ML20217G901

From kanterella
Jump to navigation Jump to search
Proposed Tech Specs Changing Wording in Action 36 of TS Table 3.3.3-1, Emergency Core Cooling Sys Actuation Instrumentation
ML20217G901
Person / Time
Site: Nine Mile Point Constellation icon.png
Issue date: 07/31/1997
From:
NIAGARA MOHAWK POWER CORP.
To:
Shared Package
ML20217G891 List:
References
NUDOCS 9708080106
Download: ML20217G901 (6)
v • d • e


Text

_ _-__ - -__- _ _ __ _ - _

TABLE 3.3.31_ (Ccntinued)

'. EMERGENCY CORE COOLING SYSTEM ACTUATION INSTRUMENTATION ACTION ACTION 32 - With the number of OPERABLE channels less than required by the Minimum OPERABLE Channels per Trip Function requirement, within 24 hours2.777778e-4 days <br />0.00667 hours <br />3.968254e-5 weeks <br />9.132e-6 months <br /> declare the associated ADS Trip System or ECCS inoperable.

ACTION 33 - With the number of OPERABLE channels less than required by the Minimum OPERABLE Channels per Trip Function requirement, place the inoperable channel in the tripped condition within 24 hours2.777778e-4 days <br />0.00667 hours <br />3.968254e-5 weeks <br />9.132e-6 months <br />.

ACTION 34 - Not Used.

ACTION 35 - With the number of OPERABLE channels less than required by the

! Minimum OPERABLE Channels per Trip Functicn requirement, restore the inoperable channel to OPERABLE status within 8 hours9.259259e-5 days <br />0.00222 hours <br />1.322751e-5 weeks <br />3.044e-6 months <br /> or declare the associated ADS valve or ECCS inoperable.

ACTION 36 - With the number of OPERABLE channels less than required by the l Minimum OPERABLE Channels per Trip Function requirement:

a. With one channel inoperable, place the inoperable channel in [

the tripped condition within 24 hours2.777778e-4 days <br />0.00667 hours <br />3.968254e-5 weeks <br />9.132e-6 months <br />

b. With more than one channel inoperable, declare the HPCS l system inoperable.

ACTION 37 - With the number of OPERABLE channels less than required by the Minimum OPERABLE Channels per Trip Function requirement, place at least one inoperable channel in the tripped condition within 24 hours2.777778e-4 days <br />0.00667 hours <br />3.968254e-5 weeks <br />9.132e-6 months <br />' or declare the HPCS system inoperable.

ACTION 38 - With the number of OPERABLE channels less than the Total Number of Channels, declare the associated emergency diesel generator inoperable and take the ACTION required by Specification 3.8.1.1 or 3.8.1.2, as appropriate.

ACTION 39 - With the number of OPERABLE channels one less than the Total Number of Channels, place the inoperable channel in the tripped condition within 1 hour1.157407e-5 days <br />2.777778e-4 hours <br />1.653439e-6 weeks <br />3.805e-7 months <br /> *; operation may then continue until performance of the next required CHANNEL FUNCTIONAL TEST.

+'

  • The provisions of Specification 3.0.4 are not applicable.

NINE MILE POINT - UNIT 2 .,

3/4334 AMENDMENT NO. N 9708000106 970731 PDR ADOCK 05000410 P PDR ,

se *'

TABLE 3.3.3-1 (Continued)

E TAGENCY CORE COOLING SYSTEM ACTUATION INSTRUMENTAT1QH ACTION ACTION 32 -

With the number of OPERABLE channels less than required by the Minimum OPERABLE Channels per Trip Function requirement, within 24 hours2.777778e-4 days <br />0.00667 hours <br />3.968254e-5 weeks <br />9.132e-6 months <br /> declare the l associated ADS Trip System or ECCS inoperable.

ACTION 33 - With the number of OPERABLE channels less than required by the Minimum OPERABLE Channels per Trip Function requirement, place the inoperable channel in the tripped condition vithin 24 hours2.777778e-4 days <br />0.00667 hours <br />3.968254e-5 weeks <br />9.132e-6 months <br />. l ACTION 34 - Not used.

hCTION 35 - With the number of OPERABLE channels less than required by the Minimum OPERABLE Channels per Trip Function requirement, restore the inoperable channel to OPERABLE status within 8 hours9.259259e-5 days <br />0.00222 hours <br />1.322751e-5 weeks <br />3.044e-6 months <br /> or declare the associated ADS valve or ECCS inoperable.

ACTION 36 -

With the number of OPERABLE channels-ene-less than l required by the Minimum OPERABLE Channels per Trip l Function requirement:

wa ra cut cumuts. **JcteMed +lte '"cPEA AG A CHoddet

a. Ter enc Trip Oystem, place-thct Trip Oystem in the tripped condition within 24 hours2.777778e-4 days <br />0.00667 hours <br />3.968254e-5 weeks <br />9.132e-6 months <br />

wow su.st ruw cae CHMaa sus /custs

b. Ter beth Trip Systems, declare the HPCS system inoperable.

ACTION 37 - .

With the number of OPERABLE channels less than required by the Minimum OPERABLE Channels per Trip Function requirement, place at least one inoperable channel in the tripped condition within 24 hours2.777778e-4 days <br />0.00667 hours <br />3.968254e-5 weeks <br />9.132e-6 months <br />

ACTION 38 -

With the number of OPERABLE channels less than the Total Number of Channels, declare the associated emergency diesel generator inoperable and take the ACTION required by Specification 3.8.1.1 or 3.8.1.2, as appropriate.

ACTION 39 -

With the number of OPERABLE channels one less than the Total Number of Channels, place the inoperable channel in the tripped condition within 1 hour1.157407e-5 days <br />2.777778e-4 hours <br />1.653439e-6 weeks <br />3.805e-7 months <br /> *;

operation may then continue until performanca cf the next required CHANNEL FUNCTIONAL TEST.

The provisions of Specification 3.0.4 are not applicable.

NINE MILE POINT - UNIT 2 3/4 3-34 AMENDMENT NO. )d'

___D

~

ATTACHMENT B NIAGARA MOHAWK POWER CORPORATION LICENSE NO. NPF-69 DOCKET NO. 50 410 Supportino Information and No Stanificant Hazards Consideration Analysis INTRODUCTION The proposed Nine Mile Point Unit 2 (NMP2) Technical Specification (TS) change contained herein presents a revision to NMP2 TS Table 3.3.3-1, " Emergency Core Cooling System Actuation Instrumentation."

On March 27,1997, the NRC granted NMP2 enforcement discretion with respect to TS l 3.0.3. A failure to meet certain response time testing surveillance requirements forced

' NMP2 to enter into Required Action 3.3.3.b and, by reference, Table 3.3.3-1. However, inappropriate wording added by a previous amendment that changed Action 36 of Table 3.3.3-1 resulted in the action statement not addressing the plant condition of more than one inoperable channel per trip function in the High Pressure Core Spray (HPCS) drywell pressure and reactor water level instrumentation. This caused NMP2 to enter TS 3.0.3.

As part of the enforcement discretion, Niagara Mohawk Power Corporation (NMPC) committed to correct the restrictive wording with a TS amendment request submitted on a -

non-emergency basis.

The proposed changes revise the wording of Action 36 so that it addresses the plant condition of more than one channel being inoperable. Presently, the action only addresses the plant condition of having one channel per trip function inoperable. The Action 36 currently states "With the number of OPERABLE channels one less than required by the Minimum OPERABLE Channels per Trip Function requirements:...". The proposed change would revise the wording so that the statement will read "With the number of OPERABLE channels less than required by the Minimum OPERABLE Channels per Trip Function requirements:..." The wording of Action 36-a and 36-b was revit.ed to describe actions to be taken with one or more channels inoperable within a trip function.

EVALUATION The proposed revisions to TS Table 3.3.3-1, " Emergency Core Cooling System Actuation Instrumentation," Action 36, will allow Action 36 to be in effect for plant conditions where more than one channel per trip function is inoperable in the HPCS drywell pressure and reactor water level instrumentation.

Page 1 of 3

The changes would prevent unnecessary plant shutdowns per TS 3.0.3 when the plant has more than one channel inoperable per trip function in the HPCS drywell pressure and reactor water levelinstrumentation. The proposed revision would give NMP2 the capability to declare the HPCS inoperable should the plant enter the condition described above.

The proposed change provides consistency between the ECCS instrumentation and system TS. Clearly the initiating instrumentation should not haw more restrictive actions than the system which it automatically initiates. For example, inoperability of the HPCS system p -

LCO 3.5.1 may be due to the unavailability of the pump; whereas, initiating instrumentation being inoperable does not preclude manually starting the HPCS pump to deliver rated flow to the vessel. The TS also continues to require the operability of other injection systems coincidental with HPCS inoperability. Accordingly, inoperability of the auto initiating instrumentation is equivalent to or less severe than inoperability of the entire -

system. This capability to declare the system inoperable under these conditions is consistent with the Improved Technical Specifications (ITS standard).

CONCLUSIONS The current wording is inappropriate because it requires actions for initiating instrumentation that are more restrictive in regard to plant operation than the actions required for HPCS inoperability. The proposed revisions to Action 36 of Table 3.3.31 will change the inappropriate wording that caused NMP2 to be in a TS 3.0.3 condition on March 26,1997 and will clarify the actions required if more than one channel is inoperable.

This revision will prevent unnecessary plant shutdowns per TS 3.0.3 by allowing NMP2 to declare the HPCS system inoperable under these conditions and to enter the apprcpriate TS for HPCS inoperability. The capability to declare HPCS inoperable under these conditions is consistent with ITS.

ANALYSIS No Sionificant Hazards Consideration Analvtn i 10CFR50.91 requires that at the time a licensee requests an amendment, it must provide to the Commission its analysis using the standards in 10CFR50.92 concerning the issue of no significant hazards consideration. Therefore, in accordance with 10CFR50.91, the following analyses have been performed with respect to the requested change:

The coeration of Nine Mile Point Unit 2. in accordance with the crocosed amendment, will not involve a sionificant increase in the orobability or conseauences of an accident oreviousiv evaluatod.

The changes to Table 3.3.3-1, Action 36, will allow Action 36 to be in effect for the plant condition where more than one channel is inoperable per trip function in the HPCS drywell pressure and reactor water levelinstrumentation and will clarify the actions required if more than one channel is inoperable. Specifically, this action statement will allow the HPCS to be declared inoperable rather than to initiate plant shutdown per TS 3.0.3.- None of the precursors of previously evaluated accidents are affected and therefore, the probability of an accident previously evaluated is not increased.

Page 2 of 3 o

The'HPCS system will continue to perform its safety function to automatically initiate and inject water into the vessel. The out of service time for the initiating instruments remains bounded by the out of service time for HPCS. Therefore, these changes will not involve a significant increase in the consequences of an accident previously evaluated.

The coeration of Nine Mile Point Unit 2. in accordance with the orooosed amendment, will not create the oossibility of a new or different kind of accident from any accident previousiv evaluated.

The changes to Table 3.3.3-1, Action 36, will allow Action 36 to be in effect for plant conditions where more than one channel is inoperable per .tip function in the HPCS drywell pressurc and reactor water level instrumentation and will clarify the actions required if more than one channel is inoperable. No physical modification of the plant is involved and no changes to the methods in which plant systems are operated are required. The changes do not introduce any new failure modes or conditions that may create a new or different accident. Therefore, the changes do not by themselves create the possibility of a new or different kind of accident previously evaluated.

l The coeration of Nine Mile Point Unit 2. In accordance with the crocosed amendment. will not involve a sianificant reduction in a marain of safety.

The change to Table 3.3.3-1, Action 36, will allow Action 36 to be in effect for plant conditions where more than one channel is inoperable per trip function in tho HPCS drywell pressure and reactor water level instrumentation and will clarify the actions required if more than one channel is inoperable. The changes do not adversely affect any physical barrier to the release of radiation to plant personnel or to the public. The proposed chance provides consistency between the ECCS instrumentation and system TS. The TS also continues to require the operability of other injection systems coincidental with HPCS inoperability. The change has the benefit of avoiding unnecessary challenges to plant systems during an unnecessary plant shutdown. Therefore, the changes do not involve a significant reduction in a margin of safety.

Accordingly, the proposed changes do not present a significant hazards consideration.

Page 3 of 3

___ _ D

ATTACHMENT C NIAGARA MOHAWK POWER CORPORATION l 1.lCENSE NO. NPF 69 DOCKET NO. 50-410 Matked Cooy of Proposed Chances to Current Technical Specification The current version of page 3/4 3-34 of the NMP2 Technical Specifications has been hand marked-up to reflect the proposed change. -

i a . .

-. E

Retrieved from "https://kanterella.com/w/index.php?title=ML20217G901&oldid=3199393"