ML021230465
| ML021230465 | |
| Person / Time | |
|---|---|
| Site: | Seabrook  |
| Issue date: | 03/25/2002 |
| From: | Feigenbaum T North Atlantic Energy Service Corp |
| To: | Document Control Desk, Office of Nuclear Reactor Regulation |
| References | |
| LAR-01-07, NYN-02035 | |
| Download: ML021230465 (15) | |
Text
North Atlantic Energy Service Corporation P.O. Box 300 North Seabrook, NH 03874 Atlantic (603) 474-9521 The Northeast Utilities System March 25, 2002 Docket No. 50-443 NYN-02035 United States Nuclear Regulatory Commission Attention: Document Control Desk Washington, D.C. 20555-001 Seabrook Station Response to Request for Additional Information Regarding License Amendment Request 01-07, "Changes to Certain Technical Specifications Associated with Response Time Testing" North Atlantic Energy Service Corporation (North Atlantic), in response to questions from the Staff, has enclosed herein additional information regarding License Amendment Request (LAR) 01-07. As a result of a telephone conference conducted on February 27, 2002, the NRC requested North Atlantic to provide additional information to address specific questions on the proposed changes to the Technical Specifications (TS) associated with response time testing. contains the response to the Request for Additional Information.
contains the revised LAR tables for enhanced clarity. Enclosure 3 contains the attachments of historical data. Enclosure 4 contains vendor technical literature for Rosemount Model 1153 and 1154 pressure transmitters. In addition, North Atlantic requests withdrawal of the associated TS Bases that was submitted as part of LAR 01-07 since NRC approval of TS Bases information is not a regulatory requirement.
This additional information does not change the conclusions of the original LAR 01-07 submittal, that the proposed change does not involve a significant hazard consideration pursuant to 1 OCFR50.92, and still meets the criteria of 1 OCFR51.22(c)(9) for a categorical exclusion from the requirements for an Environmental Impact Statement.
Should you have any questions regarding this letter, please contact Mr. James M. Peschel, Manager - Regulatory Programs, at (603) 773-7194.
Very truly yours, NORTH ATLANTIC ENERGY SERVICE CORP.
andChieigenbaum ecutive Vice President
'andCth'e f Nuclear Officer
.6. Nuc ear Reguiatory (Comnission NYN-02035/ Page 2
- without Enclosure 4 cc:
H. J. Miller, NRC Regional Administrator*
R.D. Starkey, NRC Project Manager, Project Directorate 1-2 G. F. Dentel, NRC Senior Resident Inspector*
ENCLOSURE 1 TO NYN-02035 I
Response to Request for Additional Information Regarding License Amendment Request 01-07 The following provides North Atlantic Energy Service Corporation's (North Atlantic) response to the NRC Staff's request for additional information (RAI) regarding License Amendment Request (LAR) 01-07:
RAI 1: Were the Tobar 32DP2 (Reactor Coolant Flow Rate) and Tobar 32PA2 (Steam Line Pressure) sensors approved in the NRC SER for WCAP-13632-P-A?
If not, was a Failure Modes and Effects (FMEA) analysis performed?
Response
Tobar 32DP2, Differential Pressure Transmitters, and 32PA2, Absolute Pressure Transmitters, were approved for elimination of response time testing (RTT) Technical Specifications (TS) requirements in the NRC SER for WCAP-13632-P-A.
These particular instruments are identified on page 3 of section 1.0 "Introduction and Background" and on page 15 of section 3 "Evaluation". These transmitters are part of a subset of transmitters typically installed in Westinghouse plants and were evaluated by similarity analysis to compare their design to those evaluated using FMEA in the EPRI report.
The Tobar 32DP2 and 32PA2 transmitters are listed in Table 9-1 of WCAP 13632-P-A, Revision 2, with their applicable evaluated response times. The values and methodology of section 9.0 of WCAP-13632 are endorsed on page 18 of section 4.0 "Conclusion" in the NRC SER.
RAI 2: On Page 3 of the LAR North Atlantic identified that certain Rosemount transmitters were not evaluated in WCAP-13632-P-A. North Atlantic stated that it will use response times based on actual transmitter performance. For response time calculations, conservative values of 0.200 seconds for DB, GB and GP units and 0.600 seconds for DP units were applied. How do you know that the values are conservative? Please identify the basis for this information. What are the past values? What penalty factors were used?
How were the conservative values obtained?
Response
Rosemount gage and differential pressure transmitter models 1153 and 1154 were evaluated by EPRI and are identified in section 4.4 of WCAP-13632-P-A and section 3.0 of the NRC SER. These transmitters are part of the entire set of transmitters identified where analysis has shown that changes in response time of the sensor will be accompanied by changes in performance characteristics which are detectable during routine periodic tests such as calibrations and channel checks. Typical response times for these transmitters are however, not identified in Table 9-1 of the WCAP. Guidance in WCAP-13632 and the NRC SER state that when response times for listed transmitters are not identified in Table 9-1 that neither the manufacturer nor Westinghouse currently provides this information. Applicable response times should therefore be obtained using conservative data from either previous plant insitu response time testing (historical records) or, if replacing the transmitter, the response time obtained through testing. This methodology is identified in section 9 of WCAP-13632, page 9 of section 2, "Discussion" of the NRC SER and endorsed on page 18 of section 4, "Conclusion" of the NRC SER.
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Historical records from past performance at Seabrook Station were used in establishing the response times for Rosemount transmitters as identified in the LAR on page 3. The data for Rosemount GB9 and GP9 transmitters reflected response times of less than 0.200 seconds and for DP4 units all data recorded was less than or equal to 0.500 seconds. This plant data was further verified against Rosemount publications for consistency with the manufacturer's specifications and found to be in agreement with vendor specifications.
"* Rosemount Publication 00813-0100-4302, R/AB, 1999, Model 1153DB5 & GB9, Specification Section: Response Time for Range Code 5 & 9 = 0.200 seconds.
" Rosemount Publication 00813-0100-4514, R/AA, 1999, Model 1154GP9 & DP9, Specification Section: Response Time for Range Code 9 = 0.200 seconds and for Range Code 4 = 0.500 seconds.
Based on the historical data (see Enclosure 3, Attachment A) and confirmation with Rosemount specifications, North Atlantic has chosen to apply 0.200 seconds for Rosemount GB9 and GP9 transmitters and 0.500 seconds1 for DP4 transmitters. Since transmitter historical data never exceeded the response times specified the values specified were considered conservative.
RAI 3: On Page 4, North Atlantic stated that they may complete the following actions as an alternative to performing periodic drift monitoring of Rosemount transmitters as specified in Bulletin 90-01, Supplement 1. The NRC requested that North Atlantic either withdraw the option or commit to it.
Response
North Atlantic will not pursue the alternative action that was outlined in the LAR with respect to periodic drift monitoring for Rosemount pressure and differential pressure transmitters. As such, North Atlantic withdraws this information.
RAI 4
On Page 7 and 8 of the LAR North Atlantic provided two tables (Table I.B-1 and I.B-2). The NRC requested that North Atlantic consider combining both tables and make a stand alone table and that the table be changed to more clearly identify which sensor is being used. The table needs to correlate the brand and model of the individual sensors.
Additionally note 4 needs clarification to identify the information pertaining to the function, the sensor, the applicable portions of the process cabinet, and the input of relay and logic information.
The description of response times for the Rosemount DP transmitter on page 3 of the LAP. and the attached table is in error. The correct response time is 0.500 seconds, as stated herein. The tables in have been corrected to reflect 0.500 seconds for the DP4 transmitter.
3
Response
LAR tables I.B-1 and I.B-2 are individually listed to separate Reactor Trip System and Engineered Safety Feature Actuation System Response Times. This is typical to Seabrook Station's Technical Specifications and Technical Requirements Manual. Transmitters applicable to each listed function are ideptified in section B of the LAR. For clarity, each table was revised to show the applicable transmitter model number associated with each protection function.
LAR page 5 states that North Atlantic will use allocations for system response times either from the bounding criteria in Reference 2 or from the summation of individual components within a specific channel. The response times listed in Tables LB-1 and I.B-2 are generic bounding response times from WCAP-14036 Table 8-1 as endorsed in Table 1, page 12 of the NRC SER.
For clarity the individual components (cards) within each specific channel have been added to the table.
Reviewers should note that the summation of response times of the individual components would provide a response time much less than the generic value listed. North Atlantic is cognizant of this and prefers to use the longer generic times for the protection system functions.
Upon further review of the application of generic bounding response times associated with all the protection functions, it was noted that the Emergency Feedwater Flow channel does not appropriately fit the generic criteria. Therefore, North Atlantic will continue to response time test the EFW Flow channel, with exception of the transmitter since the transmitter is addressed in the WCAP and SER. Table I.B-2 has been revised accordingly.
Table I.B-l and I.B-2 lists 7300 Process Cabinet string times based on generic bounding response times as outlined in Table 8-1 of WCAP-14036-P-A and Tal,le 1 on page 12 of the NRC SER on this same WCAP. This same criterion applies to the rate trips of the Westinghouse Nuclear Instrumentation System and the table reflects a value of 0.200 seconds for the NIS PR High Negative Rate. In addition to the NIS PR High Negative Rate trip Seabrook Station also has a NIS High Positive Rate Trip. Although similar circuitry is used for these two rate trips they are in fact physically different. The difference is in the size of the input filter resistors on the applicable circuit cards. This difference has been previously identified at Seabrook Station and documented in its corrective action program as ACR 96-1265. The value listed in Table I.B 1 of 0.300 seconds has been established from historical data (see Enclosure 3, Attachment B), as referred to by Note 4 of Table I.B-1. The established value has never been exceeded in any documented RTT, is an appropriate value for the string response time and conforms to the overall response time required by Technical Specifications and Technical Requirements Manual.
Solid State Protection System input relays and logic card times are also listed on Table I.B-1 and I.B-2. These individual components are specifically credited in this LAR because the remainder of the SSPS circuitry is considered as part of the final actuated device and will continue to be regularly tested during other routine test procedures. The input relay logic times are different depending on if the relay is normally energized or normally de-energized. These relays were evaluated in the Westinghouse WCAP and a detail of their response times can be found on page 4-24 of WCAP-14036. The time response for the SSPS logic circuits was also evaluated in the Westinghouse WCAP and page 4-24 documents a response time of 0.000349 seconds. Current North Atlantic response time procedures use 0.01 seconds as an acceptance criterion for this position of the SSPS.
4
North Atlantic believes the 0.01 second to be a reasonable value for SSPS logic performance.
This value envelopes the WCAP performance criteria and when summed with other protection channel response times yields total channel response times within the bounds of our accident analysis. Therefore, North Atlantic has listed 0.01 seconds for the response time of the SSPS logic circuits in Table I.B-1 and I.B-2 of the LAR.
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ENCLOSURE 2 TO NYN-02035 6
TABLE I.B-1 Reactor Trip System (RTS) Response Time Allocations RTS Function Sensor 7300 Process Cabinet Type (Sec.)
String (Sec.)
SSPS Input Relay / Logic (Note 1)
(Sec.)
NIS PR High & Low SP NIS PR High Positive Rate NIS PR High Negative Rate OTAT, OPAT / Tavg Pressurizer Pressure Low & High Reactor Coolant Flow Low S/G Level Low-Low RCP Undervoltage RCP Underfrequency Notes:
- 1.
For the h relays.
(Note 2)
(Note 2)
(Note 2)
(Note 2)
(Note 2)
(Note 2)
(Note 5)
(Note 5)
Rosemount 1154 GP9 0.200 Westinghouse 0.400 Veritrak 76 DPI &
Tobar 32 DP2 Rosemount 1154 DP4 0.500 (Note 6)
(Note 6)
(Note 6)
(Note 6)
NIS cabinet NIS cabinet NIS cabinet NRA+NSA+
NSA+NSA+
NAL NLP+NAL NLP+NAL NLP+NAL nput Relays, the response time allocation is 0.020 sec.
0.065 (Note 3) 0.300 (Note 4) 0.200 (Note 3) 0.400 0.100 0.100 0.020 / 0.01 0.020 / 0.01 0.020/0.01 0.020 / 0.01 0.020 / 0.01 0.020 / 0.01 0.100 0.020/0.01 for normally energized
- 2.
Nuclear Instrumentation detectors are not response time tested.
Westinghouse Nuclear Instrumentation Cabinet time allocation from WCAP-14036-P-A, Revision 1 (Reference 2).
Westinghouse Nuclear Instrumentation Cabinet time allocation from Seabrook Station Plant Data.
Periodic response time testing of the Resistance Temperature Detectors (RTDs) will continue.
Periodic response time testing of these functions will continue.
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- 3.
- 4.
- 5.
6.
TABLE I.B-2 Engineered Safety Features Actuation System (ESFAS) Response Time Allocations ESFAS Function Sensor 7300 Process SSPS Input Cabinet String Relay / Logic (Note 1)
Type (Sec.)
(Sec.)
(Sec.)
Containment Pressure HI-1 Westinghouse Barton 0.400 NLP & NAL 0.020 / 0.01 752 0.100 Pressurizer Pressure Low Rosemount 1154 GP9 0.200 NLP & NAL 0.020 / 0.01 0.100 Steam Pressure Low Westinghouse 0.200 NLP & NAL 0.020 / 0.01 VXritrk"- 76 PG1 0.100 Containment Pressure HI-3 Containment Pressure HI-2 Steam Line Hi Negative Rate S/G Level HI-HI S/G Level Low-Low Emergency Feedwater Flow RWST Level Low-Low LOP Diesel Generator Start CBA Actuation on Control Room HI Radiation Notes:
- 1.
For the Input Re relays, and 0.026
- 2.
Periodic responst Tobar 32 PA2, Rosemount 1153 GB9 Westinghouse Barton 0.400 752 Westinghouse Barton 0.400 752 Westinghouse 0.400 Veritrak 76 PG1 Rosemount 1154 DP4 0.500 Rosemount 1154 DP4 0.500 Rosemount 1153 DB5 0.200 Westinghouse 0.400 Veritrak 76 DPI (Note 2)
(Note (Note 2)
(Note NLP & NAL 0.100 NLP & NAL 0.100 NLP & NAL 0.100 NLP & NAL 0.100 NLP & NAL 0.100 (Note 2)
NLP & NAL 0.100 0.026 / 0.01 0.020/0.01 0.020 / 0.01 0.020 / 0.01 0.020 / 0.01 0.026 / 0.01
- 2) 2)
lays, the response time allocation is 0.020 sec. for normally energized see. for normally de-energized relays.
time testing of these functions will continue.
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ENCLOSURE 3 TO NYN-02035 9
Attachment A page I of 2 Rosemount 1154DP4 Year Response Time*
87 0.228 / 0.249 89 0.203 / 0.350 91 0.120 / 0.275 91 0.294 /0.385 92 0.150/ 0.240 92 0.160 / 0.220 92 0.160 / 0.245 92 0.180 / 0.260 94 0.035 / 0.125 94 0.058 / 0.165 94 0.072 / 0.245 95 0.085 / 0.160 95 0.110 / 0.230 95 0.170 / 0.210 95 0.178 / 0.295 95 0.240 / 0.260 97 0.105 / 0.260 97 0.130 / 0.310 97 0.130 / 0.260 97 0.140 / 0.150 97 0.170 / 0.240 97 0.170 / 0.370 97 0.260 / 0.390 99 0.065 / 0.205 99 0.240 / 0.320 99 0.280 / 0.360 99 0.360 / 0.320 00 0.280 / 0.450 00 0.290 / 0.400 00 0.300 / 0.380 00 0.400 / 0.500 01 0.180 / 0.260 Rosemount 1154GP9 10
Attachment A (continued) page 2 of 2 Rosemount 1153DB5 Year Response Time 97 0.040 97 0.040 97 0.047 97 0.050 98 0.035 98 0.040 99 0.055 99 0.070 00 0.045 00 0.050
- Double entries are based on increasing and decreasing process ramps.
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Attachment B page 1 of 1 NIS POWER HIGH POSITIVE RATE TRIP Year Response Time*
97 0.236/ 0.236 97 0.237 / 0.236 97 0.250 /0.245 97 0.257 / 0.260 97 0.262 / 0.265 98 0.275 / 0.277 99 0.217 / 0.220 00 0.223 / 0.222
- Double entries are based on increasing and decreasing process ramps.
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ENCLOSURE 4 to NYN-02035 13