ML20081B744
| ML20081B744 | |
| Person / Time | |
|---|---|
| Site: | Clinton  |
| Issue date: | 03/09/1995 |
| From: | Office of Nuclear Reactor Regulation |
| To: | |
| Shared Package | |
| ML20081B742 | List: |
| References | |
| NUDOCS 9503160326 | |
| Download: ML20081B744 (6) | |
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NUCLEAR REGULATORY COMMISSION
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WASHINGTON. D.C. 20066 4001 -
SAFETY EVALUATION BY THE OFFICE OF NUCLEAR REACTOR REGULATIOJ E
RELATED TO AMENDMENT NO.on TO FACILITY OPERATING LICENSE NO.'NPF-62 ILLINDIS POWER COMPANY. ET AL.
CLINTON POWER STATION. UNIT NO. 1 DOCKET NO. 50-461
- 1. 0' INTRODUCTION I
i Current technical specifications (TSs) require nuclear power plants to periodically perform response time testing for instrument channels on the reactor protection system (RPS), emergency core cooling systems (ECCS) and the i
isolation actuation instrumentation. The intent of these tests is to ensure that changes in response time of instrumentation beyond the limits assumed in safety analyses are detected, and combined with instrument calibration, to ensure that the instrument is operating correctly. The response time tests do not demonstrate that the instrument response time design value is met, but rather that the specified performance requirements of the TSs are satisfied.
By letter dated January 14, 1994, the Boiling Water Reactor Owners' Group (BWROG) submitted topical report NEDO-32291, " System Analyses for Eliminatic, of Selected Response Time Testing Requirements," for staff review. The BWROG stated in NED0-32291 that operational history has shown that significant degradation of instrumentation response times is being detected during the performance of calibrations and other surveillance tests. The BWROG further stated that the performance of conventional response time tests has proven to be of little value in assuring that instrumentation will perform as required or for determining the health of the instrument because the majority of allowable instrumentation response times are system response times rather than instrument times.
The primary argument provided in the topical report in support for the elimination of response time testing is that appropriate alternatives are currently in place per the criteria of Regulatory Guide 1.118, " Periodic Testing of Electric Power and Protection Systems," and IEEE 338-1977, i
" Criteria for the Periodic Testing of Nuclear Power Generating Station Safety Systems," which states:
" Response time testing of all safety-related equipment, per se, is not required if, in lieu of response time testing, the response time of the safety equipment is verified by functional testing, calibration checks or other tests, or both. This is acceptable if it can be demonstrated that changes in response time beyond acceptable limits are accompanied by changes in performance characteristics which are detectable during routine periodic tests."
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., By letter dated December 28, 1994, from B. Boger to R. Pinelli, the staff-approved use of NED0-32291 for the elimination of response time testing _
requirements.
In the accompanying safety evaluation, the staff concluded that significant degradation of instrument response times, i.e., delays greater than about 5 seconds, can be detected during the performance of other surveillance tests, principally calibration, if properly performed.
Accordingly, the staff concluded that response time testing can be eliminated from technical specifications for the selected instrumentation identified in the topical report and accepted NED0-32291 for reference in license amendment applications for all boiling water reactors with the conditions discussed-below:
When submitting plant-specific license amendment requests, licensees must confirm the applicability of the generic analysis of NED0-32291 to their plant, and in addition to the request as shown in Appendix I of the topical report,- the technical specification markup tables as shown in Appendix H, and a list of affected instrument loop components as shown in Appendix C.1, licensees must state that they are following the recemmendations from EPRI NP-7243, " Investigation of Response Time Testing Requirements," and, therefore, are requiring the.following actions:
(a)
Prior to installation of a new transmitter / switch or following refurbishment of a transmitter / switch (e.g., sensor cell or variable damping components), a hydraulic response time test shall be performed to determine an initial sensor-specific response time value, and (b)
For transmitters and switches that use capillary tubes, capillary tube testing shall be performed after initial installation and after any maintenance or modification activity that could damage the lines.
Licensees must also state the following in their requests.
(a)
That calibration is being done with equipment designed to provide a step function or fast ramp in the process variable, (b)
That provisions have been made to ensure that operators and technicians, through an appropriate training program, are aware of the consequences of instrument response time degradation, and that applicable procedures have been reviewed and revised as necessary to assure that technicians monitor for response time degradation during the performance of calibrations and functional tests, (c)
That surveillance testing procedures have been reviewed and revised if necessary to ensure calibrations and functional _ tests are being performed in a manner that allows simultaneous monitoring of both the input and' output response of units under
- test,
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(d)
That for any request involving the: elimination of response time A
testing for Rosemount~ pressure transmitters, the licensee is ini compliance with the guidelines of Supplement I to Bulletin 90-01,-
" Loss of Fill-011 in Transmf tters Manufactured by Rosemount," and-(e).
That for those instruments where the manufacturer recommends periodic response time testing as well as. calibration to ensure?
correct functioning, the licensee has ensured that elimination of.
u response time testing is nevertheless acceptable-for the i
particular application involved.
i By letter dated January 27, 1995, Illinois Power submitted a license amendment application to eliminate instrument response time testing in accordance with NE00-32291.
I 2.0 EVALUATION The licensee's letter of January 27, 1995, referenced NED0-32291 and proposed
-l elimination of response time testing for selected parameters of the (1) t Reactor Protection System (RPS), (2) Containment and Reactor Vessel Isolation 1
Control System (CRVICS), and (3) Emergency Core Cooling System (ECCS)..The licensee stated that the response time tests proposed for elimina' ion are-of little safety significance and result in unnecessary personnel radiation j
exposure, reduced availability of systems during plant shutdown, increased
-1 potential for inadvertent actuations of safety systems, and a significant burden to utility resources. The proposed changes to the Clinton Power Station (CPS) Technical Specifications are different than that provided in Appendix H of NED0-32291 since CPS has recently adopted TS written in the
't Improved TS format. However, the proposed changes meet the intent of Appendix H of NED0-32291.
In accordance with the conditions identified in the staff's safety. evaluation, f
the licensee provided the following information:
Illinois Power (IP) confirmed the applicability of C D0-32291 to CPS.
As identified in Appendix A of the topical report, IP was a participating utility in the evaluation.
In addition, IP has confirmed that the components within the scope of the license amendment application have been evaluated in NED0-32291. The components are identified in Table 1 of the staff's safety evaluation as those instruments / components for which response time testing can be i
eliminated.
IP confirmed that CPS is in conformance with the fo lowing recommendations from EPRI NP-7243, " Investigation of Response Time Testing Requirements:"
1 (a)
Prior to installation of a new transmitter / switch or following refurbishment of a transmitter / switch (e.g., sensor cell or '
variable damping components), a hydraelic response time test will be performed to determine an initial sensor-specific response time i
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IP committled to revise applicable CPS procedures ~ prior to!
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the upcoming refueling outage (RF-5) to fulfill this
. recommendation.
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(b)'
For transmitters and switches that use capillary tubes, capillaryc
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- tube testing shall? be performed after. initial installation and ~
after.any. maintenance or modification activity that could damage the lines. 'IP. stated that CPS does not utilize any: transmitters' 1*
or switches that use capillary tubes in anyJapplication thatD.
4 requires response time testing.. Therefore, thisirecommendation is:
not applicable:to CPS.
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'IP committed to revise applicable calibeation procedures to-include -
steps to input a fast ramp or step change to system components during.
calibrations.
IP has conducted training for operators and technicians in response to Requested Action 4.a of NRC Bulletin 90-01, " Loss of Fill-011 in.
Transmitters Manufactured by Rosemount."
In addition to. addressing the symptoms that.a transmitter exhibits if it is experiencing a loss of ~
' fill oil, this training also addressed the consequences ofcinstrument-response time degradation.
LIP committed to revise surveillance. testing procedures ~to ensure-calibrations and functional tests are being performed in a manner that
. allows simultaneous monitoring of both the input and output response 'of:
' units under. test. The applicable calibration procedures will be. revised to require the. technicians at different locations to be in direct communication to verify that-the response of the transmitter to a step-input' change is prompt, and in all. cases less than five seconds.
IP has complied with the guidelines of Supplement I to NRC Bulletin 90-01.
NRC's evaluation was documented in the staff's letter to IP.
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dated June 15, 1994.
The components affected by this amendment request are: limited to
' i Rosemount transmitters'model 1152, 1153,.1154; GE trip units model-14708505; and GE solid-state logic cards which are currently exempt from response time testing.
IP has revi ued the vendor recommendations for.
these devices and confirmed that they do not contain recommendations.for periodic response time testing.
IP requested response time deletion.for the main steam isolation valve closure c::tuation function which was' not part 'of NED0-32291. By letter dated February 10, 1995, from T. A. Green to Paul Loeser (NRC), adequate justification for the deletion of the response time test for this function was provided. The.
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>1 staff finds this acceptable.
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t The licensee also proposed moving existing SR 3.3.5.1.6 requirements that i
-verify the ECCS response-time limits from the instrumentation section to'new SR 3.5.1.8 under TS 3.5.1, "ECCS-Operating.". This change, which.is outside the scope of NEDO-32291, would be accompr.nied by a note stating that the ECCS actuation instrumentation are-excluded from the ECCS RESPONSE TIME test.
ECCS response time operability requirements specify a time limit for the entire channel, from the time-the monitored parameter exceeds its setpoint until. the i
ECCS equipment is capable of performing its intended function. The frequency of this SR has been changed from "18 months on a STAGGERED TEST BASIS" to "18 months" in order to relate to the appropriate frequency for-testing the associated ECCS subsystem (rather than the instrument channel). Moving the SR from the instrumentation section to the systems section of the TS represents a-relaxation of requirements because existing SR 3.3.5.1.6 was applicable during all MODES of operation when the ECCS subsystems were required to be operable whereas SR 3.5.1.8 is only applicable during MODES 1, 2 and 3.
The staff considers these changes acceptable because there are no design basis events during MODES 4 and 5 where the ECCS systems are relied upon and the response time tests, which are typically performed during shutdown conditions, would idea +1fy any operability problems that may exist.
In addition, during MODES 4 and 5, the probability and consequences of accidents are reduced due to the pressure and temperature limitations of these MODES.
The staff has previously concluded that licensees may reference NED0-32291 in license amendment applications provided that certain conditions are met.
In their application dated January 27, 1995, the licensee addressed each of these conditions and the staff finds the responses acceptable. Therefore, the staff finds the licensee's proposed changes to the CPS TSs acceptable.
3.0 STATE CONSULTATION
In accordance with the Commission's regulations, the Illinois State official was notified of the proposed issuance of the amendment. The State official had no comments.
4.0 ENVIRONMENTAL CONSIDERATION
i This amendment changes a requirement with respect to installation or use of a facility component located within the restricted area as defined in 10 CFR Part 20 and changes surveillance requirements. The NRC staff has determined that the amendment involves no significant increase in the amounts, and no significant change in the types, of any effluent that may be released offsite, and that there is no significant increase in individual or cumulative occupational radiation exposure.
The Commission has previously issued a proposed finding that the amendment involves no significant hazards consideration and there has been no public comment on such finding (60 FR 6739).
Accordingly, the amendment meets the eligibility criteria for categorical exclusion set forth in 10 CFR 51.22(c)(9).
Pursuant to 10 CFR 51.22(b), no environmental impact statement or environmental assessment need be prepared in connection with the issuance of the amendment.
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- 5.0' CONCLUSION The staff has' concluded, based on the considerations discussed above, that:
(1) there is reasonable assurance that the health and safety of the public will not be endangered by operation in the proposed manner, (2) such activities will be conducted in compliance with the Commission's regulations, and (3) the issuance of the amendment will not be inimical to the common
' defense and Lsecurity or to.the health and safety of the public.
Principal Contributor: Douglas V. Pickett Date:
March 9, 1995 f
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