ML20206N360
| ML20206N360 | |
| Person / Time | |
|---|---|
| Site: | North Anna  |
| Issue date: | 05/06/1999 |
| From: | Christian D VIRGINIA POWER (VIRGINIA ELECTRIC & POWER CO.) |
| To: | NRC OFFICE OF INFORMATION RESOURCES MANAGEMENT (IRM) |
| Shared Package | |
| ML20206N365 | List: |
| References | |
| 99-261, NUDOCS 9905170205 | |
| Download: ML20206N360 (29) | |
Text
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Vinuixir Ei,ECTRIC ann Powen CONWANY j
Riemump, huisia 23nt May 6, 1999 U.S. Nuclear Regulatory Commission Serial No.99-261 Attention: Document Control Desk NL&OS/ETS R0 Washington, D.C. 20555 Docket Nos.
50-338 50-339 License Nos. NPF-4 NPF-7 Gentlemen:
VIRG'NIA ELECTRIC AND POWER COMPANY NORTH ANNA POWER STATION UNITS 1 AND 2
' PROPOSED TECHNICAL SPECIFICATION CHANGE REVISED SURVElLLANCE FREQUENCY AND ACTION TIMES REACTOR TRIP AND ENGINEERED SAFETY FEATURES ACTUATION SYSTEMS Pursuant to 10 CFR 50.90, Virginia Electric and Power Company requests amendments, in the form of changes to the Technical Specifications for Facility 1
Operating License Numbers NPF-4 and NPF-7 for North Anna Power Station Units 1 and 2, respectively. The proposed changes will revise the surveillance frequency for the Reactor Trip System (RTS) and Engineered Safety Features Actuation System (ESFAS) analog instrumentation channels. In addition, the allowed outage time and action times for the RTS and ESFAS analog instrumentation channels and the j
actuation logic' are being modified.
A discussion of the proposed Technical Specifications changes is provided in Attachment 1.
The proposed Technical Specifications changes have been reviewed and approved by the Station Nuclear Safety and Operating Committee and the Management Safety Review Committee. Based on the increase in core damage frequency, it has been determined that the proposed Technical Specifications changes do involve an unreviewed safety question as defined in 10 CFR 50.59 but do not involve a significant hazards consideration as defined in 10 CFR 50.92. Although these changes increase the core damage frequency by about three percent, the NRC has generally found this increase to be acceptable as documented in their Safety Evaluation Report dated July 15,1998, for WCAP-14333-NP, "Probabilistic Risk Analysis of the RTS and ESFAS Test Times and Completion Times."
The' proposed Technical Specifications changes are provided as a mark-up in and as a typed version in Attachment 3. The basis for our determination that the changes do not involve a significant hazards consideration is provided in.
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Due to the number of program and procedure changes necessary to implement these changes, we request ninety days from the issuance date of the amendments to implement the Technical Specifications changes. If you have any further questions, please contact us.
Very truly yours, q
D. A. Christian Vice President-Nuclear Operations Attachments 1.
Discussion of Changes 2.
Mark-up of Technical Specifications Changes 3.
Proposed Technical Specifications Changes 4.
Significant Hazards Consideration Determination Commitments made in this letter:
1.
North Anna's existing programs and procedures will be revised to require evaluation of failures of analog instrumentation channels for plausible common cause prior to implementing the proposed Technical Specifications.
cc:
U.S. Nuclear Regulatory Commission Region II Atlanta Federal Center 61 Forsyth Street, SW Suite 23T85 Atlanta, Georgia 30303 Mr. M. J. Morgan NRC Senior Resident inspector North Anna Power Station Commissioner Department of Radiological Health Room 104A 1500 East Main Street Richmond,VA 23219 Mr. J. A. Reasor Old Dominion Electric cooperative innsbrook Corporate center 4210 Dominion Blvd.
Glen Allen, Virginia 23260
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COMMONWEALTH OF VIRGINIA
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COUNTY OF HENRICO
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The foregoing document was acknowledged before me, in and for the County and Commonwealth aforesaid, today by D. A. Christian, who is Vice President -
Nuclear Operations, of Virginia Electric and Power Company. He has affirmed before me that he is duly authorized to execute and file the foregoing document in behalf of that Company, and that the statements in the document are true to the best of his knowledge and belief.
'Ib-Acknowledged before me this day of MOLI
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My Commission Expires: March 31,2000.
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l Discussion of Change l
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l Virginia Electric and Power Company North Anna Power Station Units 1 and ?
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Discussion of Change Introduction In the early 1980s, in response to growing concerns of the impact of current testing and maintenance requirements on plant operation, particularly as related to instrumentation systems, the Westinghouse Owners Group (WOG) initiated a program to develop a justification to be used to revise generic and plant specific instrumentation Technical Specifications.
Operating plants experienced many inadvertent reactor trips and engineered safety features actuations during performance of instrumentation surveillance, causing unnecessary transients and challenges to safety systems.
Significant time and effort on the part of the operating staff was devoted to performing, reviewing, documenting and tracking the various surveillance activities, which in many instances seemed unwarranted based on the high reliability of the equipment.
Significant benefits for operating plants appeared to be achievable through revision of instrumentation test and maintenance requirements. The results of these initial studies and the recommended changes to the testing of Reactor Trip System (RTS) and Engineered Safety Features Actuation System (ESFAS) instrumentation are documented in WCAP-10271, Supplement 1, " Evaluation of Surveillance Frequencies and Out of Service Times for the Reactor Protection Instrumentation System" and WCAP-10271, Supplement 2, " Evaluation of Surveillance Frequencies and Out of Service Times for the Engineered Safety Features Actuation System."
The NRC completed an evaluation of surveillance testing at power, which indicated that testing in many areas can be reduced without any significant decrease in safety. These i
findings and recommendations are documented in NUREG-1366, " Improvement to Technical Specifications Surveillance Requirements," and Generic Letter 93-05, "Line-Item Technical Specifications improvements to Reduce Surveillance Requirements for Testing During Power Operation." Reduced surveillance testing of the RTS and ESFAS analog instrumentation was recommended. Recently, the NRC has completed a review of the Westinghouse Owners Group Topical Report WCAP-14333P, "Probabilistic Risk Analysis of the RPS and ESFAS Test Times and Completion Times." The NRC approved additional time for testing and extended allowed outage time for the RTS and ESFAS on July 15,1998.
Consistent with WCAP 10271 - Supplements 1 and 2, WCAP-14333P and the associated NRC Safety Evaluations, North Anna is proposing changes to the surveillance frequencies, allowed outage times, completion times and action statements for the RTS and ESFAS analog instrumentation and actuation logic. These proposed changes in the allowed outage times, completion times, action statements, and surveillance frequency provide additional time to perform testing and maintenance as well as reduce the number of high-risk surveillances performed at power.
In WCAP-10271 and its supplements, the WOG evaluated the impact of the proposed surveillance test interval and allowed outage times and changes on core damage frequency and public risk. The NRC staff concluded in its evaluation of the WOG evaluation that an overall upper bound increase of the core damage frequency due to the propose surveillance test intervals and allowed outage times changes is less than 6 Page 1 of 25
percent for Westinghouse Pressurized Water Reactor plants. The NRC Staff also concluded that actual core damage frequency increases for individual plants are expected to be substantially less than 6 percent. The NRC Staff considered this core damage frequency increase to be small compared to the range of uncertainty in the core damage frequency analyses and therefore acceptable.
For the additional relaxations in WCAP-14333, the WOG evaluated the impact of the additional relaxation of allowed outage times and completion times, and action statements on core damage frequency. The change in core damage frequency is 3.1 percent for those plants with two out of three logic schemes that have not implemented the proposed surveillance test interval, allowed outage times, and completion times evaluated in WCAP-10271 and its supplements. This analysis calculates a significantly lower increase in core damage frequency than the WCAP-10271 analysis calculated.
This can be attributed to more realistic maintenance intervals used in the current analysis and crediting the AMSAC system as an alternative method of initiating the auxiliary feedwater pumps.
The NRC performed an independent evaluation of the impact on core damage frequency (CDF) and large early release fraction (LERF). The results of the staff's review indicate that the increase in core damage frequency is small (approximately 3.2%) and the large early release fraction would increase by only 4 percent for 2 out of 3 logic schemes that have not implemented the proposed surveillance test interval, allowed outage times, and completion times evaluated in WCAP-10271 and its supplements.
Background
WCAP-10271 and its supplements document the justification for plant specific
. Technical Specifications changes.
The justification consists of a risk-informed evaluation of the effects of particular Technical Specification changes with consideration given to such things as safety, equipment requirements, human factors, and operational impact. The objective was to reach a balance in which safety and operability are ensured. The proposed Technical Specification revisions provide for increased test and maintenance times, less frequent surveillance, and testing in bypass for the RTS and ESFAS analog instrumentation channels, logic trains and permissives.
The NRC determined that the requirement to routinely verify permissive status is a different consideration than the availability of trip or actuation channels which are required to change state on the occurrence of an event and for which the function availability is more dependent on the surveillance insal.
In February 1985 the NRC issued the SER (letter to J. J. Sheppard from Cecil O.
Thomas dated February 21,1985, Reference 6) for WCAP-10271 and Supplement 1.
This SER approved quarterly testing, six hours to place a failed channel in a tripped mode, increased Allowed Outage Times (AOT) for test and maintenance, and testing in bypass for analog channels of the Reactor Trip System (RTS). The quarterly testing had to be conducted on a staggered basis.
Page 2 of 25
On March 20,1986 the WOG submitted WCAP-10271, Supplement 2 " Evaluation of Surveillance Frequencies and Out of Service Times for the Engineered Safety Systems Actuation System." On May 12,1987 the WOG submitted WCAP-10271, Supplement 2, Revision 1, (References 7 and 8). Supplement 2 and Supplement 2, Revision 1 specifically demonstrated the applicability of the justification contained in WCAP-10271 to the ESFAS for two, three and four loop plants with either relay or solid state systems.
In February 1989 the NRC issued the SER (Letter to Roger A. Newton from Charles E.
Rossi dated February 22,1989, Reference 11) for WCAP-10271 Supplement 2 and Supplement 2, Revision 1. The SER approved quarterly testing, six hours to place a failed channel in a tripped mode, increased allowed outage times for test and maintenance, and testing in bypass for analog channels of the ESFAS. The ESFAS functions approved in the SER were those presented in Appendix A1 of the referenced WCAPs.
These functions are included in the Westinghouse Standard Technical Specifications. Staggered testing was not required for ESFAS analog channels and the requirement was removed from the RTS analog channels.
In their letter dated April 30,1990 (Reference 12), the NRC issued the Supplemental SER (SSER) for WCAP-10271 Supplement 2 and Supplement 2, Revision 1.
The SSER approved the surveillance test interval (STI) and allowed outage time (AOT) extensions for the ESFAS functions that were included in Appendix A2 of WCAP-10271, Supplement 2, Revision 1. The functions approved are associated with the Safety injection, Steam Line Isolation, Main Feedwater Isolation, and Auxiliary Feedwater Pump Start signals. The configurations contained in the Appendix A2 are those that are not contained in the Westinghouse Standard Technical Specifications.
The SSER also approved the extended AOTs for the Reactor Trip System actuation logic that were requested in WCAP-10271, Supplement 2, Revision 1, Appendix D.
The NRC has recently completed a review of the Westinghouse Owners Group Topical Report WCAP-14333P, "Probabilistic Risk Analysis of tne RPS and ESFAS Test Times and Completion Times," (Reference 14). Additional time for testing and extended allowed outage time for the RTS and ESFAS were approved by the NRC on July 15, 1998 (Reference 16).
Current Licensing Basis i
The current surveillance intervals for RTS and ESFAS instrumentation, including analog channels, actuation logic and actuation relays, are monthly. The permissives are not currently required to be tested between the refueling calibrations. The allowed outage times, completion times, and action statements are consistent with NUREG-0452, Standard Technical Specifications for Westinghouse Pressurized Water Reactors.
Current Design Basis The RTS provides the means for controlling the reactor in response to various measured primary and secondary variables associated with power, temperature, pressure, level, flow, and the availability of electric power.
If the combination of Page 3 of 25
monitored variables indicates an approach to unsafe conditions, the RTS will initiate the appropriate protective action, e.g., load runback, prevention of rod withdrawal, or reactor trip (opening the reactor trip breakers).
The RTS and ESFAS are designed in accordance with IEEE-279 " Standard, Nuclear Power Plant Trip Systems," August 1968. The RTS is designed so that the most probable modes of failure in each channel result in a partial or full reactor trip signal.
The RTS design combines redundant sensors and channel independence with coincident trip philosophy so that a safe and reliable system is provided in which a single failure will not defeat the channel function, cause a spurious trip, or violate reactor protection criteria.
RTS channels are designed with sufficient redundancy for individual channel calibration and testing to be performed during power operation without degrading reactor protection. Specific testing exceptions are provided to not require testing of backup channels, such as reactor coolant pump breakers. Testing will not cause a trip unless a trip condition exists concurrently in another channel. During such operation the active parts of the system continue to meet the single-failure criterion, since the channel under test is either tripped or makes use of superimposed test signals that do not negate the process signal. "One-out-of-two" systems are permitted to violate the single-failure criterion during channel bypass provided that acceptable reliability of operation can be demonstrated and the bypass time interval is short.
Discussion of Change The Nuclear Regulatory Commission approved four specific changes for the RTS and ESFAS Analog Channels evaluated in WCAP-10271 Supplements 1 and 2.
The analog channel functional test frequency may be reduced from monthly to quarterly. Surveillance testing of most permissives may be extended to a refueling interval.
4 The time allowed for a channel to be inoperable or out of service in an untripped condition may be changed from one hour to six hours. (WCAP-14333 further justified up to 72 hours8.333333e-4 days <br />0.02 hours <br />1.190476e-4 weeks <br />2.7396e-5 months <br />.)
The time a channel in a functional group may be bypassed to perform testing may be increased from two to four hours. This bypass time applies to either an inoperable channel when tested in the tripped mode or to the channel in test when tested in the bypass mode. (WCAP-14333 further justified up to 12 hours1.388889e-4 days <br />0.00333 hours <br />1.984127e-5 weeks <br />4.566e-6 months <br /> for bypassing a channel for surveillance testing.)
Only if hardware is installed, routine channel testing may be performed in the bypassed condition instead of the tripped condition.
In order to implement the changes the NRC imposed five conditions on utilities seeking to implement the technical specification changes approved generically as a result of Page 4 of 25
their review of WCAP-10271 and WCAP-10271 Supplement 1, and two conditions as a result of their review of WCAP-10271 Supplement 2 and Supplement 2, Revision 1.
Two of the conditions imposed in the RTS SER are no longer applicable due to approvals given in the ESFAS SER.
The first condition in the RTS SER requires the use of a staggered test plan for the RTS channels changed to the quarterly test frequency.
In the ESFAS SER, this requirement was not required for ESF channels. Thus, the NRC removed the staggered testing requirement for the RTS channels.
The second condition in the RTS SER requires that plant procedures address a common cause evaluation for failure in the RTS analog channels on a quarterly test frequency. Additional testing for plausible common cause failures for the RTS channel are required by the NRC in the safety evaluation for WCAP-10271.
From a practical standpoint, there are several types of failures that the NRC staff does not regard as common cause failures. Failures such as instrument drift and 1
power supply failures to a single channel are not considered common cause failures. Additional testing is not necessary for these failures or other failures if the cause of those other failures can be evaluated and shown not to affect multiple channels.
Other failures of the type that are " announced" through control room alarms or annunciation or through other readily observed means need not be considered to be plausible common cause problems and do not require additional testing.
Plausible common cause problems should be identified only where failure can be shown to be attributable to processes, which are common to redundant equipment. That is, the underlying failure mechanism must be shown to have had the potential for causing failures in redundant channels. The failure may also be considered a plausible common cause problem if the failure was
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attributed to an improper test method that damaged components and that damage can only be found by subsequent testing. In this case a review of the test records may indicate other channels subjected to the improper test method that warrant addMonal testing.
North Anna's existing programs and procedures will be revised to evaluate plausible common cause failures prior to implementing the proposed Technical Specifications. Plant procedures will require that appropriate remedial action be taken, such as additional testing of the other channels in that function if a common cause failure is determined.
Plausible common cause failures are identified only where failure can be shown to be attributable to the processes which are common to redundant equipment.
The root cause mechanism must be shown to have the potential for causing failures in redundant channels. Failures that are not considered as common cause failures include but are not limited to the following:
Page 5 of 25
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Instrument drift, normal drift correctable by calibration.
Loss of power to single channel.
Simple transistor / component failures that have no distinguishing characteristics may be considered random failures.
Failures that are announced through control room alarms or through other readily observed means.
Failures that may be considered as plausible common cause failures are limited to the following:
Failures cased by improper test method that damages components during the testing process.
Test equipment out-of-calibration and/or tolerance used to calibrate redundant equipment.
- Incorrect steps in procedures used to calibrate redundant modules.
Incorrect engineering calculations and/or setpoints used to calibrate redundant modules.
Incorrect part installed in similar loops during module repair.
- Design changes resulting in change of component function.
Manufacturing changes resulting in changes in module performance.
The third condition in the RTS SER requires installed hardware capability for testing in the bypass mode, as stated in the NRC in the safety evaluation for WCAP-10271:
" Testing of the RTS analog channels in the bypassed cond; tion by use of l
temporary jumpers or by lifting leads is not acceptable. The chance of personnel errors leaving a number of channels in the bypassed condition would be too large for the routine use of such methods. Therefore, licensees choosing this option to perform routine channel testing in the bypass mode should ensure that the plant design allows testing in bypass without lifting leads or installing temporary jumpers. "
j North Anna does not have the hardware capability to perform bypass testing of each RTS and ESFAS instrument channel. With the exception of the power range nuclear instrumentation channels, only those instrument channels that have hardware installed to permit testing in bypass without lifting leads or installing jumpers will be routinely tested in bypass (i.e., source and intermediate range, and containment pressure).
In order to perform the zero current adjustment during the routine surveillance of the power range channels the power / signal cable must be removed, which is effectively a bypass operation.
However, the reinstallation of this cable is easily recognizable by both the technicians performing the surveillance and the operations staff with the reactor at power.
In addition, removal and reinstallation of the cable are strictly controlled by procedure. Routine analog channel testing, with an inoperable Page 6 of 25 l
channel, will be completed in the trip condition with the inoperable channel in bypass as limited by the Technical Specification.
The fourth condition in the RTS SER involves channels that provide input to both the RTS and the ESFAS, as stated by NRC in the safety evaluation for WCAP-10271:
Now that the ESFAS SER has been issued and all of the relaxations for the l
RTS analog channels are applicable to the ESFAS analog channels, this condition does not apply.
The fifth condition in the RTS SER, and second in the ESFAS SER, addresses setpoint drift. As stated by NRC in the safety evaluation for WCAP-10271:
"The bistable equipment is inherently stable and should show good performance. In many cases, channels are not recalibrated for many months. A review of the 'as found' and 'as left' data over a twelve-month period should provide sufficient information to address the adequacy of the existing setpoints and allowable values."
A review of the RTS and ESFAS instrument loops was completed. In every case the review established at a 95% confidence level, that each instrument loop was found to exhibit drift well below the assumed value of 1 percent per month as well as per quarter. Permissive drifts were verified to be less than 1% over eighteen months. In addition, the review evaluated the impact of drift on control parameters and confirmed that the instrument drift remains acceptable for plant control systems.
This condition in the ESFAS SER requires that the plant specific applications must confirm the applicability of the generic analyses to the plant.
The RTS and ESFAS trip functions and the associated logic schemes evaluated in WCAP-10271, Supplements 1 and 2 are representative of the three loop protective functions and logic schemes at North Anna.
Subsequently, the Nuclear Regulatory Commission approved WCAP-14333, which justified additional allowed outage times and bypass time changes for the RTS and ESFAS.
Increase the test bypass time and allowed outage time for both the solid state protection system and relay protection system RTS and ESFAS designs.
For analog channels, increase the allowed outage time from 6 hours6.944444e-5 days <br />0.00167 hours <br />9.920635e-6 weeks <br />2.283e-6 months <br /> to 72 hours8.333333e-4 days <br />0.02 hours <br />1.190476e-4 weeks <br />2.7396e-5 months <br />, and the test bypass time from 4 to 12 hours1.388889e-4 days <br />0.00333 hours <br />1.984127e-5 weeks <br />4.566e-6 months <br />.
For logic cabinets, master and slave relays, increase the allowed outage times from 6 to '24 hours2.777778e-4 days <br />0.00667 hours <br />3.968254e-5 weeks <br />9.132e-6 months <br />.
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In order to implement the extended test times and allowed outage times the staff has imposed two conditions on each licensee.
The first condition was to confirm the applicability of the WCAP-14333P, analyses for their plants.
Tables 1,2, and 3, attached, establish the applicability of North Anna RTS and ESFAS to the WCAP-14333 analysis.
The second condition was to address the Tier 2 and 3 analyses including the configuration risk management program (CRMP) insights which confirm that these insights are incorporated into their decision making process before taking equipment out of service.
We have incorporated a Configuration Risk Management Program (CRMP) into the Technical Specification to support a risk-informed extended emergency diesel generator allowed outage time.
The attributes of our CRMP are discussed in our letter to the NRC, dated March 25,1998 (Serial No.98-071).
The CRMP was incorporated into the North Anna Technical Specifications on August 26,1998, in amendments 214 and 195 for Units 1 and 2, respectively.
Consistent with the Safety Evaluation Report for WCAP-14333, Virginia Power i
has examined the impact of outages of the analog instruments and the RTS and ESFAS logic trains in order to identify potential limitations of concurrent equipment outages. When compared to the base case with all risk significant equipment available, there were no significant increases in component importance due to the unavailability of any of the channels or trains identified above. As a result, there is no need for special restrictions to avoid risk significant configurations.
Instantaneous risk is already evaluated and controlled by the Virginia Power CRMP. Planned configurations of high risk are avoided; in the case of emergent work, high-risk windows are avoided or minimized.
The impact on the Probabilistic Risk Assessment due to an increase in the RTS and ESFAS surveillance interval from monthly to quarterly is considered minor.
The evaluation used the North Anna PRA model to establish an overall change in the CDF of approximately one percent.
Specific Changes The following changes are being made to implement the extended AOTs, Action Statements, and quarterly testing of the RTS and ESFAS, including numerous editorial changes (e.g., capitalization, item descriptions, acronyms, tense, etc.) to provide consistent wording in the Unit 1 and Unit 2 Specifications:
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Changes to TS Page 3/4 3-1 Include " risk informed" notation on TS 3.3.1.1 to indicate changes in required actions and allowed outage times are supported by risk insights.
Modify Surveillance Requirement (SR) 4.3.1.1.1 to include the RTS interlocks and automatic trip logic. Eliminate the discussion of surveillance requirements (e.g., channel check, calibration etc.) and establish reference to Table 4.3-1 for surveillance requirements.
Delete existing SR 4.3.1.1.2 for the interlocks as redundant. These surveillance requirements are incorporated into Table 4.3-1, Functional Unit 23. Therefore, SR 4.3.1.1.3 is being renumbered as 4.3.1.1.2.
Changes to Tables 3.3-1, Reactor Trip System Instrumentation Revise Actions 2, 7, 8, and 9 to increase the time that an inoperable analog instrument channel may be maintained in an untripped condition from 1 hour1.157407e-5 days <br />2.777778e-4 hours <br />1.653439e-6 weeks <br />3.805e-7 months <br /> to 72 hours8.333333e-4 days <br />0.02 hours <br />1.190476e-4 weeks <br />2.7396e-5 months <br /> consistent with the WCAPs and NRC SERs.
Revise Action 16 to increase the time that the logic cabinets, master, or slave relays may be inoperable from 2 hours2.314815e-5 days <br />5.555556e-4 hours <br />3.306878e-6 weeks <br />7.61e-7 months <br /> to 24 hours2.777778e-4 days <br />0.00667 hours <br />3.968254e-5 weeks <br />9.132e-6 months <br /> consistent with the WCAPs and NRC SERs.
Revise Actions 2,7, and 8 to increase the time that an inoperable channel may be bypassed to allow testing from 2 hours2.314815e-5 days <br />5.555556e-4 hours <br />3.306878e-6 weeks <br />7.61e-7 months <br /> to 12 hours1.388889e-4 days <br />0.00333 hours <br />1.984127e-5 weeks <br />4.566e-6 months <br /> consistent with the WCAPs and NRC SERs.
Modify Functional Unit 1, " Manual Reactor Trip," to provide a separate ACTION for Modes 3,4, and 5 with the reactor trip breakers closed consistent with the STS NUREG-1431, Rev.1.
Delete the operability requirements for Functional Units 7, "Overtemperature AT,"
and 8, " Overpressure AT," with less than three loops in operation. Alsro, delete the associated ACTION 9 and the current Notation "**". Units 1 and 2 are not licensed for operation with less than three RCS loops in operation. The Notation
- will be reused to define the mode applicability for interlock / permissive P-6.
Revise the required actions for Functional Units 9,11,12,16,17 and 20 ("at-power" trips) to only require a power reduction to less than the P-7 setpoint consistent with Standard Technical Specifications for Westinghouse Pressurized Water Reactors (STS) NUREG-1431, Rev.1. The accident analysis does not assume operability of these "at power trips" below 10% power.
Combine Functional Unit 13, " Loss of Flow - Two Loops (Above P-8)," and Functional Unit 12, " Loss of Flow - Single Loop (above P-7 and below P-8)" into Page 9 of 25
" Loss of Flow (Above P-7)." The risk analysis performed in WCAPs 10271 and 14333 did not account for the additional allowed outage time if the inoperable channel was discovered above P-8 and the channel could not be placed in tripped condition. At this point, the Unit would be required to be placed in a condition where the channel operability was not required (i.e., power below P-8).
Now, Functional Unit 13 becomes applicable (i.e., power < P-8 but > P-7), and these additional hours (6 or 72) provided to place the channel in trip prior to placing the unit in a condition where the channel operability requirement did not apply (i.e., below P-7) would invalidate the risk analysis performed for WCAPs 10271 and 14333. The new functional unit will use ACTION 8 which will allow 72 hours8.333333e-4 days <br />0.02 hours <br />1.190476e-4 weeks <br />2.7396e-5 months <br /> to place the channel in trip and if not accomplished in that time reduce power to less than P-7 consistent with STS (NUREG-1431, Rev.1).
Revise functional unit 18B, " Turbine Stop Valve Closure," Minimum Channels Operable requirement from 4 to 3 consistent with STS (NUREG-1431, Rev.1).
This will permit continued operation with a channel inoperable and in trip without causing a verbatim cornpliance issue with the Minimum Channel Operable requirement.
Revise the required action for Functional Units 19, " Safety injection input from ESF," and 22, " Automatic Trip Logic," consistent with WCAP-10271, and the associated NRC SERs. This will provide an additional 18 hours2.083333e-4 days <br />0.005 hours <br />2.97619e-5 weeks <br />6.849e-6 months <br /> to restore operability before requiring a unit shutdown.
Revise Functional Unit 20, " Reactor Coolant Pump Breaker Position Trip," similar to the changes to Functional Units 12 and 13. The new required actions are consistent with STS (NUREG-1431, Rev.1)
Establish Functional Unit 23, " Reactor Trip System Interlocks," and the e
accompanying ACTION 17. This Functional Unit and the required actions are consistent with STS (NUREG-1431, Rev.1).
Modify ACTION 1 to permit a reactor trip breaker to be bypassed for up to 4 e
hours for concurrent surveillance testing of the automatic trip logic and the reactor trip breaker consistent with WCAP-14333.
Modify ACTION 2 to provide additional time to reset the neutron flux trip setpoint consistent with the additional 72 hours8.333333e-4 days <br />0.02 hours <br />1.190476e-4 weeks <br />2.7396e-5 months <br /> provided to place a channel in trip and STS (NUREG-1431, Rev.1)
Modify ACTION 7 to permit STARTUP and POWER OPERATION with an e
inoperable channel beyond the next scheduled surveillance test.
To accommodate operation beyond the next surveillance test with an inoperable channel, ACTION 7 is modified to include bypassing of an inoperable channel for up to 12 hours1.388889e-4 days <br />0.00333 hours <br />1.984127e-5 weeks <br />4.566e-6 months <br /> to permit surveillance testing of another channel. Also,72 hours8.333333e-4 days <br />0.02 hours <br />1.190476e-4 weeks <br />2.7396e-5 months <br /> is provided to place an inoperable channel in the tripped condition. (Functional Units - 8,10,14,15)
Page 10 of 25
Establish ACTION 8 to permit STARTUP and POWER OPERATION with an e
inoperable channel beyond the next scheduled surveillance test.
To accommodate operation beyond the next surveillance test with an inoperable channel, ACTION 8 is modified to include bypassing of an inoperable channel for up to 12 hours1.388889e-4 days <br />0.00333 hours <br />1.984127e-5 weeks <br />4.566e-6 months <br /> to permit surveillance testing of another channel. Also,72 hours8.333333e-4 days <br />0.02 hours <br />1.190476e-4 weeks <br />2.7396e-5 months <br /> is provided to place an inoperable channel in the tripped condition. However, if the channel cannot be placed 'in the tripped condition power is only required to be reduced to less than the P-7 permissive setpoint for the "at-power" trips consistent with Standard Technical Specifications, NUREG-1431, Rev.1.
(Functional Units 9,11,12,16,17, and 20)
Delete existing ACTION 9 since plant operation with less than three reactor e
coolant loops in operation is prohibited during STARTUP and POWER OPERATION.
Establish new ACTION 9 for Functional Unit 18 A, " Low Auto Stop Oil Pressure" and 18B " Turbine Stop Valve Closure." The new action will permit STARTUP and POWER OPERATION to proceed with less than the Total Number of Channels operable, if the inoperable channel (s) is placed in trip within 72 hours8.333333e-4 days <br />0.02 hours <br />1.190476e-4 weeks <br />2.7396e-5 months <br />.
If the channel cannot be placed in the tripped condition power is only required to be reduced below the P-8 permissive setpoint consistent with the accident analysis assumptions and STS (NUREG-1431, Rev.1).
Delete ACTION 10 since Functional Unit 20, " Reactor Coolant Pump Breaker Position Trip," has been revised and the required actions are no longer applicable.
Establish ACTION 16 to allow 24 hours2.777778e-4 days <br />0.00667 hours <br />3.968254e-5 weeks <br />9.132e-6 months <br /> to restore an inoperable channel / train to operable status before requiring the unit to be placed in HOT STANDBY within the next 6 hours6.944444e-5 days <br />0.00167 hours <br />9.920635e-6 weeks <br />2.283e-6 months <br />.
Also allow bypass of a channel for up to 4 hours4.62963e-5 days <br />0.00111 hours <br />6.613757e-6 weeks <br />1.522e-6 months <br /> for surveillance testing, provided the other channel is OPERABLE. ACTION 16 is applicable to Functional Unit 19, " Safety injection input from ESF," and Functional Unit 22, " Automatic Trip Logic," rather than existing ACTION 1.
Establish ACTION 17 for Functional Unit 23, " Reactor Trip System Interlocks."
These required actions include verifying that the interlock is in the required state for the plant conditions or shutting down the unit consistent with STS (NUREG-1431, Rev.1)
Changes to Table 4.3-1, Reactor Trip System Instrument Surveillance Requirements Revise Functional Units 2 through 15 to increase the surveillance intervals for e
Reactor Trip System analog channel functional tests from once per month to once per quarter consistent with the WCAPs and NRC SERs.
i i
Page 11 of 25
\\
Separate Functional Unit 2, " Power Range-Neutron Flux," into High and Low Setpoint Functional Units to clarify the surveillance requirements and Mode applicability. Note 6 is also added to permit exclusion of neutron detectors from the surveillance requirement. Also, incorporate appropriate notation consistent J
with STS (NUREG-1431, Rev.1).
Modify Functional Unit 6, " Source Range-Neutron Flux," channel check requirement for Unit 1 from N.A. (not applicable) to S (once per shift) consistent with Unit 2. Delete Mode applicability "*, Reactor Trip Breakers Closed," from the Modes the surveillance is required to be performed is consistent with Unit 1. The Mode Applicability 2, 3,4, and 5 is adequate to ensure that the source range instruments are tested to ensure operability when relied upon for protection and indication.
Mode 6 operability and surveillance requirements are covered in Refueling Operations Technical Specifications.
Combine Functional Unit 13, " Loss of Flow - Two Loops (Above P-8)," with Functional Unit 12, " Loss of Flow - Single Loop (above P-7 and below P-8)" into Functional Unit 12 " Loss of Flow" to establish consistency with the Functional Units in Table 3.3-1. Functional Unit 13 is being deleted.
However, the surveillance requirement is not changing the Loss of Flow trip functions will continue to be tested for power operation above P-7 and P-8.
Establish New Functiona! Unit 23, " Reactor Trip System Interlocks," to delineate the surveillance requirements for the interlocks. The surveillance frequency for the channel functional test frequency and notations for each of the five interlocks are consistent with WCAP-10271 and the NRC SERs and STS.
Delete the "**" notation for Functional Unit 19, " Safety injection Input From ESF,"
from Unit 2 only. This note was only applicable for Cycle 9 operation.
Modify Note 1 from "if not performed in the previous 7 days" to "if not performed in the previous 31 days" consistent with WCAP-10271 and NRC SERs.
Establish a new Note 7 to define the Mode Applicability for the surveillance requirements of Functional Unit 23a for Unit 1 to be consistent with Unit 2.
~
Renumber existing Notes 7 through 12 as 8 through 13 for Unit 1 only. The renumbering affects Functional Units 1,5,6, and 21.
Modify renumbered Note 12 to require verification that permissive P-6 and P-10 are in the required state for plant conditions during the quarterly surveillance test instead of monthly for the source and intermediate range channels. (Functional Units 5 and 6)
Changes to TS Page 3/4 3-15 include " risk informed" notation on TS 3.3.2.1 to indicate changes in required e
actions and allowed outage times are supported by risk insights.
Page 12 of 25
Modify Surveillance Requirement (SR) 4.3.2.1.1 to include the ESFAS interlocks and automatic trip logic. Eliminate the discussion of surveillance requirements (e.g., channel check, calibration etc.) and establish reference to Table 4.3-1 for surveillance requirements.
Delete existing SR 4.3.2.1.2 for the interlock. These surveillance requirements are incorporated into Table 4.3-1, Functional Unit 8. Therefore, SR 4.3.2.1.3 is being renumbered as 4.3.2.1.2.
Changes to Table 3.3-3, Engineered Safety Features Actuation System Instrumentation Revise ACTIONS 14,16, and 19 to increase the time that an inoperable ESFAS analog channel may be maintained in an untripped condition to 72 hours8.333333e-4 days <br />0.02 hours <br />1.190476e-4 weeks <br />2.7396e-5 months <br /> consistent with the WCAPs and NRC SERs.
Revise ACTIONS 13 and 20 to provide 24 hours2.777778e-4 days <br />0.00667 hours <br />3.968254e-5 weeks <br />9.132e-6 months <br /> to repair an inoperable logic cabinet, master, or slave relays prior to requiring shutdown consistent with the WCAPS and NRC SERs.
Revise ACTIONS 16 and 19 to increase the time that an inoperable ESFAS channel may be bypassed to allow testing of another channel in the same function from 2 hours2.314815e-5 days <br />5.555556e-4 hours <br />3.306878e-6 weeks <br />7.61e-7 months <br /> to 12 hours1.388889e-4 days <br />0.00333 hours <br />1.984127e-5 weeks <br />4.566e-6 months <br />. Revise ACTION 12 to establish a 12-hour limit for bypassing an inoperable channel for testing of another channel in the same function. Both these changes are consistent with the WCAPs and NRC SERs Revise ACTIONS 13 and 20 to increase the time that an inoperable ESFAS e
channel / train may be bypassed to allow testing of another channel in the same function from 2 hours2.314815e-5 days <br />5.555556e-4 hours <br />3.306878e-6 weeks <br />7.61e-7 months <br /> to 4 hours4.62963e-5 days <br />0.00111 hours <br />6.613757e-6 weeks <br />1.522e-6 months <br /> consistent with the WCAPS and NRC SERs.
Deleted the Note "# #" associated with the applicability for Functional Unit 1.e,
" Steam Line Differential Pressure - Safety injection," since the protection cannot be blocked without modifying the circuitry.
Delete the Mode 4 Applicability for Functional Unit 1.c, " Containment Pressure-High," consistent with the Mode Applicability requirement for Containment Pressure throughout Table 3.3-1 and the STS (NUREG-1431, Rev.1).
Delete the Functional Units 1.e,1.f, and 4.d operability requirements with less than three loops in operation and delete the associated Action 15 and Note # #
The functional units, required actions, and note are not necessary since operation with less than three RCS loops in operation in MODES 1 and 2 is not permitted. Revise the Unit 1 " Channels to Trip" for Functional Units 1.f and 4.d consistent with the Unit 2 wording (editorial).
Page 13 of 25
Include an "*" for ACTION 16 associated with Functional Unit 2.c, Containment Pressure High-High. This will provide a '.~5 3.0.4 exclusion which will permit mode changes with a channel blocked consistent with the STS (NUREG-1431, Rev.1).
Eliminate Mode 4 from the Applicable MODES for Functional Units 4.a, " Steam Line Isolation - Manual," and 4.b, " Steam Line Isolation - Automatic Actuation Logic," consistent with the MODE Applicability requirements for the Main Steam isolation Valves (TS 4/3.7.1.5), the accident analysis, and STS (NUREG-1431, Rev.1). Consistent with eliminating Mode 4 Applicability (and the Unit 2 required action), the required action for Unit 1's Functional Unit 4.a, " Manual" is being changed from ACTION 18 to ACTION 21 which only requires the plant to be taken to HOT SHUTDOWN rather than COLD SHUTDOWN consistent with STS (NUREG-1431, Rev.1)
Modify the required action for Functional Unit 4b, " Steam Line Isolation -
Actuation Logic." From ACTION 13 to ACTION 20 consistent with Unit 2's required action, the WCAPs and NRC SERs.
Establish Functional Units 5.b, " Turbine Trip and Feedwater Isolation, Actuation Logic and Actuation Relays," and 5.c, " Safety injection," consistent with Standard Technical Specifications (NUREG-1431, Rev.1). The Actuation Logic and Actuation Relays use ACTION 20 for required actions with an inoperable channel / train and Safety injection uses the standard note to refer to Functional Unit 1 for actions consistent with STS (NUREG-1431, Rev.1).
Include an "*" for ACTION 14 associated with Functional Unit 6.c, Steam Generator Water Level Low-Low, for Unit 2.
This will provide a TS 3.0.4 exclusion, which will permit mode changes with a channel blocked, consistent with Unit 1 and the STS (NUREG-1431, Rev.1).
Change the required ACTION for Functional Unit 6.f, Main Feed Pump Trip for Unit 2 from ACTION 18 to ACTION 17 to be consistent with Unit 1 required actions and the STS (NUREG-1431, Rev.1).
Modify the Total Number of Channels, Channels to Trip, and Minimum Channel Operable Requirements for Functional Unit 6e
" Auxiliary Feedwater Pump Start-Station Blackout" to better represent the channel logic. Also modify the required actions with an inoperable channel from ACTION 18 to ACTION 21 J
consistent with STS (NUREG-1431, Rev.1).
Modify the Mode Applicability for Functional Unit 7, " Loss of Power," to include Mode 4 consistent with Unit 2 and STS (NUREG-1431, Rev.1).
Establish Functional Unit 8 - Engineered Safety Features System Interlocks and the accompanying ACTION 22. This Functional Unit and the required actions are consistent with WCAP-10271 and the STS (NUREG-1431, Rev.1).
Page 14 of 25
Establish new Note "# # #" to qualify the Applicable MODES for Functional Units 5.a and b consistent with WCAP-14333 and the STS (NUREG-1431, Rev.1)
Modify ACTION 13 to permit 24 hours2.777778e-4 days <br />0.00667 hours <br />3.968254e-5 weeks <br />9.132e-6 months <br /> to restore an inoperable channel to OPERABLE status before requiring the unit shutdown to HOT STANDBY within the next 6 hours6.944444e-5 days <br />0.00167 hours <br />9.920635e-6 weeks <br />2.283e-6 months <br /> and increase the allowed bypass time from 2 to 4 hours4.62963e-5 days <br />0.00111 hours <br />6.613757e-6 weeks <br />1.522e-6 months <br /> for surveillance testing. (Functional Units 1.b,2.b,3.a.2,3.b.2).
Modify ACTION 14 to permit STARTUP and POWER OPERATION with an inoperable channel beyond the next scheduled surveillance test.
To accommodate operation beyond the next surveillance test with an inoperable channel, ACTION 14 is modified to include bypassing of an inoperable channel for up to 12 hours1.388889e-4 days <br />0.00333 hours <br />1.984127e-5 weeks <br />4.566e-6 months <br /> to permit surveillance testing of another channel. Also,72 hours8.333333e-4 days <br />0.02 hours <br />1.190476e-4 weeks <br />2.7396e-5 months <br /> are provided to place an inoperable channel in the tripped condition.
(Functional Units 1.c,1.d,1.e,1.f,4.c,4.d,5.a, and 6.c)
Eliminate ACTION 15 and the current Table Notation "###" since they are only associated with the requirements for operation with less than three reactor coolant loops.
Modify ACTION 16 to permit 72 hours8.333333e-4 days <br />0.02 hours <br />1.190476e-4 weeks <br />2.7396e-5 months <br /> to place an inoperable channelin trip and eliminate the need to verify the Minimum channel OPERABLE requirement in 1 hour1.157407e-5 days <br />2.777778e-4 hours <br />1.653439e-6 weeks <br />3.805e-7 months <br /> consistent with NUREG-1431, Rev.1. In addition,12 hours1.388889e-4 days <br />0.00333 hours <br />1.984127e-5 weeks <br />4.566e-6 months <br /> are provided to bypass / block an inoperable channel for surveillance testing of the other channels.
Modify ACTION 17 to require the inoperable channel to be restored to OPERABLE status within 48 hours5.555556e-4 days <br />0.0133 hours <br />7.936508e-5 weeks <br />1.8264e-5 months <br /> or be in at least HOT STANDBY within the next 6 hours6.944444e-5 days <br />0.00167 hours <br />9.920635e-6 weeks <br />2.283e-6 months <br /> consistent with STS (NUREG-1431, Rev.1). (Functional Unit 6.f,
" Main Feed Pump Trip"]
Modify ACTION 20 to provide 24 hours2.777778e-4 days <br />0.00667 hours <br />3.968254e-5 weeks <br />9.132e-6 months <br /> to restore the inoperable channel to operable status prior to requiring a unit shutdown. This ACTION is applicable to Functional Unit 4.b Steam Line Isolation Automatic Logic and 5.b Turbine Trip and Feedwater Isolation Actuation Logic and Actuation Relays.
Establish ACTION 22 to delineate the required actions for an inoperable interlock channel. (Functional Unit 8,"ESFAS Interlocks"]
Changes to Table 4.3-2, Engineered Safety Features Actuation System Instrumentation Surveillances increase in surveillance intervals for ESFAS analog channel operational tests e
from once per month to once per quarter. (Functional Units 1.c, d, e, f; 2.c; 3.b.3; 4.c and d; 5.a; 6.c; 7.a and b)
Page 15 of 25
Modify the Applicable MODES for Functional Unit 1.c, " Containment Pressure -
e High," to eliminate Mode 4. This is consistent with the remaining applicabilities for Functional Units 2.c, 3b.3 and 4.c, " Containment Pressure - High," in the Units 1 and 2 Technical Specifications. This change in Mode applicability is also consistent with the accident analysis assumptions and STS (NUREG -1413, Rev.1).
Modify the Mode Applicability for Functional Unit 7, " Loss of Power," to include Mode 4 consistent with Unit 2 and STS (NUREG-1431). In addition, eliminate Note 2 (eliminates staggered monthly testing consistent with the WCAPs and NRC SERs) from the Functional Test requirement and replace it with note 5 which only identifies the functional test requirements. The channel will now be tested quarterly.
Establish Functional Units 5.b, " Turbine Trip and Feedwater Isolation - Actuation Logic and Actuation Relays" and 5.c, " Safety injection," and the associated surveillance requirements consistent with STS (NUREG-1431, Rev.1).
Establish Functional Unit 8, " Engineered Safety Features Actuation System Interlocks," and the associated surveillance requirements. The data analysis concluded that the permissives included substantial margin to the analysis assumption on rack drift, even with testing extended to refueling intervals.
Although no PRA analysis was performed for refueling intervals on the permissives, they are still verified as being in the " safe" position during power operation via the channel check. Unlike the RTS and ESFAS functions which perform automatic safety functions, the permissives merely allow a manual block of limited safety functions during a controlled shutdown. Power operation occurs with the permissive in its safe position, analogous to placing a protection function channel in TRIP for testing. Standard Technical Specifications only require refueling testing of the RTS permissives. Testing of P-11 and P-12 at a refueling interval is consistent with the practice for the RTS permissives. Due to hardware limitations, P-11 cannot be functionally tested during power operations.
Consistent with the Reactor Trip System Interlock surveillance requirements, P-11 and P-12 will be functionally tested during the Channel Calibration performed on a Refueling basis.
The functional test requirements will be Refueling.
Currently the plant performs -a functional test and channel calibration on a refueling basis of all permissives.
Include Note 3 for Functional Units 14,2.c,4.c (Unit 1) and Functional Unit 4.c (Unit 2) for consistency in the Technical Spe.cifications. The note requires the transmitter to be exercised and is included for each containment pressure instrument surveillance.
Establish Note "#" to further define the Mode applicability for Functional Units 5.a, Turbine Trip and Feedwater Isolation
" Steam Generator High-High," and 5.b," Actuation Logic."
Page 16 of 25
Revisions to the 3/4.3.1 and 3/4.3.2 PROTECTIVE AND ENGINEERED SAFETY FEATURES INSTRUMENTATION BASES.
- Changes in the first and third paragraphs as follows:
The OPERABILITY of the Reactor Trip System and ESFAS instrumentation systems and interlocks ensures that 1) the associated ESF action and/or reactor trip will be initiated when the parameter monitored by each channel or combination thereof exceeds its setpoint, 2) the specified coincidence logic and sufficient redundancy are maintained to permit a channel to be out of service for testing or maintenance consistent with maintaining an appropriate level of reliability of the RTS and ESFAS instrumentation and 3) sufficient system functional capability is available from diverse parameters.
The surveillance requirements specified for these systems ensure that the overall system functional capability is maintained comparable to the original design standards. The periodic surveillance tests performed at the minimum frequencies are sufficient to demonstrate this capability. Specific surveillance intervals and surveillance and maintenance outage times have been determined in accordance with WCAP-10271, EVALUATION OF SURVEILLANCE FREQUENCIES AND OUT OF SERVICE TIMES FOR THE REACTOR TRIP INSTRUMENTATION SYSTEM, and supplements to that report, WCAP-10271 Supplement 2, EVALUATION OF SURVEILLANCE FREQUENCIES AND OUT OF SERVICE TIMES FOR THE ENGINEERED SAFETY FEATURES ACTUATION SYSTEM, and supplements to that report, and WCAP-14333P, PROBABILISTIC RISK ANALYSIS OF THE RPS AND ESF TEST TIMES AND COMPLETION TIMES, as approved by the NRC and documented in SERs dated February 21, 1985, Februan/ 22,1989, the SSER dated April 30,1990 for WCAP-10271 and July 15, 1998 fcr WCAP-14333P.
Add a new basis paragraph to include a discussion of surveillance testing:
Surveillance testing of instrument channels is routinely performed with the channel in the tripped condition. With the exception of the Power Range Neutron Flux instrument channels, only those instrument channels with hardware permanently i
installed that permits bypassing without lifting a lead or installing a jumper are routinely tested in the bypass condition. However, an inoperable channel may be bypassed by lifting a lead or installing a jumper to permit surveillance testing of another instrument channel of the same functional unit.
Revise Administrative Technical Specification 6.8.4.g to include TS 3.3.1.1 and TS 3.3.2.1 in the listing of as risk-informed Technical Specifications Page 17 of 25
Safety Significance in WCAP-14333, the WOG evaluated the impact of the additional relaxation of allowed outage times and completion times, and action statements on core damage frequency.
The change in core damage frequency is 3.1 percent for those plants with two out of three logic schemes that have not implemented the proposed surveillance test interval, allowed outage times, and completion times evaluated in WCAP-10271 and its supplements. This analysis calculates a significantly lower increase in core damage frequency than the WCAP-10271 analysis calculated. This can be attributed to more realistic maintenance intervals used in the current analysis and crediting the AMSAC system as an attemative method of initiating the auxiliary feedwater pumps. The NRC Staff considered this core damage frequency increase to be small compared to the range of uncertainty in the core damage frequency analyses and therefore acceptable.
The NRC performed an independent evaluation of the impact on core damage frequency (CDF) and large early release fraction (LERF). The results of the staff's review indicate that the increase in core damage frequency is small (approximately 3.2%) and the large early release fraction would increase by only 4 percent for 2 out of 3 logic schemes that have not implemented the proposed surveillance test interval, allowed outage times, and completion times evaluated in WCAP-10271 and its supplements.
The impact on the Probabilistic Risk Assessment due to an increase in the RTS and ESFAS instrumentation surveillance interval from monthly to quarterly is considered minor. The evaluation used the current North Anna PRA model to establish an overall change in the PRA of approximately one percent The NR'C Staff concluded in addition that a staggered test strategy need not be implemented for ESFAS analog channel testing and is no longer required for RTS analog channel testing. This conclusion was based on the small relative contribution of the analog channels to RTS/ESFAS unavailability, process parameter signal diversity, and normal operational testing sequencing.
The NRC determined that the requirement to routinely verify permissive status is a different consideration than the availability of trip or actuation channels which are i
required to change state on the occurrence of an event and for which the function availability is more dependent on the surveillance interval. The definition of the channel check includes comparison of the channel status with other channels for the same parameter.
For the RTS and ESFAS interlocks, the change from the monthly surveillance requirement to at least once every 18 months is therefore justified.
The proposed changes are consistent with the NRC staff's letters dated February 21,1985, February 22,1989, April 30,1990, and July 15,1998, to the WOG regarding evaluation of WCAP-10271, WCAP-10271 Supplement 1, WCAP-10271 Supplement 2 WCAP-10271 Supplement 2, Revision 1, and WCAP-14333.
Page 18 of 25
Environmental Assessment The proposed Technical Specifications changes address instrumentation issues and have no environmental impact or increase in the individual or cumulative occupational radiation exposure. The protection circuitry retains sufficient redundancy and diversity to ensure that core protection is maintained and hence the risk of offsite release is not increased.
The Reactor Trip System and Engineered Safety Features Actuation System will continue to be operated and tested in the same manner. No new effluents or effluent release paths are created as a result of the proposed Technical Specifications changes to the Reactor Trip System and Engineered Safety Features Actuation System instrumentation and actuation logic operability and surveillance requirements. The proposed changes will continue to ensure the RTS and ESFAS, will be operable as assumed in the safety analysis to mitigate the consequences of the accidents identified above and therefore, there is no environmental impact as a result of the proposed Technical Specifications changes.
1 r
Page 19 of 25
References 1.
WCAP-10271, " EVALUATION OF SURVEILLANCE FREQUENCIES AND OUT OF SERVICE TIMES FOR THE REACTOR PROTECTION INSTRUMENTATION SYSTEM," dated January 1983.
2.
WCAP-10271 Supplement 1, " EVALUATION OF SURVEILLANCE FREQUENCIES AND OUT OF SERVICE TIMES FOR THE REACTOR PROTECTION INSTRUMENTATION SYSTEM," dated July 1983.
3.
Let+er (OG-86) from J. J. Sheppard (WOG) to H. R. Denton (NRC) dated February 3, 1983 (WCAP-10271 submittal).
4.
Letter from C. O. Thomas (NRC) to J. J. Sheppard (WOG) dated July 28,1983 (NRC Request Number 1 for Additional Information on WCAP-10271).
5.
Letter (OG-106) from J. J. Sheppard (WOG) to C. O. Thomas (NRC) dated October 4,1983 (WCAP-10271 Supplement 1 and question response submittal).
6.
Letter from C. O. Thomas (NRC) to J. J. Sheppard (WOG) dated February 21,1985 (NRC Safety Evaluation Report for WCAP-10271).
7.
WCAP-10271 Supplement 2 " EVALUATION OF SURVEILLANCE FREQUENCIES AND OUT OF SERVICE TIMES FOR THE ENGINEERED SAFETY FEATURES ACTUATION SYSTEM," dated February 1986.
8.
WCAP-10271-P-A Supplement 2, Revision 1 " EVALUATION OF SURVEILLANCE FREQUENCIES AND OUT OF SERVICE TIMES FOR THE ENGINEERED SAFETY FEATURES ACTUATION SYSTEM," dated June 1990.
9.
Letter (OG-87-15) from Roger A. Newton (WOG Chairman) to R. W. Starosticki (NRC) dated May 12,1987 (WCAP-10271 Supplement 2, Revision 1 submittal.)
- 10. Letter H. R. Denton (NRC) to L. D. Butterfield (WOG Chairman) dated July 24,1985 (Comments to Guidelines).
- 11. Letter Charles E. Rossi (NRC) to Roger A. Newton (WOG) dated February 22,1989 (NRC Safety Evaluation Report for WCAP-10271 Supplement 2 and Supplement 2, Revision 1).
- 12. Letter Charles E. Rossi (NRC) to Gerard T. Goering (WOG) dated April 30,1990 (NRC Supplemental Safety Evaluation Report for WCAP-10271 Supplement 2, Revision 1).
Page 20 of 25
i References (continued)
- 13. Letter Charles E. Rossi (NRC) to Robert F. Janacek, Chairman BWR Owners Group dated April 27,1988," STAFF GUIDANCE FOR LICENSEE DETERMINATION THAT THE DRIFT CHARACTERISTICS FOR INSTRUMENTATION USED IN RTS CHANNELS ARE BOUNDED BY NEDC-30851P ASSUMPTIONS WHEN THE FUNCTIONAL TEST INTERVAL IS EXTENDED FROM MONTHLY TO QUARTERLY."
- 14. WCAP-14333P, "PROBABILISTIC RISK ANALYSIS OF THE RPS AND ESFAS TEST TIMES AND COMPLETION TIMES," dated May 1995.
- 15. WCAP-14334NP,"PROBABILISTIC RISK ANALYSIS OF THE RPS AND ESF TEST TIMES AND COMPLETION TIMES," dated May 1995.
- 16. Letter Thomas H. Essig to Mr. Louis F. Liberatori Jr., Chairman Westinghouse Owners Group, dated July 15,1998, " REVIEW OF WESTINGHOUSE OWNERS GROUP TOPICAL REPORTS WCAP 14333P AND WCAP-14334NP, DATED MAY, 1995, PROBABILISTIC RISK ANALYSIS OF THE RPS AND ESFAS TEST TIMES AND COMPLETION TIMES."
l Page 21 of 25 I
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