ML20034E804

Proposed Tech Specs SR 4.9.G.1 & Associated Bases Re Electrical Protective Assemblies Surveillance Interval

ML20034E804
Person / Time
Site:	FitzPatrick
Issue date:	02/22/1993
From:	POWER AUTHORITY OF THE STATE OF NEW YORK (NEW YORK
To:
Shared Package
ML20034E797	List: JPN-93-005, Forwards Application for Amend to License DPR-59,revising SR 4.9.G.1 & Associated Bases Using Guidance in GL 91-09, Mod of Surveillance Interval for Electrical Protective Assemblies in Power Supplies for Rps ML20034E803 ML20034E804
References
NUDOCS 9303010389
Download: ML20034E804 (13)

Text

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f ATTACHMENT I to JPN-93-005 PROPOSED TECHNICAL SPECIFICATION CHANGES ELECTRICAL PROTECTIVE ASSEMBLIES (EPAs)

SURVEILLANCE INTERVAL I

(JPTS-91-010) i l

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1 New York Power Authority JAMES A. FITZPATRICK NUCLEAR POWER PLANT Docket No. 50-333 DPR-59 9303010389 930222 PDR ADOCK 05000333 P

PDR

r JAFNPP 3.9 (cont'd) 4.9 (cont'd) 3.

From and after the time both power supplies are made or found inoperable the reactor shall be brought to cold condition within 24 hours2.777778e-4 days <br />0.00667 hours <br />3.968254e-5 weeks <br />9.132e-6 months <br />.

G.

REACTOR PROTECTION SYSTEM ELECTRICAL PROTECTION G,

REACTOR PROTECTION SYSTEM ELECTRICAL PROTECTION ASSEMBLIES ASSEMBLIES Two RPS electrical protection assemblies for each inservice The RPS electrical protection assemblies instrumentation shall RPS MG set and inservice alternate source shall be operable be determined operable by:

except as specified below:

1.

Performing a channel functional test each time the plant is 1.

With one RPS electrical protection assembly for an in cold shutdown for a period of more than 24 hours2.777778e-4 days <br />0.00667 hours <br />3.968254e-5 weeks <br />9.132e-6 months <br />, inservice RPS MG set or an inservice alternate power unless performed in the previous 6 months.

supply inoperable, restore the inoperable channel to operable status within 72 hours8.333333e-4 days <br />0.02 hours <br />1.190476e-4 weeks <br />2.7396e-5 months <br /> or remove the associated 2.

At least once per operating cycle, demonstrating the RPS MG set or alternate power supply from service, operability of over-voltage, under-voltage and under-frequency protective instrumentation by 2.

With two RPS electrical protection assemblies for an performance of a channel calibration including simulated inservice RPS MG set or an inscrvice alternato power automatic actuation of the protective relays, tripping logic supply inoperable, restore at least one to operable status and output circuit breakers and verifying the following within 30 minutes or remove the associated RPS MG set set points:

or alternate power supply from service.

RPS MG SET SOURCE OVER-VOLTAGE s132V s4 second Time Delay l

UNDER-VOLTAGE 2108V s4 second Time Delay l

UNDER-FREQUENCY 257HZ

$4 second Time Delay l

Amendment No.

(continued on page 222d) 222c

JAFNPP 4.9 BASES (con't)

D.

Battery System Measurements and electrical tests are conducted at specified intervals to provide indication of cell condition and to determine the discharge capability of the batteries. Performance and service tests are conducted in accordance with the recommendations of IEEE 450-1987.

E.

LPCI MOV Indeoendent Power Sucolv Measurement and electrical tests are conducted at specified intervals to provide indication of cell condition, to determine the discharge capab:lity of the battery.

Performance and service tests are conducted in accordance with the recommendations of IEEE 450-1987.

F.

Reactor Protection Power Sunolies Functional tests of the electrical protection assemblies l

are conducted at specified intervals utilizing a built-in test device and once per operating cycle by performing an instrument calibration which verifies operation within the limits of Section 4.9.G.

Amendment No. p,7f, If4,1f7, 226

Attachment il to JPN-93-005 SAFETY EVALUATION FOR PROPOSED TECHNICAL SPECIFICATION CHANGES ELECTRICAL PROTECTIVE ASSEMBLIES (EPAs)

SURVEILLANCE INTERVAL (JPTS-91-0101 1.

DESCRIPTION OF THE PROPOSED CHANGES The proposed change to the James A. FitzPatrick Technical Specifications revises the surveillance interval for electrical protective assemblies (EPAs) for the Reactor Protection System (RPS). The proposed change is addressed below.

Minor changes in format, such as type font, margins or hyphenation, are not described in this submittal. These changes are typographical in nature and do not affect the content of the Technical Specification.

Paae 222c. Specification 4.9.G.1.

Replace the specification:

"At least once every 6 months, performing a channel functional test."

with:

" Performing a channel functional test each time the plant is in cold shutdown for a period of more than 24 hours2.777778e-4 days <br />0.00667 hours <br />3.968254e-5 weeks <br />9.132e-6 months <br />, unless performed in the previous 6 months."

Paae 222c Soecification 4.9.G.2.

Replace "s" with "second" in three locations.

Paae 226. Bases 4.9.F in the first sentence, replace the phrase "once each six (6) months" with the phrase "at specified intervals."

11. PURPOSE OF THE PROPOSED CHANGES Electrical protective assemblies (EPAs) are used in the power supplies for the Reactor Protective System (RPS). The EPAs ensure that RPS components are protected from abnormal voltages or frequencies from the RPS motor generator (MG) set or the alternate power supplies. The EPAs protect the RPS components by tripping a breaker between the MGs and the RPS when abnormal voltages or frertuencies are encountered.

Generic Letter 91-09 (Reference 1) encouraged Licensees to propose Technical Specification changes to modify the surveillance interval of EPAs used in power supplies for the RPS. Standard Technical Specifications (Reference 2) require channel functional testing of EPAs at six month intervals. The Generic Letter allows changing the test interval to require testing every time the plant is in cold shutdown for more than 24 hours2.777778e-4 days <br />0.00667 hours <br />3.968254e-5 weeks <br />9.132e-6 months <br />, unless testing was performed in the previous 6 months. This change was identified as a line item improvement in the STS.

Attachment il to JPN-93-005 SAFETY EVALUATION Page 2 of 5 The purpose of this Technical Specification change request is to implement the guidance of the Generic Letter at the FitzPatrick plant. Technical Specification 4.9.G.1 currently requires a channel functional test every 6 months regardless of whether or not the plant is operating. A minor editorial change is also being made for clarity by changing an "s" to "second."

l11. SAFETY IMPLICATIONS OF THE PROPOSED CHANGES The Authority has reviewed plant design and operating event reports to assess the effects on plant safety associated with a change to the testing interval. The small risks of the increased testing period are outweighed by the reduced possibility of inadvertent trips that challenge safety systems. The Generic Letter and its conclusions are applicable to the FitzPatrick plant.

Generic Letter 91-09 identifies a safety concern with the transfer of power supplies to the RPS when testing an EPA channel. The transfer is a dead-bus transfer and the momentary interruption of power results in a half scram rand half isolation. The Generic Letter notes that many plants have encountered problems with the reset of the half trip resulting in inadvertent scrams and group isolations that challenge safety systems during power operation. Testing during cold shutdown eliminates this safety concern.

i If there is no cold shutdown of 24 hours2.777778e-4 days <br />0.00667 hours <br />3.968254e-5 weeks <br />9.132e-6 months <br /> or more during a fuel cycle, the proposed change can result in an increase in the testing period from 6 months up to 18 months.

The Generic Letter concluded that the increased testing period would be of small risk to i

safety and that the limitation of testing to periods of cold shutdown would provide a positive safety benefit by reducing the possibility of inadvertent trips and challenges to safety systems. The benefit to safety of eliminating testing during power operation more than offsets the risk to safety from relaxing the surveillance test interval.

The results of a review by the Authority indicate that the conclusions of the Generic Letter are applicable to the FitzPatrick plant. The review identified the following factors The plant is designed so that interruption of power results in a half scram and half isolation. The plant procedure for functionally testing an EPA channel (Reference 3) requires transfer of power sources resulting in a momentary half scram and half isolation. The situation identified in the Generic letter is, therefore, applicable.

No plant events have been identified where testing the EPAs at power has resulted in a scram. This does not mean that such an event will not occur in the future. The Generic Letter is, therefore, applicable.

Testing at cold shutdown does not present the risk of reactor scram with a l

resulting cha!!enge to safety systems. This provides a positive safety benefit.

The HPCI, RCIC, RWCU and shutdown cooling systems are designed with a one-out

-of-two or more isolation logic. These systems receive an isolation signal during the test. The proposed change provides a positive safety benefit because the HPCI, RCIC and RWCU systems are not required in cold shutdown.

Attachment il to JPN-93-005 l

SAFETY EVALUATION Page 3 of 5 j

i During cold shutdown and refueling, the shutdown cooling function is required.

Shutdown cooling is isolated with the de-energization of a RPS bus. Shutdown cooling isolation valve 10-MOV-18 closes with a loss of RPS bus "A" and valve 10-MOV-17 closes with a loss of RPS bus "B." There have been events (References 4,5 and 6) where momentary power interruption to the isolation logic resulted in shutdown cooling isolation during cold shutdown. Corrective action has l

been taken to prevent a recurrencs.

The potential for isolation of shuu.own cooling exists every refueling outage. The potential for isolation of shutdown cooling is slightly increased by the new requirement for testing during periods of cold shutdown that exceed 24 hours2.777778e-4 days <br />0.00667 hours <br />3.968254e-5 weeks <br />9.132e-6 months <br />. This can occur up to two times (after the first and second six months of a fuel cycle) between refuel outages. Planned mid cycle maintenance outages will be one time when testing is required. If inadvertent isolation occurs during this testing, the isolation is readily correctable. The event requires operator action (reset the isolation and reopen valves) and is less significant than a scram and/or isolation at power which challenges safety systems. The potential for isolation of shutdown cooling does not change the conclusions of the Generic Letter that the benefit to safety of eliminating testing at power offsets the risk to safety of rehixing the test interval.

The changes do not effect the conclusions of the plants accident analyses as documented in the updated FSAR or the NRC staff SER.

The editorial change has no safety significance. It serves to clarify the Specification since "s" is not a comrnon abbreviation for second.

IV. EVALUATION OF SIGNIFICANT HAZARDS CONSIDERATION Operation of the FitzPatrick plant in accordance with the proposed Amendment would nct involve a significant hazards consideration as defined in 10 CFR 50.92, since it would not:

1. involve a significant increase in the probability or consequences of an accident previously evaluated.

The proposed changes revise the testing frequency for the electrical protective assemblies (EPAs) for the Reactor Protection System (RFS). These changes are in accordance with Generic Letter 01-09. There are no changes to plant design or operation. Increasing the test interval up to 18 months pror' ces a small increase in probability that an inoperable EPA would not be detected. I creased testing during cold shutdown produces a smallincrease in probability 11 shutdown cooling can be isolated. These risks are offset by eliminating the possibility of trips due to j

testing during power that would challenge safety systems.

2. create the possibility of a new or different kind of accident from any accident previously evaluated.

The prooosed change will not change design, operation or the testing process. The

A7tachment il to JPN-93-005 SAFETY EVALUATION Page 4 of 5 change to testing intervals will not effect any condition that could result in a new or different type of accident.

3. involve a significant reduction in a margin of safety.

The testing of each EPA channelinvolves a dead-bus transfer and the momentary l

interruption of power results in a half scram and half isolation. Generic Letter 91-09 notes that many plants have encountered problems with the reset of the half trip resulting in inadvertent scrams and group isolation that challenge safety systems during power operation. Eliminating EPA testing at power operation increases the margin of safety by eliminating the potential for trips due to testing that challenge safety systems. An insignificant reduction in the margin of safety is introduced by increasing the test interval up to 18 months producing a small increase in risk that an inoperable EPA would not be detected. The elimination of potential challenges to safety systems provides a safety benefit that offsets the increased risks of component tailure and shutdown cooling isolation.

V. IMPLEMENTAT!ON OF THE PROPOSED CHANGES Implementation of the proposed changes will not adversely affect the ALARA or Fire Protection Programs at the FitzPatrick plant, nor will the changes affect the environment. The proposed changes involve a change to the frequer.cy of testing. The l

testing is not performed in high radiation areas, will involve no modifications to plant systems or components and results in no plant discharges.

i VI. CONCLUSION The changes, as proposed, do not constitute an unreviewed safety question as defined in 10 CFR 50.59. That is, they:

1. will not change the probability nor the consequences of an accident or malfunctinq of equipment important to safety as previously evaluated in the Safety Analysis Report;

2. will not increase the possibility of an accident or malfunction of a type different from any previously evaluated in the Safety Analysis Report; and

3. will not reduce the margin of safety as defined in the basis for any technica!

specification.

The changes involve no significant hazards consideration, as defined in 10 CFR 50.92.

Vll. REFERENCES

1. NRC Generic Letter 91-09, " Modification of Surveillance Interval for the Electrical Protective Assemblies in Power Supplies for the Reactor Protection System," dated June 27,1991.

i

Attachrnent 11 to JPN-93-005 SAFETY EVALUATION Page 5 of 5 i

2. NRC NUREG-1433, " Standard Technical Specifications for General Electric Boiling Water Reactors (BWR/4)," dated September 1992.

3. James A. FitzPatrick Nuclear Power Plant instrument Surveillance Procedure (ISP) 94, " Reactor Protection System Electrical Protection Assembly Functional Test / Calibration.

4. James A. FitzPatrick Nuclear Power Plant Licensee Event Report 92-047, t

" Automatic Shutdown Cooling isolation Due to Voltage Transient," dated December 4,1992.

5. James A. FitzPatrick Nuclear Power Plant Licenseo Event Report 92-046,

" Automatic Shutdown Cooling isolation Due to Procedure Deficiency," dated November 16,1992.

6. James A. FitzPatrick Nuclear Power Plant Licensee Event Report 90-013, Revision i

0, " Isolation of Shutdown Cooling System Due to Test Jumper Falling Off of isolation Logic Circuit," dated May 9,1990, i

7. James A. FitzPatrick Nuclear Power Plant Licensee Event Report 90-022, Revision i

1, " Engineered Safety Feature Actuation Due to Low Voltage Trip of Power Supply j

to Reactor Protection System," dated June 19,1991.

8. James A. FitzPatrick Nuclear Power Plant Updated Final Safety Analysis Report, i

Sections 4.8.6, 7.2.4, 7.3.4, 8.9 and Chapter 14.

9. James A. FitzPatrick Nuclear Power Plant Safety Evaluation Report (SER), dated November 20,1972, and Supplements.

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ATTACHMENT lli to JPN-93-005 I

PROPOSED TECHNICAL SPECIFICATION CHANGES ELECTRICAL PROTECTIVE ASSEMBLIES (EPAs)

SURVE!LLANCE INTERVAL MARKUP OF TECHNICAL SPECIFICATION PAGES (JPTS-91-010) i 1

I New York Power Authority JAMES A. FITZPATRICK NUCLEAR POWER PLANT Docket No. 50-333 DPR-59 l

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4.9 (cont'd) 3.9 (cont'd)

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From and after the time both power 3.

supplies are made or found inoperable I

the reactor shall be brought to cold MCN b condition within 24 hourn.

f G.

REACTOR PROTECTIOli SYSTEM EJECTRICAb r

R.EACTOR PROTECTIOtt SYSTEtt EtECTRICAl PitOTECTIO!I ASSEl1DLIES O.

PROTECTION ASSET 1RLIES Two RPS electrical protection anaemb-The RPS electrical protection annemblies lies for each innervice ItPS HG net instrumentation chall be determined And Jnoervice alternate nource el I be operable except an specified operable byr 1.

At least once every 6 montha, With one RPS clectrical protection performing a channel functional 1.

ansembly for an innervice RPS MG tent.

set or an Inservice alternate power least once por operating c'ycle, oupply inoperable, restore s_he 2.

At demonstrating the operability of inoperable channel to operable over-voltage, under-voltage and h~

.otatun within 72 hours8.333333e-4 days <br />0.02 hours <br />1.190476e-4 weeks <br />2.7396e-5 months <br /> or remove under-frequency protective instrumentatii the annociated RPS MG net or alternate power nupply from by performance of a channel calibration including nimulated automatic actuation service.

of the protective relays, tripping logic and output cJrcuit breakers and With two RPS cicetrical protection verifying the following not pointst 2..

nonemb11eo for an inservice itPS HG set or an Inservice alternate power supply inoperable, restore JtP_J,MG SET SOURCE at least one to operable status within 30 minuten or remove the

< 132V annociated RPG MG not or alternate OVER-VOLTAGE

._. <4, Time Delay _

power nupply from service.

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2100Vh UNDER-VObTAGE i

i G ETime Delay C

Ut3 DER-FREQUEtiCY 25711Z j

$4 -

1me Delay I

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222c (continued on page 222d)

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INSERT A l

Performing a channel functional test each time the plant is in cold shutdown for a period of l

more than 24 hours2.777778e-4 days <br />0.00667 hours <br />3.968254e-5 weeks <br />9.132e-6 months <br />, unless performed in the previous 6 months.

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JAFNPP 4.9 BASES (cont'd)

D.

Battery System Measurements and electrical tests are conducted at specified p

intervals to provido indication of cell condition and to determino the discharge capability of the batteries. Performance and service tests are conducted in accordance with the recommendations of IEEE 450-1987.

E.

LPCI MOV Independent Power Supply Measurement and electrical tests are conducted at specified intervals to provido indication of cell condition, to determine the dischargo capability of the battery. Performance and servico tests are conducted in accordance with the recommendations of IEEE 450-1987.

g F.

Reactor Protection Power Supplies b

Functional tests of the electrical protection assemblics are conducted (onco each six (6) montfib utilizing a built-in test device and onco pcFoperatingAcycle by performing an instrument calibration which verifies operation within the limits of Section 4.9.G.

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Amendment No. [,7,1[

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_ DISTRIBUTION LISI i

JAE NYD WEQ H. Salmon G. Goldstein R. E. Beedle R. Barrett A. Levine R. Converse l

D. Lindsey S. Zulla M. Colomb W. Josiger A. Zaremba J. A. Gray, Jr.

J.Hoddy T. Dougherty RMS R. Ram i

R. Fromm R. Lauman A. Klausmann l

F.Pesce i

J. Adams K. Mavrikis G. Wilverding J. B. Ellmers J. A. Greene I

M. Jacobs M. Mora A. Stewart H. Fish L. Labruzzo

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K. Kingsley r

J. Patel S. Prussman i

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Woge Ptacs New Yort 10601 914 681.5646 I

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& Authority Nxtea Gene a r February 22,1993 JPN-93-005 B

U.S. Nuclear Regulatory Commission l

ATTN: Document Control Desk Mail Station P1-137 Washington, D.C. 20555

SUBJECT:

James A FitzPatrick Nuclear Power Plant j

Docket No. 50-333 Proposed Change to the Technical Specifications l

Electrical Protective Assemblies (EPAs) l Surveillance interval (JPTS.91.Q1 Q1 f

REFERENCE:

1. NRC Generic Lettu 91-09, " Modification of Surveillance Interval for the Electrical Protective Assemblies in Power l

Supplies for the Reactor Protection System," dated June 27,1991.

I i

Dear Sir:

This applicetion for an amendment to the James A. FitzPatrick Technical

.i Specifications proposes to revise Surveillance Requirement 4.9.G.1 and I

associated Bases using the guidance of Generic Letter 91-09 (Reference 1).

I The Generic Letter allows a line item Technical Specification improvement by the elimination of testing for electrical protective assemblies (EPAs) during power operation. This change reduces the possibility of inadvertent reactor f

trips caused by testing of EPAs during power operation.

j i.

The signed original of the Application for Amendment to Operating License is enclosed for filing. Attachments I and 11 to this application contain

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the proposed changes to the Technical Specifications and the associated l

Safety Evaluation.

In accordance with 10 CFR 50.91, a copy of this application and the associated attachments are being provided to the designated New York

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State official.

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If you have any questions regarding the proposed changes, please

~I contact Mr. J. A. Gray, Jr.

Very truly yours, Y

- e Ralph E. Beedle

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att: as stated l

cc: Regional Administrator 6

U.S. Nuclear Regulatory Commission 475 Allendale Road King of Prussia, PA 19406 Office of the Resident inspector U.S. Nuclear Regulatory Commission P.O. Box 136 Lycoming, NY 13093 i

Mr. Brian C. McCabe Project Directorate 1-1 Division of Reactor Projects -l/Il U.S. Nuclear Regulatory Commission Mail Stop 14 B2 Washington, DC 20555 Ms. Donna Ross

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New York State Energ.: Office 2 Empire State Plaza 16* Floor

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Albany, NY 12223 i

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BEFORE THE UNITED STATES NUCLEAR REGULATORY COMMISSION In the matter of

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NEW YORK POWER AUTHORITY

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Docket No. 50-333 James A. FitzPatrick Nuclear Power Plant

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APPLICATION FOR AMENDMENT TO OPERATING LICENSE 1

The New York Power Authority requests an amendment to the Techn: cal i

Specifications contained in Appendix A to Facility Operating License DPR-59 for the James A. FitzPatrick Nuclear Power Plant. This application is filed in accordance with Section 10 CFR 50.90 of the Nuclear Regulatory Commission's regulation.

This application for an amendment to the James A. FitzPatrick Technical Specifications proposes to revise Surveillance Requirement 4.9.G.1 and associated Bases using the guidance of Generic Letter 91-09. The Generic Letter allows a line item Technical Specification improvement by the elimination of testing for electrical protective assemblies (EPAs) during power operation. This change reduces the possibility of inadvertent reactor trips caused by testing of EPAs during power operation.

i; The proposed change to the Technical Specifications is Attachment I to this Application for Amendment to the Operating License. The Safety Evaluation for the proposed change is included as Attachment 11.

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New york, Power Authority C-Ralph E. Beedle Executive Vice President Nuclear Generation STATE OF NEW YORK COUNTY OF WESTCHESTER Subscribed and sworn to before me KATHLEEN D GALLAGHER this 2 hyfay of Ke.o,l Notary Pubbc. State of New York 1993.

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OuaI6ec in Westchester County b,. r_

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Commuseon Expires Nov.18,184.j Notary Public i

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i ATTACHMENT I to JPN-93-005 PROPOSED TECHNICAL SPECIFICATION CHANGES

+

ELECTRICAL PROTECTIVE ASSEMBLIES (EPAs)

SURVEILLANCE INTERVAL (JPTS-91-010)

I i

New York Power Authority JAMES A. FITZPATRICK NUCLEAR POWER PLANT Docket No. 50-333 DPR-59

~~ T V & T b W $ C '7

/2 ff.

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l JAFNPP j

3.9 (cont'd) 4.9 (cont'd) l 3.

From and af ter the time both power supphes are made or j

found inoperable the reactor shall be brought to cold condition within 24 hours2.777778e-4 days <br />0.00667 hours <br />3.968254e-5 weeks <br />9.132e-6 months <br />.

G.

REACTOR PROTECTION SYSTEM ELECTRICAL PROTECTION G.

REACTOR PROTECTION SYSTEM ELECTRICAL PROTECTION ASSEMBLIES ASSEMBLIES Two RPS electrical protection assemblies for each inservice The RPS electrical protection assemblies instrumentation shall RPS MG set and inservice alternate source shall be operable be determined operable by:

except as specified below:

1.

Performing a channel functional test each time the plant is 1.

With one RPS electr. cal protection assembly for an in cold shutdown for a period of more than 24 hours2.777778e-4 days <br />0.00667 hours <br />3.968254e-5 weeks <br />9.132e-6 months <br />, inservice RPS MG set or an inservice alternate power unless performed in the previous 6 months.

supply inoperable, restore the inoperable channel to operable status wittiin 72 hours8.333333e-4 days <br />0.02 hours <br />1.190476e-4 weeks <br />2.7396e-5 months <br /> or remove the associated 2.

At least once per operating cycle, demonstrating the RPS MG set or alternate power supply from service.

operability of over-voltage, under-voltage and under frequency protective instrumentation by 2.

With two RPS electrical protection assemblies for an performance of a channel calibration including simulated inservice RPS MG sut or an inservice alternate power automatic actuation o! the protective relays, tripping logic supply inoperable, restore at least one to operable status and output circuit breakers and verifying the following within 30 minutes or remove the associated RPS MG set set points:

or alternate power supply from service.

RPS MG SET SOURCE OVER-VOLTAGE s132V s4 second Time Delay

[

UNDER-VOLTAGE 2108V s4 second Time Delay l

UNDER FREQUENCY 2 57HZ s4 second Time Delay l

Amendment No.

(continued on page 222d) 222c

JAFNPP 4.9 BASES (con't)

D.

Batterv System Measurements and electrical tests are conducted at specified intervals to provide indication of cell condition and to determine the d,scharge capability of the batteries. Performance and service tests are conducted in accordance with the recommendations of IEEE 450-1987.

E.

LPCI MOV Independent Power Supply Measurement and electri:al tests are conducted at specified intervals to provide indication of cell condition, to determine the discharge capability of the battery.

Performance and service tests are conducted in accordance with the recommendations of IEEE 450-1987.

F.

Reactor Protection Power Supplies Functional tests of the electrical protection assemblies l

are conducted at specified intervals utilizing a built-in test device and once per operating cycle by performing an instrument calibration whic'1 verifies operation within the limits of Section 4.9.G.

Amendment No. p,7f, If4, If7,

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. 1 to JPN-93-005

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-t SAFETY EVALUATION FOR PROPOSED TECHNICAL SPECIFICATION CHANGES ELECTRICAL PROTECTIVE ASSEMBLIES (EPAs)

SURVEILL ANCE INTERVAL (JPTS-91 -010) i 1.

DESCRIPTION OF THE PROPOSED CHANGES

-l I

The proposed change to the James A. FitzPatrick Technical Specifications revises the.

surveillance interval for electrical protective assemblies (EPAs) for the Reactor

.f

' Protection System (RPS). The proposed change is addressed below.

i i

. Minor changes in format, such as type font, margins or hyphenation, are not described

'j in this submittal. These changes are typographical in nature and do not affect the.

content of the Technical Specificationi i

i Pace 222c. Soecification 4.9.G 1.

Replace the specification:

"At least once every 6 months, performing a channel functional test."

with-i

" Performing a channel functional test each time the plant is in cold shutdown for a period of more than 24 hours2.777778e-4 days <br />0.00667 hours <br />3.968254e-5 weeks <br />9.132e-6 months <br />, unless performed in the previous 6 months."

i Pace 222c. Soecification 4.9.G.2.

Replace "s" with "second" in three locations.

l Pace 226. Bases 4.9.F In the first sentence, replace the phrase "once each six (6) months" with the phrase "at specified intervals."

4 I!, PURPOSE OF THE PROPOSED CHANGES l

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I Electrical protective assemblies (EPAs) are used in the power supplies for the Reactor Protective System (RPS). The EPAs ensure that RPS components are protected from abnormal voltages or frequencies from the RPS motor generator (MG) set or the alternate power -supplies. The EPAs protect the RPS components by tripping a breaker j

between the MGs and the RPS when abnormal voltages or frequencies are encountered.

'l Generic Letter 91-09 (Reference 1) encouraged Licensees to propose Technical f

Specification changes to modify the surveillance interval of EPAs used in power supplies for the RPS. Standard Technical Specifications (Reference 2) require channel functional testing of EPAs at six month ~ intervals.' The Generic Letter allows changing the test interval to require testing every time the plant is in cold shutdown for more than 24 hours2.777778e-4 days <br />0.00667 hours <br />3.968254e-5 weeks <br />9.132e-6 months <br />, unless testing was performed in the previous 6 months. This change l

was identified as a line item improvement in the STS.

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Attachment il to JPN-93-005 SAFETY EVALUATION Page 2 of 5 The purpose of this Technical Specification change request is to implement the guidance of the Generic Letter at the FitzPatrick plant. Technical Specification 4.9.G.1 currently requires a channel functional test every 6 months regardless of whether or not the plant is operating. A minor editorial change is also being made for clarity by changing an "s" to "second."

111. SAFETY IMPLICATIONS OF THE PROPOSED CHANGES The Authority has reviewed plant design and operating event reports to assess the effects on plant safety associated with a change to the testing interval. The small risks of the increased testing period are outweighed by the reduced possibility of inadvertent trips that challenge safety systems. The Generic Letter and its conclusions are applicable to the FitzPatrick plant.

r Generic Letter 91-09 identifies a safety concern with the transfer of power supplies to the RPS when testing an EPA channel. The transfer is a dead-bus transfer and the momentary interruption of power results in e half scram and half isolation. The Generic Letter notes that many plants have encountered problems with the reset of the half trip resulting in inadvertent scrams and group isolations that challenge safety systems during power operation. Testing during cold shutdown eliminates this safety concern.

l if there is no cold shutdown of 24 hours2.777778e-4 days <br />0.00667 hours <br />3.968254e-5 weeks <br />9.132e-6 months <br /> or more during a fuel cycle, the proposed change can result in an increase in the testing period from 6 months up to 18 months.

The Generic Letter concluded that the increased testing period would be of small risk to safety and that the limitation of testing to periods of cold shutdown would provide a positive safety benefit by reducing the possibility of inadvertent trips and challenges to safety systems. The benefit to safety of eliminating testing during power operation more than offsets the risk to safety from relaxing the surveillance test interval.

The results of a review by the Authority indicate that the conclusions of the Generic Letter are applicable to the FitzPatrick plant. The review identified the following factors:

The plant is designed so that interruption of power results in a half scram and half isolation. The plant procedure for functionally testing an EPA channel (Reference 3) requires transfer of power sources resulting in a momentary half scram and half isolation. The situation identified in the Generic Letter is, therefore, applicable.

No plant events have been identified where testing the EPAs at power has resulted in a scram. This does not mean that such an event will not occur in the future. The j

Generic Letter is, therefore, applicable.

Testing at cold shutdown does not present the risk of reactor scram with a resulting challenge to safety systems. This provides a positive safety benefit.

The HPCI, RCIC, RWCU snd shutdown cooling systems are designed with a one-out

-of-two or more isolation logic. These systems receive an isolation signal during the test. The proposed change provides a positive safety benefit because the HPCl, RCIC and RWCU systems are not required in cold shutdown.

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Attachmsnt 11 to JPN 93-005 SAFETY EVALUATION Page 3 of 5 During cold shutdown and refueling. the shutdown cooling function is required.

1 Shutdown cooling is isolated with the de-energization of a RPS bus. Shutdown cooling isolation valve 10-MOV-18 closes with a loss of RPS bus "A" and valve 10-MOV-17 closes with a loss of RPS bus "B." There have been events (References 4,5 and 6) where momentary power interruption to the isolation logic resulted in shutdown cooling isolation during cold shutdown. Corrective action has been taken to prevent a recurrence.

{

r The potential for isolation of shutdown cooling exists every refueling outage. The potential for isolation of shutdown cooling is slightly increased by the new requirement for testing during periods of cold shutdown that exceed 24 hours2.777778e-4 days <br />0.00667 hours <br />3.968254e-5 weeks <br />9.132e-6 months <br />. This can occur up to two times (after the first and second six months of a fuel cycle) between refuel outages. Planned mid cycle maintenance outages will be one time when testing is required, if inadvertent isolation occurs during this testing, the isolation is readily correctable. The event requires operator action (reset the isolation and reopen valves) and is less significant than a scram and/or isolation at power which challenges safety systems. The potential for isolation of shutdown cooling does not change the conclusions of the Generic Letter that the benefit to safety of eliminating testing at power offsets the risk to safety of relaxing the test interval.

The changes do not effect the conclusions of the plants accident analyses as documented in the updated FSAR or the NRC staff SER.

The editorial change has no safety significance. It serves to clarify the Specification since "s" is not a common abbreviation for second.

IV. EVAL.UATION OF SIGNIFICANT HAZARDS CONSIDERATION Operation of the FitzPatrick plant in accordance with the proposed Amendment would not involve a significant hazards consideration as defined in 10 CFR 50.92, since it would not:

1. involve a significant increase in the probability or consequences of an accident previously evaluated.

The proposed changes revise the testing frequency for the electrical protective assemblies (EPAs) for the Reactor Protection System (RPS). These changes are in accordance with Generic Letter 91-09. There are no changes to plant design or operation. Increasing the test interval up to 18 months produces a smallincrease in i

probability that an inoperable EPA would not be detected. Increased testing during cold shutdown produces a smallincrease in probability that shutdown cooling can be isolated. These risks are offset by eliminating the possibility of trips due to i

testing during power that would challenge safety systems.

2. create the possibility of a new or different kind of accident from any accident previously evaluated.

The proposed change will not change design, operation or the testing process. The

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Attachment il to JPN-93-005 SAFETY EVALUATION Page 4 of 5 i

change to testing intervals will not effect any condition that could result in a new i

or different type of accident.

3. involve a significant reduction in a margin of safety.

The testing of each EPA channelinvolves a dead-bus transfer and the momentary interruption of power results in a half scram and half isolation. Generic Letter 91-09 notes that many plants have encountered prob:ams with the reset of the half trip resulting in inadvertent scrams and group isolation that challenge safety systems during power operation. Eliminating EPA testing at power operation increases the margin of safety by el;minating the potential for trips due to testing that challenge safety systems. An insignificant reduction in the margin of safety is introduced by increasing the test interval up to 18 mor ihs producing a small increase in risk that an inoperable EPA would not be detected. The elimination of potential challenges to safety systems provides a safety benefit that offsets the i

increased nsks of component f ailure and shutdown cooling isolation.

V. IMPLEMENTATION OF THE PROPOSED CHANGES Implementation of the proposed changes will not adversely affect the ALARA or Fire Protection Programs at the FitzPatrick plant, nor will the changes affect the environment. The proposed changes involve a change to the frequency of testing. The testing is not performed in high radiation areas, will involve no modifications to plant i

systems or components and results in no plant discharges.

VI. CONCLUSION i

The changes, as proposed, do not constitute an unreviewed safety question as defined in 10 CFR 50.59. That is, they:

1. will not change the probability nor the consequences of an accident or malfunction of equipment important to safety as previously evaluated in the Safety Analysis Report;

2. will not increase the possibility of an accident or malfunction of a type different from any previously evaluated in the Safety Analysis Report; and

3. will not reduce the margin of safety as defined in the basis for any technical specification.

The changes involve no significant hazards consideration, as defined in 10 CFR 50.92.

l Vll. REFERENCES

1. NRC Generic Letter 91-09, " Modification of Surveillance interval for the Electrical Protective Assemblies in Power Supplies for the Reactor Protection System," dated j

June 27,1991.

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Attachmsnt il to JPN-93-005 SAFETY EVALUATION Page 5 of 5

2. NRC NUREG-1433, " Standard Technical Specifications for General Electric Boiling Water Reactors (BWR/4)," dated September 1992.

3. James A. FitzPatrick Nuclear Power Plant instrument Surveillance Procedure (ISP) 94, " Reactor Protection System Electrical Protection Assembly Functional Test / Calibration.

4. James A. FitzPatrick Nuclear Power Plant Licensee Event Report 92-047,

" Automatic Shutdewn Cooling isolation Due to Voltage Transient," dated i

December 4,1992.

4

5. James A. FitzPatrick Nuclear Power Plant Licensee Event Report 92-046,

" Automatic Shutdown Cooling isolation Due to Procedure Deficiency," dated November 16,1992.

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6. James A. FitzPatrick Nuclear Power Plant Licensee Event Report 90-013, Revision 0, " Isolation of Shutdown Cooling System Due to Test Jumper Falling Off of isolation Logic Circuit," dated May 9,1990.

7. James A. FitzPatrick Nuclear Power Plant Licensee Event Report 90-022, Revision 1, " Engineered Safety Feature Actuation Due to Low Voltage Trip of Power Supply to Reactor Protection System," dated June 19,1991.

8. James A. FitzPatrick Nuclear Power Plant Updated Final Safety Analysis Report, Sections 4.8.6. 7.2.4, 7.3.4, 8.9 and Chapter 14.

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9. James A. FitzPatrick Nuclear Power Plant Safety Evaluation Report (SER), dated November 20,1972, and Supplements.

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ATTACHMENT lit to JPN-93-005 PROPOSED TECHNICAL SPECIFICATION CHANGES ELECTRICAL PROTECTIVE ASSEMBLIES (EPAs)

SURVEILLANCE INTERVAL MARKUP OF TECHNICAL SPECIFICATION PAGES (JPTS-91-010)

I New York Power Authosity JAMES A. FITZPATRICK NUCLEAR POWER PLANT Docket No. 50-333 DPR-59 i

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4.9 (cont'd) 3.9 (cont'd) 3.

From and after the time both power supplies are made or found inoperable the reactor shall be brought to cold 7-g condition within 24 hours2.777778e-4 days <br />0.00667 hours <br />3.968254e-5 weeks <br />9.132e-6 months <br />.

C G.

REAQTOILPit9TI;GTlQ(I SYSTEM El&CTnICAT, HEACTOR PROTECTIOtt SYSTEtt EIEgTHICAl*

G.

PHOTECTIOtl ASSEttDI,IES PHOTECTIOli AUSEH111.1ES Two HPS ciectrical protection annemb-The RPS electrical protection annemblies lies for each innervice IIPS HG net instrumentation chall be determined 6nd innervice alternate nource shall be operable except au specified operable by:

below:

- least once every 6 months, 1.

At 1.

With one BPS electrical protection performing a channel functional assembly for an inservice HPS HG tent.

set or an innervice alternate power supply inoperable, restore the 2.

At leant once per operating c'ycle, inoperable channel to operabic demonstrating the operability of status within 72 hours8.333333e-4 days <br />0.02 hours <br />1.190476e-4 weeks <br />2.7396e-5 months <br /> or remove over-voltage, under-voltage and h

the associated itPS MG set or under-frequency protective instrumentatie alternate power nupply from by performance of a channel calibration including nimulated automatic actuation service.

of the protective relayn, tripping I

2.

With two RPS clectrical protection logic and output circuit breakers and assemblica for an innervice HPS verifying the following not points:

MG set or an Inservice alternate power supply inoperabic, restore ppf,.11G SET SOURCE i

at least one to operabic statun within 30 minuten or remove the

.annociated HPS MG net or alternate OVEH-VOLTAGE

< 132V

$4 _ Time Delay power supply from service.

f 2100v UNDER-VOI.TAGE i

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<A me Delay g

Ut3DElt-FREOllEtlCY 25711Z

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$4 ime Delay l

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SeL0nd Amendment tio.

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INSERT A Performing a channel functional test each time the plant is in cold shutdown for a period of more than 24 hours2.777778e-4 days <br />0.00667 hours <br />3.968254e-5 weeks <br />9.132e-6 months <br />, unless performed in the previous 6 months.

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JAFNPP 4.9 IIASES (cont'd) 9 O.

Battery System Measurements and electrical tests are conducted at specified p

intervals to provido indication of cell condition and to determino the discharge capability of the batteries. Performanco and service tests are conducted in accordanco with the recommendations of IEEE 450-1987.

E.

LPCI MOV Independent Power Supply Measurement and electrical tests are conducted at specified intervals to provido indication of cell condition, to deformino the discharge capability of the battery. Performanco and service tests are conducted in accordance with the recommendations of IEEE 450-1907.

F.

Roactor Protection Power Supplies h

Functional tests of the electrical protection assemblies are conducted (orico each six M montli!butilizing a built-in test device and onco por operating,3 cycle by posforming an instrument calibration which verifies operation within the limits of Section 4.9.G.

Of SpiS sed iMervcds amendmcni no. 7.p ip i/i 5

m s,