ML20127L646

Proposed Tech Spec Change to Correct Errors in Instrument Range & Testing Requirements & to Delete Functional Test Requirement for Three Devices.Safety Evaluation Encl

ML20127L646
Person / Time
Site:	North Anna
Issue date:	05/17/1985
From:	VIRGINIA POWER (VIRGINIA ELECTRIC & POWER CO.)
To:
Shared Package
ML20127L635	List: ML20127L633 ML20127L646
References
NUDOCS 8505230045
Download: ML20127L646 (8)

Text

_____ _. _ . . _ - _ _ _ -_. _ __ - ._ __ _ - - _ _ - - _ _ - _ _ _ _ _ - _ _ . _-____---_ _

4 e

b I

ATTACBENT 1 PROPOSED TECHNICAL SPECIFICATION CHANGE FOR UNIT I 9

4 P PDR

TABLE 3.3-7 SEISMIC MONITORING INSTRUMENTATION MINIMUM MEASUREMENT INSTRUMENTS INSTRUMENTS AND SENSOR LOCATIONS RANGE OPERABLE

1. Triaxial Time-History Accelerographs

a. Containment Mat

• O - 1.0 g 1

b. Containment Operating Level

• O-1.0g i

2. Triaxial Peak Accelerographs

a. RHR Heat Exchanger 0 - 5.0 s 1

b. Safety Injection pipe 0 - 5.0 g I

c. Component Cooling Heat Exchanger 0 - 5.0 g 1

3. Triaxial Seismic Switches

a. Containment Mat

• NA NA

4. Triaxial Response-Spectrum Recorders

a. Containment Mat

• 1 - 30 Hz 1

b. Auxiliary Building Mat 1 - 30 Hz 1

c. RHR Pipe Support 1 - 30 Hz 1

d. Component Cooling Heat Exchanger 1 - 30 Hz 1 Support

• With reactor control room indication NORTH ANNA - UNIT 1 3/4 3-41

TABLE 4.3-4 SEISMIC MONITORING INSTRUMENTATION SURVEILLANCE REQUIREMENTS CHANNEL CHANNEL CHANNEL FUNCTIONAL INSTRUMENTS AND SENSCR LOCATIONS CHECK CALIBRATION TEST

1. Triaxial Time-History Accelerographs

a. Containment Mat M* R SA*

b. Containment Operating Level M* R SA*

2. Triaxial Peak Accelerographs

a. RRR Heat Exchanger NA R NA

b. Safety Injection Pipe NA R NA

c. Component Cooling Heat Exchanger NA R NA

3. Triaxial Seismic Switches

a. Containment Mat NA R SA

4. Triaxial Response-Spectrum Recorders

a. Containment Mat NA R ,

SA**

b. Auxiliary Building Mat NA R NA

c. RHR Pipe Support NA R NA

d. Component Cooling Heat Exchanger Support NA R NA

• Except seismic trigger

• • Testing will include annunciator circuit only.

NORTH ANNA - UNIT 1 3/4 3-42

.r--

g 1 b.

he i

ATTACHMENT 2 SAFETY EVALUATION d

I d

1:

J; SAFETY EVALUATION The- current surveillance requirements for seismic monitoring

. instrumentation require semiannual channel functional tests for the four (4) triaxial response recorders listed in Technical Specifications Table 4.3-4. Three of these recorders (the Auxiliary Building Mat, RHR Pipe

' Support and Component Cooling Heat Exchanger Support) are passive devices with no remote indications. Guidance provided by Regulatory Guide 1.12, 1974, ANSI /ANS Standard 2.2, 1978, and the recorder manufacturer, Engdahl

-Enterprises, indicate that these recorders do not require a channel functional test. Table 1 of ANSI /ANS Standard 2.2 on frequency of

. maintenance specifically recommends that no channel functional test -be performed for self contained, - passive instruments. The physical act of testing may also cause significant damage to the device. The proposed change will. revise . the ; specifications to be consistent with current regulatory guidance and the manufacturer's recommendations.

The Containment Mat triaxial response recorder is an inaccessble, active l device with a remote indication (annunciator). Present surveillance requirements and ANSI /ANS Standard 2.2, 1978, require semiannual l,

functional testing. Because this device-is normally inaccessable during l

t l plant operations, testing every six months would require the use of protective ~ clothing, self contained breathing apparatus and limited access. time (ALARA concerns). The manufacturer (Engdahl) agrees that any

[ testing under these conditions could damage this sensitive equipment. .The l

[- proposed change is to limit the semisnnual functional cest requirement to the -testing of .the remote indication (annunciator) only. (Note: the

-c.,.- . . . . . _ - ~ , , . _ . . . _ _ . _ - , _ . _ , _ . - - - _ _ . . . _ _ . . . _ _ _ _ _ _ , . - - . _

refueling channel calibration requirement remains unchanged). It should

,be noted that we., currently perform an instrumentation department PM, on a six month frequency, to visually inspect the containment mat triaxial recorders.

An additional change is proposed to Ochnical Specifications Table 3.3-7,

. Item 4. The listed instrument measuament range for the triaxial response- spectrum recorders is og - 34g. The couser range should be 1.0 Hz - 30 Hz. This is consistent with the ANSI /ANS Standard 2.2, 1978 and with Section 3.7.4.5 of the North Anna UFSAR. This proposed change is administrative to correct an error in the existing specifications.

50.59 and Significant Hazards Review The proposed changes do not alter the operability requirements of the triaxial . recorders and are largely administrative in nature in order to reflect actual instrument requirements. In the modification of the semiannual functional test for the containment mat recorder, the proposed change is intended to enhance instrument availability by eliminating a

j. . test that will likely damage the equipment. Operability of the remote i

l s

indication will be verified by performance of a functional test.

I Pursuant. to 10CFR50.59, we have reviewed the proposed Technical l Specification changes and have concluded that no unreviewed safety l.

question exists. The possibility of occurrence or the consequence of a

, malfunction of the equipment previously evaluated in the UFSAR is not i.

increased. The possibility of a different type of accident other than discussed in tite UFSAR has not been created and the margin of safety as described in the BASES Section of any part of Technical Specifications has not been reduced.

This change does not pose a significant hazards consideration as defined in 10 CFR 50.92. The Commission has provided examples (48FR14870) of changes that constitute no significant hazards consideration: example

-(i) consists of purely administrative changes and example (vi) includes changes which either may result in some increase to the probability or consequences of a previously analyzed accident or may reduce in some way a safety margin, btit where the results of the change are clearly within all acceptable criteria with respect to the system or component specified in the Standard Review Plan.

The proposed change is similar to example (1) in that it corrects an incorrectly specified frequency range for the triaxial response -

spectrum recorders. The correct range is specified in the North Anna UFSAR and is also consistent with applicable ANSI standards. Therefore, this portion of the change is administrative.

The proposed change is similar to example (vi) in that the change appears to reduce a safety margin in some way; i.e., deletion of periodic functional testing. However, the deletion of the periodic functional testing for the components is clearly within the acceptable criteria (Regulatory Guides, ANSI Standards and manufacturer's recommendations) s

for the components. In fact, both current regulatory guidance and the manufacturer's. , recommendations indicate that the functional test requirement- may -_be detrimental to proper equipment functioning.

Assurance that the equipment, will perform to its intended function continues to be provided through periodic calibration requirements.

Thus,_this portion of the change is.similar to example (vi), and we conclude that no significant hazards considerations are involved in the proposed change.

O A