ML20236P096

Proposed Tech Specs,Revising HPCI & RCIC Steam Line High Flow Indication

ML20236P096
Person / Time
Site:	Quad Cities
Issue date:	11/06/1987
From:	COMMONWEALTH EDISON CO.
To:
Shared Package
ML20236P041	List: ML20236P039 ML20236P096
References
NUDOCS 8711170147
Download: ML20236P096 (9)

Text

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ATTACHMENT 1 1

PROPOSED CHANGES TO APPENDIX A TECHNICAL SPECIFICATIONS FOR

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OUAD CITIES STATION UNITS 1 AND 2 FACILITY OPERATING LICENSES DPR-29 AND DPR-30 Revised Pages:

3.2/4.2-11 (DPR-29) 3.2/4.2-12 (DPR-29) 3.2/4.2-10 (DPR-30) 3.2/4.2-11 (DPR-30) 8711170147 871106 PDR ADOCK 05000254 P

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QUAD-CITZES

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OPR-29 3..

Reactor-water level instruments 1-263-73A;& B, HPCI high' steam flow?

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instruments'l-2352 & 1-2353, and HPCI steam line low pressure instruments 2389A-D have been modified to be analog-trip: systems.

The analog trip 1

system consists of an analog sensor (transmitter);and a master / slave trip' l]

unit setup which ultimately. drives a trip; relay.

The' frequency of calibration and function testing for instrument loops of: the analog trip

system has-been established in LicensingLTopical. Report NE00-21617-A (December 1978).. With the one-out-of-two-taken-twice logic,1NEDO-21617-A' states that each trip unit be subjected-to a calibration / functional test

' frequency of_one' month. An adequate calibration / surveillance. test interval for the: transmitter is once per operating cycle.

The radiation monitors in-ths ventilation duct and on the refueling floor which initiate building isolation and standby gas treatment operation are arranged in:two one-out;of two logic systems.. The bases given above for the rod blo'cks apply here also and'were used to arrive at:the functional testing frequency.

Based on experience at Dresden Unit I with instruments of similar design' a testing interval:of.once every'3 months has been found.to be: adequate.

The: automatic pressuie relief instrumentation can be considered to be a l

one-cut-of-two_ logic system, and the discussion above applies to it also.

The instrumentation which is required for the postaccident condition will be tested,and calibrated at regularly scheduled intervals.. The basis for the calibration and testing of.this instrumentation is the same as was discussed above for. the reactor protection system'and.the emergency core cooling systems.

References

'l.

!B. Epstein and A. Shiff, " Improving Availability and Readiness of Field

Equipment Through. Periodic Inspection", UCRL-50451, Lawrence Radiation Laboratory, p 10, Equation (24), July 16, 1968 i

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07408-3.2/4.2-11 Amendment No.

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TABLE 3.2-1 l >:

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-INSTRUMENTATION THAT ' INITIATES PRIMARY CONTAINMENT !$0LATION FUNCTIONS Mininan Number -

3 of Operable or-Tripped -

Instrumep{,

channelsu.A Instruments.

Trio Level tetting Action U.

Reactor low water (5) 3144 inches above top of-A 4

' active fue1.*

4 Reactor low low water 184 inches above top of A.

active fue1*

High drywell pressure (S]

12.5 psig [33 A

4 16 High flow main steamline[5}

1140% of rated steam flow 8 16 High temperature main' 1200* F B

-steamline tunnel 4

High radiation

-17 x normal rated power B

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'steamline tunnel background Low main steam pressureI43, 1825 psig B

.4 C

2

.High flow RCIC steamline-1300())ofratedsteam flow 16 RCIC turbine area high 1200* F C

. temperature l

2 High flow HPCI steamline 1300 f rated steam D

l-j.

flow

-1 16 HPCI area high temperature 1200* F 0

Notes Whenever primary containment integrity is required, there shall be two operable or 1.

tripped v.ystems for each function, except for low pressure main steamline which only j

need be available in the Run position, Action.'if the first column cannot be met for one of the trip systems, that trip 2.

system shall be tripped.

If the first column cannot be met for both trip systems, the appropriate actions listed below shall be taken.

Initiate an orderly shutdown and have the reactor in Cold Shutdown condition in A.

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

B.

Initiate an orderly load reduction and have reactor in Hot Standby within 8 l

hours.

1 3

C.

Close isolation valves in RCIC system.

D.

Close isolation valves in HPCI subsystem.

3.

Need not be operable when primary containment integrity is not required.

4.

The isolation trip signal is bypassed when the mode switch is in Refuel or Startup/

Hot Shutdown.

5.

The instrumentation also isolates the control room ventilation system.

I This signal also automatically closes the mechanical vacuum pump discharge line iso-j 6.

lation valves, i

7.

Includes a time delay of 3 1 t i 9 seconds.

• Top of active fuel is defined as 360* above vessel zero for all water levels used in the LOCA analysis (see Bases 3.2).

07408 3.2/4.2-12 Amendment No.

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07R-30 pv X,

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0#mizing e?ch' channel independently may not truly optimize the system 1

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considering tE n overall rules of. system operation. However, true system c ( O f,a d eptim wition is a complex problem.. The optimums are broad, r,ots W rp, an0' e optimizing the individual channels.is genert11.y adequate,for,tp *,y%Vm

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'The formula given above minimizes the unavai M ility of a f,ingit'chainel n

whicP w st be bypassed during testing. The miMaization of ' tM., '

. unasailacility is illustrated by curva 1 of F@rc 4.2-2 which assumes

• that V

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..a etav.e1 has a f aiTure rate of Oc1910 /Mur and C;5 hala.ts fequirvd to.

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titt % The unavailability is a mMmum at triest interM[di t.f 3.6 y,-

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,Q t ' ;' a If. td similar channels are used inia. ore-out,oht6o cE)f 4pration,' the test y'..

d' inter el for minimum availability changes as s'NnctioWgf,the rules for -

j 2/

testing. The simplest case is to test each one'ircepeH4et of the other.

1 In this case, there is assumed to be a finite probab)14ty.1, hat both may be IN'

' bypassed at one time..This case is shown by curve $, kole phat the

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' unavailability is lower, as expected ha LrWdant system, and the minimum

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.jf t 6 j occurs at the same test interval. ~ Thus'/if'thd t wo channels are testeh E

independently, the equation above yielos the test interval for minin a

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unagilability.

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'O A more usual case is that the testing is not done independently. If.bcth.

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chaan@s are bypassed and tested at-the same time, the result is shown ' t.L i% b,

curve 3.

Note that the minimum occurs at about 40.000 hours0 days <br />0 hours <br />0 weeks <br />0 months <br />, much longer f

than for Cases 1 and 2.

Also, the mininium is not rmf y"as low as Case 2,,

which indicates that this method of testing does not take full advantage of-j

.the redundant channel.. Bypassing both channels.for $1mu'ftfdie2us testing should be avoided.

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T*' A w$t likely case. would be to stipulate that one <;hanacVbu bypused.

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tested, and restorec.L and then intnediately following.tte second cnan9e1 be d

bypassed, tested, and restored. This is shown by curn,4.

' Note that there

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is not true n.*nimum.

The curve does have a definite knm.ar.C very little

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-reduction in system unavailability is achieved bW testing 9t a shorter

-jnterval than camputed by the equation for a single' channel, i

in 1

The best test proc Cure of all those examined is to perfectly stagger the tests. This is.1Ftje test interval is 4 months, test one of the other channels every 2 montnb, This is shown in curve 5.

The' difference between

g, Cases 4. and 5 is net.lt;ible, ThJre me he other arguments, however, that f

M.'I morestronglysuppert-(teperfectly]taggeredtests.,includingreductionsin human error.

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.The conclusiutts to be d p yn are these:

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a.

A one-out-of-n system may be treated t.he same as a sing 1v. channel, in terms of choosing a test intervsl.

j b.

More than'one channel should no,be bypassed for testing at any one time, 1

Reactor water level instruments 2-263-73A-D)

HPCk31ghsteamflow<

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instruments 2-2352 & 2-2353, and HPCI steam line low pressure inttrumet,ts 2-2389A-D have been modified to be analog trip syst as The analog trip

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system consists of an analog sensor (transmitter) and a master / slave trip unit setup which ultimately drives a trip relay. The frequency of calibration and function testing for instrumentThops of the analog trip system has been estat1 W.ed in Licensing Topical Report NEDO-21617-A (December 1978). With the o.':*-out-of-two-taken-twice logic, NEDO-21617-A l

states that each trip u.'it be sdjected to a calibration / functional test '

l frequency of one month. An adequete calibration / surveillance test interval J

for the transmitter is one per operating cycle.

The radiation' monitors in the.?ntilat an duct and on the refueling floor which initiate building isolation ed stan@y gas treatment operation are arranged in two one-out-of two logic

%." sas. The bases given above for the rod blocks apply here also and were used to arrive _at the functional testing frequency.

f 0740B 3.2/4.2-10 knendnent No.

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.l M E/ A. %, INSTRUMENTATION THAT, INITIATES PRIMARY CONTAINMENT ISOLATION FUNCTIONS'

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. Minimum Numberi 3,:}Q[h;,4R

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M -,4 -Instrume

_ Trio Level settino Action W -

channels Instruments

,g 40 Reactor low wa'ter(5)

- >144 inches above t'op of

'A

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active fuel" gg7

~4 Reactor low low < water 184 inches above top of A

m.

active-fuela

~ 4.

High drywell pressure (5]

12.5 psig (33 A

i High flow main'steamline(5]. 1140% of rated' steam flow: B-

'16>

E J

-16 High temperature main 1200* F.

B steamline tunnel r;,

k&

4. ; 4

.Highradiationmagg-17 x: normal rated power.

B 4

steamline tunnell f background

..E 3..

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\\ Low main, steam pressure [4]

.i825,psig B

Utp s [g/yg.

High flow RCIC steamline 1100 of rated steam C

g flow 0 g~ n' W

. RCIC turbine area high.

1200* F

.C 16.

L n 7.g

temperature N

2

High flow HPCI steamline.

' 1300f7gf rated steam :

'D-~

' flow

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.HPCI area high temperature 1200* F.

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Notes (QN[L!lf"Ij Q :,/

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Whenever primary containment integrityLis required, there shall.be two operable or h

tripped systems for each function, except for low pressure main steamline which only 1

](yM g's need be-available in the Run position.

.A c @ tr2. 'Acti k if the first co Nmn cannot be met for one of the trip systems, that trip U

h Q --t g ystem shall be trtppyn a

1y If the first column ( W.ot bA met for both trip systems, the appropriate actions

< i, listed below shall be taken, k

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A.

Initiate an orderly shutdown and have the reactor in Cold Shutdown condition in l

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

B.

Initiate an orderly load reduction ar.d.have reactor 'in Hot standby within 8 hours9.259259e-5 days <br />0.00222 hours <br />1.322751e-5 weeks <br />3.044e-6 months <br />.

C.

Close isolation valves in RCIC system.

D.

Close isolation valves in HPCI subsystem.

3.

Need not be operable when primary containment integrity is not required.

4., The isolation trip signal is bypassed when the mode switch is in Refuel or Startup/

Hot $hutdown.

5.

The instrumentation also isolates the control room ventilation system.

6.. This signal also automatically closes the mechanical vacuum pump discharge line iso-lation valves.

7.

Includes.a time delay of 3 1 t i 9 seconds.

l

• Top of active fuel is defined as 360" above vessel zero for all water levels used in the LOCA analysis (see Bases 3.2).

07408 3.2/4.2-11 Amendment No.

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ATTACHMENT'2:

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SUMMARY

OF CHANGES

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.. Five (5). changes to-the Quad cities Station Technical-Specifications have been identified and'are listed below as follows:

N 1)1 Page-3.2/4.2-11 (DPR-29) and HPCI steam line.

i (a) ' Replace "1-2352 & 2353".with "1-2352 & 1-2353, low pressure. instruments 1-2389 A-D"

2) Page 3'.2/4.2-10 (DPR-30)

(a) Replace'"2-2389 A-D and HPCI Steamline Low Pressure Instruments 2352 and 2353"" with "2-2352 and 2-2353, and HPCI steam line-low pressure instruments 2-2389 A-D" i

3) 'Page 3.2/4.2-12 (DPR-29) and Page 3.2/4.2-11 (DPR-30)

(a)L Change minimum number of operable or tripped instrument channels from "4" for high flow RCIC steam line instruments to "2".

)

-(b) Change minimum number of operable or tripped instrument channels i

from "4" for high flow HPCI steam line instruments to "2".

(c) 'Under Note (7), change the HPCI and RCIC high steam flow logic setting from "3 6 t i 10 seconds" to "3 i t i 9 seconds".

I The 10 seconds value should be changed to 9 seconds.

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,4-ATTACHMENT 3 i

EVALUATION OF SIGNIFICANT HAZARDS CONSIDERATION

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i HPCI/RCIC Steamline High Flow Indication Tech Specs (DPR-29, pps. 3.2/4.3-11 and 12, DPR-30, pps. 3.2/4.2-10 and 11) j i

i The proposed amendment involves the Quad Cities Units 1 and 2 HPCI and RCIC Steamline High Flow Indication Technical Specifications. The amendment revises the Tech Specs to reflect the actual plant conditions, corrects a typographical error and revises a time delay relay setting for the i

HPCI and RCIC high steam flow logic to be consistent with an engineering recommendation based on a General Electric Company analysis.

The first change revises the number of operable or tripped HPCI and i

.RCIC steam line high flow indication instrument channels from a m n mum of l

ii four (4) channels to two (2). The current Technical Specifications require l

four (4) channels for both the HPCI and RCIC steam line high flow indications.

This number is not consistent with the Quad Cities design which utilizes two 2

-(2) channels in lieu of four (4) channels. This is a discrepancy that has existed since the original Technical Specifications were issued.

t The basis for changing the minimum number of operable or tripped

. instrument channels for the HPCI and RCIC steam line high flow lies in the fact that guad Cities Station utilizes a one-out-of-two-once logic for these A detailed review of the Station Final Safety Analysis Report (FSAR) systems.

has shown that this type of logic system was employed as a secondary means of steam line break detection, i.e., the HPCI and RCIC area high temperature detection logic. A review of the original system design specification and FSAR has confirmed that the two (2) high flow instrument set-up was the intended design. The proposed amendment revises the number of channels to be consistent with the original design basis and actual plant conditions.

The second change revised the HPCI and RCIC high steam flow settings. The original Quad Cities Station relays were replaced as part of a station modification with new time delay relays to prevent inadvertent HPCI isolation due to system pressure transients during start-up. This was done in response to Generic Letter 83-02.

The Technical Specifications were amended at that time to allow a time delay setting of 3 4 t 4 10 seconds for the new relays. This value was reviewed and accepted by NRC Staff in amendment numbers 88 and 83 to DPR-29, 30 dated June 6, 1984.

In the Safety Evaluation Report associated with this amendment, the staff concluded that a maximum delay of up to 10 seconds is within the design basis of the HPCI and RCIC isolation system and therefore acceptable. Since that time, Commonwealth Edison's BWR Engineering Department has recommended, based on the value used in a General Electric Company analysis, that the setting be changed to 3yi ty[ 9 seconds, thereby revising the maximum allowed setting from ten (10) to nine (9) seconds.

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Theproposedamendmentwouldchangethetimesettingfrom3dbtd$10 to 3 t$ t f 9 seconds to be consistent with the Engineering Department c

recommendation and General Electric Company analysis. The change decreases the maximum allowed time delay setting from a value which was previously approved by the Nuclear Regulatory Commission to a yet more conservative setting.

The last change revises a typographical error that can be found in DpR-29 and DpR-30 involving the instrument number designations for the HpCI high steam flow and low pressure instruments. The current Unit 1 and 2 Technical Specifications identify the high steam flow instruments as 1-2389 A-D and 2-2389 A-D while the correct designations are 1-2352, 1-2353, 2-2352 and 2-2353. The low pressure instruments are listed as 1-2352, 1-2353 in the Unit 1 and 2 Technical Specifications while the correct designations are 1-2389 A-D and 2-2389 A-D.

The instrument numbers'for the high steam flow instrumentation, as found in the Tech Specs, are actually the designations for the low pressure instrumentation while the instrument numbers for the low pressure instrumentation are actually the designations for the HPCI high steam flow instruments. Revising these instrument designations is considered to be an administrative change.

BASIS FOR NO SIGNIFICANT HAZARDS DETERMINATION Commonwealth Edison has evaluated this proposed snendment and determined that it involves no significant hazards consideration.

In accordance with the criteria of 10 CFR 50.92(c), a proposed amendment to an operating license involves no significant hazards considerations if operation of the facility, in accordance with the proposed amendment, would not:

1) Involve a significant increase in the probability or consequences of an accident previously evaluated ecause:

(a) Previously evaluated accidents were based on two channels for the RCIC and HPCI steam line flow indications not four; this means that the evaluations were based on conditions that actually exist in the plant, not the number of channels found in the current Technical Specifications. Therefore, the change does not increase the probability or consequences of previously evaluated accidents.

(b) The proposed time delay setting is lower than the setting which currently exists. Operating with a maximum time delay setting of nine seconds is more conservative than the previously approved ten second valve. Therefore, changing the maximum time delay setting for HpCI and RCIC steam line high flow does not increase the probability or consequences of previously evaluated accidents.

(c) Changing the instrument designation to correct a typographical error is considered to be an administrative change that has no effect upon j

p:eviously evaluated accident scenarios. Therefore, the change does l

not increase the probability or consequences of previously evaluated j

accidents.

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2) Create the possibility of a new or different kind of accident from any l

accident previously evaluated because:

(a) The revision to the Technical Specifications does not change the manner in which the plant has been or will be operated. The amendment corrects the number of HPCI and RCIC instrument channels to reflect the number of channels that actually exist and upon j

which the original system design was based. Additionally, j

operating with a minimum number of two tripped or operable HPCI or i

t RCIC high flow instrument channels is more conservative than with four channels. Therefore, the change does not create the possibility of a new or different kind of accident from any accident previously evaluated.

1 (b) The new time delay setting is more conservative than the value that

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currently exists in the Quad Cities Technical Specifications.

l Therefore, the change does not create the possibility of a new or different kind of accider t from any previously evaluated accident.

(c) The change merely correctis a typographical error and is considered j

to be administrative.in nature. An administrative change does not l

create the possibility of a new or different kind of accident from

{

any previously evaluated accident.

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3) Involve a significant reduction in the margin of safety because:

(a) The change just. corrects the number of HPCI and RCIC instrument channels that actually exist in the plant. There are no changes being made to hardware. The proposed amendment does not reduce the margin of safety since the minimum number of operable or tripped 1

channels will be more conservative as a result of this change. As a result, the margin of safety is unaltered.

(b) The new maximum time delay setting will be more conservative than the value that currently than the value that currently exists in the Quad Cities Technical Specifications. Therefore, the margin of safety is not being compromised as a result of this proposed license amendment.

(c) The change corrects a typographical error involving the designation for the HPCI instrumentation. This change is administrative and as l

a result, does not reduce the margin of safety.

1 Therefore, since the proposed license amendment satisfies the criteria specified in 10 CFR 50.92, commonwealth Edison has determined that l

a no significant hazards consideration exist for these items. We further request their approval in accordance with the provisions of 10 CPR 50.91(a)(4).

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