ML052420132

Change & Surveillance Requirement for Reactor Trip Circuit Breakers - Supplemental Information

ML052420132
Person / Time
Site:	Calvert Cliffs
Issue date:	08/26/2005
From:	Joseph E Pollock Constellation Energy Group
To:	Document Control Desk, Office of Nuclear Reactor Regulation
References
Download: ML052420132 (6)

Text

Calvert Cliffs Nuclear Power Plant 1650 Calvert Cliffs Parkway Constellation Generation Group, LLC Lusby, Maryland 20657 Constellation Energy August 26, 2005 U. S. Nuclear Regulatory Commission Washington, DC 20555 ATTENTION: Document Control Desk

SUBJECT:

Calvert Cliffs Nuclear Power Plant Unit Nos. I & 2; Docket Nos. 50-317 & 50-318 Change a Surveillance Requirement for Reactor Trip Circuit Breakers -

Supplemental Information

REFERENCES:

(a) Letter from Mr. G. Vanderheyden (CCNPP) to Document Control Desk (NRC), dated August 3, 2004, License Amendment Request: Change a Surveillance Requirement for Reactor Trip Circuit Breakers (b) Letter from Mr. G. Vanderheyden (CCNPP) to Document Control Desk (NRC), dated July 8, 2005, Change a Surveillance Requirement for Reactor Trip Circuit Breakers - Supplemental Information Reference (a) submitted a request to change the frequency of the surveillance test interval for the reactor trip circuit breakers (RTCB) from 31 days to 92 days. This requested change was based on topical report CE NPSD-95 1-A, Revision 01, "Reactor Trip Circuit Breakers Surveillance Frequency Extension."

Supplemental information was provided in Reference (b). Subsequent discussion with the Nuclear Regulatory Commission (NRC) staff has resulted in the need to provide supplemental information for our original request. Changes to the marked up Technical Specification page are contained in Attachment (1) and supersede those provided in Reference (b).

In Reference (a), we proposed extending the RTCB testing (Surveillance Requirement [SR] 3.3.3.1) from monthly to quarterly and alternating the testing with the RTCB logic testing (SR 3.3.3.2). The alternating testing was proposed so the RTCB reliability to trip on demand would be verified approximately every six weeks instead of every three months. This testing schedule is supported by the approved topical report, CE NPSD-95 I-A, Revision 01, "Reactor Trip Circuit Breakers Surveillance Frequency Extension."

We proposed putting the requirements to alternate the testing in the Technical Specification Bases (Reference a), but did not submit the proposed Technical Specification Bases changes. Since the requirement to alternate surveillance testing is described in the topical report and demonstrates the vendor recommended interval for cycling of each RTCB, we are submitting the marked up Technical Specification Bases changes to the NRC Staff showing how we will capture the appropriate testing intervals. The marked up Technical Specification Bases changes are also contained in Attachment (1).

Note that the Technical Specification Bases are controlled in accordance with Technical Specification 5.5.14, "Technical Specification Bases Control Program."

P&D

Document Control Desk August 26, 2005 Page 2 The information contained in this letter does not affect the No Significant Hazards Determination or the Environmental Consideration provided in Reference (a).

Should you have questions regarding this matter, please contact Mr. L. S. Larragoite at (410) 495-4922.

Very truly yours, ph E. Pollock Plant General Manager STATE OF MARYLAND

TO WIT:

COUNTY OF CALVERT I, Joseph E. Pollock, being duly sworn, state that I am Plant General Manager - Calvert Cliffs Nuclear Power Plant, Inc. (CCNPP), and that I am duly authorized to execute and file this License Amendment Request on behalf of CCNPP. To the best of my knowledge and belief, the statements contained in this document are true and correct. To the extent that these statements are not based on my personal knowledge, they are based upon information provided by other CCNPP employees and/or consultants.

Such information has been reviewed in accordance with company practice and I believe it to be reliable.

Subscribed and sworn before me a Notary P blic in and for the State of Maryland and County of 57 f 2 this d day of c ,2005.

( / /

WITNESS .my Hand and Notarial Seal:

Notary Publics My Commission Expires: cl 625 oo I aDe JEPIPSF/bjd

Attachment:

(1) Marked-up Technical Specification Page and Marked-up Technical Specification Bases Pages cc: P. D. Milano, NRC Resident Inspector, NRC S. J. Collins, NRC R. 1.McLean, DNR

ATTACHMENT (1)

MARKED-UP TECHNICAL SPECIFICATION PAGE AND MARKED-UP TECHNICAL SPECIFICATION BASES PAGES 3.3.3-2 B 3.3.3-11 B 3.3.3-12 Calvert Cliffs Nuclear Power Plant, Inc.

August 26,2005

RPS Logic and Trip Initiation 3.3.3 ACTIONS (continued)  ;

CONDITION REQUIRED ACTION COMPLETION TIME D. Two channels of RTCBs D.1 Open the affected Immediately or Trip Path Logic RTCBs.

affecting the same trip leg inoperable.

E. Required Action and E.1 Be in MODE 3. 6 hours6.944444e-5 days <br />0.00167 hours <br />9.920635e-6 weeks <br />2.283e-6 months <br /> associated Completion Time of Condition A, AND B, or D not met.

E.2 Open all RTCBs. 6 hours6.944444e-5 days <br />0.00167 hours <br />9.920635e-6 weeks <br />2.283e-6 months <br /> OR One or more Functions with two or more Manual Trip, Matrix Logic, Trip Path Logic, or RTCB channels inoperable for reasons other than Condition A or D.

SURVEILLANCE REQUIREMENTS SURVEILLANCE FREQUENCY SR 3.3.3.1 Perform a CHANNEL FUNCTIONAL TEST on each RTCB channel.

SR 3.3.3.2 Perform a CHANNEL FUNCTIONAL TEST on each 92 days RPS Logic channel.

CALVERT CLIFFS - UNIT 1 3.3.3-2 Amendment No. 227 CALVERT CLIFFS - UNIT 2 Amendment No. 201

RPS Logic and Trip Initiation B 3.3.3 BASES one manual trip, matrix logic, trip path logic, or RTCB channel is inoperable for reasons other than Condition A or D.

If the RTCBs associated with the inoperable channel cannot be opened, the reactor must be shut down within 6 hours6.944444e-5 days <br />0.00167 hours <br />9.920635e-6 weeks <br />2.283e-6 months <br /> and all the RTCBs opened. A 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 the required MODE from full power conditions in an orderly manner, without challenging plant systems, and to open RTCBs. All RTCBs should then be opened, placing the plant in a MODE where the LCO does not apply and ensuring no CEA withdrawal occurs.

SURVEILLANCE SR 3.3.3.1 REQUIREMENTS A CHANNEL FUNCTIONAL TEST is performed on each RTCB channel e days. This verifies proper operation of each RTCB.

qZ The RTCB must then be closed prior to testing the other RTCBs, or a reactor trip may result. The frequency of days is bae o h -libl'

<~s°->F Is x;g- e erv<3. ,

S ..2%ervdoxr r i dz~ -o-^ls~G- c~c.Avy of e m /~~c A~~o eCHNE P logcT c~-T annel isl performed every 92 days to ensure the entire channel will perform its intended function when needed.

In addition to reference voltage tests, the RPS CHANNEL FUNCTIONAL TEST consists of three overlapping tests as described in Reference 1, Section 7.2. These tests verify that the RPS is capable of performing its intended function, from bistable input through the RTCBs. The first test, the instrument channel test, is addressed by SR 3.3.1.4 in 3 LCO 3.3.1.

St 3.3.3.Q sand ta ~ it' This SR addresses the two tests associated with the RPS i~TC..QS 4t~v~ '6 ?P 9r

-- t nlfrmbsalHipttruhthOTW.Tefis ogic: matrix logic and trip path logic.l et h c4 Aces4 evcs-. Wa ML*5 vJtrctor ocO~- ~ M~atrix Loaic Tests These tests are performed one matrix at a time. They verify perthat a coincidence in the two instrument channels for each CAaETCLFFRPUITs ca2abl3f3r3-1 Rneviion,2 CALVERT CLIFFS - UNITS 1 & 2 B 3.3.3-11 Revision 2

RPS Logic and Trip Initiation B 3.3.3 BASES Function removes power from the matrix relays. During testing, power is applied to the matrix relay test coils and prevents the matrix relay contacts from assuming their de-energized state. The matrix logic tests will detect any short circuits around the bistable contacts in the coincidence logic such as may be caused by faulty bistable relay or trip bypass contacts.

Trip Path Tests These tests are similar to the matrix logic tests, except that test power is withheld from one matrix relay at a time, allowing the trip path circuit to de-energize, opening the affected set of RTCBs. The RTCBs must then be closed prior to testing the other three trip path circuits, or a reactor trip may result.

The Frequency of 92 days is based on the reliability analysis presented in Reference-l SR 3.3.3.3 A CHANNEL FUNCTIONAL TEST on the manual trip channels is performed prior to a reactor startup to ensure the entire channel will perform its intended function if required. The manual trip Function can be tested either at power or shut down. However, the simplicity of this circuitry and the absence of drift concern makes this Frequency adequate.

Additionally, operating experience has shown that these components usually pass the SR when performed once within 7 days prior to each reactor startup.

REFERENCES 1. UFSAR

2. 10 CFR Part 100, "Reactor Site Criteria" Combustion Engineering Topical Report CEN-327,

/ "RPS/ESFAS Extended Test Interval Evaluation" dated

( June 2, 1986, including Supplement 1, March 3, 1989 (a TVeirttp It Ct~v~ i~ts Sur-vc8tkseu Frc.y n UITS1 & B .3.312 evison CIFF CALVERTCALVRT CLIFFS - UNITS 1 & 2 B 3.3.3-12 Revision 2