ML20112D571

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Proposed Tech Specs,Eliminating Selected Response Time Testing Requirements
ML20112D571
Person / Time
Site: FitzPatrick Constellation icon.png
Issue date: 05/30/1996
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POWER AUTHORITY OF THE STATE OF NEW YORK (NEW YORK
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ML20112D563 List:
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NUDOCS 9606040397
Download: ML20112D571 (20)
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.- l Attachment I to JPN-96-024 REVISED TECHNICAL SPECIFICATION PAGES RESPONSE TIME TESTING REQUIREMENTS (JPTS-96-006) l l

New York Power Authority JAMES A. FITZPATRICK NUCLEAR POWER PLANT Docket No. 50-333 DPR-59 9606040397 960530 PDR ADOCK 05000333 P ppg

LIST OF PAGE CHANGES RESPONSE TIME TESTING REQUIREMENTS (JPTS-96-006)

Revise Appendix A as follows: -'

Remove Pages insert Paoes 30g 30g 38 38 49 49 61 61

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3.1 LIMITING CONDITIONS FOR OPERATION 4.1 SURVElLLANCE REQUIREMENTS

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3.1 REACTOR PROTECTION SYSTEM 4.1 REACTOR PROTECTION SYSTEM Aoplicability- ADplicabilitv-Applies to the instrumentation and associated devices which Applies to the surveillance of the instrumentation and associated devices initiate the reactor scram. wnich initiate reactor scram.

Objective: Obiective:

To assure the operability of the Reactor Protection System. To specify the type of frequency of surveillance to be applied to the protection instrumentation.

Specification: Soecificatiorn A. The setpoints and minimum number of instrument channels A. Instrumentation systems shall be functionally tested and calibrated per trip system that must be operable for each position of as indicated in Tables 4.1-1 and 4.1-2 respectively, the reactor mode switch, shall be as shown in Table 3.1-1.

The response time of the reactor protection system trip functions listed below shall be demonstrated to be within its limit at least once per 18 mor@s. Neutron detectors are exempt from response time testing. Eacn test shall include at least one channel in each trip system. All channels in both trip systems shall be tested within two test intervah. -

1. Reactor Hi h Pressure (02-3PT-55A, B, C, D) ' l
2. Drywell Hi Pressure (05PT-12A, B, C, D)
3. Reactor er Level-Low (L3 (02-3LT-101 A, B, C, D)
  • l
4. Main Steam Line isolation Va)lve Closure 29PNS-80A2, B2, C2, D2) 9PNS-86A2, B2, C2, D2)
5. rbine Stop Valve Closure (94PNS-101,102,103,104) 1
6. Turbine Control Valve Fast Closure (94PS-200A, B, C, D)
7. APRM Fixed High Neutron Flux
8. APRM Flow Referenced Neutron Flux
  • Sensor is eliminated from response time testing for the RPS actuation logic circuits. Response time testing and conformance to the test acceptance criteria for the remaining channel components includes trip unit and relay logic. i Amendment No. 227, 30g

JAFNPP -

4.1 BASES (cont'd)

The individual sensor response time may be measured by Two instrument channels in Table 4.1-1 have not been simulating a step change of the particular parameter. This included in Table 41-2. These are: mode switch in shutdown method provides a conservative value for the sensor response and manual scram. All of the devices or sensors associated time, and confirms that the instrument has retained its specified with these scram functions are simple on-off switches and, electromechanical characteristics. When sensor response time hence, calibration during operation is not applicable.

is measured independently, it is necessary to also measure the remaining portion of the response time in the logic train up to B. The MFLPD is checked once per day to determine if the the time at which the scram pilot valve solenoids de-energize. APRM scram requires adjustment. Only a small number of The channel response time must include all component delays control rods are moved daily and thus the MFLPD is not in the response chain to the ATTS output relay plus the design expected to change significantly and thus a daily check of the allowance for RPS logic system response time. A response MFLPD is adequate.

time for the RPS logic relays in excess of the design allowance is acceptable provided the overall response time does not The sensitivity of Lf 5RM detectors decreases with exposure exceed the response time !!mits specified in the UFSAR. The 'to neutron flux at a slow and approximately constant rate.

basis for excluding the neutron detectors from response time This is compensated for in the APRM system by calibrating testing is provided by NRC Regulatory Guide 1.118, Revision twice a week using heat balance data and by calibrating 2, section C.S. individual LPRM's every 1000 effective full power hours, using TIP traverse data.

The sensors for the Reactor High Pressure and Reactor Water Level - Low (L3) trip functions are exempted from response time testing based on analyses provided in NEDO-32291-A,

" System Analyses for the Elimination of Selected Response Time Testing".

The 18 month response time testing interval is based on NRC NUREG-0123, Revision 3, " Standard Technical Specifications," surveillance requirement 4.3.1.3.

Amendment No. 44,83,134,183,227, 38

1 JAFNPP .

3.2 LIMITING CONDITIONS FOR OPERATION 4.2 SURVEILLANCE REQUIREMENTS 3.2 INSTRUMENTATION 4.2 INSTRUMENTATION Applicabilitv: Applicabilitv-Applies to the plant instrumentation which either (1) initiates and Applies to the surveillance requirement of the instrumentation which controls a protective function, or (2) provides information to aid the either (1) initiates and controls protective function, or (2) provides operator in monitoring and assessing plant status during normal and information to aid the operator in monitoring and assessing plant status accident conditions. during normal and accident conditions.

Objective: Obiective:

To assure the operability of the aforementioned instrumentation. To specify the type and frequency of surveillance to be applied to the aforementioned instrumentation.

Specifications: Specifications:

A. Primarv Containment Isolation Functions 'A. Primarv Containment isolation Functions When primary containment integrity is required, the limiting instrumentation shall be functionally tested and calibrated as conditions of operation for the instrumentation that initiates iridicated in Table 4.2-1. System logic shall be functionally tested primary containment isolation are given in Table 3.2-1. as indicated in Table 4.2-1.

The response time of the main steam isolation valve actuation instrumentation isolation trip functions listed below shall be demonstrated to be within their limits at least once per 18 months.

Each test shall include at least one channel in each trip system.

All channels in both trip systems shall be tested within two test irMrvals.

1. MSIV Closure - Reactor Low Water Level (L1) *

(02-3LT-57A,B and 02-3LT-58A,B)

2. MSIV Closure - Low Steam Line Pressure *

(02PT-134A,B,C,D)

3. MSIV Closure - High Steam Une Flow *

(02 D PT- 1 16A- D, 1 17A- D, 1 18A-D , 1 19A- D)

  • Sensor is eliminated from response time testing for the MSIV actuation logic circuits. Response time testing and conformance to the test acceptance criteria for the remaining channel components includes trip unit and relay logic.

Amendment No. 400-483;-227, 49

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JAFNPP ,

4.2 BASES .

The instrumentation listed in Tables 4.2-1 through 4.2-8 will be 5. GE Topical Report NEDC-30936P-A, Parts 1 and 2 "BWR functionally tested and calibrated at regularly scheduled Owners Group Technical Specification Improvement intervals. The same design reliability goal as the Reactor Methodology (With Demonstration for BWR ECCS Protection System is generally applied. Sensors, trip devices Actuation Instrumentation)," December 1988.

and power supplies are tested, calibrated and checked at the same frequency as comparable devices in the Reactor Protection 6. GE Topical Report GENE-770-06-1-A, " Bases for Changes System. to Surveillance Test Intervals and Allowed Out-Of-Service Times For Selected Instrumentation Technical The surveillance test interval for the instrumentation channel Specifications," Pccs.5ber 1992.

functional tests are once/three months for most instrumentation.

This surveillance interval is based on the following NRC 7. GE Topical Report GENE-770-06-2-A, " Addendum to Bases approved licensing topical reports: for Changes to Surveillance Test Intervals and Allowed Out-Of-Service Times For Selected Instrumentation Technical

1. GE Topical Report NEDC-30851P-A, " Technical Specifications," December 1992.

Specification improvement Analysis for BWR Reactor Protection System," March 1988.

The measurement of the response time interval for the Main

2. GE Topical Raport NEDC-30851P-A, Supplement 1 Steam Isolation Valve (MSIV) isolation actuation instrumentation

" Technical Specification Improvement Analysis for BWR begins when the monitored parameter exceeds the isolation Control Rod Block Instrumentation," October 1988. actuation setpoint at the channel sensor and ends when the MSIV pilot solenoid relay contacts open. With the exception of

3. GE Topical Report NEDC-30851P-A, Supplement 2 the MSIVs, response time testing is not required for any other

" Technical Specification improvement Analysis for BWR primary containment isolation actuation instrumentation. The Isolation Instrumentation Common to RPS and ECCS safety analyses results are not sensitive to individual sensor instrumentation," July 1986. response times of the logic systems to which the sensors are connected for is'olation actuation instrumentation. The sensors

4. GE Topical Report NEDC-31677P-A, " Technical for the MSIV actuation isolation trip functions are exempted from Specification improvement Analysis for BWR lsolation response time testing based on analyses provided in NEDO-Actuation Instrumentation, " July 1990. 32291-A, " System Analyses for the Elimination of Selected Response Time Testing".

Amendment No. 80,134,161,183,227, 61

_ . _ . . _ _ . _ . . _ _ _ _ - _ - _ . _ . _ _ _ . _ _ = . _ _ _ - . - _-- . -.

l Attachment il to JPN-96-024 SAFETY EVALUATION RESPONSE TIME TESTING REQUIREMENTS (JPTS-96-006)

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

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Attachment ll to JPN-96-024

. SAFETY EVALUATION Page 1 of 6

1. INTRODUCTION This application for amendment to the James A. FitzPatrick Technical Specifications (TS) ,

proposes the elimination of sensor response time testing for the Reactor Vessel High l Pressure and Reactor Water Level - Low (L3) trip functions in the Reactor Protection  !

System (RPS); and the MSIV Closure - Reactor Low Water Level; MSIV Closure - Low  !

l Steam Une Pressure and MSIV Closure - High Steam Une Flow trip functions in the  ;

Primary Containment Isolation System.

I l 1. Page 30g, Specification 4.1.A Add the following note to trip functions "1. Reactor High Pressure" and "3. Reactor Water Level - Low (L3)":

"* Sensor is eliminated from response time testing for the RPS actuation logic circuits. Response time testing and conformance to the test acceptance criteria ,

i for the remaining channel components includes trip unit and relay logic. l

2. Page 49, Specification 4.2.A Add the following note to the three Primary Containment isolation trip functions i listed in this section:

Sensor is eliminated from response time testing for the MSIV actuation logic I circuits. Response time testing and conformance to the test acceptance l criteria for the remaining channel components includes trip unit and relay logic."

3. Page 38, Bases 4.1 Add the following after the first paragraph:

"The sensors for the Reactor High Pressure and Reactor Water Level - Low (L3) trip functions are exempted from response time testing based on analyses provided in NEDO-32291-A, " System Analyses for the Elimination of Selected Response Time Testing".

4. Page 61, Bases 4.2 Add the following after the last paragraph:

"The sensors for the MSIV actuation isolation trip functions are exempted from response time testing based on analyses provided in NEDO-32291-A, " System Analyses for the Elimination of Selected Response Time Testing".

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, Attachment il to JPN-96-024 SAFETY EVALUATION Page 2 of 6

11. PURPOSE OF THE PROPOSED CHANGES Analyses have been performed by the BWR Owners' Group (BWROG) demonstrating that other periodic tests required by TS, such as channel calibrations, channel checks, channel functional tests, and logic system functional tests, in conjunction with actions i taken in response to NRC Bulletin 90-01, " Loss of Fill-Oil in Transmitters Manufactured by Rosemount," and Supplement 1 to Bulletin 90-01, provide adequate assurance that

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instrument response times are within acceptable limits. The evaluation is documented in i Reference 1. This change eliminates response time tests that are of little safety l significance and could result in unnecessary personnel radiation exposure, reduced  ;

availability of systems during plant shutdowns, increased potential for inadvertent  !

actuation of safety systems, and a significant burden to utility resources.

111. SAFETY IMPLICATIONS OF THE PROPOSED CHANGES.

The basis for this request is consistent with Regulatory Guide 1.118 (Revision 2)

(Reference 6) which endorses IEEE 338-1977 (Reference 7) which states: l

" Response time testing of all safety related equipment, per se, is not required if, in I ileu of response time testing, the response time of safety system 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."

l NEDO-32291-A identified potential failure modes of components in the affected instrumentation loops which could potentially impact the instrument loop response time. .

In addition, industry operating experience was reviewed to identify failures that affect i response times and how they were detected. The failure modes identified were then evaluated to determine if the effect on response time would be detected by other TS testing requirements (channel calibrations, channel checks, channel functional tests, and I logic system functional tests). Actions taken in response to NRC Bulletin 90-01 Supplement 1 are sufficient to identify failure modes or degradation in instrument - i response times and ensure opereon of the analyzed instrumentation loops within acceptable limits. NEDO-32291-A concluded that failure modes detected by response time testing, are detectable by other TS required tests.

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The evaluation documented in NEDO 32291-A demonstrates that the following response l time testing required in the FitzPatrick TS can be eliminated:

1) Sensors for selected RPS actuation instrumentation, and
2) Sensors for selected MSIV closure actuation instrumentation.

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, Attachment il to JPN-96-024 )

SAFETY EVALUATION I Page 3 of 6 Additional Information 4

In accordance with the conditions identified in the NRC staff's safety evaluation of

NEDO-32291-A, the following information is provided:

1 The New York Power Authority (NYPA) has confirmed the applicability of NEDO-32291-A l to the James A. FitzPatrick Nuclear Plant. During 1996, the FitzPatrick Plant became a participating plant in addition to those listed in Appendix A of NEDO-32291-A. In addition,

NYPA has confirmed that the sensors within the scope of this request have been evaluated in NEDO-32291-A. These sensors are identified in an Addendum to Appendix G (new Table G-14) of NEDO-32291-A and Table 1 of the NRC staff's safety evaluation of NEDO-32291-A. The components within the scope of this request are Rosemount l transmitter model 1153. j l

NYPA confirms that the FitzPatrick Plant is in compliance with the following recommendations from EPRI NP-7243 (Reference 5):

, a) Prior to installation of new transmitters / switches or following maintenance of transmitters / switches in selected instrument loops addressed in NEDO-32291-A, a hydraulic respcnse time test (RTT) shall be conducted to determine the initial sensor specific response time value. Procedures will be changed to incorporate this method following amendment issuance.

b) The FitzPatrick Plant does not utilize capillary tube transmitters or switches for instrument loops required for RTT as specified in the Technical Specifications.

The following additional information is provided in response to the NRC request to unsure compliance to NEDO-32291-A (Reference 1).

a) Calibration procedures will be revised to include steps for fast ramp or step change to the input of the system components during calibrations. The response check will be performed prior to the instrument being calibrated.

i b) Training has been performed in response to NRC Bulletin No. 90-01 action item 4.a to ensure operators and technicians have been made aware of consequences of instrument response time degradation.

4 c) l&C technicians are stationed during calibration and functional surveillance tests to allow for simultaneous monitoring of both input and output of the channel under test.

d) The FitzPatrick Plant has responded to NRC Bulletin 90-01, Supplement 1 conceming " Loss of Fill-Oil in Transmitters Manufactured by Rosemount". This response documents the actions to comply with the Bulletin.

e) The FitzPatrick Plant has reviewed the manufacturers requirements for Rosemount 1153 series B transmitters, and has determined the transmitters do not require periodic component response checks as specified by the vendor manual.

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, Attachment Il to JPN-96-024

. SAFETY EVALUATION Page 4 of 6 By letter dated December 28,1994, the NRC staff provided their acceptance of NEDO-32291 A, subject to certain conditions, for reference in license amendment applications.

Since issuance of this document, the FitzPatrick Plant has become a participant in i addition to those listed in Appendix A of NEDO-32291-A.

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

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

The purpose of the proposed TS change !s to eliminate response time testing ,

requirements for selected sensors in the RPS and Primary Containment isolation '

System. The BWROG has completed an evaluation which demonstrates that response time testing is redundant to the other TS required testing. These other tests in conjunction with actions taken in response to NRC Bulletin 90-01, " Loss of Fill-Oil in Transmitters Manufactured by Rosemount," and Supplement 1 to Bulletin 90-01, are sufficient to identify failure modes or degradation in instrument response time and ensure operation of the associated systems within acceptable limits.

Furthermore, failure modes detected by response time testing are detectable by other TS required testing. This evaluation was documented in Reference 1. NYPA has confimled the applicability of this evaluation to the FitzPatrick Plant. In addition, NYPA will complete the actions identified in the NRC staff's safety evaluation of NEDO-32291-A.

Because of the continued application of other existing TS required tests such as channel calibrations, channel checks, channel functional tests, and logic system functional tests, the response time of these systems will be maintained within the acceptance limits assumed in plant safety analyses and required for successful mitigation of an initiating event. The proposed changes do not affect the capability of

, the associated systems to perform their intended function within their required response time, nor do the proposed changes themselves affect the operation of any equipment. Therefore, the proposed change does not involve a significant increase in the probability or consequences of an accident previously evaluated.

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2. create the possibility of a new or different kind of accident from those previously evaluated because:

The proposed changes do not affect the ability of the systems to perform their intended function within the acceptance limits assumed in plant safety analyses and required for successful mitigation of an initiating event. No new failure modes are introduced by the changes. Therefore, the proposed changes do not create the possibility of a new or different kind of accident from any accident previously evaluated.

, Attacnment Il to JPN-96-024 SAFETY EVALUATION Page 5 of 6

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

The current TS required response time test limits are based on the maximum allowable values assumed in the plant safety analyser. These analyses conservatively establish the margin of safety. As described above, the proposed changes do not affect the capability of the associated systems to perform their intended function within the allowed response time used as the basis for the plant safety analysis. Plant and system response to an initiating event will remain in compliance within the assumptions of the safety analyses, and therefore the margin of safety is not affected.

Further, although not explicitly evaluated, the proposed changes will provide an improvement to plant safety and operation by reducing the time safety systems are unavailable, reducing safety systems actuations, reducing plant shutdown risk, limiting radiation exposure to plant personnel, and eliminating the diversion of key personnel to conduct unnecessary testing. Therefore, the overall effect of the changes should increase the margin the safety.

V. IMPLEMENTATION OF THE PROPOSED CHANGES Implementation of the proposed changes will not adversely affect the ALARA or Fire Protection Programs at the FitzPatrick plant, nor will the changes impact the environment.

VI. CONCLUSION Based on the discussions above, the elimination of the identified response time testing requirements for sensors in the RPS and Primary Containment isolation System may be safely implemented.

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

The Plant Operating Review Committee (PORC) and the Safety Review Committee (SRC) have reviewed these proposed changes to the Technical Specifications and have concluded they do not involve an unreviewed safety question, or a significant hazards consideration, and will not endanger the health and safety of the public.

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. Attachment 11 to JPN-96-024 )

SAFETY EVALUATION  ;

Page 6 of 6 )

I Vll. REFERENCES  ;

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1. BWR Owners' Group Ucensing Topical Report NEDO-32291-A, " System Analyses -)

for the Elimination of Selected Response Time Testing Requirements", October l 1995 '

2. NRC Letter to BWR Owner's Group Documenting NRC Review of NEDO-32291-A, dated December 28,1994
3. NYPA Letter, W. Femandez to the NRC, dated July 19,1990, (JAFP-90-0549)

" Response to NRC Bulletin 90-01" l

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4. NYPA Letter, R.E. Beedle to the NRC, dated March 5,1993, (JPN-93-010)  !

" Response to NRC Bulletin 90-01, Supplement 1"

5. EPRI NP-7243, " Investigation of Response Time Testing Requirements", Final Report May 1991
6. R.G.1.118, Rev. 2, " Periodic Testing of Electric Power and Protection Systems",

dated June 1978 7, IEEE 338-1977, " Standard Criteria for the Periodic Testing of Nuclear Power Generating Station Safety Systems", dated September 1977 1

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Attachment lli to JPN-96-024 l

MARKED-UP TECHNICAL SPECIFICATION PAGES J l

RESPONSE TIME TESTING REQUIREMENTS (JPTS-96-006)

)

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

JAFNPP -

3.1 LIMITING CONDITIONS FOR OPERATION 4.1 SURVEILLANCE REQUIREMENTS 3.1 REACTOR PROTECTION SYSTEM 4.1 REACTOR PROTECTION SYSTEM Anchcabartw Anpticab5ity-3 Applies to the instrumentation and associated devices which Applies to the survealance of the estrumentation and associated B initiate the reactor scram. deveces wtuch initiate reactorscram.

g Obiective: Obiectrve:

<h

? To assure the operatWity ,r the Reactor Protection System. To specify the type of frequency of surveillance to be applied to the

$ protection instrumentatiott Specification: Seedfaia-i:

W d A. The setpoints and minimum number ofinstrument channels A. Instrumentation systems shaE be funchonally tested and g per trip system that must be operable for each position of the calibrated as indicated in Tables 4.1-1 and 4.1-2 respechvely m reactor mode switch, shas be as shown in Table 3.1-1.

m m The response time of the reactor pwin.su6 systern trip funchons listed below shes be dernonstrated to be wnthn its limit at least once per 18 months Neutron detectors are exempt from response time testing. Each test shall include at least one channelin each trip system. AE channels in both1 rip systerns shall be tested within two test intervals.

1. Reactor High Pressure (02-3PT-55A, B, C, D) #
2. Drywell High Pressure (05PT-12A, B, C, D)
3. Reactor Water Level-Low (L3) (02-3LT-101 A, B, C, D) (p
4. Main Steam Line Isolahan Valve Closure (29PNS-80A2, B2, C2,02)

(29PNS-86A2, B2, C2, D2) 8

5. Turbine Stop Valve Closure (94PNS-101,102,103,104)

[

g 6. Turbine Control Valve Fast Closure (94PS-200A, B, C, D)

7. APRM Fixed High Neutron Flux
8. APRM Flow Referenced Neutron Rux pr.eea~/

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, Arnendment No. ,

3Og

JAFNPP I,

):

4.1 BASES (cont'd)' h, Si O  :

The indhndual sensor response time may be measured by 8. The MFLPD is checked once per day to det ennme N the APRM  !

sianulating a step deange of the particular parameter. This scram requires at$ustment. Only a smaN number of conhol method prowdes a conservative value for the sensor response rods are moved daily and thus the hFLPO is not expected to time, and confums that the instrument has retained its speedied change signsficantly and thus a daily check of the MFLPO is ,

electromechanical charactenstics. When sensor response time adequate.  !

is measured indeperidentfy, it is necessary to also measure the remaining porton of the response time in the logic train up to the The sensitivity of LPRM detectors deaeases with exposure to time at which the scram pdot valve solenoods de-energize. The neutron flux at a slow and approximately constarit rate. This is channel response time must include all w...penerd delays in the compensated forin the APRM system by caBbrating twice a response chain to the ATTS output relay plus the design week using heat balance data and by calibrating individual aBowance for RPS logic system response time. A response time LPRM's every 1000 effecawe full power hours, using TIP for the RPS logic relays in excess of the design atowance is traverse data. $

acceptable provided the overall response time does not exceed "

the response time twruts speofied in the UFSAR. The basis for T excluding the neutron detectors from response time testing is

  • provided by NRC Reendatory Guide 1.11_8, Revision 2, section y C.S. i j INSc.Kr T The 18 month response time testing interval is based on NRC NUREG-0123. Revision 3. " Standard Tedinical Specifications," h surveillance requirement 4 3.1.3. @

Two instrument channels in Table 4.1-1 have not been inctuded in Table 4.1-2. These are: mode switdi in shutdown and manual g scram. All of the devices or sensors associated with these  ;;

scram functions are simple on-off switches and, hence.

  • calibration during operation is not applicable.

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Amendment No. 04,30,1~' A ,133M7, 38

JAFNPP

". f 3.2 LIMITING COf0fTIONS FOR OPERATION 4.2 SURVEILLANCE REQUIREMENTS g 3.2 INSTRUMENTATION 4.2 INSTRUNENTATION y l

ApphcatWBtv- Acclicatnihr:

Applies to the plant instrumentation which either(1) initiates and Applies to the surveillance requirement of the instrumentation which controls a protechve funchon, or (2) provides irWormahon to aid the either(1)inhiates and controls protedwe function. Or (2) provides operator in monitoring and assessing plant status during normal and information to aid the operatorin morytoring and assessing plant accident conditions. status cunng normal and accident coruktions Objechvi Otmective.

To assure the operabitty of the aforemenhoned instrumentation. To specify the type and hoquency of surveBance to be apphed to the aforemenhoned instrumentation w Ui Soecdications: Specnicahons:

A. Primant Cornamment Isotahon Functions A. Pnmary Contaenment 1soinhon Funchons When primary containment integnty is required. the limiting Instrumentabon shaE be furu:bonelly tested and caibrated as conditions of operation for the instrumentation that initiates privnary irwarated in Table 4.2-1. System logic shal be funchonally tested containtnent isotahon are given in Table 3 2-1. as indicated in Table 4.2-1.

The response time of the main steam isolation valve actuation  ?

instrumentation isolation trip functions listed below shaI be $

dernonstrated to be within their limits at least once per 18 months Each test shas include at least one channet in each trip system. @

AN channels in both trip systems shall be tested within two test g intervals.

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1. MSIV Closure - Reactor Low Water Level (L1) $ j (02-3LT-57A,B and 02-3LT-58A 8) -4
2. MSIV Closure - Low Steam Line Pressure it S (02PT-134A,B,C,D)
3. MSIV Closure - High Steam Line Flow (02DPT-116A-D,1 17A-D, 116A-D, 119A-D) 4 $l g-o, Amendment No. 900-463 j TNseRT 'O

. . , . ~ . - - = . - - _ - - - . - - . - . . - . . - . . - . .- . . - - . - - - .- .. - - - - - - - - .

JAFMPP 4.2 BASES Methodology (With Demonstrabon for BWR ECCS Achastion

'. f; The instrumentation listed in Tables 4.2-1 through 4.2-8 wit be Instrumentation)," December 1988.

$f '

functionally tested and caEbrated at regulerty sebeduled intervals. 6. - GE Topical Report GEME-77046-1-A, " Bases for Changes to The same desagn reliab5ity goal as the Reactor Protechon Systern h Surveillance Test wviervals and Amowed out-of.Sernce is generally applied. Sensors, trip devices and power supplies ese Tunes For Selected instrumentstron Techmcal tested, celtwated and checked at the same frequency as l Speedicatons," December 1992.  ;

cornparable devices in the Reactor Protection System.

7. GE Topocal Report GENE-770-06-2-A, " Addendum to Bases The surveitance test w' iterval for the instrumentaton channel for Changes to Surveillance Test Intervals and Allowed Out- '

functional tests are oncetthree months for most instrumentation. Of-Service Tirnes For Selected Instruments 6on Technical l This survettarece intervalis based on the fotowmg NRC approved Speedications " December 1992. t licensing topical reports: i

1. GE Topical Report NEDC-30851P-A. " Technical Speedication Tree rnessurement of the response time interval for the Main Steam improvement Analysis for BWR Reactor Protedion System,' isolation Valve (MSIV) isolation actuanon instrume:1tation begins w March 1988. when the monitored parameter exceeds the isoistron actuohon
  • I setpomt at the channel sensor and ends when the MSiv pilot T
2. GE Topical Report NEDC-30851P-A, Supplernent 1 solenoid relay contacts open. With the exception of the MSIVs, *

" Technical Specification improvement Analysis for BWR response time testing is not required for any other primary y Control Rod Block lastrumentation," October 1988. containment isolation actuohon instrumentation. The safety w analyses results are not sensitive to individual sensor response

3. GE Topical Report NEDC-30851P-A, Supplement 2 tuties of the logic systems to which the sensors are connected for hi

" Technical Specnication improvement Arlafysis for BWR isolation aduation instrumentation. f isolation Instrumentation Common to RPS and ECCS f INSE47 'O @'

y, instrumentabon," July 1986.

4. GE Topical Report NEDC-31677P-A, " Technical Specification Improvernent Analysis for BWR isolation Actuation -!

Instrumentation, " July 1990.

E' S

5. GE Topacal Report NEDC-30936P-A, Parts 1 and 2 *BWR -

Owners Group Technical Specificatron improvement S, Amendment No. ",0,104,1",1,100 ENg 61

_ . _ _ _ _ _ _ _ __m_____.__ _ _ _ _ _ _ __ _ ____ ___ ___._ _ _ _ _ _ _ _ _ _ _ _ _ _ _ _ _ _ _ . _ _ _ _ . _ _ _ _ _ _ _ _ _ _ _ _ _ _ _ _ _ _ . _ _ _ _ _ _ _ _ _ _ _

, Attechmtnt lli to JPN-96-024 MARKED-UP TECHNICAL SPECIFICATION PAGES Insert A:

l "* Sensor is eliminated from response time testing for the RPS actuation logic l circuits. Response time testing and conformance to the test acceptance criteria for the remaining channel components includes trip unit and relay logic."

! Insert B:

l

Sensor is eliminated from response time testing for the MSIV actuation logic circuits. Response time testing and conformance to the test acceptance criteria for the remaining channel components includes trip unit and relay logic."

Insert C:

i "The sensors for the Reactor High Pressure and Reactor Water Level- Low (L3) trip functions are exempted from response time testing based on analyses provided in NEDO-32291-A, " System Analyses for the Elimination of Selected Response Time Testing."

Insert D:

"The sensors for the MSIV action isolation t rip functions are exempted from response time testing based on analyses provided in NEDO-32291-A, " System ,

Analyses for the Elimination of Selected Response Time Testing." l I

l 1

r i

, Attachm::nt IV to JPN-96-024 LIST OF COMMITMENTS RESPONSE TIME TESTING REQUIREMENTS (JPTS-96-006)

Commitment No. Description Due Date JPN-96-024-01 Prior to installation of new Within 30 days of transmitters / switches or following amendment issuance maintenance of transmitters / switches in selected instrument loops addressed in NEDO-32291-A, a hydraulic response time test (RTT) shall be conducted to determine the initial sensor specific response time value. Procedures will be changed to incorporate this method following amendment issuance.

JPN-96-024-02 Applicable calibration procedures will be Procedures to be revised to include steps for fast ramp or revised prior to next step change to the input of the system performance, with all components during calibrations. These procedures completed steps will be placed after test equipment within 30 days of hook-up and before the instrument is amendment issuance calibrated. The revision will ensure that the test is performed in a manner that allows simultaneous monitoring of both input and output of channel under test and that technicians are aware of, and monitor for, response time degradation.

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