ML20207E925
| ML20207E925 | |
| Person / Time | |
|---|---|
| Site: | FitzPatrick  |
| Issue date: | 12/23/1986 |
| From: | POWER AUTHORITY OF THE STATE OF NEW YORK (NEW YORK |
| To: | |
| Shared Package | |
| ML20207E895 | List: |
| References | |
| NUDOCS 8701050203 | |
| Download: ML20207E925 (9) | |
Text
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ATTACHMENT I to JPN-86-62 PROPOSED TECHNICAL SPECIFICATION CHANGES TO REFLECT ANALOG TRANSMITTER TRIP SYSTEM (ATTS) INSTALLATION (JPTS-86-013)
NEW YORK POWER AUTHORITY JAMES A.
FITZPATRICK NUCLEAR POWER PLANT DOCKER NO. 50-333 8701050203 861223 DPR-59 PDR ADOCK 05000333 P
ppg
JAFNPP Table 4.1-1 (cont'd)
REACTOR PROTECTION SYSTEM (SCRAM) INSTRUMENT FUNCTIONAL TESTS MINIMUM FUNCTIONAL TEST FREQUENCIES FOR SAFETY INSTRUMENT AND CONTROL CIRCUITS Group (2)
Functional Test Minimum Frequency (3)
Main Steam Line High Radiation B
Trip Channel and Alarm (4)
Once/ week.
Closure Main Steam Line Isolation Valve A
Trip Channel and Alarm Once/ month. (1)
Closure Turtine Control Valve EHC Oil A
Trip Channel and Alarm Once/ month.
Pressure Turbine First Stage Pressure B
Trip Channel and Alarm (4)
Once/ month. (1)(8)
Permissive ( ATTS) l Turtine Stop Valve Closure A
Trip Channel and Alarm Once/ month. (1)
Reactor Pressure Permissive (ATTS) A Trip Channel and Alarm (4)
Once/mnth. (1)(8) l NOTES FOR TABLE 4.1-1 1.
Initially once every enth until acceptable failure rate data are available; thereafter, a request may te made to the NRC to change the test frequency. The compilation of instrument failure rate data may include data obtained from other boiling water reactors for which the same design instrument operates in an environment similar to that of JAFNPP.
2.
A description of the three groups is included in the Bases of this Specification.
3.
Functional tests are not required on the part of the system that is not required to be operable or are tripped.
If tests are missed on parts not required to be operable or are tripped, then they shall be performed prior to returning the system to an operable status.
4.
This instrumentation is exempted from the instrument channel test definition. This instrument channel functional test will consist of injecting a simulated electrical signal into the instrument channels.
Amendment No.gfr(g 45
a JAFNPP Table 4.1-2 (cont'd) -
REACTOR PROTECTION SYSTEM (SCRAM) INSTRUMENT CALIBRATION MINIMUM CALIBRATION FREQUENCIES FOR REACTOR PROTECTION INSTRUMENT CHANNELS Instrument Channel Group (1)
Calibration (4)
Minimus Frequency (2)
Turbine Control Valve Fast A
Standard Pressure Source Once/ operating cycle Closure Oil Pressure Trip Turbine Stop Valve Closure A
Note (5)
Note (5)
Reactor Pressure Permissive ( ATTS)
A Standard Pressure Source Note (7) g NOTES FOR TABLE 4.1-2 1.
A description of three groups is included in the Bases of this Specification.
2.
Calibration test is not required on the part of the system that is not required to be operable, or is tripped, but is required prior to return to service.
3.
The current source provides an instrument channel alignment. Calibration using a radiatio 9 source shall be made each refueling outage.
4 Response time is not a part of the routine instrument channel test but will be cherted once per operating cycle.
5.
Actuation of these switches by normal means will be performed during the refueling outages.
6.
Calibration shall be performed utilizing a water column or similar device to provide assurance that damage to a float or other portions of the float assembly will be detected.
7.
Sensor calibration once per operating cycle. Master /sisve trip unit calibration once per 6 months.
l l
l Amendment No. 74,,W 47 1
JAFNPP TABLE 4.2-R 1
MINIMUM TEST AND CALIBRATION FREQUENCY FOR CORE AND CONTAINMENT COOLING SYSTEMS Instrument Channel Instrument Functional Test Calibration Frequency Instrument Check (4) la) Reactor Water Level (Non-ATTS)
(1)
Once/3 months Once/ day lb) Reactor Water Level ( ATTS)
(1)(5)
(15)
Once/ day 2a) Drywell Pressure (non-ATTS; (1)
Once/3 months None 2b) Drywell Pressure (ATTS)
(1)(5)
(15)
Once/ day 3a) Reactor Pressure (non-ATTS)
(1)
Once/3 months None 3b) Reactor Pressure (ATTS)
(1)(5)
(15)
Once/ day 4)
Auto Sequencing Timers None Once/ operating cycle None 5)
(1)
Once/3 months None 6)
Trip System Bus Power Monitors (1)
None None 8)
Core Spray Sesrger d/p (1)
Once/3 months Once/ day 9)
Steam Line High Flow (HPCI & RCIC)
(1)(5)
(15)
Once[ day 10)
Steam Line/ Area High Temp. (HPCI & RCIC) (1)(5)
(15)
Once/ day 12)
HPCI & RCIC Steam Line Low Pressure (1?(5)
(15).
Once/ day 13)
HPCI & RCIC Suction Source Levels (1)
Once/3 months None e
14a) 4Ky Emergency Power Under-Voltage Once/ operating cycle Once/ operating cycle None (Loss of Voltage) Relays and Timers 14b) 4KV Emergency Bus Under-Voltage Once/ operating cycle Once/ operating cycle None (Degraded Voltage) Relays and Timers 15)
HPCI & RCIC Exhaust Diaphragm (1)
Once/3 months None Pressure High f
17)
LPCI/ Cross Connect Valve Position Once/ operating cycle None None 1,
NOTE:
See listing of notes following Table 4.2-6 for the notes referred to herein.
r Amendment No.,14, ~43', Jrf,,89
}'^
,.'.. m 79 c
ATTACHMENT II TO JPN 62 NEW YORK POWER AUTHORITY James A.
FitzPatrick Nuclear Power Plant Docke t No. 50-333 DPR-59 Safety Evaluation for Technical Specification Changes Related to the Installation of ANALOG TRANSMITTER TRIP SYSTEM (ATTS)
I.
Description of Changes The following changes are proposed for Table 4.1-1
(" Reactor Protection System (SCRAM) Instrument Functional Test Minimum Functional Test Frequencies for Safety Instrument and control Circuits") on page 45:
[a]
Instrument Channel " Reactor Pressure Permissive" Functional Test note "(4)" is added; and Minimum Frequency of "Every 3 months" is changed to "Once/ month notes (1)(8)".
[b]
The acronym "(ATTS)" is added after instrument channels
" Turbine First Stage Pressure Permissive and " Reactor Pressure Permissive".
The following changes are proposed for Table 4.1-2
(" Reactor Protection System (SCRAM) Instrutaent Calibration Minimum Calibration Frequencies For Reactor Protection Instrument Channels") on page 47:
[c]
Instrument Channel " Reactor Pressure Permissive" Minimum Frequency of "Every 6 months" is changed to read " Note (7)".
[d]
The acronym "(ATTS)" is added af ter " Reactor Pressure Permissive" in the Instrument Channel column.
The following changes are proposed for Table 4.2-2
(" Minimum Test And Calibration Frequency for Core and Containment Cooling Systems") on page 79:
[e]
In the Instrument Channel column, Item No. "l) Reactor Water Level" is revised to read "la) Reactor Water Level (non-ATTS)" with corresponding instrument function test of
"(1)",
calibration frequency of "once/3 months", and instrument check of "once/ day".
[f]
Add new item in the Instrument Channel column, "lb)
Reactor Water Level (ATTS)" with corresponding Instrument Functional Test of notes "(1)(5)", Calibration Frequency of note "(15)", and Instrument Check of "Once/ day".
II. Furpose of the Proposed Changes Replacement of mechanical sensors and relays with an Analog Transmitter Trip System is a technically superior approach to satisfy trip input requirements on nuclear safety
- systems, operating experience has shown that mechanical sensors inherently drift out of tclerance and require frequent maintenance, testing, calibration and repair due to age and wear.
Personnel errors as well as physical jarring of the mechanical sensors have caused unscheduled plant shutdowns.
The ATTS is an all solid-state electronic trip system designed to provide stable and accurate monitoring of protection parameters.
Installation of the ATTS will result in the following benifits:
Plant safety will be improved because an electronic system is more reliable than a mechanical system.
The number of plant outages due to inadvertent reactor shutdown will be reduced with the use of more reliable instrumentation.
There will be a significant decrease in the time required for surveillance testing of the instrumentation.
Maintenance and' associated radiation exposure will be reduced.
Equipment failure due to instrument drift and required Licensee Event Reports to the NRC will be reduced.
ATTS replaces pressure, level, and temperature switches in the RPS and ECCS with analog sensor / trip unit combinations.
The system is designed to improve sensor reliability, while the basic logic functions remain the same.
Since ATTS instrumen-tation demonstrates less drift than the mechanical switches it replaces, certain surveillance requirements are being extended.
Plant modifications for the continuing installation of the ATTS will be completed during the current Reload 7/ Cycle 8 refueling cutage scheduled to begin January 1987.
Four (4) existing mechanical reactor pressure permissive switches (02-3PS-51A, B,
C& D) will be replaced with four ATTS instrument channels.
This replacement requires that the corresponding Technical Specifications surveillance requirements be changed accordingly.
The proposed changes to the Technical Specifications on pages 45 and 47 (items [a] & [c]) reduce minimum test and calibration frequencies to take advantage of the increased reliability of the ATTS equipment. -
The proposed changes. t'o incorpora te the acronym "(ATTS)"
on pages 45 and 47 (itens [b] & [d])-are added to Instrument Channels " Reactor Pressure Permissive" and " Turbine First Stage Pressure Permissive" for clarity.
The proposed changes to Instrument Channel item "l)
Reactor Water Level" on page 79 (items [e] & [f]) clarify the use of "Non-ATTS" and "ATTS" equipment with corresponding surveillance requirements.
III. Impact of the Proposed Changes The proposed changes to the Technical Specification on pages 45 & 47 (items [b] & [d]) do not impact the operation of the plant since they are administrative in nature and only clarify where ATTS equipment is used.
The proposed changes on pages 45, 47, & 79 (items [a], [c], [e], & [f]) reduce surveillance requirements for new ATTS equipment.
ATTS modifications at the FitzPatrick Plant and its associated Technical Specification changes will: reduce the number of challenges to the RPS, improve plant availability, simplify calibration procedures, and enhance plant safety.
Changing to an analog system will improve overall sensor accuracy and reliability; reduce the amount of time the RPS logic is in a half scram condition and consequently reduce the potential for inadvertent plant scrams; reduce calibration frequency; reduce the number of Licensee Event Reports filed with the NRC associated with instrument setpoint drif t; and reduce radiation exposure to plant personnel.
The replacement of mechanical sensor switches with an analog transmitter trip system will permit personnel to more accurately and reliably determine system parameters.
Changing the instrument from a mechanical to an analog system does not alter the requirements for instrument initiation, function, and operation that existed prior to the change.
Therefore, the installation of ATTS only affects the system at the sensor level, not the logic level.
Reduced surveillance requirements will maintain availability, accuracy, and reliability at the level which existed prior to the installation of ATTS.
The existing system (mechanical sensors) required frequent surveillance testing which required the plant be placed in a half-scram condition.
The new ATTS sensors require less maintenance, surveillance testing, and nearly eliminate instrumentation setpoint drift.
The reason for this is that electronic components are highly reliable, more accurate, and have low failure rates.
Therefore they required less frequent testing and maintenance to insure the same level of safety.
This conclusion is supported in Section 3.4 of Reference 3 which describes ATTS availability in detail.
I l
The operation, design and surveillance criteria, upon whi ch the ATTS modification is based, has been analyzed by General Electric in Reference 3.
State-of-the-art qualification type testing has been conducted in accordance with IEEE 323-1974 (Reference 4).
This report documents the improvements in performance that the ATTS provides over the existing nechanical switches.
This testing demonstrated qualified life longer than those "Mean Time Between Failures" discussed in NEDO-21617-A (Reference 3).
NRC letter dated June 27, 1978 (Reference 7) states that NEDO-21617-A report is acceptable for reference in license applications.
Reference 2 also provides additional information regarding implementation of ATTS.
The Technical Specifications changes proposed will not alter the conclusions reached in the FSAR and SER accident analyses.
The proposed changes to the Technical Specification are similar to those submitted to the Commission in Reference 1 and supplemented with additional information in Reference 2.
In Reference 6, the Commission issued Amendment No. 89 approving those changes to support the operation of ATTS at the FitzPatrick plant.
IV. Evaluation of Significant Hazards Considerations The Authority considers that this proposed amendment to the FitzPatrick Technical Specifications can be classified as not likely to involve a significant hazards consideration since this proposed amendment, as per 10 CFR 50.92, does not:
(1) involve a significant increase in the probability or consequences of an accident previously evaluated because the proposed changes only improve sensor accuracy.
In addition the reduction in surveillance requirements do not reduce system accuracy or availability as described above and in NEDO-21617-A.
All system functions remain the same.
(2) create the possibility of a new or different kind of accident from any accident previously evaluated, since the incorporation of the ATTS system with the reduced surveillance requirements will only improve censor accuracy and reliability and not change or affect system logic functions.
(3) involve a significant reduction in a margin of safety, since the replacement of existing mechanical sensor switches with an analog system (ATTS) will more accurately and reliably measure system parameters, thereby, increasing the margin of safety.
Reduced surveillance testing frequencies will not significantly reduce the margin of safety, since the reduction is based on system accuracy and availability as and in NEDO-21617-A (Reference 3). _
V.
Implementation of the Changes Implementation of Thess changes, as proposed, will not impact ALARA, Security, and the Fire Protection programs at FitzPatrick, nor will the changes impact the environment.
VI. Conclusion The incorporation of these changes:
a) will not change the probability or the consequences of an accident or malfunction of equipment important to safety as previously evaluated in the Safety Analysis Report; b) will not increase the possibility or an accident or malfunction of a different type than any evaluated previously in the Safety Analysis Report; c) will not reduce the margin of safety as defined in the basis for any Technical Specifications; d) does not constitute an unreviewed safety question as defined in 10 CFR 50.59; Lnd e) involves no significant hazard considerations, as defined in 10 CFR 50.92.
VII. References 1.
NYPA letter, J.
P.
Bayne to D.
B.
Vassallo, dated March 21, 1985; Proposed Technical Specification Changes regarding Analog Transmitter Trip System.
2.
NYPA letter, J.
P.
Bayne to D.
B.
Vassallo, dated March 28, 1985 regarding additional information for the implementation of ATTS.
3.
General Electric Licensing Topical Report N"DO-21617-A Class I, Dated December 1978, " Analog Transmitter / Trip Unit System for Engineered Safeguard Sensor Trip Inputs."
4.
' Qualifying Class lE Equipment for Nuclear Power Generation Stations.
5.
IEEE 344-1975 - Recommended Practices for Seismic Qualification of Class lE Equipment for Nuclear Equipment.
6.
NRC letter, H.
I.
Abelson to J.P.
Bayne, dated May 7, 1985 regarding issuance of Amendment No.
89,' implementing ATTS Technical Specification changes.
7.
NRC letter, O.
D.
Parr to G.
G.
Sherwood (G.E.), dated June 27, 1978 (MFN-279-78), Review of General Electric Topical Report NEDO-21617, " Analog Transmitter / Trip Unit System for Engineered Safeguard Sensor Trip Input".