Text

Safety Evaluation Supporting Amends 104 & 90 to Licenses NPF-11 & NPF-18,respectively
	ML20087C279
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Site:	LaSalle
Issue date:	08/02/1995
From:	; NRC (Affiliation Not Assigned)
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NUCLEAR REGULATORY COMMISSION

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SAFETY EVALUATION BY THE-0FFICE OF NUCLEAR REACTOR REGULATION RELATED TO AMENDMENT NO. 104 TO FACILITY OPERATING LICENSE NO. NPF-ll-AND AMEN 0 MENT NO. 90 TO FACILITY OPERATING-LICENSE NO. NPF COMMONWEALTH EDIS0N COMPANY LASALLE COUNTY STATION. UNITS 1 AND 2 DOCKET NOS. 50-373 AND 50-374

1.0 INTRODUCTION

By letter dated December 14, 1994, Commonwealth Edison Company (Comed, the licensee) requested an amendment to Facility Operating Licenses No. NPF-ll ar.d NPF-18 for LaSalle County Station, Units 1 and 2.

The proposed amendments would revise technical specifications (TSs) related to allowed outage times (A0T) and surveillance test intervals (STI) for certain actuation instrumentation in the reactor protection system (RPS), primary containment isolation system (PCIS), emergency core cooling system (ECCS), recirculation j

_ pump trip, reactor core isolation cooling (RCIC), control rod withdrawal block, monitoring, and feedwater/ main turbine trip systems.

These changes are i

generally consistent with General Electric topical reports which have been reviewed and approved by the NRC. The changes also include revising the Feedwater/ Main Turbine Trip Limiting Condition for Operation (LCO) 3.3.8' J

ACTION statement to achieve consistency with existing instrumentation LCOs*

deleting the surveillance of the_ Average Power Range Monitor (APRM) Neutron.

Flux - High, Setdown functional unit in Operational Condition.1; revising the applicability of the provisions of Specification 4.0.4 to several Reactor Protection System and Control Rod Withdrawal Block Instrumentation surveillance requirements; adding the requirement to perform shiftly channel checks for applicable RPS, PCIS, ECCS,. and RCIC instrumentation channels equipped with master trip units; and other changes to correct typographical errors and to delete cycle specific footnotes which are no longer applicable.

1 2 '. 0 EVALUATION 4

The majority of the proposed changes revise the STIs and A0Ts for certain actuation instrumentation in the reactor protection, isolation, emergency core cooling, control rod withdrawal block, monitoring and feedwater/ main -turbine trip systems.

The proposed changes are based on the NRC staff's previous approvals of the following GE licensing topical _ reports (LTRs):

1.

NEDC-30851P-A, " Technical Specification Improvement Analyses for BWR Reactor Protection System," dated March 1988.

This LTR was approved by letter and enclosed safety evaluation dated July 15, 1987, from A. C.

Thadani (NRC) to T. A. Pickens (BWR Owners' Group).

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2.

NEDC-30851P-A (Supplement 2), " Technical Specification Improvement Analysis for BWR Isolation Instrumentation Common to RPS and ECCS:

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Instrumentation," dated March 1989. _This LTR was approved by letter and enclosed safety evaluation dated January 6,1989, from C.

E.- Rossi (NRC).-

to D. N. Grace (BWR Owners' Group).

3.

NEDC-31677P-A, " Technical Specification Improvement Analysis - for BWR Isolation Actuation Instrumentation,"idated ' July 1990.

This.LTR was-approved by letter and enclosed safety evaluation dated June 18, 1990, from C.- E. Rossi (NRC) to S. D. Floyd (BWR Owners' Group).

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'4.

NEDC-30936P-A, "BWR Owner's Group Technical Specification Improvement I

Methodology (With Demonstration for BWR ECCS Actuation instrumentation),

Part 1," dated December 1988.

This LTR was approved by letter and enclosed safety evaluation dated December 9,1988, from A. C.-Thadani 4

(NRC) to D. N. Grace (BWR Owners' Group).

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NEDC-30936P-A, "BWR Owner's Group Technical Specification Improvement j

Methodology (With Demonstration for BWR ECCS Actuation Instrumentation) i Part 2," dated December 1988. This LTR-was approved by_ letter and~_

enclosed safety evaluation dated December 9, 1988, from C. E. Rossi (NRC) to D. N. Grace (BWR Owners' Group).

6.

GENE-770-06-2, " Addendum to Bases for Changes to Surveillance Test' Intervals and Allowed Out-of-Service Times for Selected Instrumentation Technical Specifications," dated February 1991.

This LTR was approved by letter and enclosed safety evaluation dated September 13, 1991, from C. E. Rossi (NRC) to G. J. Beck (BWR Owners' Group).

7.

NEDC-30851P-A (Supplement 1),'" Technical Specification Improvement Analysis for BWR Control Rod Block Instrumentation," dated October 1988.-

This LTR was approved by letter and enclosed safety evaluation dated September 22, 1988,. from C. E. Rossi (NRC) to D. N. Grace (BWR Owners' Group).

8.

GENE-770-06-1, " Bases for. Changes to Surveillance Test' Intervals and Allowed Out-of-Service Times for Selected Instrumentation. Technical

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. Specifications," dated February 1991. This LTR was approved by' letter and enclosed safety evaluation dated' July 21. 1992, from C. E. Rossi (NRC) to R. D. Bing IV (BWR Owners' Group).

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Each of:the'above.LTRs was prepared and approved on a generic basis with l

requirements for individual licensees to perform plant-specific evaluations to demonstrate that the LTRs are applicable to plant-specific license amendment.

. requests.

The licensee has performed the required plant-specific evaluations for LaSalle County Station, Units 1 and 2.

These evaluations are' discussed below:

1.

NEDC-30851P-A identifies LaSalle, a GE BWR-5 product line reactor with a p

Mark 11 containment, as a participating plant in the development of this

LTR. The licensee's December 14, 1994, submittal included proprietary and non-proprietary versions of GE Report MDE-83-0485, Revision 3,

" Technical Specification Improvement Analysis for the Reactor Protection System for LaSalle County Station, Units 1 and 2", April 1991, which concluded that differences between LaSalle and the assumptions in the generic analysis are not significant and that the generic analysis in NEDC-30851P-A is applicable to LaSalle.

The licensee's submittal stated that the applicability of the analyses was not adversely impacted by recent plant modifications. Therefore, the staff concludes that the first condition regarding the use of the LTR has been satisfied for LaSalle.

2.

NEDC-30851P-A (Supplement 2) identifies LaSalle as a participating plant in the development of this LTR.

Section 3.2 of the LTR specifically analyzes BWR 5/6 plants.

The licensee's December 14, 1994, submittal stated that the applicability of the analyses had been confirmed and was not adversely impacted by recent plant modifications.

Therefore, the staff finds that NEDC-30851P-A (Supplement 2) is applicable to LaSalle and, provided other conditions are satisfied, may be used to justify plant specific TS changes.

3.

NEDC-31677P-A identifies LaSalle as a participating plant in the development of this LTR.

Section 5.2 and Appendix C2 of the LTR specifically analyze BWR 5/6 plants. The licensee's December 14, 1994, submittal stated that the applicability of the analyses had been confirmed and was not adversely impacted by recent plant modifications.

Therefore, the staff finds that NEDC-31677P-A is applicable to LaSalle and, provided other conditions are satisfied, may be used to justify plant specific TS changes.

4.

Part 1 of NEDC-30936P-A identifies LaSalle as a participating plant in the development of this LTR. The licensee's December 14, 1994, submittal included proprietary and non-proprietary versions of GE Report RE-025, Revision 1, " Technical Specification Improvement Analysis for the Emergency Core Cooling System Actuation Instrumentation for LaSalle County Station, Units 1 and 2," April 1991, which concludes thct the differences between LaSalle and the assumptions of the generic analysis are not significant and that the generic analyses in NEDC-30936P-A, Parts 1 and 2, are applicable to LaSalle.

The licensee's December 14, 1994, submittal stated that the applicability of the analyses was not adversely impacted by recent plant modifications. Therefore, the staff concludes that the first condition for use of NEDC-30936P-A, Part 1, has been satisfied for LaSalle.

5.

Part 2 of NEDC-30936P-A identifies LaSalle as a participating plant in the development of this LTR. Section 5.5 of the LTR specifically analyzes EWR 5/6 plants.

Furthermore, as noted above, GE Report RE-025, Revision 1, also concludes that the generic analyses in NEDC-30936P-A are applicable to LaSalle. The licensee's December 14, 1994, submittal stated that the applicability of the analyses was not adversely

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Therefore, the staff concludes-that the first condition for use of NEDC-30936P-A, Part 2, has been satisfied for LaSalle.

6.

GENE-770-06-1 identifies application of changes to surveillance test

-intervals and allowed out-of-service times for selected instrumentation 1

for all BWR plants. The licensee's December 14, 1994, submittal stated that an evaluation was performed to verify the applicability of the i

analyses, including the potential impact of recent plant modifications, and it was determined that the generic analyses are valid for LaSalle.

l Therefore, the staff concludes that GENE-770-06-1 is an appropriate j

reference for the justification of certain plant specific TS changes for l

LaSalle.

7.

GENE-770-06-2 addressed TS changes for BWR 5/6 plants such as LaSalle.

l The licensee's December 14, 1994, submittal stated that an evalnation was performed to verify the applicability of the analyses, including the potential impact of recent plant modifications, and it was determined that the generic analyses are valid for LaSalle.

Therefore, the staff concludes that GENE-770-06-2 may be used as part of the justification of.

j plant. specific TS changes for LaSalle.

8.

NEDC-30851P-A (Supplement 1) identifies LaSalle as a participating plant in the development of this LTR.

Section 4 of the LTR addresses BWR-5 i

plants such as LaSalle. The licensee's December 14, 1994, submittal stated that the applicability of the analyses had been confirmed and was not adversely impacted by recent plant modifications. Tperefore,the' staff concludes that the first condition for use of NEDC-30851P-A l

(Supplement 1) has been satisfied for LaSalle.

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Each of the above LTRs also contains requirements for licensees to demonstrate j

that the drift characteristics for the applicable instrumentation are bounded by the assumptions used in the LTRs when the' functional test interval is extended from-monthly to quarterly.

The' LaSalle setpoint calculations assumed 18-month trip unit calibration intervals and, therefore, are not affected by the changes proposed in the licensee's amendment request. In addition, sensor calibrction intervals for the LaSalle instrumentation addressed by the LTR; were verified by the licensee to be equal to or longer than once per quarter and are, therefore, unaffected by the proposed changes. The licensee has i

concluded that the drift characteristics of the involved instrumentation are not impacted by the extension of functional test intervals since calibration frequencies are not changed from their current quarterly or refueling outage interval.

The staff finds that the licensee has adequately addressed the conditional approval of the LTRs as it relates to the concern of instrument drift.

This finding is consistent with the clarification regarding instrument drift allowances provided in a letter dated April 27, 1988, from C. E. Rossi (NRC) to R. F. Janecek (BWR Owners' Group).

4 NEDC-30851P-A requires licensees confirm at the differences between a plant specific RPS and those of the base case plant modelled in the LTR are i

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. evaluated in a plant-specific analysis using the procedures of Appendix K of the LTR.

The plant-specific analysis was documented in GE Report MDE-83-0485, Revision 3.

This report utilized the procedures of Appendix K of NEDC-30851P-A to identify and evaluate the RPS differences. The results of this analysis indicated that while the LaSalle and base case RPS configurations have several differences, the differences do not have a significant impact on the generic conclusions.

The staff concludes that the licensee has satisfied the requirement of NEDC-30851P-A to evaluate the RPS configuration differences and that those differences do not adversely impact the applicability of the topical report to LaSalle.

The GE Report RE-025, Revision 1, was included in the submittal and included a similar evaluation of the LaSalle ECCS as compared to the generic analyses of NEDC-30936P-A.

As with the RPS, several differences were identified between the base case and LaSalle. The evaluation determined that those differences did not adversely impact the applicability of the ECCS actuation instrumentation STI and A0T extensions to LaSalle.

Several suggested changes included in the LTRs were previously incorporated into the LaSalle, Units 1 and 2, TS by Amendment Nos. 95 and 79.

These changes included decreasing the channel functional test interval requirement for RPS Functional Unit 12, Manual Scram, from monthly to weekly and increasing the channel functional test interval requirement for Main Steam Line Isolation Valve Closure, Turbine Stop Valve Closure, and Turbine Control Valve Fast Closure Valve Trip System Oil Pressure Low from monthly to quarterly.

Given that the licensee has demonstrated that the conditions for application of the above LTRs have been satisfied, the staff finds that the acceptability of the proposed changes may be determined by ensuring they are consistent with those contained in the LTRs.

The staff evaluations of specific proposed changes are as follows:

TS 3/4.3.1 - Reactor Protection System (RPS) Instrumentation ACTIONS a. and b. for TS 3.3.1 specify actions to be taken in the event that the rumber of operable RPS instrumentation channels is less than required by TS Table 3.3.1-1. The proposed changes would revise ACTIONS a. and b. to read:

l a.

With one channel required by Table 3.3.1-1 inoperable in one or more Functional Units, place the inoperabic channel and/or that trip system in the tripped condition

within 12 hours1.388889e-4 days 0.00333 hours 1.984127e-5 weeks 4.566e-6 months .

b.

With two or more channels required by Table 3.3.1-1 inoperable in one or more functional Units:

1.

Within one hour, verify sufficient channels remain OPERABLE or tripped

to maintain trip capability in the Functional Unit, and

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2.

Within 6 hours6.944444e-5 days 0.00167 hours 9.920635e-6 weeks 2.283e-6 months , place the inoperable channel (s) l

1 in one trip system and/or that trip system ** in i

the tripped condition *, and 3.

Within 12 hours1.388889e-4 days 0.00333 hours 1.984127e-5 weeks 4.566e-6 months , restore the inoperable channels i

in'the other. trip system to an OPERABLE status or tripped *,

l c.

Otherwise, take the ACTION required by Table 3.3.1-1 for the

'3 functional Unit.

An inoperable channel or trip system need not be placed.in the tripped condition where this would cause the Trip Function to occur.

In these cases, if the inoperable channel is not restored to OPERABLE status within the required time, the i

ACTION required by Table 3.3.1-1 for the Functional Unit shall be taken.

- This ACTION applies to that' trip system with the most inoperable channels; if both trip systems have the same number of inoperable channels, the ACTION can be applied to either trip system.

The proposed changes-to ACTIONS a. and b. for TS 3.3.1 would increase.and' clarify the time permitted to place an inoperable RPS instrumentation channel in the tripped condition when the number of operable channels is less than required.

These changes are consistent with NEDC-30851P-A and with current

'NRC staff positions and related guidance provided in NUREG-1434 to ensure that.

j a loss of function will not exist if two or more channels are inoperable.

The staff finds the changes acceptable, j

j The proposed change to Table Notation (a).on TS Table 3.3.1-1 would revise the allowable time a channel may be: inoperable for the purpose of performing required surveillances without-placing the channel in the tripped condition provided at least one operable channel in the same trip system is monitoring 1

that parameter. The allowed time is changed from 2 hours2.314815e-5 days 5.555556e-4 hours 3.306878e-6 weeks 7.61e-7 months to 6 hours6.944444e-5 days 0.00167 hours 9.920635e-6 weeks 2.283e-6 months . 'This-proposed change is consistent with the provisions' of NEDC-30851P-A and is, therefore, acceptable.

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The proposed changes included in the licensee's December 14,-1994, submittal included revising the channel functional test interval for the following functional Units from weekly or monthly to quarterly:

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2.b Average Power Range Monitor Flow Biased Simulated Thermal Power Upscale 2.c Average Power Range Monitor Fixed Neutron Flux - Upscale 2.d Average Power Range Monitor Inoperative 3

Reactor Vessel Steam Dome Pressure - High 4

Reactor Vessel Water Level - Low, Level 3 l

6 Main Steam Line Radiation - High 7

Drywell Pressure - High 8

Scram Discharge Volume Water Level - High The proposed changes to the above STIs in TS Table 4.3.1.1-1 are consistent with previously reviewed and approved LTR NEDC-30851P-A and the plant specific verifications in MDE-78-0485 and are, therefore, acceptable.

In addition to the above changes related to STI extensions, the licensee has proposed to revise the channel check requirements for functional unit 4, Reactor Vessel Water Level - Low, Level 3, from NA (not applicable) to once

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per shift. This change results from-LaSalle installing analog instrumentation t

to replace static-o-ring (SOR) switches for reactor vessel level determination in the RPS, PCIS, ECCS, and RCIC systems. The SOR switches'previously used for reactor vessel water level applications were not equipped with an indicator which would permit the performance of a channel check. The master trip units are now equipped with indicators which permit performing I

instrumentation channel checks. The requirement to perform this task is not stated in the TSs. A requirement to perform a shiftly channel check may now be added to the TSs for the applicable RPS, PCIS, ECCS, and RCIC instrumentation channels equipped with master trip units.

The staff finds the addition of the channel check requirement improves the reliability of the channel and is, therefore, acceptable.

The licensee has proposed to revise TS Table 4.3.1.1-1, functional unit 1, Intermediate Range Monitors, and functional unit 2, APRM, by the addition of a footnote to operational conditions 2 and 3.

The footnote states that:

"The provisions of Specification 4.0.4 are not applicable for a period of 24 hours2.777778e-4 days 0.00667 hours 3.968254e-5 weeks 9.132e-6 months after entering OPERATIONAL CONDITION 2 or 3 when shutting down from OPERATIONAL CONDITION 1."

This change is intended to provide the plant operators with better guidance for the application of TS 4.0.4.

In cases where complete surveillances can not be achieved, such as during a plant shutdown, then the required surveillances will be performed within 24 hours2.777778e-4 days 0.00667 hours 3.968254e-5 weeks 9.132e-6 months of entering the MODE or condition in which the surveillance is required. The APRM Fixed Neutron Flux

- High quarterly function tests most of.the APRM channel equipment associated with the APRM Neutron Flux - High, Setdown scram.

The APRM Fixed Neutron Flux

- High and other RPS functions would also be available to provide protection

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in the event of a design basis accident or transient. The staff finds the change is generally consistent with the guidance provided in Generic Letter 87-09 which discussed possible conflicts associated with TS surveillances and e

. changes in operational conditions, and with previously issued amendments and NUREG-1434. The staff finds the addition of the footnote acceptable.

The licensee has also proposed to delete Operational Condition 1 from the list of applicable conditions for the requirements of the APRM Fixed Flux - High, Setdown (functional unit 2.a).

This is proposed in order to make Table 4.3.1.1-1 consistent with Table 3.3.1-1 and Bases 2.2.1, Item 2, Average Power Range Monitor. The APRM Neutron Flux - High, Setdown scram setting provides adequate thermal margin between the setpoint and the Safety Limits for operation at low pressure and low flow during plant startup (power ascension).

However, upon entering Operational Condition 1, the Setdown function is bypassed and it is not practical to perform a surveillance.

Therefore, the staff finds it appropriate to delete the requirement for performing the surveillance in Operational Condition 1.

TS 3/4 ].2 - Isolation Actuation Instrumentation t

ACTIONS b. and c. for TS 3.3.2 specify actions to be taken in the event that the number of operable isolation actuation instrumentation channels is less than the minimum required by Table 3.3.2-1.

The proposed changes would revise ACTIONS b. and c. to read:

b.

With the number of OPERABLE channels less than required by the i

Minimum OPERABLE Channels per Trip System Requirement for one trip system, either 1.

Place the inoperable channel (s) in the tripped condition within a) I hour for trip functions without an OPERABLE channel, b) 12 hours1.388889e-4 days 0.00333 hours 1.984127e-5 weeks 4.566e-6 months for trip functions common to RPS Instrumentation, and c) 24 hours2.777778e-4 days 0.00667 hours 3.968254e-5 weeks 9.132e-6 months for trip functions not common to RPS Instrumentation.

or 2.

Take the ACTION required by Table 3.3.2-1.

c.

With the number of OPERABLE channels less than required by the Minimum OPERABLE Channels per Trip System requirement for both trip systems, 1.

Place at least one trip system ** in the tripped condition ***

within one hour, and 2.

a) Place the inoperable channel (s) in the remaining trip system in the tripped condition *** within

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1) 1 hour1.157407e-5 days 2.777778e-4 hours 1.653439e-6 weeks 3.805e-7 months for trip functions without an OPERABLE channel',

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2) 12 hours1.388889e-4 days 0.00333 hours 1.984127e-5 weeks 4.566e-6 months fc

+ rip functions common to RPS Instrumente wn,.and l

3) 24 hours2.777778e-4 days 0.00667 hours 3.968254e-5 weeks 9.132e-6 months for trip functions not common to RPS j

Instrumentation.

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b) Take the ACTION required by Table 3.3.2-1.

t The proposed changes to ACTIONS b. and c. for TS 3.3.2 would increase and clarify the time permitted to place an inoperable channel in the tripped condition when the number of operable channels is less than required. The revised footnote (*). increases the allowable time from 2 hours2.314815e-5 days 5.555556e-4 hours 3.306878e-6 weeks 7.61e-7 months to 6 hours6.944444e-5 days 0.00167 hours 9.920635e-6 weeks 2.283e-6 months to restore an inoperable channel whose placement in the tripped condition would cause the Trip function to occur.

These changes are acceptable since they are i

consistent with NEDC-30851P-A (Supplement 2) and NEDC-31677P-A and with I

current NRC staff positions and related guidance provided in NUREG-1434 to ensure that a loss of function will not exist if two or more channels are inoperable.

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The proposed change to'TS Table 3.3.3-1 note -(a) increases the time permitted for an isolation actuation instrumentation channel to be placed in an inoperable status for surveillance purposes without placing the trip system in the tripped condition from 2 to 6 hours6.944444e-5 days 0.00167 hours 9.920635e-6 weeks 2.283e-6 months .

This proposed change is consistent with the provisions of NEDC-30851P-A (Supplement 2) and NEDC-31677P-A and is,.

therefore, acceptable.

The proposed changes to TS Table 4.3.2.1-1 would increase the' channel functional test interval requirement for the following Trip Functions from monthly to quarterly:

1.

Primary Containment Isolation 2.

Secondary Containment Isolation 3.

Reactor Water Cleanup System Isolation

.i (except for standby liquid control system initiation which is currently performed on a refueling outage interval) 4.

Reactor Core Isolation Cooling System Isolation 5.

Residual Heat Removal (RHR) System Steam Condensing Mode Isolation 6.

RHR System Shutdown Cooling Mode Isolation The proposed changes to TS Table 4.3.2.1-1 are consistent with the previously reviewed and approved LTRs NEDC-30851P-A (Supplement 2) and NEDC-31677P-A.

.The staff finds these changes acceptable.

In addition to the above changes related to STI extensions, the licensee has proposed to revise the channel check requirements' for functional units A.I.a.1, PCIS Reactor Vessel Water Level - Low, Level 3; A.I.a.3, PCIS Reactor Vessel Water Level - Low, Low, Low, level 1; and A.6.a. RHR Shutdown Cooling Mode Isolation, Reactor Vessel Water Level - Low, Level 3, from NA (not

10 -

applicable) to once per shift.

This change results from LaSalle changing the plant design such that the channel checks are now feasible. Master trip units are now equipped with indicators which permit performing instrumentation channel checks. The requirement to perform this task is not stated in the TSs. A requirement to perform a shiftly channel check may now be added to the TSs for the applicable RPS, PCIS, ECCS, and RCIC instrumentation channels equipped with master trip units.

The staff finds the addition of the channel check requirement improves the reliability of the channel and is, therefore, acceptable.

TS 3/4.3.3 - Emeraency Core Coolina System Actuation Instrumentation The current Table Notation (a) on TS Table 3.3.3-1 specifies that an ECCS actuation instrumentation channel may be placed in an inoperable status for up to 2 hours2.314815e-5 days 5.555556e-4 hours 3.306878e-6 weeks 7.61e-7 months during periods of required surveillance without placing the trip system in the tripped condition provided at least one other operable channel in the same trip system is monitoring that parameter. The proposed change to Table Notation (a) would revise the 2 hours2.314815e-5 days 5.555556e-4 hours 3.306878e-6 weeks 7.61e-7 months to 6 hours6.944444e-5 days 0.00167 hours 9.920635e-6 weeks 2.283e-6 months .

Table Notation (d) is added to address the Loss of Power functional units.

The proposed (d) notation is the same as the existing (a) notation and allows 2 hours2.314815e-5 days 5.555556e-4 hours 3.306878e-6 weeks 7.61e-7 months for restoration of operability without placing the channel in trip.

The footnote was added because the generic analyses did not address the loss of power function and, therefore, the licensee maintained the existing limitations.

ACTION 30 on TS Table 3.3.3-1 applies to Reactor Vessel Water Level - Low, Low, Low, Level 1 and Drywell Pressure - High Instrument Channels.

The current ACTION 30 requires that if one channel is inoperable and the number of operable channels is less than required by the minimum operable channels per trip function requirement, the inoperable channel must be placed in the tripped condition within I hour or the associated system must be declared inoperable. The proposed change to ACTION 30 would extend the 1 hour1.157407e-5 days 2.777778e-4 hours 1.653439e-6 weeks 3.805e-7 months to 24 hours2.777778e-4 days 0.00667 hours 3.968254e-5 weeks 9.132e-6 months .

ACTION 31 on TS Table 3.3.3-1 applies to Low Pressure Core Spray (LPCS) Pump Discharge Flow - Low (Bypass), Low Pressure Coolant Injection (LPCI) Pump Discharge Flow - Low (Bypass), High Pressure Core Spray (HFCS) System Flow Rate - Low (Bypass), and HPCS Pump Discharge Pressure - High (Bypass) channels.

The current ACTION 31 requires that if the number of operable channels is less than required by the minimum operable channels per trip function requirement, the inoperable channel must be placed in the tripped condition within I hour and restored to operable status within 7 days or the associated system must be declared inoperable. The proposed change to ACTION 31 would extend the I hour to 24 hours2.777778e-4 days 0.00667 hours 3.968254e-5 weeks 9.132e-6 months .

ACTION 32 on TS Table 3.3.3-1 applies to LPCS and LPCI Injection Valve Injection Line Pressure - Low (Permissive), LPCI Pump Start Time Delay Relay, ADS (Automatic Depressurization System) Initiation Timer, Reactor Vessel Water Level - Low, Level 3 (Permissive), LPCS Pump Discharge Pressure - High (Permissive), LPCI Pump Discharge Pressure - High (Permissive), Drywell Pressure Bypass Timer, and Reactor Vessel Water Level - High, level 8

. channels. The current ACTION 32 requires that if the number of operable channels is less than required by the minimum operable channels per trip function requirement, the associated ADS trip system or ECCS must be declared inoperable. The proposed change to ACTION 32 would provide a period of 24 hours2.777778e-4 days 0.00667 hours 3.968254e-5 weeks 9.132e-6 months before the associated ADS trip system or ECCS must be declared inoperable.

ACTION 33 on TS Table 3.3.3-1 applies to LPCS and LPCI Injection Valve Permissive channels during operational conditions 4 and 5.

The current ACTION 33 requires that if the number of operable channels is less than required by the minimum operable channels per trip function requirement, the inoperable i

channel must be placed in the tripped condition with I hour. The proposed change to ACTION 33 would extend the 1 hour1.157407e-5 days 2.777778e-4 hours 1.653439e-6 weeks 3.805e-7 months to 24 hours2.777778e-4 days 0.00667 hours 3.968254e-5 weeks 9.132e-6 months .

ACTION 34 on TS Table 3.3.3-1 applies to the ECCS Manual Initiation and ADS manual initiation and manual inhibit channels. The current ACTION 34 requires that if the number of operable channels is less than required by the minimum operable channels per trip function requirement, the inoperable channel must i

be restored to operable status within 8 hours9.259259e-5 days 0.00222 hours 1.322751e-5 weeks 3.044e-6 months or the associated ADS trip system or ECCS must be declared inoperable. The proposed change to ACTION 34 j

would extend the 8 hours9.259259e-5 days 0.00222 hours 1.322751e-5 weeks 3.044e-6 months to 24 hours2.777778e-4 days 0.00667 hours 3.968254e-5 weeks 9.132e-6 months , ACTION 35 on TS Table 3.3.3-1 applies to the Reactor Vessel Water Level - Low, Low, Level 2 and Drywell Pressure - High channels that actuate HPCS. The current ACTION 35 requires that if the number of operable channels is less than required by the minimum operable channels per trip function requirement for one trip system, that trip system must be placed in the tripped condition j

within I hour or the HPCS system must be declared inoperable. The proposed change to ACTION 35 would extend the 1 hour1.157407e-5 days 2.777778e-4 hours 1.653439e-6 weeks 3.805e-7 months to 24 hours2.777778e-4 days 0.00667 hours 3.968254e-5 weeks 9.132e-6 months .

ACTION 38 on TS Table 3.3.3-1 applies to the LPCS and LPCI Injection Valve Reactor Pressure - Low (Permissive) channels during operational conditions 1, 2 and 3.

The current ACTION 38 requires that with one channel inoperable, remove the inoperable channel within one hour and restore the inoperable channel within 7 days or declare the associated ECCS systems inoperable.

The proposed change to ACTION 38 would extend the I hour to 24 hours2.777778e-4 days 0.00667 hours 3.968254e-5 weeks 9.132e-6 months .

The proposed changes to TS Table 3.3.3-1 are acceptable since they are consistent with the previously reviewed and approved LTR NEDC-30936P-A

)

(Part 2), the plant specific analysis in RE-025, Revision 1, and with current NRC staff positions and related guidance provided in NUREG-1434 to ensure that a loss of function will not exist if two or more channels are inoperable.

The proposed changes to TS Table 4.3.3.1-1 would extend the channel functional test interval requirement from monthly to quarterly for the trip functions 4

listed below. The ECCS and ADS Manual Initiation and ADS Manual Inhibit channels remain on a refueling outage interval for channel functional testing.

The calibration frequencies remain on either a quarterly or refueling outage interval.

. a.

Division I Trip System - (Trip Function A.)

b.

Division 11 Trip System - (Trip Function B.)

Division III Trip System - (Trip Function C.)

c.

The proposed changes to TS Table 4.3.3.1-1 are consistent with the previously reviewed and approved LTRs NEDC-30936P-A (Parts 1 and 2) and the plant specific analysis provided in RE-025, Revision 1.

The staff finds these changes acceptable.

In addition to the above changes related to STI extensions, the licensee has proposed to revise the channel check requirements for ECCS actuation instrumentation functional units related to Reactor Vessel Water Level -Low, Low, Low, Level 1 and Reactor Vessel Water Level - Low, Level 3.

The requirements are changed from NA (not applicable) to once per shift.

This change results from LaSalle changing the plant design such that the channel checks are now feasible. Master trip units are now equipped with indicators which permit performing instrumentation channel checks.

The requirement to perform this task is not currently stated in the TSs.

A requirement to perform a shiftly channel check may now be added to the TSs for the applicable RPS, PCIS, ECCS, and RCIC instrumentation channels equipped with master trip units.

The staff finds the addition of the channel. check requirement improves the reliability of the channel and is, therefore, acceptable.

TS 3/4.3.4 - Recirculation Pumo Trio Actuation Instrumentation ACTION b. for TS 3.3.4.1 currently requires that the inoperable channel (s) be placed in the tripped condition within I hour if the number of operable anticipated transient without scram recirculation pump trip (ATWS-RPT) system channels is one less than required by the minimum operable channels per trip system requirement for one or both trip systems.

The proposed change to ACTION b. would extend the I hour period to 24 hours2.777778e-4 days 0.00667 hours 3.968254e-5 weeks 9.132e-6 months .

ACTION c.l. for TS 3.3.4.1 currently requires that both inoperable channels be placed in the tripped condition within I hour if the minimum number of operable ATWS-RPT system channels is two or more less than required by the minimum operable channels per trip system requirement for one trip system and the inoperable channels consist of one reactor vessel water level channel and one reactor vessel pressure channel.

The proposed change to Action c.l. would extend the 1 hour1.157407e-5 days 2.777778e-4 hours 1.653439e-6 weeks 3.805e-7 months period to 24 hours2.777778e-4 days 0.00667 hours 3.968254e-5 weeks 9.132e-6 months . Notation (a) for TS Table 3.3.4.1-1 currently allows one channel in one trip system to be placed in an inoperable status for up to 2 hours2.314815e-5 days 5.555556e-4 hours 3.306878e-6 weeks 7.61e-7 months for required surveillance provided that all other channels are operable. The proposed change would extend the 2 hours2.314815e-5 days 5.555556e-4 hours 3.306878e-6 weeks 7.61e-7 months to 6 hours6.944444e-5 days 0.00167 hours 9.920635e-6 weeks 2.283e-6 months .

The proposed changes to TS 3.3.4.1 and TS Table 3.3.4.1-1 are consistent with the previously reviewed and approved LTR GENE-770-06-1 and are, therefore, acceptable.

I

3

. The proposed revisions to TS Table 4.3.4.1-1 would change the channel functional test interval requirement from monthly to quarterly for the following trip functions:

1.

Reactor Vessel Water Level - Low, Low, Level 2 2.

Reactor Vessel Pressure - High The proposed changes to TS Table 4.3.4.1-1 are consistent with the previously reviewed and approved LTR GENE-770-06-1 and are, therefore, acceptable.

ACTION b. for TS 3.3.4.2 currently requires that the inoperable end-of-cycle recirculation pump trip (EOC-RPT) instrumentation channel (s) be placed in the tripped condition within I hour if the number of operable channels is one less than required by the minimum operable channels per trip system requirement for one or both trip systems.

The proposed change to ACTION b. would extend the I hour for placing the inoperable channel (s) in the tripped condition to 12 hours1.388889e-4 days 0.00333 hours 1.984127e-5 weeks 4.566e-6 months .

ACTION c.l. for TS 3.3.4.2 currently requires that both inoperable channels be placed in the tripped condition within I hour if the number of operable E0C-RPT channels is two or more less than required by the minimum operable channels per trip system requirement for one trip system and if the inoperable channels consist of one turbine control valve channel and one turbine stop valve channel.

The proposed change to ACTION c.l. would extend the I hour period to 12 hours1.388889e-4 days 0.00333 hours 1.984127e-5 weeks 4.566e-6 months .

The proposed change to the footnote (a) on Table 3.3.4.2-1 would extend the amount of tim'e that an EOC-RPT trip system may be placed in an inoperable status for required surveillance from 2 hours2.314815e-5 days 5.555556e-4 hours 3.306878e-6 weeks 7.61e-7 months to 6 hours6.944444e-5 days 0.00167 hours 9.920635e-6 weeks 2.283e-6 months .

The proposed changes to TS 3.3.4.2 and TS Table 3.3.4.2-1 are consistent with the previously reviewed and approved LTR GENE-770-06-1 and are, therefore, acceptable.

15 3/4.3.5 - Reactor Core isolation Coolina System Actuation Instrumentation Table Notation (a) on TS Table 3.3.5-1 currently permits a RCIC system actuation instrument channel to be placed in an inoperable status for up to 2 hours2.314815e-5 days 5.555556e-4 hours 3.306878e-6 weeks 7.61e-7 months for required surveillance.

The proposed change to Notation (a) would extend the 2 hours2.314815e-5 days 5.555556e-4 hours 3.306878e-6 weeks 7.61e-7 months to 6 hours6.944444e-5 days 0.00167 hours 9.920635e-6 weeks 2.283e-6 months .

ACTION 50 on TS Table 3.3.5-1 applies to the Reactor Vessel Water Level - Low, Low, level 2 instrumentation functional units. ACTION 50 currently specifies that the inoperable channel must be placed in the tripped condition within I hour or the RCIC system must be declared inoperable if the number of operable channels for one trip system is less than required by the minimum operable channels per trip system requirement. The proposed change to ACTION 50 would extend the I hour to 24 hours2.777778e-4 days 0.00667 hours 3.968254e-5 weeks 9.132e-6 months .

l

. ACTION 51 on TS table 3.3.5-1 applies to the Reactor Vessel Water Level -

High, Level 8 instrumentation functional units. ACTION 51 currently specifies that the RCIC system be declared inoperable if the number of operable channels is less than the minimum operable channels per trip system requirement. The proposed change incorporates a 24 hour2.777778e-4 days 0.00667 hours 3.968254e-5 weeks 9.132e-6 months allowable time period in which to declare the RCIC system inoperable.

ACTION 52 on TS Table 3.3.5-1 applies to the Manual Initiation RCIC instrumentation functional unit. ACTION 52 currently specifies that the inoperable channel must be restored to operable status within 8 hours9.259259e-5 days 0.00222 hours 1.322751e-5 weeks 3.044e-6 months or the RCIC system must be declared inoperable if the number of operable channels is one less than required by the minimum operable channels per trip system requirement. The proposed change to ACTION 52 would extend the 8 hours9.259259e-5 days 0.00222 hours 1.322751e-5 weeks 3.044e-6 months to 24 hours2.777778e-4 days 0.00667 hours 3.968254e-5 weeks 9.132e-6 months .

The proposed changes to TS Table 3.3.5-1 are consistent with the previously reviewed and approved LTR GENE-770-06-2 and are, therefore, acceptable.

The proposed changes to TS Table 4.3.5.1-1 would revise the channel functional test interval requirement for the following RCIC trip functions from monthly to quarterly:

a.

Reactor Vessel Water Level - Low, Low, Level 2 b.

Reactor Vessel Water Level - High, Level 8 Functional unit (c), Manual Initiation, is maintained with its current refueling outage interval for channel functional testing.

Channel calibration intervals are also retained at the current refueling outage intervals.

The proposed changes to TS Table 4.3.5.1-1 are consistent with the previously reviewed and approved GENE-770-06-2 and are, therefore, acceptable.

In addition to the above changes related to STI extensions, the licensee has l

proposed to revise the channel check requirements for RCIC actuation instrumentation functional unit (b), Reactor Vessel Water Level - High, Level 8.

This change results from LaSalle changing the plant design such that the channel checks are now feasible. Master trip units are now equipped with indicators which permit performing instrumentation channel checks. The requirement to perform this task is not currently stated in the TSs. A requirement to perform a shiftly channel check may now be added to the TSs for the applicable RPS, PCIS, ECCS, and RCIC instrumentation channels equipped with master trip units. The staff finds the addition of the channel check requirements improves the reliability of the channels and is acceptable.

TS 3/4.3.6 - Control Rod Withdrawal Block Instrumentation The licensee has proposed to add a footnote to TS 4.3.6 that would allow a control rod block instrumentation channel to be placed in an inoperable status for up to 6 hours6.944444e-5 days 0.00167 hours 9.920635e-6 weeks 2.283e-6 months for required surveillance or up to 12 hours1.388889e-4 days 0.00333 hours 1.984127e-5 weeks 4.566e-6 months for repair without placing the trip system in the tripped condition, provided at least

i l

3

. one other operable channel in the same trip system is monitoring that trip function.

ACTION 62 on TS Table 3.3.6-1 applies to the control rod block trip functions 5., Scram Discharge Volume and 6., Recirculation Flow Unit. ACTION 62 currently specifies that an inoperable channel must be placed in the tripped condition within I hour if the minimum number of operable channels is less than required by the minimum operable channels per trip system requirement.

The proposed revision to ACTION 62 would change the I hour to 12 hours1.388889e-4 days 0.00333 hours 1.984127e-5 weeks 4.566e-6 months .

The proposed changes to TS 4.3.6 and TS Table 3.3.6-1 are consistent with previously reviewed and approved LTR GENE-770-06-1 and, therefore, acceptable.

The proposed changes to TS Table 4.3.6-1 would modify the channel functional test interval requirement for the following control rod block trip functions from monthly to quarterly:

1.

Rod Block Monitor 2.

APRM (Average Power Range Monitor) 5.b Scram Discharge Volume - Switch in Bypass 6

Reactor Coolant System Recirculation Flow The proposed changes to TS Table 4.3.6-1 are consistent with the previously reviewed and approved LTR NEDC-30851P-A (Supplement 1) and are, therefore, acceptable.

The licensee has also proposed a footnote which would apply to control rod withdrawal block functions 2.d, APRM Neutron Flux - High; 3., Source Range Monitors; and 4., Intermediate Range Monitors. The footnote specifies that the provisions of TS 4.0.4 are not applicable for a period of 24 hours2.777778e-4 days 0.00667 hours 3.968254e-5 weeks 9.132e-6 months after entering operational conditions 2 or 3 when shutting down from operational condition 1.

This change is related to the previous discussion of neutron monitors input to the RPS.

This footnote is generally consistent with the guidance provided in Generic Letter 87-09 which discussed possible conflicts associated with TS surveillances and changes in operational conditions, and with previously issued amendments and NUREG-1434.

The staff finds the addition of the footnote acceptable.

TS 3/4.3.7 - Monitorina Instrumentation The licensee has proposed to add a Table Notation (e) to TS Table 3.3.7.1-1, Radiation Monitoring Instrumentation.

This table notation would apply to the Main Control Room Ventilation Radiation Monitor channels and permit a single channel to be placed in an inoperable status for up to 6 hours6.944444e-5 days 0.00167 hours 9.920635e-6 weeks 2.283e-6 months for required surveillance without placing the trip system in the tripped condition, provided at least one other operable channel in the same trip system is monitoring the trip function.

e

. i The proposed revision to TS' Table 4.3.7.1-1 would change the channel functional test interval requirement for the Main Control Room Ventilation Radiation Monitors from monthly to quarterly.

The proposed changes to TS Tables 3.3.7.1-1 and 4.3.7.1-1 are consistent with the previously reviewed and approved LTR GENE-770-06-1 and are, therefore, acceptable.

3/4.3.8 - Feedwater/ Main Turbine Trio System Actuation Instrumentation ACTIONS a, b, and c for TS 3/4.3.8, Feedwater/ Main Turbine Trip System Actuation Instrumentation, specif1es the requirements for conditions involving inoperable channels of Reactor Vessel Water Level - High, level 8 instrumentation.

The proposed changes would revise the action statements to read:

a.

With a feedwater/ main turbine trip system actuation instrumentation channel trip setpoint less conservative than the value shown in the Allowable Values column of Table 3.3.8-2, declare the channel inoperable until the channel is restored to f

OPERABLE status with its trip setpoint adjusted consistent with the Trip Setpoint value, b.

With the number of OPERABLE channels one less than that required by the Minimum OPERABLE Channels per Trip System requirement:

1.

Within 7 days, either place the inoperable channel in the tripped

condition or restore the inoperable channel to OPERABLE status.

2.

Otherwise, be in at least STARTUP within 6 hours6.944444e-5 days 0.00167 hours 9.920635e-6 weeks 2.283e-6 months .

c.

With the number of OPERABLE channels two less than required by the Minimum OPERABLE Channels per Trip System requirement:

1.

Within two hours place or verify at least one inoperable channel in the tripped

condition, and restore either i

inoperable channel to OPERABLE status within 72 hours8.333333e-4 days 0.02 hours 1.190476e-4 weeks 2.7396e-5 months , or,

)

1 2.

Be in at least STARIUP within the next 6 hours6.944444e-5 days 0.00167 hours 9.920635e-6 weeks 2.283e-6 months .

An inoperable channel need not be placed in the tripped condition where this would cause the Trip Function to occur.

The revised ACTION Statement 3. is primarily an editorial change and, with the changes proposed for ACTIONS b. and c., does not involve any revision of TS requirements or available alternatives. The revised ACTIONS b. and c. allow I

an inoperable channel to be placed in the tripped condition in lieu of restoring it to operable status.

This option had previously been available as part of ACTION a. in regard to channels with a setpoint less conservative than

s l

e l

-.' l the value specified in Table 3.3.8-2.

The proposed change would also allow tripping a channel in lieu of restoring it for other conditions that render the channel inoperable.

During the 7 day interval in which a channel can be inoperable under the conditions of ACTION b., the remaining two operable channels can provide the required actuation.

However, with an inoperable channel, the actuation logic requires both remaining channels and, therefore, the reliability of the system is reduced.

The 7 day allowable interval to place the channel in trip or restore its operability provides an acceptably low probability of an initiating event occurring coincident with a failure in the remaining instrument channels. The proposed action requirements are consistent with NUREG-1433. The licensee has maintained the alternative to the above action that would require shutdown to at least the startup operational condition within 6 hours6.944444e-5 days 0.00167 hours 9.920635e-6 weeks 2.283e-6 months of exceeding the 7 day allowable interval.

j ACTION c. addresses the condition in which two channels are inoperable and, therefore, the feedwater and main turbine high water level trip instrumentation is not maintained. The proposed action requires restoration of the function, by placing one of the inoperable channels in the tripped condition within 2 hours2.314815e-5 days 5.555556e-4 hours 3.306878e-6 weeks 7.61e-7 months .

The 2 hour2.314815e-5 days 5.555556e-4 hours 3.306878e-6 weeks 7.61e-7 months requirement is sufficient for the operator to take corrective action, and takes into account the likelihood of an event requiring actuation of the feedwater and turbine high water level trip during this period.

The 2 hour2.314815e-5 days 5.555556e-4 hours 3.306878e-6 weeks 7.61e-7 months requirement is consistent with NUREG-1433.

The licensee has maintained the existing additional requirement to restore either inoperable channel to operable status within 72 hours8.333333e-4 days 0.02 hours 1.190476e-4 weeks 2.7396e-5 months .

In addition, the proposed change also retains the alternative to the above actions that would require shutdown to at least the startup operational mode j

within 6 hours6.944444e-5 days 0.00167 hours 9.920635e-6 weeks 2.283e-6 months of exceeding the above allowable intervals.

The applicable footnote to ACTIONS b. and c. states that an inoperable channel need not be placed in the tripped condition where this would cause the trip function to occur.

This statement is consistent with the LTRs and previous staff positions such as those contained in NUREG-1433.

The staff finds the proposed revisions to the action requirements to be acceptable.

3 Table Notation (*) is added to TS Table 3.3.8-1 to allow a Reactor Vessel Water - High, level 8 instrument channel to be placed in an inoperable status for up to 6 hours6.944444e-5 days 0.00167 hours 9.920635e-6 weeks 2.283e-6 months for required surveillance without placing the trip system in the tripped condition.

The proposed change to TS Table 4.3.8.1-1 would i

revise the channel functional test interval requirement for the Feedwater System / Main Turbine Trip system from monthly to quarterly.

i The proposed changes to TS Tables 3.3.8-1 and 4.3.8.1-1 are consistent with the previously reviewed and approved LTR GENE-770-06-1 and are, therefore, acceptable.

L

c-

>c

)

d EDITORIAL CORRECTIONS / CHANGES The licensee proposed several editorial corrections and deletion of several outdated footnotes as part of the submittal. The staff reviewed these changes and concluded that they were corrections to typographical errors, minor wording changes to improve clarity, or removal of footnotes related to past i

conditions or operating cycles.

The staff included the removal of the j

footnote related to the February 1995, one-time extension of MSIV Isolation Valve - Closure quarterly surveillance in Unit 2 TS Table 4.3.1.1-l', as one of the editorial corrections. The staff finds these changes acceptable.

The proposed changes would also modify the TS Bases in order to reference the GE LTRs and address the various changes in TS requirements. The NRC staff offers no objection to the proposed Bases changes.

l

3.0 STATE CONSULTATION

In accordance with the Commission's regulations, the Illinois State official was notified of the proposed issuance of the amendments.

The State official had no comments, l

4.0

[NVIRONMENTAL CONSIDERATION The amendments change a requirement with respect to the installation or use of a facility component located within the restricted area as defined in 10 CFR Part 20 and change surveillance requirements.

The NRC staff has determined that the amendments involve no significant increase in the amounts, and no significant change in the types, of any effluents that may be released offsite, and that there is no significant increase in individual or cumulative i

occupational radiation exposure. The Commission has previously issued a proposed finding that the amendments involve no significant hazards consideration, and there has been no public comment on such finding (60 FR 11128).

Accordingly, the amendments meet the eligibility criteria for categorical exclusion set forth in 10 CFR 51.22(c)(9).

Pursuant to 10 CFR Sl.22(b), no environmental impact statement or environmental assessment need be prepared in connection with the issuance of the amendments.

5.0 CONCLUSION

i The Commission 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 amendments will not be inimical to the common defense and security or to the health and safety of the public.

Principal Contributor:

W. Reckley Date: August 2, 1995 6

ML20087C279

Contents

Text

1.0 INTRODUCTION

3.0 STATE CONSULTATION

5.0 CONCLUSION

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ML20087C279

Text

1.0 INTRODUCTION

3.0 STATE CONSULTATION

5.0 CONCLUSION

Navigation menu

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