ML20063F308
| ML20063F308 | |
| Person / Time | |
|---|---|
| Site: | LaSalle  |
| Issue date: | 01/28/1994 |
| From: | Benes G COMMONWEALTH EDISON CO. |
| To: | Murley T NRC OFFICE OF INFORMATION RESOURCES MANAGEMENT (IRM), Office of Nuclear Reactor Regulation |
| Shared Package | |
| ML19303F853 | List: |
| References | |
| NUDOCS 9402140244 | |
| Download: ML20063F308 (16) | |
Text
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owners Grove, Ilknois 60515 January 28,1994 i
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 Request for Exigent Technical Specification Amendment Facility Operating License NPF-11 and NPF-18 NRC Docket 50-373 and 50-374
Dear Dr. Murley:
Pursuant to 10 CFR 50.91(a)(6), Commonwealth Edison Company (CECO) proposes to amend Appendix A, Technical Specifications, of Facility Operating Licenses NPF-11 and NPF-18 and requests that the Nuclear Regulatory Commission (NRC) grant an exigent amendment to Technical Specification 3.3.1 and 3.3.4. This amendment is needed by 10:00 a.m. CST on February 26,1994.
Due to a problem that has developed with the LaSalle Unit 2 MSIV Limit Switches, LaSalle Unit 2 must shut down to at least the Startup mode prior to the end of the channel functional test interval (10:00 a.m. on February 26,1994) to verify the proper position of the MSIV limit switches for RPS instrumentation operability. Approval of this exigent change will change the functional test interval from monthly to quarterly and allow Unit 2 to continue power operation.
This will allow more time for the root cause of the problem, and associated corrective action, to be determined.
An exigent change is needed and could not be avoided due to the short time frame that exists between when the problem was first discovered (January 18, 1994), and when the MSIV-Closure channel functional test must be performed (February 26, 1994). This short time frame, combined with the time necessary to develop this request, will not allow the normal 30 day period for public comment.
Therefore, this condition was not created by the failure to make a timely application for a Technical Specification Amendment. The attached safety analysis shows that this proposal provides a net safety benefit by not requiring LaSalle Unit 2 to shut down to the Startup mode and undergo unnecessary thermocycles i
on plant equipment and any associated challenges to safety systems.
9402140244 940128 k#
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i This proposed exigent' amendment request is subdivided as follows:
1.
Attachment A gives a description and safety analysis of the proposed ~
changes in this amendment.
.j 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 1
10 CFR 50.92 (c), which confirms that no significant hazard consideration is involved.
4.
Attachment D provides an Environmental Assessment Applicability Review i
5.
Attachment E is the General Electric Technical Specification Improvement Analysis for the Reactor Protection System for LaSalle County Station Units 1 and 2.
-l 6.
Attachment F is a withholding affidavit for the General Electric Technical '
Specification Improvement Analysis.
l This proposed amendment has been reviewed and approved by CECO On-Site j
and Off-Site Review in accordance with Commonwealth Edison procedures.
The attached General Electric Technical Specification Improvement Analysis for the Reactor Protection System contains information proprietary to General l
Electric Company. In accordance with the requirements of 10CFR 2.790(b), an l
affidavit for this letter is enclosed as Attachment F to support the withholding of this report from public disclosure.
j To the best of my knowledge and belief, the statements contained above are true and correct. In some respect these statements are not based on my personal knowledge, but from obtained information furnished by other Commonwealth 1
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.
f amendment by transmitting a copy of this letter and its attachments to the
-)
designated state ofYicial.
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rr Please direct any questions you may have concerning this submittal to this office.
Very truly yours, (w GBe d
- =::- ::::::=:::::==::3 OFFICIAL SEAL Gary Benes Nuclear Licensing MARY JO YACK NoTADV PUBUC ET ATE of RUNotSh Administrator
,$-i-SSY-I@I"I-17-5:"'UII Subscribed and Sworn to before me on' this
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,1994.
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Attachments:
A.
Description and Safety Analysis of the Proposed Changes B.
Marked-Un Technical Specification Pages i
C.
Evaluation of Significant Hazards Considerations 1
D.
Environmental Assessment Applicability Review E.
General Electric Technical Specification Improvement Analysis for the Reactor Protection System F.
Withholding Affidavit for the General Electric Technical l
Specification Improvement Analysis for the Reactor Protection System.
cc:
J. B. Martin, Regional Administrator - RIII
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D. L. Hills, Senior Resident Inspector - LSCS A. T. Gody Jr., Project Manager, NRR
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Office of Nuclear Facility Safety - IDNS
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ATTACHMENT A DESCRIPTION OF SAFETY ANALYSIS OF THE PROPOSED CHANGES Description ofthe Proposed Change This Exigent Technical Specification amendment request proposes to minimize unnecessary testing for certain instruments in the Reactor Protection System (RPS) and the End-of Cycle Recirculation Pump Trip system (EOC-RPT) for LaSalle County Station (LaSalle), Units 1 and 2 Technical Specifications. This eflbrt is part of the Technical Specification Improvement Project. This request is needed to allow continued operation of LaSalle Unit 2 beyond 1.25 times 31 days, the current fimetional test frequency.for the Reactor Protection System Main Steam Line Isolation Valve - Closure scram.
Description of the Current Operating License / Technical Specification Requiremerit The current requirements of Technical Specification Surveillance Requirement 4.3.1.1, Reactor Protection System Instrumentation, requires the following:
"4.3.1.1 Each reactor protection system instrumentation channel shall be demonstrated OPERABLE by the performance of the CHANNEL CHECK, CHANNEL FUNCTIONAL TEST, AND CHANNEL CALIBRATION operations for the OPERATIONAL CONDITIONS and at the frequencies shown in Table 4.3.1.1-1."
Table 4.3.1.1-1, " Reactor Protection System Instrumentation Surveillance Requirements," requires a monthly channel functional test for the following
" Functional Units" that are requested to be changed to quarterly channel functional tests:
5.
" Main Steam Line Isolation Valve - Closure."
9.
" Turbine Stop Valve - Closure."
- 10. " Turbine Control Valve Fast Closure Valve Trip System Oil Pressure -
Low."
Table 4.3.1.1-1, " Reactor Protection System Instrumentation Surveillance Requirements," requires a monthly channel functional test for the " Functional Unit," that is requested to be changed to a ' weekly channel functional tests:
5
- 12. " Manual Scram."
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s ATTACHMENT A
. DESCRIPTION OF SAFETY ANALYSIS OF THE PROPOSED CHANGES.
t The current requirements of Technical Specification Surveillance Requirement 4.3.4.2.1, End-of-Cycle Recirculation Pump Trip (EOC-RPT) System Instrumentation, requires the following:
4.3.4.2.1 "Each end-of-cycle recirculation pump trip system instrumentation chimnel shall be demonstrated OPERABLE by the performance of the CHANNEL FUNCTIONAL TEST and CHANNEL CALIBRATION operations at the frequencies shown in Table 4.3.4.2.1-1.
l 4.3.4.2.1-1, "End-of-Cycle Recirculation Pump Trip System Surveillance Requirements," requires a monthly channel functional test for the following " Trip Functions," that are requested to be changed to quarterly channel functional tests:
1.
" Turbine Stop Valve-Closure" I
2.
" Turbine Control Valve. Fast Closure".
Rases for the Current Reuttirement The bases for the current requirements of the above Technical Specification.
items provide Operational Conditions for which Surveillances are required and the l
Surveillance Requirements needed to preserve the ability of these systems to.
perform their intended. design functions. - The chtnnel functional test verifies that the associated scram and EOC-RPT " instrument" and associated relays will function to cause a scram and/or Recirculation Pump trip. These tests are performed monthly based on the need to assure trip channel operability.
l Descrintion of the Need for Amendine the Technical Snecification and Basis for Exigency Three of the Reactor Protection System Instrumentation " Functional Units" listed in Table 4.3.1.1-1 will cxceed the specified ' monthly surveillance interval and j
the allowed factor of 1.25 times the surveillancc interval on February 19,1994 for Items 9 and 10; and February 21,1994 for Item 5. The EOC-RPT system instrumentation channel functional tests are due at the same time.
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ATTACHMENT A DESCRIPTION OF SAFETY ANALYSIS OF THE PROPOSED CHANGES Due to a problem that has developed with the LaSalle_ Unit 2 MSIV Limit Switches, LaSalle Unit 2 must shut down to at least the Startup mode prior to the end of the channel functional test interval to verify that the limit switches are in the " Spring Return-to-Normal" position. The nature of the problem is that some of
.the limit switches will not always automatically return the limit switch arm to the normal position after being toggled during valve strokes. If a limit switch arm is not in the normal position when the valve is next moved from open to closed or vice-versa, the limit switch will not toggle. For the MSIV limit switches that input to the MSIV - Closure Scram RPS logic (MSIV-RPS limit switch), the problem can be readily identified. This failure will occur when a MSIV-RPS limit switch fails to return to normal after tripping during closure of the associated MSIV (only partial closure is required to conduct the functional test). When the MSIV is reopened, the limit switch will not be reset and thus the associated RPS logic relay will remain de-energized. If an MSIV-RPS limit switch returns to normal after being tripped, then the limit switch will reset, and thus re-energize the associated RPS logic relay. However, the limit switch may not spring return to the normal position after being reset, which is not detectable until the next time the MSIV is cycled for a surveillance. During the time interval, an MSIV-RPS limit switch could be inoperable, unable to trip on MSIV closure. Therefore, LaSalle Unit 2 mr.st educe power to less than 12% (Startup Mode) to de-inert the primary containment for entry to verify proper reset of the inboard MSIVs limit switches.
All MSIV limit switches were in the " Spring Return-to-Normal" position when LaSalle Unit 2 was started up on January 19,1994, and therefore the RPS limit.
switches for the MSIV - Closure Scram are currently Operable. IIowever, the position of the MSIV limit switches will be unknown, without visual observation, after cycling the MSIVs during the next scheduled channel functional test.
Therefore, LaSalle Unit 2 must be shut down to at least the Startup mode in order to allow personnel access to verify proper MSIV limit switch position in the
" Spring Return-to-Normal" position. The monthly channel functional test is due again at a maximum of 1.25 times the current 31 day surveillance test interval.
There are three reactor protection system instrumentation surveillances that are performed on the same day, typically on the night shift (shift 1).. These surveillances meet the channel functional test requirements for item 5, Main Steam Line Isolation Valve (MSIV)- Closure; item 9, Turbine Stop Valve (TSV) -
Closure; and item 10, Turbine Control Valve (TCV) Fast Closure, Valve Trip System Oil Pressure - Low. The channel functional tests for these valves require the valves to be cycled and a reactor power decrease to s 90% thermal power is required prior to cycling MSIVs or TCVs. Due to the requirement to drop power kinla\\lasalle\\msiex2(6)-
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ATTACHMENT A -
I DESCRIPTION OF SAFETY ANALYSIS OF THE PROPOSED CHANGES l
I and the similarity of the surveillances, these surveillances are performed together (sequentially, not simultaneously). The EOC-RPT system instrumentation channel l
functional tests are also met by the same tests on the TSVs and TCVs. Therefore, l
although the urgency for this amendment request is for the MSIV - Closure -
' channel functional test, the frequencies of the TSV and TCV closure scram and '
. EOC-RPT TSV and TGV channel functional tests are also requested to be changed to quarterly. This will minimize the number of times LaSalle Unit I and 2 will be l
required to reduce thermal power to less than or equal to 90% power and it will 3
also keep these related surveillances together.
Without this Technical Specification amendment, LaSalle Unit 2 will need to be shut down to the Startup mode to verify the proper position of MSIV limit switches for RPS instrumentation operability. Approval of this exigent change will allow more time for Unit 2 to continue power operation until the root cause and associated corrective action has been determined. This provides a net safety.'
j benefit by not requiring the unit to shut down to the Startup mode and undergo unnecessary cycles on plant equipment and any associated challenges to safety systems as well as providing for the continued full power operation of LaSalle.
Unit 2 by extending the Surveillance Test Interval (STI) from monthly to quarterly.
i The circumstances leading to the exigent relief request could not be avoided, because this problem with the LaSalle Unit 2 MSIV limit switches was not identified for Unit 2 startup until January 17,1994. Determination that LaSalle Unit 2 would be required to shut down to at least the Startup mode the next time j
the channel functional test for the MSIV - closure scram was due was not made until January 18,1994 as a result of an operability evaluation. The possibility of a change to the STI from monthly to quarterly was determined on January 19, 1994. LaSalle has been developing this amendment request since January 19th.
l Due to the due date of the MSIV - Closure channel functional test that must be performed by February 26,1994 at 1000 hours0.0116 days <br />0.278 hours <br />0.00165 weeks <br />3.805e-4 months <br /> (10:00 A.M. CST), the 30 day period for public comment required for a normal Technical Specification amendment per 10 CFR 50.91(a)(2) can not be met. Therefore, this request for amendment is being submitted as an exigent per 10 CFR 50.91(a)(G). Per 3
Attachment C, this Technical Specification amendment request does not involve a j
significant hazards consideration.
l Therefore, Commonwealth Edison requests an Exigent Technical Specification amendment to extend the functional test interval for the following:
1.
Reactor protection system instrumentation surveillances for item 5, Main Steam Line Isolation Valve - Closure; item 9,' Turbine Stop Valve -
k:nlailasalle\\msiex2(7) m-m
ATTACHMENT A DESCRIPTION OF SAFETY ANALYSIS OF THE PROPOSED CHANGES Closure; and item 10, Turbine Control Valve Fast Closure Valve Trip System Oil Pressure - Low; and 2.
EOC-RPT system instrumentation surveillances for item 1, Turbine Stop Valve - Closure; and item 2, Turbine Control Valve - Fast Closure.
In late 1983 the BWR Owners' Group formed a Technical Specification Improvement (TSI) Committee to develop recommendations for improving the BWR Standard Technical Specifications. The TSI established a program for the development of reliability analyses to identify improvements for surveillance test intervals (STI) and Allowed Outage Time (AOT)in the standard technical specifications. The improved STI and AOT would be implemented to minimize unnecessary testing and excessively restrictive outage times. The improvements recommended by the TSI Committee can help to address the following problems associated with plant operations:
t-o Scrams and safety system challenges inadvertently caused during the performance of surveillance tests, o AOT not long enough to permit completion of surveillance tests, repairs or maintenance, I
o Excessive actuation of equipment which can lead to shortened lifetimes and increased failure rates, and o Radiation exposure to personnel performing surveillance tests.
At approximately the same time the NRC staffissued NUREG-1024 " Technical Specifications - Enhancing the Safety Impact," which coincided well with the efforts of the Owners' Group. The NRC suggested that-technical specification action statements be reviewed to assure that they have an adequate technical basis and to minimize risk. In April 1984 the TSI Committee met with the NRC staff to discuss the technical specification improvement program. At this meeting the NRC expressed agreement with the overall approach being taken by the Owners' Group.
General Electric (GE) subsequently submitted several topical reports to the NRC for review justifying STI and AOT extensions for reactor protection system (RPS),
primary containment isolation system (PCIS), emergency core cooling system (ECCS) and control rod block instrumentation. The NRC evaluated and approved the reports and has encouraged the utilities to submit technical specification amendment requests to implement the GE recommendations. In their safety kinla\\lasalle\\msiex2(8)
- O ATTACHMENT A' i
DESCRIPTION OF SAFETY ANALYSIS OF THE PROPOSED CHANGES evaluation reports (SER), the NRC required the applicants to:
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- 1. Confirm the applicability of the generic analyses to their specific plant.
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- 2. Demonstrate that instrumentation drift characteristics are bounded by the assumptions used in the GE analysis.
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- 3. Confirm that differences between the plant-specific and generic analyses were included in the plant-specific analysis.
GE confirmed the applicability of the generic analysis to LaSalle as well as the differences between it and the generic analysis. These are discussed for the RPS
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and EOC-RPT instrumentation groupings in Appendices I through III.
The SERs issued for the GE Topical Reports require confirmation that instrument setpoint drift due to extended STIs is properly accounted fer in the setpoint calculation methodology. This issue is not applicable to LaSalle Station because -
the drift issue pertains to instrumentation with calibration frequencies less than j
or equal to the current functional test frequencies. The channel calibration extension in the generic analysis is for analog trip units (from 31 to 92 days) when the corresponding functional test is being extended from monthly to quarterly (Reference 1). The LaSalle RPS and EOC-RPT Instrumentation functional tests being extended ~do not need to have the calibration interval extended, because the.
calibration period is already at 18 months and the instrumentation has no l
setpoint drift concerns.
i Descrintion of the Amended Technical Specification Requirement u
LaSalle County Station proposes to extend STI from a monthly to quarterly
)
interval for the above instrumentation Channel Functional Tests, except for the Manual Scram instrumentation. The STI for the Manual Scram instrumentation is being reduced from monthly to weekly in accordance with the' GE Topical Report (Reference 5). The specific changes are discussed in Appendices I through III.
The GE Topical Reports are considered to be proprietary infbrmation and are accordingly kept on file at LaSalle County Station.
Bases for_the Amended Technical Specification Request 1
Analyses provided by GE demonstrates that extending the STI for the subject instrumentation results in fewer reactor scrams and challenges to plant safety h nla\\lasalle\\msiex2(9)
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T ATTACHMENT. A DESCRIPTION OF SAFETY ANALYSIS OF THE PROPOSED CHANGES systems, enhanced equipment lifetimes, less personnel exposure and reduced labor requirements that more than offset the negligible reduction in reliability associated with the extensions. The generic RPS STI extension was approved by.
the NRC (Reference 5) and LaSalle Station Units 1 and 2 have been verified to be bounded by an analysis performed by an analysis (Reference 2 and Attachment' E).
j The EOC-RPT instrumentation channel functional test STI extension is bounded.
by the generic analysis performed by GE and accepted by the NRC (References 8 and 9). The Bases are further discussed in Appendices I and II.
Schedule
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It is requested that the proposed exigent Technical Specification amendment be approved prior to the end of the current surveillance test interval on February 26, 1994 at 1000 hours0.0116 days <br />0.278 hours <br />0.00165 weeks <br />3.805e-4 months <br /> (10:00 A.M. CST) to allow LaSalle Unit 2 to continue operating until the problem with the MSIV limit switch " spring Return-to-Normal" is resolved.
References
- 1. General Electric Topical Report, " Technical Specification Improvement Analysis for the Reactor Protection System for LaSalle County Station, Units 1 and 2," ~
MDE-83-0485 Rev.1, DRF A00-02119-D, September 1985.
- 2. General Electric Topical Report, " Technical Specification Improvement Analysis for the Reactor Protection' System for LaSalle County Station, Units 1 and 2,"
MDE-83-0485 Rev. 3, DRF C71-00072-1, April 1991.
- 3. General Electric Topical Report, " Technical Specification Improvement Analyses
.for BWR Reactor Protection System," NEDC-30851P, DRF A00-02119-A, May 1985.
- 4. U.S. Nuclear Regulatory Commission letter to BWR Owners' Group, " General Electric Company Topical Report NEDC-30851P, ' Technical Specification.
Improvement Analyses for BWR Reactor Protection System'", dated July 15,
]
1987.
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- 5. General Electric Topical Report, " Technical Specification Improvement Analyses for BWR Reactor Protection System," NEDC-30851P-A, DRF A00-02119-A, March 1988.
.j G. General Electric Topical Report, " Technical Specification Improvement Analysis k:nla\\lasalle\\msiex2(10)
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o ATTACHMENT A DESCRIPTION OF SAFETY ANALYSIS.
'1
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OF THE PROPOSED CHANGES H
1 for the Reactor Protection System for LaSalle County Station, Units 1 and 2,
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MDE-83-0485 Rev. 2, DRF C71-00072, May 1988.
- 7. General Electric Topical Report, " Technical Specification Improvement Analysis or the Reactor Protection System for LaSalle County Station, Units 1 and 2,"
l MDE-83-0485 Rev. 3, DRF C71-00072-1, April-1991.
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- 8. U.S. Nuclear Regulatory Commission letter to BWR Owners' Group " General' Electric Topical Report GENE-770-06-1, ' Bases for Changes to Surveillance Test -
i Intervals and Allowed Out-of-Service Times for Selected Instrumentation i
Technical Specifications"', dated July 21,1992.
- 9. General Electric Topical Report, " Bases for Changes to Surveillance Test Intervals and Allowed Out-of-Service Times for Selected Instrumentation Technical Specifications", GENE-770-06-1-A, December 1992.
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4 ATTACHMENT A-DESCRIPTION OF SAFETY ANALYSIS OF PROPOSED CHANGES l
APPENDIX I i
REACTOR PROTECTION SYSTEM INSTRUMENTATION SURVEILLANCE TEST-INTERVAL CHANGES GE issued a topical report (Reference 3.) for improvements to the RPS technical l
specifications which provides the probabilistic basis for extending the RPS STI and -
AOT. It was concluded that the slight increase in risk due to these extensions is offset by the benefits achieved from a reduced number of challenges to safety systems. The NRC issued an SER (Reference 4.) on July 15,1987, to extend the STI and AOT for RPS instrumentation following its review and acceptance of this report. The NRC requested that GE and the Owners' Group publish an accepted version of Reference 3. incorporating the SER. This version was released in March 1988 (Reference 5.).
GE addressed the applicability of the generic analyses to LaSalle, and confirmed that the differences between the LaSalle instrumentation and the generic model were included in the plant specific analysis in Reference 6. This report concluded that differences between LaSalle's RPS configuration and the generic model do not significantly affect the conclusions drawn in the generic analysis, and that the generic analysis does apply to LaSalle. Reference 7. is an update of Reference 6.
which accounts for modifications which could have affected the original plant specific analysis. The report concluded that the RPS system modifications do not -
affect the original analysis.
Plant modifications installed since Reference 7. was issued were evaluated to assess any effects upon the conclusions drawn in the generic and plant specific
)
analyses. The modifications installed do not affect the systems with respect to the extension of STI.
The following listing is a summary of the proposed changes to the RPS Technical Specifications for Units 1 and 2 in Attachment B):
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i ATTACHMENT A-l DESCRIPTION OF SAFETY ANALYSIS OF PROPOSED CI-LANGES APPENDIX I REACTOR PROTECTION SYSTEM INSTRUMENTATION SURVEILLANCE TEST INTERVAL CHANGES A.
Channel Functional Test Frequency - Technical Specification Table 4.3.1.1-1 1.
Change the test frequency from Monthly to Quarterly for the following:
a.
Main Steam Line Isolation Valve - Closure b.
Turbine Stop Valve - Closure c.
Turbine Control Valve Fast Closure Valve Trip System Oil Pressure -
i Low 2.
Change the test frequency from Monthly to Weekly for the Manual Scram.
-B.
Technical Specification Bases - Add a statement to the bases providing the reference for this amendment (Insert A to Attachment B).
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ATTACHMENT A DESCRIPTION OF SAFETY ANALYSIS OF PROPOSED CHANGES APPENDIX 'I END-OF-CYCLE RECIRCULATION PUMP TRIP INSTRUMENTATION SURVEILLANCE TEST INTERVAL CHANGES The turbine stop valve closure and turbine control valve low hydraulic pressure i
trips are EOC-RPT system trip functions initiated by signals common to the RPS.
These common trip functions are bounded by the generic analysis (Reference 5.)
even though they were not explicitly identified in the analysis. GE Topical i
Report GENE-770-06-1, Reference 8 formed the basis for changing the STI for EOC-RPT system trip functions and was issued with an NRC SER as GE Topical Report GENE-770-06-1-A, Reference 9.
{
GE addressed the applicability of the RPS generic analyses to LaSalle, and i
confirmed that the differences between the LaSalle instrumentation and the generic model were included in the plant specific analysis in Reference 6. This report concluded that differences between LaSalle's RPS configuration and the generic model do not significantly affect the conclusions drawn in the generic analysis, and that the generic analysis does apply to LaSalle. Revision 7. is an update of Reference 6. which accounts for modifications which could have affected j
the original plant specific analysis. The report concluded that the RPS system i
modifications do not affect the original analysis. The LaSalle EOC-RPT logic l
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configuration is the same as that analyzed by GE and accepted by the NRC in Reference 9. The LaSalle and the Generic logic for EOC-RPT is 2 out of 2 channels required to trip an individual logic Division. Each of the two logic Divisions trip both recirculation pumps. Failure of the EOC-RPT function thus requires fhilure of both logic divisions. Therefore, LaSalle EOC-RPT instrumentation STI change is bounded by the generic analysis.
Plant modifications installed since Reference 7. was issued were evaluated to assess any effects upon the conclusions drawn in the generic and plant specific
-l analyses fbr RPS and EOC-RPT. The modifications installed do not affect the l~'
systems with respect to the extension sf GTI.
The extensions of STI for the EOC-RPT system are consistent with the changes i
proposed for RPS instrumentation, as' described in Reference 9. The following-listing is a summary of the proposed changes to the EOC-RPT Technical Specifications for Units 1 and 2 contained in Attachment B.
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ATTACHAENT A l
DESCRIPTION OF SAFETY ANALYSIS OF PROPOSED CHANGES I
APPENDIX II END-OF-CYCLE RECIRCULATION PUMP TRIP INSTRUMENTATION SURVEILLANCE TEST INTERVAL CIIANGES A.
Channel Functional Test Frequency - Technical Specification Table 4.3.4.2.1-1:
P Change the test frequency from Monthly to Quarterly for the following Trip Functions:
i L
Turbine Stop Valve-Closure 2.
Turbine Control Valve - Fast Closure l
B.
Technical Specification Bases - Add a statement to the bases providing the reference for this amendment (Insert B to Attachment B).
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. ATTACHMENT A DESCRIPTION 'OF SAFETY ANALYSIS OF PROPOSED CHANGES I
APPENDIX III
- i MISCELLANEOUS EDITORIAL CIIANGES A.
This part of the amendment request deletes footnotes related to the waiver l
of surveillances required to allow operation of Unit i until the first refueling outage. The footnote on page 3/4 3-8 no longer applies and should be deleted.
1.
Delete footnote "*" in Table 4.3.1.1-1 in the channel calibration frequency designation "R*" for Turbine Controi Valve Fast Closure Valve Trip System.
l Oil Pressure Low.
2.
Delete footnote "*" at the bottom of the page.
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