ML20129G968
| ML20129G968 | |
| Person / Time | |
|---|---|
| Site: | FitzPatrick  |
| Issue date: | 10/28/1996 |
| From: | NRC (Affiliation Not Assigned) |
| To: | |
| Shared Package | |
| ML20129G964 | List: |
| References | |
| NUDOCS 9610300291 | |
| Download: ML20129G968 (5) | |
Text
p uou
~
y 1
UNITED STATES j
j NUCLEAR REGULATORY COMMISSION 2
WASHINGTON. D.C. 20666-0001 SAFETY EVALUATION BY THE OFFICE OF NUCLEAR REACTOR REGULATI0ri RELATED TO AMENDMENT NO. 235 TO FACILITY OPERATING LICENSE NO. DPR-59 POWER AUTHORITY OF THE STATE OF NEW YORK JAMES A. FITZPATRICK NUCLEAR POWER PLANT DOCKET NO. 50-333
1.0 INTRODUCTION
By letter dated May 30, 1996, as supplemented by letter dated October 11, 1996, the Power Authority of the State of New York (PASNY) proposed an amendment to the James A. Fitzpatrick Technical Specifications (TSs) to eliminate selected response time testing (RTT) requirements for certain sensors and specified loop instrumentation.
The affected TSs are TS 4.1.A,
" Surveillance Requirements, Reactor Protection System," and TS 4.2.A,
" Surveillance Requirements, Instrumentation, Primary Containment Isolation Functions." The proposed changes are supported by analyses performed by the Boiling Water Reactor Owners Group (BWROG) which demonstrate that other periodic tests required by TS, such as functional tests and calibrations, in conjunction with the actions taken in response to NRC Bulletin 90-01, " Loss of Fill-Oil in Transmitters Manufactured by Rosemount," and Supplement 1, are adequate to ensure that instrument response times are within acceptable limits.
2.0 EVALUATION An analysis performed by the BWROG to assess the impact of elimination of RTT for selected instrument loops was documented as a Licensing Topical Report (LTR) NEDO-32291 and was submitted for NRC's approval in January 1994.
The NRC approved the BWROG LTR by a generic Safety Evaluation Report (SER) dated December 28, 1994, and a supplemental SER (SSER) dated May 31, 1995.
The SER included Tables 1 and 2, which respectively lists instruments / components and systems which were evaluated in the BWROG LTR for RTT elimination.
In addition to approving elimination of RTT for selected instrumentation, the SER stipulated certain conditions that licensees must meet to apply the SER pre-approved changes to their plant-specific TS.
During 1996, the Fitzpatrick Nuclear Power Plant became a participating plant in addition to those listed in Appendix A of NED0-32291-A.
By letter dated May 30, 1996, the licensee confirmed that they followed the guidance in NE00-32291-A and met the conditions in the staff's SER and supplemental SER. As a result, the licensee requested the following TS changes to support selected RTT elimination.
9610300291 961028 PDR ADOCK 05000333 P
. 2.1 TS 4.1.A - Surveillance Requirements, Reactor Protection System 1.
Reactor High Pressure (02-3PT-55A, B, C, D) 2.
Reactor Water Level-Low (L3) (02-3LT.-101A, B, C, D)
The licensee proposed to add a note to 4.1.A Surveillance Requirements, Reactor Protection System that reads:
" 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."
2.2 TS 4.1 - Bases The licensee proposed to insert a paragraph after the first paragraph that reads:
"The sensors for the Reactor High Pressure and Reactor Water Level -
Low (L3) trip fun;:tions are exempted from response time testing based on analyses provided in NEDO-32291-A, System Analyses for the Elimination of Selected Response Time Testing."
2.3 TS 4.2. A - Surveillance Requirements, Primary Containment Isolation Functions 1.
MSIV Closure - Reactor Low Water Level (L1) 2.
MSIV Closure - Low Steam Line Pressure 3.
MSIV Closure - High Steam Line Flow The licensee proposed to add a note to 4.2.A which reads:
" Sensor is eliminated from response time testing for the MSlV actuation logic circuits.
Response time testing and conformance to the test acceptance criteria for the remaining channel components includes trip unit and relay logic."
2.4 TS 4.2 - Bases The licensee proposed to insert a paragraph after the last paragraph which reads:
"The sensors for the MSIV actuation isolation trip functions are exempted from response time testing based on analyses provided in NED0-32291-A, " System Analyses for the Elimination of Selected Response Time Testing."
3.0 DISCUSSION AND EVALVATION The staff stipulated several conditions which must be met by the licensee before the pre-approved changes of the generic SER and SSER could be applied to any plant-specific TS.
From the licensee's submittal, the staff verified that the licensee has met all applicable conditions stipulated by the staff's SER and SSER for the NED0-32291-A. Details of this verification are discussed below.
3.1 Confirm the applicability of the generic analyses to the plant In their submittal, the licensee stated that the NED0-32291-A analysis was performed for two representative boiling-water reactor plants and it:
applicability to the JAF Nuclear Plant has been verified.
During 1996, jai
l e
e
_3_
became a participating plant, in addition to those listed in Appendix A of NED0-32291-A. The staff reviewed this information and verified the applicability of the generic analyses to JAF.
3.2 EPRI NP-7243 Recommendations The licensees shall state that they are following the recommendations from EPRI NP-7243 and. therefore, shall perform the following actions:
(a) Prior to installation of new transmitters / switches or following maintenance of transmitters / switches in selected instrument loops addressed in NED0-32291-A, a hydraulic 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) JAF does not utilize capillary tube transmitters or switches for instrument loops required for RTT as specified in the TS.
In their submittal, the licensee stated that PASNY has followed the i
recommendations of EPRI NP-7243, " Investigation of Response Time Testing Requirements," May 1991, and stated their conformance to the actions described 4
in items (a) and (b) above. The staff reviewed the licensee's statements and 4
verified that the licensee is following these recommendations.
a 3.3 Device Applicability The BWROG concluded that the RTT requirements for the devices identified in Table 1 of NED0-32291-A can be removed from TSs when the devices are used in systems listed in Table 2 of NED0-32291-A. Therefore, for the devices which RTT elimination is requested, the licensee should verify that these devices are of the same model and make as indicated in Table 1 of the generic SER and are part of the systems shown on Table 2 of the generic SER.
In case the i
licensee's submittal for RTT elimination include any device (s) which is (are) not included in Table 1 of the SER, the licensee shall provide a justification for each device on a case-by-case basis.
The licensee has confirmed that the sensors within the scope of this request were evaluated in NED0-32291-A. The staff noted that these sensors were identified in an Addendum to Appendix G of NED0-32291-A and were of the same i
make and model as described in Table 1 of the generic SER. The staff also verified that all devices for which elimination of RTT requested were part of systems described in Table 2 of the generic SER. These devices were evaluated by the BWROG in NED0-32291-A, and were included in Table 1 of the generic SER.
The staff has concluded that the pre-approved SER changes can be applied to these plant-specific devices.
3.4 Rosemount oil-filled pressure transmitters In case elimination of any RTT associated with Rosemount oil-filled pressure transmitters is requested, the licensee shall be in full compliance with the guidelines of Supplement I to Bulletin 90-01, " Loss of Fill-0il in Transmitters Manufactured by Rosemount."
. In their submittal, the licensee stated that they are following the guidance of Supplement I to NRC Bulletin 90-01, " Loss of Fill-0il in Transmitters Manufactured by Rosemount," for all Rosemount transmitters for which the RTT is eliminated.
This is acceptable to the staff.
3.5 Additional plant-specific conditions The licensee provides the following additional information in response to the NRC request for information regarding certain conditions.
(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.
(b) Training has been performed in response to NRC Bulletin 90-01 action item 4.a to ensure operators and technicians have been made aware of consequences of instrument response time degradation.
(c) I&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) JAF has reviewed the manufacturer's requirements for Rosemount 1153 series B transmitters, and has determined that the transmitters do not require periodic component response checks as specified by the vendor manual.
The NRC staff has reviewed this information and concluded that it is acceptable.
Based upon the above review, the NRC staff finds that the licensee has confirmed the applicability of the generic analysis of NED0-32291-A to JAF and followed the provisions of the generic SER and Supplement SER for RTT elimination. Therefore, the staff has concluded that the proposed TS modifications to eliminate the selected response time requirements as discussed above are acceptable.
4.0 STATE CONSULTATION
In accordance with the Commission's regulations, the New York State official was notified of the proposed issuance of the amendment. The State official had no comments.
1 1
\\
~
l
, 1
5.0 ENVIRONMENTAL CONSIDERATION
The amendment changes a requirement with respect to installation or use of a facility component located within the restricted area as defined in 10 CFR Part 20 and changes surveillance requirements.
The NRC staff has determined that the amendment involves no significant increase in the amounts, and no l
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 Commission has previously issued a proposed finding that the amendment involves no significant hazards consideration, and there has been no public comment on such finding (61 FR 34896). Accordingly, the amendment meets the eligibility criteria for categorical exclusion set forth in 10 CFR 51.22(c)(9).
Pursuant to 10 CFR 51.22(b) no environmental impact statement or environmental assessment need be prepared in connection with the issuance of the amendment.
6.0 CONCLUSION
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 tha amendment will not be inimical to the common defense and security or to the health and safety of the public.
Principal Contributor:
Sang Rhow Date: October 28, 1996