ML023460347
| ML023460347 | |
| Person / Time | |
|---|---|
| Site: | Ginna  |
| Issue date: | 12/12/2002 |
| From: | Clark R NRC/NRR/DLPM/LPD1 |
| To: | |
| Clark R, NRR/DLPM, 415-2297 | |
| References | |
| TAC MB4789 | |
| Download: ML023460347 (47) | |
Text
December 12, 2002 FACILITY:
R. E. Ginna Nuclear Power Plant LICENSEE:
Rochester Gas and Electric Corporation
SUBJECT:
SUMMARY
OF MEETING HELD ON NOVEMBER 20, 2002, WITH ROCHESTER GAS AND ELECTRIC CORPORATION RE: PROPOSED LICENSE AMENDMENT REQUEST TO REVISE R. E. GINNA NUCLEAR POWER PLANT (GINNA) SAFETY LIMITS AND INSTRUMENTATION SETPOINTS (TAC NO. MB4789)
On November 20, 2002, representatives of the Rochester Gas and Electric Corporation (RG&E or licensee) met with the members of the Nuclear Regulatory Commission (NRC) staff in Rockville, Maryland. The purpose of the meeting was to discuss RG&Es proposed response to the NRCs request for additional information (RAI) dated September 27, 2002 (ADAMS Accession No. ML022200294). This RAI was related to RG&Es license amendment request dated April 9, 2002, to revise the Ginna Improved Technical Specifications (ITSs) to remove the Trip Setpoint column from Table 3.3.1-1, Reactor Trip System Instrumentation, and replace it with a column designated Allowable Values. The amendment also proposed that the Trip Setpoint column in Table 3.3.2-1, Engineered Safety Feature Actuation System Instrumentation, be deleted. Meeting slides were used to address each RAI question for the purpose of gaining NRC staff feedback on the level of detail required, and to provide clarification. A list of attendees is given in Enclosure 1, a copy of the handout provided by RG&E is given in Enclosure 2, and a copy of the handout provided by the NRC staff is given in. Following the meeting, RG&E requested and the staff agreed that the due date for a response to the above RAI be extended to January 10, 2003. The extension was requested to allow the licensee sufficient time to address NRC staff concerns regarding the methodology used to calculate Allowable Values, which were documented in Question Number 9 of the September 27, 2002, RAI.
/RA/
Robert Clark, Project Manager, Section 1 Project Directorate I Division of Licensing Project Management Office of Nuclear Reactor Regulation Docket No. 50-244
Enclosures:
As stated cc w/encls: See next page
December 12, 2002 FACILITY:
R. E. Ginna Nuclear Power Plant LICENSEE:
Rochester Gas and Electric Corporation
SUBJECT:
SUMMARY
OF MEETING HELD ON NOVEMBER 20, 2002, WITH ROCHESTER GAS AND ELECTRIC CORPORATION RE: PROPOSED LICENSE AMENDMENT REQUEST TO REVISE R. E. GINNA NUCLEAR POWER PLANT (GINNA) SAFETY LIMITS AND INSTRUMENTATION SETPOINTS (TAC NO. MB4789)
On November 20, 2002, representatives of the Rochester Gas and Electric Corporation (RG&E or licensee) met with the members of the Nuclear Regulatory Commission (NRC) staff in Rockville, Maryland. The purpose of the meeting was to discuss RG&Es proposed response to the NRCs request for additional information (RAI) dated September 27, 2002 (ADAMS Accession No. ML022200294). This RAI was related to RG&Es license amendment request dated April 9, 2002, to revise the Ginna Improved Technical Specifications (ITSs) to remove the Trip Setpoint column from Table 3.3.1-1, Reactor Trip System Instrumentation, and replace it with a column designated Allowable Values. The amendment also proposed that the Trip Setpoint column in Table 3.3.2-1, Engineered Safety Feature Actuation System Instrumentation, be deleted. Meeting slides were used to address each RAI question for the purpose of gaining NRC staff feedback on the level of detail required, and to provide clarification. A list of attendees is given in Enclosure 1, a copy of the handout provided by RG&E is given in Enclosure 2, and a copy of the handout provided by the NRC staff is given in. Following the meeting, RG&E requested and the staff agreed that the due date for a response to the above RAI be extended to January 10, 2003. The extension was requested to allow the licensee sufficient time to address NRC staff concerns regarding the methodology used to calculate Allowable Values, which were documented in Question Number 9 of the September 27, 2002, RAI.
/RA/
Robert Clark, Project Manager, Section 1 Project Directorate I Division of Licensing Project Management Office of Nuclear Reactor Regulation Docket No. 50-244
Enclosures:
As stated cc w/encls: See next page DISTRIBUTION PUBLIC PDI-1 Rdg File SLittle RClark EMarinos KMortensen HGarg PRebstock CSchulten PLoeser RLaufer SRichards OGC ACRS/ACNW BPlatchek, RI TBergman JZwolinski/TMarsh File Name:C:\\ORPCheckout\\FileNET\\ML023460347.wpd Accession No.: ML023460347 OFFICE PDI-1/PM PDI-1/LA EEIB/SC PDI-1/SC NAME RClark SLittle EMarinos PTam for RLaufer DATE 12/12/02 12/12/02 12/12/02 12/12/02 OFFICIAL RECORD COPY
R.E. Ginna Nuclear Power Plant cc:
Dr. Robert C. Mecredy Vice President, Nuclear Operations Rochester Gas and Electric Corporation 89 East Avenue Rochester, NY 14649 Kenneth Kolaczyk, Sr. Resident Inspector R.E. Ginna Plant U.S. Nuclear Regulatory Commission 1503 Lake Road Ontario, NY 14519 Regional Administrator, Region I U.S. Nuclear Regulatory Commission 475 Allendale Road King of Prussia, PA 19406 Mr. William M. Flynn, President New York State Energy, Research, and Development Authority 17 Columbia Circle Albany, NY 12203-6399 Charles Donaldson, Esquire Assistant Attorney General New York Department of Law 120 Broadway New York, NY 10271 Daniel F. Stenger Ballard Spahr Andrews & Ingersoll, LLP 601 13th Street, N.W., Suite 1000 South Washington, DC 20005 Ms. Thelma Wideman, Director Wayne County Emergency Management Office Wayne County Emergency Operations Center 7336 Route 31 Lyons, NY 14489 Ms. Mary Louise Meisenzahl Administrator, Monroe County Office of Emergency Preparedness 1190 Scottsville Road, Suite 200 Rochester, NY 14624 Mr. Paul Eddy New York State Department of Public Service 3 Empire State Plaza, 10th Floor Albany, NY 12223 MEETING BETWEEN NRC AND ROCHESTER GAS AND ELECTRIC CORPORATION ATTENDANCE LIST NOVEMBER 20, 2002 NRC E. Marinos, NRR P. Loeser, NRR R. Clark, NRR H. Garg, NRR P. Rebstock, NRR M. Mortensen, NRR C. Schulten, NRR RG&E T. Harding J. Pacher P. Swift J. Guider T. Quinn RG&E DOCUMENTS
1 RG&E GINNA STATION PRESENTATION TO NRC November 20, 2002 Ginna License Amendment Request Instrumentation Setpoint Methodology
2 Purpose of Briefing
- Provide the NRC staff with an overview of the proposed RG&E responses to the 11 NRC request for additional information (RAI) questions dated Sept 27, 2002, associated with the RG&E instrumentation setpoint methodology
3 Proposed RAI Responses
- For each of the 11 NRC questions from the Sept. 27th letter, responses have been developed. An overview of the proposed answers and description of any associated attachments is included here. The purpose is to gain NRC feedback on the level of detail and ensure the necessary documentation responds to the question.
4 Background
- Ginna licensed in September 1969 RTS setpoints specified using inequalities No ESFAS or CVI setpoints specified, only channel requirements No Safeguard Bus UV requirements No Control Room isolation requirements
5 Background (Cont.)
- 1981 - Added Safeguards Bus requirements via a curve
Trip setpoint equivalent to nominal setpoint Allowable value equivalent to accident analysis value
- 1985 - Added nominal setpoints for control room isolation
6 Background (Cont.)
- 1996 - ITS implemented LCOs with only Trip Setpoint (single column format):
3.3.1, RTS 3.3.5, CVI 3.3.6, CREATS Instrumentation LCOs with both Trip Setpoint and Allowable Value (two column format):
3.3.2, ESFAS 3.3.4, DG Start Instrumentation
7 Background (Cont.)
- Various use of trip setpoint Two column format uses a nominal value as the Trip Setpoint Single column format uses the Trip Setpoint as an operability basis
- Inconsistent operability statements in Bases
- NUREG-1431 Revision 2 includes format agreed to by both the NRC and the Industry
8 Background (Cont.)
- Revise 4 LCOs to only a single column Allowable Value format (CREATS Instrumentation previously submitted)
- Use an Allowable Value equivalent to rack portion of instrument loop that supports trip bistable (COT) bistable uncertainties test/measuring equipment uncertainties anything between test module and bistable
9 Question 1
- Ginna instrumentation setpoint methodology updated since the issue of ISA S67.04-1994 Part I and II
- Methodology follows the guidelines of the ISA Standard, NRC Reg. Guide 1.105 and Generic Letter 91-04 for Drift Analyses
- There has been no specific docketed NRC review and approval of the Ginna in-house methodology
10 Question 2
- No effect, the assumptions that support time constants in the lead/lag calculations are unaffected
- This is also the process followed for most, if not all, nuclear plants in the U.S.
11 Questions 3, 4, 5, and 6
- A table has been developed by RGE and will be provided in our response which lists the values for the various functions
- The next slide shows the planned format of the table
12 ITS Section Item Analytical Limit Allowable Value ISA-RP67.04-PART II, method 3
Calculated Setpoint Nominal Setpoint Tolerance 3.3.1 Function #2.a 118%
113.4%
112.3%
108%
107.46 to 108.54%
Function #2.b 35%
30.4%
29.28%
24%
23.88 to 24.12%
Function #7.a 1760 psig
1777 psig 1791.2 psig 1873 psig 1865.0 to 1881.0 psig Function #7.b 2410 psig
2406 psig 2396.2 psig 2377 psig 2369.0 to 2385.0 psig 3.3.2 Function #1.c 6.0 psig
5.71 psig 4.61 psig 4 psig 3.40 to 4.60 psig Function #1.d 1715 psig
1731 psig 1744.8 psig 1750 psig 1742.0 to 1758.0 psig
13 Question 7
- In most cases the calibration tolerance is greater than or equal to the device reference accuracy (RA)
- Both the tolerance and RA are included in the calculation for cases where the calibration tolerance is less than the RA
14 Question 8
- As-found and as-left data is recorded within the Ginna calibration and channel operability test procedures
- Ginna drift analysis includes plant specific data for all functions on Tables 3.3.1-1 and 3.3.2-1
- The basis for a drift analysis program is shown in the attached slides
15 SURVEILLANCE EXTENSION ELEMENTS OF THE PROGRAM (GENERIC LETTER 91-04)
Comparative Review of Surveillance Testing Surveillance and Corrective Maintenance History Review Drift Analysis Setpoint Analysis
16 GENERIC LETTER 91-04 NRC STAFF IDENTIFIED SPECIFIC ACTION THAT LICENSEES SHOULD ADDRESS:
Confirm that instrument drift as determined by As Found / As Left calibration data from surveillance and maintenance records has not, except on rare occasions, exceeded acceptable limits for a calibration interval.
The surveillance and maintenance history for instrument channels should demonstrate that most problems affecting instrument operability are found as a result of surveillance tests other than the instrument calibration. If the calibration data show that instrument drift is beyond acceptable limits on other than rare occasions, the calibration interval should not be increased because instrument drift would pose a greater safety problem in the future.
17 GENERIC LETTER 91-04 (continued)
NRC STAFF IDENTIFIED SPECIFIC ACTION THAT LICENSEES SHOULD ADDRESS:
Confirm that the values of drift for each instrument type (make, model, and range) and application have been determined with a high probability and high degree of confidence. Provide a summary of the methodology and assumptions used to determine the rate of instrument drift with time based upon historical plant calibration data.
The licensee should have a body of As Found / As Left calibration data that permits the determination of the rate of instrument drift with time over the calibration interval. This data should allow the determination of instrument drift for those instruments that perform safety functions.
18 DRIFT ANALYSIS ISA RP67.04 APP E Determine the amount of drift that has occurred for a specific make/model instrument, process and unit
19 IHPA TRENDING PLOT Function: Demo-5 Tag No.: PT001-1 Pt-1 3.860 3.910 3.960 4.010 4.060 4.110 4.160 3/9/82 12/3/84 8/30/87 5/26/90 2/19/93 11/16/95 8/12/98 Date As Found
20 TRENDING BENEFITS Monitor performance of instrumentation to determine failure rates Provide pro-active maintenance schedules Identify measuring and test equipment errors leading to less re-calibrations or out of tolerance notices
21 GRAPHICAL RESULTS Two-Sided Calib. Point:
Pt-1 Pt-2 Pt-3 Pt-4 Pt-5 Ks Max/Min
-0.8000
-0.6000
-0.4000
-0.2000 0.0000 0.2000 0.4000 0.6000 0.8000 Pt-1 Pt-2 Pt-3 Pt-4 Pt-5 Calib. Point Delta % Span Ks Max Ks Min Xbar
22 Question 8 (Cont.)
- Surveillance results compared with TIU values including most current drift values
- Values found outside of TIU are entered into the Ginna corrective action program
- Drift results are periodically reviewed
23 Question 9
- Ginna does the following for Allowable Value (AV) calculations:
Includes conservative number of parameters to what ISA S67.04 Part II includes:
- Drift
- Accuracy
- Setting Tolerance
24 Question 9 (Cont.)
Same methodology used to calculated AV as Total Loop Uncertainty - SRSS - not arithmetic Additional margin added to calculated setpoint in most cases COT calibration limit including plant specific drift and Ginna corrective action program is station assurance that AV is not challenged.
25 PROCESS UNCERTAINTIES MEASUREMENT UNCERTAINTIES PROCESS PARAMETER CALIBRATION SOURCE SENSOR SIGNAL PROCESSING INPUT TRIP UNIT INDICATOR TRIP LOGIC FINAL DEVICE Example I&C Loop
26 A.
Allowance described in paragraph 4.3.1 B.
Allowance described in paragraph 4.3.2 C.
Region where channel may be determined inoperable D.
Plant operating margin E.
Region of calibration tolerance (acceptable as left condition) described in paragraph 4.3.1 F.
Safety margin Normal D
A C
B E
Trip Setpoint (LSSS)
Allowable Value (LSSS)
Safety limit Analytical limit F
Setpoint Relationships (ANSI/ISA S67.04.01-1994)
27 PZR High Pressure Trip Setpoint 2735 psig Safety Design Limit 2410 psig Analytical Limit 2406 psig Allowable Value 2396 psig Calculated Setpoint 2377 psig Nominal Setpoint 2310 psig Pre-trip Alarm 2235 psig Normal Operation
28 Allowable Value Methodology
- Important Points for ITS Allowable Value is used for determination of past operability Overall setpoint uncertainty methodology and Allowable Value Methodology is conservative All existing nominal setpoints have been shown to be conservative with new calculation Surveillances are generally performed quarterly
29 AV Methodology (Cont.)
- Important Points (Cont.)
Statistical drift monitoring is in place Corrective action program ensures that appropriate corrective actions are implemented in a timely manner A number of other utilities have approved use of method 3 methodology for AV determination in ITS and 24 Month Extensions
30 AV Methodology(Cont.)
- Difference in statistical analysis of large errors vs.
small:
CASE 1:
- TLU = (62 + 12 + 12 + 12) 1/2 = 6.25
- AV = (12 + 12) 1/2 = 1.41 CASE 2:
- TLU = (12 + 12 + 12 + 12) 1/2 = 2.00
- AV = (12 + 12) 1/2 = 1.41
31 Question 10
- Yes - selected method at Ginna per EP-3-S-505, Rev. 1 uses Method 3 with conservative number of allowances included in the AV calculations
- Upgraded calculations using plant specific drift methodologies per Generic Letter 91-04 and kept same setpoints for conservatism in as many cases as possible
32 Question 11 Setpoint methodology at Ginna meets the 95/95 confidence and probability levels for safety related setpoints following Reg. Guide 1.105 and Generic Letter 91-04 for 24 month nominal surveillance interval Reg. Guide 1.105 Rev. 3 endorses ISA S67.04 Part I NRC DOCUMENTS
Rx Vessel SG RCP PRZ RHRP & HX SIP PT 945 Containment Sump Electrical Penetration QH Hd R Auxiliary Bldg Containment Bldg CSP RWST Reactor Bldg CCWS Notes:
- 1. P-945 Safety Functions
- a. Initiate SI at 4 psi
- b. Initiate FW isolation at 4 psi
- c. Initiate CS at 28 psi
- 3. P-945 Uncertainty Calculations Per RG&E TLUA = TLUN Per ISA TLUA > TLUN (conservatively account for possible environmental effects (T, R, Hd ) due to HELB inside containment)
Typical PWR Plant Schematic cot U
psi
= +/- 11 pt U
psi
=
+/- 0 85 PQ U
psi
=
+/- 0 0 PM U
psi
=
+/- 0 0 1.
INPUT DATA:
Per RG&E Set Point Calculation Procedure, DA-EE-92-041-21 Bistable + Test Resistor Uncertainty Pressure Transmitter Uncertainty Power Supply Uncertainty Isolation Amplifier Uncertainty PC 945 A/B PQ 945 PT 945 Safety Injection FW Isolation 4 psig Containment Spray 28 psig Bistable
+/- 1.1 psi Containment Pressure Instrument Loop Block Diagram COT Components Pressure Transmitter
+/- 0.85 psi TP 945 10 Isolation Amplifier Power Supply PM 945 TLU U
U U
U psi pt pq pm
= +/-
+
+
+
=
+/-
+
=
+/-
cot 2
2 2
2 2
=
=
=
psi cot
=
+
=
+
=
4 61 1 1 5 72 RG E RG E SM AL AV psi
=
=
=
6 0 5 72 0 28 RG&E SETPOINT METHODOLOGY 2.
TOTAL LOOP UNCERTAINTY 3.
BISTABLE CALCULATED SETPOINT 4.
ALLOWABLE VALUE (RG&E) 5.
SAFETY MARGIN (RG&E)
ANSI/ISA - RP67.04 SETPOINT METHODOLOGY 1.
REQUIRED SAFETY MARGIN A.
Per ISA the required safety margin must account for the uncertainties associated with design-basis events. All other uncertainties are accounted for by performing surveillance testing of the complete instrument loop (i.e., a reference signal is applied to the pressure transmitter input and the difference between the voltage level at which the bistable changes state and the desired voltage level is measured).
Therefore, in accordance with ANSI/ISA - RP67.04 the required safety margin if the complete instrument loop is tested is defined as:
ISA A
N SM TLU TLU see Eq pg ANS ISA RP
= +/-
2 2
15 111 6704
(
/
)
B.
In practice the complete instrument loop is not tested during surveillance testing.
The reference signal is applied only to the bistable/resistor combination and the setpoint deviation measured. This partial test of the instrument loop is called the Channel Operability Test (COT) and is use to verify that the uncertainties associated with the bistable setpoint is within its normal operating range (+/- 1.1 psi). The COT is performed on a quarterly basis. The required safety margin for the COT is defined as:
cot cot SM TLU U
A
= +/-
2 2
This equation for the COT safety margin accounts for all uncertainties due to design-basis event effects, if applicable, plus those components not tested during the COT (pressure transmitter, power supply, isolation amplifier, etc),
For example, RG&E claims that PT-945 is not located in a harsh environment and, therefore, TLUA = TLUN. For these conditions the COT safety margin is equal to:
cot cot SM TLU U
N
= +/-
2 2
cot SM psi
= +/-
= +/-
2 2
1 39 11 0 85 2.
ALLOWABLE VALUE The allowable value is equal to the Analytical Limit (AL) minus the Required Safety Margin (SM cot):
=
=
=
cot 60 085 515
SUMMARY
Method 1 (ANSI / ISA - RP67.04)
Method 2 (RG&E)
TLU = 1.39 psi TLU = 1.39 psi SM = 0.85 psi SM = 0.28 psi 0.54 psi 1.1 psi AL = 6.0 psi AL = 6.0 psi AV = 5.15 psi AV = 5.72 psi Calculated SP = 4.61 psi Calculated SP = 4.61 psi Actual SP = 4.0 psi 1.71 psi Calibration Band PROPOSED SOLUTION Method 3 TLU = 1.39 psi SM = 0.85 psi 0.54 psi Calibration Band AL = 6.0 psi AV = 5.15 psi Calculated SP = 4.61 psi 1.1 psi Proposed Actual SP = 4.05 psi