RBG-26261, Submits Editorial Info Re 870511 & 15 Requests for Extension of Tech Spec Surveillance Intervals.Replacement Pages Encl

Submits Editorial Info Re 870511 & 15 Requests for Extension of Tech Spec Surveillance Intervals.Replacement Pages Encl

ML20235T385
Person / Time
Site:	River Bend
Issue date:	07/15/1987
From:	Booker J GULF STATES UTILITIES CO.
To:	NRC OFFICE OF ADMINISTRATION & RESOURCES MANAGEMENT (ARM)
References
RBG-26261, TAC-65129, TAC-65396, TAC-65397, NUDOCS 8707220121
Download: ML20235T385 (16)

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GULF ! STATES UTILITIES COMPANY RfVER BEND STATION *OST OFFICE eor 220 ST FRANC 83VILLE.LOutSIANA 70776 AREA CODE 604 636 6094 346 8661 July 15, 1987-

.RBG-26261

. File-Nos. G9.5 G9.25.1.4 U.S. Nuclear Regulatory, Commission-

' Document Control Desk Washington, D.C. 20555 Gentlemen:

' River Bend Station - Unit 1

. Docket No. 50-458 This ' letter provides editorial'information'as. discussed with the Staff regarding Gulf States Utilities Company's (GSU) May-11.and May 15,n 1987 ,

(RBG-25917 and-RBG-25955) submittals ~ on requests for extension of technical specification surveillance intervals. The attached pages will

-replace. each of. those _: respective pages previously submitted... In addition, GSU's' March 10, 1987 letter, Attachment 4, requests exemption .

under' '10CFR50.12 (a) (2) . . The' special circumstance -for which- an-exemption is being requested it under Item (v). If further information is required, please contact Mr. Rick J. Ring at (504) 381-4146.  !

Sincerely,

, F. Au/p '

J. E. Booker Manager, River Bend Oversight River Bend Nuclear Group  !

JEB/ ERG / ch Attachments cc: U.S. Nuclear Regulatory Commission Region IV 611'Ryan Plaza Drive, Suite 1000 Arlington, TX '76011 NRC Resident Inspector P.O. Box 1051 St. Francisv111e, LA 707T5 0

B707220121 B70715 B DR ADDCK 050 I'

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ATTACHMENT 1 REPLACEMENT PAGES FOR ATTACHMENT 1 OF GSU'S MAY 15, 1987 LETTER (2 Sheets) l l

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ATTACHMENT 1 GULF STATES UTILITIES COMPANY RIVER BEND STATION DOCKET 50-458/ LICENSE NO. NPF-47 REACTOR PRESSURE VESSEL STEAM DOME-HIGH LICENSING DOCUMENT INVOLVED TECHNICAL SPECIFICATIONS ITEMS: 4.3.1.2 PAGE 3/4 3-1 Table 4.3.1.1-1 3/4 3-7 4.3.2.2 3/4 3-9 Table 4.3.2.1-1 3/4 3-11 3/4 3-29 REASON FOR REQUEST The RBS Technical Specifications require many surveillance tests be performed every eighteen (18) months (plus a maximum extension defined by Specification 4.0.2). This proposed change is e request to extend ,

the interval for the subject Surveillance Requirement to the scheduled r refueling outage (09-15-87) .

A one time extension of approximately 31 days is being requested in accordance with 10CFR50.90 extends the interval for channel calibration and logic system functional test (LSFT) for the reactor vessel steam dome p'. essure - high reactor protection system instrumentation and the react or vessel pressure high isolation actuation instrumentation from 18 months to the first refueling outage. Gulf States Utilities Company (GSU) has and will make a good faith effort to conduct the above surveillance on the current frequency if an outage of sufficient duration occurs. The purpose of this change is to allow the above listed surveillance to be delayed from their scheduled due date of Augus t: 15, 1987 until the first refueling outage scheduled to begin September 15, 1987. Maintenance or calibration of instruments on the reactcr pressure vessel sensing legs have resulted in spurious Engineered Safety Features actuations. GSU has determined that these surveillance should be performed while in cold shutdown due to the high risk of placing the plant in a scram condition. For the plant to shutdown solely to perform surveillance would cause an unnecessary th- mal transient on the plant. GSU requests to amend the subject Technical Specifications contained in Appendix A to the River Bend Station (RBS) Operating License, as discussed below, to perform the subject test during a scheduled refueling outage. Should these proposed changes not be granted in a timely manner, GSU may be forced to implement an unnecessary outage during the first cycle.

DESCRIPTION Reactor High Pressure may indicate a threat to the reactor coolant pressure boundary or result in a collapse of voids such that fuel barrier damage may occur. This condition results in a reactor scram which counteracts the pressure increase by quickly reducing core fission heat generation. Residual Heat Removal (RHR) System isolation on g l

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' INSTRUMENTATION SURVEILLANCE REQUIREMENTS-1 4.3.2.1 Each isolation actuation instrumentation channel shall be demonstrated  !

OPERABLE by the performance of the CHANNEL CHECK, CHANNEL FUNCTIONAL TEST and CHANNEL CALIBRATION operations for the OPERATIONAL CONDITIONS and at the frequencies shown in Table 4.3.2.1-1. l 4.3.2.2 LOGIC SYSTEM FUNCTIONAL TESTS and simulated automatic operation of i all channels shall be performed at least once per 18 months.* I 4.3.2.3 The ISOLATION SYSTEM RESPONSE TIME of each isolation trip function shown in Table 3.3.2-3 shall be demonstrated to be within its limit at least once per 18 months. Each test shall include at least one channel per trip

! system such that all channels are tested at least once every N times 18 months, I where N is the total number of redundant channels in a specific isolation trip l system.

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• Logic System Functional testing period may be extended as identified by notes C and D on Table 4.3.2.1-1.

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l' ATTACHMENT 2 REPLACEMENT PAGES FOR ATTACHMENT 2 0F GSU'S MAY 15, 1987 LETTER l- (2 Sheets) l l

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As additional justification, note (b), to Technical Specification Table-4.3.2.1-1, requires calibration of the trip unit setpoint at least once per 31 days. . Therefore, this requested change only involves calibration of the transmitters, calibration of the trip unit analog meters, gross fail setpoints, and loop setpoints. We channel functional test also required by the channel calibration is performed monthly.

With respect to the requested extension of the surveillance interval for the logic system functional test, an analysis was . performed using a fault tree nodel of the MSIV isolation logic. W e basic event failure rates were taken fr m the BWR individual plant evaluation methodology and are based upon conservative WASH-1400 data. The basic event failure probabilities were detertrined for surveillance intervals of 18 nanths and 24 nonths The failure of the MSIV_jsolation logic was calculated to be 1.06 x 103 / demand and 1.41 x 10 /dmand for 18 and 24 month l intervale respectively. mis does not represent an appreciable increase in the probability for failure of the MSIV isolation logic in a high main steam line flow event.

he River Bend Station Final Safety Analysis Report (PSAR) (Section 15.6.4) does take credit for the main steam line isolation function initiated by these instruments during a main steam line pipe break outside containment. However, the function of these instruments is not being altered. Credit is not taken for these instruments in any other FSAR analysis.-

NO SIGNIFICANT HAZARDS CONSIDERATION ,

The action (s) specified by this Technical Specification change involves no Significant Hazards Considerations (as defined in 10CFR50.92) as specified below:

1. 'No significant increase in the probability or the consequences of an accident previously evaluated results from this change because:

We existing Technical Specification Trip Setpoint and Allowable Value can acccrimodate an additional calculated drift for a 30 nonth channel calibration interval. Furthermore, the increased LSFT surveillance interval results in no significant probability of an MSIV isolation logic failure.

2. This change would not create the possibility of a new or different kind of accident frm any accident previously evaluated because: j l

his change does not delete or reduce the functional capability of q the MSL Flow -

High instrumentation. Therefore, no new kind of l  !

accident can result frm this change and the response to an event '

will be as analyzed.

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[ INSTRUMENTATION SURVEILLANCE REQUIREMENTS 4.3.2.1 Each Isolation actuation instrumentation channel shall be demonstrated OPERABLE by the performance of the CHANNEL CHECK, CHANNEL FUNCTIONAL TEST and l CHANNEL CALIBRATION operations for the OPERATIONAL CONDITIONS and at the frequencies shown in Table 4.3.2.1-1.

4.3.2.2 LOGIC SYSTEM FUNCTIONAL TESTS and simulated automatic operation of ,

all channels shall be performed at least once per 18 months.* l. l 4.3.2.3 The ISOLATION SYSTEM RESPONSE TIME of each isolation trip function shown in Table 3.3.2-3 shall be demonstrated to be within its limit at least once per 18 months. Each test shall include at least one channel per trip system such that all channels are tested at least once every N times 18 months, where N is the total number of redundant channels in a specific isolation trip system.

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• Logic System Functional testing period may be extended as identified by notes C and D on Table 4.3.2.1-1.

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.6 ATTACIDfENT 3 REPLACEMENT PAGE FOR ATTACinfENT 3 0F GSU'S MAY 15, 1987 LETTER O Sheet) 1 l

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1 INSTRUMENTATION SURVEILLANCE REQUIREMENTS 4.3.2.1 Each isolation actuation instrumentation channel shall be demonstrated OPERABLE by the performance of the CHANNEL CHECK, CHANNEL FUNCTIONAL TEST and CHANNEL CALIBRATION operations for the OPERATIONAL CONDITIONS and at the frequencies shown in Table 4.3.2.1-1.

4.3.2.2 LOGIC SYSTEM FUNCTIONAL TESTS and simulated automatic operation of -

a all channels shall be performed at least once per 18 months.* l 4.3.2.3 The ISOLATION SYSTEM RESPONSE TIME of each isolation trip function shown in Table 3.3.2-3 shall be demonstrated to be within its limit at least once per 18 months. Each test shall include at least one channel per trip system such that all channels are tested at least once every N times 18 months, where N is the total number of redundant channels in a specific isolation trip system.

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• Logic System Functional testing period may be extended as identified by notes C and D on Table 4.3.2.1-1.

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'i REPLACEMENT PAGE FOR ATTACHMENT 2 0F GSU'S MAY 11, 1987 LETTER. l (l' Sheet)  !

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INSTRUMENTATION SURVEILLANCE REQUIREMENTS 4.3.2.1 Each isolation actuation instrumentation channel shall be demonstrated i OPERABLE by the performance of the CHANNEL CHECK, CHANNEL FUNCTIONAL TEST and CHANNEL CALIBRATION operations for the OPERATIONAL CONDITIONS and at the frequencies shown in Table 4.3.2.1-1.

4.3.2.f LOGIC SYSTEM FUNCTIONAL TESTS and simulated automatic operation of  ;

all channels shall be performed at least once per 18 months.* l 4.3.2.3 The ISOLATION SYSTEM RESPONSE TIME of each isolation trip function shown in Table 3.3.2-3 shall'be demonstrated to be within its limit at least once per 18 months. Each test shall include at least one channel per trip system such that all channels are tested at least once every N times 18 months, where N is the total number of redundant channels in a specific isolation trip  ;

system.

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• Logic System Functional testing period may be extended as identified by notes C and D on Table 4.3.2.1-1.

RIVER' BEND - UNIT 1 3/4 3-11

ATTACHMENT 5 REPLACEMENT PAGES FOR ATTACHMENT 3 0F GSU'S MAY 11, 1987 LETTER (4 Sheet) l 1

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i' The challenges made to this. station's ECCS systems has.been quite

. extensive as evidenced by the indepth testing during the preoperational and power ascension test phase and as evidenced during.the site LOP of-January 1986. The response to these challenges and tests by the' plants systems'has been more than adequate and has1 8 ven the operating staff of this station confidence in these systems response to any required demand

for operation.

In addition to- the extensive testing conducted prior to commercial

'. operation..there is a considerable amount of testing.that continues to l- he conducted- to' meet the Technical Specification System / Component ,

requirements for operability. Some of this testing includes performance i of channel checks, channel calibrations, and response time measurements for all ECCS and Plant Isolation / Initiation Instrumentation. In

addition, partial Logic System Functional Tests are performed simulating LOP /LOCA conditions to verify response of relaying required for initiations and isolations for many of these same instruments.

Quarterly Inservice Inspection Pump and Valve tests are performed to measure pump and valve performance in accordance with Section 4.0.5 of Technical Specifications and ASME Code XI. These tests determine a pump or valve's ability to perform to design conditions and will cause an L item that shows a trend toward sudden degradation to be tested on a more l frequent bases to ensure its continued operability. All of the ECCS

injection and opray systems are tested in this fashion. In addition.

L ASME XI requires quarterly testing of the secondary containment I

ventilation system and the Standby Service Water system, for which satisfactory test results have been received to date. Similar testing

' occurs for HVAC equipment required for safe shutdown and includes l- monthly operability checks on such components as Standby Gas Treatment, L Annulus Mixing, Containment Unit Coolers, Fuel Building Ventilation, and Control Building Ventilation. The Divisien I Diesel Generator, having shown a questionable start reliability, has had an increase in' its surveillance frequency such that it is now tested weekly. Division II Diesel Generator however, continues to be tested monthly. These tests include starting the diesels from a standby condition and measuring its ability to come up to fully rated speed and voltage in a strict time requirement. The diesels are then fully loaded for at least one hour and monitored for system leaks and performance. The result of .this L testing is that all systems required to support the plant during a LOP l or LOCA are maintained in a maximum state of readiness exclusive of the i 18 month ECCS tests. The reliability of these systems due to I

surveillance testing are greatly enhanced in their ability to perform in such an event.

As was stated earlier, a LOP event is classified as an " expected operational transient"; an event that actually occurred during this operating cycle (See LER-86-002) . The systems required to support safe shutdown of the plant during that event performed well. The cause for initiating the event has been corrected reducing considerably the probability of a recurrence. A LOCA event however, is described as a limiting fault. This is an incident that is not expected to occur but '

is postulated because the consequences may result in the release of significant amounts of radioactive material. This type of event is referred to as a " design basis (postulated) accident". The probability of the occurrence of such an event is given as less than one tenth of one percent over a 40 year cycle of the plant. This low probability is based on leak detection systems which would reveal a crack in any pipe

INSTRUMENTATION SURVEILLANCE REQUIREMENTS I

4.3.2.1 Each isolation actuation instrumentation channel shall be demonstrated OPERABLE by the performance of the CHANNEL CHECK, CHANNEL FUNCTIONAL TEST and CHANNEL CALIBRATION operations for the OPERATIONAL CONDITIONS and at the frequencies shown in Table 4.3.2.1-1.

4.3.2.2 LOGIC SYSTEM FUNCTIONAL TESTS and simulated automatic operation of all channels shall be performed at least once per 18 months.* l 4.3.2.3 The ISOLATION SYSTEM RESPONSE TIME of each isolation trip function shown in Table 3.3.2-3 shall be demonstrated to be within its limit at least I once per 18 months. Each test shall include at least one channel per trip system such that all channels are tested at least once every N times 18 months, where N is the total number of redundant channels in a specific isolation trip system.

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• Logic System Functional testing period may be extended as identified by  !

notes C and D on Table 4.3.2.1-1.

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1. The specified 18 month interval during the first operating cycle may be extended

.to concide with completion of the first refueling outage scheduled to begin 9-15-87 for those items noted on Table 3.6.4-1.

CONTAINMENT SYSTEMS 3/4.6.4 PRIMARY CONTAINMENT AND ORYWELL ISOL/.fl0N VALVES LIMITING CONDITION FOR OPERATION I- 3.6.4 The primary containment and drywell isolation valves in Table 3.6.4-1 shall be OPERABLE with isolation times less than or equal to those shown in Table 3.6.4-1.

APPLICABILITY: OPERATIONAL CONDITIONS 1, 2, and 3.

ACTION:

With one or more of the primary containment or drywell isolation valves shown in Table 3.6.4-1 inoperable, maintain at least one isolation valve OPERABLE in each affected penetration that is open and, within 4 hours4.62963e-5 days <br />0.00111 hours <br />6.613757e-6 weeks <br />1.522e-6 months <br />, either:

a. Restore the inoperable valve (s) to OPERABLE status, or

b. Isolate each affected penetration by use of at least one deactivated automatic valve secured in the isolated position,* or

c. Ieolate each affected penetration by use of at least one closed manual valve or blind flange.*

d. The provisions of Specification 3.0.4 are not applicable provided t

that the affected penetration is isolated in accordance with ACTION b, or c. above, and provided that the associated system, if applicable, is declared inoperable and the appropriate ACTION statements for that system are performed.

Otherwise, be in at least HOT SHUTDOWN within the next 12 hours1.388889e-4 days <br />0.00333 hours <br />1.984127e-5 weeks <br />4.566e-6 months <br /> and in COLD SHUTDOWN within the following 24 hours2.777778e-4 days <br />0.00667 hours <br />3.968254e-5 weeks <br />9.132e-6 months <br />.

SURVEILLANCE REQUIREMENTS 4.6.4.1 Each isolation valve shown in Table 3.6.4-1 shall be demonstrated OPERABLE prior to returning the valve to service, after maintenance, repair or replacement work is performed on the valve or its associated actuator, control or power circuit, by cycling the valve through at least one complete cycle of full travel and verifying the specified isolation time. l 4.6.4.2 Each automatic isolation valve shown in Table 3.6.4-1 shall be demon-strated OPERABLE during COLD SHUTDOWN or REFUELING at least once per 18 months # l by verifying that, on an isolation test signal, each automatic isolation valve actuates to its isolation position.

4.6.4.3 The isolation time of each power operated or automatic valve shown in Table 3.0.4-1 shall be determined to be within its limit when tested pursuant to Specification 4.0.5.

• Isolation valves closed to satisfy these requirements may be reopened on an intermittent basis under administrative controls.

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