ML20116K669
| ML20116K669 | |
| Person / Time | |
|---|---|
| Site: | LaSalle  |
| Issue date: | 08/14/1996 |
| From: | NRC (Affiliation Not Assigned) |
| To: | |
| Shared Package | |
| ML20116K667 | List: |
| References | |
| NUDOCS 9608150166 | |
| Download: ML20116K669 (5) | |
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UNITED STATES NUCLEAR REGULATORY COMMISSION E
E WASHINGTON, D.C. 20eeH001
%.....j SAFETY EVALUATION BY THE OFFICE OF NUCLEAR REACTOR REGULATION RELATED TO AMENDMENT N0.114 TO FACILITY OPERATING LICENSE NO. NPF-11 AND AMENDMENT BD. 99 TO FACILITY OPERATING LICENSE NO. NPF-Is COPMONWEALTH EDISON COMPANY LASALLE COUNTY STATION. UNITS 1 AND 2 DOCKET NOS. 50-373 AND 50-374.
1.0 INTRODUCTION
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 isolation actuation instrumentation. The intent of these tests is to ensure that changes in response times of instrumentation beyond the limits assumed in the safety analyses are detected, and combined with instrument calibration, to ensure that the instrument is operating correctly.
By letter dated January 14, 1994, the Boiling Water Reactor Owners' Group j
(BWROG) submitted topical report NED0-32291, " System Analyses for Elimination of Selected Response Time Testing Requirements," for staff review. The BWROG i
stated in NEDO-32291 that operational history has shown that significant i
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 1
allowable instrumentation response times are system response times rather than instrument times.
In addition, Regulatory Guide 1.118, " Periodic Testing of Electric Power and Protection Systems," endorses IEEE 338-1977, " Criteria for the Periodic Testing of Nuclear Power Generating Station Safety Systems," which states:
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" 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."
9608150166 960814 PDR ADOCK 05000373 P
l By letter dated December 28, 1994, the staff approved use of NED0-32291 for i
the elimination of response time testing requirements.
In the accompanying j
safety evaluation, the staff concluded that significant degradation of instrument response times, i.e., delays greater than about 5 seconds, can be i -
detected during the performance of other surveillance tests, principally i
calibration, if properly perfonned. Accordingly, the staff concluded that response time testing can be eliminated from TSs for the selected instrumenta-tion identified in the tt,pical report and accepted NED0-32291 for reference in i
license amendment applications for all boiling water reactors with the i
conditions discussed below:
l When submitting plant-specific license amendment requests, licensees must confirm the applicability of the generic analysis of NEDO-32291 to their plant, and, in addition to the request as shown in Appendix I of the topical report, the TS markup tables i
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 recommendations from EPRI NP-7243,
" Investigation of Response Time Testing Requirements," and, l
therefore, are required to perform the following actions:
i (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 1 -
l (b)
For transmitters and switches that use capillary tubes, capillary tube testing shall be performed after initial d
i installation and after any maintenance or modification activity that could damage the lines.
Licensees must also state the following in their amendment requests:
(a)
That calibration is being done with equipment designed to provide a step function or fast ramp in the process i
- variable, 1
l (b)
That provisions have been made to ensure that operators and j
technicians, through an appropriate training program, are aware of the consequences of instrument response time i
degradation, and that applicable procedures have been i
reviewed and revised as necessary to assure that technicians l
monitor for response time degradation during the performance j
of calibrations and functional tests, (c)
That surveillance testing procedures have been reviewed and j.
revised, if necessary, to ensure calibrations and functional tests are being performed in a manner that allows i
i a
_3 simultaneous monitoring of both the input and output response of units under test, (d)
That fer any request involving the elimination of response time tu:. ting for Rosemount pressure transmitters, the licensee is in compliance with the guidelines of i
Supplement I to Bulletin 90-01, " Loss of F111-011 in Transeitters Manufactured by Rosemount,' and (e)
That for those instruments where the manufacturer receamends periodic response time testing as well as calibration to ensure correct functioning, the licensee has ensured that elimination of response time testing is nevertheless acceptable for the particular application involved.
By letter dated May 31, 1995, the staff supplemented its safety evaluation to include approval for the elimination of response time testing for the sensors used for " Main Steam Line Flow - High" instrument loops which initiate main steam isolation valve closure.
By letter dated April 16, 1996, Commonwealth Edison Company (Comed) submitted a license amendmer.t application to eliminate instrument response time testing in accordcnce with NEDO-32291 for LaSalle County Station, Units 1 and 2.
2.0 EVALUM1QN The licensee's letter of April 16, 1996, referenced NEDO-32291 and proposed elimination of response time testing for selected parameters of the (1) Reactor Protection System, (2) Containment and Reactor Vessel Isolation Control Systee, and (3) Emergency Core Cooling System. The proposed changes includz the addition of notes to TS Tables 3.3.1-2 and 3.3.2-3 to clarify that the sensors associated with certain actuation logic circuits do not require response time testing and the addition of a note to TS Table 3.3.3-3 to clarify that iCCS actuation instrumentation is eliminated from all response time testing. The licensee stated that the response time tests proposed for elimination are of little safety significance and result in unnecessary personnel radiation exposure, reduced availability of systems durlag plant shutdown, increased potential for inadvertent actuations of safety systems, and a significant burden to utility resources.
In accordance with the conditions identified in the staff's safety evaluation, the licensee provided the following information:
Comed confirmed the applicability of NE00-32291 to LaSalle, Units 1 and 2.
As identified in Appendix A of NED0-32291, LaSalle was a participating plant in the evaluation.
In addition, Comed has confirw.d that the components within the scope of the license amendment application have been evaluated in NE00-32291. The components are identified in Table 1 of the staff's safety evaluation
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as those instruments / components for which response time testing can be eliminated.
The licensee's submittal included a list of affected instrument loop components as required by the staff's safety evaluation.
1 Comed confirmed that LaSalle is in conformance with the following
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recommendations from EPRI NP-7243, " Investigation of Response Time Testing Requirements:"
(a)
Prior to installation of a new transmitter / switch or following i
refurbishment of a transmitter / switch (e.g., sensor cell or variable damping components), a hydraulic response time test will i
be performed to determine an initial sensor-specific response time value. Comed committed to revise applicable LaSalle procedures prior to the upcoming refueling outage (L2R07) to fulfill this j
recommendation.
(b)
Comed stated that LaSalle does not utilize any transmitters or j
switches that use capillary tubes in any application that requires i
response time testing.
Therefore, this recommendation is not applicable to LaSalle.
Comed committed to revise applicable calibration procedures prior to L2R07 to include steps to input a fast ramp or step change of the input to system components under test while simultaneously monitoring the output.
Comed committed to conduct appropriate training to assure that operators and technicians are aware of the consequences of instrument response time degradation and the method for monitoring instrument response times during performance of calibrations and functional testing prior to i
L2R07.
Comed committed to revise surveillance testing procedures to ensure that 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 i
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.
Comed has complied with the guidelines of Supplement I to NRC Bulletin 90-01.
The NRC's evaluation is documented in a letter dated May 20, 1994.
The components affected by this amendment request are limited to Rosemount transmitters model 1153, 1154; Rosemount trip units type 710DU, Static-0-Ring pressure switches, GE relays type HMA and HFA, and
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9 Agastat relays type EGP. Comed has reviewed the vendor recommendations for these devices and confirmed that they do not contain recommendations for periodic response time testing.
The staff has previously concluded that licensees may reference NED0-32291 in I
license amendment applications provided that certain conditions are met.
In their application dated April 16, 1996, the licensee addressed each of these conditions and the staff finds the response acceptable. Therefore, the staff finds the licensee's proposed changes to the LaSalle TSs acceptable.
3.0 STATE CONSULTATION
In accordance with the Comission's regulations, the Illinois State official was notified of the proposed issuance of the amendments.
The State official had no coments.
4.0 ENVIRONMENTAL 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.
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 occupational radiation exposure.
The Comission has previously issued a proposed finding that the amendments involve no significant hazards consideration, and there has been no public coment on such finding (61 FR 25702). Accordingly, the amendments meet the eligibility criteria for categorical exclusion sr L forth in 10 CFR 51.22(c)(9).
Pursuant to 10 CFR SI.22(b), no environmental impact statement or environmental assessment need be prepared in connection with the issuance of the amendments.
5.0 CONCLUSION
The Commission has concluded, based en 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 Comission's regulations, and (3) the issuance of the amendments will not be inimical to the comon defense and security or to the health and safety of the public.
Principal Contributor:
D. Skay Date:
August 14, 1996
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