ML20198M690

Safety Evaluation Supporting Amend 103 to License DPR-22

ML20198M690
Person / Time
Site:	Monticello
Issue date:	12/23/1998
From:	NRC (Affiliation Not Assigned)
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NUDOCS 9901050324
Download: ML20198M690 (8)

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SAFETY EVALUATION BY THE OFFICE OF NUCLEAR REACTOR REGULATION i

RELATED TO AMENDMENT NO.103 TO FACILITY OPERATING LICENSE NO. DPR-22 NORTHERN STATES POWER COMPANY

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MONTICELLO NUCLEAR GENERATING PLANT DOCKET NO. 50-2fi3 i,

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1.0 INTRODUCTION

By letter dated July 5,1995, as supplemented October 9,1998, the Nonhern States Power r

Company (NSP or the licensee) requested an amendment to the Technical Specifications (TS) appended to Facility Operating License No. DPR-22 for the Monticello Nuclear Generating.

Plant. The proposed amendment would extend surveillance test intervals and allowable out of-service times for instrumentation in the Emergency Core Cooling (ECCS), Rod Block, i

isolation Group 4 (High Pressure Coolant injection, or HPCI) and Isolation Group 5 (Reactor i

Core Isolation Cooling, or RCIC), Reactor Building Ventilation & Standby Gas Treatment, Recirculation Pump Trip and Altemate Rod injection, and Shutdown Cooling Supply Isolation j

Systemi.

ii The October 9,1998, letter withdrew a portion of the original request, provided additional I

clarifying information, and updated TS pages. This information was within the scope of the origina1 Federa/ Register notice and did not change the staff's initial proposed no significant s

4 hazards considerations determination.

l 2.0 EVALUATION 1

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2.1 Backaround I

The amendment is Part 2 of the Monticello Surveillance Test Interval / Allowed Outage Time s

(STi/AOT) Program to extend surveillance test intervals and allowed outage times for selected instrumentation. The purposes of the proposed changes are to minimize unnecessary testing

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and remove excessively restrictive out-of-service times that could potentially degrade overall plant safety and availability. Part 1 of the Monticello STl/AOT Program was previously i

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approved by the NRC via Amendment No. 81 to Facility Operating License No. DPR-22, dated April 16,1992. The changes were based on analyses presented in General Electric Company (GE) tcpical reports (Refs.1 through 3) to support the determination that current on-line Reactor Protection System (RPS) test intervals were consistent with the high ava!! ability required by item 4.5.3 of NRC Generic Letter 83-28, " Required Actions Based on Generic Implications of Salem ATWS Events," dated July 8,1983.

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y Following evaluation, the staff found the GE analyses acceptable (Refs. 4 through 6). The staff also approved other GE analyses (Refs. 7 through 10) for extensions to STis and increases for AOTs for rod block and isolation instrumentation via subsequent safety evaluations (Refs.11 through 15). The GE methodology for changing instrument functional testing from monthly to 4

quarterly was found to be acceptable provided the generic analyses were shown to be applicable to the specific plant, and instrument drift expected with the extended functional test interval was within the margins of the methodology.

2.2 Aeolicability of Toolcal Reoorts As stated in its application, the licensee confirmed that it had reviewed the GE generic and plant-specific analyses and concluded that they were applicable to Monticello Nuclear i

Generating Plant. To address the instrument setpoint drift issue, the licensee performed a drift analysis on each instrument channel whose surveillance interval is being extended. The 4

analysis was done in accordance with guidance provided by letter from C. Rossi (NRC) to i

R. Janecek (BWR Owners' Group), " Staff Guidance for Licensee Determination that the Drift Characteristics for Instrumentation Used in RPS Channels are Bounded by NEDC-30851P Assumptions when the Functional Test Interval is Extended from Monthly to Quarterly," dated April 27,1988. To address the setpoint drift in the amendment proposal, the licensee analyzed plant-specific drift that could be expected. Drift was shown to remain within required allowance for all instruments with the exception of PS 2-3-52A, " tow Reactor Pressure ECCS Valve Permissive." The licensee replaced PS 2-3-52A to address the additional drift, as confirmed by l

the October 9,1998, supplement.

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Based on the above, the findings of the GE topical reports and the conclusions of the

. subsequent staff safety evaluations are applicable to Monticello.

2.3 Evaluation of Pronosed Chanoes

a. The licensee proposes to revise the note associated with the column labeled " Required Conditions when minimum conditions for operation are not satisfied," referenced in TS.

Table 3.1.1, " Reactor Protection System (Scram) Instrument Requirements," by adding a g'

reference to TS 3.1.B. TS 3.1.B specifies actions to be taken upon discovery that the

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requirements for the number of operable or operating trip systems or instrument channels are i

not satisfied, as follows: with one required instrument channel inoperable in one or more trip functions, place the inoperable channel (s) or trip system in the tripped condition within i

12 hours1.388889e-4 days <br />0.00333 hours <br />1.984127e-5 weeks <br />4.566e-6 months <br />, or with more than one instrument channel inoperable for one or more trip functions, immediately satisfy the minimum requirements by placing appropriate channel (s), or trip system (s) in the tripped condition, or place and maintain the plant under tne specified required i

conditions using normal operating procedures. The revision of the note does not change the requirements of the TS and is acceptable to the staff.

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The licensee also proposes to remove the time 'within 8 hours9.259259e-5 days <br />0.00222 hours <br />1.322751e-5 weeks <br />3.044e-6 months <br />" for Required Condition A so that it reads, "All operable control rods fully inserted." As a result, control rods would be required to 1

be inserted in accordance with TS 3.1.B.3, allowing a time frame defined by normal operating I

procedures, instead of within 8 hours9.259259e-5 days <br />0.00222 hours <br />1.322751e-5 weeks <br />3.044e-6 months <br />. The changes eliminate a potential conflict between TS 3.1.B.3 and Table 3.1.1 Required Condition A and allow for a controlled p! ant shutdown in

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. accordance with normal operating procedures if required by plant conditions. These changes are acceptable to the staff.

b. The licensee proposes to change the wording for instrument channel, " Mode Switch in Shutdown," in Table 4.1.1, " Scram Instrument Functional Tests - Minimum Functional Test Frequencies for Safety Instrumentation and Control Circuits," from "Each refueling ouSge" to "Every operating cycle," to be consistent with the wording elsewhere in the TS, such as in Table 4.1.2, " Scram Instrument Calibration - Minimum Calibration Frequencies for Reactor Protection Instrument Channels." The change does not affect the frequency of the test and is acceptable to the staff,

c. The licensee propos% to remove the wording "and on high steam line radiation once per shift" from Note 2 of Table 4.1.1. The wording should have been removed as part of Amendment No. 83 to Facility Operating License No. DPR-22, dated August 18,1992, which deleted the main steam line high radiation scram and associated reactor vessel isolation function from the TS. The change is editorial and is acceptable to the staff.

d. The licensee proposes to add border lines to Tables 3.2.1,3.2.2,3.2.4,3.2.8, and 4.2.1.

The changes are editorial and are acceptable to the staff.

e. The licensee proposes to correct a typographical error in Bases Section 4.1 by changing

" amplifies" to " amplifiers." The corrected sentence will read, "For those devices which employ amplifiers eic., drift specifications call for drift to be less than 0.5%/ month; i.e., in the period of a month a drift of 0.5% would occur and thus provide an adequate margin." The change is editorial and is acceptable to the staff.

f. In Table 3.2.1, " Instrumentation That initiates Primary Containment Isolation Functions," the licensee proposes to add the designations " Group 4" to item 4, "HPCI Steam Lines," and

" Group 5" to item 5, "RCIC Steam Lines." The change provides additional descriptive information and makes the wording of these two titles consistent with the titles listed earlier in the same table. The addition does not changa the meaning or requirements of the sections.

The change is editorial and is acceptable to the staff.

g. The licensee proposes to modify Notes 1 and 2 to Table 3.2.1, " Instrumentation That Initiates Primary Containment Isolation Functions," to eliminate separate entries for Groups 1, 2, and 3 and Groups 4,5, and Reactor Pressure Interlocks and make Notes 1 and 2 applicable to all groups. The phrase, "a shared channelis considered one channel," would be added to Note 1.

In Part 1 of the licensee's STl/AOT extension program (Amendment No. 81 to Facility Operating License No. DPR-22, dated April 16,1992), Notes 1 and 2 to Table 3.2.1 were divided up to recognize new AOT requirements for the instrumentation on the extended (3-month) surveillance cycle (Groups 1,2, and 3). Since the current proposal will put the remaining instrumentation on a 3-month STI, it deletes the existing wording and places the same AOT requirements on the remaining instrumentation (Groups 4,5, and Reactor Pressure Interlocks).

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. The extension of AOTs provides time to perform testing or to make repairs without significantly affecting overall instrumentation failure frequency or plant safety. The wording proposed for the Part 2 instrumentation is identical to the wording approved in Part 1 with the addition of the phrase, "a shared channel is considered one channel." This phrase is being added to clarify that a shared channel is treated as a single channel. The change is consistent with the AOTs recommended by GE in References 3,9, and 10 and approved by the staff in safety evaluations References 6,14, and 15, respectively, and is acceptable.

h. The licensee proposes to add Note 6 and revise Note 3 to Table 3.2.2, " Instrumentation That Initiates Emergency Core Cooling Systems." Note 6 is to be added to the columns titled,

" Minimum No. of Operable or Operating Trip Systems" and " Minimum No. of Operable or Operating Instrument Channels per Trip System."

Proposed Note 6 reads, "A channel (a shared channel is considered one channel) may be placed in an inoperable status for up to 6 hours6.944444e-5 days <br />0.00167 hours <br />9.920635e-6 weeks <br />2.283e-6 months <br /> for required surveillance without placing the trip system in the tripped condition provided that at least one other operable channel in the same trip system is monitoring that parameter." The addition of Note 6 is to add the 6-hour out-of-service tima for performance of surveillance without tripping the system. The addition of the phrase, "a shared channel is considered one channel," is being added to clarify that a shared channel is treated as a single channel.

The proposed revision to Note 3 includes a new condition "a" that allows "with one required instrument channel inoperable per trip function, place the inoperable channel or trip system in the tripped condition within 12 hours1.388889e-4 days <br />0.00333 hours <br />1.984127e-5 weeks <br />4.566e-6 months <br />," changing old cond; tion "a" to condition "b" and revising it to read, "with more than one instrument channel per trip system inoperable, immediately satisfy

~ the requirements by placing appropriate channels or systems in the tripped condition," and changing old cond; tion "b" to condition "c" without revision.

The changes are consistent with the AOT recommended by GE in Reference 8 and approved by the staff in safety evaluations References 12 and 13, and are acceptable.

i. The licensee proposes to add new Notes 5 and 6 to Table 3.2.4, " Instrumentation That Initiates Reactor Building Ventilation Isolation and Standby Gas Treatment System initiation."

New Note 5 requires that, "Upon discovery that minimum requirements for the number of operable or operating trip systems or instrument channels are not satisfied action shall be initiated as follows: (a) With one required instrument channel inoperable per trip function, place the inoperable channel or trip system in the tripped condition within 12 hours1.388889e-4 days <br />0.00333 hours <br />1.984127e-5 weeks <br />4.566e-6 months <br />, or (b) With more than one instrument channel per trip system inoperable, immediately satisfy the requirements by placing appropriate channels or systems in the tripped condition, or (c) Place the plant under the specified required conditions using normal operating procedures." New Note 6 requires j

that, "A channel may be placed in an inoperable status for up to 6 hours6.944444e-5 days <br />0.00167 hours <br />9.920635e-6 weeks <br />2.283e-6 months <br /> for required surveillance without placing the trip system in the tripped condition provided that at least one

. other operabie channel in the same trip system is monitoring that parameter." New Notes 5 and 6 would be applicable to the Low Low Reactor Water Level and High Drywell Pressure functions.

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.. The addition of Notes 5 and 6 add the extension of AOTs to perform testing or to make repairs for the Low Low Reactor Water Level and High Drywell Pressure functions without significantly affecting overallinstrumentation failure frequency or plant safety. The change is consistent with the AOTs recommended by GE in References 2 and 3, which were approved by the staff in safety evaluations References 5 and 6, respectively, and is acceptable.

The licensee proposes to rearrange the applicability notes in Table 3.2.4 to place them all in the column titled,'

• Min. No. of Operable or Operating Instrument Channels Per Trip System." The l-rearrangement is to lessen the chances that any notes may be overlooked. The changes are l

editorial and are acceptable to the staff.

J. The licensee proposes to revise the notes for Table 3.2.8, "Other Instrumentation," to modify the AOTs for the Low Low Reactor Level, High Reactor Level, and Condensate Storage Tank Low Level functions. Modified Note 1 requires that, "Upon discovery that minimum requirements for the number of operable or operating trip systems or instrument channels are not satisfied, action shall be initiated as follows: a. With one required instrument channel inoperable per trip function, place the inoperable channel or trip system in the tripped condition within 12 hours1.388889e-4 days <br />0.00333 hours <br />1.984127e-5 weeks <br />4.566e-6 months <br />, or b. With more than one instrument channel per trip system inoperable, immediately satisfy the requirements by placing appropriate channels or systems in the tripped condition, or c. Place the plant under the specified required conditions using normal operating procedures.' New Note 2 requires that, "A channel may be placed in an inoperable status for up to 6 hours6.944444e-5 days <br />0.00167 hours <br />9.920635e-6 weeks <br />2.283e-6 months <br /> for required surveillance without placing the trip system in the tripped condition provided that at least one other operable channel in the same top system is monitoring that parameter." The change is consistent with the changes proposed for Table 3.2.1 above and AOTs recommended by GE in Reference 3 and approved by the staff in safety evaluation Reference 6, and is acceptable.

The proposed change to Note 1 also deletes reference to the described tripped condition

" turbine /feedwater trip only," since it is not applicable to the functions described in Table 3.2.8.

The change is editorial and is acceptable to the staff.

In Table 3.2.8, the licensee proposes to correct the " Total No. of Instrument Channels Per Trip System" and " Minimum No. of Operable or Operating Instrument Channels Per Trip System" for RCIC Initiation from 2 to 4. These were errors in the table that existed since it was first added.

The licensee reviewed Electrical Print NX-7822-22-2 to verify the correct numbers. The change is editorial and is acceptable to the staff.

The licensee proposes to revise Table 3.2.8 Required Condition A to reference the specific TS, TS 3.5.A, that pertains to the applicable condition. TS 3.5.A, "ECCS Systems," provides the specific limiting conditions for operation to be entered, and so is more descriptive than the current wording of Required Condition A, which lists only the allowable modes. The change is consistent with other sections of the TS. In addition, the licensee proposes to revise Table l

3.2.8 Required Condition C to read, " place the plant in the Required Condition A for HPCI, or B for RCIC." The addition provides separate pointers to the correct TS sections pertaining to HPCI and RCIC. The changes clarify existing TS and do not add or delete existing j

requirements. The changes are acceptable to the staff.

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k. The licensee proposes to increase the test frequency to once/3 months for all entries currently listed as once/ month in Table 4.2.1, " Minimum Test and Calibration Frequency for Core Cooling Rod Block and Isolation Instrumentation," including ECCS, Rod Block, Isolation Group 4 (HPCI), Isolation Group 5 (RCIC), Reactor Building Ventilation & Standby Gas Treatment, Recirculation Pump Trip and Altemate Rod Injection, and Shutdown Cooling Supply isolation Systems. The extended STls will reduce the potential for unnecessary plant scrams, thereby reducing challenges to plant shutdown systems and excessive cycling of equipment,

. thus improving plant availability. In addition, the elimination of unnecessary testing results in a l

potential safety gain and operational improvement by improving utilization of personnel and l

resources required for testing activities, by decreasing radiation exposure, and by reducing potential equipment wearout. The changes are consistent with the STis recommended by GE in References 1 through 3 and 7 through 10 and approved by the staff in safety evaluations l

References 4 through 6 and 11 through 15 and are acceptable.

3.0 STATE CONSULTATION

in accordance with the Commission's regulations, the Minnesota State official was notified of the proposed issuance of the amendment. The State official had no comments.

4.0 ENVIRONMENTAL CONSIDERATION

l The amendment changes requirements with respect to the installation or use of a facility j

component located within the restricted area as defineri in 10 CFR Part 20 and changes surveillance requirements. The staff has determined that the amendment involves no significant increase in the amounts, and no significant change in the types, of any effluents that l

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 (60 FR 45182). 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),

L no environmental impact statement or environmental assessment need be prepared in l

connection with the issuance of the amendment.

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5.0 CONCLUSION

l The Commission has concluded, based on the considerations discussed above, that: (1) there l

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 l

Commission's regulations, 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.

Principal Contributor: C. Lyon Date: December 23,.1998

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6.0 REFERENCES

1. GE Topical Report NEDC-30851P, " Technical Specification improvement Analysis for BWR j

Reactor Protection System," dated May 31,1985. (NRC-accepted version dated March 1988.)

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(Proprietary Information. Not publicly available.)

2. GE Topical Report NEDC-30851P, Supplement 2, " Technical Specification Improvement Analysis for BWR lsolation instrumentation Common to RPS and ECCS instrumentation," dated August 29,1986. (NRC-accepted version dated March 1989.) (Proprietary Information. Not publicly available.)

3. GE Topical Report NEDC-31677P, " Technical Specification improvement Analysis for BWR isolation Actuation Instrumentation," dated June 27,1989. (NRC-accepted version dated July 1990.) (Proprietary Information. Not publicly available.)

4. Letter and enclosed safety evaluation approving GE Topical Reports NEDC-30844 and NEDC-30851P, dated July 15,1987, from A. Thadani (NRC) to T. Pickens (BWR Owners' Group).

5. Letter and enclosed safety evaluation approving GE Topical Report NEDC-30851P, Supplement 2, dated January 6,1989, from C. Rossi (NRC) to D. Grace (BWR Owners' Group).

6. Letter and enclosed safety evaluation approving GE Topical Report NEDC-31677P, dated June 18,1990, from C. Rossi (NRC) to S. Floyd (BWR Owners' Group).

7. GE Topical Report NEDC-30851P, Supplement 1, " Technical Specification Improvement Analysis for BWR Control Rod Block instrumentation," dated June 23,1986. (NRC-accepted version dated October 1988.) (Proprietary Information. Not publicly available.)

8. GE Topical Report NEDC-30936P, *BWR Owners' Group Technical Specification Improvement Methodology (With Demonstration for BWR ECCS Actuation Instrumentation),

Parts 1 and 2," dated July 23,1987. (NRC-accepted version dated December 1988.)

(Proprietary Information. Not publicly available.)

9. GE Topical Report GENE-770-06-1, " Bases for Changes to Surveillance Test Intervals and Allowed Out-of-Service Times for Selected Instrumentation Technical Specifications," dated February 19,1991. (NRC-accepted version dated December 1992.) (Proprietary and nonproprietary reports available.)

10. GE Topical Report GENE-770-06-2, " Addendum to Bases for Changes to Surveillance Test Intervals and Allowed Out-of-Service Times for Selected Instrumentation Technical Specifications" (BWR RCIC Instrumentation), dated February 19,1991. (NRC-accepted version dated December 1992.) (Proprietary Inforrmn. Not publicly available.)

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.1. Letter and enclosed safety evaluation approving GE Topical Report NEDC-30851P, Supplement 1, dated September 22,1988, from C. Rossi (NRC) to D. Grace (BWR Owners' Group).

12. Letter and enclosed safety evaluation approving GE Topical Report NEDC-30936P, Part 1,

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dated September 26,1988, from A. Thadani (NRC) to R. Janecek (BWR Owners' Group).

13. Letter and enclosed safety evaluation approving GE Topical Report NEDC-30936P, Part 2, dated December 9,1988, from C. Rossi (NRC) to D. Grace (BWR Owners' Group).

14. Letter and enclosed safety evaluation approving GE Topical Report GENE-770-06-1, dated l

July 21,1992, from C. Rossi (NRC) to R. Binz (BWR Owners' Group).

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15. Letter and enclosed safety' evaluation approving GE Topical Report GENE-770-06-2, dated September 13,1991, from C. Rossi (NRC) to G. Beck (BWR Owners' Group).