ML20238F494
| ML20238F494 | |
| Person / Time | |
|---|---|
| Site: | Limerick  |
| Issue date: | 08/26/1998 |
| From: | Geoffrey Edwards PECO ENERGY CO., (FORMERLY PHILADELPHIA ELECTRIC |
| To: | NRC OFFICE OF INFORMATION RESOURCES MANAGEMENT (IRM) |
| References | |
| NUDOCS 9809030397 | |
| Download: ML20238F494 (17) | |
Text
_ _ _ _ - - _ _.
ttition Support Depirtment s
v PECO NUCLEAR esco tee <o, cemneev 965 Chesterbrook Boulevard a
A Unit of PECO Energy Wayne, PA 19087 5691 August 26,1998 Docket Nos. 50-352 50-353 License Nos. NFP-39 NFP-85 U.S. Nuclear Regulatory Commission Attn: Document Control Desk Washington, DC 20555
Subject:
Limerick Generating Station, Units 1 and 2 Technical Specifications Change Request 96-09-0 Response to Request for Additional information (RAl-2)
Dear Sir / Madam:
By letter dated August 8,1996, PECO Energy submitted Technical Specifications (TS) Change Request No. 96-09-0 for Limerick Generating Station (LGS), Units 1 and 2. This proposed TS i
change involves revising TS Sections 3/4.3.1, " Reactor Protection System Instrumentation,"
3/4.3.2, *lsolation Actuation Instrumentation," 3/4.3.3, " Emergency Core Cooling System Actuation Instrumentation," and associated TS Bases Section 3/4.3.1 and 3/4.3.2 to eliminate selected response time testing requirements. The proposed TS changes are supported by analyses performed by the Boiling Water Reactor Owners' Group (BWROG) and documented in NEDO-32291," System Analyses for the Elimination of Selected Response Time Testing Requirements," dated January 1994.
By letter dated June 30,1997, PECO Energy submitted additionalinformation in support of this proposed TS change at the request of the NRC during telephone conversations. Subsequently, by letter dated September 3,1997, the NRC issued a supplemental request for additional information which identified four (4) additional questions.
Accordingly, the attachment and exhibit to this letter provide the requested information. Each of the four (4) questions are restated in the attachment followed by our resnonse to each question.
The exhibit contains information to support the response to question 4.
This information is being ll submitted under affirmation, and the associated affidavit is enclosed.
1 (0
9909030397 990826 PDR ADOCK 05000352 P
i s
August 26,1998 1
Page 2 l
l i
l If you have any questions or require additional information, please do not hesitate to contact us.
l
.i Very truly yours, I
j l
G. D. Edwards I
Director - Licensing Attachment / Exhibit Enclosure cc:
H. J. Miller, Administrator, Region I, USNRC (w/ attachment / exhibit, enclosure) l A. L. Burritt, USNRC Senior Resident inspector, LGS (w/ attachment! exhibit, enclosure)
R. R. Janati, Director, PA Bureau of Radiological Protection (w/ attachment / exhibit, enclosure) i l
I l
t
COMMONWEALTH OF PENNSYLVANIA ss.
COUNTY OF CHESTER J. B. Cotton, being first duly swom, deposes and says:
That he is Vice President of PECO Energy Company, the Applicant herein; that he has read the foregoing response to the request for additional information for Technical Specifications Change Request No.
96@-0 for Limerick Generating Station, Units 1 and 2, Facility Operating License Nos. NPF-39 and NPF-85, concerning proposed revisions to response time testing requirements for selected instrumentation, and knows the contents thereof; and that the statements and matters set forth therein are true and correct to the best of his knowledge, information, and belief.
/
/
Vice President Subscribed and swom to before me this dId day of 1998.
l LA.
1
/
/
Notary Public I
NOTARIAL SEAL OAMDL A.WALTON. Notary PutsBs g al PNadelphia. Phda.
gy wwion Expires May 28, l
l
i
)
l ATTACHMENT Limerick Generating Station, Units 1 and 2 Response to Request for Additional Information Questions for Technical Specification Change Request 96-09-0 i
l i
l Attachment Page 1 of 4 Limerick Generating Station, Units 1 and 2 Response to Request for Additional Information Technical Specifications Change Request 96-09-0 I
1 i
Question 1 PleaseJustify any systems for which RTTelimination was requested which were not identified in Table 2.
1 Specifically, please explain why item 12 on page 9, involving "High Pressure,'should be c3nsidered as a candidate forelimination of RTT.
l
Response
item 12 on page 9 of our submittal is the containment high pressure isolation signal for the primary
)
containment isolation trip function. This isolation signalis not specifically listed in Table 2 of NEDO-32291 A. However, Section 2 of Table 2 does include the isolation System actuation instrument loops for Primary Containment isolation System. This containment high pressure isolation signal is included in Table 4-1, item 1.b and Table 4-2, item 1.b (Fermi-2 and River Bend RTT Requirements Selected For Analysis) for the scope of trip functions for the primary containment isolation system evaluated as part of NEDO-32291 A. The isolation Actuation Instrumentation is discussed in Section 5.3.2. This containment high pressure isolation signal is also included in the Limerick Specific Technical Specification Markup Table for the primary containment isolation system contained in Appendix H of NEDO-32291 A.
Consequently, the high containment pressure isolation signal is included in Table 2 of NEDO-32291 A under Section 2 for Primary Containment isolation System actuation instrument loops.
The instruments used to monitor containment pressure and actuate the subject trip function are Rosemount pressure sensors and trip units identical to those Rosemount pressure sensors and trip units included in Table 1 of NEDO-32291 A. These instrument loops will operate in a fraction of a second consistent with other similar instrumentation evaluated in NEDO-32291 A.
i The containment high pressure isolation signal trip function is included in the scope of NEDO-32291 A, the instruments used to generate this trip function are identical to Rocemount pressure sensors and trip units evaluated in the NEDO, and this trip function is specifically identified in the Limerick specific Technical Specification markup. Consequently, NEDO-32291 A is directly applicable to this trip function and the trip function is a valid candidate for elimination of RTT.
Question 2 Since the elimination of RTT was only for specific equipment listed in Table 1 of the SER, pleaseJustify the elimination of equipment not on that list. Specifically, please state what characteristics of the following equipment make it suitable for elimination of RTT; Amerace ETR Relay Amerace EPG Relay Amerace GPIRelay Bailey 745 Switch GE CR2940 Relay i
I Attachment Page 2 of 4
Response
in our submittal for elimination of selected RTT we requested that various Amerace ETR, EGP and GP relays be eliminated. Amerace is used in the LGS compone.1t record list (CRL) description of these instruments from which our submittal tables were developed. Amerace is the manufacturer of Agastat GP/EGP family of relays that are part identified in our request. Therefore, all EGP and GP/GPl Agastat relays identified in our submittal request as Amerace are bounded by the SER Table 1. Likewise, the Bailey 745 " Switch" description used in the LGS CRL is identified in the NEDO and is identified in the SER 1
Table 1 as a 745 "Alarr.1 Unit" under "Extemal Devices." Therefore, the Bailey 745 " Switches" referenced in Table iof our submittal request are bounded by the SER Table 1.
Our original submittal incorrectly identified various ETR relays in the HPCI (Table 2) and RCIC (Table 4)
Steam Line DP-High. In accordance with NEDO-32291, Chapter 7, time delay relays are not to be included in elimination of RTT because they require calibration for response verification and to assure setpoint accuracy. The time delay relays are also tested as part of Logic System Functional Tests.
Therefore, in accordance with the NEDO, we withdraw the associated ETR relays from our request.
Likewise, the GE CR2940 relays identified in our submittal Table 1 - NSSS RWCU Differential Flow-High are switches, not relays, and are not identified in the SER Table 1. Therefore, in accordance with the NEDO, we withdraw the associated GE CR2940 switches from our request.
There are no changes necessary to the TS marked-up pages that were provided as part of our submittal.
Question 3 Since the Elimination of RTTis only for specific systeme when using specific equipment, please describe the method by which RTT will be reinitiated for those systems if the specific equipment now used were to be replaced in the future with equipment not listed on Table 1 of the SER.
Response
The UFSAR change that is being performed in conjunction with the Technical Specifications change request will be revised to include wording that indicates that the RPS instrumentation, Isolation instrumentation and ECCS instrumentation affected by this change are governed by the NEDO-32291 analysis and that replacement of the instruments identified by the NEDO will require an engineering evaluation similar to the NEDO, or RTT must be performed.
UFSAR Section 7.1.2.5.26," Regulatory Guide 1.118 (June 1978)- Periodic Testing of Electric Power and Protection Systems," will be revised to include a statement that reads similar to the following:
"RPS instrumentation, Isolation instrumentation, and ECCS instrumentation affected by this change are govemed by the NEDO-32291A. The analysis applies only to instrumentation specifically analyzed. The replacement of the instrumentation identified by the NEDO-32291A other than in-kind willrequire an engineering evaluation similar to that contained in NEDO-
+
32291A, or periodic RTTof the replacement instrumen% tion must be resumed."
l i
l l
)
i
I l
l Attachment l
Page 3 of 4 l
l l
Question 4 In those cases where only a portion of the actuation time is no longer measured, but testing for the remainder of the system is stillrequired, please explain what estimated response time will be used for those portions of the system no longer tested when determining overall system response time. What statistically valid analysis was done to ensure this time is appropriate? As an example, if sensor response time testing requirements are eliminated, but there is still a requirement to determine the overall system l
response time, will the manufacturer's numbers be used? If historical data is used, by what method is this data analyzed to determine the maximum response time possible without affecting calibration or other periodic test? If the manufacturer's response times are to be used, what will be done in those cases where the manufacturer does not provide response time values?
Responw The estimatej response time that will be used for those portions of the system no longer tested, when determink,g overall system response time, is listed in Table 1.
The value for estimated response time for the RWCU differential flow trip function is based on historical test data. This value is a combined vaiue for the Bailey Controls trip units, square root converters, signal converters, Agastat (Amerace) relays, and Eagle Timers used to provide the trip functions. A sample of response time test data from 1992-1996 was retrieved and evaluated using standard MATHCAD (Version
- 6) functions for determining the mean (mean) and standard deviation (stdev) for a sample population. The estimated response time was verified to be greater than the mean plus two standard deviations. Refer to i
Exhibit page 6 for the sample data, evaluation, and results.
i The values for estimated response time for Rosemount differential pressure transmitters are based on historical test data. A sample of response time data from 1992-1998 was retrieved and evaluated using standard MATHCAD (Version 6) functions as described in the previous paragraph. Separate evaluations i
are provided to correspond to groupings of trip functions and allotted response times used in the response time test procedures. Refer to Exhibit pages 1-5 for the sample data, evaluations, and results.
The value for estimated response time for Rosemount trip units is based on engineering judgment. The value is supported by testing performed by General Electric Co., to support the Analog Transmitter / Trip j
Unit System For Engineered Safeguard Sensor Trip inputs upgrade project in LTR NEDO-21617-A.
Testing of a model 510 master / slave trip unit tandem combination resulted in a maximum measured time delay of 1.5 msec. A more conservative value of 2 msec will be used. Based on the similarity of design of the model 510 and 710 trip units, this estimated response time will also be used for model 710 trip units.
Response time test procedures verify the combined response time of trip units and Agastat relays.
Consequently, historic response time data is not available for the trip unit alone. However, since the response time of the trip unit is expected to be two orders of magnitude less than the transmitter response time, and 3-4 orders of magnitude less than the trip function response time, the trip unit contribution to trip function response time is insignificant.
The value for estimated response time for Agastat (Amerace) general purpose relays is based on manufacturers supplied data.
l
\\
h S
e t
ce c
c c
c c
o ag N
s e
e e
e e
N O
c c
s s
s s
s
(
t t
a t
AP P
a:
c
- t l
e m
m m
m m
e Sl n a s E iooo m 0
0 5
0 0
s t
0 3
5 5
8 7
RCCT2 2
2 3
4 4
4 Y
G sa O 'e t
t t
t t
t r
s s
s s
t s
L a
e e
e e
s r d g
e Ou T
ce int T T
T T
e t
Dt d r nla la l
l l
l a
a a
a Oah ee c
c c
c emi i
ir ic ic ir Hf s r
r r
r n
ui go a o a o a o a o a o a T nb igd s l
t t
t t
t t
E a u n uia t
t t
t t
t s
s iaia is s
s aiaia MMP EJHD HDHD HDHDHD ee r r le le le uu ss v
v v
ss wwe e
e ee er r lool L
L l
ee rPPe FF r r
r L
N r r r
uu u e
e e
AI yyu yyt O
ss t
t sl l
s l
a a
a I
ss spps lpp T
T ee eppe ppW W
W N
r PPrP uur uul le l
R C s s
N n n
l l
l r
s s
s E
o leet Uio it ommroww mms s
s FH e
e e
FG t
F oo aa s
a a
wwcaatcl l
eeV w
V V
I I
c yyaee aFF l
r D H o
i r r et t
t t r
r Tlp F
o o
U R
I Cc c
c C W t
E p p
I C
CC CI a L
t t
t n
O F a A
hhhCI i i w
a a
o g g gP C o W W PC e S
e e
WL All l
l C
i SA A
HHHHRLRR HRR M
R R
RF d
n a
R n
E io R
U ta T
t t
t t
t t
t n
C n
n n
n n
n T
e A
u u
u u
u u
o o
o o
o o
A m
F ta YYYT u
Ut m
m m
m m
m EEES r
N s e
e e
e e
e LLLA a
s s
s s
s s
t s
Ag o
o o
o o
o AAAG I
I I
n MA R
R R
R R
R BBBA i
d e
t c
R e
E l
s T
e S
it 9
O n
R O
/
r U
5 5
7 4
5 E
o TT R f
ip C
C C
C C
I RE R
R R
R R
N s
r e
T U ER Y
)
m s
0 VA A 1
1 1
1 1
5 5
5 5
5 PNUL I
i
(
1 T
L P 7
1 1
1 1
1 ROQE EG 1
1 1
1 1
e
/
TCSR
/
/
/
/
/
s D P 3
3 3
3 3
n OG 0
5 5
5 5
5 520l P
1 1
1 1
1 1
455 o
ME 5
1 1
1 1
1 p
777G s
eR d
D i
T n n
e
/
S A
ta
)
m D'
77 6789*
5DD
//
(
4'0888021 55*1 8888 3 AA t
I s
s 0
1 s
o o
9575591 4 00 0000 0 43 D 8
8 9
00000000NN 0 NNNN 0 0
00/
6 E
Ni it t
N N
N66A E a a
N N N N N N N N * *- N KK6 Mic ic
- * * * * * *
- 59
- 1 1 1 1
- 1 P lp lp 22259244 54 4444 2
2 2
4*-
K E
I p
p 44454444 00 0000 4 44 L
U a a
00000000TT0 TTTT0 0
S 44 8
- - 4 4
4 1
B Qll l
TTTTTTTTDDT DDDDT T
DYY2 l
A EA A
PPPPPPFFPPL PPPPL L
FFFB T
l i
l l
F EXHIBIT Instrument Response Time Data i
i l
l l
l
s ALLOTTED RESPONSE TIME = 200 msec
. FUNCTIONS: RWCU Flow, Reactor Pressure Rosemount Transmitters, Range Codes 5,9 Units = milliseconds 1
l
~290'
'210'
' 60 '
30' 50 -
280-200
> 40 -
30 :
'50" 80 200-250 40 -
60 40 70 210 220 40 '
40 60 110 I
50 BC1 :
BC2 =
90 120 110 40 60 60 pg D2 60 110 90 70 -
30 70 50 110 110
~30 30 ;
40 120 90 100 30 20 60 g
90,
,100, 30 '
40 '
20 E2 = 50
- 20 ~
20 30 50
.30 20 l 40 90 El :
90 50
^O C3 ~ stack (BCl,DI)
CS = stack (C3,El) 50 30 L
20 C4 e stack (BC2,D2)
C6 : stack (C4,E2) 30 60 20 C 1 stack (C5,C6) nc = rows (C) nc = 87 20-30 -
30 40 CALCULATE THE MEAN VALUE 30 30 MEANC = mean(C)
MEANC = 71.034 30 30 CALCULATE THE STANDARD DEVIATION 30 p
STDC -stdev(C)E SE = 60.097 nc 1 l
. CALCULATE THE UPPER BOUND FOR THE ALLOTTED RESPONSE TIME THe upper bound is ARTC ARTC - MEANC - (2 STDC) - ARTC = 191.229 Page1
ALLOTTED RESPONSE TIME = 230 msec FUNCTIONS: Reactor VesselWater Level Rosemount Transmitters, Range Code 5-50 50 60 70 Units = milliseconds.
70 110 80 110 60 '
60 40 60 31 _
g 210 -
130 J ' utack(J1,J2) nj rows (J) nj = 24 j
140 100 50 '
130 O
70 CALCULATE THE MEAN VALUE q
- 140, 160 MEANJ = mean(J)
MEANJ = 93.333 130i 90 CALCULATE THE STANDARD DEVIATION stdev(J), 3 STDJ STDJ - 42.902 g
CALCULATE THE UPPER BOUND FOR THE ALLOTTED RESPONSE TIME The upper bound is ARTG ARTJ MEANJ - (2 STDJ)
ARTJ = 179.137 Page 2 l
i j
i
i ALLOTTED RESPONSE TIME = 355 msec FUNTIONS: Main Steam Line Flow Rosemount Transmitters, Range Code 7 Units = milliseconds 320
.40 60 40
^50 20:
280
.70 60 40 50 20-290
- 50 60 30 40 20 260
'60 30 40 40 20 290 60 30 20 50 20 -
290
+40 30 40 50 20 '
270
'50 30 40 '
40 30-All :
A12 60 A13 60 A21 A22 ~ 50 A23 = 10-270 60 50 30 40 20 320 60 60 30 40 20 330 40 30 30 40 20 300 70 60 30 40 20 7
230
.50 30 30 40 20 280
'60 40 30 50 20 300
.40 30 30 40 20 280 30 30 30 40 20 AI stack ( Al1 Al2)
A3 stack ( A1, A13)
A2 stack ( A21, A22)
A4 = stack ( A2, A23)
A stack ( A3, A4) na rows ( A) na = 96 Calculate the mean value MEANA mean( A)
MEANA = 80.521 Calculate the standard deviation STDA stdev(A)-
,, y STDA = 95.679 CALCULATE THE UPPER BOUND FOR THE ALLOTTED RESPONSE TIME The upper bound is ARTA ARTA ' MEANA - (2 STDA)
ARTA = 271.879 Page 3 i
l l
l i
I L
.)
l l
ALL.OTTED RESPONSE TIME = 450 msec l
FUNCTIONS: Reactor Vessel Water Level I
Rosemount Transmitters, Range Code 4 60 50 90 50 Units = milliseconds 390 110 I
210 90 60' 80 0
i G1 G2 210 150 l
G stack (Gl,G2) ng rows (G) ng = 24 140 100 l
80 90 l
60 70
' CALCULATE THE MEAN VALUE 210 130 MEANG = mean(G)
MEANG = 122.5 150 270 i-CALCULATE THE STANDARD DEVIATION l
STDG stdev(G)
"E -
STDG = 84.094 ng 1 l
i CALCULATE THE UPPER BOUND FOR THE ALLOTTED RESPONSE TIME i
The upper bound is ARTG ARTG MEANG -- (2 STDG)
ARTG = 290.687 i
l l
Page 4 l
l 1
t l"
All,OTTED RESPONSE TIME = 480 msec FUNCTIONS: REACTOR VESSEL WATER LEVEL Rosemount Transmitters, Range Code 5 70
~ 90 280 310 Units = milliseconds 80 140 470 490 60 70 340 420 90 100 440 410 50 100 110 70 120 130 73 _ 450 g, 120 80 80 F stack (F1,F2) nf - rows (F) nf = 48 90 60 190 120 450 110 60 90 t
CALCULATE THE MEAN VALUE 80 90 MEANF mean(F)
MEANF = 162.708 140 160 130
.100 60 70 CALCULATE THE STANDARD DEVIATION 70 50 170 130 nf
- 'b -
STDF = stdev(F) gp STDF = 133.397 CALCULATE THE UPPER BOUND FOR THE ALLOTTED RESPONE TIME 6
The upper bound is ARTF ARTF MEANF (2 STDF) ARTF = 429.501 l
i r
j Page5
ALLOTTED RESPONSE TIME = 47 see FUNCTIONS: RWCU DIFFERENTIAL FLOW Bailey Controls, Model 745,750,752; Agastat GPl Relays Units = seconds 45.3 44.5 45.2 44.5 46.5 44.2 46.4 44.6 44.5 HI H2 45.8 45 H : stack (HI,H2) nh rows (H) nh = 22 44.7 45.45 44.5 45 45 44
' CALCULATE THE MEAN VALUE 45.5 45 45 MEANH mean(H)
MEANH = 45.061 CALCULATE THE STANDARD DEVIATION STDH stdev(H)-,nhT-STDH = 0.645 1
CALCULATE THE UPPER BOUND FOR THE ALLOTTED RESPONE TIME The upper bound is ARTF ARTH : MEANH-(2 STDH)
ARTH = 46.351 T
Page 6 i
_ _ _ _ _ _ _ _ _ _ _ _ _ _ _ - _ _