View source for JPN-96-047, Requests That NRC Review Encl Discrepancies to SERs Associated W/Ts Amends 232 & 233 & Provide Corrected Documentation

{{Adams
| number = ML20135A024
| issue date = 11/22/1996
| title = Requests That NRC Review Encl Discrepancies to SERs Associated W/Ts Amends 232 & 233 & Provide Corrected Documentation
| author name = Cahill W
| author affiliation = POWER AUTHORITY OF THE STATE OF NEW YORK (NEW YORK
| addressee name = 
| addressee affiliation = NRC OFFICE OF INFORMATION RESOURCES MANAGEMENT (IRM)
| docket = 05000333
| license number = 
| contact person = 
| document report number = JPN-96-047, JPN-96-47, TAC-M92631, TAC-M93725, TAC-M94084, TAC-M94210, TAC-M94638, NUDOCS 9612030037
| document type = CORRESPONDENCE-LETTERS, INCOMING CORRESPONDENCE
| page count = 9
| project = TAC:M92631, TAC:M93725, TAC:M94084, TAC:M94210, TAC:M94638
| stage = Other
}}

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            . 123 Main Street
  .            White Plains. New York 10601 914-681-6840 914-287-3309 (FAX)
       #> NewYorkPower
       & Authority                                                                                   wun.m a. c si,i. s,.
Chief NuclearOfficer November 22,1996 JPN-96-047                                      ,
U.S. Nuclear Regulato y Commission Attn: Document Control Desk                                                                                      .
Mail Station P1-137 Washington,' D.C. 20555

==SUBJECT:==
James A. FitzPatrick Nuclear Power Plant Docket No. 50-333 Submittal of Corrections to SERs Associated with                                    i Technical Specification Amendments 232 and 233                                      !
1

==Reference:==
: 1. NRC letter, K. Cotton to W. J, Cahill, dated A'ugust 16,1996,                 l Issuance of Amendment 232 for James A. FitzPatrick Nuclear Power Plant (TAC Nos. M92631, M93725. M94084 and M94210)                      i
: 2. NRC letter, K. Cotton to W. J. Cahill, dated October 2,1996, Issuance of Amendment 233 for James A. FitzPatrick Nuclear Power Plant (TAC No. M94638)

==Dear Sir:==
                                  -w During the implementation reviews of Amendments 232 and 233 to the James A. FitzPatrick                          i five discrepancies in the text of the amendment Safety Evaluation Reports SERs were identii
        . Technical Specifications (References 1 and 2)f,ed. Four of th                                                   ?
believed to be typographical errors. The fifth discrepancy is the inclusion of information in the SER for Amendment 233 which is no longer applicable to the Technical Specifications as the                       l referenced surveillance requirement was deleted by Amendment 231. These discrepancies                            J are minor and do not alter the bases for either SER or their conclusions.                                         l The specific discrepancies are described in detail on Attachments 1 and 2. Please review these discrepancies and provide corrected documentation.
If you have any questions, please feel free to contact Charlene Faison.
Very truly yours,                               j
                                                                                                                          \
:: = , -                                 ;
William J. Cahill, Jr.
Chief Nuclear Officer Attachments as Stated cc:     see next page 9612030037 961122 ADOCK 05000333 PDR P                           PDR                                                                              [,/  '
290106

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:                      cq:    Regional Administrator
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               .              U. S. Nuclear Regulatory Commission 475 Allendale Road j                    ,
                           . King of Prussia, PA 19406 Office of the Resident inspector
                             - U. S. Nuclear Regulatory Commission P.O. Box 136
:                            Lycoming, NY 13093 Ms. K. Cotton, Acting Project Manager Project Directorate 1-1
:                             Division of Reactor Projects-l/ll U. S. Nuclear Regulatory Commission i
Mail Sto 14 B2 Washin ton, DC 20555 4                             Mr. F. William Valentino, President j                             New York State Energy, Research,
'                             and Development Authority 2 Rockefeller Plaza
,                             Albany, NY 12223-1253 1.
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Attachment 1 to JPN-96-047 Discrepancies in SER for FitzPatrick TS Amendment 232 l
                                                                                                                    \
.i There is an error on pages 10 and 11 of the Safety Evaluation regarding the frequency of        '
station battery pe,rformance (or modified performance) testing for battenes which have reached 4
85% of their service life. These errors and their corrections are indicated on the attached marked-up pages.
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,                                                        2 f          recommendations of IEEE-450-1995.         Based on the above, the use of the modified         ,
             . performance test'is acceptable.        .
4.
,             The proposed requirements for battery testing are consistent with those stipulated in IEEE Standard 450-1995. The performance or modified performance 4              testing of TS 4.9.E.4, in conjunction with the other requirements in TS 4.9.E, provide a high level of confidence that the condition of the station batteries will be detected prior to degradation leading to battery inoperability.
4              Potential station battery and charger operability problems would be detected by the following combination of on-line tests and inspections:
(a)  Every week the specific gravity, voltage and temperature of the pilot l
cell and overall battery voltage is measured.
:                (b)  The 125V DC system is also subjected weekly to visual inspections and                 )
f tests for cracked cells or electrolyte leakage, corrosion at either                    l terminals or connectors, electrolyte level within the level r.arking on                '
the jars, and the proper battery charger current and voltage output. A weekly battery charger visual inspection is also required by 1$.t.
.                (c) A quarterly stai.lon battery surveillance test measures the volttge of                  j
,                     each cell to the nearest 0.0iV, the specific gravity of each ce;1, and                 i the temperature of every fifth cell.                                                   I 1                                                                                                            l
,                (d)   " Accelerated performance testing (or modified performance test) shall be l                 conducted on any battery:
!                      a)     Annually if capacity drops more than 10% from its previous performance test (or modified performance test).
b)     Annua"v if capacity is below 90% of manufacturer's rating c)      Annually if it has reached 85% of its service life with capacity
        ,4, .                  s 00% of manufacturer's rating.                                               l d)      Once every 24 months if it has reached 85% of its service life with capacity 2100% of the manufacturer's rating."
Thus, adequate on-line surveillance testing and maintenance pograms are in place to ensure that the station batteries and their associated chargers are functioning properly. This extensive on-line testing program establishes the operability of the batteries while testing performed during each refueling outage demonstrates the battery's ability to meet the design requirements of the system.
The 125V DC station battery s;rvice and charger performance to veillance test required by current TSs 4.9.E.' and 4.9.E.5 can be safely ext uded to accomadate a 24-month operating cycle because:
: 1)   Service and performance testing of battery capability is consistent with I                 the recommendations of IEEE 450-1995.

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                                                     )    $         2) On-line testir.g provides adequate assurances that station battery and charger performance problems would be detected through the weekly, quarterly'and annual surveillances, if certain conditions ' exist.
: 3) A review of previous discharge tests up through 1995 indicate that the acceptance criteria has always been satisfied for this test.
: 4) Computer trending of the specific gravity of the indiyidual cells should indicate potential problems with the battery.
e           Based on the associated surveillance tests for current TSs 4.9.E.3 and 4.9.E.5 discussed above, the proposed TS surveillance test intervals can be safely extended to accommodate a 24 month operating cycle.
Technical Specification 4.9.E.4 requires a performance test of the batteries 4
at 5-year (i.e., 60-month) intervals. The frequency of this surveillance test requirement will not be changed to accommodate the 24-month operating cycle.
It is proposed that the TS be revised to state that the performance test shall verify the battery capacity is at least 80% of the manufacturers rating. This acceptance criterion is consistent with the recommendations of IEEE-450-1995.
A capacity of <80% shows that the rate of battery degradation is increasing, even if there is ample capacity to meet the load requirement.
i New TS 4.9.E.5 proposes accelerated performance testing requirements for any battery that shows signs of degradation or has reached 85% of its service l
life. Degradation is indicated when battery capacity drops by more than 10%
relative to its capacity on the previous performance test (or modified performance test), or when its capacity is below 90% of the manufacturers j          rating. If the battery shows degradation, or if it has reached 85% of its expected life and capacity is <100% of the manufacturers rating, the surveillance frequency is reduced to 12 months. However, if the battery shows no degradation but has reached 85% of its expecte'd life, the surveillance go requency is only reduced to 24 months for batteries that retain capacity 5 00% of the manufacturers rating. These performance testing requirements are onsistent with those stipulated in IEEE standard 450-1995, and are acceptable.                             -
2.2.3       LPCI Station Batteries The surveillance associated with current TSs 4.9.F.3 and 4.9.F.5 is the LPCI Battery Duty Cycle and Charger-Inverter Performance Surveillance Test. This      i test demonstrates operability of the Low Pressure Coolant Injection (LPCI) independent power supply battery oy performance of a duty cycle test.
In the'same manner as discussed above for the station batteries, new commitments for modified performance testing and accelerated performance testing for LPCI station batteries are proposed in TSs 4.9.F.3, 4.9.F.4, and 4.9.F.5. Surveillance intervals are revised to 24 months for the LPCI battery service test in TS 4.9.F.3 and the battery charger performance test (current TS 4.9.F.5, renumbered to 4.9.F.6). In addition, TS 4.9.F.3 has been revised to specify that a modified performance test may be performed in lieu of the
      ;   battery ' service test.
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  .                                    Attachment 2 t2 JPN-96-047
           ,            Discrepancies in SER for FitzPatrick TS Amendment 233
: 1. SER section 2.2.3.a. (page 4): Wron (marked-up correction is attached). g acronym is used; "PCIC" should be "PCIS"
: 2. SER section 2.2.3.c. (second instance of "c." in this section; page 10): This section 4.11.B.2; Crescent Area Unit Cooler addresses Temperature surveillance      requirement ControlInstrumentation  Ca    (SR)librations. Technical Specification sectionsl 3.11.B; Crescent Area Ventilati3n and 4.11.B; SR for deleted with Technical Specification Amendme[nt         This231.] Crescent section         Area of the SER     Ventilation were should be deleted.
: 3. SER section 2.2.10 (page 12) has a grammatical error. The third sentence in this                     l section reads:
                     "The licensee analyzed the the pilot valve solenoids anY' o$her relays and concluded that the minimumact voltage should be raised for the RPS scram pilot valve solenoids to ensure proper operation."
This sentence should read (correction in bold):
                     "The licensee analyzed the impact of the voltage drop from the EPAs to the i
scram the min [imum voltage should be raised for the RPS scram pilot valve solenoid to ensure proper operation."
A marked-up page indicating this correction is included for your reference.                    ;
: 4. This amendment changes the aurveillance requirement for instrument line excess flow                   i check valves from "At least one per operating cycle" to "Once per 24 months." This                   '
change is not discussed in tne NRC SER.
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were replaced with Rosemount Transmitters. Square root and suming components of the APRM flow bias loop were found out of procedural tolerance in the past due to a tight CT. New calibration tolerances have been calculated based on past performance and should bound future drift. The main steam isolation valves (MSIV) limit switches (Item 10) have experienced problems during plant operation primarily due to failure of the switches to reset, and slow resets during the periodic MSIV limit switch instrument functional test. The                                           ;
  " -           majority of the limit switch failures were related to a reset of the switches,                                  i rather than instrument drift. The failure to reset problem has been addressed                                   '
by installation of modified actuating levers during the Reload 11/ Cycle 12 Refueling Outage.
j Projected values of future
* drift were incorporated into icop accuracy                                         !
calculations for Item; 5, 5, 3,11, and 12. The calculations determined that sufficient margin exitts between the field trip setpoints ed the analytic                                       ,
limit when the 30-month drift uncertainties are considered. For the APRM flow bias signal transmitters (Item 3), the projected drift based on Rosemount information of the new transmitters is significantly less than the old                                         !
transmf t+.ers evaluated in the drift analysis using past drift data.                                           ;
Therefore, it is acceptable to extend the calibration interval to 24 months for these instruments. Extension of the calibration intervals for Item 7,10,                                   i l
and 13 require changes to the field settings to ensure that sufficient margin exists between the field setting and the TS shtpoint limit. The field setting changes will be completed prior to implementation of the 24-month STI. The staff finds these changes acceptable.
: d.      RPS EPA Channel Calibration - SR 4.9.G.2 (Change A.1.18)
This SR currently requires a once per operating cycle calibration of the overvoltage (OV), undervoltage (UV) and underfrequency (UF) protective instrumentation. This includes simulated automatic actuation of relays, logic and output breakers.
Extension of the calibration interval for the Nonnal and Alternate EPA time                               '
delays is accepttMe because sufficient margin is available between the field settings and the TS trip setpoints to accommodate the projected drift and uncertainties associated with a 30-month calibration interval. The staff finds these changes acceptable.
2.2.3 Primary Containment Isolation System (PCIS) Instrumentation
: a.      PCIS Instrument Response Time Testing - SR 4.2.A (Change 1.A.5)
Pcts This SR currently requires that respobe ines of the MSIV actuation trip functions listed in SR 4.2.A be demon tr ted et                within specified limits once per a 24-month operating cycle                 ,
18 months. This SR can be extended                         IC adequate   on-line testing to because of the redundant design o he detect failures that could affect                         response  times, available margin to accommodate potentially slower response times, and a monitoring program to This detect failures of these transmitters due to loss of fill-cil.
conclusion is supported by a review of past surveillance results which indicate that all required acceptance criteria have consistently been met.
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                              .                               ,                  replaced with new switches. Past drift for the temperature indicating controllers has exceeded the CT on more than rare occasions with four out of
;                  the five failures occurring before 1988. Past drift for the emergency trains
;                  differential pressure switches has exceeded the CT on more than rare occasions. All these failures were minimally above CT and did nrt jeopardize 2
the switch design function. New calibration tolerances have been calculated for these instruments based on past performance to bound future drift for the
:                  extended interval. Predicted values of future drift were incorporated into a
loop accuracy calculations for these instruments. New calibration tolerance
;                  bands for the DPS, DPIS, and certain temperature instrumentation were calculated based on past instrument perfomance. The calculations detemined L               that future drift over the longer STI is predicted to remain within the 2               existing or revised calibfation tolerance. Sufficient margin is provided y ,y.           between the field trip setpoint and the TS setpoint limit. Based on the above gg                 analysis, the proposed extension of the calibration STI to 24 months for this i         .        instrumentation is acceptable, f Y c.      SR 4.11.B.2 Crescent Area Unit Cooler Temperature Control Instrumentatio M                       Calibrations (Change 1.A.20)
N u.
j hc A review of drift data for the fan control temperature switchas and the temperature indicating controllers for the crescent area indicates that drift A       values were within the required calibration t6lerance. Therefore, the d >M               instrumentation has an acceptable past performance record as defined in d                  Generic Letter 91-04. Predicted values of future drift for these instruments Xto[d              were incorporated into loop accuracy calculations to ensure that sufficient i;>4 @tI      h    margin exists between the field setpoint and the TS setpoint limit considering i                 30-month drift uncertainties. Based on the results of the above analysis, the j $ $*2            proposed extension of the calibration interval for the temperature control instrumentation is acceptable.f j
ww3 hpt i                   d. SR 4.11.C.2 Battery Room Ventilation Temperature Transmitter and Differential Pressure Switch Calibrations (Change 1.A.21)
A review of past drift data for the battery room differential pressure             '
switches indicates that drift has exceeded the calibration tolerance on several occasions. These failures were on the air handling unit (AHU) and recirculation fan switches which provide annunciation only and do not perform a safety-related function, and on the exhaust fan switches which provide an automatic start of the exhaust fans. New calibration tolerances have been calculated for these instrtments based on past performance to bound future drift.       Predicted values of future drift for these instruments were incorporated into loop accuracy calculations to ensure that sufficient margin exists between the field trip setpoint and the TS trip setpoint limit when 30-month drift uncertainties are considered. Based on the results of the above analysis, the proposed extensior, is acceptable to the staff.
: e. RETS SR 3.7.a. , 3.7.b.2 and 3.7.b.: Off-Gas System Explosive Gas Instrumentation Channel Functional Test and Instrument Calibrations (Changes 1. A.22, l. A.23,1. A.24, l. A.25) 6

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4 2.10 Changes to the RPS Normal Supply EPA Undervoltage Trip Setting in SR j-                             4.9.G.2 (Change 1.B.6)               .g.y The licensee perfomed a calculation to determine he total channel i
uncertainties associated with the normal RPS F."A his     rip setpoints over a 24-j month operating cycle. Based on the result's of '            calculation, the RPS MG j                 set source undervoltage (UV) setpoint specified         In  SR 4.9.G.2 requires L
revision from its present value of 2108V to 211.3V. The licensee analyzed 4'                the impact of the voltage drop from the EPAs to scram thf" pilot valve solenoids and other relays and concluded that the minimum voltage should be l                 raised for the RPS scram. pilot valve solenoids to ensure proper operation.
j                 The proposed SR 4.g.G.2 RPS MG set source UV setpoint, 2112.3V, is more
,                 conservative. Sased on our review of the setpoint analysis and the fact that is acre conservative, the, staff concludes that this setpoint chan's is acceptable.
t 2.2.11 Editorial, Clarification and Bases Changes i
: a. Technical Specification Tables 4.1-2, 3.2-10, 4.2-5, 4.2-6, and            4.2-j 8 are revised to make the fomat consistent with the changes in the 4
proposed amendment and the BWR Standard Technical Specifications. These
!                         proposed changes are editorial in nature to clarify the TS requirements i                         and are, therefore, acceptable.             -
S i                  b. The proposed changes to Table 3.2-10 clarify the operability and i
surveillance requirements by adding instrumentation components previously
: i.                        omitted from the table, and by refomatting the table to make it l
consistent with other instrumentation tables in the TS. These changes               i clarify operability and surveillance requirements for the remote shutdown           l equipment, incorporate editorial changes and do not change any TS                   ;
4 j                         requirementg.. They are, therefore, acceptable.
: c. The proposed changes to the Technical Specification Bases revise tems such as "each refueling outage," "during refueling outage," "once per              l operating cycle," and "once per 24 months" to provide consistency between the surveillance test intervals and the Bases discussion. These proposed changes clarify the new STIs and are acceptable.
Based on review of the proposed changes to the James A. FitzPatrick Nuclear Power Plant TS, the NRC staff finds that the proposed changes to extend instrumentation survalliance test intervals to support 24-month operating                ;
cycles are consistent with the provisions of Generic 1.etter g1-04. In addition, the staff finds that the proposed instrument setpoint changes           ~       '
provide sufficient margin between the field settings and the TS limits for instrument drift predicted for the extended calibration interval. Finally, the staff finds that the proposed editorial changes and Bases changes more clearly define tha surveillance requirements with specific applicability and corrective actions. The staff, therefore, concludes that the proposed TS changes for instrumentation surveillances on a 24-month operating cycle as discussed above are acceptable.
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