ML20211M848

Proposed Tech Specs Replacement Bases Pages Associated W/Proposed Amend to License Re Response Time Testing

ML20211M848
Person / Time
Site:	Grand Gulf
Issue date:	10/06/1997
From:	ENTERGY OPERATIONS, INC.
To:
Shared Package
ML20211M846	List: ML20211M842 ML20211M848
References
NUDOCS 9710150162
Download: ML20211M848 (6)

Text

_-

~

RPS Instrumentation B 3.3.1.1 j BASES SURVEILLANCE $R 3.3.1.1.15 REQUIREMENTS (continued)

This SR ensures that the individual channel response times are less than accident or equal to the maximum values assumed in the analysis.

The RPS RESPONSE TIME acceptance criteria are included in the applicable plant procedures.

As noted, neutron detectors are excluded from RPS RESPONSE TIME testing because the principles of detector o virtually ensure an instantaneous response time. peration 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 alternate testing requirements and restrictions of Reference 10 are performed.

As stated in Reference 10, analysis has demonstrated that other Technical Specification testing requirements (CHANNEL CALIBRATIONS, CHANNEL CHECKS, CHANNEL FUNCTIONAL TESTS, a 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 within acceptable limits. times and assure operation of the analyze Reference 10 also identifies that there are no known channel sensor failure modes identified that can be detected by Technical Specification required surveillances. Therefore, response time when the requirements, including sensor types, of Reference 10 are complied with, adequate assurance of the response time of the sensors is provided.

This assurance of the time testing of the remainder of the channel ensures tha the individual channel response times are less than er equal to the maximum values assumed in the accident analysis.The calibration shall be performed such that fast ramp or step 1

change to system components during calibrations is performed change is prompt.to verify that the response of the transmitter to the i time degradation during the performance of calibrations. Tech Technicians shall be appropriately trained to en.ture they are aware of the consequences of instrument response time degradation.

11. These items are commitments made per Reference If the alternate testing requirements of Reference 10 are not complied with, then the entire channel will be response time tested including the sensors.

. (continued)

GRAND GULF B 3.3-29 LOC 97078 9710150162 PDR 971006 P ADOCK 05000416 PDR

RPS Instrumeatation B 3.3.1.1 BASES SURVEILLANCE SR 3.3.1.1.15 (continued)

REQUIREMENTS RPS RESPONSE TIME tests are conducted on an 18 month STAGGERED TEST BASIS. Note 3 requires STAGGERED TEST BASIS I Frequency to be determined based on 4 channels per trip system, in lieu of the 8 channels specified in Table 3.3.1.1-1 for the MSIV Closure Function. This Frequency is based on the logic interrelationships of the various channels required to produce an RPS scram signal.

Therefore, staggered testing results in response time verification of these devices every 18 months. This Frequency is consistent with the typical industry refueling cycle and is based upon plant operating experience, which shows that random failures of instrumentation components causing serious time degradation, but not channel Failure, are infrequent.

1 REFERENCES 1. UFSAR, Figure 7.2-1.

I 2. UFSAR, Section 5.2.2.

l

3. UFSAR, Section 6.3.3.

4. UFSAR, Chapter 15.

5. UFSAR, Section 15.4.1.

6. NED0-23842, " Continuous Control Rod Withdrawal in the Startup Range,' April 18, 1978.

7. UFSAR, Section 15.4.9.

(continued)

GRAND GULF B 3.3-29a LDC 97078 o

RPS Instrumentation B 3.3.1.1 BASES REFERENCES 8. Letter, P. Check (NRC) to G. Lainas (NRC), "BWR (continued) Scram Discharge System Safety Evaluation,"

December ', 1980, as attached to NRC Generic Letter dated December 9, 1980.

9. NED0 30851-P-A, " Technical Specification improvement Analyses for BWR Reactor Protection System,"

March 1988.

10. NEDO-32291-A, " System Analyses for Elimination of Selected Response Time Testing Requirements," October 1995,

11. GNRI-97/000__, Amendment 133 to the Operating License.

t GRAND GULF B 3.3-30 LDC 97078 o

+. ..

. Pricary Containment and Drywell Isolation Instrumentation B 3.3.6.1 BA$ES w

SURVEILLANCE SR 3.3.6.1.7 REQUIREMENTS (continued) The LOGIC SYSTEM FUNCTIONAL TEST demonstrates the OPERABILITY of the required isolation logic for a specific channel. The system functional testing performed on isolation valves in LC0 3.6.1.3 and LCO 3.6.5.3 overlaps this !"rveillance to provide complete testing of the assumed safety function. The 18 month Frequency is based on the '

need to perform this Surveillance under the conditions that apply during a plant outage arid the potential for an unplanned transient if the Surveillance were performed with the reactor at power.

Operating experience has shown these components usually pass the Surveillance when performed at the 18 month Frequency.

SR 3.3.6.1.8 This SR ensures that the individual channel response times are less than or equal to the maximum values assumed in the accident analysis. Testing is performed only on channels where the assumed response time does not correspond to the I

diesel generator (DG) start time. For channels assumed to respond within the DG start time, sufficient margin exists in the 10 second start time when compared to the typical channel response time (milliseconds) so as to assure adequate response without a specific measurement test.

Testing of the closure times of the MSIVs is not included in this Surveillance since the closure time of the MSIVs is tested by SR 3.6.1.3.6. ISOLATION SYSTEM RESPCNSE TIME acceptance criteria for this instrumentation is included in the applicable plant procedures.

As Noted, the channel sensor may be excluded from response time testin~g. 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 l requirements (CHANNEL CALIBRATIONS, CHANNEL CHECKS, CHANNEL 1 FUNCTIONAL TESTS, and LOGIC SYSTEM FUNCTIONAL TESTS) and <

actions taken'in response to NRC Bulletin 90-01 Supplement 1 are sufficient to identify failure modes or degradation in (continued) .

GRAND GULF B 3.3-170 LOC 97078

_ -- J

Primary Containment and Drywell isolation instrumentation B 3.3.6.1 BASES SURVEILLANCE SR 3.3.6.1.8 (continued)

REQUIREMENTS instrument response times and assure ooeration 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 response time testing that cannot also L> detected by other Tec1nical Specification required surveillances. Therefore, when the requirements, including sensor types, of Reference 7 are complied with, adequate assurance of the response time of the sensurs is provided. This assurance of the response i time of the sensors when combined with the response time testing of the remainder of the channel ensures that the l individual channel response times are less than or equal to the maximum values assumed in the a.cident analysis. The calibration shall be performed suct that fast ramp or step change to system components during calibrations is aerformed toverifythattheresponseofthetransmittertot1einput change is prompt. Tecnnicians shall monitor for response time degradation during the performance of calibrations.

l- Technicians shall be appropriately trained to ensure they l

are aware of the consequences of instrument response time degradation. These items are commitments made per Reference

8. If the alternate testing requirements of Reference 7 are not complied with then the entire channel will be response time tested including the sensors.

ISOLATION SYSTEM RESPONSE TIME tests for this instrumentation are conducted on an 18 month STAGGERED TEST BASIS. This test Frequency is consistent with the typical industry refueling cycle and is based upon plant operating experience that shows that random failures of instrumentation components causing serious response time degradation, but not channel failure, are infregunt.

REFERENCES 1. UFSAR, Chapter 6,

2. UFSAR, Chapter 15.

l (continued)

GRAND GULF B 3.3 170a LDC 97078

\\~ _

Pricary Containment and Drywell isolation Instrumentation B 3.3.6.1 BASES REFERENCES 3. NE00 31466, " Technical Specification Screening (continued) Criteria Application and Risk Assessment,"

November 1987

4. UFSAR, Section 9.3.5.

5. NEDC 31677 P A. " Technical Specification improvement i Analysis for BWR isolation Actuation instrumentation,"

June 1989.

6. NEDC 30851 P A, Supplement 2. " Technical Specifications improvement Analysis for BWR isolation Instrumentation Common to RPS and ECCS Instrumentation," March 1989.

7. NED0 32291 A, " System Analyses for Elimination of Selected Response Time Testing Requirements," October 1995.

8. GNRI 97/000_ , Amendment 133 to the Operating License.

4 GRtND GULF B 3.3 171 LOC 97078

~