accordance with the Surveillance Frequency Control Program LA01 LA01 TADOT A04SR 3.3.5.1SR 3.3.5.2 Page 6 of 6 DISCUSSION OF CHANGES ITS 3.3.5, LOSS OF POWER (LOP) DIESEL GENERATOR (DG) START INSTRUMENTATION Sequoyah Unit 1 and Unit 2 Page 1 of 4 ADMINISTRATIVE CHANGES A01 In the conversion of the Sequoyah Nuclear Plant (SQN) Current Technical Specifications (CTS) to the plant specific Improved Technical Specifications (ITS), certain changes (wording preferences, editorial changes, reformatting, revised numbering, etc.) are made to obtain consistency with NUREG-1431, Rev. 4.0, "Standard Technical Specifications-Westinghouse Plants" (ISTS) and additional Technical Specification Task Force (TSTF) travelers included in this
submittal.
These changes are designated as administrative changes and are acceptable because they do not result in technical changes to the CTS.
A02 CTS 3.3.3.11 ACTION d requires entrance into the applicable ACTIONS of LCO 3.3.2 "Engineered Safety Feature Actuation System Instrumentation," for Auxiliary Feedwater Loss of Power Start Instrumentation which is made inoperable by LOP DG Start Instrumentation. ITS 3.3.5 does not contain this ACTION. This changes the CTS by not including the ACTION to enter the ACTIONS of LCO 3.3.2.
This change is acceptable because ITS 3.3.2 contains an ACTION to take for the Auxiliary Feedwater Loss of Offsite Power Start Instrumentation. Therefore, there is no reason to have a specific ACTION in ITS 3.3.5. This change is considered administrative because it does not result in a technical change to the CTS. A03 CTS 4.3.3.11.1 requires, in part, that the LOP DG Start instrumentation in Table 4.3-10 be demonstrated OPERABLE by performance of a CHANNEL CHECK for the MODES and at the Frequencies shown in Table 4.3-10. ITS LCO 3.3.5 does not include a CHANNEL CHECK. This changes the CTS by deleting the reference to a CHANNEL CHECK surveillance requirement.
The purpose of CTS 4.3.3.11.1 is to provide the requirement for performance of those Surveillances listed in CTS Table 4.3-10. CTS 4.3.3.11.1 requires that each LOP DG Start Instrumentation channel be demonstrated OPERABLE by the performance of the CHANNEL CHECK, CHANNEL CALIBRATION, and CHANNEL FUNCTIONAL TEST operations for the MODES and at the Frequencies shown in Table 4.3-10. CTS Table 4.3-10 does not contain any requirements to perform a CHANNEL CHECK for any of the listed Functions.
ITS Table 3.3.5-1 contains the same instruments as CTS Table 4.3-10 and
similarly does not contain any requirements to perform a CHANNEL CHECK. Because ITS Table 3.3.5-1 does not contain any requirements for performance of a CHANNEL CHECK reference to a CHANNEL CHECK is deleted. This change is considered administrative because it does not result in a technical change to the CTS.
A04 CTS 4.3.3.11.1 requires, in part, that the LOP DG Start instrumentation in Table 4.3-10 be demonstrated OPERABLE by performance of CHANNEL FUNCTIONAL TEST. CTS Table 4.3-10 Function 1.a (6.9 kV Shutdown Board - Loss of Voltage - Voltage Sensors) and Function 2.a (6.9 kV Shutdown Board -
DISCUSSION OF CHANGES ITS 3.3.5, LOSS OF POWER (LOP) DIESEL GENERATOR (DG) START INSTRUMENTATION Sequoyah Unit 1 and Unit 2 Page 2 of 4 Degraded Voltage - Voltage Sensors) require performance of a CHANNEL FUNCTIONAL TEST. ITS Table 3.3.5-1 Function 1.a (6.9 kV Shutdown Board -
Loss of Voltage - Voltage Sensors) and Function 2.a (6.9 kV Shutdown Board -
Degraded Voltage - Voltage Sensors) require performance of a TADOT. ITS SR 3.3.5.1, perform a TADOT, is modified by a Note that states that verification of relay setpoints is not required. This changes the CTS by requiring a TADOT without verification of relay setpoints instead of a CHANNEL FUNCTIONAL
TEST. This change is acceptable because the TADOT continues to perform a test similar to the current CHANNEL FUNCTIONAL TEST. CTS defines a CHANNEL FUNCTIONAL TEST based on the type of channel. In CTS a CHANNEL FUNCTIONAL TEST shall be: for Analog channels, the injection of a simulated signal into the channel as close to the sensor as practicable to verify OPERABILITY including alarm and/or trip functions; for Bistable channels, the injection of a simulated signal into the sensor to verify OPERABILITY including alarm and/or trip functions; and for Digital channels, the injection of a simulated signal into the channel as close to the sensor input to the process racks as practicable to verify OPERABILITY including alarm and/or trip functions. This does not include the adjustment, as necessary, of the channel output such that it responds with the necessary range and accuracy to known values of the parameter which the channel monitors as does the CHANNEL CALIBRATION. The TADOT provides a similar test with the addition that the TADOT includes adjustments, as necessary, of the required alarm, interlock, and trip setpoints required for channel OPERABILITY such that the setpoints are within the necessary range and accuracy. With the addition of the Note modifying ITS SR 3.3.5.1 to exclude the requirement to include an adjustment, as necessary, of the trip actuating device so that it actuates at the required setpoint within the necessary accuracy the ITS SR 3.3.5.1 provides a similar surveillance as the CTS CHANNEL FUNCTION TEST. This change is considered administrative because it does not result in a technical change to the CTS MORE RESTRICTIVE CHANGES None RELOCATED SPECIFICATIONS None REMOVED DETAIL CHANGES LA01 (Type 5 - Removal of SR Frequency to the Surveillance Frequency Control Program) CTS Table 4.3-10 Functional Unit 1.a requires a monthly CHANNEL FUNCTIONAL TEST and a refueling outage CHANNEL CALIBRATION for the 6.9 kV Shutdown Board - Loss of Voltage - Voltage Sensors. CTS Table 4.3-10 Functional Unit 1.b requires a refueling outage CHANNEL FUNCTIONAL TEST DISCUSSION OF CHANGES ITS 3.3.5, LOSS OF POWER (LOP) DIESEL GENERATOR (DG) START INSTRUMENTATION Sequoyah Unit 1 and Unit 2 Page 3 of 4 for the 6.9 kV Shutdown Board - Loss of Voltage - Diesel Generator Start and Load Shed Timer. CTS Table 4.3-10 Functional Unit 2.a requires a monthly CHANNEL FUNCTIONAL TEST and a refueling outage CHANNEL CALIBRATION for the 6.9 kV Shutdown Board - Degraded Voltage - Voltage Sensors. CTS Table 4.3-10 Functional Unit 2.b requires a refueling outage CHANNEL CALIBRATION for the 6.9 kV Shutdown Board - Degraded Voltage -
Diesel Generator Start and Load Shed Timer. CTS Table 4.3-10 Functional Unit 2.c requires a refueling outage CHANNEL CALIBRATION for the 6.9 kV Shutdown Board - Degraded Voltage - SI/Degraded Logic Enable Timer. ITS SR 3.3.5.1 and SR 3.3.5.2 require similar Surveillances and specify the periodic Frequency as, "In accordance with the Surveillance Frequency Control Program." This changes the CTS by moving the specified Frequencies for these SRs and associated Bases to the Surveillance Frequency Control Program.
The removal of these details related to Surveillance Requirement Frequencies from the Technical Specifications is acceptable, because this type of information is not necessary to be included in the Technical Specifications to provide adequate protection of public health and safety. The existing Surveillance Frequencies are removed from Technical Specifications and placed under licensee control pursuant to the methodology described in NEI 04-10. A new program (Surveillance Frequency Control Program) is being added to the Administrative Controls section of the Technical Specifications describing the control of Surveillance Frequencies. The surveillance test requirements remain in the Technical Specifications. The control of changes to the Surveillance Frequencies will be in accordance with the Surveillance Frequency Control Program. The Program shall ensure that Surveillance Requirements specified in the Technical Specifications are performed at intervals sufficient to assure the associated Limiting Conditions for Operation are met. This change is designated as a less restrictive removal of detail change, because the Surveillance Frequencies are being removed from the Technical Specifications.
LESS RESTRICTIVE CHANGES L01 (Category 5 - Deletion of Surveillance Requirement) CTS 4.3.3.11.2 requires a verification that the ENGINEERED SAFETY FEATURES RESPONSE TIME for each LOP DG Start Instrumentation function is within the limit at least once per 18 months. Additionally, it requires that each verification shall include at least one train such that both trains are verified at least once per 36 months and one channel per function such that all channels are verified at least once every N times 18 months where N is the total number of redundant channels. ITS 3.3.5 does not require this Surveillance Requirement. This changes the CTS by not requiring the LOP DG Start instrumentation to have a verification of the ENGINEERED SAFETY FEATURE RESPONSE TIME.
The purpose of CTS 4.3.3.11.2 is to ensure that the actuation response time is less than or equal to the maximum value assumed in the accident analyses. This change is acceptable because the DG loading has been included in the delay time associated with each safety system component requiring DG supplied power following a loss of offsite power. Therefore, the Surveillance Requirement DISCUSSION OF CHANGES ITS 3.3.5, LOSS OF POWER (LOP) DIESEL GENERATOR (DG) START INSTRUMENTATION Sequoyah Unit 1 and Unit 2 Page 4 of 4 is not necessary to verify the equipment used to meet the LCO can perform its required functions. This change is also acceptable because the equipment will continue to be tested in a manner and frequency necessary to give the confidence that the equipment can perform its assumed safety function. This change is designated as less restrictive because a Surveillance Requirement that was required in the CTS will no longer be required in the ITS.
Improved Standard Technical Specifications (ISTS) Markup and Justification for Deviations (JFDs)
LOP DG Start Instrumentation (Without Setpoint Control Program) 3.3.5 A Westinghouse STS 3.3.5 A-1 Rev. 4.0 1 4 1 Amendment XXX SEQUOYAH UNIT 1 CTS 3.3 INSTRUMENTATION
3.3.5 A Loss of Power (LOP) Diesel Generator (DG) Start Instrumentation (Without Setpoint Control Program)
LCO 3.3.5 A [Three] channels per bus of the loss of voltage Function and [three] channels per bus of the degraded voltage Function shall be OPERABLE.
APPLICABILITY: MODES 1, 2, 3, and 4, When associated DG is required to be OPERABLE by LCO 3.8.2, "AC Sources - Shutdown." ACTIONS
NOTE-----------------------------------------------------------
Separate Condition entry is allowed for each Function.
CONDITION REQUIRED ACTION COMPLETION TIME
A. One or more Functions with one channel per bus inoperable.
A.1 --------------NOTE--------------
The inoperable channel may be bypassed for up to
[4] hours for surveillance testing of other channels.
Place channel in trip.
[6] hours B. One or more Functions with two or more channels per bus inoperable.
B.1 Restore all but one channel per bus to OPERABLE status.
1 hour1.157407e-5 days <br />2.777778e-4 hours <br />1.653439e-6 weeks <br />3.805e-7 months <br /> C. Required Action and associated Completion Time not met.
C.1 Enter applicable Condition(s) and Required Action(s) for the associated DG made inoperable by
instrumentation.
Immediately The LOP DG start instrumentation for each Function in Table 3.3.5-1 According to Table 3.3.5-1.3.3.3.11 Applicabilit y ACTION c Restore the inoperable channel to OPERABLE status.INSERT 1 1 2 2 2 2 2 2 3 ACTION a ACTION b ACTION a ACTION b voltage sensor voltage sensor
.1 INSERT 2 3.3.5 Insert Page 3.3.5-1 CTS INSERT 1 One or more Functions with two or more voltage sensor channels inoperable.
OR One or more Functions with one required timer inoperable.
INSERT 2 AND B.1.2 Restore required 1 hour1.157407e-5 days <br />2.777778e-4 hours <br />1.653439e-6 weeks <br />3.805e-7 months <br /> timer to OPERABLE status.
2 ACTION b ACTION b 2 LOP DG Start Instrumentation (Without Setpoint Control Program) 3.3.5 A Westinghouse STS 3.3.5 A-2 Rev. 4.0 1 4 1 Amendment XXX SEQUOYAH UNIT 1 CTS SURVEILLANCE REQUIREMENTS SURVEILLANCE FREQUENCY SR 3.3.5.1 [ Perform CHANNEL CHECK.
[ 12 hours1.388889e-4 days <br />0.00333 hours <br />1.984127e-5 weeks <br />4.566e-6 months <br /> OR In accordance with the Surveillance Frequency Control Program ] ]
2 Perform TADOT.
[ [31] days OR In accordance with the Surveillance
Frequency
Control Program
] SR 3.3.5.
3 Perform CHANNEL CALIBRATION with [Nominal Trip Setpoint and Allowable Value] as follows:
- a. [ Loss of voltage Allowable Value [2912] V and [ ] V with a time delay of [0.8]
+/- [ ] second. Loss of voltage Nominal Trip Setpoint [2975]
V with a time delay of [0.8]
+/- [ ] second. ] b. [ Degraded voltage Allowable Value [3683] V and [ ] V with a time delay of
[20] +/- [ ] seconds.
Degraded voltage Nominal Trip Setpoint [3746]
V with a time delay of [20]
+/- [ ] seconds. ] [ [18] months OR In accordance
with the Surveillance Frequency
Control Program
] INSERT 5 INSERT 3.1 2 2 2 5 5 5 5 2 24.3.3.11.1 INSERT 4 4 2 3.3.5 Insert Page 3.3.5-2a CTS INSERT 3 ------------------------------------------------------------NOTE----------------------------------------------------------- Refer to Table 3.3.5-1 to determine which SRs apply for each LOP DG Start Instrumentation Function.
INSERT 4
NOTE---------------------------- Verification of relay setpoints not required. -------------------------------------------------------------------
24.3.3.11.1 DOC A04 2 3.3.5 Insert Page 3.3.5-2b CTS INSERT 5 Table 3.3.5-1 (page 1 of 1) Loss of Power (LOP) Diesel Generator (DG) Start Instrumentation FUNCTION APPLICABLE MODES OR OTHER SPECIFIED CONDITIONS REQUIRED CHANNELS SURVEILLANCE REQUIREMENTS ALLOWABLE VALUE NOMINAL TRIP SETPOINT 1.6.9 kV Shutdown Board -Loss of Voltagea.Voltage Se nsors 1,2,3,4, (a) 3 per Shutdown Board SR 3.3.5.1 SR 3.3.5.2 533 1 V and 5688 V 5520 V b.Diesel Generator Startand Load Shed Timer 1,2,3,4, (a) 1 per Shutdown Board SR 3.3.5.2 1.00 sec and 1.50 sec 1.25 sec 2.6.9 kV Shutdown Board -Degraded Voltagea.Voltage Se nsors 1,2,3,4, (a) 3 per Shutdown Board SR 3.3.5.1 SR 3.3.5.2 640 3.5 V and 6522.5 V 6456 V b.Diesel Generator Startand Load Shed Timer 1,2,3,4, (a) 1 per Shutdown Board SR 3.3.5.2 218.6 sec and 370 sec 300 sec c.SI/Degraded VoltageLogic Enable Timer 1,2,3,4 1 per Shutdown Board SR 3.3.5.2 7.5 sec and 11.5 sec 9.5 sec (a) When the associated DG is required to be OPERABLE by LCO 3.8.2, "AC Sources - Shutdown." 2Footnote # Function 1 Function 1.a Function 1.b Function 2 Function 2.a Function 2.b Function 2.c LOP DG Start Instrumentation (Without Setpoint Control Program) 3.3.5 A Westinghouse STS 3.3.5 A-1 Rev. 4.0 1 4 1 Amendment XXX SEQUOYAH UNIT 2 CTS 3.3 INSTRUMENTATION
3.3.5 A Loss of Power (LOP) Diesel Generator (DG) Start Instrumentation (Without Setpoint Control Program)
LCO 3.3.5 A [Three] channels per bus of the loss of voltage Function and [three] channels per bus of the degraded voltage Function shall be OPERABLE.
APPLICABILITY: MODES 1, 2, 3, and 4, When associated DG is required to be OPERABLE by LCO 3.8.2, "AC Sources - Shutdown." ACTIONS
NOTE-----------------------------------------------------------
Separate Condition entry is allowed for each Function.
CONDITION REQUIRED ACTION COMPLETION TIME
A. One or more Functions with one channel per bus inoperable.
A.1 --------------NOTE--------------
The inoperable channel may be bypassed for up to
[4] hours for surveillance testing of other channels.
Place channel in trip.
[6] hours B. One or more Functions with two or more channels per bus inoperable.
B.1 Restore all but one channel per bus to OPERABLE status.
1 hour1.157407e-5 days <br />2.777778e-4 hours <br />1.653439e-6 weeks <br />3.805e-7 months <br /> C. Required Action and associated Completion Time not met.
C.1 Enter applicable Condition(s) and Required Action(s) for the associated DG made inoperable by
instrumentation.
Immediately The LOP DG start instrumentation for each Function in Table 3.3.5-1 According to Table 3.3.5-1.3.3.3.11 Applicabilit y ACTION c Restore the inoperable channel to OPERABLE status.INSERT 1 1 2 2 2 2 2 2 3 ACTION a ACTION b ACTION a ACTION b voltage sensor voltage sensor
.1 INSERT 2 3.3.5 Insert Page 3.3.5-1 CTS INSERT 1 One or more Functions with two or more voltage sensor channels inoperable.
OR One or more Functions with one required timer inoperable.
INSERT 2 AND B.1.2 Restore required 1 hour1.157407e-5 days <br />2.777778e-4 hours <br />1.653439e-6 weeks <br />3.805e-7 months <br /> timer to OPERABLE status.
2 ACTION b ACTION b 2 LOP DG Start Instrumentation (Without Setpoint Control Program) 3.3.5 A Westinghouse STS 3.3.5 A-2 Rev. 4.0 1 4 1 Amendment XXX SEQUOYAH UNIT 2 CTS SURVEILLANCE REQUIREMENTS SURVEILLANCE FREQUENCY SR 3.3.5.1 [ Perform CHANNEL CHECK.
[ 12 hours1.388889e-4 days <br />0.00333 hours <br />1.984127e-5 weeks <br />4.566e-6 months <br /> OR In accordance with the Surveillance Frequency Control Program ] ]
2 Perform TADOT.
[ [31] days OR In accordance with the Surveillance
Frequency
Control Program
] SR 3.3.5.
3 Perform CHANNEL CALIBRATION with [Nominal Trip Setpoint and Allowable Value] as follows:
- a. [ Loss of voltage Allowable Value [2912] V and [ ] V with a time delay of [0.8]
+/- [ ] second. Loss of voltage Nominal Trip Setpoint [2975]
V with a time delay of [0.8]
+/- [ ] second. ] b. [ Degraded voltage Allowable Value [3683] V and [ ] V with a time delay of
[20] +/- [ ] seconds.
Degraded voltage Nominal Trip Setpoint [3746]
V with a time delay of [20]
+/- [ ] seconds. ] [ [18] months OR In accordance
with the Surveillance Frequency
Control Program
] INSERT 5 INSERT 3.1 2 2 2 5 5 5 5 2 24.3.3.11.1 INSERT 4 4 2 3.3.5 Insert Page 3.3.5-2a CTS INSERT 3 ------------------------------------------------------------NOTE----------------------------------------------------------- Refer to Table 3.3.5-1 to determine which SRs apply for each LOP DG Start Instrumentation Function.
INSERT 4
NOTE---------------------------- Verification of relay setpoints not required. -------------------------------------------------------------------
24.3.3.11.1 DOC A04 2 3.3.5 Insert Page 3.3.5-2b CTS INSERT 5 Table 3.3.5-1 (page 1 of 1) Loss of Power (LOP) Diesel Generator (DG) Start Instrumentation
FUNCTION APPLICABLE MODES OR OTHER SPECIFIED CONDITIONS
REQUIRED CHANNELS SURVEILLANCE REQUIREMENTS
ALLOWABLE VALUE NOMINAL TRIP SETPOINT 1. 6.9 kV Shutdown Board - Loss of Voltage
- a. Voltage Sensors 1,2,3,4, (a) 3 per Shutdown Board SR 3.3.5.1 SR 3.3.5.2 5331 V and 5688 V 5520 V b. Diesel Generator Start and Load Shed Timer 1,2,3,4, (a) 1 per Shutdown Board SR 3.3.5.2 1.00 sec and 1.50 sec 1.25 sec
- 2. 6.9 kV Shutdown Board - Degraded Voltage
- a. Voltage Sensors 1,2,3,4, (a) 3 per Shutdown Board SR 3.3.5.1 SR 3.3.5.2 6403.5 V and 6522.5 V 6456 V b. Diesel Generator Start and Load Shed Timer 1,2,3,4, (a) 1 per Shutdown Board SR 3.3.5.2 218.6 sec and 370 sec 300 sec c. SI/Degraded Voltage Logic Enable Timer 1,2,3,4 1 per Shutdown Board SR 3.3.5.2 7.5 sec and 11.5 sec 9.5 sec (a) When the associated DG is required to be OPERABLE by LCO 3.8.2, "AC Sources - Shutdown." 2Footnote # Function 1 Function 1.a Function 1.b Function 2 Function 2.a Function 2.b Function 2.c JUSTIFICATION FOR DEVIATIONS ITS 3.3.5, LOSS OF POWER (LOP) DIESEL GENERATOR (DG) START INSTRUMENTATION Sequoyah Unit 1 and Unit 2 Page 1 of 1 1. The type of Setpoint Control Program (Without Setpoint Control Program) and the Specification designator "A" are deleted since they are unnecessary. This information is provided in NUREG 1431, Rev. 4.0 to assist in identifying the appropriate Specification to be used as a model for the plant specific ITS conversion, but serves no purpose in the plant specific implementation. In addition, ISTS 3.3.5B (with Setpoint Control Program Specification) is not used and is not shown.
- 2. ISTS 3.3.5 is written for LOP DG start instrumentation that contains a loss of voltage function and a degraded voltage function. ITS 3.3.5 is written for LOP DG start instrumentation that contains a loss of voltage function, a degraded voltage function, a load shed function and a DG start function that is consistent with the current licensing bases. As such, a Table (Table 3.3.5-1) was added and the Applicability, ACTIONS, and Surveillance Requirements were changed to reflect the current licensing bases and renumbered as appropriate.
- 3. The ISTS contains bracketed information and/or values that are generic to Westinghouse vintage plants. The brackets are removed and the proper plant specific information/value is inserted to reflect the current licensing basis.
- 4. Changes are made (additions, deletions, and/or changes) to the ISTS that reflect the plant specific nomenclature, number, reference, system description, analysis, or licensing basis description.
- 5. ISTS SR 3.3.5.2 and SR 3.3.5.3 (ITS SR 3.3.5.1 and SR 3.3.5.2, respectively) provide two options for controlling the Frequencies of Surveillance Requirements. SQN is proposing to control the Surveillance Frequencies under the Surveillance Frequency Control Program.
Improved Standard Technical Specifications (ISTS) Bases Markup and Bases Justification for Deviations (JFDs)
LOP DG Start Instrumentation (Without Setpoint Control Program)
B 3.3.5 A Westinghouse STS B 3.3.5 A-1 Rev. 4.0 1 2SEQUOYAH UNIT 1 Revision XXX 1B 3.3 INSTRUMENTATION B 3.3.5 A Loss of Power (LOP) Diesel Generator (DG) Start Instrumentation (Without Setpoint Control Program)
BASES BACKGROUND The DGs provide a source of emergency power when offsite power is either unavailable or is insufficiently stable to allow safe unit operation. Undervoltage protection will generate a LOP start if a loss of voltage or degraded voltage condition occurs in the switchyard. There are two LOP start signals , one for each 4.16 kV vital bus. Three undervoltage relays with inverse time characteristics are provided on each 4160 Class 1E instrument bus for detecting a sustained degraded voltage condition or a loss of bus voltage. The relays are combined i n a two-out-of-three logic to generate a LOP signal if the voltage is below 75% for a short time or below 90% for a long time. The LOP start actuation is described in FSAR, Section 8.3 (Ref. 1). The Allowable Value in conjunction with the trip setpoint and LCO establishes the threshold for Engineered Safety Features Actuation
System (ESFAS) action to prevent exceeding acceptable limits such that the consequences of Design Basis Accidents (DBAs) will be acceptable.
The Allowable Value is considered a limiting value such that a channel is OPERABLE if the setpoint is found not to exceed the Allowable Value during the CHANNEL CALIBRATION. Note that although a channel is OPERABLE under these circumstances, the setpoint must be left adjusted to within the established calibration tolerance band of the setpoint in accordance with uncertainty assumptions stated in the referenced setpoint methodology, (as-left-criteria) and confirmed to be operating within the statistical allowances of the uncertainty terms assigned. Allowable Values and LOP DG Start Instrumentation Setpoints
REVIEWER'S NOTE-----------------------------------
Alternatively, a TS format incorporating an Allowable Value only may be proposed by a licensee. In this case the Nominal Trip Setpoint value is located in the TS Bases or in a licensee controlled document outside the TS. Changes to the trip setpoint value would be controlled by 10 CFR 50.59 or administratively as appropriate, and adjusted per the setpoint methodology and applicable surveillance requirements. At their option, the licensee may include the trip setpoint in the surveillance requirement as shown, or suggested by the licensee's setpoint methodology.
6.9 INSERT 1 U 1 2 2 3Shutdown Board B 3.3.5 Insert Page B 3.3.5-1 INSERT 1 Six undervoltage relays (two per phase) are provided on each 6.9 kV Shutdown Board for detecting a sustained degraded voltage condition or a loss of bus voltage. The relays are combined into two different two-out-of-three logic circuits; Loss of Voltage Function and Degraded Voltage Function. The Loss of Voltage Function (Function 1.a) logic generates a LOP signal if the voltage is below a nominal 80% for a short time while the Degraded Voltage Function (Function 2.a) logic generates a LOP signal if the voltage is below a nominal 93.5% for a longer time.
Six timers are provided on each 6.9 kV Shutdown Board, two timers associated with the Loss of Voltage Function logic and four timers associated with the Degraded Voltage Function logic. The two Loss of Voltage timers (Diesel Start and Load Shed Timers, Function 1.b) are arranged in a one-out-of-two logic with each timer set at a nominal 1.25 seconds. The Degraded Voltage timers are arranged in two sets of two; each set in a one-out-of-two logic. One set of Degraded Voltage timers (Diesel Start and Load Shed Timers, Function 2.b) are set at a nominal 300 seconds. The other set of Degraded Voltage timers (SI/Degraded Voltage Logic Enable Timers, Function 2.c) are set at a nominal 9.5 seconds. These timers along with the under voltage relays, ensure adequate voltage is available to the safety related loads and that unintended actuations from degraded voltage or voltage perturbations will not occur.
The Loss of Voltage Function voltage sensors monitor 6.9kV Shutdown Board voltage and actuate if voltage drops below 5520 volts. If two-out-of-three Loss of Voltage, Voltage Sensors detect less than 5520 volts, a signal is sent to the Diesel Generator Start and Load Shed Timers starting the 1.25 second timer. If Shutdown Board voltage increases to above the Loss of Voltage, Voltage Sensors setpoint before the Diesel Generator Start and Load Shed Timers reach their set time, the circuit returns to normal and the timers reset. If Shutdown Board voltage does not increase above the Loss of Voltage, Voltage Sensor setpoint within 1.25 seconds, a LOP signal is generated that trips the normal and alternate feeder breakers, starts the diesel generator, and trips major 6.9kV and 480V Shutdown Board loads.
The Degraded Voltage Function voltage sensors monitor 6.9kV Shutdown Board voltage and actuate if voltage drops below 6456 volts. If two-out-of-three Degraded Voltage, Voltage Sensors detect less than 6456 volts, a signal is sent to the Diesel Generator Start and Load Shed Timers starting their 300 second timer and to the SI/Degraded
Voltage Logic Enable Timers starting their 9.5 second timer. If Shutdown Board voltage increases to above the Degraded Voltage, Voltage Sensors setpoint before the Diesel Generator Start and Load Shed Timers or the SI/Degraded Voltage Logic Enable Timers reach their set time, the circuit returns to normal and the timers reset. If Shutdown Board voltage does not increase above the Degraded Voltage, Voltage Sensor setpoint within 300 seconds a LOP signal is generated that trips the normal and alternate feeder breakers, starts the Diesel Generator, and trips major 6.9kV and 480V Shutdown Board loads. If Shutdown Board voltage does not increase above the Degraded Voltage, Voltage Sensor setpoint within 9.5 seconds and a safety injection signal is present or if a safety injection signal is generated after 9.5 seconds, a signal is generated that trips major 6.9kV and 480V Shutdown Board loads.
2 LOP DG Start Instrumentation (Without Setpoint Control Program)
B 3.3.5 A Westinghouse STS B 3.3.5 A-2 Rev. 4.0 1 2SEQUOYAH UNIT 1 Revision XXX 1BASES
BACKGROUND (continued)
The Trip Setpoints used in the relays are based on the analytical limits presented in FSAR, Chapter 15 (Ref. 2). The selection of these trip setpoints is such that adequate protection is provided when all sensor and processing time delays are taken into account.
Setpoints adjusted consistent with the requirements of the Allowable Value ensure that the consequences of accidents will be acceptable, providing the unit is operated from within the LCOs at the onset of the accident and that the equipment functions as designed.
Allowable Values and/or Nominal Trip Setpoints are specified for each Function in SR 3.3.5.3. Nominal Trip Setpoints are also specified in the unit specific setpoint calculations. The trip setpoints are selected to ensure that the setpoint measured by the surveillance procedure does not exceed the Allowable Value if the relay is performing as required. If the measured setpoint does not exceed the Allowable Value, the relay is considered OPERABLE. Operation with a trip setpoint less conservative than the nominal Trip Setpoint, but within the Allowable Value, is acceptable provided that operation and testing is consistent with the assumptions of the unit specific setpoint calculation (Ref.
3).
APPLICABLE The LOP DG start instrumentati on is required for the Engineered Safety SAFETY Features (ESF) Systems to function in any accident with a loss of offsite ANALYSES power. Its design basis is that of the ESF Actuation System (ESFAS).
Accident analyses credit the loading of the DG based on the loss of offsite power during a loss of coolant accident (LOCA). The actual DG start has historically been associated with the ESFAS actuation. The DG loading has been included in the delay time associated with each safety system component requiring DG supplied power following a loss of offsite power.
The analyses assume a non-mechanistic DG loading, which does not explicitly account for each individual component of loss of power detection and subsequent actions.
The required channels of LOP DG start instrumentation, in conjunction
with the ESF systems powered from the DGs, provide unit protection in the event of any of the analyzed accidents discussed in Reference 2 , in which a loss of offsite power is assumed.
The delay times assumed in the safety analysis for the ESF equipment include the 10 second DG start delay, and the appropriate sequencing delay, if applicable. The response times for ESFAS actuated equipment in LCO 3.3.2, "Engineered Safety Feature Actuation System (ESFAS)
Instrumentation," include the appropriate DG loading and sequencing delay. 2Table 3.3.5-1 42, 3, and 4 2 5 2 s the associated setpoint scaling document LOP DG Start Instrumentation (Without Setpoint Control Program)
B 3.3.5 A Westinghouse STS B 3.3.5 A-3 Rev. 4.0 1 2SEQUOYAH UNIT 1 Revision XXX 1BASES
APPLICABLE SAFETY ANALYSES (continued)
The LOP DG start instrumentation channels satisfy Criterion 3 of 10 CFR 50.36(c)(2)(ii).
LCO The LCO for LOP DG start instrumentation requires that [three] channels per bus of both the loss of voltage and degraded voltage Functions shall be OPERABLE in MODES 1, 2, 3, and 4 when the LOP DG start instrumentation supports safety systems associated with the ESFAS. In MODES 5 and 6, the [three] channels must be OPERABLE whenever the associated DG is required to be OPERABLE to ensure that the automatic start of the DG is available when needed. A channel is OPERABLE with a trip setpoint value outside its calibration tolerance band provided the trip setpoint "as-found" value does not exceed its associated Allowable Value and provided the trip setpoint "as-left" value is adjusted to a value within the "as-left" calibration tolerance band of the Nominal Trip Setpoint. A trip setpoint may be set more conservative than the Nominal Trip Setpoint as necessary in response to plant conditions. Loss of the LOP DG Start Instrumentation Function could result in the delay of safety systems initiation when required. This could lead to unacceptable consequences during accidents. During the loss of offsite power the DG powers the motor driven auxiliary feedwater pumps. Failure of these pumps to start would leave only one turbine driven pump, as well as an increased potential for a loss of decay heat removal through the secondary system.
APPLICABILITY The LOP DG Start Instrumentation Functions are required in MODES 1, 2, 3, and 4 because ESF Functions are designed to provide protection in these MODES. Actuation in MODE 5 or 6 is required whenever the required DG must be OPERABLE so that it can perform its function on a
LOP or degraded power to the vital bus.
ACTIONS ---------------------------------------REVIEWER'S NOTE-------------------------------
In TS 3.3.5, "Loss of Power (LOP) Diesel Generator (DG) Start Instrumentation," the loss of power function was not included in the generic evaluations approved in either WCAP
-10271, as supplemented, or WCAP-14333. In order to apply relaxations similar to those in WCAP-10271, as supplemented, or WCAP
-14333 , licensees must submit plant specific evaluations for NRC review and approval.
In the event a channel's trip setpoint is found nonconservative with respect to the Allowable Value, or the channel is found inoperable, then the function that channel provides must be declared inoperable and the LCO Condition entered for the particular protection function affected.
Functions 5 5 4 4 3associated 6.9 kV Shutdown Boards 2, as required by Table 3.3.5-1 , as required by Table 3.3.5-1, LOP DG Start Instrumentation (Without Setpoint Control Program)
B 3.3.5 A Westinghouse STS B 3.3.5 A-4 Rev. 4.0 1 2SEQUOYAH UNIT 1 Revision XXX 1BASES
ACTIONS (continued)
Because the required channels are specified on a per bus basis, the Condition may be entered separately for each bus as appropriate.
A Note has been added in the ACTIONS to clarify the application of Completion Time rules. The Conditions of this Specification may be entered independently for each Function listed in the LCO. The Completion Time(s) of the inoperable channel(s) of a Function will be tracked separately for each Function starting from the time the Condition was entered for that Function.
A.1 Condition A applies to the LOP DG start Functions with one loss of voltage or one degraded voltage channel per b us inoperable.
If one channel is inoperable, Required Action A.1 requires that channel to be placed in trip within [6] hours. With a channel in trip, the LOP DG start instrumentation channels are configured to provide a one
-out-of-three logic to initiate a trip of the incoming offsite power.
A Note is added to allow bypassing an inoperable channel for up to
[4] hours for surveillance testing of other channels. This allowance is made where bypassing the channel does not cause an actuation and where at least two other channels are monitoring that parameter.
The specified Completion Time and time allowed for bypassing one channel are reasonable considering the Function remains fully OPERABLE on every b us and the low probability of an event occurring during these intervals.
B.1 Condition B applies when more than one loss of voltage or more th an one degraded voltage channel per bus are inoperable.
Required Action B.1 requires restoring all but one channel per bus to OPERABLE status. The 1 hour1.157407e-5 days <br />2.777778e-4 hours <br />1.653439e-6 weeks <br />3.805e-7 months <br /> Completion Time should allow ample time to repair most failures and takes into account the low probability of an event requiring a LOP start occurring during this interval. or more Functions with one voltage sensorof the voltage sensors restored to OPERABLE status shutdown board shutdown board voltage sensor 4 4 4 4 4 is one or more Functions have one required timer 4 2.1Required Action B.1.2 requires restoring the required load shed timer to OPERABLE status. one or more Functions have two or more volta ge sensor channels inoperable LOP DG Start Instrumentation (Without Setpoint Control Program)
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ACTIONS (continued)
C.1 Condition C applies to each of the LOP DG start Functions when the Required Action and associated Completion Time for Condition A or B are
not met.
In these circumstances the Conditions specified in LCO 3.8.1, "AC Sources - Operating," or LCO 3.8.2, "AC Sources - Shutdown," for the DG made inoperable by failure of the LOP DG start instrumentation are required to be entered immediately. The actions of those LCOs provide for adequate compensatory actions to assure unit safety.
SURVEILLANCE SR 3.3.5.1 REQUIREMENTS Performance of the CHANNEL CHECK ensures that a gross failure of instrumentation has not occurred. A CHANNEL CHECK is normally a comparison of the parameter indicated on one channel to a similar parameter on other channels. It is based on the assumption that instrument channels monitoring the same parameter should read approximately the same value. Significant deviations between the two instrument channels could be an indication of excessive instrument drift in one of the channels or of something even more serious. A CHANNEL CHECK will detect gross channel failure; thus, it is key to verifying that the instrumentation continues to operate properly between each CHANNEL CALIBRATION.
Agreement criteria are determined by the unit staff, based on a combination of the channel instrument uncertainties, including indication and readability. If a channel is outside the criteria, it may be an indication that the sensor or the signal processing equipment has drifted outside its limit. [ The Frequency of 12 hours1.388889e-4 days <br />0.00333 hours <br />1.984127e-5 weeks <br />4.566e-6 months <br /> is based on operating experience that demonstrates channel failure is rare. The CHANNEL CHECK supplements less formal, but more frequent, checks of channels during normal operational use of the displays associated with the LCO required channels.
OR The Surveillance Frequency is controlled under the Surveillance Frequency Control Program.
4 LOP DG Start Instrumentation B 3.3.5 Westinghouse STS B 3.3.5-6 Rev. 4.0 2SEQUOYAH UNIT 1 Revision XXX BASES
SURVEILLANCE REQUIREMENTS (continued)
REVIEWER'S NOTE-----------------------------------
Plants controlling Surveillance Frequencies under a Surveillance Frequency Control Program should utilize the appropriate Frequency description, given above, and the appropriate choice of Frequency in the Surveillance Requirement.
]
2 SR 3.3.5.2 is the performance of a TADOT. A successful test of the required contact(s) of a channel relay may be performed by the verification of the change of state of a single contact of the relay. This clarifies what is an acceptable TADOT of a relay. This is acceptable because all of the other required contacts of the relay are verified by other Technical Specifications and non-Technical Specifications tests at least once per refueling interval with applicable extensions. The test checks trip devices that provide actuati on signals directly, bypassing the analog process control equipment. For these tests, the relay trip setpoints are verified and adjusted as necessary. There is a plant specific program which verifies that the instrument channel functions as required by verifying the as-left and as-found setting are consistent with those established by the setpoint methodology.
[ The Frequency of 31 days is based on the known reliability of the relays and controls and the multichannel redundancy available, and has been shown to be acceptable through operating experience.
OR The Surveillance Frequency is controlled under the Surveillance Frequency Control Program.
REVIEWER'S NOTE-----------------------------------
Plants controlling Surveillance Frequencies under a Surveillance Frequency Control Program should utilize the appropriate Frequency description, given above, and the appropriate choice of Frequency in the Surveillance Requirement.
] 1 1 3 4 3 6INSERT 2 2 B 3.3.5 Insert Page B 3.3.5-6 INSERT 2 The SR is modified by a Note that excludes verification of setpoints for relays. Relay setpoints require elaborate bench calibration and are verified during CHANNEL CALIBRATION.
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SURVEILLANCE REQUIREMENTS (continued)
3 SR 3.3.5.3 is the performance of a CHANNEL CALIBRATION.
The setpoints, as well as the response to a loss of voltage and a degraded voltage test, shall include a single point verification that the trip occurs within the required time delay, as shown in Reference 1.
CHANNEL CALIBRATION is a complete check of the instrument loop, including the sensor. The test verifies that the channel responds to a measured parameter within the necessary range and accuracy. There is a plant specific program which verifies that the instrument channel functions as required by verifying the as-left and as-found setting are consistent with those established by the setpoint methodology.
[ The Frequency of [18]
months is based on operating experience and consistency with the typical industry refueling cycle and is justified by the assumption of an [18]
month calibration interval in the determination of the magnitude of equipment drift in the setpoint analysis.
OR The Surveillance Frequency is controlled under the Surveillance Frequency Control Program.
REVIEWER'S NOTE-----------------------------------
Plants controlling Surveillance Frequencies under a Surveillance Frequency Control Program should utilize the appropriate Frequency description, given above, and the appropriate choice of Frequency in the Surveillance Requirement.
]
REFERENCES 1. FSAR, Section
[8.3].
- 2. FSAR, Chapter
[15].
- 3. Plant specific setpoint methodology study. U 2 2 INSERT 3 4 3 6 2 2 5 2 5 B 3.3.5 Insert Page B 3.3.5-7 INSERT 3 TVA Calculation 27 DAT, "Demonstrated Accuracy Calculation 27 DAT." 3.TVA Calculation DS1-2, "Demonst rated Accuracy Calculation DS1-2." 4.TVA Calculation SQN-EEB-MS-TI06-0008, "Degraded Voltage Analysis." 2 LOP DG Start Instrumentation (Without Setpoint Control Program)
B 3.3.5 A Westinghouse STS B 3.3.5 A-1 Rev. 4.0 1 2SEQUOYAH UNIT 2 Revision XXX 1B 3.3 INSTRUMENTATION
B 3.3.5 A Loss of Power (LOP) Diesel Generator (DG) Start Instrumentation (Without Setpoint Control Program)
BASES
BACKGROUND The DGs provide a source of emergency power when offsite power is either unavailable or is insufficiently stable to allow safe unit operation. Undervoltage protection will generate a LOP start if a loss of voltage or degraded voltage condition occurs in the switchyard. There are two LOP start signals , one for each 4.16 kV vital bus. Three undervoltage relays with inverse time characteristics are provided on each 4160 Class 1E instrument bus for detecting a sustained degraded voltage condition or a loss of bus voltage. The relays are combined i n a two-out-of-three logic to generate a LOP signal if the voltage is below 75% for a short time or below 90% for a long time. The LOP start actuation is described in FSAR, Section 8.3 (Ref. 1).
The Allowable Value in conjunction with the trip setpoint and LCO establishes the threshold for Engineered Safety Features Actuation
System (ESFAS) action to prevent exceeding acceptable limits such that the consequences of Design Basis Accidents (DBAs) will be acceptable.
The Allowable Value is considered a limiting value such that a channel is OPERABLE if the setpoint is found not to exceed the Allowable Value during the CHANNEL CALIBRATION. Note that although a channel is OPERABLE under these circumstances, the setpoint must be left adjusted to within the established calibration tolerance band of the setpoint in accordance with uncertainty assumptions stated in the referenced setpoint methodology, (as-left-criteria) and confirmed to be operating within the statistical allowances of the uncertainty terms assigned.
Allowable Values and LOP DG Start Instrumentation Setpoints
REVIEWER'S NOTE-----------------------------------
Alternatively, a TS format incorporating an Allowable Value only may be proposed by a licensee. In this case the Nominal Trip Setpoint value is located in the TS Bases or in a licensee controlled document outside the TS. Changes to the trip setpoint value would be controlled by 10 CFR 50.59 or administratively as appropriate, and adjusted per the setpoint methodology and applicable surveillance requirements. At their option, the licensee may include the trip setpoint in the surveillance requirement as shown, or suggested by the licensee's setpoint methodology.
6.9 INSERT 1 U 1 2 2 3Shutdown Board B 3.3.5 Insert Page B 3.3.5-1 INSERT 1 Six undervoltage relays (two per phase) are provided on each 6.9 kV Shutdown Board for detecting a sustained degraded voltage condition or a loss of bus voltage. The relays are combined into two different two-out-of-three logic circuits; Loss of Voltage Function and Degraded Voltage Function. The Loss of Voltage Function (Function 1.a) logic generates a LOP signal if the voltage is below a nominal 80% for a short time while the Degraded Voltage Function (Function 2.a) logic generates a LOP signal if the voltage is below a nominal 93.5% for a longer time.
Six timers are provided on each 6.9 kV Shutdown Board, two timers associated with the Loss of Voltage Function logic and four timers associated with the Degraded Voltage Function logic. The two Loss of Voltage timers (Diesel Start and Load Shed Timers, Function 1.b) are arranged in a one-out-of-two logic with each timer set at a nominal 1.25 seconds. The Degraded Voltage timers are arranged in two sets of two; each set in a one-out-of-two logic. One set of Degraded Voltage timers (Diesel Start and Load Shed Timers, Function 2.b) are set at a nominal 300 seconds. The other set of Degraded Voltage timers (SI/Degraded Voltage Logic Enable Timers, Function 2.c) are set at a nominal 9.5 seconds. These timers along with the under voltage relays, ensure adequate voltage is available to the safety related loads and that unintended actuations from degraded voltage or voltage perturbations will not occur.
The Loss of Voltage Function voltage sensors monitor 6.9kV Shutdown Board voltage and actuate if voltage drops below 5520 volts. If two-out-of-three Loss of Voltage, Voltage Sensors detect less than 5520 volts, a signal is sent to the Diesel Generator Start and Load Shed Timers starting the 1.25 second timer. If Shutdown Board voltage increases to above the Loss of Voltage, Voltage Sensors setpoint before the Diesel Generator Start and Load Shed Timers reach their set time, the circuit returns to normal and the timers reset. If Shutdown Board voltage does not increase above the Loss of Voltage, Voltage Sensor setpoint within 1.25 seconds, a LOP signal is generated that trips the normal and alternate feeder breakers, starts the diesel generator, and trips major 6.9kV and 480V Shutdown Board loads.
The Degraded Voltage Function voltage sensors monitor 6.9kV Shutdown Board voltage and actuate if voltage drops below 6456 volts. If two-out-of-three Degraded Voltage, Voltage Sensors detect less than 6456 volts, a signal is sent to the Diesel Generator Start and Load Shed Timers starting their 300 second timer and to the SI/Degraded
Voltage Logic Enable Timers starting their 9.5 second timer. If Shutdown Board voltage increases to above the Degraded Voltage, Voltage Sensors setpoint before the Diesel Generator Start and Load Shed Timers or the SI/Degraded Voltage Logic Enable Timers reach their set time, the circuit returns to normal and the timers reset. If Shutdown Board voltage does not increase above the Degraded Voltage, Voltage Sensor setpoint within 300 seconds a LOP signal is generated that trips the normal and alternate feeder breakers, starts the Diesel Generator, and trips major 6.9kV and 480V Shutdown Board loads. If Shutdown Board voltage does not increase above the Degraded Voltage, Voltage Sensor setpoint within 9.5 seconds and a safety injection signal is present or if a safety injection signal is generated after 9.5 seconds, a signal is generated that trips major 6.9kV and 480V Shutdown Board loads.
2 LOP DG Start Instrumentation (Without Setpoint Control Program)
B 3.3.5 A Westinghouse STS B 3.3.5 A-2 Rev. 4.0 1 2SEQUOYAH UNIT 2 Revision XXX 1BASES
BACKGROUND (continued)
The Trip Setpoints used in the relays are based on the analytical limits presented in FSAR, Chapter 15 (Ref. 2). The selection of these trip setpoints is such that adequate protection is provided when all sensor and processing time delays are taken into account.
Setpoints adjusted consistent with the requirements of the Allowable Value ensure that the consequences of accidents will be acceptable, providing the unit is operated from within the LCOs at the onset of the accident and that the equipment functions as designed.
Allowable Values and/or Nominal Trip Setpoints are specified for each Function in SR 3.3.5.3. Nominal Trip Setpoints are also specified in the unit specific setpoint calculations. The trip setpoints are selected to ensure that the setpoint measured by the surveillance procedure does not exceed the Allowable Value if the relay is performing as required. If the measured setpoint does not exceed the Allowable Value, the relay is considered OPERABLE. Operation with a trip setpoint less conservative than the nominal Trip Setpoint, but within the Allowable Value, is acceptable provided that operation and testing is consistent with the assumptions of the unit specific setpoint calculation (Ref.
3).
APPLICABLE The LOP DG start instrumentati on is required for the Engineered Safety SAFETY Features (ESF) Systems to function in any accident with a loss of offsite ANALYSES power. Its design basis is that of the ESF Actuation System (ESFAS).
Accident analyses credit the loading of the DG based on the loss of offsite power during a loss of coolant accident (LOCA). The actual DG start has historically been associated with the ESFAS actuation. The DG loading has been included in the delay time associated with each safety system component requiring DG supplied power following a loss of offsite power.
The analyses assume a non-mechanistic DG loading, which does not explicitly account for each individual component of loss of power detection and subsequent actions.
The required channels of LOP DG start instrumentation, in conjunction
with the ESF systems powered from the DGs, provide unit protection in the event of any of the analyzed accidents discussed in Reference 2 , in which a loss of offsite power is assumed.
The delay times assumed in the safety analysis for the ESF equipment include the 10 second DG start delay, and the appropriate sequencing delay, if applicable. The response times for ESFAS actuated equipment in LCO 3.3.2, "Engineered Safety Feature Actuation System (ESFAS)
Instrumentation," include the appropriate DG loading and sequencing delay. 2Table 3.3.5-1 42, 3, and 4 2 5 2 s the associated setpoint scaling document LOP DG Start Instrumentation (Without Setpoint Control Program)
B 3.3.5 A Westinghouse STS B 3.3.5 A-3 Rev. 4.0 1 2SEQUOYAH UNIT 2 Revision XXX 1BASES
APPLICABLE SAFETY ANALYSES (continued)
The LOP DG start instrumentation channels satisfy Criterion 3 of 10 CFR 50.36(c)(2)(ii).
LCO The LCO for LOP DG start instrumentation requires that [three] channels per bus of both the loss of voltage and degraded voltage Functions shall be OPERABLE in MODES 1, 2, 3, and 4 when the LOP DG start instrumentation supports safety systems associated with the ESFAS. In MODES 5 and 6, the [three] channels must be OPERABLE whenever the associated DG is required to be OPERABLE to ensure that the automatic start of the DG is available when needed. A channel is OPERABLE with a trip setpoint value outside its calibration tolerance band provided the trip setpoint "as-found" value does not exceed its associated Allowable Value and provided the trip setpoint "as-left" value is adjusted to a value within the "as-left" calibration tolerance band of the Nominal Trip Setpoint. A trip setpoint may be set more conservative than the Nominal Trip Setpoint as necessary in response to plant conditions. Loss of the LOP DG Start Instrumentation Function could result in the delay of safety systems initiation when required. This could lead to unacceptable consequences during accidents. During the loss of offsite power the DG powers the motor driven auxiliary feedwater pumps. Failure of these pumps to start would leave only one turbine driven pump, as well as an increased potential for a loss of decay heat removal through the secondary system.
APPLICABILITY The LOP DG Start Instrumentation Functions are required in MODES 1, 2, 3, and 4 because ESF Functions are designed to provide protection in these MODES. Actuation in MODE 5 or 6 is required whenever the required DG must be OPERABLE so that it can perform its function on a
LOP or degraded power to the vital bus.
ACTIONS ---------------------------------------REVIEWER'S NOTE-------------------------------
In TS 3.3.5, "Loss of Power (LOP) Diesel Generator (DG) Start Instrumentation," the loss of power function was not included in the generic evaluations approved in either WCAP
-10271, as supplemented, or WCAP-14333. In order to apply relaxations similar to those in WCAP-10271, as supplemented, or WCAP
-14333 , licensees must submit plant specific evaluations for NRC review and approval.
In the event a channel's trip setpoint is found nonconservative with respect to the Allowable Value, or the channel is found inoperable, then the function that channel provides must be declared inoperable and the LCO Condition entered for the particular protection function affected.
Functions 5 5 4 4 3associated 6.9 kV Shutdown Boards 2, as required by Table 3.3.5-1 , as required by Table 3.3.5-1, LOP DG Start Instrumentation (Without Setpoint Control Program)
B 3.3.5 A Westinghouse STS B 3.3.5 A-4 Rev. 4.0 1 2SEQUOYAH UNIT 2 Revision XXX 1BASES
ACTIONS (continued)
Because the required channels are specified on a per bus basis, the Condition may be entered separately for each bus as appropriate.
A Note has been added in the ACTIONS to clarify the application of Completion Time rules. The Conditions of this Specification may be entered independently for each Function listed in the LCO. The Completion Time(s) of the inoperable channel(s) of a Function will be tracked separately for each Function starting from the time the Condition was entered for that Function.
A.1 Condition A applies to the LOP DG start Functions with one loss of voltage or one degraded voltage channel per b us inoperable.
If one channel is inoperable, Required Action A.1 requires that channel to be placed in trip within [6] hours. With a channel in trip, the LOP DG start instrumentation channels are configured to provide a one
-out-of-three logic to initiate a trip of the incoming offsite power.
A Note is added to allow bypassing an inoperable channel for up to
[4] hours for surveillance testing of other channels. This allowance is made where bypassing the channel does not cause an actuation and where at least two other channels are monitoring that parameter.
The specified Completion Time and time allowed for bypassing one channel are reasonable considering the Function remains fully OPERABLE on every b us and the low probability of an event occurring during these intervals.
B.1 Condition B applies when more than one loss of voltage or more th an one degraded voltage channel per bus are inoperable.
Required Action B.1 requires restoring all but one channel per bus to OPERABLE status. The 1 hour1.157407e-5 days <br />2.777778e-4 hours <br />1.653439e-6 weeks <br />3.805e-7 months <br /> Completion Time should allow ample time to repair most failures and takes into account the low probability of an event requiring a LOP start occurring during this interval. or more Functions with one voltage sensorof the voltage sensors restored to OPERABLE status shutdown board shutdown board voltage sensor 4 4 4 4 4 is one or more Functions have one required timer 4 2.1Required Action B.1.2 requires restoring the required load shed timer to OPERABLE status. one or more Functions have two or more volta ge sensor channels inoperable LOP DG Start Instrumentation (Without Setpoint Control Program)
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ACTIONS (continued)
C.1 Condition C applies to each of the LOP DG start Functions when the Required Action and associated Completion Time for Condition A or B are
not met.
In these circumstances the Conditions specified in LCO 3.8.1, "AC Sources - Operating," or LCO 3.8.2, "AC Sources - Shutdown," for the DG made inoperable by failure of the LOP DG start instrumentation are required to be entered immediately. The actions of those LCOs provide for adequate compensatory actions to assure unit safety.
SURVEILLANCE SR 3.3.5.1 REQUIREMENTS Performance of the CHANNEL CHECK ensures that a gross failure of instrumentation has not occurred. A CHANNEL CHECK is normally a comparison of the parameter indicated on one channel to a similar parameter on other channels. It is based on the assumption that instrument channels monitoring the same parameter should read approximately the same value. Significant deviations between the two instrument channels could be an indication of excessive instrument drift in one of the channels or of something even more serious. A CHANNEL CHECK will detect gross channel failure; thus, it is key to verifying that the instrumentation continues to operate properly between each CHANNEL CALIBRATION.
Agreement criteria are determined by the unit staff, based on a combination of the channel instrument uncertainties, including indication and readability. If a channel is outside the criteria, it may be an indication that the sensor or the signal processing equipment has drifted outside its limit. [ The Frequency of 12 hours1.388889e-4 days <br />0.00333 hours <br />1.984127e-5 weeks <br />4.566e-6 months <br /> is based on operating experience that demonstrates channel failure is rare. The CHANNEL CHECK supplements less formal, but more frequent, checks of channels during normal operational use of the displays associated with the LCO required channels.
OR The Surveillance Frequency is controlled under the Surveillance Frequency Control Program.
4 LOP DG Start Instrumentation B 3.3.5 Westinghouse STS B 3.3.5-6 Rev. 4.0 2SEQUOYAH UNIT 2 Revision XXX BASES SURVEILLANCE REQUIREMENTS (continued) -----------------------------------REVIEWER'S NOTE-----------------------------------
Plants controlling Surveillance Frequencies under a Surveillance Frequency Control Program should utilize the appropriate Frequency description, given above, and the appropriate choice of Frequency in the Surveillance Requirement.
] SR 3.3.5.
2 SR 3.3.5.2 is the performance of a TADOT. A successful test of the required contact(s) of a channel relay may be performed by the verification of the change of state of a single contact of the relay. This clarifies what is an acceptable TADOT of a relay. This is acceptable because all of the other required contacts of the relay are verified by other Technical Specifications and non-Technical Specifications tests at least once per refueling interval with applicable extensions. The test checks trip devices that provide actuati on signals directly, bypassing the analog process control equipment. For these tests, the relay trip setpoints are verified and adjusted as necessary. There is a plant specific program which verifies that the instrument channel functions as required by verifying the as-left and as-found setting are consistent with those established by the setpoint methodology.
[ The Frequency of 31 days is based on the known reliability of the relays and controls and the multichannel redundancy available, and has been shown to be acceptable through operating experience.
OR The Surveillance Frequency is controlled under the Surveillance Frequency Control Program. -----------------------------------REVIEWER'S NOTE-----------------------------------
Plants controlling Surveillance Frequencies under a Surveillance Frequency Control Program should utilize the appropriate Frequency description, given above, and the appropriate choice of Frequency in the Surveillance Requirement.
] 1 1 3 4 3 6INSERT 2 2 B 3.3.5 Insert Page B 3.3.5-6 INSERT 2 The SR is modified by a Note that excludes verification of setpoints for relays. Relay setpoints require elaborate bench calibration and are verified during CHANNEL CALIBRATION.
4 LOP DG Start Instrumentation B 3.3.5 Westinghouse STS B 3.3.5 A-7 Rev. 4.0 1 2Sequoyah Unit 2 Revision XXX BASES
SURVEILLANCE REQUIREMENTS (continued)
3 SR 3.3.5.3 is the performance of a CHANNEL CALIBRATION.
The setpoints, as well as the response to a loss of voltage and a degraded voltage test, shall include a single point verification that the trip occurs within the required time delay, as shown in Reference 1.
CHANNEL CALIBRATION is a complete check of the instrument loop, including the sensor. The test verifies that the channel responds to a measured parameter within the necessary range and accuracy. There is a plant specific program which verifies that the instrument channel functions as required by verifying the as-left and as-found setting are consistent with those established by the setpoint methodology.
[ The Frequency of [18]
months is based on operating experience and consistency with the typical industry refueling cycle and is justified by the assumption of an [18]
month calibration interval in the determination of the magnitude of equipment drift in the setpoint analysis.
OR The Surveillance Frequency is controlled under the Surveillance Frequency Control Program.
REVIEWER'S NOTE-----------------------------------
Plants controlling Surveillance Frequencies under a Surveillance Frequency Control Program should utilize the appropriate Frequency description, given above, and the appropriate choice of Frequency in the Surveillance Requirement.
]
REFERENCES 1. FSAR, Section
[8.3].
- 2. FSAR, Chapter
[15].
- 3. Plant specific setpoint methodology study. U 2 2 INSERT 3 4 3 6 2 2 5 2 5 B 3.3.5 Insert Page B 3.3.5-7 INSERT 3 TVA Calculation 27 DAT, "Demonstrated Accuracy Calculation 27 DAT." 3.TVA Calculation DS1-2, "Demonst rated Accuracy Calculation DS1-2." 4.TVA Calculation SQN-EEB-MS-TI06-0008, "Degraded Voltage Analysis." 2 JUSTIFICATION FOR DEVIATIONS ITS 3.3.5 BASES, LOSS OF POWER (LOP) DIESEL GENERATOR (DG) START INSTRUMENTATION Sequoyah Unit 1 and Unit 2 Page 1 of 1 1. The type of Setpoint Control Program (Without Setpoint Control Program) and the Specification designator "A" are deleted since they are unnecessary. This information is provided in NUREG 1431, Rev. 4.0 to assist in identifying the appropriate Specification to be used as a model for the plant specific ITS conversion, but serves no purpose in the plant specific implementation. In addition, ISTS B 3.3.6B (with Setpoint Control Program Specification) is not used and is not shown.
- 2. Changes are made (additions, deletions, and/or changes) to the ISTS Bases that reflect the plant specific nomenclature, number, reference, system description, analysis, or licensing basis description.
- 3. The Reviewer's Note has been deleted. This information is for the NRC reviewer to be keyed into what is needed to meet this requirement. This Note is not meant to be retained in the final version of the plant specific submittal.
- 4. Changes are made to be consistent with changes made to the Specification
- 5. The ISTS contains bracketed information and/or values that are generic to Westinghouse vintage plants. The brackets are removed and the proper plant specific information/value is inserted to reflect the current licensing basis.
- 6. ISTS SR 3.3.5.2 and SR 3.3.5.3 (ITS SR 3.3.5.1 and SR 3.3.5.2, respectively) Bases provide two options for controlling the Frequencies of Surveillance Requirements. SQN is proposing to control the Surveillance Frequencies under the Surveillance Frequency Control Program. Additionally, the Frequency description which is being removed will be included in the Surveillance Frequency Control Program.
Specific No Significant Haza rds Considerations (NSHCs)
DETERMINATION OF NO SIGNIFICANT HAZARDS CONSIDERATIONS ITS 3.3.5, LOSS OF POWER (LOP) DIESEL GENERATOR (DG) START INSTRUMENTATION Sequoyah Unit 1 and 2 Page 1 of 1 There are no specific No Significant Hazards Considerations for this Specification.
ATTACHMENT 6 ITS 3.3.6, CONTAINMENT VENTILATION ISOLATION INSTRUMENTATION
Current Technical Specification (CTS) Markup and Discussion of Changes (DOCs)
A01ITS ITS 3.3.6 INSTRUMENTATION 3/4.3.2 ENGINEERED SAFETY FEATURE ACTUATION SYSTEM INSTRUMENTATION LIMITING CONDITION FOR OPERATION 3.3.2.1 The Engineered Safety Feature Actuation System (ESFAS) instrumentation channels and interlocks shown in Table 3.3-3 shall be OPERABLE with their trip setpoints set consistent with the values shown in the Nominal Trip Setpoint column of Table 3.3-4. APPLICABILITY: As shown in Table 3.3-3.
ACTION: a. With an ESFAS instrumentation channel or interlock trip setpoint less conservative than the value shown in the Allowable Values column of Table 3.3-4, declare the channel inoperable and apply the applicable ACTION requirement of Table 3.3-3 until the channel is restored to OPERABLE status with the trip setpoint adjusted consistent with the Nominal Trip Setpoint value.
- b. With an ESFAS instrumentation channel or interlock inoperable, take the ACTION shown in Table 3.3-3.
SURVEILLANCE REQUIREMENTS 4.3.2.1.1 Each ESFAS instrumentation channel shall be demonstrated OPERABLE by the performance of the CHANNEL CHECK, CHANNEL CALIBRATION and CHANNEL FUNCTIONAL TEST operations for the MODES and at the frequencies shown in Table 4.3-2.
4.3.2.1.2 The logic for the interlocks shall be demonstrated OPERABLE during the automatic actuation logic test. The total interlock function shall be demonstrated OPERABLE at least once per 18 months during CHANNEL CALIBRATION testing of each channel affected by interlock operation.
4.3.2.1.3 The ENGINEERED SAFETY FEATURES RESPONSE TIME of each ESFAS function shall be verified to be within the limit at least once per 18 months. Each verification shall include at least one train such that both trains are verified at least once per 36 months and one channel per function such that all channels are verified at least once per N times 18 months where N is the total number of redundant channels in a specific ESFAS function as shown in the "Total No. of Channels" Column of Table 3.3-3.
September 13, 2006 SEQUOYAH - UNIT 1 3/4 3-14 Amendment No. 190, 251, 310 Page 1 of 24 See ITS 3.3.2 Containment Ventilation Isolation Containment Ventilation Isolation Containment Ventilation Isolation A02 A02 A02 A02ACTUATION LOGIC TEST / COT / TADOT M01 A02 A03 A03Containment Ventilation Isolation Containment Ventilation Isolation LCO 3.3.6 Applicabilit y ACTION A ACTION A SR Note SR 3.3.6.8 A0418 months on a STAGGERED TEST BASIS In accordance with the Surveillance Frequency Control Program A05 LA01 L01Add proposed SR 3.3.6.8 Note A01ITS ITS 3.3.6 TABLE 3.3-3 (Continued )
ENGINEERED SAFETY FEATURE ACTUATION SYSTEM INSTRUMENTATION FUNCTIONAL UNIT TOTAL NO.
OF CHANNE LS CHANNELS TO TRIP MINIMUM CHANNELS OPERABLE APPLICABLE MODES ACTION b.Phase "B" Iso lation1)Manual 2 1** 2 1, 2, 3, 4 20 2)Automatic Actuation Logi c 2 1 2 1, 2, 3, 4 15 3) Contai nment Pressure-High-High 4 2 3 1, 2, 3 18 c.Contai nment Ventilation 2 1 2 1, 2, 3, 4 19 Isolation1)Manual2)Automatic Isol ation Logi c 2 1 2 1, 2, 3, 4 15 3)Containment Purge Air 2 1 1 1, 2, 3, 4 19 Exhaust Moni tor Radioactivity-High**Two switches must be operated simultaneously for actuation. April 11, 2005 SEQUOYAH - UNIT 1 3/4 3-17 Amendment No. 41, 63, 168, 301 Page 2 of 24 See ITS 3.3.2 See ITS 3.3.2 LA02 LA02 LA02 A02Containment Ventilation Isolation Table 3.3.6-1 Function 1 Function 2 Function 3 M02Add proposed Function 4.
A01ITS ITS 3.3.6 TABLE 3.3-3 (Continued)
TABLE NOTATION
- Trip function may be bypassed in this MODE below P-11 (Pressurizer Pressure Block of Safety Injection) setpoint.
- Trip function automatically blocked above P-11 and may be blocked below P11 when Safety Injection on Steam Line Pressure-Low is not blocked.
ACTION STATEMENTS
ACTION 15 - With the number of OPERABLE Channels one less than the Total Number of Channels, be in at least HOT STANDBY within 12 hours1.388889e-4 days <br />0.00333 hours <br />1.984127e-5 weeks <br />4.566e-6 months <br /> and in COLD SHUTDOWN within the following 30 hours3.472222e-4 days <br />0.00833 hours <br />4.960317e-5 weeks <br />1.1415e-5 months <br />; however, one channel may be bypassed for up to 4 hours4.62963e-5 days <br />0.00111 hours <br />6.613757e-6 weeks <br />1.522e-6 months <br /> for surveillance testing per Specification 4.3.2.1.1 provided the other channel is OPERABLE.
ACTION 16 - Deleted.
ACTION 17 - With the number of OPERABLE Channels one less than the Total Number of Channels, STARTUP and/or POWER OPERATION may proceed provided the following conditions are satisfied:
- a. The inoperable channel is placed in the tripped condition within 6 hours6.944444e-5 days <br />0.00167 hours <br />9.920635e-6 weeks <br />2.283e-6 months <br />.
- b. The Minimum Channels OPERABLE requirements is met; however, the inoperable channel may be bypassed for up to 4 hours4.62963e-5 days <br />0.00111 hours <br />6.613757e-6 weeks <br />1.522e-6 months <br /> for surveillance testing of other channels per Specification 4.3.2.1.1.
ACTION 18 - With the number of OPERABLE Channels one less than the Total Number of Channels, operation may proceed provided the inoperable channel is placed in the bypassed condition within 6 hours6.944444e-5 days <br />0.00167 hours <br />9.920635e-6 weeks <br />2.283e-6 months <br /> and the Minimum Channels OPERABLE requirement is met; one additional channel may be bypassed for up to 4 hours4.62963e-5 days <br />0.00111 hours <br />6.613757e-6 weeks <br />1.522e-6 months <br /> for surveillance testing per Specification 4.3.2.1.1.
ACTION 19 - With less than the Minimum Channels OPERABLE, operation may continue provided the containment purge supply and exhaust valves are maintained closed. ACTION 20 - With the number of OPERABLE Channels one less than the Total Number of Channels, restore the inoperable channel to OPERABLE status within 48 hours5.555556e-4 days <br />0.0133 hours <br />7.936508e-5 weeks <br />1.8264e-5 months <br /> or be in at least HOT STANDBY within the next 6 hours6.944444e-5 days <br />0.00167 hours <br />9.920635e-6 weeks <br />2.283e-6 months <br /> and in COLD SHUTDOWN within the following 30 hours3.472222e-4 days <br />0.00833 hours <br />4.960317e-5 weeks <br />1.1415e-5 months <br />.
September 14, 2006 SEQUOYAH - UNIT 1 3/4 3-22 Amendment No. 63, 141, 168, 182, 188, 202, 207, 213, 301, 311 Page 3 of 24 See ITS 3.3.2 See ITS 3.3.2 See ITS 3.3.2 L02Add proposed ACTIONS Note.
A06 ACTION A ACTION A Add proposed Required Action A.1 M03Add proposed Required Action A.1 L02 A01ITS ITS 3.3.6 TABLE 3.3-4 (Continued)
ENGINEERED SAFETY FEATURE ACTUATION SYSTEM INSTRUMENTATION TRIP SETPOINTS
FUNCTIONAL UNIT NOMINAL TRIP SETPOINT ALLOWABLE VALUES
- a. Manual Initiation
Not Applicable
Not Applicable
- b. Automatic Actuation Logic Not Applicable Not Applicable
- c. Containment Pressure--High-High 2.81 psig 2.9 psig
- 3. CONTAINMENT ISOLATION
- a. Phase "A" Isolation
- 1. Manual
Not Applicable
Not Applicable
- 2. From Safety Injection Automatic Actuation logic Not Applicable Not Applicable
- b. Phase "B" Isolation
- 1. Manua1
Not Applicable
Not Applicable
- 2. Automatic Actuation Logic Not Applicable Not Applicable
- 3. Containment Pressure--High-High 2.81 psig 2.9 psig
- c. Containment Ventilation Isolation
- 1. Manual
Not Applicable
Not Applicable
- 2. Automatic Isolation Logic Not Applicable Not Applicable
September 13, 2006 SEQUOYAH - UNIT 1 3/4 3-25 Amendment No. 12, 141, 310 Page 4 of 24 See ITS 3.3.2 A03 A03 A02Containment Ventilation Isolation Table 3.3.6-1 Function 1 Function 2 See ITS 3.3.2 See ITS 3.3.2 A01ITS ITS 3.3.6 TABLE 3.3-4 (Continued)
ENGINEERED SAFETY FEATURE ACTUATION SYSTEM INSTRUMENTATION TRIP SETPOINTS FUNCTIONAL UNIT NOMINAL TRIP SETPOINT ALLOWABLE VALUES
- 3. Containment Purge Air Exhaust Monitor Radioactivity-High 8.5 x 10-3 µCi/cc 8.5 x 10-3 µCi/cc 4. STEAM LINE ISOLATION
- a. Manual
Not Applicable
Not Applicable
- b. Automatic Actuation Logic
Not Applicable
Not Applicable c. Containment Pressure-- 2.81 psig 2.9 psig High-High
- d. Steam Line Pressure--Low 600 psig steam line pressure 592.2 psig steam line pressure (Note 1) (Note 1)
- e. Negative Steam Line 100.0 psi (Note 2) 107.8 psi (Note 2) Pressure Rate-High
- 5. TURBINE TRIP AND FEEDWATER ISOLATION
- a. Steam Generator Water 81% of narrow range instrument 81.7% of narrow range level-- High-High span each steam generator instrument span each steam generator
- b. Automatic Actuation Logic N.A.
N.A.
September 13, 2006 SEQUOYAH - UNIT 1 3/4 3-26 Amendment No. 63, 141, 168, 310 Page 5 of 24 See ITS 3.3.2 A02Containment Ventilation Isolation Table 3.3.6-1 Function 3 A03 A01ITS ITS 3.3.6 TABLE 4.3-2 (Continued)
ENGINEERED SAFETY FEATURE ACTUATION SYSTEM INSTRUMENTATION SURVEILLANCE REQUIREMENTS CHANNE L CHE CK CHANNEL CALIBRATION CHANNEL FUNCTIONAL TEST MODES FOR WHICH SURVEILLANCE IS REQUIRED FUNCTIONAL UNIT CONTAINMENT ISOLATIONa.Phase "A" Isolation1)Manual N.A. N.A. R 1, 2, 3, 4 2)From Safety InjectionAutomatic Actuation Logic N.A. N.A.
M(1) 1, 2, 3, 4 b.Phase "B" Isolation1)Manual N.A. N.A. R 1, 2, 3, 4 2)Automatic Actuation Logic N.A. N.A.
M(1) 1, 2, 3, 4 3)Containment Pressure-- High-High S R Q 1, 2, 3 c.Containment Ventilation Isolation1)Manual N.A. N.A. R 1, 2, 3, 4 2)Automatic Isolation Logic N.A. N.A.
M(1) 1, 2, 3, 4 3)Containment Purge AirExhaust Monitor Radio-activity-High S R Q 1, 2, 3, 4 March 4, 1996 SEQUOYAH - UNIT 1 3/4 3-35 Amendment No. 47, 168, 220 Page 6 of 24 ACTUATION LOGIC TEST / COT / TADOT M01SR 3.3.6.1 SR 3.3.6.7 A02Containment Ventilation Isolation 92 days on a STAGGERED TEST BASIS L03Table 3.3.6-1 Function 1 Function 2 Function 3 M04Add proposed SR 3.3.6.3 with a Frequency of 92 days on a STAGGERED TEST BASIS for ITS Table 3.3.6-1 Function 2 Add proposed SR 3.3.6.5 with a of Frequency of every 18 months for ITS Table 3.3.6-1 Function 2 M04In accordance with the Surveillance Frequency Control Program LA01 See ITS 3.3.2 SR 3.3.6.6SR 3.3.6.2SR 3.3.6.4In accordance with the Surveillance Frequency Control Program LA01Add proposed SR 3.3.6.6 Note A07 A01ITS ITS 3.3.6 TABLE 4 .3-2 (Continued)
TABLE NOTATION (1) Each train or logic channel shall be tested at least every 62 days on a STAGGERED TEST BASIS.
(2) The total interlock function shall be demonstrated OPERABLE during CHANNEL CALIBRATION testing of each channel affected by interlock operation. September 14, 2006 SEQUOYAH - UNIT 1 3/4 3-38 Amendment No. 47, 182, 188, 207, 311 Page 7 of 24 See ITS 3.3.2 92 days on a STAGGERED TEST BASIS L03 LA01In accordance with the Surveillance Frequency Control Program SR 3.3.6.2 A01ITS ITS 3.3.6 3/4.3.3 MONITORING INSTRUMENTATION RADIATION MONITORING INSTRUMENTATION LIMITING CONDITION FOR OPERATION 3.3.3.1 The radiation monitoring instrumentation channels shown in Table 3.3-6 shall be OPERABLE with their alarm/trip setpoints within the specified limits.
APPLICABILITY: As shown in Table 3.3-6.
ACTION: a. With a radiation monitoring channel alarm/trip setpoint exceeding the value shown in Table 3.3-6, adjust the setpoint to within the limit within 4 hours4.62963e-5 days <br />0.00111 hours <br />6.613757e-6 weeks <br />1.522e-6 months <br /> or declare the channel inoperable.
- b. With one or more radiation monitoring channels inoperable, take the ACTION shown in Table 3.3-6.
- c. The provisions of Specification 3.0.3 are not applicable.
SURVEILLANCE REQUIREMENTS 4.3.3.1 Each radiation monitoring instrumentation channel shall be demonstrated OPERABLE by the performance of the CHANNEL CHECK, CHANNEL CALIBRATION and CHANNEL FUNCTIONAL TEST operations for the MODES and at the frequencies shown in Table 4.3-3.
April 11, 2005 SEQUOYAH - UNIT 1 3/4 3-39 Amendment No. 301 Page 8 of 24 M05 A03 M06 A02 A02 A02 COT M01 A02Containment Ventilation Isolation Containment Ventilation Isolation Containment Ventilation Isolation Containment Ventilation Isolation LCO 3.3.6 Applicabilit y ACTION A ACTION B SR Note A01ITS ITS 3.3.6 TABLE 3.3-6 RADIATION MONITORING INSTRUMENTATION INSTRUMENT MINIMUM CHANNELS OPERABLE APPLICABLE MODES ALARM/TRIP SETPOINT MEASUREMENT RANGE ACTION 1.AREA MONITORa.Fuel Storage Pool Area 1* 151 mR/hr 10 10 4 mR/hr26 2.PROCESS MONITORS a.Containment Purge Air 1 1, 2, 3, 4
& 6 8.5x 10-3µCi/cc 10 - 10 7 cpm28 b.Containment i.Deletedii.ParticulateActivityRCS LeakageDetection 1 1, 2, 3 & 4 N/A 10 - 10 7 cpm 27 c.Control Room Isolation 2 ALL MODES and during movement of irradiated fuel assemblies 400 cpm**
10 - 10 7 cpm 29 _______________________________ *With fuel in the storage pool or building
- Equivalent to 1.0 x 10
-5 µCi/cc.December 04, 2008 SEQUOYAH - UNIT 1 3/4 3-40 Amendment Nos. 12, 60, 112, 168, 256, 310, 322 Page 9 of 24 A02 See ITS 3.3.8 See ITS 3.4.15 See ITS 3.3.7 See ITS 3.3.7 See ITS 3.3.8 LA03 LA03 L04Containment Ventilation Isolation During movement of recently irradiated fuel assemblies within containment Function 3 Table 3.3.6-1 A03 A01ITS ITS 3.3.6 TABLE 3.3-6 (Continued)
ACTION STATEMENTS ACTION 26 - With the number of OPERABLE channels less than required by the Minimum Channels OPERABLE requirement, perform area surveys of the monitored area with portable monitoring instrumentation at least once per 24 hours2.777778e-4 days <br />0.00667 hours <br />3.968254e-5 weeks <br />9.132e-6 months <br />. ACTION 27 - With the number of OPERABLE channels less than required by the Minimum Channels OPERABLE requirement, comply with the ACTION requirements of Specification 3.4.6.1. ACTION 28 - With the number of OPERABLE channels less than required by the Minimum Channels OPERABLE requirement, comply with the ACTION requirements of Specification 3.9.9 (MODE 6) and 3.3.2.1 (MODES 1, 2, 3, and 4). ACTION 29 - a.With one channel inoperable, place the associated control room emergencyventilation system (CREVS) train in recirculation mode of operation within 7 daysor be at least HOT STANDBY within the next 6 hours6.944444e-5 days <br />0.00167 hours <br />9.920635e-6 weeks <br />2.283e-6 months <br /> and in COLD SHUTDOWNwithin the following 30 hours3.472222e-4 days <br />0.00833 hours <br />4.960317e-5 weeks <br />1.1415e-5 months <br />.b.With two channels inoperable, within 1 hour1.157407e-5 days <br />2.777778e-4 hours <br />1.653439e-6 weeks <br />3.805e-7 months <br /> initiate and maintain operation of oneCREVS train in the recirculation mode of operation and ent er the requiredActions for one CREVS train made inoperable by inoperable CREVS actuationinstrumentation.Orplace both trains in the recirculation mode of operation within one hour.If the completion time of Action 29b cannot be met in Modes 1, 2, 3, and 4, be inat least HOT STANDBY within the next 6 hours6.944444e-5 days <br />0.00167 hours <br />9.920635e-6 weeks <br />2.283e-6 months <br /> and in COLD SHUTDOWN withinthe following 30 hours3.472222e-4 days <br />0.00833 hours <br />4.960317e-5 weeks <br />1.1415e-5 months <br />.If the completion time of Action 29b cannot be met during the movement ofirradiated fuel assemblies, suspend core alterations and suspend movement ofirradiated fuel assemblies.If the completion time of Action 29b cannot be met in Modes 5 and 6, initiateaction to restore one CREVS train.May 31, 2000 SEQUOYAH - UNIT 1 3/4 3-41 Amendment No. 12, 112, 168, 256 Page 10 of 24 See ITS 3.3.8 See ITS 3.4.15 See ITS 3.3.7 ACTION B ACTION A Table 3.3.6-1 L04During movement of recently irradiated fuel assemblies within containment A01ITS ITS 3.3.6 TABLE 4.3-3 RADIATION MONITORING INSTRUMENTATION SURVEILLANCE REQUIREMENTS INSTRUMENT CHANNELCHECK CHANNEL CALIBRATION CHANNEL FUNCTIONAL TEST MODES FOR WHICH SURVEILLANCE REQUIRED 1.AREA MONI TOR a.Fuel Storag e Pool Area S R Q
- 2.PROCESS MONITORSa.Containment Purge Air Exhaust S R Q 1, 2, 3, 4
& 6 b.Contai nment i. Deleted ii.Particulate ActivityRCS Leakag e Dete ction S R Q 1, 2, 3, & 4 c.Control Room Isolation S R Q ALL MODES ______________________
- With fuel in the storage pool or buildin g.December 04, 2008 SEQUOYAH - UNIT 1 3/4 3-42 Amendment Nos. 12, 112,168, 220, 322 Page 11 of 24In accordance with the Surveillance Frequency Control Program LA01 L04SR 3.3.6.4 SR 3.3.6.1SR 3.3.6.7 COT M01 See ITS 3.3.8 See ITS 3.4.15 See ITS 3.3.7 See ITS 3.3.8 A02Containment Ventilation Isolation During movement of recently irradiated fuel assemblies within containment Function 3 Table 3.3.6-1 M04Add proposed SR 3.3.6.3 with a Frequency of 92 days on a STAGGERED TEST BASIS for ITS Table 3.3.6-1 Function 2 Add proposed SR 3.3.6.5 with a of Frequency every 18 months for ITS Table 3.3.6-1 Function 2 M04In accordance with the Surveillance Frequency Control Program LA01In accordance with the Surveillance Frequency Control Program LA01 A01ITS ITS 3.3.6 REFUELING OPERATIONS 3/4.9.9 CONTAINMENT VENTILATION ISOLATION SYSTEM LIMITING CONDITION FOR OPERATION 3.9.9 The Containment Ventilation isolation system shall be OPERABLE.
APPLICABILITY: During movement of irradiated fuel within the containment.
ACTION: With the Containment Ventilation isolation system inoperable, close each of the Ventilation penetrations providing direct access from the containment atmosphere to the outside atmosphere. The provisions of Specification 3.0.3 are not applicable.
SURVEILLANCE REQUIREMENTS 4.9.9 The Containment Ventilation isolation system shall be demonstrated OPERABLE within 100 hours0.00116 days <br />0.0278 hours <br />1.653439e-4 weeks <br />3.805e-5 months <br /> prior to the start of and at least once per 7 days during movement of irradiated fuel within containment by verifying that Containment Ventilation isolation occurs on manual initiation and on a high radiation test signal from each of the containment radiation monitoring instrumentation channels. April 11, 2005 SEQUOYAH - UNIT 1 3/4 9-9 Amendment No. 260, 301 Page 12 of 24 ACTION B 92 days for containment radiation monitors 18 months for manual initiation L05 L05In accordance with the Surveillance Frequency Control Program LA01 L06 See ITS 3.9.4 INSTRUMENTATIONinstrumentation instrumentation instrumentation A02 A02 A02 A02LCO 3.3.6 Applicabilit y SR 3.3.6.2, SR 3.3.6.4 M06recently L04 A01ITS ITS 3.3.6 INSTRUMENTATION
3/4.3.2 ENGINEERED SAFETY FEATURE ACTUATION SYSTEM INSTRUMENTATION
LIMITING CONDITION FOR OPERATION 3.3.2 The Engineered Safety Feature Actuation System (ESFAS) instrumentation channels and interlocks shown in Table 3.3-3 shall be OPERABLE with their trip setpoints set consistent with the values shown in the Nominal Trip Setpoint column of Table 3.3-4. APPLICABILITY: As shown in Table 3.3-3.
ACTION:
- a. With an ESFAS instrumentation channel or interlock trip setpoint less conservative than the value shown in the Allowable Values column of Table 3.3-4, declare the channel inoperable and apply the applicable ACTION requirement of Table 3.3-3 until the channel is restored to OPERABLE status with the trip setpoint adjusted consistent with the Nominal Trip Setpoint value. b. With an ESFAS instrumentation channel or interlock inoperable, take the ACTION shown in Table 3.3-3.
SURVEILLANCE REQUIREMENTS 4.3.2.1.1 Each ESFAS instrumentation channel and interlock shall be demonstrated OPERABLE by the performance of the CHANNEL CHECK, CHANNEL CALIBRATION and CHANNEL FUNCTIONAL TEST operations for the MODES and at the frequencies shown in Table 4.3-2.
4.3.2.1.2 The logic for the interlocks shall be demonstrated OPERABLE during the automatic actuation logic test. The total interlock function shall be demonstrated OPERABLE at least once per 18 months during CHANNEL CALIBRATION testing of each channel affected by interlock operation.
4.3.2.1.3 The ENGINEERED SAFETY FEATURES RESPONSE TIME of each ESFAS function shall be verified to be within the limit at least once per 18 months. Each verification shall include at least one train such that both trains are verified at least once per 36 months and one channel per function such that all channels are verified at least once per N times 18 months where N is the total number of redundant channels in a specific ESFAS function as shown in the "Total No. of Channels" Column of Table 3.3-3.
September 13, 2006 SEQUOYAH - UNIT 2 3/4 3-14 Amendment No. 182, 242, 299 LCO 3.3.6 Applicabilit y ACTION A ACTION A SR Note See ITS 3.3.2 ACTUATION LOGIC TEST / COT / TADOT M01Containment Ventilation Isolation A02Containment Ventilation Isolation A02 A03Containment Ventilation Isolation A02Containment Ventilation IsolationContainment Ventilation Isolation A02 A02Page 13 of 24 A03SR 3.3.6.8 A0418 months on a STAGGERED TEST BASIS In accordance with the Surveillance Frequency Control Program A05 LA01 L01Add proposed SR 3.3.6.8 Note A01ITS ITS 3.3.6 TABLE 3.3-3 (Continued )
ENGINEERED SAFETY FEATURE ACTUATION SYSTEM INSTRUMENTATION FUNCTIONAL UNIT TOTAL NO.
OF CHANNELS CHANNELS TO T RIP MINIMUM CHANNELS OPERABLE APPLICABLE MODES ACTION
- 3. CONTAINMENT ISOLATION b. Phase "B" Isolation
- 1) Manual
2
1**
2
1, 2, 3, 4
20 2) Automatic Actuation Logic 2 1 2 1, 2, 3, 4 15 3) Containment Pressure-High-High 4 2 3 1, 2, 3 18 c. Containment Ventilation Isolation 1) Manual 2 1 2 1, 2, 3, 4 19
- 2) Automatic Isolation Logic 2 1 2 1, 2, 3, 4 15 3) Containment Purge 2 1 1 1, 2, 3, 4 19 Air Exhaust Monitor Radioactivity-High
- Two switches must be operated simultaneously for actuation.
April 11, 2005 SEQUOYAH - UNIT 2 3/4 3-17 Amendment No. 55, 158, 290 Table 3.3.6-1 Function 1 Function 2 Function 3 See ITS 3.3.2 See ITS 3.3.2 LA02Containment Ventilation Isolation A02 LA02Page 14 of 24 M02Add proposed Function 4.
A01ITS ITS 3.3.6 TABLE 3.3-3 (Continued)
TABLE NOTATION
- Trip function may be bypassed in this MODE below P-11 (Pressurizer Pressure Block of Safety Injection) setpoint.
- Trip function automatically blocked above P-11 and may be blocked below P-11 when Safety Injection on Steam Line Pressure-Low is not blocked.
ACTION STATEMENTS ACTION 15 - With the number of OPERABLE Channels one less than the Total Number of Channels, be in HOT STANDBY within 12 hours1.388889e-4 days <br />0.00333 hours <br />1.984127e-5 weeks <br />4.566e-6 months <br /> and in COLD SHUTDOWN within the following 30 hours3.472222e-4 days <br />0.00833 hours <br />4.960317e-5 weeks <br />1.1415e-5 months <br />; however, one channel may be bypassed for up to 4 hours4.62963e-5 days <br />0.00111 hours <br />6.613757e-6 weeks <br />1.522e-6 months <br /> for surveillance testing per Specification 4.3.2.1.1 provided the other channel is OPERABLE.
ACTION 16 - Deleted.
ACTION 17 - With the number of OPERABLE Channels one less than the Total Number of Channels, STARTUP and/or POWER OPERATION may proceed provided the following conditions are satisfied:
- a. The inoperable channel is placed in the tripped condition within 6 hours6.944444e-5 days <br />0.00167 hours <br />9.920635e-6 weeks <br />2.283e-6 months <br />.
- b. The Minimum Channels OPERABLE requirements is met; however, the inoperable channel may be bypassed for up to 4 hours4.62963e-5 days <br />0.00111 hours <br />6.613757e-6 weeks <br />1.522e-6 months <br /> for surveillance testing of other channels per Specification 4.3.2.1.1.
ACTION 18 - With the number of OPERABLE Channels one less than the Total Number of Channels, operation may proceed provided the inoperable channel is placed in the bypassed condition within 6 hours6.944444e-5 days <br />0.00167 hours <br />9.920635e-6 weeks <br />2.283e-6 months <br /> and the Minimum Channels OPERABLE requirement is met; one additional channel may be bypassed for up to 4 hours4.62963e-5 days <br />0.00111 hours <br />6.613757e-6 weeks <br />1.522e-6 months <br /> for surveillance testing per Specification 4.3.2.1.1.
ACTION 19 - With less than the Minimum Channels OPERABLE, operation may continue provided the containment purge supply and exhaust valves are maintained closed.
ACTION 20 - With the number of OPERABLE Channels one less than the Total Number of Channels, restore the inoperable channel to OPERABLE status within 48 hours5.555556e-4 days <br />0.0133 hours <br />7.936508e-5 weeks <br />1.8264e-5 months <br /> or be in at least HOT STANDBY within the next 6 hours6.944444e-5 days <br />0.00167 hours <br />9.920635e-6 weeks <br />2.283e-6 months <br /> and in COLD SHUTDOWN within the following 30 hours3.472222e-4 days <br />0.00833 hours <br />4.960317e-5 weeks <br />1.1415e-5 months <br />.
September 14, 2006 SEQUOYAH - UNIT 2 3/4 3-22 Amendment Nos. 55, 132, 158, 174, 180, 192, 197, 203, 290, 300 See ITS 3.3.2 See ITS 3.3.2 See ITS 3.3.2 A06Add proposed ACTIONS Note.
L02 ACTION A ACTION A Page 15 of 24Add proposed Required Action A.1 L02Add proposed Required Action A.1 M03 A01ITS ITS 3.3.6 TABLE 3.3-4 (Continued)
ENGINEERED SAFETY FEATURE ACTUATION SYSTEM INSTRUMENTATION TRIP SETPOINTS FUNCTIONAL UNIT NOMINAL TRIP SETPOINT ALLOWABLE VALUES
- a. Manual Initiation Not Applicable Not Applicable
- b. Automatic Actuation Logic Not Applicable Not Applicable
- c. Containment Pressure--High-High 2.81 psig 2.9 psig 3. CONTAINMENT ISOLATION
- a. Phase "A" Isolation
- 1. Manual Not Applicable Not Applicable
- 2. From Safety Injection Automatic Actuation logic Not Applicable Not Applicable
- b. Phase "B" Isolation
- 1. Manual Not Applicable Not Applicable
- 2. Automatic Actuation Logic Not Applicable Not Applicable
- 3. Containment Pressure--High-High 2.81 psig 2.9 psig c. Containment Ventilation Isolation
- 1. Manual Not Applicable Not Applicable
- 2. Automatic Isolation Logic Not Applicable Not Applicable
September 13, 2006 SEQUOYAH - UNIT 2 3/4 3-25 Amendment No. 132, 299 Table 3.3.6-1 Function 1 Function 2 Containment Ventilation Isolation A02 A03 A03 See ITS 3.3.2 See ITS 3.3.2 Page 16 of 24 A01ITS ITS 3.3.6 TABLE 3.3-4 (Continued)
ENGINEERED SAFETY FEATURE ACTUATION SYSTEM INSTRUMENTATION TRIP SETPOINTS FUNCTIONAL UNIT NOMINAL TRIP SETPOINT ALLOWABLE VALUES
- 3. Containment Purge Air Exhaust Monitor Radioactivity - High 8.5 x 10-3 µCi/cc 8.5 x 10-3 µCi/cc 4. STEAM LINE ISOLATION
- a. Manual Not Applicable Not Applicable
- b. Automatic Actuation Logic Not Applicable Not Applicable
- c. Containment Pressure--High-High 2.81 psig 2.9 psig d. Steam Line Pressure--Low 600 psig steam line 592.2 psig steam line pressure (Note 1) pressure (Note 1)
- e. Negative Steam Line Pressure 100.0 psi (Note 2) 107.8 psi (Note 2) Rate--High
- 5. TURBINE TRIP AND FEEDWATER ISOLATION
- a. Steam Generator Water level -- 81% of narrow range 81.7% of narrow range High-High instrument span each steam instrument span each generator steam generator
- b. Automatic Actuation Logic N.A. N.A.
September 13, 2006 SEQUOYAH - UNIT 2 3/4 3-26 Amendment Nos. 55, 132, 158, 299 See ITS 3.3.2 Function 3 Table 3.3.6-1 A02Containment Ventilation Isolation Page 17 of 24 A03 A01ITS ITS 3.3.6 TABLE 4.3-2 (Continued)
ENGINEERED SAFETY FEATURE ACTUATION SYSTEM INSTRUMENTATION SURVEILLANCE REQUIREMENTS FUNCTIONAL UNIT CHANNEL CHECK CHANNEL CALIBRATION CHANNE L FUNCTIONAL TEST MODES FOR WHI CH SURVEILLANCE IS REQUIRED 3.CONTAINMENT ISOLATION a.Phase "A" Isolation 1)ManualN.A. N.A.
R 1, 2, 3, 4 2)From Safety Inject ion Automatic Actuation Logi c N.A. N.A. M(1) 1, 2, 3, 4 b.Phase "B" Isolation1)Manual N.A. N.A. R 1, 2, 3, 4 2)Automatic Actuation Logi c N.A. N.A. M(1) 1, 2, 3, 4 3)Containment Pressu re--High-High S R Q 1, 2, 3 c.Contai nment Ventilation Isolation1)Manual N.A.N.A.R 1, 2, 3, 4 2)Automatic Isolation Logi cN.A. N.A.
M(1) 1, 2, 3, 4 3)Containment Purge Air Exhaust Moni tor Radioactivity-High S R Q 1, 2, 3, 4 March 4, 1996 SEQUOYAH - UNIT 2 3/4 3-35 Amendment Nos. 39, 158, 210 Table 3.3.6-1 Function 1 Function 2 Function 3 See ITS 3.3.2 Containment Ventilation Isolation A02ACTUATION LOGIC TEST / COT / TADOT M0192 days on a STAGGERED TEST BASIS L03Add proposed SR 3.3.6.5 with a of Frequency every 18 months for ITS Table 3.3.6-1 Function 2 M04In accordance with the Surveillance Frequency Control Program LA01Add proposed SR 3.3.6.3 with a Frequency of 92 days on a STAGGERED TEST BASIS for ITS Table 3.3.6-1 Function 2 M04Page 18 of 24SR 3.3.6.1 SR 3.3.6.7SR 3.3.6.6SR 3.3.6.2SR 3.3.6.4In accordance with the Surveillance Frequency Control Program LA01Add proposed SR 3.3.6.6 Note A07 A01ITS ITS 3.3.6 TABLE 4.3-2 (Continued)
TABLE NOTATION
(1) Each train or logic channel shall be tested at least every 62 days on a STAGGERED TEST BASIS.
(2) The total interlock function shall be demonstrated OPERABLE during CHANNEL CALIBRATION testing of each channel affected by interlock operation.
September 14, 2006 SEQUOYAH - UNIT 2 3/4 3-39 Amendment No. 39, 174, 180, 197, 300 SR 3.3.6.2 See ITS 3.3.2 92 days on a STAGGERED TEST BASIS L03In accordance with the Surveillance Frequency Control Program LA01Page 19 of 24 A01ITS ITS 3.3.6 INSTRUMENTATION 3/4.3.3 MONITORING INSTRUMENTATION RADIATION MONITORING INSTRUMENTATION LIMITING CONDITION FOR OPERATION
3.3.3.1 The radiation monitori ng instrumentation channels shown in Table 3.3-6 shall be OPERABLE with their alarm/trip setpoints within the specified limits. APPLICABILITY: As shown in Table 3.3-6.
ACTION:
- a. With a radiation monitoring channel alarm/trip setpoint exceeding the value shown in Table 3.3-6, adjust the setpoint to within the limit within 4 hours4.62963e-5 days <br />0.00111 hours <br />6.613757e-6 weeks <br />1.522e-6 months <br /> or declare the channel inoperable.
- b. With one or more radiation monitoring channels inoperable, take the ACTION shown in Table 3.3-6.
- c. The provisions of Specification 3.0.3 are not applicable.
SURVEILLANCE REQUIREMENTS 4.3.3.1 Each radiation monitoring instrumentation channel shall be demonstrated OPERABLE by the performance of the CHANNEL CHECK, CHANNEL CALIBRATION and CHANNEL FU NCTIONAL TEST operations for the MODES and at the frequencies shown in Table 4.3-3.
April 11, 2005 SEQUOYAH - UNIT 2 3/4 3-40 Amendment No. 290 LCO 3.3.6 Applicabilit y ACTION A ACTION B SR Note M05Containment Ventilation Isolation A02Containment Ventilation Isolation A02Containment Ventilation Isolation A02 M06Containment Ventilation Isolation A02 COT M01Page 20 of 24 A03 A01ITS ITS 3.3.6 TABLE 3.3-6 RADIATION MONITORING INSTRUMENTATION INSTRUMENT MINIMUM CHANNELS OPERABLE APPLICABLE MODES ALARM/TRIP SETPOINT MEASUREMENT RANGE ACTION 1. AREA MONITORa.Fuel Storage Pool 1
- 151 mR/hr 10 10 4 mR/hr 26 Area 2. PROCESS MONITORSa.Containment Purge Air1 1, 2, 3, 4
& 6 8.5 x 10-3µCi/cc 10 - 10 7 cpm 28 b. Containment
- i. Deletedii.ParticulateActivity RCS LeakageDetection 1 1, 2, 3 & 4 N/A 10 - 10 7 cpm 27 c.Control Room Isolation2 ALL MODES and during movement of irradiated fuel assemblies 400 cpm**
10 - 10 7 cpm 29 _______________________________
- With fuel in the storage pool or building** Equivalent to 1.0 x 10
-5 µCi/cc. December 04, 2008 SEQUOYAH - UNIT 2 3/4 3-41 Amendment Nos. 52, 102, 158, 247, 299, 314 Function 3 Table 3.3.6-1 Containment Ventilation Isolation A02 LA03During movement of recently irradiated fuel assemblies within containment L04 LA03 See ITS 3.3.8 See ITS 3.4.15 See ITS 3.3.7 See ITS 3.3.8 See ITS 3.3.7 Page 21 of 24 A03 A01ITS ITS 3.3.6 TABLE 3.3-6 (Continued)
ACTION STATEMENTS ACTION 26 - With the number of OPERABLE channels less than required by the Minimum Channels OPERABLE requirement, perform area surveys of the monitored area with portable monitoring instrumentation at least once per 24 hours2.777778e-4 days <br />0.00667 hours <br />3.968254e-5 weeks <br />9.132e-6 months <br />. ACTION 27 - With the number of OPERABLE channels less than required by the Minimum Channels OPERABLE requirement, comply with the ACTION requirements of Specification 3.4.6.1. ACTION 28 - With the number of OPERABLE channels less than required by the Minimum Channels OPERABLE requirement, comply with the ACTION requirements of Specification 3.9.9 (MODE 6) and 3.3.2 (MODES 1, 2, 3, and 4). ACTION 29 -
a.With one channel inoperable, place the associated control room emergenc y ventilation system (CREVS) train in recirculation mode of operation within 7 day s or be at least HOT STANDBY within the next 6 hours6.944444e-5 days <br />0.00167 hours <br />9.920635e-6 weeks <br />2.283e-6 months <br /> and in COLD SHUTDO WN within the following 30 hours3.472222e-4 days <br />0.00833 hours <br />4.960317e-5 weeks <br />1.1415e-5 months <br />.
b.With two channels inoperable, within 1 hour1.157407e-5 days <br />2.777778e-4 hours <br />1.653439e-6 weeks <br />3.805e-7 months <br /> initiate and maintain operation of oneCREVS train in the recirculation mode of operation and ent er the required Actions for one CREVS train made inoperable by inoperabl e CREVS actuation instru mentati on.Orplace both trains in the recirculation mode of operation within one hour.If the completion time of Action 29b cannot be met in Mode s 1, 2, 3, and 4, be in at least HOT STANDBY within the next 6 hours6.944444e-5 days <br />0.00167 hours <br />9.920635e-6 weeks <br />2.283e-6 months <br /> and in COLD SHUTDOWN withinthe following 30 hours3.472222e-4 days <br />0.00833 hours <br />4.960317e-5 weeks <br />1.1415e-5 months <br />.If the completion time of Action 29b cannot be met during the move ment of irradiated fuel assemblies, suspend core alterations and suspend movement of irradiated fuel assemblies.If the completion time of Action 29b cannot be met in Modes 5 and 6, initiate action to restore one CRE VS train.May 31, 2000 SEQUOYAH - UNIT 2 3/4 3-42 Amendment Nos. 102, 158, 247 See ITS 3.3.8 See ITS 3.4.15 See ITS 3.3.7 Table 3.3.6-1 ACTION B ACTION A Page 22 of 24 L04During movement of recently irradiated fuel assemblies within containment A01ITS ITS 3.3.6 TABLE 4.3-3 RADIATION MONITORING INSTRUMENTATION SURVEILLANCE REQUIREMENTS INSTRUMENT CHANNEL CHECK CHANNEL CALIBRATION CHANNEL FUNCTIONAL TEST MODES FOR WHICH SURVEILLANCE IS REQUIRED 1.AREA MONI TOR a.Fuel Storage Pool AreaS R Q
- 2.PROCESS MONITORS a.Containment Purge Air Exhaust S R Q 1, 2, 3, 4
& 6 b.Contai nmenti.Deletedii.Particul ate Activity RCS Leakag e Dete ction S R Q 1, 2, 3 & 4 c.Control Room IsolationS R Q ALL MODES ______________________
- With fuel in the storage pool or buildin g.December 04, 2008 SEQUOYAH - UNIT 2 3/4 3-43 Amendment Nos. 102, 158, 210, 314Function 3 Table 3.3.6-1 See ITS 3.3.8 See ITS 3.4.15 See ITS 3.3.7 See ITS 3.3.8 COT Containment Ventilation Isolation During movement of recently irradiated fuel assemblies within containment A02 M01 L04Add proposed SR 3.3.6.3 with a Frequency of 92 days on a STAGGERED TEST BASIS for ITS Table 3.3.6-1 Function 2 Add proposed SR 3.3.6.5 with a of Frequency every 18 months for ITS Table 3.3.6-1 Function 2 M04 M04In accordance with the Surveillance Frequency Control Program LA01In accordance with the Surveillance Frequency Control Program LA01Page 23 of 24SR 3.3.6.4 SR 3.3.6.1SR 3.3.6.7In accordance with the Surveillance Frequency Control Program LA01 A01ITS ITS 3.3.6 REFUELING OPERATIONS 3/4.9.9 CONTAINMENT VENTILATION ISOLATION SYSTEM LIMITING CONDITION FOR OPERATION 3.9.9 The Containment Ventilation Isolation System shall be OPERABLE.
APPLICABILITY: During movement of irradiated fuel within the containment.
ACTION: With the Containment Ventilation Isolation System inoperable, close each of the Ventilation penetrations providing direct access from the containment atmosphere to the outside atmosphere. The provisions of Specification 3.0.3 are not applicable.
SURVEILLANCE REQUIREMENTS 4.9.9 The Containment Ventilation Isolation System shall be demonstrated OPERABLE within 100 hours0.00116 days <br />0.0278 hours <br />1.653439e-4 weeks <br />3.805e-5 months <br /> prior to the start of and at least once per 7 days during movement of irradiated fuel within containment by verifying that Containment Ventilation isolation occurs on manual initiation and on a high radiation test signal from each of the containment radiation monitoring instrumentation channels. April 11, 2005 SEQUOYAH - UNIT 2 3/4 9-11 Amendment No. 251, 290 ACTION B LCO 3.3.6 Applicabilit y SR 3.3.6.2, SR 3.3.6.4 See ITS 3.9.4 92 days for containment radiation monitors 18 months for manual initiation INSTRUMENTATIONinstrumentationinstrumentationinstrumentation A02 A02 A02 A02 L05 L05 L06In accordance with the Surveillance Frequency Control Program LA01 M06Page 24 of 24recently L04 DISCUSSION OF CHANGES ITS 3.3.6, CONTAINMENT VENTILATION ISOLATION INSTRUMENTATION Sequoyah Unit 1 and Unit 2 Page 1 of 12 ADMINISTRATIVE CHANGES A01 In the conversion of the Sequoyah Nuclear Plant (SQN) Current Technical Specifications (CTS) to the plant specific Improved Technical Specifications (ITS), certain changes (wording preferences, editorial changes, reformatting, revised numbering, etc.) are made to obtain consistency with NUREG-1431, Rev. 4.0, "Standard Technical Specifications-Westinghouse Plants" (ISTS) and additional Technical Specification Task Force (TSTF) travelers included in this
submittal. These changes are designated as administrative changes and are acceptable because they do not result in technical changes to the CTS. A02 CTS 3.3.2.1 (Unit 1) and CTS 3.3.2 (Unit 2) require, in part, the Engineered Safety Features Actuation System (ESF AS) instrumentation to be OPERABLE. CTS 3.3.2.1 (Unit 1) and CTS 3.3.2 (Unit 2) ACTIONS a and b provide the compensatory actions to take when an ESFAS instrument is inoperable. CTS 4.3.2.1.1 provides the testing requirements for the ESFAS instrumentation.
CTS Table 3.3-3 provides the Total No. of Channels, Channels to Trip, Minimum Channels OPERABLE, Applicable MODES, and ACTIONS for the ESFAS Functional Units. CTS Table 3.3-4 provides the Nominal Trip Setpoint and Allowable Values for the ESFAS Functional Units. CTS Table 4.3-2 provides the Surveillance Requirements for the ESFAS Functional Units. CTS 3.3.3.1 requires, in part, the Radiation Monitoring Instrumentation channels to be OPERABLE. CTS 3.3.3.1 ACTIONS a and b provide the Required Actions and associated Completion Time for when the Radiation Monitoring Instrumentation is inoperable. CTS 4.3.3.1 provides testing requirements for Radiation Monitoring Instrumentation. CTS Table 3.3-6 provides the Minimum Channels OPERABLE, Applicable MODES, Alarm/Trip Setpoint, Measurement Range, and ACTIONS for the Radiation Monitoring Instrumentation. CTS Table 4.3-3 provides the Surveillance Requirements for the Radiation Monitoring Instrumentation. CTS 3.9.9 provides the Limiting Condition for Operation
requirements, ACTIONS, and Surveillance Requirements for the Containment Ventilation Isolation System. ITS LCO 3.3.6 requires, in part, that the Containment Ventilation Isolation instrumentation be OPERABLE. ITS Table 3.3.6-1 provides the Applicable MODES, Required Channels, Surveillance Requirements, and Trip Setpoints for Containment Ventilation Isolation Instrumentation. This changes the CTS by having a separate Specification for the Containment Ventilation Isolation Instrumentation in lieu of including it in the ESFAS Instrumentation and the Radiation Monitoring Instrumentation Specifications. This change is acceptable because the technical requirements for the ESFAS Instrumentation and the Radiation Monitoring Instrumentation are maintained with the change in format. The Containment Ventilation Isolation Instrumentation continues to require the OPERABILITY of the ESFAS and Radiation Monitoring Instrumentation. This change is designated as administrative because it does not result in a technical change to the CTS. A03 CTS 3.3.2.1 (Unit 1) and CTS 3.3.2 (Unit 2) require the ESFAS Instrumentation and interlock setpoints to be set consistent with the Nominal Trip Setpoint values DISCUSSION OF CHANGES ITS 3.3.6, CONTAINMENT VENTILATION ISOLATION INSTRUMENTATION Sequoyah Unit 1 and Unit 2 Page 2 of 12 shown in Table 3.3-4. CTS 3.3.3.1 requires the Radiation Monitoring Instrumentation channels to be set consistent with the Trip Setpoint values shown in Table 3.3-6. CTS 3.3.2.1 (Unit 1) and CTS 3.3.2 (Unit 2) ACTION a require the channel to be restored to OPERABLE status with the trip setpoint adjusted consistent with the Nominal Trip Setpoint. The Nominal Trip Setpoint and Allowable Values in CTS Table 3.3-4 Functional Unit 3.c.3 (Containment Purge Air Exhaust Monitor Radioactivity-High) and the Alarm/Trip Setpoint in CTS Table 3.3-6, Instrument 2.a (Containment Purge Air) indicate the same value. ITS 3.3.6 requires the Containment Ventilation Isolation Instrumentation Functions to be OPERABLE and specifies the Trip Setpoint for the Containment Ventilation Isolation Instrumentation Functions. ITS Table 3.3.6-1 Function 3 (Containment Purge Air Radiation Monitor) specifies a Trip Setpoint consistent with the values indicated in CTS Table 3.3-4, Function 3.c.3 and CTS Table 3.3-6 Instrument 2.a. This changes the CTS by indicating a Trip Setpoint instead of an Allowable Value or Nominal Trip Setpoint for the Containment Purge Air Radiation Monitor instrumentation.
The purpose of CTS 3.3.2.1 (Unit 1) and CTS 3.3.2 (Unit 2) Table 3.3-4, Functional Unit 3.c.3, and CTS 3.3.3.1 Table 3.3-6, Instrument 2.a is to establish the requirements for Containment Ventilation Isolation on a Containment Purge Air Radiation Monitor - High signal to maintain control room and offsite radiological doses below limits in the event of an accident. However, the trip setpoint for the Containment Purge Air Radiation Monitor instrumentation is not associated with an Analytical Limit assumed in the safety analysis that prevents violation of the Safety Limits from postulated Anticipated Operational Occurrences (AOOs). This change is acceptable since the channel will continue to be declared inoperable if the Trip Setpoint is found to be less conservative than the tolerance specified by the calibration procedure. This change is designated as administrative because it does not result in a technical change to
the CTS.
A04 CTS 4.3.2.1.3 requires verification that the ENGINEERED SAFETY FEATURES (ESF) RESPONSE TIME of each ESFAS function is within limits. ITS Table 3.3.6-1 requires the performance of SR 3.3.6.8, "Verify ESF RESPONSE TIME is within limits," for Function 3 (Containment Purge Air Radiation Monitor). This changes the CTS by specifically stating the ESFAS Function that requires ESF
RESPONSE TIME testing.
The purpose of CTS 4.3.2.1.3 is to ensure that the actuation response times are less than or equal to the maximum values assumed in the accident analysis. UFSAR Table 7.3.1-4 specifies response times for those ESF Functions assumed in the SQN safety analys es. Sequoyah License Amendment 190 and 182, for Unit 1 and Unit 2 respectively, relocated the ESFAS response time limits to the UFSAR (ADAMS Accession No. ML013300393). UFSAR Table 7.3.1-4 contains these limits listing the information in two columns, "Initiating Signal and Function," and "Response Time in Seconds." The Initiating Signals listed in UFSAR Table 7.3.1-4 includes Containment Purge Air Exhaust Radioactivity -
High. This change is acceptable because ITS 3.3.6, Table 3.3.6-1 continues to require ESF RESPONSE TIME testing (ITS SR 3.3.6.8) for the Containment Ventilation Isolation, Containment Purge Air Exhaust Monitor Radioactivity-High DISCUSSION OF CHANGES ITS 3.3.6, CONTAINMENT VENTILATION ISOLATION INSTRUMENTATION Sequoyah Unit 1 and Unit 2 Page 3 of 12 as is delineated in UFSAR Table 7.3.1-4. This change is designated as administrative because it does not result in technical changes to the CTS. A05 CTS 4.3.2.1.3 states, in part, that the ESF RESPONSE TIME of each ESFAS function shall be demonstrated to be within its limit at least once per 18 months.
The requirement specifies that each test shall include at least one logic train such that both logic trains are tested at least once per 36 months, and one channel per function such that all channels are tested at least once every N times 18 months where N is the total number of redundant channels in a specific reactor trip function as shown in the "Total No. of Channels" column of Table 3.3-3 ITS SR
3.3.6.8 requires the verification of ESF RESPONSE TIMES every 18 months "on a STAGGERED TEST BASIS." The ITS definition of STAGGERED TEST BASIS is consistent with the CTS testing Frequency. This changes the CTS by utilizing the ITS definition of STAGGERED TEST BASIS for the Frequency of the ESF
RESPONSE TIME testing. This change is acceptable because the requirements for ESF RESPONSE TIME testing for the ESFAS channels remain unchanged. The ITS definition of STAGGERED TEST BASIS and its application in this requirement do not change the current testing Frequency requirements. This change is designated as administrative because it does not result in technical changes to the CTS. A06 ITS 3.3.6 ACTIONS contains a Note which states that separate Condition entry is allowed for each Function. The ACTIONS for CTS 3.3.2.1 (Unit 1), CTS 3.3.2 (Unit 2), and CTS 3.3.3.1 do not contain this Note. This changes the CTS by specifically allowing separate Condition entry for each Function in ITS Table 3.3.6-1. This change is acceptable because it clearly states the current requirement. The CTS considers each ESFAS and radiation monitoring instrument Function to be separate and independent. This change is designated as administrative because it does not result in a technical change to the CTS. A07 CTS Table 4.3-2 requires a CHANNEL FUNCTIONAL TEST for Functional Unit c.1 (Manual). ITS Table 3.3.6-1 requires a simila r test; ITS SR 3.3.6.6 (TADOT) to be performed for Function 1 (Manual Initiation) with the addition of a Note that states, "Verification of setpoint is not required." This changes the CTS by requiring a TADOT without setpoint verification instead of a CHANNEL FUNCTIONAL TEST. CTS 1.6 states that for an analog channel a CHANNEL FUNCTIONAL TEST shall be the injection of a simulated signal into the channel as close to the sensor as practicable to verify OPERABILITY including alarm and/or trip functions.
ITS 1.1 defines a TADOT as consisting of operating the trip actuating device and verifying the OPERABILITY of all devices in the channel required for trip actuating device OPERABILITY. ITS further states that the TADOT shall include adjustment, as necessary, of the trip actuating device so that it actuates at the required setpoint within the necessary accuracy. Because the TADOT includes adjustment, as necessary, of the trip actuating device so that it actuates at the required setpoint within the necessary accuracy, which is not included in the CTS CHANNEL FUNCTIONAL TEST, ITS SR 3.3.3.6 includes the Note, "Verification DISCUSSION OF CHANGES ITS 3.3.6, CONTAINMENT VENTILATION ISOLATION INSTRUMENTATION Sequoyah Unit 1 and Unit 2 Page 4 of 12 of setpoint is not required." A TADOT without setpoint verification provides a similar test for these channels as the CTS CHANNEL FUNCTIONAL TEST. This change is designated as administrative because it does not result in technical changes to the CTS. MORE RESTRICTIVE CHANGES M01 CTS 4.3.2.1.1 requires, in part, that the ESFAS instrumentation on Table 4.3-2 be demonstrated OPERABLE by performance of a CHANNEL FUNCTIONAL TEST. Table 4.3-2 Functional Unit 3.c.1 (Containment Ventilation Isolation - Manual), Functional Unit 3.c.2 (Containment Ventilation Isolation - Automatic Isolation Logic), and Functional Unit 3.c.3 (Containment Ventilation Isolation -
Containment Purge Air Exhaust Monitor R adioactivity-High) require a CHANNEL FUNCTIONAL TEST. CTS 4.3.3.1 requires, in part, that the Radiation Monitoring Instrumentation on Table 4.3-3 be demonstrated OPERABLE by performance of a CHANNEL FUNCTIONAL TEST. Table 4.3-3 Instrument 2.a (Process Monitors - Containment Purge Air) requires a CHANNEL FUNCTIONAL TEST.
ITS Table 3.3.6-1 Function 1 (Manual Initiation) requires performance of a TADOT (SR 3.3.6.6). ITS Table 3.3.6-1 Function 2 (Automatic Actuation Logic and Actuation Relays) requires performance of an ACTUATION LOGIC TEST (SR 3.3.6.2). ITS Table 3.3.6-1 Function 3 (Containment Purge Air Radiation Monitor) requires performance of a COT (SR 3.3.6.4). This changes the CTS by requiring a TADOT, a COT, or ACTUATION LOGIC TEST instead of a CHANNEL FUNCTIONAL TEST. This change is acceptable because the COT, TADOT, or ACTUATION LOGIC TEST continue to perform tests similar to the current CHANNEL FUNCTIONAL TEST. CTS defines a CHANNEL FUNCTIONAL TEST based on the type of channel. In CTS a CHANNEL FUNCTIONAL TEST shall be: for Analog channels, the injection of a simulated signal into the channel as close to the sensor as practicable to verify OPERABILITY including alarm and/or trip functions; for Bistable channels, the injection of a simulated signal into the sensor to verify OPERABILITY including alarm and/or trip functions; and for Digital channels, the injection of a simulated signal into the channel as close to the sensor input to the process racks as practicable to verify OPERABILITY including alarm and/or trip functions. This does not include the adjustment, as necessary, of the channel output such that it responds with the necessary range and accuracy to known values of the parameter which the channel monitors as does the CHANNEL CALIBRATION. The COT, TADOT, and ACTUATION LOGIC TEST provide similar tests with the addition that the COT and TADOT includes adjustments, as necessary, of the required alarm, interlock, and trip setpoints required for channel OPERABILITY such that the setpoints are within the
necessary range and accuracy. This change is designated as more restrictive because the ITS requires additional acceptance criteria that is not currently required in the CTS. M02 CTS Table 3.3-3 Functional Unit 3.c provides requirements for Containment Ventilation Isolation Functions, but does not explicitly provide requirements for the Safety Injection (SI) signal that results in closure of the containment purge supply and exhaust isolation valves. ITS 3.3.6, "Containment Ventilation INSERT 1 A0 8 CTS Table 3.3
-6 specifies, in part, that Instrument 2.a (Process Monitors, Containment Purge Air) requires one channel OPERABLE during Modes 1, 2, 3, 4, and 6 (See DOC L04 regarding the relaxation in the Mode of Applicability for CTS Table 3.3-6, Instrument 2.a, Process Monitors, Containment Purge Air, from Mode 6 to during the movement ofirradiated fuel assemblies within the containment
). CTS 3.9.9 requires the Containment Ventilation Isolation System to be OPERABLE during the movement of irradiated fuel within the containment. An OPERABLE Containment Ventilation Isolation System requires two OPERABLE channels. ITS 3.3.6 combines requirements from CTS Table 3.3-6 and CTS 3.9.9 to form a single Specification, Containment Ventilation Isolation Instrumentation. ITS Table 3.3.6
-1 requires Function 3 (Containment Purge Air Radiation Monitor) to have two channels OPERABLE during the movement of irradiated fuel assemblies within containment. This changes the CTS by having a single Specification for the Containment Ventilation Isolation Instrumentation function in lieu of including it in the Radiation Monitoring Instrumentation and Containment Ventilation Isolation System Specifications.
This change is acceptable because the technical requirements for the Radiation Monitoring Instrumentation and Containment Ventilation Isolation System are maintained with the change in format. The Containment Ventilation Isolation Instrumentation continues to require the OPERABILITY of Radiation Monitoring Instrumentation and the Containment Ventilation Isolation System. This change is designated as administrative because it does not result in a technical change to the CTS.
Enclosure 2, Volume 8, Rev. , Page 904 of 1148 Enclosure 2, Volume 8, Rev. , Page 904 of 1148 DISCUSSION OF CHANGES ITS 3.3.6, CONTAINMENT VENTILATION ISOLATION INSTRUMENTATION Sequoyah Unit 1 and Unit 2 Page 5 of 12 Isolation Instrumentation," provides requirements for the SI input from ESFAS Function (Function 4) to be OPERABLE in MODES 1, 2, 3, and 4. The proposed change provides a cross-reference to LCO 3.3.2, "ESFAS Instrumentation,"
Function 1, SI, for all requirements and functions, including ACTIONS and Surveillances. This changes the CTS by explicitly requiring the SI input from ESFAS Function for the Containment Ventilation Isolation instrumentation.
This change is acceptable because the SI input from ESFAS Function is required to support the OPERABILITY of the containment purge supply and exhaust isolation valves. As such, explicitly including requirements for the SI input from ESFAS Function in the Technical Specifications provides additional assurance that the OPERABILITY of the Containment Ventilation Isolation instrumentation will be maintained. The requirements for the Containment Ventilation Isolation instrumentation continue to require the isolation of the Containment Ventilation Isolation on Manual Initiation, Containment Purge Air Radiation, and SI input from ESFAS signals. This change is designated as more restrictive because it adds OPERABILITY requirements for the SI input from ESFAS Function to the CTS.
M03 CTS Table 3.3-3 ACTION 19 requires that when the Containment Ventilation Isolation - Manual channels are less than the Minimum Channels OPERABLE, that operation may continue provided the containment purge supply and exhaust valves are maintained closed. ITS 3.3.6 ACTION A requires, in part, when one or more Functions with one or more manual trains are inoperable to enter the applicable Conditions and Required Actions of LCO 3.6.3, "Containment Isolation
Valves," for containment purge and exhaus t isolation valves made inoperable by isolation instrumentation. This changes the CTS by requiring the ACTIONS of LCO 3.6.3 to be entered rather than maintaining the containment purge and supply valves in a closed position.
This change is acceptable because the containment purge and exhaust valves are considered containment isolation valves. Therefore, ITS LCO 3.6.3 will provide the appropriate compensatory actions to take when one or more Containment Ventilation Isolation - Manual channels are inoperable. This change is designated as more restrictive since the ITS provides additional requirements for an inoperable Containment Ventilation Isolation - Manual channel than were required in the CTS.
M04 CTS Table 4.3-2 Functional Unit 3.c.3 requires the Containment Ventilation Isolation - Containment Purge Air Exhaust Monitor Radioactivity - High channels to have a CHANNEL CHECK, a CHANNEL FUNCTIONAL TEST, and a CHANNEL CALIBRATION. CTS Table 4.3-3 Instrument 2.a requires the Process Monitors - Containment Purge Air Exhaust Monitor Radioactivity - High channels to have a CHANNEL CHECK, a CHANNEL FUNCTIONAL TEST, and a CHANNEL CALIBRATION. ITS 3.3.6 requires similar Surveillances, but also requires the performance of a MASTER RELAY TEST every 92 days on a STAGGERED TEST BASIS (ITS SR 3.3.6.3) and a SLAVE RELAY TEST every 18 months (ITS SR 3.3.6.5). (See DOC LA01 for the discussion on moving the Surveillance Frequencies to the Surveillance Frequency Control Program.) Additionally, ITS SR 3.3.6.3 contains a Note that states, that the Surveillance is DISCUSSION OF CHANGES ITS 3.3.6, CONTAINMENT VENTILATION ISOLATION INSTRUMENTATION Sequoyah Unit 1 and Unit 2 Page 6 of 12 only applicable to the master relays of the ESFAS Instrumentation. This changes the CTS by adding testing requirements for the master and slave relays. This change is acceptable because the Automatic Actuation Logic and Actuation Relays Function is required to support the OPERABILITY of the Containment Ventilation Isolation Function. The addition of SR 3.3.6.3 (MASTER RELAY TEST) and SR 3.3.6.5 (SLAVE RELAY TEST) is acceptable since they will ensure the master and slave relays are able to perform their required safety function. This change is designated as more restrictive because it adds SRs for the Automatic Actuation Logic and Actuation Relays that were not included in the
CTS. M05 CTS 3.3.3.1 ACTION a requires that when a radiation monitor channel alarm/trip setpoint exceeds the value shown in Table 3.3.6, to adjust the setpoint within 4 hours4.62963e-5 days <br />0.00111 hours <br />6.613757e-6 weeks <br />1.522e-6 months <br /> or declare the channel inoperable. ITS 3.3.6 does not contain an ACTION for adjusting a setpoint that exceeds the required valued. Instead, ITS 3.3.6 ACTION B requires that when one required radiation monitoring channel is inoperable (i.e., setpoint not within tolerance) to enter the applicable Required Actions immediately. This changes the CTS by not allowing adjustment of the setpoint in 4 hours4.62963e-5 days <br />0.00111 hours <br />6.613757e-6 weeks <br />1.522e-6 months <br /> before declaring the channel inoperable. The purpose of CTS 3.3.3.1 ACTION a is to allow adjustment of the radiation monitor setpoint to within limits before declare the channel inoperable. Although ITS does not include this allowance, restoration such that the LCO is met, is always an option. This change is acceptable because the channel requirements in ITS 3.3.6 will ensure that the required radiation monitoring channel is OPERABLE. The proposed ITS ACTION for when one channel is inoperable will ensure that the Required Actions and Completion Times used establish remedial measures that when taken minimize risk associated with continued operation.
This change is designated as more restrictive because more stringent Required Actions and Completion Times are being applied in the ITS than were applied in
the CTS. M06 CTS 3.3.3.1 ACTION c and CTS 3.9.9 ACTION state, in part, that the provisions of Specification 3.0.3 are not applicable for the Containment Purge Air Radiation Monitoring Instrumentation. ITS 3.3.6 does not contain this exception. This changes the CTS by eliminating an exception to LCO 3.0.3 from the
requirements for the Containment Purge Air Radiation Monitoring Instrumentation. The purpose of CTS 3.3.3.1 and CTS 3.9.9, in part, is to provide the requirements for Containment Purge Air Radiation Monitoring Instrumentation used to alert the operators and provide an input to effect a containment ventilation isolation actuation in the event of an accident. CTS 3.0.3 would require the unit be shut down when the requirements of the LCO and the associated ACTIONS are not satisfied. This change is acceptable because ITS 3.3.6 provides the appropriate LCO requirements and ACTIONS to take when the LCO is not met. If the LCO is not met and further unit operation under the specified ACTIONS is not permitted, it is appropriate to take the ACTIONS specified in LCO 3.0.3 to place the plant in a MODE in which the Specification does not apply. Eliminating the LCO 3.0.3 exemption ensures that the operators DISCUSSION OF CHANGES ITS 3.3.6, CONTAINMENT VENTILATION ISOLATION INSTRUMENTATION Sequoyah Unit 1 and Unit 2 Page 7 of 12 are provided guidance regarding actions to take in the event the required Radiation Monitoring Instrumentation is inoperable and the associated ACTIONS are not satisfied within the required Completion Time. This change is designated as more restrictive because an explicit exception to the requirements of LCO 3.0.3 is eliminated from the CTS. RELOCATED SPECIFICATIONS None REMOVED DETAIL CHANGES LA01 (Type 5 - Removal of SR Frequency to the Surveillance Frequency Control Program) CTS 4.3.2.1.3 requires a RESPONSE TIME TEST every 18 months on a STAGGERED TEST BASIS for CTS Table 3.3-3 Functional Unit 3.c.3), Containment Ventilation Isolation - Containment Purge Air Exhaust Monitor Radioactivity - High. CTS Table 4.3-2 Functional Unit 3.c.1 requires a refueling outage CHANNEL FUNCTIONAL TEST for the Containment Ventilation Isolation
-Manual channels. CTS Table 4.3-2 Functional Unit 3.c.2 requires a monthly CHANNEL FUNCTIONAL TEST for the Containment Ventilation Isolation - Automatic Isolation Logic channels. (See DOC L03 for the change of the Frequency from monthly on a STAGGERED TEST BASIS to 92 days on a STAGGERED TEST BASIS.) CTS Table 4.3-2 Functional Unit 3.c.3 requires that the Containment Ventilation Isolation - Containment Purge Air Exhaust Monitor Radioactivity - High channels have a CHANNEL CHECK every shift, a CHANNEL FUNCTIONAL TEST every quarter, and a CHANNEL CALIBRATION every refueling outage. CTS Table 4.3-3 Instrument 2.a requires that the Process Monitors - Containment Purge Air Exhaust channels have a CHANNEL CHECK every shift, a CHANNEL FUNCTIONAL TEST every quarter, and a CHANNEL CALIBRATION every refueling outage. CTS 4.9.9 requires a verification that Containment Ventilation Isolation occurs on a manual initiation and on a high radiation test signal from each of the containment radiation monitoring instrumentation channels within 100 hours0.00116 days <br />0.0278 hours <br />1.653439e-4 weeks <br />3.805e-5 months <br /> prior to the start of and at least once per 7 days during the movement of irradiated fuel assemblies within containment. (See DOC L06 for discussion on the deletion of "within 100 hours0.00116 days <br />0.0278 hours <br />1.653439e-4 weeks <br />3.805e-5 months <br /> prior to the start of movement of irradiated fuel within containment.") Additionally, ITS SR 3.3.6.3 has been added to require performance of a MASTER RELAY TEST at a Frequency of 92 days on a STAGGERED TEST BASIS and SR 3.3.6.5 has been added to require the performance of a SLAVE RELAY TEST at a Frequency of 18 months. (See DOC M04 for the discussion of adding SR 3.3.6.3 and SR 3.3.6.5.) ITS SR 3.3.6.1, SR 3.3.6.2, SR 3.3.6.3, SR 3.3.6.4, SR 3.3.6.5, SR 3.3.6.6, SR 3.3.6.7, and 3.3.6.8 require similar Surveillances and specify the periodic Frequency as, "In accordance with the Surveillance Frequency Control Program." This changes the CTS by moving the specified Frequencies for this SR and associated Bases to the Surveillance Frequency Control Program. (See DOC M01 for discussion on changing the CHANNEL FUNCTIONAL TEST to a COT/ACTUATION LOGIC TEST.)
DISCUSSION OF CHANGES ITS 3.3.6, CONTAINMENT VENTILATION ISOLATION INSTRUMENTATION Sequoyah Unit 1 and Unit 2 Page 8 of 12 The removal of these details related to Surveillance Requirement Frequencies from the Technical Specifications is acceptable, because this type of information is not necessary to be included in the Technical Specifications to provide adequate protection of public health and safety. The existing Surveillance Frequencies are removed from Technical Specifications and placed under licensee control pursuant to the methodology described in NEI 04-10. A new program (Surveillance Frequency Control Program) is being added to the Administrative Controls section of the Technical Specifications describing the control of Surveillance Frequencies. The surveillance test requirements remain in the Technical Specifications. The control of changes to the Surveillance Frequencies will be in accordance with the Surveillance Frequency Control Program. The Program shall ensure that Surveillance Requirements specified in the Technical Specifications are performed at intervals sufficient to assure the associated Limiting Conditions for Operation are met. This change is designated as a less restrictive removal of detail change, because the Surveillance Frequencies are being removed from the Technical Specifications.
LA02 (Type 1 - Removing Details of System Design and System Description, Including Design Limits)
CTS Table 3.3-3, "Engineered Safety Feature Actuation System Instrumentation," has three columns stating various requirements for the Containment Ventilation Isolation Manual, Automatic Isolation Logic, and Containment Purge Air Exhaust Monitor Radioactivity-High. These columns are labeled "TOTAL NO. OF CHANNELS," "CHANNELS TO TRIP," and "MINIMUM CHANNELS OPERABLE." ITS 3.3.6 does not include the "TOTAL NO. OF CHANNELS" and "CHANNELS TO TRIP" columns. This changes the CTS by moving the information of the "TOTAL NO. OF CHANNELS" and "CHANNELS TO TRIP" columns to the Bases.
The removal of these details, which are related to system design, from the Technical Specifications, is acceptable because this type of information is not necessary to be included in the Technical Specifications to provide adequate protection of public health and safety. The ITS still retains the requirement for the number of required channels and the appropriate Condition to enter if a required channel becomes inoperable. Also, this change is acceptable because the removed information will be adequately controlled in the ITS Bases.
Changes to the Bases are controlled by the Technical Specification Bases Control Program in Chapter 5. This program provides for the evaluation of changes to ensure the Bases are properly controlled. This change is designated as a less restrictive removal of detail change because information relating to system design is being removed from the Technical Specifications.
LA03 (Type 1 - Removing Details of System Design and System Description, Including Design Limits) CTS Table 3.3-6, "Radiation Monitoring Instrumentation," includes a column providing the measurement range of the required instrumentation. This column is labeled "MEASUREMENT RANGE." ITS 3.3.6 does not include the "MEASUREMENT RANG E" column. This changes the CTS by moving the information of the "MEASUREMENT RANGE" column to the Bases. The removal of these details, which are related to system design, from the Technical Specifications, is acceptable because this type of information is not DISCUSSION OF CHANGES ITS 3.3.6, CONTAINMENT VENTILATION ISOLATION INSTRUMENTATION Sequoyah Unit 1 and Unit 2 Page 9 of 12 necessary to be included in the Technical Specifications to provide adequate protection of public health and safety. The ITS still retains the requirement for the number of required channels and the appropriate Condition to enter if a required channel becomes inoperable. Also, this change is acceptable because the removed information will be adequately controlled in the ITS Bases.
Changes to the Bases are controlled by the Technical Specification Bases Control Program in Chapter 5. This program provides for the evaluation of changes to ensure the Bases are properly controlled. This change is designated as a less restrictive removal of detail change because information relating to system design is being removed from the Technical Specifications. LESS RESTRICTIVE CHANGES L01 (Category 6 - Relaxation of Surveillance Requirement Acceptance Criteria)
CTS 4.3.2.1.3 states, in part, that the ESF RESPONSE TIME of each ESFAS function shall be demonstrated to be within its limit at least once per 18 months. ITS SR 3.3.6.8 Note states that the radiation detectors are excluded from response time testing. This changes the CTS by excluding the radiation monitor from the ESF RESPONSE TIME testing for the Containment Ventilation Isolation High Radiation Function. The purpose of CTS 4.3.2.1.3 is to ensure that the actuation response times are less than or equal to the maximum values assumed in the accident analysis.
UFSAR Table 7.3.1-4 specifies response times and exceptions allowed for the Containment Ventilation Isolation Function initiated by the Containment Purge Air Exhaust Radioactivity -High signal. Sequoyah License Amendment 190 and 182, for Unit 1 and Unit 2 respectively, relocated the ESFAS response time limits to the UFSAR (ADAMS Accession No. ML013300393). UFSAR Table 7.3.1-4 contains these limits listing the information in two columns, "Initiating Signal and Function," and "Response Time in Seconds." The Initiating Signals listed in UFSAR Table 7.3.1-4 includes Containment Purge Air Exhaust Radioactivity -
High for Function Containment Ventilation Isolation. The Response Time column in UFSAR Table 7.3.1-4 for Containment Ventilation Isolation is modified by Note (6). UFSAR Table 7.3.1-4 Note (6) states that the radiation detectors for Containment Ventilation Isolation Function may be excluded from Response Time Testing. This Note modifies the CTS definition of an ESF RESPONSE TIME test and was removed from CTS by License Amendment 190 and 182. ITS SR 3.3.6.8 is modified by a similar Note that excludes the radiation detector from ESF RESPONSE TIME testing. This change is acceptable because ITS 3.3.6, Table 3.3.6-1 retains the CTS intent of requiring ESF RESPONSE TIME testing (ITS SR 3.3.6.8) for those ESFAS Functions listed in UFSAR Table 7.3.1-4 as modified by the associated Table 7.3.1-4 Note. This change is designated as less restrictive because less stringent Surveillance Requirements are being applied in the ITS than were applied in the CTS.
L02 (Category 4 - Relaxation of Required Action) CTS Table 3.3-3 ACTION 15 requires that when one channel of Containment Ventilation Isolation - Automatic Isolation Logic (Functional Unit 3.c.2) is inoperable to be in at least HOT STANDBY within 12 hours1.388889e-4 days <br />0.00333 hours <br />1.984127e-5 weeks <br />4.566e-6 months <br /> and in COLD SHUTDOWN within the following 30 hours3.472222e-4 days <br />0.00833 hours <br />4.960317e-5 weeks <br />1.1415e-5 months <br />. Additionally, CTS Table 3.3-3 ACTION 15 allows one channel of the DISCUSSION OF CHANGES ITS 3.3.6, CONTAINMENT VENTILATION ISOLATION INSTRUMENTATION Sequoyah Unit 1 and Unit 2 Page 10 of 12 Containment Ventilation Isolation - Automatic Isolation Logic to be bypassed for up to 4 hours4.62963e-5 days <br />0.00111 hours <br />6.613757e-6 weeks <br />1.522e-6 months <br /> for surveillance testing per Specification 4.3.2.1.1, provided the other channel is OPERABLE. ITS 3.3.6 ACTION A requires, in part, that with one or more Containment Ventilation Isolation automatic actuation trains inoperable, to immediately enter the applicable Conditions and Required Actions of LCO 3.6.3, "Containment Isolation Valves," for containment purge supply and exhaust isolation valves made inoperable by isolation instrumentation. This changes the CTS by allowing continued unit operation when one or more Containment Ventilation Isolation - Automatic Isolation trains are inoperable.
The purpose of the CTS Table 3.3-3 ACTION 15 requirements is to ensure that the MODE of Applicability has been exited when the Automatic Isolation Logic is inoperable. This change is acceptable because the ITS Required Actions are used to establish remedial measures that must be taken in response to the degraded conditions in order to minimize risk associated with continued operation while providing time to repair inoperable features. The ITS Required Actions are consistent with safe operation under the specified Condition, considering the operability status of the redundant systems of required features, the capacity and capability of remaining features, a reasonable time for repairs or replacement of required features, and the low probability of a DBA occurring during the repair period. The proposed Required Action ensures that the function of the inoperable channel is satisfied by entering the applicable Conditions and Required Actions of LCO 3.6.3, "Containment Isolation Valves," for containment purge supply and exhaust isolation valves made inoperable by isolation instrumentation. The proposed change allows the Containment Isolation Valve Specification to ensure that the containment purge supply and exhaust isolation valves are in the correct position required for containment isolation. This change is designated as less restrictive because the less stringent requirements are being applied in the ITS than were applied in the CTS.
L03 (Category 9 - Allowed Outage Time, Surveillance Frequency, and Bypass Time Extensions Based on Generic Topical Reports)
CTS Table 4.3-2 Functional Unit 3.c.2 requires a CHANNEL FUNCTIONAL TEST of the Containment Ventilation Isolation - Automatic Actuation Logic every 62 days on a STAGGERED TEST BASIS (i.e., monthly), in MODES 1, 2, 3, and 4. ITS Table 3.3.6-1 Function 2, for Automatic Actuation Logic and Actuation Relays, requires performance of an ACTUATION LOGIC TEST (SR 3.3.6.2) every 92 days on a STAGGERED TEST BASIS. (See DOC M01 for discussio n on the change from the CHANNEL FUNCTION TEST to the ACTUATION LOGIC TEST.) This changes the CTS by extending the testing requirements for the Containment Ventilation Isolation Automatic Actuation Logic and Actuation Relays from monthly to 92 days on a STAGGERED TEST BASIS.
The purpose of the CHANNEL FUNCTIONAL TEST/COT/ACTUATION LOGIC TEST is to ensure that the instrumentation is functioning properly. These changes are acceptable and are the result of WCAP-10271, Revision 0
("Evaluation of Surveillance Frequencies and Out of Service Times for the Reactor Protection Instrumentation System"), dated May 1996, and supplements, WCAP-14333, Revision 1 ("Probabilistic Risk Analysis of the RPS and ESFAS Test Times and Completion Times"), dated October 1998, or WCAP-15376, Revision 1 ("Risk-Informed Assessment of the RTS and ESFAS Surveillance DISCUSSION OF CHANGES ITS 3.3.6, CONTAINMENT VENTILATION ISOLATION INSTRUMENTATION Sequoyah Unit 1 and Unit 2 Page 11 of 12 Test Intervals and Reactor Trip Breaker Test and Completion Times"), dated March 2003 (or a combination of the WCAPs). TVA has performed evaluations of the applicable changes associated with the three WCAPs to justify the above changes. The evaluations supporting these changes are provided in Enclosure 4 of this submittal. This change is designated as less restrictive because less stringent Frequencies are being applied in the ITS than were applied in the CTS.
L04 (Category 2 - Relaxation of Applicability) CTS 3.3.3.1, CTS Table 3.3-6 Instrument 2.a, and CTS Table 4.3-3 Instrument 2.a require the Containment Purge Air Instrumentation to be OPERABLE, in part, in MODE 6. CTS 3.9.9 applies during the movement of irradiated fuel within the containment. CTS 4.9.9 requires that the containment ventilation isolation system shall be demonstrated OPERABLE during movement of irradiated fuel within containment by verifying that containment ventilation isolation occurs on manual initiation and on a high radiation test signal from each of the containment radiation monitoring instrumentation channels. ITS 3.3.6 Applicability, in part, is during the movement of recently irradiated fuel assemblies wi thin containment. ITS 3.3.6 ACTION B applies during the movement of recently irradiated fuel assemblies in containment, and requires that when one or more Functions with one or more manual actuation trains inoperable or with one required radiation monitoring channel inoperable, to immediately place and maintain the containment purge supply and exhaust valves in the closed position, or immediately enter the Conditions and Required Actions of LCO 3.9.4 for containment purge and exhaust isolation valves made inoperable by isolation instrumentation. The ITS 3.3.6 Surveillance Requirements are required to be satisfied when ITS 3.3.6 is applicable. This changes the CTS Applicability from requiring the containment purge air process monitors to be OPERABLE in MODE 6, to an Applicability of during movement of recently irradiated fuel assemblies within containment. The purpose of CTS 3.3.3.1 and CTS 3.9.9 are to provide assurance that the Containment Ventilation Isolation Syst em can perform its required safety functions. This change in Applicability is acceptable because the requirements continue to ensure that the structures, system and components are maintained in the MODES and other specified conditions assumed in the safety analyses and licensing basis. TVA has performed a Fuel Handling Accident Radiological Accident Analysis for SQN using the alternate source term analysis methodology described in Regulatory Guide 1.183 obtaining acceptable results. The SQN fuel handling analysis assumes, in part, that the accident occurs within 100 hours0.00116 days <br />0.0278 hours <br />1.653439e-4 weeks <br />3.805e-5 months <br /> after a plant shut down, radioactive decay during the interval between shut down and movement of the first spent fuel assembly is taken into account, and a single fuel assembly is damaged. As a result of the analysis, it has been determined that the handling of spent fuel assemblies can take place with the containment open and the Auxiliary Building Gas Treatment System out of service (i.e., no credit for filtration of releases) when handling fuel that has not occupied part of a critical reactor core within the previous 100 hours0.00116 days <br />0.0278 hours <br />1.653439e-4 weeks <br />3.805e-5 months <br />. The NRC approved use of this analysis for SQN under License Amendment 288/278 (Unit 1/Unit 2)
(ADAMS Accession No. ML033070057). This change is designated as less restrictive because the LCO is applicable in fewer operating conditions under the
DISCUSSION OF CHANGES ITS 3.3.6, CONTAINMENT VENTILATION ISOLATION INSTRUMENTATION Sequoyah Unit 1 and Unit 2 Page 12 of 12 L05 (Category 7 - Relaxation of Surveillance Frequency) CTS 4.9.9 includes a Surveillance Frequency of "once per 7 days" during conditions specified in the Applicability for performing Surveillances of the Containment Ventilation Isolation System on the manual initiation channels and the high radiation monitoring instrumentation channels. The ITS SR 3.3.6.4 requires the performance of a COT on the Containment Purge Air Radiation Monitoring Instrumentation, every 92 days. ITS SR 3.3.6.6 requires the performance of a TADOT on the manual initiation channels every 18 months. This changes the CTS by changing the Surveillance Frequency from 7 days to 92 days for the Containment Purge Air Radiation monitoring channels and 18 months for the manual initiation channels.
(See DOC LA01 for a discussion on moving the Surveillance Frequencies to the Surveillance Frequency Control Program.)
The purpose of CTS 4.9.9 is to verify t he equipment required to meet the LCO is OPERABLE. This change is acceptable because the new Surveillance Frequency has been evaluated to ensure that it provides an acceptable level of equipment reliability. Containment ventilation isolation instrumentation testing is still required, but at a Frequency consistent with the testing Frequency for containment isolation instrumentation required in CTS Table 4.3-2 and CTS Table 4.3-3. This Frequency provides an appropriate degree of assurance that the instruments are OPERABLE. This change is designated as less restrictive because Surveillances will be performed less frequently under the ITS than under the CTS.
L06 (Category 7 - Relaxation of Surveillance Frequency) CTS 4.9.9 states, in part, that the Containment Ventilation isolation system shall be demonstrated OPERABLE within 100 hours0.00116 days <br />0.0278 hours <br />1.653439e-4 weeks <br />3.805e-5 months <br /> prior to the start of movement of irradiated fuel within containment. ITS SR 3.3.6.2 and ITS SR 3.3.6.4 do not include the Frequency of within 100 hours0.00116 days <br />0.0278 hours <br />1.653439e-4 weeks <br />3.805e-5 months <br /> prior to the start of movement of irradiated fuel within containment. ITS SR 3.0.1 states "SRs shall be met during the MODES or other specified conditions in the Applicability for individual LCOs, unless otherwise stated in the SR." Therefore, the ITS requires the Surveillance be met prior to initiation of movement of recently irradiated fuel. (See DOC L04 for discussion on changing the Applicability from during movement of irradiated fuel to during movement of recently irradiated fuel.) This changes the CTS by eliminating the stipulation that the Surveillances be met within 100 hours0.00116 days <br />0.0278 hours <br />1.653439e-4 weeks <br />3.805e-5 months <br /> prior to entering the conditions specified in the Applicability. The purpose of CTS 4.9.9 is to verify that the Containment Ventilation Isolation System is OPERABLE. This change is acceptable because the new Surveillance Frequency has been evaluated to ensure that it provides an acceptable level of equipment reliability. The periodic Surveillance Frequency for verifying that Containment Ventilation isolation occurs is acceptable during the conditions specified in the Applicability, and is also acceptable during the period prior to entering the conditions specified in the Applicability. This change is designated as less restrictive because Surveillance will be performed less frequently under the ITS than under the CTS.
Improved Standard Technical Specifications (ISTS) Markup and Justification for Deviations (JFDs)
Containment Purge and Exhaust Isolation Instrumentation (Without Setpoint Control Program) 3.3.6 A Westinghouse STS 3.3.6 A-1 Rev. 4.0 Ventilation 2SEQUOYAH UNIT 1 Amendment XXX CTS 13.3 INSTRUMENTATION 3.3.6 A Containment Purge and Exhaust Isolation Instrumentation (Without Setpoint Control Program) LCO 3.3.6 The Containment Purge and Exhaust Isolation instrumentation for each Function in Table 3.3.6-1 shall be OPERABLE.
APPLICABILITY: According to Table 3.3.6-1. ACTIONS ------------------------------------------------------------NOTE----------------------------------------------------------- Separate Condition entry is allowed for each Function.
CONDITION REQUIRED ACTION COMPLETION TIME A. One radiation monitoring channel inoperable.
A.1 Restore the affected channel to OPERABLE s tatus. 4 hours4.62963e-5 days <br />0.00111 hours <br />6.613757e-6 weeks <br />1.522e-6 months <br /> B. ------------NOTE------------
Only applicable in MODE 1, 2, 3, or 4. ---------------------------------
One or more Functions with one or more manual or automatic actuation trains inoperable.
OR Two or more radiation monitoring channel s inoperable.
OR Required Action and associated Completion Time of Condition A not met. B.1 Enter applicable Conditions and Required Actions of LCO 3.6.3, "Containment Isolation Valves," for
containment purge and
exhaust isolation valves
made inoperable by isolation instrumentation.
Immediately VentilationVentilation3.3.2.1 3.3.3.1 3.9.9 3.3.2.1 Applicability, 3.3.3.1 Applicability, 3.9.9 Applicabilit y DOC A06 3.3.2.1 ACTION a, ACTION b; Table 3.3-3 ACTION 15, ACTION 19; Table 3.3-6 ACTION 28 1 1 2 2 A A One required 2 supply 2 Containment Purge and Exhaust Isolation Instrumentation (Without Setpoint Control Program) 3.3.6 A Westinghouse STS 3.3.6 A-2 Rev. 4.0 Ventilation 2SEQUOYAH UNIT 1 Amendment XXX CTS 1ACTIONS (continued)
CONDITION REQUIRED ACTION COMPLETION TIME C. ------------NOTE------------
Only applicable during movement of
[recently] irradiated fuel assemblies within
containment. ---------------------------------
One or more Functions with one or more manual
or automatic actuation trains inoperable.
OR Two or more radiation monitoring channel s inoperable.
OR Required Action and associated Complet ion Time for Condition A not met. C.1 Place and maintain containment purge and exhaust valves in closed position.
OR C.2 Enter applicable Conditions and Required Actions of LCO 3.9.4, "Containment Penetrations," for
containment purge and
exhaust isolation valves
made inoperable by isolation instrumentation.
Immediately Immediately Table 3.3-6 ACTION 28, 3.9.9 ACTION 3 2One required B B B 2 2 supply 2 supply Containment Purge and Exhaust Isolation Instrumentation (Without Setpoint Control Program) 3.3.6 A Westinghouse STS 3.3.6 A-3 Rev. 4.0 Ventilation 2SEQUOYAH UNIT 1 Amendment XXX CTS 1SURVEILLANCE REQUIREMENTS ------------------------------------------------------------NOTE-----------------------------------------------------------
Refer to Table 3.3.6-1 to determine which SRs apply for each Containment Purge and Exhaust Isolation Function.
SURVEILLANCE FREQUENCY
SR 3.3.6.1 Perform CHANNEL CHECK.
[ 12 hours1.388889e-4 days <br />0.00333 hours <br />1.984127e-5 weeks <br />4.566e-6 months <br /> OR In accordance
with the Surveillance
Frequency Control Program
] SR 3.3.6.2 Perform ACTUATION LOGIC TEST.
[ 31 days on a STAGGERED TEST BASIS OR In accordance with the Surv eillance Frequency Control Program
] SR 3.3.6.3 Perform MASTER RELAY TEST.
[ 31 days on a STAGGERED TEST BASIS OR In accordance with the Surveillance Frequency Control Program
] Ventilation Table 4.3-2 Function 3.c.3, Table 4.3-3 Instrument 2.a 1 4 4 5 54.3.2.1.1, 4.3.3.1 Containment Purge and Exhaust Isolation Instrumentation (Without Setpoint Control Program) 3.3.6 A Westinghouse STS 3.3.6 A-4 Rev. 4.0 Ventilation 2SEQUOYAH UNIT 1 Amendment XXX CTS 1SURVEILLANCE REQUIREMENTS (continued) SURVEILLANCE FREQUENCY
REVIEWER'S NOTE---------------------------------
The Frequency of 92 days on a STAGGERED TEST BASIS is applicable to the actuation logic processed through the Relay or Solid State Protection System.
[SR 3.3.6.
4 -------------------------------NOTE------------------------------ This Surveillance is only applicable to the actuation logic of the ESFAS Instrumentation.
Perform ACTUATION LOGIC TEST.
[ 92 days on a STAGGERED TEST BASIS ]
OR In accordance
with the Surveillance Frequency Control Program
] 2 Table 4.3-2 Function 3.c.2 6 4 4 5 3 Containment Purge and Exhaust Isolation Instrumentation (Without Setpoint Control Program) 3.3.6 A Westinghouse STS 3.3.6 A-5 Rev. 4.0 Ventilation 2SEQUOYAH UNIT 1 Amendment XXX CTS 1SURVEILLANCE REQUIREMENTS (continued) SURVEILLANCE FREQUENCY
REVIEWER'S NOTE---------------------------------
The Frequency of 92 days on a STAGGERED TEST BASIS is applicable to the master rela ys processed through the Solid State Protection Sys tem. -----------------------------------------------------------------------------------------------
[SR 3.3.6.
5 -------------------------------NOTE------------------------------ This Surveillance is only applicable to the master relays of the ESFAS Instrumentation.
Perform MASTER RELAY TEST.
[ 92 days on a STAGGERED TEST BASIS OR In accordance
with the Surveillance Frequency Control Program ] ] SR 3.3.6.
6 Perform COT.
[ 92 days OR In accordance
with the Surveillance
Frequency
Control Program
] 4 3 DOC M04 Table 4.3-2 Function 3.c.3, Table 4.3-3 Instrument 2.a, 4.9.9 6 4 4 3 5 3 5 4 4 Containment Purge and Exhaust Isolation Instrumentation (Without Setpoint Control Program) 3.3.6 A Westinghouse STS 3.3.6 A-6 Rev. 4.0 Ventilation 2SEQUOYAH UNIT 1 Amendment XXX CTS 1SURVEILLANCE REQUIREMENTS (continued)
SURVEILLANCE FREQUENCY SR 3.3.6.
7 Perform SLAVE RELAY TEST.
[ [92] days OR In accordance with the Surveillance
Frequency
Control Program
] SR 3.3.6.
8 -------------------------------NOTE------------------------------
Verification of setpoint is not required. ---------------------------------------------------------------------
Perform TADOT.
[ [18] months OR In accordance
with the Surveillance
Frequency Control Program
] SR 3.3.6.
9 Perform CHANNEL CALIBRATION.
[ [18] months OR In accordance with the Surveillance
Frequency
Control Program
] 6 7 5 DOC M04 Table 4.3-2 Function 3.c.1, 4.9.9 Table 4.3-2 Function 3.c.3, Table 4.3-3 Instrument 2.a 5 4 4 5 4 4 5 4 4 DOC A07 INSERT 1 2 ITS 3.3.6 Insert Page 3.3.6-6 INSERT 1 SR 3.3.6.8 ------------------------------NOTE------------------------------- Radiation detectors are excluded from response time testing. ---------------------------------------------------------------------
Verify ESF RESPONSE TIME is within limits.
In accordance with the Surveillance
Frequency
Control Program
24.3.2.1.3 DOC L01 Containment Purge and Exhaust Isolation Instrumentation (Without Setpoint Control Program) 3.3.6 A Westinghouse STS 3.3.6 A-7 Rev. 4.0 Ventilation 2SEQUOYAH UNIT 1 Amendment XXX CTS 1Table 3.3.6-1 (page 1 of 1) Containment Purge and Exhaust Isolation Instrumentation FUNCTION APPLICABLE MODES OR OTHER SPECIFIED CONDITIONS REQUIRED CHANNELS SURVEILLANCE REQUIREMENTS TRIP SETPOINT 1.Manual Initiation 1,2,3,4, (a) 2 SR 3.3.6.
8 NA2.Automatic Actuation Logic andActuation Relays 1,2,3,4, (a) 2 trains SR 3.3.6.2 SR 3.3.6.3 [SR 3.3.6.
4] [SR 3.3.6.
5] SR 3.3.6.
7 NA 3.[ Containment Radiationa.Gaseous 1,2,3,4 , (a) [1] SR 3.3.6.1 SR 3.3.6.
6 SR 3.3.6.
9 [2 x background]
b.Particulate 1,2,3,4, (a)
[1] SR 3.3.6.1 SR 3.3.6.6 SR 3.3.6.9 [2 x background]
c.Iodine 1,2,3,4, (a)
[1] SR 3.3.6.1 SR 3.3.6.6 SR 3.3.6.9 [2 x background]
d.Area Radiation 1,2,3,4, (a)
[1] S R 3.3.6.1 SR 3.3.6.6 SR 3.3.6.9 [2 x background]
] 4.Containment Isolation
-Phase A Refer to LCO 3.3.2, "ESFAS Instrumentation," Function 3.a., for all initiation functions and requirements. (a) During movement of
[recently] irradiated fuel assemblies within containment.
6 4 7 Purge Air Monitor 8.5 x 10-3 µCi/ccVentilation 2 3 5 Tables 3.3-3, 4.3-2, and 3.3-4, Function 3.c.1 Tables 3.3-3, 4.3-2, and 3.3-4, Function 3.c.2 Tables 3.3-3, 4.3-2, and 3.3-4, Function 3.c.3, and Table 3.3-6 Instrument 2.a DOC M02 1 5 5 3 5 3Safety Injection 1 2SR 3.3.6.8INSERT 2 ITS 3.3.6 Insert Page 3.3.6-7 INSERT 2 FUNCTION APPLICABLE MODES OR OTHER SPECIFIED CONDITIONS REQUIRED CHANNELS SURVEILLANCE REQUIREMENTS TRIP SETPOINT (a) 1 SR 3.3.6.1 SR 3.3.6.4 SR 3.3.6.7 8.5 x 10-3 µCi/cc 3FUNCTION APPLICABLE MODES OR OTHER SPECIFIED CONDITIONS REQUIRED CHANNELS SURVEILLANCE REQUIREMENTS TRIP SETPOINT (a)
INSERT
Containment Purge and Exhaust Isolation Instrumentation (Without Setpoint Control Program) 3.3.6 A Westinghouse STS 3.3.6 A-1 Rev. 4.0 Ventilation 2SEQUOYAH UNIT 2 Amendment XXX CTS 13.3 INSTRUMENTATION 3.3.6 A Containment Purge and Exhaust Isolation Instrumentation (Without Setpoint Control Program) LCO 3.3.6 The Containment Purge and Exhaust Isolation instrumentation for each Function in Table 3.3.6-1 shall be OPERABLE.
APPLICABILITY: According to Table 3.3.6-1. ACTIONS ------------------------------------------------------------NOTE----------------------------------------------------------- Separate Condition entry is allowed for each Function.
CONDITION REQUIRED ACTION COMPLETION TIME A. One radiation monitoring channel inoperable.
A.1 Restore the affected channel to OPERABLE s tatus. 4 hours4.62963e-5 days <br />0.00111 hours <br />6.613757e-6 weeks <br />1.522e-6 months <br /> B. ------------NOTE------------
Only applicable in MODE 1, 2, 3, or 4. ---------------------------------
One or more Functions with one or more manual or automatic actuation trains inoperable.
OR Two or more radiation monitoring channel s inoperable.
OR Required Action and associated Completion Time of Condition A not met. B.1 Enter applicable Conditions and Required Actions of LCO 3.6.3, "Containment Isolation Valves," for
containment purge and
exhaust isolation valves
made inoperable by isolation instrumentation.
Immediately VentilationVentilation3.3.2 3.3.3.1 3.9.9 3.3.2 Applicability, 3.3.3.1 Applicability, 3.9.9 Applicabilit y DOC A06 3.3.2 ACTION a, ACTION b; Table 3.3-3 ACTION 15, ACTION 19; Table 3.3-6 ACTION 28 1 1 2 2 A A One required 2 supply 2 Containment Purge and Exhaust Isolation Instrumentation (Without Setpoint Control Program) 3.3.6 A Westinghouse STS 3.3.6 A-2 Rev. 4.0 Ventilation 2SEQUOYAH UNIT 2 Amendment XXX CTS 1ACTIONS (continued)
CONDITION REQUIRED ACTION COMPLETION TIME C. ------------NOTE------------
Only applicable during movement of
[recently] irradiated fuel assemblies within
containment. ---------------------------------
One or more Functions with one or more manual or automatic actuation trains inoperable.
OR Two or more radiation monitoring channel s inoperable.
OR Required Action and associated Complet ion Time for Condition A not met. C.1 Place and maintain containment purge and exhaust valves in closed position.
OR C.2 Enter applicable Conditions and Required Actions of LCO 3.9.4, "Containment Penetrations," for
containment purge and
exhaust isolation valves
made inoperable by isolation instrumentation.
Immediately Immediately Table 3.3-6 ACTION 28, 3.9.9 ACTION 3 2One required B B B 2 2 supply 2 supply Containment Purge and Exhaust Isolation Instrumentation (Without Setpoint Control Program) 3.3.6 A Westinghouse STS 3.3.6 A-3 Rev. 4.0 Ventilation 2SEQUOYAH UNIT 2 Amendment XXX CTS 1SURVEILLANCE REQUIREMENTS ------------------------------------------------------------NOTE-----------------------------------------------------------
Refer to Table 3.3.6-1 to determine which SRs apply for each Containment Purge and Exhaust Isolation Function.
SURVEILLANCE FREQUENCY SR 3.3.6.1 Perform CHANNEL CHECK.
[ 12 hours1.388889e-4 days <br />0.00333 hours <br />1.984127e-5 weeks <br />4.566e-6 months <br /> OR In accordance
with the Surveillance
Frequency Control Program
] SR 3.3.6.2 Perform ACTUATION LOGIC TEST.
[ 31 days on a STAGGERED TEST BASIS OR In accordance with the Surv eillance Frequency Control Program
] SR 3.3.6.3 Perform MASTER RELAY TEST.
[ 31 days on a STAGGERED TEST BASIS OR In accordance with the Surveillance Frequency Control Program
] Ventilation Table 4.3-2 Function 3.c.3, Table 4.3-3 Instrument 2.a 1 4 4 5 54.3.2.1.1, 4.3.3.1 Containment Purge and Exhaust Isolation Instrumentation (Without Setpoint Control Program) 3.3.6 A Westinghouse STS 3.3.6 A-4 Rev. 4.0 Ventilation 2SEQUOYAH UNIT 2 Amendment XXX CTS 1SURVEILLANCE REQUIREMENTS (continued) SURVEILLANCE FREQUENCY
REVIEWER'S NOTE---------------------------------
The Frequency of 92 days on a STAGGERED TEST BASIS is applicable to the actuation logic processed through the Relay or Solid State Protection System.
[SR 3.3.6.
4 -------------------------------NOTE------------------------------ This Surveillance is only applicable to the actuation logic of the ESFAS Instrumentation.
Perform ACTUATION LOGIC TEST.
[ 92 days on a STAGGERED TEST BASIS ]
OR In accordance
with the Surveillance Frequency Control Program
] 2 Table 4.3-2 Function 3.c.2 6 4 4 5 3 Containment Purge and Exhaust Isolation Instrumentation (Without Setpoint Control Program) 3.3.6 A Westinghouse STS 3.3.6 A-5 Rev. 4.0 Ventilation 2SEQUOYAH UNIT 2 Amendment XXX CTS 1SURVEILLANCE REQUIREMENTS (continued) SURVEILLANCE FREQUENCY
REVIEWER'S NOTE---------------------------------
The Frequency of 92 days on a STAGGERED TEST BASIS is applicable to the master rela ys processed through the Solid State Protection Sys tem. -----------------------------------------------------------------------------------------------
[SR 3.3.6.
5 -------------------------------NOTE------------------------------ This Surveillance is only applicable to the master relays of the ESFAS Instrumentation.
Perform MASTER RELAY TEST.
[ 92 days on a STAGGERED TEST BASIS OR In accordance
with the Surveillance Frequency Control Program ] ] SR 3.3.6.
6 Perform COT.
[ 92 days OR In accordance
with the Surveillance
Frequency
Control Program
] 4 3 DOC M04 Table 4.3-2 Function 3.c.3, Table 4.3-3 Instrument 2.a, 4.9.9 6 4 4 3 5 3 5 4 4 Containment Purge and Exhaust Isolation Instrumentation (Without Setpoint Control Program) 3.3.6 A Westinghouse STS 3.3.6 A-6 Rev. 4.0 Ventilation 2SEQUOYAH UNIT 2 Amendment XXX CTS 1SURVEILLANCE REQUIREMENTS (continued) SURVEILLANCE FREQUENCY SR 3.3.6.
7 Perform SLAVE RELAY TEST.
[ [92] days OR In accordance with the Surveillance
Frequency
Control Program
] SR 3.3.6.
8 -------------------------------NOTE------------------------------ Verification of setpoint is not required.
Perform TADOT.[ [18] months OR In accordance
with the Surveillance
Frequency Control Program
] SR 3.3.6.
9 Perform CHANNEL CALIBRATION.
[ [18] months OR In accordance
with the Surveillance
Frequency
Control Program
] 6 7 5 DOC M04 Table 4.3-2 Function 3.c.1, 4.9.9 Table 4.3-2 Function 3.c.3, Table 4.3-3 Instrument 2.a 5 4 4 5 4 4 5 4 4 DOC A07 INSERT 1 2 ITS 3.3.6 Insert Page 3.3.6-6 INSERT 1 SR 3.3.6.8 ------------------------------NOTE------------------------------- Radiation detectors are excluded from response time testing. ---------------------------------------------------------------------
Verify ESF RESPONSE TIME is within limits.
In accordance with the Surveillance
Frequency
Control Program
24.3.2.1.3 DOC L01 Containment Purge and Exhaust Isolation Instrumentation (Without Setpoint Control Program) 3.3.6 A Westinghouse STS 3.3.6 A-7 Rev. 4.0 Ventilation 2SEQUOYAH UNIT 2 Amendment XXX CTS 1Table 3.3.6-1 (page 1 of 1) Containment Purge and Exhaust Isolation Instrumentation FUNCTION APPLICABLE MODES OR OTHER SPECIFIED CONDITIONS REQUIRED CHANNELS SURVEILLANCE REQUIREMENTS TRIP SETPOINT 1.Manual Initiation 1,2,3,4, (a) 2 SR 3.3.6.
8 NA2.Automatic Actuation Logic andActuation Relays 1,2,3,4, (a) 2 trains SR 3.3.6.2 SR 3.3.6.3 [SR 3.3.6.
4] [SR 3.3.6.
5] SR 3.3.6.
7 NA 3.[ Containment Radiationa.Gaseous 1,2,3,4 , (a) [1] SR 3.3.6.1 SR 3.3.6.
6 SR 3.3.6.
9 [2 x background]
b.Particulate 1,2,3,4, (a)
[1] SR 3.3.6.1 SR 3.3.6.6 SR 3.3.6.9 [2 x background]
c.Iodine 1,2,3,4, (a)
[1] SR 3.3.6.1 SR 3.3.6.6 SR 3.3.6.9 [2 x background]
d.Area Radiat ion 1,2,3,4, (a)
[1] S R 3.3.6.1 SR 3.3.6.6 SR 3.3.6.9 [2 x background]
] 4.Containment Isolation
-Phase A Refer to LCO 3.3.2, "ESFAS Instrumentation," Function 3.a., for all initiation functions and requirements. (a) During movement of
[recently] irradiated fuel assemblies within containment.
6 4 7 Purge Air Monitor 8.5 x 10-3 µCi/ccVentilation 2 3 5 Tables 3.3-3, 4.3-2, and 3.3-4, Function 3.c.1 Tables 3.3-3, 4.3-2, and 3.3-4, Function 3.c.2 Tables 3.3-3, 4.3-2, and 3.3-4, Function 3.c.3, and Table 3.3-6 Instrument 2.a DOC M02 1 5 5 3 5 3Safety Injection 1 2SR 3.3.6.8INSERT 2 ITS 3.3.6 Insert Page 3.3.6-7 INSERT 2 FUNCTION APPLICABLE MODES OR OTHER SPECIFIED CONDITIONS REQUIRED CHANNELS SURVEILLANCE REQUIREMENTS TRIP SETPOINT (a) 1 SR 3.3.6.1 SR 3.3.6.4 SR 3.3.6.7 8.5 x 10-3 µCi/cc 3FUNCTION APPLICABLE MODES OR OTHER SPECIFIED CONDITIONS REQUIRED CHANNELS SURVEILLANCE REQUIREMENTS TRIP SETPOINT SR 3.3.6. SR 3.3.6. INSERT (a) S R 3.3.6.
JUSTIFICATION FOR DEVIATIONS ITS 3.3.6, CONTAINMENT VENTILATION ISOLATION INSTRUMENTATION Sequoyah Unit 1 and Unit 2 Page 1 of 1 1.The type of Setpoint Control Program (Without Setpoint Control Program) and the Specification designator "A" are deleted since they are unnecessary. Th is information is provided in NUREG 1 431, Re v. 4.0 to assist in identifying the appropriate Specification to be used as a model for the plant specific ITS conversion, but serves no purpose in the plant specific implementation. In addition, IS TS 3.3.6B (with Setpoint Control Program Specification) is not used and is not show n.Furthermore, the title of the Specification has been changed from "Containm ent Purge and Exhaust Isolation Instrumentation" to " Containment Ventilatio n Isolation Instrumentation" since Sequoyah Nuclear Plant (SQN) does not have a Containmen t Purge and Exhaust Isola tion Instrumentation.
2.Changes are made (additions, deletions, and/or changes) to the ISTS that reflect theplant specific nomenclature, number, refer ence, system description, analysis, or licensing ba sis description.
3.The ISTS contains bracketed information and/or values that ar e generic to Westinghouse vintage plants. The brackets are removed and the proper plant specific information/value is inserted to reflect th e current licensing basis.
.6.1, SR 3.3.6.4, SR 3.3.6.5, SR 3.3.6.6, SR 3.3.6.7, SR 3.3.6.8 and SR 3.3.6.9 (ITS SR 3.3.
6.1, SR 3.3.6.2, SR 3.3.6.3, SR 3.3.6.4, SR 3.3.6.5, SR 3.3.6.6, and SR 3.3.6.7, respectively) pro v ide two options for controlling the Frequencies of Surveillance Requirements. SQN is proposi ng to control the Surveillance Frequencie s under the Surveillance Frequency Control Program.
5.The ACTUATION LOGIC TEST and MASTER RELAY TEST for SQN are processedthrough the Solid State Protection System. Since ISTS SR 3.3.6.4 and IS TS SR 3.3.6.5 are the appropriate Surveillances for the ACTUATION LOGIC TEST and MASTER RELAY TEST when they are processed through the Solid State Protectio n System, ISTS SR 3.3.6.2 and SR 3.3.6.3 have been deleted and the subs equent Surveillance Requireme nts have been renumbered.
6.The Reviewer's Note has been deleted. Thi s information is for the NRC reviewer to be keyed into what is needed to meet this requirement. This Note is not meant to be retained in the final version of the plant specific submittal.
Improved Standard Technical Specifications (ISTS) Bases Markup and Bases Justification for Deviations (JFDs)
Containment Purge and Exhaust Isolation Instrumentation (Without Setpoint Control Program)
B 3.3.6 A Westinghouse STS B 3.3.6 A-1 Rev. 4.0 1SEQUOYAH UNIT 1 Revision XXX Ventilation 1 2B 3.3 INSTRUMENTATION B 3.3.6A Containment Purge and Exhaust Isolation Instrumentation (Without Setpoint Control Program) BASES BACKGROUND Containment purge and exhaust isolation instrumentation closes the containment isolation valves in the Mini Purge System and the Shutdown Purge System. This action isolates the containment atmosphere from the environment to minimize releases of radioactivity in the event of an accident. The Mini Purge System may be in use during reactor operation and the Shutdown Purge System will be in use with the reactor shutdown. Containment purge and exhaust isolation initiates on a automatic safety injection (SI) signal through the Containment Isolatio n - Phase A Function, or by manual actuation of Phase A Isolation. The Bases for LCO 3.3.2, "Engineered Safety Feature Actuation System (ESFAS)
Instrumentation," discuss these modes of initiation. Four radiation monitoring channels are also provided as input to the containment purge and exhaust isolation. The four channels measure containment radiation at two locations. One channel is a containment area gamma monitor, and the other three measure radiation in a sample of the containment purge exhaust. The three purge exhaust radiation detectors are of three different types: gaseous, particulate, and iodine monitors. All four detectors will respond to most events that release radiation to containment. However, analyses have not been conducted to demonstrate that all credible events will be detected by more than one monitor. Therefore, for the purposes of this LCO the four channels are not considered redundant. Instead, they are treated as four one
-out-of-one Functions. Since the purge exhaust monitors constitute a sampling system, various components such as sample line valves, sample line heaters, sample pumps, and filter motors are required to support monitor OPERABILITY.
Each of the purge system s has inner and outer containment isolation valves in its supply and exhaust ducts. A high radiation signal from any one of the four channels initiates containment purge isolation, which closes both inner and outer containment isolation valves in the Mini Purge System and the Shutdown Purge System. Th ese system s are described in the Bases for LCO 3.6.3, "Containment Isolation Valves." APPLICABLE The safety analyses assume that the containment remains intact with
SAFETY penetrations unnecessary for core cooling isolated early in the event, ANALYSESwithin approximately 60 seconds. The isolation of the purge valves has not been analyzed mechanistically in the dose calculations, although its Containment The containment Ventilation VentilationVentilationContainment 300 containment purge 1 1Containment 2 2 1 2 2 2of SI signals 2ventilation is is Containment Purge and Exhaust Isolation Instrumentation (Without Setpoint Control Program)
B 3.3.6 A Westinghouse STS B 3.3.6 A-2 Rev. 4.0 1SEQUOYAH UNIT 1 Revision XXX Ventilation 1 2BASES APPLICABLE SAFETY ANALYSES (continued) rapid isolation is assumed. The containment purge and exhaust isolation radiation monitors act as backup to the SI signal to ensure closing of the purge and exhaust valves. They are also the primary means for automatically isolating containment in the event of a fuel handling accident during shutdown. Containment isolation in turn ensures meeting the containment leakage rate assumptions of the safety analyses, and ensures that the calculated accidental offsite radiological doses are below 10 CFR 100 (Ref. 1) limits.
[Due to radioactive decay, containment is only required to isolate during fuel handling accidents involving handling recently irradiated fuel (i.e., fuel that has occupied part of a critical reactor core within the previous [X] days).] The containment purge and exhaust isolation instrumentation satisfies Criterion 3 of 10 CFR 50.36(c)(2)(ii). LCO The LCO requirements ensure that the instrumentation necessary to initiate Containment Purge and Exhaust Isolation, listed in Table 3.3.6-1, is OPERABLE.
- 1. ManualInitiationThe LCO requires two channels OPERABLE. The operator caninitiate Containment Purge Isolation at any time by using either of twoswitches in the control room. Either switch actuates both trains.
Thisaction will cause actuation of all components in the same manner asany of the automatic actuation signals.The LCO for Manual Initiation ensures the proper amount ofredundancy is maintained in the manual actuation circuitry to ensurethe operator has manual initiation capability.Each channel consists of one push button and the interconnectingwiring to the actuation logic cabinet.2.Automatic Actuation Logic and Actuation RelaysThe LCO requires two trains of Automatic Actuation Logic andActuation Relays OPERABLE to ensure that no single random failure can prevent automatic actuation.
containment supply 100 hours0.00116 days <br />0.0278 hours <br />1.653439e-4 weeks <br />3.805e-5 months <br />selector switchventilation ventilationVentilation 2 1 2 3 3 1 1 2Ventilation INSERT 1 1 2(10 CFR 50.67 limits for a fuel handling accident) 2, in addition
,
B 3.3.6 Insert Page B 3.3.6-2 INSERT 1 one of three sets of manual initiation switches in the control room. Either of the two Phase A and Containment Ventilation Isolation switches (HS-30-63A and HS-30-63B) or, both Phase B and Containment Ventilation Isolation switches (HS-30-64A and HS-30-64B), or both Phase B Containment Isolation switches (HS-30-68A and HS-30-68B), will actuate both trains of CVI.
2 Containment Purge and Exhaust Isolation Instrumentation (Without Setpoint Control Program)
B 3.3.6 A Westinghouse STS B 3.3.6 A-3 Rev. 4.0 1SEQUOYAH UNIT 1 Revision XXX Ventilation 1 2BASES LCO (continued) Automatic Actuation Logic and Actuation Relays consist of the same features and operate in the same manner as described for ESFAS Function 1.b, SI , and ESFAS Function 3.a, Containment Phase A Isolation. The applicable MODES and specified conditions for the containment purge isolation portion of these Functions are different and less restrictive than those for the ir Phase A isolation and SI role s. If one or more of the SI or Phase A isolation Functions becomes inoperable in such a manner that only the Containment
Purge Isolation Function is affected, the Conditions applicable to the ir SI and Phase A is olation Functions need not be entered. The less restrictive Actions specified for inoperability of the Containment Purge Isolation Functions specify sufficient compensatory measures for this case.
- 3. Containmen t Radiation The LCO specifies f our required channel s of radiation monitors to ensure that the radiation monitoring instrumentation necessary to initiate Cont ainment Purge Isolation remains OPERABLE.For sampling systems, channel OPERABILITY involves more than OPERABILITY of the channel electronics. OPERABILITY may also require corr ect valve lineup s , sample pump operation, and filter motor operation, as well as detector OPERABILITY, if these suppor tingfeatures are necessary for trip to occur under the conditions assumed by the safety analyses.
- 4. Containmen t Isolation
- Phase A Refer to LCO 3.3.2, Function 3.a., for all initiating Functions a nd requirements.
APPLICABILITY The Manual Initiation, Automatic Actuation Logic and Actuation Relays, Containment Isolation
- Phase A, and Containment Radiation Functions are required OPERABLE in MODES 1, 2, 3, and 4, and during movement of [recently] irradiated fuel assemblies
[(i.e., fuel that has occupied part of a critical reactor core within the previous [X] days)] within containment. Under these conditions, the potential exists for an accident that could release significant fission product radioactivity into containment.
Therefore, the containment purge and exhaust isolation instrumentation must be OPERABLE in these MODES. 100 hours0.00116 days <br />0.0278 hours <br />1.653439e-4 weeks <br />3.805e-5 months <br /> Ventilation 3 1ventilation the SI Function is Ventilation Ventilation Ventilation one Safety Injection (SI) 1 2 2 2 4Safety Injection INSERT 2 4 4 and s 2 B 3.3.6 Insert Page B 3.3.6-3 INSERT 2 Since the movement of recently irradiated fuel assemblies in containment can only occur in MODE 6 or with the unit defueled, only one Containment Purge Air Radiation Monitor is required to be OPERABLE during the movement of recently irradiated fuel assemblies in containment.
2 Containment Purge and Exhaust Isolation Instrumentation (Without Setpoint Control Program)
B 3.3.6 A Westinghouse STS B 3.3.6 A-4 Rev. 4.0 1SEQUOYAH UNIT 1 Revision XXX Ventilation 1 2BASES
APPLICABILITY (continued)
While in MODES 5 and 6 without fuel handling in progress, the containment purge and exhaust isolation instrumentation need not be OPERABLE since the potential for radioactive releases is minimized and operator action is sufficient to ensure post accident offsite doses are maintained within the limits of Reference 1.
The Applicability for the containment purge and exhaust isolation on the ESFAS Containment Isolation
-Phase A Functions are specified in LCO 3.3.2. Refer to the Bases for LCO 3.3.2 for discussion of the Containment Isolation
-Phases A Function Applicability.
ACTIONS The most common cause of channel inoperability is outright failure or drift of the bistable or process module sufficient to exceed the tolerance allowed by unit specific calibration procedures. Typically, the drift is found to be small and results in a delay of actuation rather than a total loss of function. This determination is generally made during the performance of a COT, when the process instrumentation is set up for adjustment to bring it within specification. If the Trip Setpoint is less conservative than the tolerance specified by the calibration procedure, the channel must be declared inoperable immediately and the appropriate Condition entered.
A Note has been added to the ACTIONS to clarify the application of Completion Time rules. The Conditions of this Specification may be entered independently for each Function listed in Table 3.3.6-1. The Completion Time(s) of the inoperable channel(s)/train(s) of a Function will be tracked separately for each Function starting from the time the Condition was entered for that Function.
A.1 Condition A applies to the failure of one containment purge isolation radiation monitor channel.
Since the four containment radiation monitors measure different parameters , failure of a single channel may result in loss of the radiation monitoring Function for certain events. Consequently, the failed channel must be restored to OPERABLE status.
The 4 hours4.62963e-5 days <br />0.00111 hours <br />6.613757e-6 weeks <br />1.522e-6 months <br /> allowed to restore the affected channel is justified by the low likelihood of events occurring during this interval, and recognition that one or more of the remaining channel s will respond to most events.
ventilation ventilation 1 1Safety Injection Safety Injection 4 4 2 4 Containment Purge and Exhaust Isolation Instrumentation (Without Setpoint Control Program)
B 3.3.6 A Westinghouse STS B 3.3.6 A-5 Rev. 4.0 1SEQUOYAH UNIT 1 Revision XXX Ventilation 1 2BASES ACTIONS (continued)
B.1 Condition B applies to all Containment Purge and Exhaust Isolation Functions and addresses the train orientation of the Solid State Protection System (SSPS) and the master and slave relays for these Functions. It also addresses the failure of multiple radiation monitoring channels, or the inability to restore a single failed channel to OPERABLE status in the time allowed for Required Action A.1. If a train is inoperable
, multiple channels are inoperable, or the Required Action and associated Completion Time of Condition A are not met, operation may continue as long as the Required Action for the applicable Conditions of LCO 3.6.3 is met for each valve made inoperable by failure
of isolation instrumentation. A Note is added stating that Condition B is only applicable in MODE 1, 2, 3, or 4. C.1 and C.2 Condition C applies to all Containment Purge and Exhaust Isolation Functions and addresses the train orientation of the SSPS and the master and slave relays for these Functions. It also addresses the failure of
multiple radiation monitoring channels, or the inability to restore a single failed channel to OPERABLE status in the time allowed for Required Action A.1. If a train is inoperable, multiple channels are inoperable, or the Required Action and associated Completion Time of Condition A are not met, operation may continue as long as the Required Action to place and maintain containment purge and exhaust isolation valves in their closed position is met or the applicable Conditions of LCO 3.9.4, "Containment Penetrations," are met for each valve made inoperable by failure of isolation instrumentation. The Completion Time for these Required Actions is Immediately.
A Note states that Condition C is applicable during movement of
[recently] irradiated fuel assemblies within containment. SURVEILLANCE A Note has been added to the SR Table to clarify that Table 3.3.6-1 REQUIREMENTS determines which SRs apply to which Containment Purge and Exhaust Isolation Functions. VentilationVentilationventilation Ventilation 1 1 1 1 3the single required or the required radiation monitoring channel is 4 A B A or A B B 4 4 4 4 4 4 4 4 Containment Purge and Exhaust Isolation Instrumentation (Without Setpoint Control Program)
B 3.3.6 A Westinghouse STS B 3.3.6 A-6 Rev. 4.0 1SEQUOYAH UNIT 1 Revision XXX Ventilation 1 2BASES
SURVEILLANCE REQUIREMENTS (continued)
Performance of the CHANNEL CHECK ensures that a gross failure of instrumentation has not occurred. A CHANNEL CHECK is normally a comparison of the parameter indicated on one channel to a similar parameter on other channels. It is based on the assumption that instrument channels monitoring the same parameter should read approximately the same value. Significant deviations between the two instrument channels could be an indication of excessive instrument drift in one of the channels or of something even more serious. A CHANNEL CHECK will detect gross channel failure; thus, it is key to verifying the instrumentation continues to operate properly between each CHANNEL CALIBRATION.
Agreement criteria are determined by the unit staff, based on a combination of the channel instrument uncertainties, including indication and readability. If a channel is outside the criteria, it may be an indication that the sensor or the signal processing equipment has drifted outside its limit.
[ The Frequency of 12 months is based on operating experience that demonstrates channel failure is rare. The CHANNEL CHECK supplements less formal, but more frequent, checks of channels during normal operational use of the displays associated with the LCO required channels.
OR The Surveillance Frequency is controlled under the Surveillance Frequency Control Program.
REVIEWER'S NOTE-----------------------------------
Plants controlling Surveillance Frequencies under a Surveillance Frequency Control Program should utilize the appropriate Frequency description, given above, and the appropriate choice of Frequency in the Surveillance Requirement.
]
5 6 Containment Purge and Exhaust Isolation Instrumentation (Without Setpoint Control Program)
B 3.3.6 A Westinghouse STS B 3.3.6 A-7 Rev. 4.0 1SEQUOYAH UNIT 1 Revision XXX Ventilation 1 2BASES
SURVEILLANCE REQUIREMENTS (continued)
SR 3.3.6.2 SR 3.3.6.2 is the performance of an ACTUATION LOGIC TEST. The train being tested is placed in the bypass condition, thus preventing inadvertent actuation. Through the semiautomatic tester, all possible logic combinations, with and without applicable permissives, are tested for each protection function. In addition, the master relay coil is pulse tested for continuity. This verifies that the logic modules are OPERABLE and there is an intact voltage signal path to the master relay coils. [
This test is performed every 31 days on a STAGGE RED TEST BASIS. The Surveillance interval is acceptable based on instrument reliability and industry operating experience.
OR The Surveillance Frequency is controlled under the Surveillance Frequency Control Program.
REVIEWER'S NOTE-----------------------------------
Plants controlling Surveillance Frequencies under a Surveillance Frequency Control Program should utilize the appropriate Frequency description, given above, and the appropriate choice of Frequency in the Surveillance Requirement.
]
SR 3.3.6.3 SR 3.3.6.3 is the performance of a MASTER RELAY TEST. The MASTER RELAY TEST is the energizing of the master rela y, verifying contact operation and a low voltage continuity check of the slave relay coil. Upon master relay contact operation, a low voltage is injected to the slave relay coil. This voltage is insufficient to pick up the slave relay, but large enough to demonstrate signal path continuity.
[ This test is performed every 31 days on a STAGGERED TEST BASIS. The Surveillance interval is acceptable based on instrument reliability and industry operating experience.
OR The Surveillance Frequency is controlled under the Surveillance Frequency Control Program.
4 4 Containment Purge and Exhaust Isolation Instrumentation (Without Setpoint Control Program)
B 3.3.6 A Westinghouse STS B 3.3.6 A-8 Rev. 4.0 1SEQUOYAH UNIT 1 Revision XXX Ventilation 1 2BASES
SURVEILLANCE REQUIREMENTS (continued)
REVIEWER'S NOTE-----------------------------------
Plants controlling Surveillance Frequencies under a Surveillance Frequency Control Program should utilize the appropriate Frequency description, given above, and the appropriate choice of Frequency in the Surveillance Requirement.
]
[ SR 3.3.6.
4 SR 3.3.6.4 is the performance of an ACTUATION LOGIC TEST. The train being tested is placed in the bypass condition, thus preventing inadvertent actuation. Through the semiautomatic tester, all possible logic combinations, with and without applicable permissives, are tested for each protection function. In addition, the master relay coil is pulse tested for continuity. This verifies that the logic modules are OPERABLE and there is an intact voltage signal path to the master relay coils.
[ This test is performed every 92 days on a STAGGERED TEST BASIS. The Surveillance interval is justified in Reference 2.
OR The Surveillance Frequency is controlled under the Surveillance Frequency Control Program.
REVIEWER'S NOTE-----------------------------------
Plants controlling Surveillance Frequencies under a Surveillance Frequency Control Program should utilize the appropriate Frequency description, given above, and the appropriate choice of Frequency in the Surveillance Requirement.
]
The SR is modified by a Note stating that the Surveillance is only applicable to the actuation logic of the ESFAS Instrumentation.
] [ SR 3.3.6.
5 SR 3.3.6.5 is the performance of a MASTER RELAY TEST. The MASTER RELAY TEST is the energizing of the master relay, verifying contact operation and a low voltage continuity check of the slave relay coil. Upon master relay contact operation, a low voltage is injected to the slave relay coil. This voltage is insufficient to pick up the slave relay, but
2 2 3 3 6 4 5 6 4 3 3 Containment Purge and Exhaust Isolation Instrumentation (Without Setpoint Control Program)
B 3.3.6 A Westinghouse STS B 3.3.6 A-9 Rev. 4.0 1SEQUOYAH UNIT 1 Revision XXX Ventilation 1 2BASES SURVEILLANCE REQUIREMENTS (continued) large enough to demonstrate signal path continuity.
[ This test is performed every 92 days on a STAGGERED TEST BASIS. The Surveillance interval is justified in Reference 2.
OR The Surveillance Frequency is controlled under the Surveillance Frequency Control Program.
REVIEWER'S NOTE-----------------------------------
Plants controlling Surveillance Frequencies under a Surveillance Frequency Control Program should utilize the appropriate Frequency description, given above, and the appropriate choice of Frequency in the Surveillance Requirement.
] The SR is modified by a Note stating that the Surveillance is only applicable to the master relays of the EFAS Instrumentation.
] SR 3.3.6.
6 A COT is performed on each required channel to ensure the entire channel will perform the intended Function. A successful test of the required contact(s) of a channel relay may be performed by the verification of the change of state of a single contact of the relay. This clarifies what is an acceptable COT of a relay. This is acceptable because all of the other required contacts of the relay are verified by other Technical Specifications and non-Technical Specifications tests at least once per refueling interval with applicable extensions.
[ The Frequency of 92 days is based on the staff recommendation for increasing the availability of radiation monitors according to NUREG
-1366 (Ref.
3). OR The Surveillance Frequency is controlled under the Surveillance Frequency Control Program. -----------------------------------REVIEWER'S NOTE-----------------------------------
Plants controlling Surveillance Frequencies under a Surveillance Frequency Control Program should utilize the appropriate Frequency description, given above, and the appropriate choice of Frequency in the Surveillance Requirement.
] 4 5 6 3 4 5 6 Containment Purge and Exhaust Isolation Instrumentation (Without Setpoint Control Program)
B 3.3.6 A Westinghouse STS B 3.3.6 A-10 Rev. 4.0 1SEQUOYAH UNIT 1 Revision XXX Ventilation 1 2BASES
SURVEILLANCE REQUIREMENTS (continued)
This test verifies the capability of the instrumentation to provide the containment purge and exhaust system isolation. There is a plant specific program which verifies that the instrument channel functions as required by verifying the as-left and as-found setting are consistent with
those established by the setpoint methodology.
7 SR 3.3.6.7 is the performance of a SLAVE RELAY TEST. The SLAVE RELAY TEST is the energizing of the slave relays. Contact operation is verified in one of two ways. Actuation equipment that may be operated in the design mitigation mode is either allowed to function or is placed in a condition where the relay contact operation can be verified without operation of the equipment. Actuation equipment that may not be operated in the design mitigation mode is prevented from operation by the SLAVE RELAY TEST circuit. For this latter case, contact operation is verified by a continuity check of the circuit containing the slave relay.
[ The Frequency of 92 days is acceptable based on instrument reliability and industry operating experience.
OR The Surveillance Frequency is controlled under the Surveillance Frequency Control Program.
REVIEWER'S NOTE-----------------------------------
Plants controlling Surveillance Frequencies under a Surveillance Frequency Control Program should utilize the appropriate Frequency description, given above, and the appropriate choice of Frequency in the Surveillance Requirement.
] SR 3.3.6.
8 SR 3.3.6.8 is the performance of a TADOT. This test is a check of the Manual Actuation Functions. Each Manual Actuation Function is tested up to, and including, the master relay coils. A successful test of the required contact(s) of a channel relay may be performed by the verification of the change of state of a single contact of the relay. This
5 5 6 6 1 4 5 6 4ventilation Containment Purge and Exhaust Isolation Instrumentation B 3.3.6 A Westinghouse STS B 3.3.6 A-11 Rev. 4.0, SEQUOYAH UNIT 1 Revision XXX 1 2Ventilation 1BASES
SURVEILLANCE REQUIREMENTS (continued)
clarifies what is an acceptable TADOT of a relay. This is acceptable because all of the other required contacts of the relay are verified by other Technical Specifications and non-Technical Specifications tests at least once per refueling interval with applicable extensions. In some instances, the test includes actuation of the end device (i.e., pump starts, valve cycles, etc.).
The test also includes trip devices that provide actuation signals directly to the SSPS, bypassing the analog process control equipment.
The SR is modified by a Note that excludes verification of setpoints during the TADOT. The Functions tested have no setpoints associated with them.
[ The Frequency of 18 months is based on the known reliability of the Function and the redundancy available, and has been shown to be acceptable through operating experience.
OR The Surveillance Frequency is controlled under the Surveillance Frequency Control Program.
REVIEWER'S NOTE-----------------------------------
Plants controlling Surveillance Frequencies under a Surveillance Frequency Control Program should utilize the appropriate Frequency description, given above, and the appropriate choice of Frequency in the Surveillance Requirement.
] SR 3.3.6.
9 CHANNEL CALIBRATION is a complete check of the instrument loop, including the sensor. The test verifies that the channel responds to a measured parameter within the necessary range and accuracy. There is a plant specific program which verifies that the instrument channel functions as required by verifying the as-left and as-found setting are consistent with those established by the setpoint methodology.
[ The Frequency of 18 months is based on operating experience and is consistent with the typical industry refueling cycle.
OR 7 5 6 4 5 2 Containment Purge and Exhaust Isolation Instrumentation B 3.3.6 A Westinghouse STS B 3.3.6 A-12 Rev. 4.0 2 1Revision XXXSEQUOYAH UNIT 1 Ventilation 1BASES
SURVEILLANCE REQUIREMENTS (continued)
The Surveillance Frequency is controlled under the Surveillance Frequency Control Program.
REVIEWER'S NOTE-----------------------------------
Plants controlling Surveillance Frequencies under a Surveillance Frequency Control Program should utilize the appropriate Frequency description, given above, and the appropriate choice of Frequency in the Surveillance Requirement.
]
REFERENCES 1. 10 CFR 100.11.
- 2. WCAP-15376, Rev. 0, October 2000.
- 3. NUREG-1366, [date].
6 2 2UFSAR Table 7.3.1-4 WCAP-14036-P-A, Revision 1, "Elimination of Periodic Protection Channel Response Time Tests," December 1995 INSERT 3 2 B 3.3.6 Insert Page B 3.3.6-12 INSERT 3 SR 3.3.6.8 This SR ensures the individual channel response times are less than or equal to the maximum values assumed in the accident analysis.
Response Time testing acceptance criteria are included in the Updated Final Safety Analysis Report, Table 7.3.1-4 (Ref. 2). Individual component response times are not modeled in the analyses. The analyses model the overall or total elapsed time, from the point at which the parameter exceeds the Trip Setpoint value to the point at which the equipment in both trains reaches the required functional state (e.g.,
valves in full open or closed position).
Response time may be verified by actual response time tests in any series of sequential, overlapping or total channel measurements, or by the summation of allocated signal processing and actuation logic response times with actual response time tests on the remainder of the channel.
WCAP-14036-P, Revision 1, "Elimination of Periodic Protection Channel Response Time Tests," (Ref. 3) provides the basis and methodology for using allocated signal processing and actuation logic response times in the overall verification of the protection system channel response time. The allocations for signal conditioning and actuation logic response times must be verified prior to placing the component in operational service and re-verified following maintenance that may adversely affect response
time. In general, electrical repair work does not impact response time provided the parts used for repair are of the same type and value. Specific components identified in the WCAP may be replaced without verification testing.
The Surveillance Frequency is controlled under the Surveillance Frequency Control Program.
SR 3.3.6.8 is modified by a Note stating that radiation detectors are excluded from response time testing.
2 Containment Purge and Exhaust Isolation Instrumentation (Without Setpoint Control Program)
B 3.3.6 A Westinghouse STS B 3.3.6 A-1 Rev. 4.0 1SEQUOYAH UNIT 2 Revision XXX Ventilation 1 2B 3.3 INSTRUMENTATION
B 3.3.6A Containment Purge and Exhaust Isolation Instrumentation (Without Setpoint Control Program) BASES
BACKGROUND Containment purge and exhaust isolation instrumentation closes the containment isolation valves in the Mini Purge System and the Shutdown Purge System. This action isolates the containment atmosphere from the environment to minimize releases of radioactivity in the event of an accident. The Mini Purge System may be in use during reactor operation and the Shutdown Purge System will be in use with the reactor shutdown.
Containment purge and exhaust isolation initiates on a automatic safety injection (SI) signal through the Containment Isolatio n - Phase A Function, or by manual actuation of Phase A Isolation. The Bases for LCO 3.3.2, "Engineered Safety Feature Actuation System (ESFAS) Instrumentation," discuss these modes of initiation.
Four radiation monitoring channels are also provided as input to the containment purge and exhaust isolation. The four channels measure containment radiation at two locations. One channel is a containment area gamma monitor, and the other three measure radiation in a sample of the containment purge exhaust. The three purge exhaust radiation detectors are of three different types: gaseous, particulate, and iodine monitors. All four detectors will respond to most events that release radiation to containment. However, analyses have not been conducted to demonstrate that all credible events will be detected by more than one monitor. Therefore, for the purposes of this LCO the four channels are not considered redundant. Instead, they are treated as four one
-out-of-one Functions. Since the purge exhaust monitors constitute a sampling system, various components such as sample line valves, sample line heaters, sample pumps, and filter motors are required to support monitor OPERABILITY.
Each of the purge system s has inner and outer containment isolation valves in its supply and exhaust ducts. A high radiation signal from any one of the four channels initiates containment purge isolation, which closes both inner and outer containment isolation valves in the Mini Purge System and the Shutdown Purge System. Th ese system s are described in the Bases for LCO 3.6.3, "Containment Isolation Valves." APPLICABLE The safety analyses assume that the containment remains intact with
SAFETY penetrations unnecessary for core cooling isolated early in the event, ANALYSES within approximately 60 seconds. The isolation of the purge valves has not been analyzed mechanistically in the dose calculations, although its Containment The containment Ventilation VentilationVentilationContainment 300 containment purge 1 1Containment 2 2 1 2 2 2of SI signals 2ventilation is is Containment Purge and Exhaust Isolation Instrumentation (Without Setpoint Control Program)
B 3.3.6 A Westinghouse STS B 3.3.6 A-2 Rev. 4.0 1SEQUOYAH UNIT 2 Revision XXX Ventilation 1 2BASES APPLICABLE SAFETY ANALYSES (continued) rapid isolation is assumed. The containment purge and exhaust isolation radiation monitors act as backup to the SI signal to ensure closing of the purge and exhaust valves. They are also the primary means for automatically isolating containment in the event of a fuel handling accident during shutdown. Containment isolation in turn ensures meeting the containment leakage rate assumptions of the safety analyses, and ensures that the calculated accidental offsite radiological doses are below 10 CFR 100 (Ref. 1) limits.
[Due to radioactive decay, containment is only required to isolate during fuel handling accidents involving handling recently irradiated fuel (i.e., fuel that has occupied part of a critical reactor core within the previous [X] days).] The containment purge and exhaust isolation instrumentation satisfies Criterion 3 of 10 CFR 50.36(c)(2)(ii). LCO The LCO requirements ensure that the instrumentation necessary to initiate Containment Purge and Exhaust Isolation, listed in Table 3.3.6-1, is OPERABLE.
- 1. Manual Initiation The LCO re quires two channels OPERABLE. T he operator can initiate Cont ainment Purge Isolation at any time by using either of two switches in the control room. Either switch actuates both trains.
This action will cause actuation of all co mponents in the same manner as any of the automatic actuation signals.The LCO for Manual Initiation ensures the proper amount of redundancy is maintained in the manual actuation circuitry to ensure the operator has manual initiation ca pability.Each channel consists of one push button and the interconne cting wiring to the actuation logic cabinet.
2.Automatic Actuation Logic and Actuation Relays The LCO requires two trains of Automatic Actuation Logic an d Actuation Relays OPERABLE to ensure that no single rando m failure can prevent automatic actuation.
containment supply 100 hours0.00116 days <br />0.0278 hours <br />1.653439e-4 weeks <br />3.805e-5 months <br />selector switchventilation ventilationVentilation 2 1 2 3 3 1 1 2Ventilation INSERT 1 1 2(10 CFR 50.67 limits for a fuel handling accident) 2, in addition
,
B 3.3.6 Insert Page B 3.3.6-2 INSERT 1 one of three sets of manual initiation switches in the control room. Either of the two Phase A and Containment Ventilation Isolation switches (HS-30-63A and HS-30-63B) or, both Phase B and Containment Ventilation Isolation switches (HS-30-64A and HS-30-64B), or both Phase B Containment Isolation switches (HS-30-68A and HS-30-68B), will actuate both trains of CVI.
2 Containment Purge and Exhaust Isolation Instrumentation (Without Setpoint Control Program)
B 3.3.6 A Westinghouse STS B 3.3.6 A-3 Rev. 4.0 1SEQUOYAH UNIT 2 Revision XXX Ventilation 1 2BASES LCO (continued) Automatic Actuation Logic and Actuation Relays consist of the same features and operate in the same manner as described for ESFAS Function 1.b, SI , and ESFAS Function 3.a, Containment Phase A Isolation. The applicable MODES and specified conditions for the containment purge isolation portion of these Functions are different and less restrictive than those for the ir Phase A isolation and SI role s. If one or more of the SI or Phase A isolation Functions becomes inoperable in such a manner that only the Containment
Purge Isolation Function is affected, the Conditions applicable to the ir SI and Phase A is olation Functions need not be entered. The less restrictive Actions specified for inoperability of the Containment Purge Isolation Functions specify sufficient compensatory measures for this case.
- 3. Containmen t Radiation The LCO specifies f our required channel s of radiation monitors to ensure that the radiation monitoring instrumentation necessary to initiate Cont ainment Purge Isolation remains OPERABLE.For sampling systems, channel OPERABILITY involves more than OPERABILITY of the channel electronics. OPERABILITY may also require corr ect valve lineup s , sample pump operation, and filter motor operation, as well as detector OPERABILITY, if these suppor tingfeatures are necessary for trip to occur under the conditions assumed by the safety analyses.
- 4. Containmen t Isolation
- Phase A Refer to LCO 3.3.2, Function 3.a., for all initiating Functions a nd requirements.
APPLICABILITY The Manual Initiation, Automatic Actuation Logic and Actuation Relays, Containment Isolation
- Phase A, and Containment Radiation Functions are required OPERABLE in MODES 1, 2, 3, and 4, and during movement of [recently] irradiated fuel assemblies
[(i.e., fuel that has occupied part of a critical reactor core within the previous [X] days)] within containment. Under these conditions, the potential exists for an accident that could release significant fission product radioactivity into containment.
Therefore, the containment purge and exhaust isolation instrumentation must be OPERABLE in these MODES. 100 hours0.00116 days <br />0.0278 hours <br />1.653439e-4 weeks <br />3.805e-5 months <br /> Ventilation 3 1ventilation the SI Function is Ventilation Ventilation Ventilation one Safety Injection (SI) 1 2 2 2 4Safety Injection INSERT 2 4 4 and s 2 B 3.3.6 Insert Page B 3.3.6-3 INSERT 2 Since the movement of recently irradiated fuel assemblies in containment can only occur in MODE 6 or with the unit defueled, only one Containment Purge Air Radiation Monitor is required to be OPERABLE during the movement of recently irradiated fuel assemblies in containment.
2 Containment Purge and Exhaust Isolation Instrumentation (Without Setpoint Control Program)
B 3.3.6 A Westinghouse STS B 3.3.6 A-4 Rev. 4.0 1SEQUOYAH UNIT 2 Revision XXX Ventilation 1 2BASES
APPLICABILITY (continued)
While in MODES 5 and 6 without fuel handling in progress, the containment purge and exhaust isolation instrumentation need not be OPERABLE since the potential for radioactive releases is minimized and operator action is sufficient to ensure post accident offsite doses are maintained within the limits of Reference 1.
The Applicability for the containment purge and exhaust isolation on the ESFAS Containment Isolation
-Phase A Functions are specified in LCO 3.3.2. Refer to the Bases for LCO 3.3.2 for discussion of the Containment Isolation
-Phases A Function Applicability.
ACTIONS The most common cause of channel inoperability is outright failure or drift of the bistable or process module sufficient to exceed the tolerance allowed by unit specific calibration procedures. Typically, the drift is found to be small and results in a delay of actuation rather than a total loss of function. This determination is generally made during the performance of a COT, when the process instrumentation is set up for adjustment to bring it within specification. If the Trip Setpoint is less conservative than the tolerance specified by the calibration procedure, the channel must be declared inoperable immediately and the appropriate Condition entered.
A Note has been added to the ACTIONS to clarify the application of Completion Time rules. The Conditions of this Specification may be entered independently for each Function listed in Table 3.3.6-1. The Completion Time(s) of the inoperable channel(s)/train(s) of a Function will be tracked separately for each Function starting from the time the Condition was entered for that Function.
A.1 Condition A applies to the failure of one containment purge isolation radiation monitor channel.
Since the four containment radiation monitors measure different parameters , failure of a single channel may result in loss of the radiation monitoring Function for certain events. Consequently, the failed channel must be restored to OPERABLE status.
The 4 hours4.62963e-5 days <br />0.00111 hours <br />6.613757e-6 weeks <br />1.522e-6 months <br /> allowed to restore the affected channel is justified by the low likelihood of events occurring during this interval, and recognition that one or more of the remaining channel s will respond to most events.
ventilation ventilation 1 1Safety Injection Safety Injection 4 4 2 4 Containment Purge and Exhaust Isolation Instrumentation (Without Setpoint Control Program)
B 3.3.6 A Westinghouse STS B 3.3.6 A-5 Rev. 4.0 1SEQUOYAH UNIT 2 Revision XXX Ventilation 1 2BASES
ACTIONS (continued)
B.1 Condition B applies to all Containment Purge and Exhaust Isolation Functions and addresses the train orientation of the Solid State Protection System (SSPS) and the master and slave relays for these Functions. It also addresses the failure of multiple radiation monitoring channels, or the inability to restore a single failed channel to OPERABLE status in the time allowed for Required Action A.1.
If a train is inoperable
, multiple channels are inoperable, or the Required Action and associated Completion Time of Condition A are not met, operation may continue as long as the Required Action for the applicable Conditions of LCO 3.6.3 is met for each valve made inoperable by failure
of isolation instrumentation.
A Note is added stating that Condition B is only applicable in MODE 1, 2, 3, or 4.
C.1 and C.2 Condition C applies to all Containment Purge and Exhaust Isolation Functions and addresses the train orientation of the SSPS and the master and slave relays for these Functions. It also addresses the failure of
multiple radiation monitoring channels, or the inability to restore a single failed channel to OPERABLE status in the time allowed for Required Action A.1. If a train is inoperable, multiple channels are inoperable, or the Required Action and associated Completion Time of Condition A are not met, operation may continue as long as the Required Action to place and maintain containment purge and exhaust isolation valves in their closed position is met or the applicable Conditions of LCO 3.9.4, "Containment Penetrations," are met for each valve made inoperable by failure of isolation instrumentation. The Completion Time for these Required Actions is Immediately.
A Note states that Condition C is applicable during movement of
[recently] irradiated fuel assemblies within containment.
SURVEILLANCE A Note has been added to the SR Table to clarify that Table 3.3.6-1 REQUIREMENTS determines which SRs apply to which Containment Purge and Exhaust Isolation Functions. VentilationVentilationventilation Ventilation 1 1 1 1 3the single required or the required radiation monitoring channel is 4 A B A or A B B 4 4 4 4 4 4 4 4 Containment Purge and Exhaust Isolation Instrumentation (Without Setpoint Control Program)
B 3.3.6 A Westinghouse STS B 3.3.6 A-6 Rev. 4.0 1SEQUOYAH UNIT 2 Revision XXX Ventilation 1 2BASES
SURVEILLANCE REQUIREMENTS (continued)
Performance of the CHANNEL CHECK ensures that a gross failure of instrumentation has not occurred. A CHANNEL CHECK is normally a comparison of the parameter indicated on one channel to a similar parameter on other channels. It is based on the assumption that instrument channels monitoring the same parameter should read approximately the same value. Significant deviations between the two instrument channels could be an indication of excessive instrument drift in one of the channels or of something even more serious. A CHANNEL CHECK will detect gross channel failure; thus, it is key to verifying the instrumentation continues to operate properly between each CHANNEL CALIBRATION.
Agreement criteria are determined by the unit staff, based on a combination of the channel instrument uncertainties, including indication and readability. If a channel is outside the criteria, it may be an indication that the sensor or the signal processing equipment has drifted outside its limit.
[ The Frequency of 12 months is based on operating experience that demonstrates channel failure is rare. The CHANNEL CHECK supplements less formal, but more frequent, checks of channels during normal operational use of the displays associated with the LCO required channels.
OR The Surveillance Frequency is controlled under the Surveillance Frequency Control Program.
REVIEWER'S NOTE-----------------------------------
Plants controlling Surveillance Frequencies under a Surveillance Frequency Control Program should utilize the appropriate Frequency description, given above, and the appropriate choice of Frequency in the Surveillance Requirement.
]
5 6 Containment Purge and Exhaust Isolation Instrumentation (Without Setpoint Control Program)
B 3.3.6 A Westinghouse STS B 3.3.6 A-7 Rev. 4.0 1SEQUOYAH UNIT 2 Revision XXX Ventilation 1 2BASES
SURVEILLANCE REQUIREMENTS (continued)
SR 3.3.6.2 SR 3.3.6.2 is the performance of an ACTUATION LOGIC TEST. The train being tested is placed in the bypass condition, thus preventing inadvertent actuation. Through the semiautomatic tester, all possible logic combinations, with and without applicable permissives, are tested for each protection function. In addition, the master relay coil is pulse tested for continuity. This verifies that the logic modules are OPERABLE and there is an intact voltage signal path to the master relay coils. [
This test is performed every 31 days on a STAGGE RED TEST BASIS. The Surveillance interval is acceptable based on instrument reliability and industry operating experience.
OR The Surveillance Frequency is controlled under the Surveillance Frequency Control Program.
REVIEWER'S NOTE-----------------------------------
Plants controlling Surveillance Frequencies under a Surveillance Frequency Control Program should utilize the appropriate Frequency description, given above, and the appropriate choice of Frequency in the Surveillance Requirement.
]
SR 3.3.6.3 SR 3.3.6.3 is the performance of a MASTER RELAY TEST. The MASTER RELAY TEST is the energizing of the master rela y, verifying contact operation and a low voltage continuity check of the slave relay coil. Upon master relay contact operation, a low voltage is injected to the slave relay coil. This voltage is insufficient to pick up the slave relay, but large enough to demonstrate signal path continuity.
[ This test is performed every 31 days on a STAGGERED TEST BASIS. The Surveillance interval is acceptable based on instrument reliability and industry operating experience.
OR The Surveillance Frequency is controlled under the Surveillance Frequency Control Program.
4 4 Containment Purge and Exhaust Isolation Instrumentation (Without Setpoint Control Program)
B 3.3.6 A Westinghouse STS B 3.3.6 A-8 Rev. 4.0 1SEQUOYAH UNIT 2 Revision XXX Ventilation 1 2BASES
SURVEILLANCE REQUIREMENTS (continued)
REVIEWER'S NOTE-----------------------------------
Plants controlling Surveillance Frequencies under a Surveillance Frequency Control Program should utilize the appropriate Frequency description, given above, and the appropriate choice of Frequency in the Surveillance Requirement.
]
[ SR 3.3.6.
4 SR 3.3.6.4 is the performance of an ACTUATION LOGIC TEST. The train being tested is placed in the bypass condition, thus preventing inadvertent actuation. Through the semiautomatic tester, all possible logic combinations, with and without applicable permissives, are tested for each protection function. In addition, the master relay coil is pulse tested for continuity. This verifies that the logic modules are OPERABLE and there is an intact voltage signal path to the master relay coils.
[ This test is performed every 92 days on a STAGGERED TEST BASIS. The Surveillance interval is justified in Reference 2.
OR The Surveillance Frequency is controlled under the Surveillance Frequency Control Program.
REVIEWER'S NOTE-----------------------------------
Plants controlling Surveillance Frequencies under a Surveillance Frequency Control Program should utilize the appropriate Frequency description, given above, and the appropriate choice of Frequency in the Surveillance Requirement.
]
The SR is modified by a Note stating that the Surveillance is only applicable to the actuation logic of the ESFAS Instrumentation.
] [ SR 3.3.6.
5 SR 3.3.6.5 is the performance of a MASTER RELAY TEST. The MASTER RELAY TEST is the energizing of the master relay, verifying contact operation and a low voltage continuity check of the slave relay coil. Upon master relay contact operation, a low voltage is injected to the slave relay coil. This voltage is insufficient to pick up the slave relay, but
2 2 3 3 6 4 5 6 4 3 3 Containment Purge and Exhaust Isolation Instrumentation (Without Setpoint Control Program)
B 3.3.6 A Westinghouse STS B 3.3.6 A-9 Rev. 4.0 1SEQUOYAH UNIT 2 Revision XXX Ventilation 1 2BASES SURVEILLANCE REQUIREMENTS (continued) large enough to demonstrate signal path continuity.
[ This test is performed every 92 days on a STAGGERED TEST BASIS. The Surveillance interval is justified in Reference 2.
OR The Surveillance Frequency is controlled under the Surveillance Frequency Control Program.
REVIEWER'S NOTE-----------------------------------
Plants controlling Surveillance Frequencies under a Surveillance Frequency Control Program should utilize the appropriate Frequency description, given above, and the appropriate choice of Frequency in the Surveillance Requirement.
] The SR is modified by a Note stating that the Surveillance is only applicable to the master relays of the EFAS Instrumentation.
] SR 3.3.6.
6 A COT is performed on each required channel to ensure the entire channel will perform the intended Function. A successful test of the required contact(s) of a channel relay may be performed by the verification of the change of state of a single contact of the relay. This clarifies what is an acceptable COT of a relay. This is acceptable because all of the other required contacts of the relay are verified by other Technical Specifications and non-Technical Specifications tests at least once per refueling interval with applicable extensions.
[ The Frequency of 92 days is based on the staff recommendation for increasing the availability of radiation monitors according to NUREG
-1366 (Ref.
3). OR The Surveillance Frequency is controlled under the Surveillance Frequency Control Program. -----------------------------------REVIEWER'S NOTE-----------------------------------
Plants controlling Surveillance Frequencies under a Surveillance Frequency Control Program should utilize the appropriate Frequency description, given above, and the appropriate choice of Frequency in the Surveillance Requirement.
] 4 5 6 3 4 5 6 Containment Purge and Exhaust Isolation Instrumentation (Without Setpoint Control Program)
B 3.3.6 A Westinghouse STS B 3.3.6 A-10 Rev. 4.0 1SEQUOYAH UNIT 2 Revision XXX Ventilation 1 2BASES
SURVEILLANCE REQUIREMENTS (continued)
This test verifies the capability of the instrumentation to provide the containment purge and exhaust system isolation. There is a plant specific program which verifies that the instrument channel functions as required by verifying the as-left and as-found setting are consistent with
those established by the setpoint methodology.
7 SR 3.3.6.7 is the performance of a SLAVE RELAY TEST. The SLAVE RELAY TEST is the energizing of the slave relays. Contact operation is verified in one of two ways. Actuation equipment that may be operated in the design mitigation mode is either allowed to function or is placed in a condition where the relay contact operation can be verified without operation of the equipment. Actuation equipment that may not be operated in the design mitigation mode is prevented from operation by the SLAVE RELAY TEST circuit. For this latter case, contact operation is verified by a continuity check of the circuit containing the slave relay.
[ The Frequency of 92 days is acceptable based on instrument reliability and industry operating experience.
OR The Surveillance Frequency is controlled under the Surveillance Frequency Control Program.
REVIEWER'S NOTE-----------------------------------
Plants controlling Surveillance Frequencies under a Surveillance Frequency Control Program should utilize the appropriate Frequency description, given above, and the appropriate choice of Frequency in the Surveillance Requirement.
] SR 3.3.6.
8 SR 3.3.6.8 is the performance of a TADOT. This test is a check of the Manual Actuation Functions. Each Manual Actuation Function is tested up to, and including, the master relay coils. A successful test of the required contact(s) of a channel relay may be performed by the verification of the change of state of a single contact of the relay. This
5 5 6 6 1 4 5 6 4ventilation Containment Purge and Exhaust Isolation Instrumentation B 3.3.6 A Westinghouse STS B 3.3.6 A-11 Rev. 4.0, SEQUOYAH UNIT 2 Revision XXX 1 2 1VentilationBASES
SURVEILLANCE REQUIREMENTS (continued)
clarifies what is an acceptable TADOT of a relay. This is acceptable because all of the other required contacts of the relay are verified by other Technical Specifications and non-Technical Specifications tests at least once per refueling interval with applicable extensions. In some instances, the test includes actuation of the end device (i.e., pump starts, valve cycles, etc.).
The test also includes trip devices that provide actuation signals directly to the SSPS, bypassing the analog process control equipment.
The SR is modified by a Note that excludes verification of setpoints during the TADOT. The Functions tested have no setpoints associated with them.
[ The Frequency of 18 months is based on the known reliability of the Function and the redundancy available, and has been shown to be acceptable through operating experience.
OR The Surveillance Frequency is controlled under the Surveillance Frequency Control Program.
REVIEWER'S NOTE-----------------------------------
Plants controlling Surveillance Frequencies under a Surveillance Frequency Control Program should utilize the appropriate Frequency description, given above, and the appropriate choice of Frequency in the Surveillance Requirement.
] SR 3.3.6.
9 CHANNEL CALIBRATION is a complete check of the instrument loop, including the sensor. The test verifies that the channel responds to a measured parameter within the necessary range and accuracy. There is a plant specific program which verifies that the instrument channel functions as required by verifying the as-left and as-found setting are consistent with those established by the setpoint methodology.
[ The Frequency of 18 months is based on operating experience and is consistent with the typical industry refueling cycle.
OR 7 5 6 4 5 2 Containment Purge and Exhaust Isolation Instrumentation B 3.3.6 A Westinghouse STS B 3.3.6 A-12 Rev. 4.0 2 1Revision XXXSEQUOYAH UNIT 2 1VentilationBASES
SURVEILLANCE REQUIREMENTS (continued)
The Surveillance Frequency is controlled under the Surveillance Frequency Control Program.
REVIEWER'S NOTE-----------------------------------
Plants controlling Surveillance Frequencies under a Surveillance Frequency Control Program should utilize the appropriate Frequency description, given above, and the appropriate choice of Frequency in the Surveillance Requirement.
]
REFERENCES 1. 10 CFR 100.11.
- 2. WCAP-15376, Rev. 0, October 2000.
- 3. NUREG-1366, [date].
6 2 2UFSAR Table 7.3.1-4 WCAP-14036-P-A, Revision 1, "Elimination of Periodic Protection Channel Response Time Tests," December 1995 INSERT 3 2 B 3.3.6 Insert Page B 3.3.6-12 INSERT 3 SR 3.3.6.8 This SR ensures the individual channel response times are less than or equal to the maximum values assumed in the accident analysis.
Response Time testing acceptance criteria are included in the Updated Final Safety Analysis Report, Table 7.3.1-4 (Ref. 2). Individual component response times are not modeled in the analyses. The analyses model the overall or total elapsed time, from the point at which the parameter exceeds the Trip Setpoint value to the point at which the equipment in both trains reaches the required functional state (e.g.,
valves in full open or closed position).
Response time may be verified by actual response time tests in any series of sequential, overlapping or total channel measurements, or by the summation of allocated signal processing and actuation logic response times with actual response time tests on the remainder of the channel.
WCAP-14036-P, Revision 1, "Elimination of Periodic Protection Channel Response Time Tests," (Ref. 3) provides the basis and methodology for using allocated signal processing and actuation logic response times in the overall verification of the protection system channel response time. The allocations for signal conditioning and actuation logic response times must be verified prior to placing the component in operational service and re-verified following maintenance that may adversely affect response
time. In general, electrical repair work does not impact response time provided the parts used for repair are of the same type and value. Specific components identified in the WCAP may be replaced without verification testing.
The Surveillance Frequency is controlled under the Surveillance Frequency Control Program.
SR 3.3.6.8 is modified by a Note stating that radiation detectors are excluded from response time testing.
2 JUSTIFICATION FOR DEVIATIONS ITS 3.3.6 BASES, CONTAINMENT VENTILATION ISOLATION INSTRUMENTATION Sequoyah Unit 1 and Unit 2 Page 1 of 1 1. The type of Setpoint Control Program (Without Setpoint Control Program) and the Specification designator "A" are deleted since they are unnecessary. This information is provided in NUREG 1431, Rev. 4.0 to assist in identifying the appropriate Specification to be used as a model for the plant specific ITS conversion, but serves no purpose in the plant specific implementation. In addition, ISTS B 3.3.6B (with Setpoint Control Program Specification) is not used and is not shown. Furthermore, the title of the Specification has been changed from "Containment Purge and Exhaust Isolation Instrumentation" to " Containment Ventilation Isolation Instrumentation" since Sequoyah Nuclear Plant (SQN) does not have a Containment Purge and Exhaust Isolation Instrumentation.
- 2. Changes are made (additions, deletions, and/or changes) to the ISTS Bases that reflect the plant specific nomenclature, number, reference, system description, analysis, or licensing basis description.
- 3. The ISTS contains bracketed information and/or values that are generic to Westinghouse vintage plants. The brackets are removed and the proper plant specific information/value is inserted to reflect the current licensing basis.
- 4. Changes are made to be consistent with changes made to the Specification.
- 5. ISTS SR 3.3.6.1, SR 3.3.6.4, SR 3.3.6.5, SR 3.3.6.6, SR 3.3.6.7, SR 3.3.6.8 and SR 3.3.6.9 (ITS SR 3.3.6.1, SR 3.3.6.2, SR 3.3.6.3, SR 3.3.6.4, SR 3.3.6.5, SR 3.3.6.6, and SR 3.3.6.7, respectively) provide two options for controlling the Frequencies of Surveillance Requirements. SQN is proposing to control the Surveillance Frequencies under the Surveillance Frequency Control Program.
- 6. The Reviewer's Note has been deleted. This information is for the NRC reviewer to be keyed into what is needed to meet this requirement. This Note is not meant to be retained in the final version of the plant specific submittal.
Specific No Significant Haza rds Considerations (NSHCs)
DETERMINATION OF NO SIGNIFICANT HAZARDS CONSIDERATIONS ITS 3.3.6, CONTAINMENT VENTILATION ISOLATION INSTRUMENTATION Sequoyah Unit 1 and 2 Page 1 of 1 There are no specific No Significant Hazards Considerations for this Specification.
ATTACHMENT 7 ITS 3.3.7, CONTROL ROOM EMERGENCY VENTILATION SYSTEM (CREVS) ACTUATION INSTRUMENTATION
Current Technical Specification (CTS) Markup and Discussion of Changes (DOCs)
A01ITS ITS 3.3.7 3/4.3.3 MONITORING INSTRUMENTATION RADIATION MONITORING INSTRUMENTATION LIMITING CONDITION FOR OPERATION 3.3.3.1 The radiation monitoring instrumentation channels shown in Table 3.3-6 shall be OPERABLE with their alarm/trip setpoints within the specified limits.
APPLICABILITY: As shown in Table 3.3-6.
ACTION: a. With a radiation monitoring channel alarm/trip setpoint exceeding the value shown in Table 3.3-6, adjust the setpoint to within the limit within 4 hours4.62963e-5 days <br />0.00111 hours <br />6.613757e-6 weeks <br />1.522e-6 months <br /> or declare the channel inoperable.
- b. With one or more radiation monitoring channels inoperable, take the ACTION shown in Table 3.3-6.
- c. The provisions of Specification 3.0.3 are not applicable.
SURVEILLANCE REQUIREMENTS 4.3.3.1 Each radiation monitoring instrumentation channel shall be demonstrated OPERABLE by the performance of the CHANNEL CHECK, CHANNEL CALIBRATION and CHANNEL FUNCTIONAL TEST operations for the MODES and at the frequencies shown in Table 4.3-3.
April 11, 2005 SEQUOYAH - UNIT 1 3/4 3-39 Amendment No. 301 CONTROL ROOM EMERGENCY VENTILATION (CREVS) ACTUATION A02CREVS actuation A02 M01CREVS actuation instrumentation A02 M02CREVS actuation A02CHANNEL OPERATIONAL TEST (COT)
M03LCO 3.3.7 Applicabilit y SR Table Note ACTION A, ACTION B, ACTION C, ACTION D, ACTION E Add proposed ACTIONS Note A03 Page 1 of 8 A01ITS ITS 3.3.7 TABLE 3.3-6 RADIATION MONITORING INSTRUMENTATION INSTRUMENT MINIMUM CHANNELS OPERABLE APPLICABLE MODES ALARM/TRIP SETPOINT MEASUREMENT RANGE ACTION 1.AREA MONI TOR a.Fuel Storag e Pool Area 1* 151 mR/hr 10 10 4 mR/hr 26 2.PROCESS MONITORSa.Contai nment Purge Air 1 1, 2, 3, 4 & 6 8.5x 10-3µCi/cc 10 - 10 7 cpm28 b.Contai nmenti.Deletedii.ParticulateActivity RCS Leakag e Dete ction 1 1, 2, 3 & 4 N/A 10 - 10 7 cpm 27 c.Control Room Isolation 2 ALL MODES and du ring movement of irradiated fuel assemblies 400 cpm**
10 - 10 7 cpm 29 _______________________________ *With fuel in the storage pool or building
- Equivalent to 1.0 x 10
-5 µCi/cc.December 04, 2008 SEQUOYAH - UNIT 1 3/4 3-40 Amendment Nos. 12, 60, 112, 168, 256, 310, 322 See ITS 3.3.8 See ITS 3.3.6 See ITS 3.4.15 See ITS 3.3.8 CONTROL ROOM EMERGENCY VENTILATION (CREVS) ACTUATION A02 LA01 LA01 M04Function 3 Footnote (b)
Page 2 of 8 Add proposed Table 3.3.7-1 Function 1 Table 3.3.7-1 M06Add proposed Table 3.3.7-1 Function 4 M05Add proposed Table 3.3.7-1 Function 2 A01ITS ITS 3.3.7 TABLE 3.3-6 (Continued)
ACTION STATEMENTS ACTION 26 - With the number of OPERABLE channels less than required by the Minimum Channels OPERABLE requirement, perform area surveys of the monitored area with portable monitoring instrumentation at least once per 24 hours2.777778e-4 days <br />0.00667 hours <br />3.968254e-5 weeks <br />9.132e-6 months <br />. ACTION 27 - With the number of OPERABLE channels less than required by the Minimum Channels OPERABLE requirement, comply with the ACTION requirements of Specification 3.4.6.1. ACTION 28 - With the number of OPERABLE channels less than required by the Minimum Channels OPERABLE requirement, comply with the ACTION requirements of Specification 3.9.9 (MODE 6) and 3.3.2.1 (MODES 1, 2, 3, and 4). ACTION 29 -
a.With one channel inoperable, place the associated control room emergenc y ventilation system (CREVS) train in recirculation mode of operation within 7 day s or be at least HOT STANDBY within the next 6 hours6.944444e-5 days <br />0.00167 hours <br />9.920635e-6 weeks <br />2.283e-6 months <br /> and in COLD SHUTDO WN within the following 30 hours3.472222e-4 days <br />0.00833 hours <br />4.960317e-5 weeks <br />1.1415e-5 months <br />.
- b. With two channels inoperable, within 1 hour1.157407e-5 days <br />2.777778e-4 hours <br />1.653439e-6 weeks <br />3.805e-7 months <br /> initiate and maintain operation of oneCREVS train in the recirculation mode of operation and ent er the required Actions for one CREVS train made inoperable by inoperabl e CREVS actuation instru mentati on.Orplace both trains in the recirculation mode of operation within one hour
.If the completion time of Action 29b cannot be met in Mode s 1, 2, 3, and 4, be in at least HOT STANDBY within the next 6 hours6.944444e-5 days <br />0.00167 hours <br />9.920635e-6 weeks <br />2.283e-6 months <br /> and in COLD SHUTDOWN withinthe following 30 hours3.472222e-4 days <br />0.00833 hours <br />4.960317e-5 weeks <br />1.1415e-5 months <br />.If the completion time of Action 29b cannot be met during the move ment of irradiated fuel assemblies, suspend core alterations and suspend movement of irradiated fuel assemblies.If the completion time of Action 29b cannot be met in Modes 5 and 6, initiate action to restore one CRE VS train.May 31, 2000 SEQUOYAH - UNIT 1 3/4 3-41 Amendment No. 12, 112, 168, 256 See ITS 3.3.8 See ITS 3.3.6 See ITS 3.4.15 ACTION A ACTION C ACTION B ACTION C ACTION D ACTION E Add proposed ACTIONS D and E M07 L02Add proposed Required Actions for Table 3.3.7-1 Function 1 M04Page 9 of 22 Page 3 of 8 L01 Immediately L01Immediately A01ITS ITS 3.3.7 TABLE 4.3-3 RADIATION MONITORING INSTRUMENTATION SURVEILLANCE REQUIREMENTS
INSTRUMENT CHANNELCHECK CHANNEL CALIBRATION CHANNEL FUNCTIONAL TEST MODES FOR WHICH SURVEILLANCE REQUIRED
- 1. AREA MONITOR
- a. Fuel Storage Pool Area S R Q
- 2. PROCESS MONITORS
- a. Containment Purge Air Exhaust S
R
Q
1, 2, 3, 4 & 6
- b. Containment
- i. Deleted ii. Particulate Activity RCS Leakage Detection
S R Q 1, 2, 3, & 4
- c. Control Room Isolation S R Q ALL MODES
______________________ *With fuel in the storage pool or building.
December 04, 2008 SEQUOYAH - UNIT 1 3/4 3-42 Amendment Nos. 12, 112,168, 220, 322 COT M03 LA02 See ITS 3.3.8 See ITS 3.3.6 See ITS 3.4.15 Add proposed SR 3.3.7.6 for Table 3.3.7-1 Function 1 at a Frequency of 18 months M04 See ITS 3.3.8 SR 3.3.7.1SR 3.3.7.2 SR 3.3.7.7Table 3.3.7-1 Function 3 CONTROL ROOM EMERGENCY VENTILATION (CREVS) ACTUATION A02In accordance with the Surveillance Frequency Control Program Add proposed SR 3.3.7.3 for Table 3.3.7-1 Function 2 at a Frequency of 92 days on a STAGGERED TEST BASIS M05Add proposed SR 3.3.7.4 for Table 3.3.7-1 Function 2 at a Frequency of 92 days on a STAGGERED TEST BASIS M05 LA02Add proposed SR 3.3.7.5 for Table 3.3.7-1 Function 2 at a Frequency of 92 days M05In accordance with the Surveillance Frequency Control Program LA02In accordance with the Surveillance Frequency Control Pro gram Page 4 of 8 A01ITS ITS 3.3.7 INSTRUMENTATION 3/4.3.3 MONITORING INSTRUMENTATION RADIATION MONITORING INSTRUMENTATION LIMITING CONDITION FOR OPERATION
3.3.3.1 The radiation monitoring instrumentation channels shown in Table 3.3-6 shall be OPERABLE with their alarm/trip setpoints within the specified limits.
APPLICABILITY: As shown in Table 3.3-6.
ACTION:
- a. With a radiation monitoring channel alarm/trip setpoint exceeding the value shown in Table 3.3-6, adjust the setpoint to within the limit wi thin 4 hours4.62963e-5 days <br />0.00111 hours <br />6.613757e-6 weeks <br />1.522e-6 months <br /> or declare the channel inoperable.
- b. With one or more radiation monitoring channels inoperable, take the ACTION shown in Table 3.3-6.
- c. The provisions of Specification 3.0.3 are not applicable.
SURVEILLANCE REQUIREMENTS 4.3.3.1 Each radiation monitoring instrumentation channel shall be demonstrated OPERABLE by the performance of the CHANNEL CHECK, CHANNEL CALIBRATION and CHANNEL FUNCTIONAL TEST operations for the MODES and at the frequencies shown in Table 4.3-3.
April 11, 2005 SEQUOYAH - UNIT 2 3/4 3-40 Amendment No. 290 LCO 3.3.7 Applicabilit y SR Table Note ACTION A, ACTION B, ACTION C, ACTION D, ACTION E CONTROL ROOM EMERGENCY VENTILATION (CREVS) ACTUATION A02CREVS actuation A02Add proposed ACTIONS Note A03CREVS actuation instrumentation A02 M02CREVS actuation A02CHANNEL OPERATIONAL TEST (COT)
M03 Page 5 of 8 M01 A01ITS ITS 3.3.7 TABLE 3.3-6 RADIATION MONITORING INSTRUMENTATION INSTRUMENT MINIMUM CHANNELS OPERABLE APPLICABLE MODES ALARM/TRIP SETPOINT MEASUREMENT RANGE ACTION 1. AREA MONI TOR a.Fuel Storag e Pool 1
- 151 mR/hr 10 10 4 mR/hr 26 Area 2. PROCESS MONITORSa.Contai nment Purge Air 1 1, 2, 3, 4 & 6 8.5 x 10-3µCi/cc 10 - 10 7 cpm 28 b. Containment
- i. Deletedii.ParticulateActivityRCS Leakag e Dete ction 1 1, 2, 3 & 4 N/A 10 - 10 7 cpm 27 c.Control Room Isolation2 ALL MODES and during movement of irradiated fuel assemblies 400 cpm**
10 - 10 7 cpm 29 _______________________________
- With fuel in the storage pool or building** Equivalent to 1.0 x 10
-5 µCi/cc. December 04, 2008 SEQUOYAH - UNIT 2 3/4 3-41 Amendment Nos. 52, 102, 158, 247, 299, 314 Footnote (b)
See ITS 3.3.8 See ITS 3.3.6 See ITS 3.4.15 CONTROL ROOM EMERGENCY VENTILATION (CREVS) ACTUATION A02 LA01 See ITS 3.3.8 Add proposed Table 3.3.7-1 Function 1 M04 Page 6 of 8 LA01Function 3 Table 3.3.7-1 M06Add proposed Table 3.3.7-1 Function 4 M05Add proposed Table 3.3.7-1 Function 2 A01ITS ITS 3.3.7 TABLE 3.3-6 (Continued)
ACTION STATEMENTS ACTION 26 - With the number of OPERABLE channels less than required by the Minimum Channels OPERABLE requirement, perform area surveys of the monitored area with portable monitoring instrumentation at least once per 24 hours2.777778e-4 days <br />0.00667 hours <br />3.968254e-5 weeks <br />9.132e-6 months <br />. ACTION 27 - With the number of OPERABLE channels less than required by the Minimum Channels OPERABLE requirement, comply with the ACTION requirements of Specification 3.4.6.1. ACTION 28 - With the number of OPERABLE channels less than required by the Minimum Channels OPERABLE requirement, comply with the ACTION requirements of Specification 3.9.9 (MODE 6) and 3.3.2 (MODES 1, 2, 3, and 4). ACTION 29 -
a.With one channel inoperable, place the associated control room emergenc y ventilation system (CREVS) train in recirculation mode of operation within 7 day s or be at least HOT STANDBY within the next 6 hours6.944444e-5 days <br />0.00167 hours <br />9.920635e-6 weeks <br />2.283e-6 months <br /> and in COLD SHUTDO WN within the following 30 hours3.472222e-4 days <br />0.00833 hours <br />4.960317e-5 weeks <br />1.1415e-5 months <br />.
- b. With two channels inoperable, within 1 hour1.157407e-5 days <br />2.777778e-4 hours <br />1.653439e-6 weeks <br />3.805e-7 months <br /> initiate and maintain operation of oneCREVS train in the recirculation mode of operation and ent er the required Actions for one CREVS train made inoperable by inoperabl e CREVS actuation instru mentati on.Orplace both trains in the recirculation mode of operation within one hour
.If the completion time of Action 29b cannot be met in Mode s 1, 2, 3, and 4, be in at least HOT STANDBY within the next 6 hours6.944444e-5 days <br />0.00167 hours <br />9.920635e-6 weeks <br />2.283e-6 months <br /> and in COLD SHUTDOWN withinthe following 30 hours3.472222e-4 days <br />0.00833 hours <br />4.960317e-5 weeks <br />1.1415e-5 months <br />.If the completion time of Action 29b cannot be met during the move ment of irradiated fuel assemblies, suspend core alterations and suspend movement of irradiated fuel assemblies.If the completion time of Action 29b cannot be met in Modes 5 and 6, initiate action to restore one CRE VS train.May 31, 2000 SEQUOYAH - UNIT 2 3/4 3-42 Amendment Nos. 102, 158, 247 See ITS 3.3.8 See ITS 3.3.6 See ITS 3.4.15 ACTION A ACTION C ACTION B ACTION C ACTION D ACTION E M07Add proposed ACTIONS D and E L02Add proposed Required Actions for Table 3.3.7-1 Function 1 M04 Page 7 of 8 L01 Immediately L01Immediately A01ITS ITS 3.3.7 TABLE 4.3-3 RADIATION MONITORING INSTRUMENTATION SURVEILLANCE REQUIREMENTS INSTRUMENT CHANNEL CHECK CHANNEL CALIBRATION CHANNEL FUNCTIONAL TEST MODES FOR WHICH SURVEILLANCE IS REQUIRED 1. AREA MONITOR
- a. Fuel Storage Pool Area S R Q
- 2. PROCESS MONITORS
- a. Containment Purge Air Exhaust S R Q 1, 2, 3, 4 & 6
- b. Containment
- i. Deleted ii. Particulate Activity RCS Leakage Detection S R Q 1, 2, 3 & 4
- c. Control Room Isolation S R Q ALL MODES
______________________
- With fuel in the storage pool or building.
December 04, 2008 SEQUOYAH - UNIT 2 3/4 3-43 Amendment Nos. 102, 158, 210, 314 See ITS 3.3.8 See ITS 3.3.6 See ITS 3.4.15 See ITS 3.3.8 CONTROL ROOM EMERGENCY VENTILATION (CREVS) ACTUATION A02 M03 COT LA02SR 3.3.7.1SR 3.3.7.2 SR 3.3.7.7 Page 8 of 8 Function 3 Table 3.3.7-1 Add proposed SR 3.3.7.6 for Table 3.3.7-1 Function 1 at a Frequency of 18 months M04In accordance with the Surveillance Frequency Control Program Add proposed SR 3.3.7.3 for Table 3.3.7-1 Function 2 at a Frequency of 92 days on a STAGGERED TEST BASIS M05Add proposed SR 3.3.7.4 for Table 3.3.7-1 Function 2 at a Frequency of 92 days on a STAGGERED TEST BASIS M05 LA02In accordance with the Surveillance Frequency Control Pro gram Add proposed SR 3.3.7.5 for Table 3.3.7-1 Function 2 at a Frequency of 92 days M05In accordance with the Surveillance Frequency Control Program LA02 DISCUSSION OF CHANGES ITS 3.3.7, CONTROL ROOM EMERGENCY VENTILATION SYSTEM (CREVS) ACTUATION INSTRUMENTATION Sequoyah Unit 1 and Unit 2 Page 1 of 7 ADMINISTRATIVE CHANGES A01 In the conversion of the Sequoyah Nuclear Plant (SQN) Current Technical Specifications (CTS) to the plant specific Improved Technical Specifications (ITS), certain changes (wording preferences, editorial changes, reformatting, revised numbering, etc.) are made to obtain consistency with NUREG-1431, Rev. 4.0, "Standard Technical Specifications-Westinghouse Plants" (ISTS) and additional Technical Specification Task Force (TSTF) travelers included in this
submittal. These changes are designated as administrative changes and are acceptable because they do not result in technical changes to the CTS. A02 CTS 3.3.3.1 requires, in part, the radiation monitoring instrumentation channels shown in Table 3.3-6 to be OPERABLE. CTS 3.3.3.1 ACTIONS a and b provide the Required Actions and associated Completion Time for when the radiation monitoring instrumentation is inoperable. CTS 4.3.3.1 requires, in part, that each radiation monitoring instrumentation channel be demonstrated OPERABLE. CTS Table 3.3-6 lists the instruments required to be OPERABLE, the Applicable MODES, and the appropriate ACTIONS to take for the Radiation Monitoring Instrumentation. ITS LCO 3.3.7 requires, in part, that the Control Room Emergency Ventilation System (CREVS) actuation instrumentation for each Function in Table 3.3.7-1 to be OPERABLE. ITS 3.3.7 ACTIONS A, B, C, D, and E provide the Required Actions and associated Completion Time for when the CREVS actuation instrumentation is inoperable. ITS SR 3.3.7.1, SR 3.3.7.2, SR 3.3.7.3, SR 3.3.7.4, SR 3.3.7.5, SR 3.3.7.6, and SR 3.3.7.7 provide the testing requirements for each CREVS actuation instrument in Table 3.3.7-1. This changes the CTS by having a separate Specification for the CREVS actuation instrumentation, in lieu of including them in the Radiation Monitoring Instrumentation Specification. This change is acceptable because the technical requirements for the radiation monitoring instrumentation are maintained with the change in format. The CREVS Actuation Instrumentation continues to require the OPERABILITY of the radiation monitoring instrumentation. This change is designated as administrative because it does not result in a technical change to the CTS. A03 The ACTIONS for CTS 3.3.3.1 do not contain a specific Note that allows separate Condition entry for each instrument. ITS 3.3.7 ACTIONS contains a Note which states that separate Condition entry is allowed for each Function.
This changes the CTS by specifically allowing separate Condition entry for each specified Function. This change is acceptable because it clearly states the current requirement. The CTS considers each radiation monitoring instrument Function to be separate and independent. This change is designated as administrative because it does not result in a technical change to the CTS.
INSERT 1 A04 CTS 3.3.3.1 requires, i n part, the Radiati on Monitoring Instrumentati on shown in Table 3.3-6 t o be OPERABLE during Applicable Modes.
CTS Table 3.3-6, I nstrument 2.c, Process M onitors, C ontrol R oom Isolation, i s required OPERABLE dur ing ALL MODES and during t he movement o f i rradiat ed fuel as semblies. ITS LC O 3.3.7 r equires, i n par t, that t he C ontrol R oom E mergency V entilation System actuation instrumentati on for eac h Func tion i n Table 3.3.7
-1 be OPERABLE dur ing A pplicabl e Modes or Other S pecified Condition s. ITS T able 3.3.7-1 , Func tion 3.a, C ontrol R oom R adiation, C ontrol R oom A ir Intakes, i s r equired OPERABLE i n Modes 1, 2, 3, 4, 5, 6, and (a), where Footnote (a) s tates, "During movement o f i rradiat ed fuel as s emblies, D uring CORE A LTERATIONS."
This c hang es the CTS b y s pecifying the Process Monitors, C ontrol R oom I solati on required OPERABLE during C ORE ALTERATIONS.
This change is a cceptable because CORE A LTERATIONS c an onl y be performed i n MODE 6. CTS 3.3.3.1 requires t he P rocess M onitors, C ontrol R oom I solation, to be OPERABLE in M ODE 6. This c hange i s des ignated as ad ministrative because it doe s not result i n a technical c hange t o t he C TS. Enclosure 2, Volume 8, Rev. , Page 977 of 1148 Enclosure 2, Volume 8, Rev. , Page 977 of 1148 DISCUSSION OF CHANGES ITS 3.3.7, CONTROL ROOM EMERGENCY VENTILATION SYSTEM (CREVS) ACTUATION INSTRUMENTATION Sequoyah Unit 1 and Unit 2 Page 2 of 7 MORE RESTRICTIVE CHANGES M01 CTS 3.3.3.1 ACTION a requires that when a radiation monitor channel alarm/trip setpoint exceeds the value shown in Table 3.3-6, to adjust the setpoint within 4 hours4.62963e-5 days <br />0.00111 hours <br />6.613757e-6 weeks <br />1.522e-6 months <br /> or declare the channel inoperable. ITS 3.3.7 does not contain an ACTION for adjusting a setpoint that exceeds the required valued. Instead, ITS 3.3.7 ACTION A requires that when one required radiation monitoring channel is inoperable (i.e., setpoint not within tolerance) to enter the applicable Required Actions immediately. This changes the CTS by not allowing adjustment of the setpoint in 4 hours4.62963e-5 days <br />0.00111 hours <br />6.613757e-6 weeks <br />1.522e-6 months <br /> before declaring the channel inoperable.
The purpose of CTS 3.3.3.1 ACTION a is to allow adjustment of the radiation monitor setpoint to within limits before declaring the channel inoperable.
Although ITS does not include this allowance, restoration such that the LCO is met, is always an option. This change is acceptable because the channel requirements in ITS 3.3.7 will ensure that the required radiation monitoring channel is OPERABLE. The proposed ITS ACTION for when one channel is inoperable will ensure that the Required Actions and Completion Times used establish remedial measures that when taken minimize risk associated with continued operation. This change is designated as more restrictive because more stringent Required Actions and Completion Times are being applied in the ITS than were applied in the CTS.
M02 CTS 3.3.3.1 ACTION c states that the provisions of Specification 3.0.3 are not applicable for the radiation monitoring instrumentation in CTS Table 3.3-6.
ITS 3.3.7 does not contain this exception. This changes the CTS by not allowing an exception to CTS Specification 3.0.3.
CTS 3.0.3 requires the unit to be shut down when the requirements of the LCO and the associated ACTIONS are not satisfied. This change is acceptable because ITS 3.3.7 does not provide an exception to LCO 3.0.3 for the radiation monitoring instrumentation used for control room isolation. Eliminating the CTS 3.0.3 exemption ensures that the operators are provided guidance regarding actions to take in the event the required radiation monitoring instrumentation is inoperable and the associated ACTIONS are not satisfied within the required time periods. This change is designated as more restrictive because an explicit
exception provided in the CTS is eliminated.
M03 CTS 4.3.3.1 requires, in part, that the radiation monitoring instrumentation on Table 4.3-3 be demonstrated OPERABLE by performance of a CHANNEL FUNCTIONAL TEST. CTS Table 4.3-3 Instrument 2.c (Process Monitors -
Control Room Isolation) requires a CHANNEL FUNCTIONAL TEST.
ITS Table 3.3.7-1 Function 3 (Control Room Radiation - Control Room Air Intakes) requires the performance of ITS SR 3.3.7.2. ITS SR 3.3.7.2 requires the performance of a CHANNEL OPERATIONAL TEST (COT). This changes the CTS by requiring a COT instead of a CHANNEL FUNCTIONAL TEST.
This change is acceptable because the COT continues to perform tests similar to the current CHANNEL FUNCTIONAL TEST. The CTS defines a CHANNEL FUNCTIONAL TEST based on the type of channel. In CTS, a CHANNEL DISCUSSION OF CHANGES ITS 3.3.7, CONTROL ROOM EMERGENCY VENTILATION SYSTEM (CREVS) ACTUATION INSTRUMENTATION Sequoyah Unit 1 and Unit 2 Page 3 of 7 FUNCTIONAL TEST shall be: for Analog channels, the injection of a simulated signal into the channel as close to the sensor as practicable to verify OPERABILITY including alarm and/or trip functions; for Bistable channels, the injection of a simulated signal into the sensor to verify OPERABILITY including alarm and/or trip functions; and for Digital channels, the injection of a simulated signal into the channel as close to the sensor input to the process racks as practicable to verify OPERABILITY including alarm and/or trip functions. This does not include the adjustment, as necessary, of the channel output such that it responds with the necessary range and accuracy to known values of the parameter which the channel monitors as does the CHANNEL CALIBRATION. The COT provides similar tests with the addition that the COT includes adjustments, as necessary, of the required alarm, interlock, and trip setpoints required for channel OPERABILITY such that the setpoints are within the
necessary range and accuracy. This change is designated as more restrictive because the ITS requires additional acceptance criteria that is not currently required in the CTS.
M04 CTS Table 3.3-6 and CTS Table 4.3-3 do not contain requirements for a manual initiation of the CREVS actuation instrumentation. ITS Table 3.3.7-1 Function 1 contains the applicable MODES, Required Channels, and Surveillance Requirements for the manual initiation of CREVS. ITS 3.3.7 ACTIONS provide the compensatory actions to take when ITS Table 3.3.7-1 Function 1 is not satisfied. Additionally, ITS SR 3.3.7.6 has been added to provide the testing
requirements for manual initiation of the CREVS. This changes the CTS by adding requirements for the manual initiation function of the CREVS.
This change is acceptable because the manual initiation Function is necessary to ensure that the operator has manual initiation capability for CREVS at any time from the control room. Initiation of CREVS can be accomplished by manual initiation of Safety Injection. The safety injection function refers the operator to LCO 3.3.2 for all of the Safety Injection initiation functions and requirements.
This change is designated as more restrictive because additional functions are required in the ITS than were in the CTS.
M05 CTS Table 3.3-6 Instrument 2.c does not contain a requirement for the Automatic Actuation Logic and Actuation Relays associated with the Control Room Isolation. CTS Table 4.3-3 Instrument 2.c does not provide Surveillance Requirements for Actuation Logic testing and Master and Slave relay testing of the Automatic Actuation Logic and Actuation Relays associated with the Control Room Isolation. ITS Table 3.3.7-1 Function 2 provides the requirements for the 2 trains of Automatic Actuation Logic and Actuation Relays in MODES 1, 2, 3, 4, 5, 6 and during movement of irradiated fuel assemblies. If one train of the Automatic Actuation Logic and Actuation Relays Function is inoperable, ACTION A specifies that one train of CREVS be placed in the recirculation mode in 7 days. If two trains of the Automatic Actuation Logic and Actuation Relays Function are inoperable, ACTION B specifies that one train of CREVS be placed in the recirculation mode immediately and the applicable Conditions are Required Actions for one CREVS train made inoperable by inoperable CREVS actuation instrumentation be entered immediately. Otherwise, both trains of CREVS are required to be placed in the recirculation mode immediately. If the Required DISCUSSION OF CHANGES ITS 3.3.7, CONTROL ROOM EMERGENCY VENTILATION SYSTEM (CREVS) ACTUATION INSTRUMENTATION Sequoyah Unit 1 and Unit 2 Page 4 of 7 Actions and Completion Times of Condition A or B are not met in MODES 1, 2, 3, or 4, ACTION C specifies that the unit be placed in MODE 3 in 6 hours6.944444e-5 days <br />0.00167 hours <br />9.920635e-6 weeks <br />2.283e-6 months <br /> and MODE 5 in 36 hours4.166667e-4 days <br />0.01 hours <br />5.952381e-5 weeks <br />1.3698e-5 months <br />. If the Required Actions and Completion Times of Condition A or B are not met during the movement of irradiated fuel assemblies, ACTION D specifies to immediately suspend the movement of fuel assemblies. If the Required Actions and Completion Times of Condition A or B are not met in MODES 5 or 6, ACTION E specifies to immediately initiate action to restore one CREVS train to OPERABLE status. Additionally, ITS Table 3.3.7-1 requires the following Surveillance Requirements for the Automatic Actuation Logic and Actuation Relays: an ACTUATION LOGIC TEST (SR 3.3.7.3) every 92 days on a STAGGERED TEST BASIS; a MASTER RELAY TEST (SR 3.3.7.4) every 92 days on a STAGGERED TEST BASIS; and a SLAVE RELAY TEST (SR 3.3.7.5) every 92 days. This changes the CTS by adding requirements for the CREVS Automatic Actuation Logic and Actuation Relays Function.
The Automatic Actuation Logic and Actuation Relays are required to support the OPERABILITY of the CREVS actuation instrumentation. Requiring two trains of Automatic Actuation Logic and Actuation Relays will ensure CREVS will actuate to terminate the supply of unfiltered outside air to the control room, initiate filtration, and pressurize the control room in the event of a design basis accident concurrent with a single failure. The specified Actions will ensure that the CREVS actuation instrumentation Function is accomplished or the unit is placed in a condition where the LCO requirements are not applicable. The addition of the proposed Surveillance Requirements will verify the OPERABILITY of the Automatic Actuation Logic and Actuation Relays. This change is designated as more restrictive because additional functions are required in the ITS than were in the CTS. M06 CTS 3.3.3.1 states, "The radiation monitoring instrumentation channels shown in Table 3.3-6 shall be OPERABLE." Table 3.3-6 lists the radiation monitors required for the Control Room Isolation. ITS LCO 3.3.7 states, "The Control Room Emergency Ventilation System (CREVS) actuation instrumentation for each Function in Table 3.3.7-1 shall be OPERABLE." ITS Table 3.3.7-1 lists all
required CREVS instrument functions which includes the Safety Injection signal.
The ITS Table 3.3.7-1 specification of the Safety Injection signal includes a reference to the requirements for the Safety Injection signal being specified in ITS 3.3.2, Engineered Safety Feature Actuation (EFAS) instrumentation. This changes the CTS by specifying an additional instrumentation actuation function for the CREVS.
ITS 3.3.7 is a system related instrumentation specification that includes all the required instrumentation for the CREVS. The Safety Injection signal, although
specified in ITS 3.3.2, EFAS instrumentation, provides an actuation of CREVS that is credited in the LOCA safety analysis. The proposed change provides a more complete listing of the required CREVS actuations in a single specification.
If the Safety Injection Function is inoperable, such that only the CREVS function is affected, the less restrictive Actions of ITS 3.3.7 would be applicable. The other credited CREVS actuation instrumentation provides a complete list of required CREVS instrumentation with a common set of Actions to assure the plant is placed in a safe condition when the required instrumentation is DISCUSSION OF CHANGES ITS 3.3.7, CONTROL ROOM EMERGENCY VENTILATION SYSTEM (CREVS) ACTUATION INSTRUMENTATION Sequoyah Unit 1 and Unit 2 Page 5 of 7 inoperable. Thus, the proposed change ensures the control room doses after a design basis event are maintained within the required limits. This change is designated as more restrictive because additional functions are required in the
ITS than were in the CTS. M07 CTS Table 3.3-6 ACTION 29a requires when one channel of the control room isolation instrumentation is inoperable and a CREVS train is not placed in the recirculation mode of operation within 7 days, to be in at least HOT STANDBY within 6 hours6.944444e-5 days <br />0.00167 hours <br />9.920635e-6 weeks <br />2.283e-6 months <br /> and in COLD SHUTDOWN within the following 30 hours3.472222e-4 days <br />0.00833 hours <br />4.960317e-5 weeks <br />1.1415e-5 months <br /> in all MODES and during movement of irradiated fuel assemblies. ITS ACTION D requires when one channel of the control room isolation is inoperable (during movement of irradiated fuel assemblies) and a CREVS train is not placed in the recirculation mode of operation within 7 days, to immediately suspend movement of irradiated fuel assemblies. ITS ACTION E requires that when one channel of the control room isolation is inoperable and a CREVS train is not placed in the recirculation mode of operation within 7 days (in MODE 5 or 6) to initiate action to immediately restore one CREVS train to OPERABLE status. This changes the CTS by adding Required Actions if one channel of control room isolation is inoperable and a CREVS train is not placed in the recirculation mode of operation within 7 days when in MODE 5 or 6 and during movement of irradiated fuel assemblies.
The purpose of CTS Table 3.3-6 ACTION 29a is to provide the compensatory actions to take when one or more instrumentation channels of CREVS are inoperable. ITS 3.3.7 ACTIONS D and E provide new compensatory actions to take during the movement of irradiated fuel assemblies and in MODE 5 or 6. This change is acceptable because these compensatory actions are commensurate with the Applicable MODES of operation or other specified conditions. During the movement of irradiated fuel assemblies, suspending the movement of irradiated fuel assemblies alone will reduce the risk of an accident that would require CREVS actuation. Furthermore, because the requirements for MODES 5 and 6 are to ensure adequate isolation capabilities in the event of a fuel handling accident, ITS 3.3.7 ACTION E, to initiate action to restore one CREVS train to OPERABLE status, is the correct action to take. This change is considered more restrictive because additional Required Actions are being applied in ITS that were not applied in CTS. RELOCATED SPECIFICATIONS None REMOVED DETAIL CHANGES LA01 (Type 1 - Removing Details of System Design and System Description, Including Design Limits) CTS Table 3.3-6 for Radiation Monitoring Instrumentation has five columns stating various requirements for the radiation monitoring instruments. These columns are l abeled "MINIMUM CHANNELS OPERABLE," "APPLICABLE MODES," "ALARM/TRIP SETPOINT," "MEASUREMENT DISCUSSION OF CHANGES ITS 3.3.7, CONTROL ROOM EMERGENCY VENTILATION SYSTEM (CREVS) ACTUATION INSTRUMENTATION Sequoyah Unit 1 and Unit 2 Page 6 of 7 RANGE," AND "ACTION." ITS Table 3.3.7-1 does not contain the column titled "MEASUREMENT RANGE." This changes the CTS by moving this information
to the Bases.
The removal of these details, which are related to system design, from the Technical Specifications, is acceptable because this type of information is not necessary to be included in the Technical Specifications to provide adequate protection of public health and safety. The ITS still retains the requirement for the number of required channels, the Applicable MODES, the alarm/trip setpoint, and the appropriate Condition to enter if a required channel becomes inoperable. Also, this change is acceptable because the removed information will be adequately controlled in the ITS Bases. Changes to the Bases are controlled by the Technical Specification Bases Control Program in Chapter 5. This program provides for the evaluation of changes to ensure the Bases are properly controlled. This change is designated as a less restrictive removal of detail change because information relating to system design is being removed from the Technical Specifications.
LA02 (Type 5 - Removal of SR Frequency to the Surveillance Frequency Control Program) CTS Table 4.3-3 Instrument 2.c requires a CHANNEL CHECK every shift (12 hours1.388889e-4 days <br />0.00333 hours <br />1.984127e-5 weeks <br />4.566e-6 months <br />), a CHANNEL FUNCTIONAL TEST every quarter (92 days), and a CHANNEL CALIBRATION every refueling cycle (18 months). ITS SR 3.3.7.1, SR 3.3.7.2, SR 3.3.7.3, SR 3.3.7.6, and SR 3.3.7.7 require similar Surveillances and specify the periodic Frequency as, "In accordance with the Surveillance Frequency Control Program." This changes the CTS by moving the specified Frequencies for this SR and associated Bases to the Surveillance Frequency Control Program. (See DOC M03 for discussion on changing the CHANNEL FUNCTIONAL TEST to a COT. See DOC M05 for the addition of ITS SR 3.3.7.3, SR 3.3.7.4, and SR 3.3.7.5. See DOC M04 for the addition of ITS
The removal of these details related to Surveillance Requirement Frequencies from the Technical Specifications is acceptable, because this type of information is not necessary to be included in the Technical Specifications to provide adequate protection of public health and safety. The existing Surveillance Frequencies are removed from Technical Specifications and placed under licensee control pursuant to the methodology described in NEI 04-10. A new program (Surveillance Frequency Control Program) is being added to the Administrative Controls section of the Technical Specifications describing the control of Surveillance Frequencies. The surveillance test requirements remain in the Technical Specifications. The control of changes to the Surveillance Frequencies will be in accordance with the Surveillance Frequency Control Program. The Program shall ensure that Surveillance Requirements specified in the Technical Specifications are performed at intervals sufficient to assure the associated Limiting Conditions for Operation are met. This change is designated as a less restrictive removal of detail change, because the Surveillance Frequencies are being removed from the Technical Specifications.
DISCUSSION OF CHANGES ITS 3.3.7, CONTROL ROOM EMERGENCY VENTILATION SYSTEM (CREVS) ACTUATION INSTRUMENTATION Sequoyah Unit 1 and Unit 2 Page 7 of 7 LESS RESTRICTIVE CHANGES L01 (Category 4 - Relaxation of Required Action) CTS Table 3.3-6 ACTION 29b requires that when two channels of the Control Room Isolation instrumentation are inoperable, to initiate and maintain operation of one CREVS train in the recirculation mode of operation and enter the required Actions for one CREVS train made inoperable by inoperable CREVS actuation instrumentation within one hour or to place both trains in the recirculation mode of operation within one hour. ITS 3.3.7 ACTION B requires the same actions, but specifies the Completion Time as "Immediately." This changes the CTS by allowing additional time to complete ITS 3.3.7 ACTION B. The purpose of CTS Table 3.3-6 ACTION 29b is to ensure that the CREVS will be able to perform its required safety function. This change is acceptable because the Required Actions have not changed, just the Completion Time. When the Completion Time of "Immediately" is used in the ITS, it requires that the Required Action should be pursued without delay and in a controlled manner.
Depending on plant conditions, the Required Action could be completed within
one hour or may take longer than one hour. The ITS 3.3.7 ACTION B Completion Time is acceptable because it will be completed without delay. This change is designated as less restrictive because less stringent Required Actions are being applied in ITS than were applied in CTS.
L02 (Category 4 - Relaxation of Required Action) CTS Table 3.3-6 ACTION 29b provides compensatory actions to take when the completion time of the specified actions cannot be met during the movement of irradiated fuel assemblies. One of the compensatory actions is to suspend core alterations. ITS 3.3.7 ACTION D does not require suspension of core alterations, but instead only requires the suspension of the movement of irradiated fuel assemblies. This changes the CTS by deleting the requirement to suspend core alterations. The purpose of CTS Table 3.3-6 ACTION 29 is to reduce the risk of an accident that would require the CREVS to operate. CORE ALTERATIONS is defined in CTS 1.1, in part, as "the movement of any fuel, sources, reactivity control components, or other components affecting reactivity within the reactor vessel with the vessel head removed and fuel in the vessel." The accidents postulated to happen during core alterations, are fuel handling accidents, inadvertent criticality (due to control rod removal error or continuous control rod withdrawal error during refueling or boron dilution), and the inadvertent loading of, and subsequent operation with, a fuel assembly in an improper location. This change is acceptable because the only accident that can occur during CORE ALTERATIONS that results in a significant radioactive release is the fuel handling accident. ITS 3.3.7 Required Action D.1 requires the immediate suspension of movement of irradiated fuel assemblies, thereby reducing the risk of an accident that would require the actuation of CREVS. This change is designated as less restrictive because less stringent Required Actions are being applied in the ITS than were applied in the CTS.
Improved Standard Technical Specifications (ISTS) Markup and Justification for Deviations (JFDs)
CRE FS Actuation Instrumentation (Without Setpoint Control Program) 3.3.7 A Westinghouse STS 3.3.7 A-1 Rev. 4.0 CTS 1 V SEQUOYAH UNIT 1 Amendment XXX 33.3 INSTRUMENTATION
3.3.7 A Control Room Emergency Filtration System (CRE F S) Actuation Instrumentation (Without Setpoint Control Program)
LCO 3.3.7 The CRE FS actuation instrumentation for each Function in Table 3.3.7-1 shall be OPERABLE.
APPLICABILITY: According to Table 3.3.7-1.
ACTIONS ------------------------------------------------------------NOTE----------------------------------------------------------- Separate Condition entry is allowed for each Function.
CONDITION REQUIRED ACTION COMPLETION TIME A. One or more Functions with one channel or train inoperable.
A.1 --------------NOTE------------
-- [ Place in toxic gas protection mode if automatic transfer to toxic gas protection mode is inoperable.
] -------------------------------------
Place one CRE F S train in emergency [radiation protection] mode.
7 days B. One or more Functions with two channels or two trains inoperable.
NOTE-------------------
[ Place in the toxic gas protection mode if automatic transfer to toxic gas protection mode is inoperable.
] ---------------------------------------------
---
B.1.1 Place one CRE F S train in emergency [radiation protection] mode. AND
Immediately 1Ventilation V V recirculationrecirculation V V3.3.3.1 3.3.3.1 Applicabilit y DOC A03 Table 3.3-6 ACTION 29a Table 3.3-6 ACTION 29b 1 2 1 2 2 1 2 3 3 CRE FS Actuation Instrumentation (Without Setpoint Control Program) 3.3.7 A Westinghouse STS 3.3.7 A-2 Rev. 4.0 CTS 1 V SEQUOYAH UNIT 1 Amendment XXX 3ACTIONS (continued)
CONDITION REQUIRED ACTION COMPLETION TIME B.1.2 Enter applicable Conditions and Required Actions for one CRE F S train made inoperable by inoperable
CRE FS actuation instrumentation.
OR B.2 Place both trains in emergency [radiation protection] mode. Immediately Immediately C. Required Action and associated Completion Time for Condition A or B not met in MODE 1, 2, 3, or 4. C.1 Be in MODE 3.
AND C.2 Be in MODE 5.
6 hours6.944444e-5 days <br />0.00167 hours <br />9.920635e-6 weeks <br />2.283e-6 months <br /> 36 hours D. Required Action and associated Completion Time for Condition A or B not met during movement of
[recently]
irradiated fuel assemblies. D.1 Suspend movement of
[recently]
irradiated fuel assemblies.
Immediately E. [ Required Action and associated Completion Time for Condition A or B not met in MODE 5
or 6. E.1 Initiate action to restore one CRE FS train to OPERABLE status. Immediately
] recirculation V V VTable 3.3-6 ACTIONS 29a and 29b DOC M07, Table 3.3-6 ACTION 29b DOC M07, Table 3.3-6 ACTION 29b Table 3.3-6 ACTION 29.b 1 1 2 2 2 2 1 3 CRE FS Actuation Instrumentation (Without Setpoint Control Program) 3.3.7 A Westinghouse STS 3.3.7 A-3 Rev. 4.0 CTS 1 V SEQUOYAH UNIT 1 Amendment XXX 3SURVEILLANCE REQUIREMENTS ------------------------------------------------------------NOTE-----------------------------------------------------------
Refer to Table 3.3.7-1 to determine which SRs apply for each CRE FS Actuation Function. -------------------------------------------------------------------------------------------------------------------------------
SURVEILLANCE FREQUENCY
SR 3.3.7.1 Perform CHANNEL CHECK.
[ 12 hours1.388889e-4 days <br />0.00333 hours <br />1.984127e-5 weeks <br />4.566e-6 months <br /> OR In accordance with the Surveillance
Frequency
Control Program
] SR 3.3.7.2 Perform COT.
[ 92 days OR In accordance
with the Surveillance Frequency
Control Program
]
SR 3.3.7.3 Perform ACTUATION LOGIC TEST.
[ 31 days on a STAGGERED TEST BASIS OR In accordance with the Surveillance Frequency Control Program
] V4.3.3.1 Table 4.3-3 Instrument 2.c Table 4.3-3 Instrument 2.c 1 4 4 4 4 4 CRE FS Actuation Instrumentation (Without Setpoint Control Program) 3.3.7 A Westinghouse STS 3.3.7 A-4 Rev. 4.0 CTS 1 V SEQUOYAH UNIT 1 Amendment XXX 3SURVEILLANCE REQUIREMENTS (continued)
SURVEILLANCE FREQUENCY SR 3.3.7.4 Perform MASTER RELAY TEST.
[ 31 days on a STAGGERED TEST BASIS OR In accordance with the Surveillance Frequency Control Program
]
REVIEWER'S NOTE----------------------------------
The Frequency of 92 days on a STAGGERED TEST BASIS is applicable to the actuation logic processed through the Relay or Solid State Protection System.
5 -------------------------------NOTE------------------------------
This Surveillance is only applicable to the actuation logic of the ESFAS Instrumentation. ---------------------------------------------------------------------
Perform ACTUATION LOGIC TEST.
[ 92 days on a STAGGERED TEST BASIS OR In accordance
with the Surveillance
Frequency Control Program
] 5 4 3 DOC M05 4 6 5 CRE FS Actuation Instrumentation (Without Setpoint Control Program) 3.3.7 A Westinghouse STS 3.3.7 A-5 Rev. 4.0 CTS 1 V SEQUOYAH UNIT 1 Amendment XXX 3SURVEILLANCE REQUIREMENTS (continued)
SURVEILLANCE FREQUENCY
REVIEWER'S NOTE----------------------------------
The Frequency of 92 days on a STAGGERED TEST BASIS is applicable to the master relays processed through the Solid State Protection System.
6 -------------------------------NOTE------------------------------
This Surveillance is only applicable to the master
relays of the ESFAS Instrumentation. ---------------------------------------------------------------------
Perform MASTER RELAY TEST.
[ 92 days on a STAGGERED TEST BASIS OR In accordance
with the Surveillance Frequency Control Program
]
7 Perform SLAVE RELAY TEST.
[ [92] days OR In accordance with the Surveillance
Frequency
Control Program
] 4 5 DOC M05 DOC M05 4 4 6 5 4 4 5 CRE FS Actuation Instrumentation (Without Setpoint Control Program) 3.3.7 A Westinghouse STS 3.3.7 A-6 Rev. 4.0 CTS 1 V SEQUOYAH UNIT 1 Amendment XXX 3SURVEILLANCE REQUIREMENTS (continued)
SURVEILLANCE FREQUENCY SR 3.3.7.
8 -------------------------------NOTE------------------------------
Verification of setpoint is not required. ---------------------------------------------------------------------
Perform TADOT.
[ [18] months OR In accordance
with the Surveillance Frequency
Control Program
]
9 Perform CHANNEL CALIBRATION.
[ [18] months OR In accordance
with the Surveillance
Frequency Control Program
] 6 7 Table 4.3-3 Instrument 2.c DOC M04 5 4 4 5 4 4 CRE FS Actuation Instrumentation (Without Setpoint Control Program) 3.3.7 A Westinghouse STS 3.3.7 A-7 Rev. 4.0 CTS 1 V SEQUOYAH UNIT 1 Amendment XXX 3Table 3.3.7-1 (page 1 of 1)
CRE FS Actuation Instrumentation FUNCTION APPLICABLE MODES OR OTHER SPECIFIED CONDITIONS REQUIRED CHANNELS SURVEILLANCE REQUIREMENTS TRIP SETPOINT 1.Manual Initiation 1, 2, 3, 4, [5, 6], (a) 2 trains SR 3.3.7.
8 NA 2.Automatic Actuation Logicand Actuation Relays 1, 2, 3, 4, [5, 6], (a) 2 trains SR 3.3.7.3 SR 3.3.7.4 SR 3.3.7.
5 SR 3.3.7.
6 SR 3.3.7.
7 NA 3.Control Room Radiationa. Control RoomAtmosphere 1, 2, 3, 4 [5, 6], (a) [2] SR 3.3.7.1 SR 3.3.7.2 SR 3.3.7.9 [2] mR/hr b. Control Room Air Intakes 1, 2, 3, 4, [5, 6], (a) [2] SR 3.3.7.1 SR 3.3.7.2 SR 3.3.7.
9 [2] mR/hr 4.Safety InjectionRefer to LCO 3.3.2, "ESFAS Instrumentation," Function 1, for all initiation functions and requirements. (a) During movement of [recently] irradiated fuel assemblies.
V 6 7 400 cpm (b) (b) Equivalent to 1.0 x 10
-5 Ci/cc.Table 4.3-3 Instrument 2.c DOC M06 DOC M04 Table 4.3-3 Instrument 2.c Table 3.3-6 Footnote **
1 2 5 5 5 2 5 2 3 5 3 4 5 DOC M05 2 3 3 CRE FS Actuation Instrumentation (Without Setpoint Control Program) 3.3.7 A Westinghouse STS 3.3.7 A-1 Rev. 4.0 CTS 1 V SEQUOYAH UNIT 2 Amendment XXX 33.3 INSTRUMENTATION
3.3.7 A Control Room Emergency Filtration System (CRE F S) Actuation Instrumentation (Without Setpoint Control Program)
LCO 3.3.7 The CRE FS actuation instrumentation for each Function in Table 3.3.7-1 shall be OPERABLE.
APPLICABILITY: According to Table 3.3.7-1.
ACTIONS ------------------------------------------------------------NOTE----------------------------------------------------------- Separate Condition entry is allowed for each Function.
CONDITION REQUIRED ACTION COMPLETION TIME A. One or more Functions with one channel or train inoperable.
A.1 --------------NOTE------------
-- [ Place in toxic gas protection mode if automatic transfer to toxic gas protection mode is inoperable.
] -------------------------------------
Place one CRE F S train in emergency [radiation protection] mode.
7 days B. One or more Functions with two channels or two trains inoperable.
NOTE-------------------
[ Place in the toxic gas protection mode if automatic transfer to toxic gas protection mode is inoperable.
] ---------------------------------------------
---
B.1.1 Place one CRE F S train in emergency [radiation protection] mode. AND
Immediately 1Ventilation V V recirculationrecirculation V V3.3.3.1 3.3.3.1 Applicabilit y DOC A03 Table 3.3-6 ACTION 29a Table 3.3-6 ACTION 29b 1 2 1 2 2 1 2 3 3