ML20134C989

Safety Evaluation Supporting Amend 233 to License DPR-59

ML20134C989
Person / Time
Site:	FitzPatrick
Issue date:	10/02/1996
From:	NRC (Affiliation Not Assigned)
To:
Shared Package
ML20134C988	List: ML20134C985 ML20134C989
References
GL-91-04, GL-91-4, NUDOCS 9610110235
Download: ML20134C989 (13)

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UNITED STATES l

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NUCLEAR REGULATORY COMMISSION WASHINGTON, D.C. 2055&0001

.....,o SAFETY EVALVATION BY THE OFFICE OF NUCLEAR REACTOR REGULATION RELATED TO AMENDMENT NO. 233 TO FACILITY OPERATING LICENSE NO. OPR-59 POWER AUTHORITY OF THE STATE OF NEW YORK JAMES A. FITZPATRICK NUCLEAR POWER PLANT DOCKET N0. 50-333

1.0 INTRODUCTION

By letter dated January 25, 1996, the Power Authority of the State of New York (the licensee) submitted a request for changes to the Jame:; A. FitzPatrick Nuclear Power Plant Technical Specifications (TSs). The amendment would extend the instrumentation surveillance test intervals to support 24-month operating cycles. These proposed changes would eliminate the mid-cycle outages to perform the TS surveillance requirements.

2.0 EVALVATION The proposed changes involve the following:

(1) extension of instrumentation and miscellaneous surveillance test intervals to support 24-month operating cycles: (2) revision of the reactor protection system (RPS) normal supply electrical protection assembly (EPA) undervoltage trip setpoint; and (3) editorial revisions, clarification and Bases changes. The instrumentation subject to this proposal involves the following:

RPS, Primary Containment Isolation Systems, Control Rod Blocks, Anticipated Transient Without Scram (ATWS) Recirculation Pump Trip, Accident Monitoring and Remote Shutdown Systems, Radiological Effluent Technical Specification (RETS) monitoring, and safety-related plant ventilation systems.

2.1 Technical Basis Generic Letter 91-04, " Changes in Technical Specification Surveillance Intervals to Accommodate 24-Month fuel Cycle," provided guidance on the type of analysis and information required to justify a change to instrument calibration intervals. The licensee's approach in evaluating 24-month calibration interval extensions is to discuss the seven specific actions delineated in Generic Letter 91-04.

This discussion provides insight to the methodology used by the licensee in evaluating the effects of an increased surveillance test interval (STI) on instrument drift.

The licensee developed Instrument Drift Evaluations (IDES) to address Issues 1, 2, and 3 of Generic Letter 91-04. The IDES document past performance and I

calculations statistically extrapolate the effect of the longer calibration interval on instrument drift. Historical calibration data for components currently calibrated once per 18 months were evaluated to assess the 9610110235 961002 PDR ADOCK 05000333 P

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4 l l acceptability of extending the calibration interval to 24 months.

In general, the IDES are comprised of two phases.

Phase I compares past instrument

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performance to theoretical acceptance limits (Vendor Drift Allowance (VDA) or Calibration Tolerance (CT)).

Phase 2 predicts future drift by statistically extrapolating derived drift data to predict maximum expected drift over a 30-i month interval (MED30).

The historical calibration data is the absolute value of the difference between the "as-found" and previous "as-left" calibration values. The term " drift" as used throughout the IDE actually represents the total instrument calibration uncertainties.

l Calibration data is collected and categorized by component type for analysis.

The tabulated drift values are then compared to theoretical acceptance limits.

I Deviations from this criteria are evaluated on a case-by-case basis.

Phase 2 of the IDE predicts future instrument performance over a maximum 30-month i

period (the maximum calibration interval permitted by TS for a 24-month cycle

+ 25% additional STI) using this Phase 1 data.

Field drift data is analyzed, i

using the square root of the sum of the squares technique, to arrive at a i

value normalized to a 30-month interval. A value of MED30 is statistically derived from normalized field drift data. The MED30 value bounds hardware 1

performance with a 95% probability at a 95% confidence level.

The MED30 value is then compared to the vendor drift allowance extrapolated to a 30-month time j

period, or CT if vendor performance limits are not available.

If MED30 exceeds VDA or CT, then further analysis is performed and loop accuracy and 4

i setpoint calculations are updated to include MED30.

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Loop accuracy calculations were performed to determine total channel i

uncertainties by accounting for instrument inaccuracies.

Loop j

accuracy /setpoint calculations are required to show that sufficient margin

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exists between the analytical limit and the existing field trip setting to confirm that the safety analysis and safety limit assumptions are not i

exceeded. The calculations verify that TS limits provide sufficient margin i

j over the analytical limit to allow for instrument inaccuracies.

If the loop accuracy /setpoint calculation shows that insufficient margin exists, considering 30-month drift uncertainties, one of the following actions is taken: (1) the calibration interval is not extended, (2) new field settings I

(the setting at which the licensee can place the setpoint which is always more conservative than the setpoint listed in the TS) are calculated and the setpoint is revised (if necessary) to ensure sufficient margin exists, or (3) analysis is performed to establish new TS Trip Level Settings that will ensure that safety actions are initiated consistent with the assumptions of the safety analysis.

2.2 Surveillance Test Interval Extension 2.2.1 Specification 1.0.T (Change 1.A.1)

This specification defines the surveillance frequency notations / intervals used in the TSs.

The note in Section 1.0.T clarifies "once per operating cycle,"

and similar phrases, by relating the interval to the definition of the frequency notation "R." The following changes are proposed to this specification:

The notation "R" is defined as " Operating Cycle" with a frequency of "At least once per 24 months (731 days)."

A new notation, "18M," is defined as "18 Months" with a frequency of "At least once per 18 months (550 days)."

Note 1 to the specification is deleted.

Note I has been replaced with phrases that specify the required time intervals such as "once per 24 months" and "once per 18 months." These changes eliminate the clarification provided in Note 1.

These proposed changes are administrative and show the method by 4

which STIs are presented in the TSs.

2.2.2 Reactor Protection System (RPS) Instrumentation a.

RPS Instrument Response Time Testing - SR 4.1.A (Change 1.A.2)

This surveillance requirement (SR) currently requires that the response time of the RPS trip functions listed in Specification 4.1.A be demonstrated at least once per 18 months. This testing verifies that RPS trip functions are completed within the time limits assumed in the accident and transient analyses.

This SR can be extended to support a 24-month STI because of the redundant design of the RPS and adequate on-line testing to detect failures that could affect RPS response times. This conclusion is supported by a review of past surveillance test results which indicate that all required acceptance criteria have consistently been met.

b.

Table 4.1 RPS Scram Instrumentation Test Requirements This SR demonstrates the ability of the reactor mode switch to cause a reactor scram when the switch is placed in " Shutdown" and demonstrates that the time delay for the reset relays is ;t10 seconds. The change in the STI from 18 to 24 months is made by a revision of the Specification 1.0.T definition of "R."

c.

Table 4.1 RPS Scram Instrument Calibration (Change 1.A.1, l.A.3, and 1.A.4)

Item 3 - Flow Bias Signal Item 5 - High Reactor Pressure Item 6 - High Drywell Pressure Item 7 - Reactor Low Water Level Item 8 - High Water Level in the SDIV (Group A)

Item 10 - MSIV Valve Closure Item 11 - Turbine First Stage Pressure Permissive Item 12 - Turbine Control Valve Fast Closure Oil Pressure Trip Item 13 - Turbine Stop Valve Closure Table 4.1-2 currently requires a once per operating cycle calibration for the above listed RPS system instrument channels. The review of past performance for items 5, 6, 7, 8,11,12, and 13 confirmed that past drift values were within the specified calibration tolerances. Therefore, this instrumentation has an acceptable past performance record as defined by GL 91-04.

Past drift for the APRM Flow Bias Signal (Item 3) flow transmitters (Barton and Foxboro) routinely exceeded the specified calibration tolerance. As a result, they

i were replaced with Rosemount Transmitters.

Square root and summing components 1

of the APRM flow bias loop were found out of procedural tolerance in the past due to a tight CT.

New calibration tolerances have been calculated based on past performance and should bound future drift. The main steam isolation valves (MSIV) limit switches (Item 10) have experienced problems during plant operation primarily due to failure of the switches to reset, and slow resets during the periodic MSIV limit switch instrument functional test. The majority of the limit switch failures were related to a reset of the switches, rather than instrument drift. The failure to reset problem has been addressed 3

by installation of modified actuating levers during the Reload 11/ Cycle 12 4

Refueling Outage.

Projected values of future drift were incorporated into loop accuracy calculations for Items 5, 6, 8, 11, and 12. The calculations determined that sufficient margin exists between the field trip setpoints and the analytic limit when the 30-month drift uncertainties are considered.

For the APRM flow bias signal transmitters (Item 3), the projected drift based on Rosemount information of the new transmitters is significantly less than the old transmitters evaluated in the drift analysis using past drift data.

Therefore, it is acceptable to extend the calibration interval to 24 months for these instruments.

Extension of the calibration intervals for Item 7,10, and 13 require changes to the field settings to ensure that sufficient margin exists between the field setting and the TS setpoint limit. The field setting changes will be completed prior to implementation of the 24-month STI.

The staff finds these changes acceptable.

d.

RPS EPA Channel Calibration - SR 4.9.G.2 (Change A.I.18)

This SR currently requires a once per operating cycle calibration of the overvoltage (OV), undervoltage (UV) and underfrequency (UF) protective instrumentation. This includes simulated automatic actuation of relays, logic and output breakers.

Extension of the calibration interval for the Normal and Alternate EPA time delays is acceptable because sufficient margin is available between the field settings and the TS trip setpoints to accommodate the projected drift and uncertainties associated with a 30-month calibration interval. The staff finds these changes acceptable.

2.2.3 Primary Containment Isolation System (PCIS) Instrumentation 4

a.

PCIS Instrument Response Time Testing - SR 4.2.A (Change 1.A.5)

This SR currently requires that response times of the MSIV actuation trip functions listed in SR 4.2.A be demonstrated within specified limits once per 18 months.

This SR can be extended to support a 24-month operating cycle because of the redundant design of the PCIC, adequate on line testing to detect failures that could affect PCIC response times, available margin to l

accommodate potentially slower response times, and a monitoring program to detect failures of these transmitters due to loss of fill-oil.

This conclusion is supported by a review of past surveillance results which indicate that all required acceptance criteria have consistently been met.

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Table 4.2 PCIS Instrumentation Test and Calibration Requirements (Changes 1.A.1, 1.A.10)

Item 2 - Reactor Low-Low-Low Water Level l

Item 3 - Main Steam Line Tunnel High Temperature

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Item 4 - Main Steam Line High Flow l

Item 5 - Main Steam Line Low Pressure Item 7 - Condenser low Vacuum Item 8 - Main Steam Line Tunnel High Radiation Item 9 - HPCI & RCIC Steam Line High Flow Item 10 - HPIC & RCIC Steam Line/ Area High Temp l

Item 11 - HPCI & RCIC Steam Line Low Pressure Table 4.2-1 currently requires a once per operating cycle sensor calibration of the above listed PCIS system trip functions to ensure that the instruments are properly calibrated and actuation takes place at previously determined setpoints. Analysis of historical surveillance data confirmed that past drift values for all devices associated with these line items were within specified tolerances.

Projected values of future drift are incorporated into loop accuracy calculations for each listed PCIS trip function. The calculations determined that the calibration intervals for Items 2, 3, 4, 8, 10, 11, and the RCIC steam line high flow portion of Item 9 can be extended to a 24-month STI because sufficient margin exists between the field trip setpoint and the TS setpoint limit considering 30-month drift uncertainties.

Therefore, extension of the calibration intervals for these items to support a 24-month operating cycle is acceptable.

Extension of the calibration interval for Items 5, 7, and the HPCI steam line high flow portion of Item 9 requires a change to the field settings to ensure that sufficient margin exists between the field setting and the TS setpoint limit. Changes to the TS setpoint level settings listed in Table 3.2-1 are not required to support these field setting changes, c.

Table 4.2 PCIS Simulated Automatic Actuation Requirements (Change 1.A.8) I Item 1 Main Steam Line Isolation Valves, Main Steam Line Drain Valves, and Reactor Water Sample Valves Item 2 RHR - Isolation Valve Control and Shutdown Cooling Valves Item 3 Reactor Water Cleanup Isolation Item 4 Drywell Isolation Valves, TIP Withdrawal, and Atmospheric Control Valves Item 5 SGT System and Reactor Building Isolation Item 6 HPCI Subsystem Auto Isolation Item 7 RCIC Subsystem Auto Isolation Table 4.2-1 defines the simulated automatic actuation (SAA) requirements for the PCIS. The SAA testing confirms the ability of the PCIS to perform its intended function by confirming proper operation of electrical and mechanical components. The extended STI for SAA testing of the PCIS is acceptable based on the high reliability of system components, the redundant design of the PCIS and existing on-line testing. A review of historical surveillance data supports this conclusion.

6 i 2.2.4 Core and Containment Cooling Instrumentation a.

Table 4.2 Core and Containment Cooling System Instrumentation Test and Calibration Requirements (Changes 1.A.1, l.A.6 and 1.A.10)

Item 1 - Reactor Water Level Item 2b - Drywell Pressure Item 3b - Reactor Pressure Item 4 - Auto Sequencing Timers Item 9 4kV Emergency Bus Undervoltage Relays & Timers Item 1C-LPCI Cross Connect Valve Position Table 4.2-2 currently requires a once per operating cycle calibration of Items 1, 2b, 3b, 4, 9, and an instrument functional test for Items 9 and 10 to ensure the instruments are properly-calibrated and actuation takes place at previously evaluated setpoints.

The calibration interval for Item 4 is not extended at this time because sufficient data is not available to properly evaluate the effects of the longer STI on instrument drift. Calibration of these timers on an 18-month STI will not impact the proposed 24-month operating cycle because the testing can be done with the plant on-line.

Therefr e, this calibration frequency will be designated as "18M."

The instrument functional test for the LPCI cross-connect valve position indication channel (Item 10) demonstrates that an annunciator alarms when either the LPCI cross-connect valve control room panel keylock switch is in the "Open" position or the LPCI cross-;annect valve is not in the full closed position.

Review of historical data shows that there have been no recorded failures of this function during testing or operations. These devices are i

I highly reliable and do not exhibit time dependent performance failures. The I

valve is verified locked closed on a monthly basis. Therefore, the safety function is verified more often than the calibration STI would require, and extension of this test interval to accommodate a 24-month operating cycle is, therefore, acceptable.

Analysis of historical surveillance data for Items 1, 2b, 3b, and 9 confirmed that past drift values for these devices were within the specified tolerances.

A review of the 4kV emergency bus undervoltage and degraded voltage relays and timers functional test indicates that all required acceptance criteria have consistently been met.

Predicted values of future drift were incorporated into loop accuracy calcu'ations for Items 1, 2b, 3b, and 9.

The calculations determined that the STI for Items 1, 2b, and 3b can be extended to support a 24-month operating cycle because sufficient margin currently exists between the field trip setpoint and the TS setpoint limit. The field trip setting and TS setpoint limit need to be changed for Item 9 to account for increased instrument drift.

The staff finds these changes acceptable.

N

' Able 4.2 Core and Containment Cooling System Instrumentation Test and

alibration Requirements (Change 1.A.8)

Item 1 Core Spray Subsystem Item 2 Low Pressure Coolant Injection Subsystem Item 4 HPCI Subsystem Item 5 ADS Subsystem Section 4.5 - Core and Containment Cooling Systems Surveillance Requirements (Changes 1.A.12 and 1.A.13) j Table 4.2-2 defines the Logic System Functional Test (LSFT) and SAA requirements for emergency core cooling system (ECCS) logic. The SAA and LSFT 3

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requirea'_nts of Items 1, 2, and 4 are duplicated in Section 4.5.A.1, 4.5. A.3, and 4.5.C.1 of the Technical Specifications. However, for the LSFT requirements, the surveillance frequency listed in Section 4.5 is once per operating cycle while the frequency listed in Table 4.2-2 is once per six months. To resolve this discrepancy, the LSFT and SAA frequencies listed in Section 4.5 will be revised to reference the SR in Table 4.2-2 (once per six months for LSFT and once per 18 months in Note 7 for SAA). The extension of SAA testing to 24 months for Items 1, 2, 4, and 5 is proposed by a revision of Note 7 of Table 4.2-2.

Extension of the SAA testing to a 24-month intarval for these systems is acceptable based on the results of a review of historical surveillance data which show high reliability of system components, redundant design of the ECCS, and existing on-line testing capability.

4.5.E.1.a - RCIC Simulated Automatic Actuation Test (Change 1.A.15) 4.5.E.1.f - RCIC LSFT (Change 1.A.15)

SR 4.5.E.1.a and 4.5.E.1.f define the LSFT and SAA requirements for the RCIC system.

Based on the results of a review of historical surveillance data which shows the acceptable reliability of system components and existing on-line testing, it is acceptable to extend the STI to 24 months for RCIC system LSFT and SAA testing.

2.2.5 Control Rod Block Instrumentation Test and Calibration Requirements Table 4.2 Control Rod Block System Logic Check and Simulated Automatic AcLation Requirement (Change 1. A.7)

The control rod block logic is arranged in a "I of n" configuration in which a rod block signal is generated each time a channel functional test or calibration is performed. Therefore, these tests are equivalent to an SAA because the testing actuates the control rod block circuitry. This adequately demonstrates the control rod block circuit design function.

Furthermore, the existing functional testing and calibrations satisfy the requirements of an LSFT. Therefore, the licensee proposes to delete the SAA and LSFT requirements for this function. Deletion of the SAA and LSFT requirements in Table 4.2-3 will also make the periodic test requirements for the control rod block instrumentation consistent with BWR Standard Technical Specifications.

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Prior to implementation of the proposed amendment, the licensee will conduct a review of surveillance testing procedures to verify that testing performed on the control rod block logic is consistent with the requirements stated in the BWR Standard Technical Specifications.

2.2.6 ATWS Recirculation Pump Trip Instrumentation Table 4.2 ATWS Recirculation Pump Trip Instrumentation Test and Calibration Requirements (Change 1.A.1)

Table 4.2-7 currently specifies a once per operating cycle channel calibration, SAA and LSFT for the ATWS instrumentation.

The LSFT and SAA testing can be extended to a 24-month STI because the instrumentation used is highly reliable, and there is sufficient on-line testing to verify operability of the system. An analysis of historical calibration data confirmed that past i

drift values for these instruments were within specified tolerances.

i Predicted values of future drift were incorporated into loop accuracy calculations for each listed circuit.

The calculations determined that the ATWS instrument calibrations can be extended to a 24-month STI because sufficient margin exists between the field trip setpoint and the TS setpoint limit.

This extended STI is, therefore, acceptable.

4 2.2.7 Accident Monitoring Instrumentation 4

Table 4.2 Minimum Test and Calibration Frequency for Accident Monitoring Instrumentation (Change 1.A.1 and 1.A.11) l Item 4 Containment High Range Radiation Monitor Item 5 - Narrow Range Drywell Pressure Item 6 - Wide Range Drywell Pressure Item 7 - Drywell Temperature i

Item 8 - Wide Range Torus Water Level Item 9 - Torus Bulk Water Temperature Item 10 - Torus Pressure Item 12 - Reactor Vessel Pressure 4'

Item 13 - Fuel Zone Reactor Water Level Item 14 - Wide Range Reactor Water Level Item 15 - Core Spray Flow Item 16 - Core Spray Discharge Pressure Item 17 - LPCI (RHR) Flow Item 18 - RHR Service Water Flow Item 20 - Narrow Range Torus Water Level Item 21 - Drywell-Torus Differential Pressure Table 4.2-8 requires a once per operating cycle instrument functional test and calibration for the above accident monitoring instrumentation. Analysis of historical surveillance data confirmed that past drift values for these instruments were within the specified tolerances. Therefore, this instrumentation has an acceptable past performance record as defined by Generic Letter 91-04.

Postulated values of future drift were incorporated into loop accuracy calculations for these instruments to maintain sufficient margin between the field trip setpoint and the TS setpoint limit. Therefore,

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extension of the functional test and calibration frequency to 24 fronths is acceptable.

2.2.8 Remote Shutdown Instrumentation j

Remote Shutdown Capability Instrumentation and Controls (Change 1.A.1) i Table 3.2-10:

Note C - Instrument Calibration for Each Required Instrument Channel Note D - Demonstrate Control Circuit and Transfer Switches Function Table 3.2-10 currently requires a once per operating cycle calibration of the i

remote shutdown instrumentation and demonstration that each control circuit l

and transfer / isolation switch is capable of performing its intended function.

Analysis of historical surveillance data for the remote shutdown instrumentation confirmed that past drift values for all these devices were i

within specified tolerances.

Therefore, this instrumentation has an l

acceptable past performance record as defined by Generic Letter 91-04.

j Predicted values of future drift for these instruments were incorporated into loop accuracy calculations to ensure that sufficient margin exists between the l

field trip setpoint and the TS setpoint limit. Therefore, the instrument calibrations can be extended to a 24-month STI. Also, a review of past 1

performance of the control circuit and transfer switch functional tests show l

no test failures.

Therefore, extension of the functional test STI interval j

for the control circuit and transfer switch is acceptable, 2.2.9 Miscellaneous Instrumentation Calibrations and Functional Tests j

l a.

Standby Gas Treatment (SGT) System Differential Pressure Switch Calibration - SR 4.7.B.1.f (Change 1.A.16) i l

This SR currently requires calibration of the SGT system differential pressure switches once per operating cycle. Analysis of past instrument performance confirmed that drift values for these devices were within the specified tolerances.

Predicted values of future drift were incorporated into loop accuracy calculations for these circuits. The calculations determined that j

sufficient margin exists between the field trip setpoint and the TS setpoint limit for the STI extension. Therefore, the proposed extension of the calibration interval to 24 months for the SGT differential pressure i

instrumentation is acceptable.

b.

SR 4.11.A.3 Control Room Ventilation Temperature Transmitter and l

Differential Pressure Switch Calibration (Change 1.A.19)

This SR currently requires calibration of the temperature transmitters and 3

differential pressure indicating switches (DPIS) for the control room i

ventilation system once per operating cycle. A review of drift data for the i

DPIS switches and temperature transmitters indicates that drift values were i

within the required calibration tolerance. Therefore, the instrumentation has an acceptable performance record as defined in Generic Letter 91-04.

Review of past drift data for the normal ventilation supply and exhaust fan j

differential pressure switches (DPS) indicates that the drift values exceeded i

specified CT on more than rare occasions. As a result, they have been l

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replaced with new switches.

Past drift for the temperature indicating controllers has exceeded the CT on more than rare occasions with four out of the five failures occurring before 1988. Past drift for the emergency trains i

differential pressure switches has exceeded the CT on more than rare i

occasions. All these failures were minimally above CT and did not jeopardize the switch design function. New calibration tolerances have been calculated for these instruments based on past performance to bound future drift for the extended interval.

Predicted values of future drift were incorporated into j

loop accuracy calculations for these instruments. New calibration tolerance 1

bands for the DPS, DPIS, and certain temperature instrumentation were l

calculated based on past instrument performance.

The calculations determined that future drift over the longer STI is predicted to remain within the

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existing or revised calibration tolerance. Sufficient margin is provided i

between the field trip setpoint and the TS setpoint limit.

Based on the above analysis, the proposed extension of the calibration STI to 24 months for this j

instrumentation is acceptable.

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c.

SR 4.11.B.2 Crescent Area Unit Cooler Temperature Control Instrumentation i

Calibrations (Change 1.A.20)

I A review of drift data for the fan control temperature switches and the temperature indicating controllers for the crescent area indicates that drift j

values were within the required calibration tolerance. Therefore, the

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instrumentation has an acceptable past performance record as defined in Generic Letter 91-04.

Predicted values of future drift for these instruments v

were incorporated into loop accuracy calculations to ensure that sufficient i

margin exists between the field setpoint and the TS setpoint limit considering 30-month drift uncertainties. Based on the results of the above analysis, the proposed extension of the calibration interval for the temperature control instrumentation is acceptable.

4 d.

SR 4.11.C.2 Battery Room Ventilation Temperature Transmitter and Differential Pressure Switch Calibrations (Change 1.A.21) 1 4

A review of past drift data for the battery room differential pressure switches indicates that drift has exceeded the calibration tolerance on several occasions. These failures were on the air handling unit (AHU) and 1

recirculation fan switches which provide annunciation only and do not perform a safety-related function, and on the exhaust fan switches which provide an 4

automatic start of the exhaust fans. New calibration tolerances have been l

calculated for these instruments based on past performance to bound future drift.

Predicted values of future drift for these instruments were incorporated into loop accuracy calculations to ensure that sufficient margin exists between the field trip setpoint and the TS trip setpoint limit when 30-month drift uncertainties are considered. Based on the results of the

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above analpis, the proposed extension is acceptable to the staff.

e.

RETS SR 3.7.a., 3.7.b.2 and 3.7.b.3 Off-Gas System Explosive Gas Instrumentation Channel Functional Test and Instrument Calibrations (Changes 1.A.22, 1.A.23, 1.A.24, 1.A.25)

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A review of past drift data for the dilution steam flow and recombiner i

temperature instruments in the off-gas explosive gas system indicates that drift values were within the required calibration tolerance. Therefore, this instrumentation has an acceptable past performance record as defined in Generic Letter 91-04.

Predicted values of future drift for the dilution 4

i system flow and recombiner temperature instruments were incorporated into loop i

accuracy calculations to ensure that sufficient margin exists between the field setpoint and the TS setpoint limit considering 30-month drift uncertainties.

Past drift for the hydrogen analyzers has exceeded the i

calibration tolerance on several occasions. A review of the hydrogen analyzer I

performance shows that the STI should not be extended for these instruments.

The manufacturer recommends that these units be calibrated once per quarter.

A new RETS 3.7.b.4 was added to require calibration of these instruments once i

per quarter.

Based on the above analysis, the extension of the calibration interval to 24 months for these instruments is acceptable with the addition of i

the new TS 3.7.b.4 which requires calibration of the hydrogen analyzer once l

per quarter.

j f.

RETS SAA and LSFT Requirements (Changes 1.A.26, 1.A.29 and 1.A.30) Table j

3.10-2:

i Item 3 - Reactor Building Area Exhaust Monitors, Recorders and Isolation i

Simulated Automatic Actuation Note f) 4 Item 6 - SJAE Radiation Monitors /0ffgas Line Isciation Simulated Automatic Actuation (Note f)

Item 8 - Mechanical Vacuum Pump Isolation Simulatti Automatic Actuation (Note f) and LSFT Item 9 - Liquid Radwaste Discharge Monitor / Isolation Simulated Automatic Actuation (Note f)

Item 12 - Normal Service Water Effluent (Note f)

Item 13 - SBGTS Actuation (Note f)

The LSFT requirement for the above listed items in Table 3.10-2 except Item 8 is not changed.

The LSFT frequency for Item 8 is changed from "Once per Operating Cycle" to "Once per 24 Months" by revision of the Table 3.10-2 notation.

The SAA testing interval of the instrumentation for Items 3, 6, 8, 9, and 13 is extended to 24 months by Note f in Table 3.10-2.

A review of the surveillance test data and operating work history revealed no failures that would prevent the initiation of their functions. Therefore, extension of the STI to 24 months is acceptable.

For Item 12, a quarterly instrument channel functional test and calibration is performed to verify the indication and alarm functions. During calibration, a source check is performed to ensure that the detector responds properly to a known source of radioactivity.

This combination of testing meets the intent of the SAA testing, which is to actuate the circuit in question by applying a simulated signal to the sensor.

Therefore, the once per operating cycle SAA testing requirement for this instrumentation is redundant to the testing that is already performed on a quarterly basis, and deletion of the SAA requirement for the normal service water effluent monitor is acceptable.

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. _ - 1 2.2.10 Changes to the RPS Normal Supply EPA Undervoltage Trip Setting in SR 4.9.G.2 (Change 1.B.6)

The licensee performed a calculation to determine the total channel uncertainties associated with the normal RPS EPA trip setpoints over a 24-month operating cycle.

Based on the results of this calculation, the RPS MG set source undervoltage (UV) setpoint specified in SR 4.9.G.2 requires revision from its present value of 2108V to 2112.3V. The licensee analyzed the impact of the voltage drop from the EPAs to scram the pilot valve solenoids and other relays and concluded that the minimum voltage should be raised for the RPS scram pilot valve solenoids to ensure proper operation.

The proposed SR 4.9.G.2 RPS MG set source UV setpoint, 2112.3V, is more conservative.

Based on our review of the setpoint analysis and the fact that is more conservative, the staff concludes that this setpoint change is acceptable.

2.2.11 Editorial, Clarification and Bases Changes a.

Technical Specification Tables 4.1-2, 3.2-10, 4.2-5, 4.2-6, and 4.2-8 are revised to make the format consistent with the changes in the proposed amendment and the BWR Standard Technical Specifications. These proposed changes are editorial in nature to clarify the TS requirements and are, therefore, acceptable.

b.

The proposed changes to Table 3.2-10 clarify the operability and surveillance requirements by adding instrumentation components previously omitted from the table, and by reformatting the table to make it consistent with other instrumentation tables in the TS.

These changes clarify operability and surveillance requirements for the remote shutdown equipment, incorporate editorial changes and do t.ot change any TS requirements.

They are, therefore, acceptable.

c.

The proposed changes to the Technical Specification hses revise teiis such as "each refueling outage," "during refueling outage," "once pe -

operating cycle," and "once per 24 months" to provide consistency between the surveillance test intervals and the Bases discussion. These proposed changes clarify the new STIs and are acceptable.

Based on review of the proposed changes to the James A. FitzPatrick Nuclear Power Plant TS, the NRC staff finds that the proposed changes to extend instrumentatirn surveillance test intervals to support 24-month operating cycles are consistent with the provisions of Generic Letter 91-04.

In addition, the staff finds that the proposed instrument setpoint changes provide sufficient margin between the field settings and the TS limits for instrument drift predicted for the extended calibration interval. Finally, the staff finds that the proposed editorial changes and Bases changes more clearly define the surveillance requirements with specific applicability and corrective actions.

The staff, therefore, concludes that the proposed TS changes for instrumentation surveillances on a 24-month operating cycle as discussed above are acceptable.

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3.0 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.

4.0 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 significant change in the types, of any effluents that may be released offsite, and that there is no si occupational radiation exposure.gnificant increase in individual or cumulative 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 i

25709). Accordingly, the amendment meets the eligibility criteria for categorical exclusion set forth in 10 CFR 51.22(c)(9).

Pursuant to 10 CFR t

51.22(b) no environmental impact statement or environmental assessment need be j

prepared in connection with the issuance of the amendment.

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, l

and (3) the issuance of the amendment will not be inimical to the common defense and security or to the health and safety of the public.

i Principal Contributor: Sang Rhow Date: October 2, 1996 l

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