ML20063E163
| ML20063E163 | |
| Person / Time | |
|---|---|
| Site: | LaSalle  |
| Issue date: | 01/24/1994 |
| From: | Benes G COMMONWEALTH EDISON CO. |
| To: | Murley T NRC OFFICE OF INFORMATION RESOURCES MANAGEMENT (IRM), Office of Nuclear Reactor Regulation |
| Shared Package | |
| ML20063E166 | List: |
| References | |
| RTR-NUREG-1366 GL-93-05, GL-93-5, NUDOCS 9402090102 | |
| Download: ML20063E163 (9) | |
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)< Commonwulth Edison
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1400 Opus Place i
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Downers Grove. tilinois 60515 i
January 24,1994 Dr. Thomas E. Murley, Director Office of Nuclear Reactor Regulation U.S. Nuclear Regulatory Commission Washington, D.C. 20555 Attn: Document Control Desk
Subject:
LaSalle County Nuclear Power Station Units 1 and 2 i
Application for Amendment of Facility Operating Licenses NPF-11 and NPF-18 Technical Specifications NRC Docket 50-373 and 50-374
Dear Dr. Murley:
Pursuant to 10 CFR 50.90, Commonwealth Edison (CECO) proposes to amend i
Appendix A, Technical Specification of Facility Operating Licenses NPF-11 and NPF-18 to delete the requirement for response time testing where the required time corresponds to the diesel start time.
Line item 5.9 of GL 93-05, "Line-Item Technical Specifications Improvements to Reduce Surveillance Requirements for Testing During Power Operation",
reenmmends deleting the requirement to perform response time testing where the required time corresponds to the diesel start time. Deleting this requirement from the applicable parts of Table 3.3.2-3 will produce significant financial savings due to a reduction in labor and critical path outage time.
The line item improvements are based on an NRC study that included a comprehensive examination of surveillance requirements, and is reported in f
NUREG-1366, " Improvements to Technical Specification Surveillance Requirements." This proposal is compatible with plant operating experience and
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the recommendations of NUREG-1366.
This proposed change eliminates a requirement that provides little or no safety benefit, yet uses significant resources to perform. Consequently, we request this be prioritized as a Cost Beneficial Licensing Action (CBLA). The savings are discussed within Attachment A.
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PDR ADOCK 05000373-i p
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l This proposed amendment request is subdivided as follows:
1.
Attachment A gives a' description and safety analysis of the proposed changes in this amendment.
t 2.
Attachment B includes a summary of the proposed changes and the marked-up Technical Specifications pages for LaSalle Unit 1 and Unit 2-with the requested changes indicated.
3.
Attachment C describes CECO's evaluation performed in accordance with 10 CFR 50.92 (c), which confirms that no significant hazard consideration is involved.
1 4.
Attachment D provides an Environmental Assessment Applicability i
Review.
j This proposed amendment has been reviewed and approved by CECO On-Site and Off-Site Review in accordance with Commonwealth Edison procedures.
To the best of my knowledge and belief, the statements contained above are l
true and correct. In some respect these statements are not based on my personal knowledge, but from obtained information furnished by other Commonwealth i
Edison employees, contractor employees, and consultants. Such information has been reviewed in accordance with company practice, and I believe it to be reliable.
Commonwealth Edison is notifying the State ofIllinois of this application for amendment by transmitting a copy of this letter and its attachments to the designated state official.
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>r Please direct any questions you may have concerning this submittal to this office.
Very truly yours, fW Ga G. Eenes OFFICIAL SEAL MARY JO YACK
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"8'"E Admimstrator NOTARY PUBUC, STATE or IWN0ls MY COMMISSION EXPtRES;11/29/97 f
Subscribed and Sworn to before me on,this WM day'of i
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,1994.
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Notary P6blic m/
Attachments:
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A.
Description and Safety Analysis of the Proposed Changes B.
Proposed Amendments to the License /I'echnical Specifications C.
Evaluation of Significant Hazards Considerations D.
Environmental Assessment Statement Applicability Review-cc:
J. B. Martin, Regional Administrator - RIII.
I D. L. Hills, Senior Resident Inspector - LSCS A. T. Gody Jr., Project Manager - NRR
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Oflice of Nuclear Facility. Safety - IDNS I
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ATTACHMENT A DESCRIPTION AND SAFETY ANALYSIS OF THE PROPOSED CHANGES Description of the Proposed Change t
The proposed change eliminates isolation system instrumentation response time t
testing where the required time corresponds to the diesel start time. In these cases, which involve non-MSIV instrument loops, the instrumentation loop response times -
are a small fraction of the total allowable system response time requirements.
GL 93-05, "Line-Item Technical Specifications improvements to Reduce Surveillance Requirements for Testing During Power Operations", provides guidance prepared by the Nuclear Regulatory Commission (NRC) staff to assist licensees in preparing license amendment requests to implement these recommendations as line item improvements. Line item 5.9 of GL 93-05 recommends deleting the requirement to perform response time testing where the required time corresponds to the diesel start time.
5 The line item improvements are based on the recommendations of an NRC study that included a comprehensive examination of surveillance requirements, and is reported in NUREG-136G,
" Improvements to Technical Specifications Surveillance Requirements". This proposal is compatible with plant operating experience and the recommendations of.NUREG-1366.
Description of the Current Operating License /I'echnical Specification Hequirement i
Technical Specification 3.3.2 requires that the isolation actuation instrumentation channels shown in Technical Specification Table 3.3.2-1 be operable with their trip setpoints set consistent with the values shown in the Trip Setpoint column of -
Technical Specification Table 3.3.2-2, and with isolation system response time as shown in Technical Specification Table 3.3.2-3.
Technical Specification surveillance 4.3.2.1 requires that the isolation actuation instrumentation channels be demonstrated operable by performing channel checks, functional tests, and calibrations.
Technical Specification surveillance 4.3.2.2 i
requires the performance of logic system functional tests and simulated automatic operation of all channels at least once per 18 months.
Technical Specification surveillance 4.3.2.3 requires that the isolation system response time of each isolation trip function shown in Technical Specification Table 3.3.2-2 be demonstrated within its limit at least once per 18 months.
The perfbrmance of these surveillances permits o stecting degraded components and/or system conditions which could adversely affect isolation actuation instrumentation system response times.
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ATTACHMENT A DESCRIPTION AND SAFETY ANALYSIS OF THE PROPOSED CHANGES Bases for the Current Requirement Boiling water reactors (BWRs) are designed with the capability to isolate portions of systems to retain reactor vessel inventory to limit the consequences ofline breaks.
Except for the MSIVs, the safety analysis does not address individual sensor response times or the response times of the logic systems to which the sensors are connected.
The analyses additionally assume that instrument channel actuation for non-MSIV -
channels occurs simultaneously with diesel generator start. The required Technical Specification response times include the instrument response time (typically measured in fractions of a second), the response times of the actuation logic circuits (typically less than a second), and the diesel generator start time (13 seconds).
This specification serves to ensure that overall system reliability is enhanced and to monitor instrument channel response time trends. This maintains the effectiveness of the instrumentation used t.o mitigate the consequences of accidents by prescribing the _ operability trip setpoints and response times for isolation of the reactor systems, and to allow for detection of response times which exceed acceptable limits assumed in safety analyses.
Description of the Need for Amending the Technical Specifications The isolation actuation instrumentation logic functions are in parallel with the startup of the diesel generators.
The 13 second response time requirement is therefore not critical for the majority ofisolation circuits. The proposed change for instrumentation response time testing involves tests where the instrumentation loop response time is a small fraction of the total allowable system response time requirement.
The chance is remote that a channel's response time would degrade to the point where it exceeds the 13 second diesel start time without a failure that would be noticeable by some other means. Failures and degradation that would affect response times, trending, and reliability are detectable by other means such as channel checks, channel functional tests, channel calibrations, and logic system functional tests.
The performance of conventional response time tests has been of little value in assuring that instrumentation will perform as required or for determining the health of the instrument. The majority of allowable instrumentation response times are much longer than instrument circuits require for signal processing from sensor input to final output signal. Additionally, the instrument response time is small compared to safety system actuation times.
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l ATTACHMENT A DESCRIPTION AND SAFETY ANALYSIS OF THE PROPOSED CHANGES This proposed change will improve plant safety, decrease equipment degradation, relieve an unnecessary burden on personnel resources, and save capital expenditures by reducing the amount of testing required by the Technical Specifications. This is consistent with the guidance provided in GL 93-05 and NUREG-1366.
The savings in labor directly associated with testing is estimated to be 500 instrument maintenance technician-hours per refueling outage. This represents at least $15,000/ unit / refueling savings in labor alone. This estimate is very conservative because additional cost savings associated with reduced coverage from the health physics departm at are not accounted for. A greater savings to be realized is the amount of time the outage can be shortened due to not performing the response time testing. Previous experience has shown that response time testing has been the critical path item for at least 12 hours1.388889e-4 days <br />0.00333 hours <br />1.984127e-5 weeks <br />4.566e-6 months <br /> of the outage. Therefore, implementation of this proposal could shorten the refuel outage by 12 hours1.388889e-4 days <br />0.00333 hours <br />1.984127e-5 weeks <br />4.566e-6 months <br />. Based on conservative replacement power costs of $7/MWe-hr, the cost of replacement power for that 12 hours1.388889e-4 days <br />0.00333 hours <br />1.984127e-5 weeks <br />4.566e-6 months <br /> of not operating could cost approximately $95,000.
The continued performance ofinstrument response time testing may actually detract from safety by: 1) increasing the time interval that safety systems are unavailable to perfbrm their safety function, 2) increasing the potential for inadvertent safety system actuations,3) increasing the exposure of plant personnel to radiation, and 4) diverting resources from other tasks important to safety.
Elimination of unnecessary response time tests can lead to improved plant safety.
Performing response time testing requires that instruments be isolated. This renders them unavailable to respont'.o an actuation signal. Eliminating the response time tests can lead to improved plant safety by minimizing the amount of time that safety systems are out of service for testing.
It is possible fbr inadvertent actuations to occur during and as a result of response time testing. There is a potential for error associated with the large number oflifted leads, jumpers, and pulled fuses which are required to simulate the system conditions needed for testing. Eliminating response time testing reduces the risk ofinadvertent actuations and equipment damage.
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l ATTACHMENT A DESCRIPTION AND SAFETY ANALYSIS OF THE PROPOSED CHANGES l
Instrument maintenance technicians supporting response time testing are often
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required to be stationed in radiation areas. A reduction in testing requirements will result in a corresponding decrease in occupational radiation exposure to the -
technicians involved.
Instrument maintenance technicians, health physics, engineering and outage planning personnel will be free to support other critical path outage tasks which have i
a greater impact on plant safety.
Description of the Amended Technical Specification Requirements With the exception of the MSIW, the 13 second response time items in Technical Specification Table 3.3.2-3 and the associated superscripted footnotes are proposed to be deleted. T-hnical Specification bases 3/4.3.2 is to be correspondingly revised to reflect this.
assion of the 3 second delay and failure of D.C. operated valves is to be acleted in the Bases, since D.C. operated valves do not serve an isolation function.
Technical Specification surveillance 4.3.2.1 maintains the requirement that the isolation actuation instrumentat ion channels be demonstrated operable by performing channel checks, functional tests, and calibrations for the operational conditions and at the frequencies shown in Table 4.3.2.1-1.
Technical Specification surveillance 4.3.2.2 maintains the requirement to perform logic system ftmetional tests and simulated automatic operation of all channels at least once per 18 months.
i Bases for the Amended Technical Specification Request Eliminating the response time testing where the required time corresponds to the diesel start time will reduce an unnecessary burden on personnel resources by -
eliminating the amount of testing required L,, the Technical Specifications. The proposed change eliminates response time testing of both the sensors and the logic systems to which they are connected, which happen to be very small in comparison to the assumed 13 second diesel generator delay. The proposed change is consistent with guidance provided by the NRC staffin GL 93-05 and NUREG-1366.
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ATTACHMENT A DESCIIIPTION AND SAFETY ANALYSIS OF TIIE PILOPOSED CHANGES u
The performance of Technical Specification surveillances 4.3.2.1 and 4.3.2.2 provides a method to detect degraded components and/or system conditicy which could i
adversely affect isolation actuation instrumentation; The ability'to er.i:ance overall system reliability and to monito'r instrumerit channel response ti ne trends is maintained. Response times which exceed acceptable 'imits assumed in safety analyses will remain detectable.
This ensures. the effectiveness of the instrumentation used to mitigate the consequences of accidents.
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LaSalle Station desires to implement the proposed amendment requirements during' the Unit 1 Sixth Refuel Outage (L1ROG), scheduled to start in March,1994.
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i NITACHMENT B PROPOSED AMENDMENTS TO THE LICENSEffECHNICAL SPECIFICATIONS y
NPF-11 NPF-18 l
3/43-9*
3/43-9*
l 3/4 3-10*
3/4 3-10*
3/4 3-18 3/4 3-18 3/4 3-19 3/4 3-19 B 3/4 3-2 B 3/4 3-2 l
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- These pages are provided for information only, there are no changes on them.
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