ML100750522

James A. FitzPatrick, Response to Request for Additional Information Application for Amendment to Modify Technical Specifications Requirements for Testing of the Shutdown Cooling System Isolation, Reactor Pressure - High Function

ML100750522
Person / Time
Site:	FitzPatrick
Issue date:	03/05/2010
From:	Peter Dietrich Entergy Nuclear Northeast, Entergy Nuclear Operations
To:	Document Control Desk, Office of Nuclear Reactor Regulation
References
JAFP-10-0033, TAC ME1819
Download: ML100750522 (6)

Text

SEntergy Entergy Nuclear Northeast Entergy Nuclear Operations, Inc.James A. FitzPatrick NPP P.O. Box 110 Lycoming, NY 13093 Pete Dietrich Site Vice President

-JAF JAFP-10-0033 March 5, 2010 United States Nuclear Regulatory Commission Attn: Document Control Desk Washington, D.C. 20555

References:

Response to Request for Additional Information Re: James A. FitzPatrick Nuclear Power Plant Application for Amendment to Modify the Technical Specifications Requirements for Testingof the Shutdown Cooling System Isolation, Reactor Pressure -High Function (TAC No. ME1 819)James A. FitzPatrick Nuclear Power Plant Docket No. 50-333 License No. DPR-59 1. Entergy Letter, JAFP-09-0086, Application for Amendment to Modify the Technical Specifications Requirements for Testing of the Shutdown Cooling System Isolation, Reactor Pressure -High Function (TAC No. ME1819), dated July 31, 2009 2. NRC Request For Additional Information Regarding James A. FitzPatrick Nuclear Power Plant Application for Amendment to Modify the Technical Specifications Requirements for Testing of the Shutdown Cooling System Isolation, Reactor Pressure -High Function (TAC No. ME1 819), dated February 2, 2010

Dear Sir or Madam:

On July 31, 2009 Entergy Nuclear Operations, Inc. (ENO), submitted an application for amendment to the Technical Specifications (TS) for the James A. FitzPatrick Nuclear Power Plant (JAF), to revise the surveillance testing requirements for the Shutdown Cooling System Isolation, Reactor High Pressure Function (Reference 1). On February 2, 2010, JAF received a request for additional information from the Nuclear Regulatory Commission (NRC) staff (Reference 2). The request was subsequently clarified in a conference call with the staff on February 17, 2010.Based on the clarifying discussions with the staff, ENO is providing this response to the request for additional information.

Attachment 1 provides a response to each request for additional information question and Attachment 2 provides a copy of calculation JAF-CALC-NBS-02052, Revision 4.

JAFP-10-0033 Page 2 of 2 In accordance with 10 CFR 50.91, a copy of this revised application, with the associated attachments, is being provided to the designated New York State official.There are no new commitments made in this letter.Questions concerning this report may be addressed to Mr. Joseph Pechacek, Licensing Manager, at (315) 349-6766.I declare under penalty of perjitly that the foregoing is true and correct.Executed onettte davy lMarch 2010.Pete Dietrich Site Vice President

-JAF PAD/JtP/e d Attachments:

1. Responses to Request for Additional Information Questions 2. Calculation JAF-CAL-NBS-02052, Revision 4 cc: next page Mr. Samuel Collins Regional Administrator, Region I U. S. Nuclear Regulatory Commission 475 Allendale Road King of Prussia, PA 19406-1415 Mr. Bhalchandra Vaidya, Project Manager Plant Licensing Branch 1--Division of Operating Reactor Licensing Office of Nuclear Reactor Regulation U.S. Nuclear Regulatory Commission Mail Stop O-8-C2A Washington, DC 20555-0001 Resident Inspector's Office U.S. Nuclear Regulatory Commission James A. FitzPatrick Nuclear Power Plant P.O. Box 136 Lycoming, NY 13093 Mr. Paul Eddy New York State Department of Public Service 3 Empire State Plaza, 10th Floor Albany, NY 12223 Mr. Francis J. Murray Jr., President New York State Energy and Research Development Authority 17 Columbia Circle Albany, NY 12203-6399 JAFP-1 0-0033 Attachment 1 Responses to Request for Additional Information Questions (3 Pages)

JAFP-1 0-0033 Attachment 1 Question: "Provide the summary calculation for the new design employing inputs from the existing reactor steam dome pressure transmitters instead of the existing pressure switches.

The summary calculation should provide setpoint methodology and the basis for calculating design limit, limiting setpoint, nominal setpoint, allowable value, acceptable as found tolerance band, and acceptable as left band." Response: Calculation JAF-CALC-NBS-02052, Revision 4 is provided as Attachment 2 to this letter. This calculation conforms to Entergy procedure EN-DC-126 (Ref. 4.2.2 in the attached calculation), which provides a single process governing preparation, revision, review, approval and use of engineering calculations.

The guidance and methodology utilized in this calculation are from Entergy procedure ENN-IC-G-003 (Ref. 4.2.1 in the attached calculation).

The guide provides basic terminology for determination of instrument uncertainties, loop uncertainties, instrument setpoints, and instrument setpoint attributes.

It further provides the methods that are to be utilized in the preparation of loop accuracies and setpoints.

ISA 67.04 methodology (referenced in ENN-IC-G-003) was utilized in this calculation.

This includes using ISA 67.04 guidance in the following areas: a) Methodologies, including sample equations, to calculate total channel uncertainty.

b) Common assumptions and practices in instrument uncertainty calculations.

c) Equations for estimating uncertainties for commonly used analog and digital modules.d) Methodologies to determine the impact of commonly encountered effects on instrument uncertainty.

e) Application of instrument channel uncertainty in setpoint determination.

f) Sources and interpretation of data for uncertainty calculations.

g) Discussion of the interface between setpoint determination and plant-operating procedures, calibration procedures, and accident analysis.h) Documentation requirements.

Page 1 of 3 JAFP-1 0-0033 Attachment 1 Question: "Describe the measures to be taken to ensure that the associated instrument channel is capable of performing its specified safety functions in accordance with applicable design requirements and associated analysis.

Include in your discussion information on the controls you employ to ensure that the as left trip setting after completion of periodic surveillance is consistent with your setpoint methodology.

Also, discuss the plant corrective action processes (including plant procedures) for restoring channels to operable status when channels are determined to be "inoperable" or "operable but degraded".

If the controls are located in a document other than the TS (e.g., plant test procedure), describe how it is ensured that the controls will be implemented." Response: Instrument channels are periodically tested in accordance with the station's Surveillance Test Program [Administrative Procedure (AP)-19.01].

Each surveillance requirement is fully tested via performance of a surveillance test procedure, or in cases of overlapping surveillances tests, multiple procedures.

The surveillance test procedures are developed in accordance with the station's "Procedure Writing Manual" (AP-02.01) and the "Control of Procedures" procedure (AP-02.04).

These documents require that procedures be developed that are adequate, technically accurate, complete, usable and that they conform to applicable standards, guidelines, industry practices and site specific documents such as licensing and design basis documents.

Additionally, these documents require independent reviews be performed for new and revised procedures to ensure they are adequate, technically accurate, complete, usable and they conform to station documents including licensing and design basis documents.

For station modifications, such as the relocation of the Shutdown Cooling pressure switches, the Engineering Change and associated calculations which evaluated and documented the plant, configuration change are used as the primary technical bases for the procedure acceptance criteria.Surveillance procedures require additional adequacy reviews to ensure surveillance requirements are fully satisfied.

These reviews consist of a Technical Review, a Technical Specification/Technical Requirements Manual Comparison and a Logic System Functional Test review. These reviews also require an independent review by the applicable System Engineer to ensure all requirements are satisfied.

The review guidance contains specific attributes to ensure items such as set points, tolerance bands, and numerical values are accurate as well as verification that the entire scope of the surveillance requirement is tested.The conduct of Surveillance Test procedures in the field is controlled via station procedures including the "Surveillance Test Program" and "Fundamentals of Maintenance" (EN-MA-101).

Test personnel are required to notify supervision of any parameter response that is different than expected and also immediate notification of the Operation Shift Manager or the Control Room Supervisor in the event that acceptance criteria is not satisfied.

Each surveillance test procedure contains steps to ensure the instrument tested is returned to the proper operational configuration.

Assurance that direction for restoration is included in the surveillance test procedure is provided by the technical and adequacy reviews.Page 2 of 3 JAFP-1 0-0033 Attachment 1 Following performance of the Surveillance Test, station procedure "Work Implementation and Closeout" (EN-WM-102) requires the discipline supervisor to review the completed procedure to ensure acceptance criteria was satisfied and that "As-Found" and "As-Left" values are within their required tolerance.

Surveillance Test procedures are also required to be reviewed by the Operations department in order to declare the tested equipment OPERABLE.In the event that surveillance acceptance criterion is not met, procedures including the Surveillance Test Program and the Corrective Action Program (EN-LI-102) require a Condition Report be initiated to document the failure to meet acceptance criteria.

Condition Reports are reviewed by the Operation staff for impact on OPERABILITY.

If a Condition Report documents that an instrument failed to meet Level 1 acceptance criteria and could not be restored to within tolerance, the instrument would be declared INOPERABLE and the appropriate Condition associated with the applicable Limiting Condition for Operation (LCO) would be entered. Once an instrument and/or system has been declared INOPERABLE, the LCO Condition can not be exited until the instrument and/or system meets all Surveillance Requirements to establish OPERABILITY.

In cases where the.instrument can be adjusted to within tolerance, the instrument would not be declared INOPERABLE; however, the potential impact on past OPERABILITY would be evaluated as part of the Corrective Action program.Page 3 of 3