ML20198S868
| ML20198S868 | |
| Person / Time | |
|---|---|
| Site: | Grand Gulf  |
| Issue date: | 11/05/1997 |
| From: | NRC (Affiliation Not Assigned) |
| To: | |
| Shared Package | |
| ML20198S849 | List: |
| References | |
| NUDOCS 9711140147 | |
| Download: ML20198S868 (11) | |
Text
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t UNITO STATES j
,j NUCLEAR REGULATORY COMMISSION f
WASHINGTON, D.C. 308 2-0001
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SAFETY EVALUATION BY THE OFFICE OF NUCLEAR REACTOR REGULATION RELATED TO AMENDMENT NO.133 TO FACILITY OPERATING LICENSE NO. NPF-29 ENTERGY OPERATIONS. INC.. ET AL.
GRAND GULF NUCLEAR STATION. UNIT 1 DOCKET NO. 50-416
1.0 INTRODUCTION
By letter dated May 7, 19 a, the licensee (Entergy Operations, Inc.),
submitted a request for changes to the Technical Specifications (TSs) for Grand Gulf Nuclear Station, Unit 1.
The proposed changes to the TSs would eliminate response time testing (RTT) requirements for selected sensors and specified instrumentation loops for the following systems:
(1) the Reactor Protection System (RPS), (2) the Primary Containmant and Drywell Isolation System, and (3) the Emergency Core Cooling System (ECCS).
The changes tn the TSs would be to Surveillance Requirements (SRs) 3.3.1.1.15, 3.3.6.1.8, and 3.5.1.8 and 3.5.2.7, respectively.
The licensee stated that there would be a reduction in occupational exposure due to the proposed reduced testing.
In the letter of October 6,1997, the licensee submitted revised changes to the Bases of the TSs for SRs 3.3.1.1.15, 3.3.6.1.8, 3.5.1.8, and 3.5.2.7.
The revisions added the commitments discussed in Section 5.0 of this evaluation.
The 19ensee provided clarifying information in the letter of October 6,1997, t' c e. J not change the initial proposed no significant hazards consideration determination for the proposed change to the TSs.
2.0 BACKGROUND
The Boiling Watcr Reactor Owner's Group (BWROG), with Grand Gulf's participation performed an analysis to assess the impact of elimination of RTT for selee.ted instrument loops. This analysis, documented as Licensing Topical Report NED0-32291 " System Analyses for Elimination of Selected Response Time Testing Requirements", was submitted for NRC approval in January 1994.
The NRC-approved NED0-32291 in a generic Safety Evaluation Report (SER) dated December 28, 1994 and approved subsequent revisions to NEDO-3229: in a supplemental SER dated May 31, 1995.
The generic SER included Tables 1 and 2, which respectively lists the make/model of instruments / devices, and systems which were evaluated in kED0-32291 for RTT elimination.
The generic SER states, "The BWROG concluded that the RTT requirements for the devices identified in Table I can be removed from the TSs when the devices are used in systems listed in Table 2."
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i 2-In addition to approving the elimination of RTT for selected instrumentation, the generic SER stipulated certain conditions that individual plant licensees must meet when implementing the NED0-32291 guidelines on a plant specific basis.
These conditions will be discussed in the. following evaluation of the licensee's proposed changes to the TSs.
The licensee addressed the conditionr in the staff's SER on NED0-3229) in its application for the changes to the TSs.
3.0 EVALUATION The licensee has proposed the elimination of the following selected RTT requirements from the Grand Gulf TSs:
1.
Reactor Protection System instrumentation - Sensors for Reactor Vessel Steam Dome Pressure-High and Reactor Vessel Low Water Level - Level 3; 2.
Isolation Actuation System instrumentation - Sensors for Reactor Vessel Low Water Level-Level 1 and Main Steam Line Flow-High, and; 3.
Emergency Core Cooling System Actuation instrumentation.
As indicated in the NRC-apprcved NEDO 32291, RTT can be eliminated for the following instrumentation based on other TS testing which is sufficient to detect instrumentation response degradation:
1.
All Emergency Core Cooling System instrument loops; 2.
All Isolation System actuation instrument' loops except for main steam line isolation valves (MSIVs);
1 3.
Sensors for selected Reactor Protection System actuation; and 4.
Sensors for MSIV closure actuation.
The specific surveillance requirements and the Bases of the Grand Gulf TSs which the licensee has proposed to change are as follows:
(a)).
Section 3.1. 1, Reacter Protection System Instruments, page 3.3-5, Surveillance Requirement 3.3.1.1.15, Notes.
Erpoosed Chance: Add a note 2 to the surveillance requirement stating "For functions 3, 4, and 5 in Table 3.3.1.1-1, the channel sensors may be excluded." The original note 2 will be relabeled as note 3.
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Bases Section B 3.3.1.1, RPS Instrumentation Surveillance Requirements, Page B 3.3-29, Surveillance Requirement SR 3.3.1.1.15.
P_tangsed Chanae: Add a paragraph between the current paragraph 2 and 3, to read:
" Note 2 allows the channel sensors'of Functions 3, 4, and 5 to be excluded from specific RPS RESPONSE TIME testing. This allowance to not perform specific response time testing of the sensors is applicable when the alturaate testing requirements and restrictions of Reference 10 are performed. As stated in Reference 10, analysis has demonstrated that other Technical Specification testing requirements (CHANNEL CAllBRATIONS. CHANNEL CHECKS, CHANNEL FUNCTIONAL TESTS, and LOGIC SYSTEM FUNCTIONAL TESTS) and actions taken in response to NRC Bulletin 90-01 Supplement I are sufficient to identify failure modes or degradation in instrument response times and assure operation of the analyzed instrument loops within acceptable limits. Reference 10 also identifies that there are no know channel sensor failure modes identified that can be detected by RTT that cannot also be detected by other Technical Specification iequired surveillances. Therefore, when the requirements, incl'iding sensor types, of Reference 10 are complied with, adequate assurt.nce of the response time of the sen:, ors is provided. This assurance of the response time of the sensors when combined with the response time testing of the remainder of the channel ensures that the individual channel response times are less than or equal to the maximum values assumed in the accident analysis. If the alternate tv. sting requirements of Reference 10 are not complied with, then the entire channel will be response time tested including the sensors."
(a)3.
Bases Section B 3.3.1.1, RPS Instrumentation Surveillance Requirements, Page B 3.3-30, References Proposed Chanae: Add reference 10 to the Bases section, to read:
10.
NE00-32291-a, " System Analysis for Elimination of Selected Response Time Testing Requirements," October 1997 Staff Evaluation:
The three functions proposed to be changed are listed in Table 3.3.1.1-1 of NEDO-32291 and are as follows:
Function 3:
Reactor Vessel Steam Dome Pressure: - High Function 4:
Reactor Vessel Water Level - Low, Level 3 Function 5:
Reactor Vessel Water Level High, Level 8 This footnote in the Bases will allow the licensee to use manufacturers response time data, and eliminate the requirement for a separate measurement of the sensor response time.
This is only for the three functions stated above. The remainder of the channel will continue to be tested for response time. This change is consistent with the approved NEDO-32291.
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(b)l.
Section 3.3.6.1, Primary Containment and Drywell Isolation Instrumentation, Surveillance Requirements, page 3.3-53, Surveillance Requirement 3.3.6.1.8, Isolation System Response Time.
Proposed Changg: Add a note to the surveillance requirement for isolation system response time for MSIVs stating that " Channel sensors may be excluded."
(b)2 Bases Section B 3.3.6.1, Primary Containment and Drywell Isolation Instrumentation Surveillance Requirements, Page B 3.3-170, Surveillance Requirement SR 3.3.6.1.8.
Proposed Chanae: Add a paragraph between the current paragraph 1 and 2, to read:
"As Noted, the channel sensor may be excluded from response time testing. This allowance to not perform specific response time testing of the sensors is applicable when the alternate testing requirements and restrictions of Reference 7 are performed. As stated in Reference 7, analysis has demonstrated that other Technical Specification testing requirements (CHANNEL CALIBRATIONS, CHANNEL CHECKS, CHANNEL FUNCTIONAL TESTS, and LOGIC SYSTEM FUNCTIONAL TESTS) and actions taken in response to NRC Bulletin 90-01 Supplement I are sufficient to identify failure modes or degradation in instrument response times and assure operation of the analyzed instrument loops within acceptable limits.
Reference 7 also identifies that there are no known channel sensor failure modes identified that can be detected by RTT that cannot also be detected by other Technical Specification required surveillances. Therefore, when the requirements, including sensor types, of Reference 7 are complied with, adequate assurance of the response time of the sensors is provided.
This assurance of the response time of the sensors when combined with the response time testing of the remainder of the channel ensures that the individual channel response times are less than or equal to the maximum values assumed in the accident analysis.
If the alternate testing requirements of Rc trence 7 are not complied with then the entire channel will be re.ponse tims tested including the sensors."
(b)3.
Bases Section B 3.3.6.1, Primary Containment and Drywell Isolation Instrumentation Surveillance Requirements, Page B 3.3-17),
References.
Proposed Chance: Add reference 7 to the Bases, to read:
7.
NE00-32291-a, " System Analysis for Elimination of Selected Response Time Testing Requirements," October 1997 1
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. Staff Evaluation: The NEDO-32291 analysis in the staff's SER showed that sensor response times could be eliminated for MSIV closure actuations. The licensee's proposed changes are, therefore, acceptable to eliminate RTT for sensors associated with XSIV closure, but not for other actuations. This change for only MSIVs will ellow the licenses to use manufacturers response time data, and eliminate the requirement for a separate measurement of the sensor response time associated with MSIV closures.
The renainder of the channel will continue to be tested for response time.
This change is consistent with the approved NED0-32291.
(c)l.
Section 3.5.1, ECCS-Operating, Surveillance Requirements, page 3.5-5, Surveillance Requirement 3.5.1.8, ECCS response time.for the high pressure core spray (HPCS) system.
Proposed Chanae: Add a note to the surveillance requirement stating "ECCS actuation instrumentation is excluded."
(c)2 Bases Section B 3.5.1, ECCS-Operating, Page B 3.5-13a, Surve111ence Requirement SR 3.5.1.8.
Proposed Chanae:
Modify the third sentence, which currently reads:
" Specific response time testing of this instrumentation is not required since these actuation channels are only assumed to respond within the diesel generator start time; therefore, sufficient margin exists in the diesel generator 10 second start time when compared to the typical channel response time (milliseconds) so as to assure adequate response without a specific measurement test." The proposed third sentence will read " Specific response time testing of this instrumentation is not required since these actuation channels are only assumed to respond within the diesel generator start time; therefore, sufficient margin exists in the diesel generator 10 second start time when compared to the typical channel response time (milliseconds) so as to assure adequate response without a specific i
measurement test (Ref 16)."
The proposed change is to add
"(Ref 16)" to the third sentence.
(c)3 Bases Section B 3.5.1 ECCS-Operatiig, Page B 3.5-14, References.
Proposed Chanae: Add reference 16, to read:
16.
NEDO-32291-a, " System Analysis for Elimination of Selected Response Time Tes',ing Requirements," October 1997 Staff Evaluation: The proposed note associated with (c)1 above refers only to the HPCS System. Other ECCS systems are not mentioned, and as such, it is i
only the HPCS system where RTT would be eliminated as a result of this TS change request.
This change will allow the licensee to use manufacturers response time data, and eliminate the requirement for a measurement of the l
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For the HPCS ECCS function, the entire channel is exempted from response time testing.
It should be noted that this approval is only for the HPCS system, and any other ECCS systems which may have previously required RTT will still require such cesting. This change is consistent with the approved NEDO-32291.
(d)l.
Section 3.5.2, ECCS-Shutdown, Surveillance Requirements, page 3.5-9, Surveillance Requirement 3.5.2.7, ECCS Response Time for the HPCS System.
Ecoposed Changg: Delete Surveillance Requirement 3.5.2.7.
The requirement currently-reads " Verify the ECCS RESPONSE TIME for the required HPCS System is wit',in limits" and has a frequency of 18 months.
(d)2.
Bases Section B 3.5.2, ECCS-Shutdos...
Pages B 3.5-19 and B 3.5-20, Surveillance Requirement SR 3.5.2.7.
Proposed Chanae: Delete the paragraph on SR 3.5.2.7.
Staff Evaluation:
The licensee stated in their request, that:
"The basis for eliminati n of ECCS - Shutdown High Pressure Core Spray (HPCS) system RTT is that there are no design basis events in MODES 4 and 5 for which the ECCS HPCS system is required to initiate within a specified period of time. ECCS response time testing performed during MODES 1, 2, and 3 is adequate to identify any operability problems with the ECCS HPCS system.1herefore, we
[the licensee] conclude that response time testing specifically for ECCS -
Shutdown can be eliminated."
Because there are no potential design basis events when the plant is shutdown for which the ECCS HPCS system is required to initiate within a specific period of time, the staff concludes that there is no need to perform specific response time tests to verify the initiation time of the HPCS ECCS.
Therefore, this change is appropriate.
It should be noted that this approval is only for the HPCS system, and any other ECCS systems which may have previously required RTT will still require testing. This change is consistent with the approved NED0-32291.
4.0 VERIFICATION OF NEDO-32291 PLANT SPECIFIC CONDITIONS i
The staff stipulated several conditions in the generic SER approving NEDO-32291 which must be met by the individual licensee referencing NED0-32291 before its guidance could be implemented in plant-specific TS change proposals.
From a review of the licensee's submittal, the staff verified that the licensee has met or will meet the applicable conditions as follows:
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. 4.1 fondition: Confirm the applicability of the generic analyses to the plant.
Ucensee's Resoonse: The licensee has confirmed the applicability of NED0-32291-A to Grar.d Gulf. As identified in Appendix A to that report, the licensee was a participating utility in the evaluation.
In addition, the licensee confirmed that the components within the scope of this request have been evaluated in NED0-32291-A. These components are identified in Appendix G (Table G-4) of NEDO-32291-/, and Table 1 of the NRC staff's Safety Evaluation of NEDO-32291. The current components within the scope of this recuest for Grand Gulf tre Rosemount transmitters models 1152 and 1153, and Rosemount trip units model 510D0 and 71000.
Future components would be limited to those listed in the staff-approved NED0-32291. Therefore, the NED0-32291 analyses are a)plicable to Grand Gulf. The staff accepts the licensee's response to t11s condition.
4.2 Condition
The Itcensee's revision request (i.e., proposed 15 amendment) shall be submitted as shown in Appendix I of the BWROG Letter.
Licensee's Resoonse: The licensee stated that the format of the proposed 15 changes are different from that provided in Appendix H (Pages H-15 through H-18) of the staff-approved NED0-32291 since the licensee has adopted TSs written in the improved Standard Technical Specification format. However, the proposed changes meet the intent of those provided in Appendix H of NED0-32291.
In addition, changes to the Grand Gulf TS Bases, which are consistent with the proposed TS changes, have been provided in Attachment 4, The staff accepts the licensee's response to this condition.
4.3 [pndition: The licensee shall state that they are in conformance with the recommendations of EPRI NP-7243 and, therefore, shall perform the following actions:
(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 RTT shall be performed to determine an initial sensor-specific response time value.
Licensee Response:
Thu licensee stated that applicable Grand Gulf procedures and/or the component data base for the affected transmitter / switch will be revised and updated as necessary to address this item upon approval of this request.
For transmitters without variable damping, the licensee also stated that, consistent with EPRI NP-7243, RTT is not required following the replacement of the electronics. The staff agrees with the licensee's statement about transmitters without variable damping and concludes that upon completion of this revision to the procedures and/or component data base the licensee will meet the above condition.
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' (b) for transmitters and switches that use capillary tubes, capillary tube testing shall be performed after initial installation and after any maintenance or modification activity that could damage the capillary tubes.
Licensee Ruponse: The licensee stated Grand Gulf currently does not utilize any transmitters or switches that use capillary tubes in any application that requires response time testing.
Therefore, the staff concludes that this recommendation is not applicable to Grand Gulf.
4.4 Condition
The Licensee must confirm the folicwing:
(a) That calibration is being done with equipment designed to provide a step function or fast ramp in the process variable, Licensee Response:
The licensee ctated that applicable calibration procedures will be revised as necessary to include steps to input a fast ramp or step charge to system components during calibrations to verify that the response of the transmitter to the input change is prompt. The expectation is that a technician will detect a sluggish response before response time exceeds ap3roximately 5 seconds. The licensee stated that after approval of tiese proposed TS changes, the applicable calibration procedures will be revised as necessary prior to the next performance of the procedure or discontinuance of the present res)onse time testing. The staff concludes that upon completion of t1ese procedure revisions the licensee will meet the above condition.
(b) That provisions have been made to ensure that operators and technicians, through an appropriate training program, are aware cf the consequences of instrument response time degradition, and that applicable procedures have been reviewed and revised as necessary to assure that technicians monitor for response time degradation during the performance of calibrations and functional tests, Licensee Respon g: The licensee state that, prior to implementing these proposed TS changes, technicians will be appropriately trained to ensure they are aware of the consequences of instrument response time degradation. Operators routinely monitor plant parameters and implement the site corrective action program if instrumentation does not oerform as expected.
The staff concludes that upon completion of t1e training the licensee will meet the cbove condition.
(c) That surveillance testing procedures have been reviewed and revised if necessary to ensure 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,
' Licensee Response: The licensee stated that surveillance testing procedures currently ensure calibrations are being performed in a manner that allows simultaneous monitoring of both the input and out)ut response of units under test. As stated above for item (b),
tecinicians will verify that the response of the traasmitter to an input change is prompt.
The expectation is that a technician will detect a sluggish response before response time exceeds approximately 5 seconds. The staff concludes that the licensee has met the above condition.
(d) That for any request involving the elimination of RTT for Rosemount pressure transmitters, the licensee is in compliance with the guidelines of Supplement I to Bulletin 90-01, " Loss of Fill-011 in Transmitters Manufactured by Rosemount."
Licensee Response: The licensee's compliance with the guidelines of Supplement I to NRC Bulletin 90-01 was reviewed and documented in a safety evaluation transmitted to the licenses by NRC letter dr.ted February 16,1994 (licensee reference GNRI-94/00041).
The staff concluded in that letter that the licensee's responses to Bulletin 90-01, " Loss of Fill-Oil in Transmitters Manufactured by Rosemount,"
and Bulletin 90-01, Supplement I conformed to the requested actions.
The staff concludes that the licensee has met the above condition.
(e) That for those instruments where the manufacturer recommends periodic RTT as well as calibration to ensure correct functionine.
the licensee has ensured that elimination of RTT is nevertheless acceptable for the particular application involved.
Licensee-Response: The licensee stated that the current components affected by this request ire limited to Rosemount transmitters models 1152 and 1153, and Rosemount trip units models 51000 end 710DU.. The licensee has reviewed the vendor recommendations for these devices and confirmed that they do not contain recommendations for periodic response time testing.
Tne staff concludes that the licensee has met the above condition.
5.0 LICENSEE COMMITMENTS RELIED UPON The licensee has committed, in its letter of May 7,1997, to do the following after the proposed changas to the TSs are approved:
Revise applicable calibration procedures, as necessary, to include steps to input a fast ramp or step change to system components during calibrations to verify that the response of the transmitter to the input change is prompt.
Revise applicable calibration procedures so that technicians monitor for response time degradation during the performance of calibrations.
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. Technicians will be appropriately trained so that they will be aware of the consequences of instrument response time degradation.
The licensee stated that these comitments would be implemented prior to the next performance of the procedure or at the discontinuance of the pres:nt response time testing method.
The staff is relying on these comitments. The licensee stated in its letter of October 6,1997, that these comitments will be included in the changes to the Bases of the TSs for the proposed changes to SRs 3.3.1.1.15, and 3.3.6.1.8.
The RTT for the HPCS is being eliminated in its entirety and these comitments do not need to be added to the Bases of the TSs for SRs 3.5.1.8 and 3.5.2.7.
The Bases for SR 3.5.2.7 is being deleted because SR 3.5.2.7 is being deleted. The new Bases pages are being issued in this amendment.
Because the changes to the Bases of the TSs are controlled by Section 5.5.11 of the Administrative Controls of the TSs, which requires prior staff approval for unreviewed safety questions (USQs) as defined by 10 CFR 50.59, any changes to these commitments will be submitted to staff for prior approval if these changes do not meet the criteria in 10 CFR 50.59. This change process for these commitments being relied upon by the staff is in t.ccordance with 10 CFR 50.59 and is, therefore, acceptable.
6.0 STAFF CONCLUSION Based upon the atove review, the staff concludes that the licensee has implemented the provisions of the generic SER for RTT elimination in accordance with the NRC-approved NEDO-32291. The changes to the Bases of the TSs are correct and are being issued in this amendment.
The change process for the licensee's commitments that the staff is relying upon is in accordance with 10 CFR 50.59 and is acceptable.
Therefore, the staff concludes that the proposed changes to the Grand Gulf TSs for selected instrument RTT elimination are acceptable.
7.0 STATE CONSULTATION
in accordance with the Commission's regulations, the Mississippi State official was notified of the proposed issuance of the amendment. The State official had no comments.
8.0 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 l
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 significant increase in individual or cumulative
-occupational radiation exposure. The Commission has previously issued a proposed finding that the amendment involves no significant ha7ards l
consideration, and there has been no public comment on such finding l
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(62 FR 33122). 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 im)act statement or environmental assessment need be prepared in connection wit 1 the issuance of the amendment.
9.0 CONCLUSION
l The Commission has concluded, based on the considerations discus:ed 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 the amendment will not be inimical to the common defense and security or to the health and safety of the public.
Principal Contributor:
P. Loeser P
Date: November 5, 1997 r....
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