ML20115F011

Application for Amends to Licenses NPF-39 & NPF-85, Consisting of TS Change Request 92-03-0 to Revise TS Surveillance Intervals to Facilitate Change in Refueling Cycles from 18 Months to 24 Months

ML20115F011
Person / Time
Site:	Limerick
Issue date:	10/15/1992
From:	Beck G PECO ENERGY CO., (FORMERLY PHILADELPHIA ELECTRIC
To:	NRC OFFICE OF INFORMATION RESOURCES MANAGEMENT (IRM)
Shared Package
ML20115F017	List: ML20115F011 ML20115F030
References
NUDOCS 9210220223
Download: ML20115F011 (50)

Text

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.. 2 PHILADELPHIA ELECTRIC COMPANY NUCLEAR GROUP HEADQUARTERS 19 CFR 50.96 955-65 CHESTERBROOK BLVD.

WAYNE, TA 19087 5691 (215) 640-6000 NUCIL.L 2RVICES del %RTMENT October 15, 1992 Docket Nos. 50-352 50-353 Licence Nos. NPF-39 NPF-85 U. S. Nuclear Regulatory Commission ATTN: Document Control Desk Jashington, DC 20555

SUBJECT:

Limerick Generating Station, Units 1 and 2 Tecnnical Specifications Change Request Gentlemen:

Phil.adelphia Electric Companf is submitting Technical Specifications Change Request (TSCr) No. 92-03-0, in accordance with 10 CFR 50.90, requesting an amendment to the Technical Specifications (TS) (Appendix A) of Operating License Nos. NPF- 39 and NPF-85. Information supporting this Change Request is contained in Attachiaent 1 to this le;ter, the proposed markup pages  ;

are contained in Attachment 1, and the final proposed replacement pages are contained in Attachment.3.

This submittal requests changes to TS surveillance intervals to facilit. e a change in the Limer':k Generating Station (LGS),

Units 1 ar.d 2, refueling cycles from 18 monthe to 24 months. The 24 month c;ueling cycle will require a change from the current 18 month TS surveillance testing interval (i.e.,'a maximum of 22.5 months accounting for the allowable grace period) to a 24 month testing-interval (i.e. , a maximula of 30 month'; accounting for the allowable grace period). These TS changr a were evaluated in accordance with the guidance provided in NRC Generic Letter No.

91-04, " Changes in Technical Specification Surveillance Intervals to Accommodate a 24-Month Fuel Cycle," dated April 2, 1991, and are being proposed accordingly.  !

9210220223 921015 '

-hD9 A00CK 050003'52 PDR ,

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1 I

,# y U. S. Nu lear-Regulatory Comt ission-- October 15, 1992 Document Control Desk .Page-2 As discussed in our letter dated. February 11,-1992, this is the' third . ( 1. e . , - the final) of three _ Change Requests being submitted to the NRC to support'the. current change to 24 month- -

refueling cycles at LGS, Units 1 and 2. This Change Request

' involves a proposed change to the TS surveillance int.rvals for instrume.it calibration TS line items, a change to the definition of -

"R" (i.e., for "Ref ueling Interval'.' ) , and the-remaining TS line items to' support 24 month refueling cycles..

-The-TS page markups contained in Attachment- 2 reflect the proposed change to 24 month testing for each specific TS Sarveillance Requirement identified-and evaluated in this Change Request. The TS-page' markups are being provided for information only. The final proposed TS replacement pages, which refit,ct the combined changes-proposed in this and the. previous Change Request No. 92-02-0, are contained in Attachment 3.

Accordingly, we request that the NRC review-- the- TS changes proposed in this - Change Request by December 1992 in order to support' approval of:this-and the-previous Change Request prior _to the: expiration of the current TS surveillance interval limits in-February 1992-(this includes _the_25% grace period). ?n addition, we request.that the approved TS changes be effective 30. days.after

-issuance of the Amendments.

If you have any questions regarding this matter, please

. contact us.

Very truly yours, O

G. J, Beck, % nager Licensing-S'.ction

~ Attachments.

cc:1 T. T. Martin, Administrator, Region I, USNRC T.-J_.. Kenny, USNRC__. Senior Resident Inspector, LGS W. P. Dornsife, Commonwealth of_ Pennsylvania 3

a l

COMMONWEALTH OF PENNSYLVANIA:

ss.

COUNTY OF CHESTER  :

D. R. Helwig, being first duly sworn, deposes and says:

That he is Vice President of Philadelphia Electric Company; 3 the Applicant herein; that he has read the foregoing Application for Facility Operating License Nos. NPF-39 and NPF-85 (Technical' Specifications Change Request No. 92-03-0) to facilitate a change in the Limerick Generating Station, Un.".ts 1 and 2 refueling cycles from 18 months to 24 months, and knows the contents thereof; and that the statements and matters set forth therein are true and correct to the beet of his knowledge, information and belief.

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Vice Preside Subscribed and sworn to before me this /6 #day of 6di, 1992, butJm ' G. htin,k 7

Notary.Public r NOTARIAL SEAL C M Hgp;.;E A. M NOE! NO W Trec@ n Twp; DECO 993 y, comm 'an cs;M ,

________________1__= -

f. .. .-

ATTACHMENT 1-LIMERICK GENERATING STATION Units 1 and 2 Docket Nos. 50-352 50-353 License Nos. NPF-39 NPF-85 TECHhICAL SPECIFICATION CHANGE REQUEST "

{

No. 92-03-0

.)

" Priority 2 (Instrumentation) Line. Item Changes in Support -)

1 of 24 Month. Refueling Cycles" l Supporting Information for Changes.- 46LPages

Attachment 1 Philadelphia Electric Company (PECo), Licensee under Fecility Operating Licenses NPF-39 and NPF-85 for the Limerick Generating Station (LGS) Units 1 and 2, respectively, requests that the Technical Specifications (TS) contained in Appendix A to the Operating Licenses be amended as proposed herein. The proposed changes specific to this Change Request are indicated on the associated TS page markups for both LGS, Units 1 and 2, and are contained in Attachment 2. The combined changes proposed in this and the previous Change Request are indicated by vertical bars in the margin of each page for both LGS, Units 1 and 2, and are contained in Attachment 3.

The proposed TS changes are requested to f acilitate the current change in the LGS, Units 1 and 2, refueling cycles from 18 months to 24 months. The 24 month refueling cycle will require a change from the current 18 month TS surveillance testing interval (i.e., a maximum of 22.5 months accounting for the allowable grace period) to a 24 month testing interval (i.e., a maximum of 30 months accounting for the allowable grace period). These TS changes were evaluated in accordance with the guidance provided in NRC Generic Letter (GL) No. 91-04, " Changes in Technical Specification Surveillance Intervals to Accommodate a 24-Month Fuel Cycle," dated April 2, 1991.

As discussed in our letter dated February 11, 1992, this is the third (i .e. ,

the final) of three Change Requests being submitted to the NRC to support the current change to 24 month refueling cycles at LGS, Units 1 and 2. This Change Request involves a proposed change to the TS surveillance intervals for instrument calibration TS line items, a change to the definition of "R" (i.e., for " Refueling Interval"), and the remaining TS line items to support 24 month refueling cycles.

The TS page markups contained in Attachment 2 reflect the proposed change to 24 month testing for each specific TS Surveillance Requirement (SR) identified and evaluated in this Change Request. The TS page markups are being provided for information only. The final proposed TS replacement pages, which reflect the combined changes proposed in this and the previous Change Request No. 92-02-0, are contained in Attachment 3.

Accordingly, we request that the NRC review the TS changes proposed in this Change Request by December 1992 in order to support approval of this and the previous Change Request prior to the expiration of the current TS surveillance interval limits in February 1992 (this includes the 25% grace period). In addition, we request that the approved TS changes be effective 30 days after issuance of the Amendments.

This Change Request provides a generic discussion on the effect of increased surveillance intervals on instrument drift and safety analysis assumptions.

This Change Request a'so i provides a discussion, description, and a safety assessment for each of the proposed TS changes by " group," information supporting a finding of No Significant Hazards Consideration, and information supporting an Environmental Assessment.

Discussion on the Effect of Increased Surveillance Intervals on Instrument Drift and Safety Analysis Assumptions NRC GL No. 91-04, Enclosure 2 provided guidance to licensees on the type of analysis and information that would be required to justify a change to the 1

Attachment 1 surveillance interval for instrument recalibrations.- Seven specific actions were delineated in the Enclosure. These actions are repeated below along with a generic discussion to provide insight into the methodology PECo used to evaluate the affects of an increased surveillance interval on instrument drift. A specific discussion on the affects of such a change are included in the description of changes and safety assessment section which follows.

1. Confirm that instrument drift as determined by as-found and as-left calibration data from surveillance and maintenance records has not, except on rare occasions, exceeded acceptable limits for a calibration interval.

The effect of increased calibration intervals on the TS instrumentation for LGS Units 1 and 2 to accommodate 24 month refueling cycles has been determined. Two issues associated with the instrumentation have been evaluated: a) instrument availability based on consideration of historical instrument test failures, and b) instrument drift.

a. Instrument Availability Based on Consideration of Historical Instrument Test Failures For the TS instrumentation at Ll.3 Units 1 and 2, a search was done of all surveillance tests that satisfy the 18 month testing requirement of instrument calibration. The Gearch identified all failed tests. Each f ailed test was reviewed .o determire the cause of the f ailure. The purpose of this evaluation was to determine the impact an increase in the surveillance frequency has on instrument availability. This review identified that instrument failure rates detected by the 18 month surveillance requirement was significantly less than one (1) percent. Because of the very small percentage of failures which are detected on an 18 month basis and because of system redundancy, the change in the surveillance frequency will have a small' impact, if any, on system availability.

b. Instrument Drift For the TS instrumentation at LGS Units 1 and 2, all applicable surveillance tests were reviewed, and historical instrument drift related data was obtained. This data included as-left values, as-found values, and required limits identified during each instc/ ment calibration. Based on this data, a drift analysis was performed.

The failure history in. combination with- the drift study demonstrated that except in' rare occasions instrument dritt has not exceeded the current allowable limits.

2. Confirm that the values of drift for each instrument type (make, model, and range) and application have been determined with a high probability and a high degree of confidence. Provide a summary of the methodology and assumptions used to determine the rate of instrument drif t with time based upon historical plant calibration data.

The methodology used to perform the LGS drift analysis is described below.

2

Attachment 1 h

4 General Electric (GE) developed a computer model for drif t determination as documented in NEDC-31336, "GE Instrument Setpoint Methodology" to perform instrument setpoint calculations. This document was submitted

- to the NRC, and is currently under review. The Boiling Water Reactor i Owners' Group (BWROG) committee for Surveillance Test Extension determined that the drift module of the GE Instrument Setpoint Methodology could be used to determine instrument drift for periods longer than 18 months based on actual instrument performance in plant j environments.

GE, under the direction of the BWROG Surveillance Test Extension

committee, developed the " General Electric Instrument Trending Analysis System" (GEITAS). This quality assured program is being used to determine the feasibility of extending various surveillance tests to

thirty-six months.

A copy of the verified and validated GEITAS program was obtained from GE and was used to project the thirty month drif t number. The as-found and

, as-lef t data was taken from 18 month instrument calibration surveillance tests and was analyzed. This analysis produc' ' values at intervals from one to thirty months. For conservatism, ,1) the various' errors contained in the as-found and as-lef t values (e.g. , instrument accuracy,

! and temperature and calibration errors) were not removed, and (2) the

! interval with the highest _ projected drift value was compared with the present 18 month surveillance test acceptance criteria.

The results of the computer runs showed acceptable 30 month drif t values d

that were within surveillance test drif t allowances if (1) there were a sufficient amount of historical data to satisfy the computer algorithms and_(2) the majority of the as-found and as-left values were within acceptable' limits.

It should be noted that for certain cases a different methodo'qqy was utilized to demonstrate that the drift was acceptable. These cases included instruments that were recently installed, instruments that were tested more frequently because of other commitments,- or instruments that

have 30 month drif t numbers published. For each -instrument where the GE

Program-was not utilized to evaluate the drift data, a summary of the methodology is contained in the_ specific discussion of the change.

3. Confirm that the magnitude of instrument drif t has been determined with a high probability and a high degree of confidence for-a bounding calibration interval of 30 months for each instrument type (make, model number, and range) and application that performs a safety function.

Provide a list of the channels by TS section - that identifies these lastrument applications.

The ' determination that the magnitude of instrument drift has been

, _ determined with 'a high . degree of probability and a high degree of l confidence for a bounding calibration interval of 30 months for each instrument type is included in the description of changes and safety assessment section that follows. A list of channels by TS section-is included.

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l

1 Attachment 1 J

4. Confirm that- a comparison of the projected instruraent drif t errors has been made with the values of drift used in the setpoint analysis. If this results in revised setpoints to accommodate larger drjft errors, provide proposed TS changes to update trip setpoints. If the drift

errors result in revised safety analysis to support existing setpoints,

provide a summary of the updated analysis conclusions to confirm that safety limits and safety analysis assumptions are not exceeded.

i The 30 month projected drift number was compared to the present allowence for the instrument application. If the drift for an instrument type did not f all within the present bounds of the acceptance criteria, the surveillance interval was either left at an 18 month calibration surveillance interval or was extended- to a 30 ~ month calibration surveillance interval based on other justification, such as, more frequent testing. If an instrument has not been in service long- )

i enough to establish a 30 month projected drift value, the surveillance interval was either left at an 18 month surveillance interval or extended to a 30 month surveillance based 7n other, more frequent-testing or justification obtained from the instrument manufacturer. In no case was the setpoint of an instrument changed to accommodate a drif t-error larger than previously evaluated.

5. Confirm that the projected instrument errors caused by drift are i acceptable for control of plant parameter.s to-effect a safe shutdown with the associated instrumentation.

As discussed in response to number 4, the justification for extending the surveillance interval _of an instrument was that the results of the  !

instrument drift calculation were within the bounding analysis.

Additional factors included more frequent _ testing or a manufacturer's recommendation. In no case was the existing safe shutdown -analysis changed to accommodate a larger drift error.

6. Confirm that all conditions and assumptions of the setpoint and safety-analyses have been checked and are appropriately reflected in the acceptance criteria of plant surveillance procedures for channel checks, channel functional tests, and channel calibrations.

PEco has not changed any setpoint or acceptance criteria of the-present 18 month surveillance tests since the 30 month projected. drift fell within the bounds of the current acceptance criteria. Otherwise, the surveillance interval was left at 18 months, or_was extended ' to 30 months based on other, more frequent testing or justification-from the manufacturer. Therefore, there is no cause _ to reverify established-acceptance criteria specified in the surveillance tests.

7. Provide a summary description of the program for monitoring and assessing the ef fects of increased calibration surveillance intervals on instrument drift and its effects on safety.

PECo's program will review each calibration surveillance that does not i meet the " leave alone" acceptance criteria (i.e., no recalibration or adjustment required) of the surveillance test. Based on the results of that review, a decision on the appropriate calibration interval will be 4

Attachment 1 made. Such a decision will consid'r such things-as shortening _ the surveillance test interval, chaugine che setp31nt of the instrument, or leaving the surveillance interval at 30 months. Review of the surveillance test results will be performed until such time as we determine that further evaluation is no longer.necessary.

Discussion, Description and Safety Assessment of_the Proposed Changes Because of the volume of TS SRs to be evaluated, specific line item changes were evaluated within each group identified below. Note that the nama of each group is merely an administrative title, and is_not intended to mean that all of the specific TS requirements related to the group title have been included. The proposed TS changes generically involve changing the calibration interval, typically stated as "at least once per 18 months," to "at least once per-24 months." The proposed TS changes also typically i Jnvolve a calibr on interval designated with an "R" notation. The "R" designation shal. smain unchanged by this Change Request. However,-in accordance with the guidance provided in GL No. 91-04, a proposed change to the definition of "R" and the associated impact of the proposed increase in

, the calibration interval for the individual affected TS line items are evaluated within the associated " groups" in this Change Request. Also, this-Change Request involves a proposed change to delete the -words "during-

. shutdown" from several TS SRs in accordance Pith the guidance provided in GL No. 91-04.

In add 1+,lon, the proposed TS changes involve a change to_ associated Bases that fadicate conformance to a specific Regulatory Guide _ related to the system being tested, i.e. , the proposed chang i would indicate that the change to a 24 month testing interval would be an exception to the'18 month testing interval guidance specified in the Regulatory Guide. These and other specific changes are proposed and evaluated within the " groups" identified below, i

The-proposed TS changes only involve a change to the surveillance intervals; there are -no changes to the SRs themselves or-to the way in which the surveillances are performed. Also, the-proposed changes do not involve any

, physical changes to plant systems or components. The proposed TS changes are described and evaluated below. These changes were evaluated in accordance

-with the guidance provided in NRC GL No. 91-04.

(1)

Reactor Coolant and Containment Leakage Systems Instrumentation TS SR 4.4.3.1.c; page 3/4 4-8 TS SR 4.6.4.1.b.3.a;-page 3/4;6-45 4

TS SR 4.4.3.1.d; page 3/4 4-8 . TS SR 4.6.4.1.b.3.b; page 3/4 6-45 TS SR 4.4.3.2.3.b; page 3/4 4-10 TS SR 4.6.4.1.b._3.c; page 3/4 6-45 TS SR 4.6.1.4.d.3; page 3/4 6-7 TS SR 4.6.6.1.b.1; page 3/4.6-57 TS SR 4.6.2.1.c.3; page 3/4 6-14 i The following TS SRs require that the Reactor Coolant System and Containment System instrumentation- identified below shall be

, demonstrated operable by performing a channel calibration "at least once per.18 months."

TS SR 4.4.3.1.c - drywell floor drain sump and drywell equipment 5

Attachment I d

j drain tank flow monitoring systems.

, TS SR 4.4.3.1.d - drywell unit coolers condensate flow rate monitoring system.

l TS SR 4.4.3.2.3.b - high/ low pressure interface valve leakage pressure monitors.

TS SR 4.6.1.4.d.3 - operating instrumentation for tho Main Steam i

Isolation Valve (MSIV) leakage control system

, (LCS).

l TS SR 4.6.2.1.c.3 - sup,oression chamber water level ani temperature indicators, i.

TS SR 4.6.4.1.b.3.b - suppression chamber - Jrywell vacuum breaker position indicators.

TS SR 4.6.6.1.b.1 - primary containment hydrogen recombiner system control room instrumentation- and control circuits.

. With respect to the suppressior' chamber - drywell vacuum breakere, TS SR 4.6.4.1.b.3.a requires verifying, at least once per'18 months, that each valve's opening setpoint from the closed position is 0.5 psid i 5%.

, Also. TS SR 4.6.4.1.b.3.c requires ve';ifying, uat least once per 18

. months, that each outboard valve's position _ indicator is capable of j detecting disk displacement 2 0.120". The proposed TS changes involve changing _ the calibration interval for the above TS SRe to "at least once-

! per 24 raonths" with the following exception. The calibration interval for TS SR 4.6.2.1.c.3 will be footnoted to indicate that the. channel

calibration for Unit I level transmitters LT-55-1N062B and -lN062F, and Unit 2 level transmitters LT-55-2N062B and'-2N062F shall be performed at least once per 18 months.

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The subject TS SRs currently require the calibration testing of the subject instrumentation nominally every 18 months. The calibration surveillance is performed to - ensure that the instrument is properly i

aligned so that actuntion takes - place at the previously evaluated setpoint to provide the required safety function._ By increasing the refueling cycle 1E.ngth, the time interval for calibration surveillance l of the subject instrumentation will be increased. However, as currently i required by LGS 23, functional tests are performed during the refueling cycle more frequently than the calibration surveillance. These

. functional tests detect failures of the instrumentation channels, except L for field devices, . such as transmitters, that are only: tested once every 18 months. Gross instrumentation failures are detected by alarms or comparison with redundant and independent. indications.

Instrumentation purchased for these functions are highly reliable. The j Containment and Reactor Coolant Leakage Systems instrumentation' that is l classified as safety related meets the stringent design criteria of l

safety related status. This includes redundancy and independent channels which ensures a high confidence of system performance even with l

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Attachment 1 i

i the failure of a single component. Based on the above discussion, we_

have e,acluded that the impact on instrument availability, if any, is

small as a result of the change to 24 month surveillance intervals.

! Portions of the Containment System and Reactor Cc'lant Leakage System 4 instrumentation are classified as non-safety relatod. Again, there are multiple and diverse instrument channels that provide backup information

, in the avent of a single channel failure.

4 l

To verify this conclusion, an evaluation of a historical search of the

surveillance tests for each instrument was - performed. The search Identified all failed or partially failed tests, and then each failed or partially failed test was reviewed and evaluated. The purpose of this evaluation was to- demonstrate that the increased calibration

surveillance interval would not increase the period an instrument would i be unavailable. The results of this search support -the above conclusions that the impact on instrument availability, if any, is small as a result of the change in the surveillance interval.

i A second evaluation performed an instrument _ drif t analysis for the increase in the calibration interval to a maximum of 30 months. The purpose of this evaluation was to determine whether or not projected drift values for 30 months are within existing _ surveillance-test _ drift

allowances. The instrument drift analysis was performed using the GE methodology previously described in response to Item No. 2 under the generic discussion regarding NRC GL No. 04, Enclosure 2. This

., analysis was performed for the Ametek, Model Nos. 91X-16-6 and 7, MSIV-

LCS instruments (TS SR 4.6.1.4.d.3); the Simmonds Precision, Model Nos.

10701F11060 and 10701D11000, suppression pool water level / temperature-instruments (TS SR 4.6.2.1.c.3); -_and the Hecon, Model No. GO 422, and Bailey, Model No. 750110AAAA1, drywell floor drain sump /drywell

equipment drain tank flow monitoring instruments . (TS SR 4.4.3.1.c) . The j results of the analysis indicate that the projected 30. month ' drif t values for these instruments do not exceed the existing-surveillance test drift allowances. Based on the drift analysis, we have-concluded that an increase in the surveillance interval to accommodate a 24 month g refueling cycle will not af fect these instruments with respect- to drif t.

. The following instrumentation was evaluated based on justification ocher i than the drift analysis.

Although the instruments that provide input to TS SRs 4.4.3.1.c and 4.4.3.1.d have an 18 month calibration interval, they also have.a more frequent testing requirement which includes a calibration check. Since this more frequent testing requirement is unchanged,_a. drift evaluation for an. increase in the calibration interval to accommodate a 24 month refueling. cycle is not required for these instruments.-

Rosemount transmitters provide input to TS SRs'4.4.3.1.c, 4.4.3.2.3.b, 4

4.6.1.4.d.3, and 4.6.6.1.b.l. Drift values for 30 months are published for. Rosemount transmitters in Rosemount Report D8900126, and the ~

published values are within the surveillance test drift allowances for these-instruments. Therefore, an increase in the surveillance interval to accommodate a 24 month refueling cycle does not affect these.

7 l

, - - - ~. . . - - . - - .- -

k Attachment-1 Rosemount transmitters with respect to drift.

Rosemount trip units are functionally checked and setpoint verified more 4 frequently, and if necessary, recalibrated. These more frequent testing requirements remain unchanged.. Therefore, an increase in the L surveillance interval to accommodate a 24 month refueling cycle does not

affect the Rosemount trip units with respect to drift.

4 Limit switches are mechanical devices that require mechanical adjustment

. only; drift is not applicable to these devices. Therefore, an increase

in the surveillance interval to accommodate a 24 month refuel'ng cycle.

does not affect the limit switches with respect to drift.

Bailey instrumentation provides . input to TS SR 4.6.6.1.b.1. .The calibration data for this instrumentation has been reviewed. This i

review indicates that from April, 1989 to July, 1991 for Unit.1,-and y from August, 1989 to February,-1991 for Unit-2, the calibration checks

identified the as-found values within limits. Minor adjustments were

,~

made to the as-found values to bring the as-left. values closer to the setpoint. Based on the review of existing data.that shows essentially

- no drif t for approximately 18 months, the surveillance interval for-the

-Bailey instrumentation can be increased to accommodate a 24-month l refueling cycle. Further, these instruments will continue to be monitored for drif t using the trending program being established for instrument drift.

4 Based on the above evaluations, we have concluded that the impact on

! containment system and reactor coolant leakage . system instrument availability, if any,'is small as a result of the-24 month surveillance.

interval changes.

(2) Reactor Protection System Instrumentation l TS Table 4.3.1.1-1; Items 1.a, 3, 4 5, 7, 8.a, 8.b,.-9, and 10; pages 3/4 3-7 and 3/4 3-8 TS SR 4.3.1.1 requires that each reactor protection system (RPS) instrumentation channel identified in TS Table 4. 3.1.1-1 shall- be demonstrated operable by the performance of a channel calibration at the f requency ~ shown . in Table 4.3.1.1-1.- The calibration -interval in TS Table 4.3.1.1-1 is designated with an "R" which is defined in' Table 1.1 in the Definitions Section of TS as "At.least once per-18 months (550 days)." The "R" designation remains unchanged by this Change Request.

However, since a change to the definition of "R" to accommodate a.24 month refueling cycle is p aposed. separately within a subsequent group.

in this Change Request, the impact of-the increase'in the calibration interval to accommodate a 24 month refueling cycle on the RPS instrumentation is evaluated within_this group. This evaluation:is

specific to the RPS instrumentation channela indicated below.

TS Table 4.3.1.1.-1, Items 1.a Intermediate Range Monitors, Neutron Flux - High

3. Reactor Vessel Steam Dome Pressure - High

-l1 L 8

l. l l l t

1 Attachment 1 ,

1

4. Reactor vessel Water Level - Low, Level 3

5. Main Steam Line Isolation Valve - Closure

7. Drywell Pressure - High

8. Scram Discharge Volume Water Level - High

a. Level transmitter

b. Float Switch

9. Turbine Stop Valve - Closure

10. Turbine Control Valve Fast Closure, Trip Oil Pressure - Low The subject TS SRs currently require the calibration testing of the subject instrumentation nominally every 18 months. The calibration surveillance is performed to ensure that the instrument is properly-aligned so that actuation takes place at the previously evaluated setpoint to provide the required safety function. By increasing the refueling cycle length, the time interval for calibration surveillance of the subject instrumentation will be increased. However, as currently required by LGS TS, functional testa are performed during the refueling cycle more frequently than the calibration surveillance. These functional tests detect f ailures of the instrumentation channels, except for field devices, such as transmitters, that are only tested once every 18 months. Gross instrumentation failures are detected by alarms or comparison with redundant and independent indications.

Instrumentation purchased for these functions _are highly reliable and meet the stringent design criteria of safety related status. All RPS instrumentation is designed with redundant and independent channels which provide means to verify proper instrumentation performance during operation, and adequate redundancy to ensure a high confidence of-system performance even with the failure of a single component. Based on-the above discussion, we have concluded that the impact on instrument availability, if any, is small.as a result of the change to 24 month surveillance intervals.

To verify this conclusion, an evaluation of a historical search of the surveillance tests for each instrument was performed. T h e -- s e a r c h identified all failed or partially f ailed tests, and then each failed or partially failed test was reviewed and evaluated. -The purpose of this evaluation was to demonstrate 'that the increased calibration surveillance interval would not increase the period an instrument would be unavailable. The results of this search support the above conclusions that the impact on instrument availability, if any, is small as a result of the change in the subject surveillance interval.

A second evaluation performed an instrument drift analysis for the increase in the calibration interval to .a maxirrum of 30.- months. The purpose of this evaluation was to determine whether or-not projected drift values for 30 months are within existing surveillance test drift allowances. The instrument drift analysis was performed using the GE methodology previously described in response to Item No. 2.under the generic discussion regarding NRC GL No. G1-04, Enclosure 2. This analysis was performed for the Gould, Model No. PD3218-100-38, scram discharge volume water level - high level transmitter (Table 4.3.1.1-1, Item 8.a) and the Magnetrol, Model No. 57-3003-006, scram discharge volume water level - high float switch (Table 4.3.1.1-1, Item 8.b) - The 9

mmm__<

1 Attachment I n

results of the analysis indicate that the projected- 30 month drift values for these instruments do not exceed the existing surveillance 4

test drift allowances. Based on the drift analysis, we have concluded that an increase in the surveillance interval to accommodate a 24 month refueling cycle will not affect these instruments with respect to drif t.

1 The following instrumentation was evalucted based on justification other than the drift analysis.

Although the instruments that provide input to TS Table 4.3.1.1-1, Item 1.a, have an 18 month calibration interval, they also have -- a more frequent testing requirement which includes a calibration check. Since

the more frequent testing requirement is unchanged, a drift evaluation

! for an increase in the calibration interval to accommodate a 24-month refueling cycle is not required.

Rosemount transmitters provide input to TS Table 4.3.1.1-1, Items' 3, 4, 7, and 10. Drift values for 30 months are published for Rosemount

' transmitters in Rosemount Report D8900126, and these published values are within the surveillance test 'drif t allowances- for these instruments.

Therefore, an increase in the surveillance interval to accommodate a 24 month efueling cycle does not affect these Rosemount' transmitters with respect to drift.

Rosemount trip units are functionally checked and setpoint verified more frequently, and if necessary, recalibrated. These-more frequent testing requirements remain unchanged. Therefore, an increase in the surveillance interval to accommodate a 24 month refueling cycle does not affect the Rosemount trip units with respect to drift.

Limit switches are mechanical devices that require mechanical adjustment l only; drif t is not applicable to these devices. Therefore, an increase in the surveillance interval to accommodate a 24 month refueling cycle-i does not affect the limit switches with respect to drift.

, The scram discharge volume (SDV) water level - high float switch provides input to TS Table 4.3.1.1-1, Item 8.b. This instrument has a more frequent testing requirement which includes a calibration check.

Since the more frequent testing requirement i s u n c h a n g e d ,- a' drif t evaluation for an increase in the calibration interval to accommodate a ,

t.

24 month refueling cycle is not required.

The pressure switch for the' main turbine control' valve-(MTCV) electro-

hydraulic control (EHC) pressure has been evaluated using the GE drift computer program. This.evaluailan showed=that these instruments (ITT Barton pressure switches for Unit 1 and Barksdale pressure swi;ches for Unit 2) experienced significant drift. This drift was.found to be 88

,. psi for the Barksdale pressure switches and 111 psi for the ITT Barton i pressure switches. This drif t exceeds the current allowable drif t of 60 l psi which is identified in NEDC 31336 and the more conservative 35 psi j identified in surveillance tests which reflect the TS requirement;for i the Eno-of-Cycle Ret irculation Pump Trip (EOC-RPT). The function of l this-pressure input is to provide an anticipatory reactor scram and the EOC-RPT in the event of the f ast closure of the MTCVs which could result l

l 10 w y -n m

Attachment 1 in a significant pressure transient following a generator load reject.

After reviewing the accident scenario and considering the potential impact to the analysis periormed for this event, we have concluded that the only impact f rom drif t in the non-conservative direction would be to the- response time of the reactor scram and EOC-RPT signal. As identified in NEDC-31336, upon initiation of the event (i.e., the generator load reject), the fast acting solenoid valve will energire allowing the trip oil to drain. The pressure will decrease from a nominal 1600 psi to 0 psi within 8-10 milliseconds. At approximately 400 psig, the disk dump valve will open to allow the MTCV to start to fast close. Since it _ takes approximately 10 milliseconds' for - the pressure to reach zero, we have concluded that the 200 pai of drift would, in the worst case, cause an additional timo delay of no greater

, than 3 milliseconds. This 3 millisecond time delay will be added to the overall response time of the trip. The " Transient Protection Parameters

, _ Verification Form" (GE Form OPL-3) identifies that the time between when the MTCV starts to fast close and the pressure switch actuates will

! be no greater than 30 milliseconds.- _ OPL-3 also identifies an additional 250 milliseconds allowed for the RPS and control rods to start' to i insert. Historically, the response times for these functions has been

_ in the order of 150 milliseconds, allowing significant' margin to the

input allowed for in OPL-3. The response time for the EOC-RPT 'is required to be 175 milliseconds as specified in TS. Again, historically

, these response times have been significantly lower than that input into the analysis.

In addition to the impact of drift on the response time, it should also

be understood that the logic for these trips provides redundancy which I'

would make it highly unlikely that all instruments composing a channel would drift to the same degree and in the same direction. Considering any potential drift in the conservative direction, we have-determined that this is not a concern since the coincident logic for these trips should prevent any spurious reactor scrams or EOC-RPTs, and any drift high will be identified during 'the operating cycle -and- require

, corrective action. When evaluating the maximum drift projected by the BWROG program and determining the potential impact on the plant's safety analysis, we have concluded that this potential drift has a negligible impact and does not increase the consequence of-an accident previously evaluated.

During the third refueling outage (lR03) for ' Unit 1 and the . first refueling outage (2R01) for Unit 2 at LGS, modifications were performed on the EHC system to eliminate severe pressure oscillations and

, vibration of EHC piping. These modifications to the~EHC system have been in place for one full cycle _of operation on Unit 1. Based on the results of the calibrations performed during the fourth refueling: outage 4 (1R04) for Unit 1, the instrument drif t was reduced within the allowable surveillance test values. We have concluded that the severe drift problem may have been caused by the EHC system vibration and pressure oscillations.

Based on the above observation, we have concluded that the surveillance

interval can be increased to a nominal 24 months since data for 'one' full ~

cycle shows that the cause of the severe drift problem has been

+

11

a 4 5-,-4,_ h- s- ,n,,4 ya:

Attachment 1 f

satisfactorily reduced, and that the severe drift has a negligible-impact on the accident analysis._ Further, _these instruments will continue to be monitored for drif t using the trending program being established for instrument drift.

Based on the above evaluations, we have concluded that the impact on RPS

. Instrument availability, if any, is small as a result of the 24 month surveillance interval changes.

(3) Isolation Actuation Instrumentation i TS Table 4.3.2.1-1; Items 1.a.1 .2, 1.c .g, 2.a b, 3.a .c, 3.0,

, 4.a .f, 4.h, 5.a .f, 5.h, 6.a .b, 6.h, 7.a .b;

pages 3/4 3-27 through 3/4 3-31.

TS SR 4.3.2.1 requires that each isolation actuation instrumentation

- channel identified in TS Table 4.3.2.'l-1 shall be demonstrated operable by performing a channel calibration at'the frequency shown. In Table

4.3.2.1-1. The calibration interval in TS Table 4.3.2.1-1 is designated j with an "R" which is defined in "-tle 1.1 of_the Definitions Section of TS as "At least once per 18 months (550 days)." The "R" designation remains unchanged by this Change Request. However,.since a_ change to the definition of "R" to accommodate a 24 month refueling cycle _is proposed sepa.ately within a-subsequent-group in this Change Request, the impact of an increase in the calibration interval to accommodate a

24 month refueling cycle on the isolation actuation instrumentation is evaluated within this group. 'This evaluation is specific to the isolation actuation instrument channels indicated below.

. TS Table 4.3.2.1-1; Items

1. Main Steam Line Isolation

a. Reactor Vessel Water Level

1) Low, Low - Level 2

2) Low, Low, Low - Level 1

c. Main Steam Line Pressure - Low

d. Main Steam Line Flow -'High

! e. Condenser Vacuum - Low

f. Outboard Main Steam Isolation Valve (MSIV) Room Temperature -

High

g. Turbine Enclosure Main Steam Line Tunnel Temperaturef- High j 2. Residual Heat Removal (RHR) Shutdown Cooling Mode Isolati3n-

a. Reactor Vessel Water, Level - Low, Level 3

b. Reactor Vessel-(RHFJCut-In Permissive) Pressure - High l 3. Reactor Water Cleanup (RWCU) System Isolation

a. RWCU System Differential Flow - High D. RWCU System Area-Temperature - High i c. RWCU System Area Ventilation Differential Temperature -

l High 12 o

Attachment 1

e. Reactor Vessel Water Level -Low, Low, Level 2

4. High Pressure Coolant Iniection (HPCI) System Isolation

a. HPCI Steam Line Differential Pressure - High b .. HPCI Steam Supply Pressure - Low . ,

c. HPCI Turbine Exhaust Diaphragm Pressure - High  !

d. HPCI Equipment-Room Temperature - High

e. HPCI Equipment Room Differential Temperature - High

f. HPCI Pipe Routing Area Temperature - High

h. HPCI Steam Line Differential Pressure Timer

5. Reactor Core Isolation Cooling (RCIC) System Isolation

a. RCIC Steam Line Differential Pressure - High

b. RCIC Steam Supply Pressure - Low c.- RCIC Turbine Exhaust Diaphragm Pressura - High

d. RCIC Equipment Room Temperature - High _

e. RCIC Equipment Room Differential Temperature - High l;

f. RCIC Pipe Routing Area Temperature - High

h. RCIC Steam Line Differential Pressure Tiner

6. Primary Containment Isolation

, 1 D

i a. . Reactor Vessel Water Level

1) -Low, Low - Level 2

2) Low, Low, Low - Level 1 i b. Drywell Pressure - High l h. Drywell Pressure - High/ Reactor Pressure - Low

7. Secondary Containment Isolation l -

a. Reactor Vessel Water Level - Low,. Low,-Level 2

b. Drywell Pressure - High-F The subject TS SRs . currently require, the calibration- testing of the subject instrumentation nominally every -18 months.= The. calibration

surveillance -is- performed to ensure that the instrument is properly

aligned so that actuation takes place at the previously evaluated.

, setpoint to provide the required safetyEfunction. By increasing the

. refueling cycle-length, the time. interval for. calibration surveillance L

of the subject instrumentation will be increased. However,. as currently required by-LGS TS, functional tests are performed during the refueling

cycle more frequently than the calibration _ surveillance. These functional tests detect f ailures of the instrumentation channels, except for field. devices, such as transmitters, that are only tested once every ,

18 months. Gross instrumentation failures are detected by alarms or comparison with redundant and independent indications.

L . -

l Instrumentation purchased for-these functions are highly reliable and l meet the stringent design criteria. of safety related status. 'All-isolation actuation instrumentation is designed with redundant . and independent channels which provide means to. verify proper instrumentation performance during operation, and adequate redundancy to L 13 i

s i

$ Attcchmont 1 i

f ensure a high confidence of system performance even with the failure of-

.. a single component. Based on the above discussion, we have concluded that the impact on instrument availability, if any, is small as a result of the change to 24 month surveillance intervals.

To verify this conclusion, an evaluation of a historical search of the surveillance tests for each instrument was performed. The search identified all f ailed or partially f ailed tests, and then each failed or partially failed' test was reviewed and evaluated. The purpose of-this evaluation was to demonstrate that the increased calibration surveillance interval would not increase the period an instrument would be unavailable. The resul;s of this search supports the above i conclusions that the impact on instrument availability, if any, is small as a result of the change in the subject surveillance interval.

A second evaluation performed an instrument drift analysis for the increase in the calibration interval to a maximum of 30 months. The purpose of this evaluation was to determine whether or.not projected drift values for 30 months are within existing surveillance test drift

. allowances. The instrument drift analysis was performed using the GE methodology previously described in response to Item No. 2 under the generic discussion regarding NRC- GL. No. 91-04, Enclosure 2. This analysis was performed for the Bailey, Model Nos. 745110AAAE2, 750110AAAN2, and 50-752410AAAN2, RWCU system differential flow-- high instruments (TS Table 4.3.2.1-1, Item 3.a) . The results of the analysis

indicate that the projected 30 month drift v 'ues-for these instruments do not exceed the existing surveillance test ' rif t allowances. Based on '

the drift analysis, we have concluded t.at an increase in the surveillance interval to accommodate a 24 month refueling cycle will not affect these instruments with respect to drift.

The following instrumentation was evaluated based on justification other-i than the drift analysis.

i General Electric's (GE's) NUMAC-instrumentation has replaced' existing l isolation actuation instrumentation associated with the steam leak l detection system. The NUMAC instrumentation is a replacement with insufficient historical data to evaluate 30 month drift using the GE drift computer program. However, GE has provided data' for 30 month drift. GE indicated that the drif t value for 30 months does not include contributions due to the sensors. The sensors for the steam leak p detection system are thermocouples. A therm couple is..a factory

(- calibrated instrument that does not exhibit drift because of - .the principle of operation of the temperature sensing mechanism. Therefore, the 30 menth value for-drift identified by GE would represent drift.for-an entire instrument loop. The value determined by GE for-30. month drift _ for the steam _ leak detection system is within existing l surveillance test drift allowances.

For Unit 1, the NUMAC instrumentation was installed durJM the refueling outage in the Spring of 1992. For Unit 2, the'NUMM astrumentation will be installed during the refueling outage in the Winter of 1992-c 1993, prior to operation for the first 24 month refueling cycle. The l existing instrumentation for Unit 2 will operate under tha existing TS l 14 L<

1 -

_ , . - - , - w n. . _ - --

Attachment 1 j requirements until the replacement of the NUMAC instrumentation occurs.

The GE NUMAC instrumentation is associated with the following steam leak detection system instrument loops: TS Table 4.3.2.1-1, Items 1.f, 1.g,

! 3.b, 3.c, 4.d, 4.e, 4.f, 5.d, 5.e, and 5.f. .

Rosemount transmitters provide input to TS Table 4.3.2.1-1, Items 1.a.1,

1. a . 2, 1. c . e , 2. a .b, 3. a , 3. e , 4 . a . c , 5. a . c , 5. h, 6. a . b, 6. h , _ 7. a-

. .b. Drif t values for 30 months are published for Rosemount transmitters l in Rosemount Roport D8900126, and these published values are within the surveillance- test drift allowances. . Therefore, an increase in the

surveillance interval to accommodate a 24 month refueling cycle does _not

affect these Rosemount transmitters with respect to drift.

! Rosemount - trip units are functionally checked and setpoints verified a more frequently, and if necessary, recalibrated. These more frequent testing requirements remain unchanged. Therefore, an increase.in the surveillance interval to accommodate a 24 month fuel cycle does_not affect the Roaemount trip units with respect to drift, The instrument loops associated with TS Table 4.3.2.1-1, Items 4.h and i 5.h inclade timer relays. Although these timer relays have an 18 month calibration interval, they also have a more frequent functional test

that performs a calibration check. Since 'ne f unctional testing requirement- is unchanged, a drift evaluation for the 18 month -

calibration interval change is not required.

Based on the above evaluations, we have concluded that the impact on isolation actuation instrument availability, if any, is small as a result of the 24 month surveillance interval changes.

(4) Emergency Core Cooling System Instrumentation TS Table 4.3.3.1-1; Items 1.a .c, 2.a .d, 3. a . c , 3. e , 4.a .b, 4.d-

.f; pages 3/4 3-40 and 41 TS Table 4.3.5-1; Items a-c; page 3/4 3-56.

TS SR 4.5.1.c; Items 3-5; page 3/4 5-5 TS SR 4=.5.1.d.2.c; page 3/4 5-5 TS SR 4.7.3.c.4; page 3/4 7-10 TS SR 4.3.3.1 requires that each Emergency Core Cooling' System (ECCS) actuation instrumentation channel-identified in TS Table.4.3.3.1-1 shall be demonstrated operable by performing a channel calibration at _ the frequency shown in Table 4.3.3.1-1.- T3 SR 4.3.5.1 requires that ee.ch Reactor Core Isolation Cooling:(RCIC) system actuation instrumentation channel' identified in TS Table 4.3.5.1-1 shall be demonetrated operable by performing _ a .-channel calibration at the frequency shown in . Table 4.3.5.1-1. The calibration interval in TS Tables 4.3.3.1-1 and 4.3.5.1-1 is designated with an "R" which is defined in Table -1.1 - in the Definitions Section of TS as "At least once per 18 months-(550 days)."

The_"R" designation remains unchanged by this Change Request. However, since a change- to the definition of " R to accommodate a 24 month refueling cycle is proposed separately within a subsequent grcup-in this

. Change Request, the impact of an increase in the calibration intervcl to 15

I

~

Attachment 1 s

2 1 4

accommodate a 24 month refueling cycle on the ECCS and RCIC system actuation instrumentation is ' evaluated within this group. This evaluation is specific to the ECCS and RCIC actuation instrument .

channels indicated below.

TS. Table 4.3.3.1-1; Items

1. Core Spray System (CSS) i

a. Reactor Vessel Water Level - Low, Low , Low, Level 1

b. Drywell Pressure - High-

c. Reactor Vessel Pressure - Low

2. Low Pressure Coolant Iniection (LPCI) Mode of RHR System i.

9

a. Reactor Vessel Water Level - Low, Low, Low, Level 1 j b. Drywell Pressure - High

! c. Reactor Vessel Pressure - Low

d. Injection Valve Differential Pressure - Low (Permissive)

3. High Pressure Coolant Iniection (HPCI) System

) a. Reactor Vessel Water Level - Low, Low, Level 2

b. Drywell Pressure - High

c. Condensate Storage Tank Level - Low

e. Reactor Vessel Water. Level - High, Level 8 i 4. Automatic Depressurization System (ADS)

a. Reactor Vessel Water Level - Low, Low, Low, Level 1

, b. Drywell Pressure - High-

d. Core Spray Pump Discharge Pressure - High

e. RHR LPCI Mode Pump Discharge Pressure - High

! f. Reactor Vessel Water Level - Low,' Level 3 TS Table 4.3.5.1-1; Items

a. Reactor Vessel Wrter Level - Low, Low, Level 2

b. Reactor Vessel hater Level -_High, Level-8

c. Condensate Storage Tank Level - Low TS Table 4.3.3.1-1, Item.3.d, will not be extended to accommodate 4 24 month refueling cycle. The calibration interval designation of "R" for i TS Table 4.3.3.1-1, Item 3.d is proposed to be changed to "E". -The "E" designation is proposed to be defined in Table 1.1 of the Definitions Section of TS as "At least once per 18 months (550 days)" as-discussed and evaluated'in a subsequent group:within this Change Request. The

pror ased change from "R" to "E" for - TS -Table ' 4. 3. 3.1-1, Item 3.d, is an administrative change which= maintains the-calibration-interval at the p existing _18 month frequency.

TS SR 4.5.1.c requires that the ECCS shall be demonstrated operable by l performing the following at least once per 18 months. (1) TS SR 4.5.1.c.3 requires performing a channel calibration of the CSS, LPCI, i'

16 i

i- Attachment 1 1

and HPCI system discharge line " keep filled" a.' irm instrumentation. (2)

TS SR 4.5.1.c.4 requires performing a chantol calibration of the CSS header differential pressure instrumentation and verifying the setpoint to-be less than or equal to the allowable value of 4.4 paid. (3) TS-SR 4.5.1.c.5 requires performing a channel calibration of the LPCI-header differential pressure instrumentation and verifying the setpoint to be

less than or equal to the allowable value of 3.0 psid. In addition, TS SR 4.5.1.d.2.c requires demonstrating the operability of the ADS at

least once per 18 months by performing a channel calibration of the l accumulator backup compressed gas system low pressure alarm system and  !

verifying an alarm setpoint of 90 1 2 psig on decreasing pressure.

Also, TS SR 4.7.3.c.4 requires demonstrating the operability of the RCIC j sys. tem at least once per 18 months by performing a channel calibration  :

of the RCIC system discharge lino " keep filled" level alarm  !

Instrumentation. The calibration interval for these instruments is l proposed to be change from "at least once per 18 months" to "at least

once per 24 months."

l' The subject TS SRs currently require the calibration testing of the subject instrumentation nominally every 18 months. The calibration

surveillance is performed to ensure that the instrument is properly aligned so that actuation takes place at the previously evaluated setpoint to provide the required safety function. By increasing the refueling cycle - 1sngth, the time interval for the calibration

, surveillance of the subject instrumentation will be increased. However, as currently required by LGS TS, functional tests are performed during the refueling cycle more frequently than the calibration surveillance.

These functional tests detect failures of the instrumentation channels, except for field devices, such as transmitters, that are only tasted once every 18 months. Gross instrumentation failures are detected by j_ alarms or comparison with redundant and independent indications.

! Instrumentation purchased for these funct h s_are highly reliable and meet the stringent design _ criteria of safs;y related status. All ECCS

=

instrumentation is designed with redundant and independent channels p'

which provide means to verify proper instrumentation performance during operation, and adequate redundancy to ensure a high confidence of system performance even with the failure.of;a single component.. Based on the

, above discussion, we have concluded that -the impact on instrument availability, if cny, is small as a result of the change to 24 month surveillance intervals.

To verify this conclusion, an evaluation of a historical search of the surveillance tests for each instrument was performed. The search identified all failed or partially failed tests, and then~each failed or partially failed test was reviewed and evaluated. The purpose of this-evaluation was to demonstrate that the increased calibration surveillance interval would not increase the period an instrument would be unavailable.

The results of this search- support the above i conclusions that the impact on instrument availability, if any,. is small

as a result of the change in the subject surveillance interval.

l- A second evaluation performed an instrument - drif t analysis for the increase in the calibration interval to a maximum of 30 months. The

~

17 I

X Attachment 1 purpose of this evaluation was to determine whether or not projected drift values for 30 months are within existing surveillance test drift allowances. The instrument drift analysis was performed using the GE methodology previously described in response to Item No. 2 under the generic discussion regarding NRC GL No. 91-04, Enclosure 2. .The analysis was performed for the ITT Barton, Model No. 289A, low level alarm instrumentation (level switches) for the CS, LPCI, HPCI, and RCIC system discharge line " keep filled" systems (TS SRs 4.5.1.c.3 and 4.7.3.c.4), and the Mercold, Model No. DAW 7443RG24E, low pressure-alarm instrumentation for the ADS accumulator backup compressed gas system (TS i S) 4.5.1.d.2.c). The results of the analysis indicated that the

projected 30 month drift values for these instruments do not exceed the existing surveillance test allowances. Based on the drift analysis, we have concluded that an' increase in the surveillance interval to accommodate a 24 month refueling cycle will not af fect these instruments with respect to drift.

The following instrumentation was evaluated based on justification other than the drift analysis.

Rosemount Transmitters provide input to the following TS instrument channels: TS Tabl e 4 . 3 . 3 .1- 1, I tems 1. a . c , 2. a . d , 3. a . c , 4 . a . b , and 4.d .f; TS Table 4.3.5.1-1, Items a and c; and TS SRs 4.5.1.c.4, 4.5.1.c.5, and 4.5.1.d.2.c. Drift values for 30 months are published-for Rosemount transmitters in Rosemount Report D8900126, and - these published values are within the surveillance test drift allowances.

Therefore an increase in the surveillance interval to accommodate a 24 month refueling cycle does not affect Rosemount transmitters with respect to drift.

Rosemount trip units are functionally checked and setpoint verified more frequently, and if necessary, recalibrated. These more frequent testing requirements remain unchanged. Therefors, an increase in the surveillance interval to accommodate a 24 month fuel cycle does not affect the Rosemount trip units with respect to drift.

For LGS Unit 2 only, the ITT Barton pressure switches, Model No. RC6-2958201-13, have not been evaluated'for 30 month drift. A review of the surveillance tests indicates that there are only 3. data points per owitch since initial operation of Unit.2 in 1989. This is-insufficient data for the GE drift computer program to determine a 30 monthudrift value. Further, since the existing data _ indicates that the switches will not operate satisfactorily for 30 months, we will replace.the ITT Barton pressure switches with a design equivalent Mercold switch. The Mercold switches, which are used for the same application on Unit 1, demonstrate acceptable 30 month drift. Therefore, based on the commitment to replace the ITT Barton switches with design equivalent  ;

Mercold switches that demonstrate acceptable -30 month drift, the j surveillance interval for these pressure switches can be increased to accommodate a 24 month fuel cycle.

Based on the above evaluations, we have concluded that the impact _on ECCS instrument availability, if any, is small as a-result of the 24-month surveillance interval changes.

18

Attachment 1 4

(5) Monitoring 4nstrumentation TS Table 4.3.7.2-1; Items 1.a.1 .6, 1.b.1 .5, 1.c.1, 2.b .c, 3.a, and 4.; pages 3/4 3-71 and 72 TS Table 4.3.7.4-1; ltems 1, 2, and 4-18; page 3/4 3-83 TS Table 4. 3. 'i . 3-1; Items 1-7, 10 and 13; page 3/4 3-87 TS SR 4.3.7.6.a.2; page 3/4 3-89 TS SR 4.3.7.8.1.c; page 3/4 3-90 TS SR 4.3.7.8.2.c; page 3/4 3-91 TS SR 4.3.7.10.c; page 3/4 3-97 TS SR 4.4.2.1.b; page 3/4 4-7 TS SR 4.3.7.2.1 requires that each of the eelcmic monitoring instruments identified in TS Table 3.3.7.2-1 shall be demonstrated operable by performing a channel calibration at the frequency shown in Table 4.3.7.2-1. TS SR 4.3.7.4.1 requires that each remote shutdown monitoring instrumentation channel identified in TS Table 3.3.7.4-1 shall be demonstrated operable by performing a channel calibration at the frequency shown in Table 4.3.7.4-1. TS SR 4.3.7.5 requires that each accident monitoring instrumentation channel identified in Table 3.3.7.5-1 shall be demonstrated operable by performing a channel calibration at the frequency shown-in Table 4.3.7.S-1. The calibration interval in TS Tables 4. 3. 7. 2-1, 4. 3. 7. 4-1, and 4. 3. 7. 5-1 is designated with an "R" ehich is defined in Table 1.1 of the Definitions Section of TS as "At least once per 18 months (550 days)." The "R" designation remains unchanged by this Change Request. However, since a change to the definition of "R" to accommodate a 24 month refueling cycle is proposed separately within a subsequent group in this Change Request, the impact of an increane in the calibration interval to accommodate a 24 month refueling cycle on the seismic, remote shutdown, and accident monitoring instrumentation is evaluated within this group. This evaluation is specific to _the monitoring instrument channels listed below.

Seismic Monitoring; TS Table 4.3.7.2-1; Itema-

1. Triaxial Time-History Accelerographs (T/A's) (

a. Sensors

1) XE-VA-102 Primary Containment Foundation (Loc. 109-R15-177)

2) XE-VA-103 Containment Structure-(Diaphragm Slab)

3) XE-VA-104 Reactor Enclosure Founnotion (Loc. 111-R11-177)

4) XE-VA-105 Reactor Piping Support (Mn. Stm. Line 'D,'

El 313', in containment)

5) XE-VA-106 Outside. Containment on Seismic Category I Equipment, (RHR Heat Exchanger,. Loc. 102-R15-177)

6) XRSH-VA-107 Foundation of an-Independent Seismic Category I Structure (Spray Pond Pump House,-

El 237')

b. Recorders (Panel 00C693) 19

Attachment 1

1) XR-VA-102 for XE-VA-102

2) XR-VA-103 for XE-VA-103

3) XR-VA-104 for XE-VA-104

4) XR-VA-105 for XE-VA-105

5) XR-VA-106 for XE-VA-106

c. Triaxial Seismic Trigger (S/T)

1) XSH-VA-001 (Activates Items 1.b.1) thru 5) above

2. Triaxial Peak Recording Accelerograph (P/A's)

b. XR-VA-152 Reactor Piping (Mn. Stm. Line 'D,' El 313',

in containment)

c. XR-VA-153 Reactor Equipment Outside Containment (RHR Heat Exchanger, Loc. 203-R15-201)

3. Triaxial Seismic Switches

a. XSHH-VA-001 Primary Containment Foundation (Loc. 118-R16-177)

4. Triaxial Response F"ectrum Analyzer (RSA)

Remote Shutdown Monicop ,1; TS Table 4.3.7.4-1; Items.

1. Reactor Vessel Pressure

2. Reactor Vessel Water Level

4. Suppression Chamber Water Level

5. Suppression Chamber Water Temperature

6. Drywell Pressure

7. Drywell Temperature

8. RHR System Flow

9. RHR Service Water Pump Discharge Pressure

10. RHR Heat Exchanger Service Water Outlet Pressure

-11. RCIC System Flow

12. RCIC Turbine Speed

13. Emergency Service Water Pump Discharge Pressure

14. Condenaate Storaje Tank Level

15. RHR Heat Exchanger Bypass Valve Position Indication (0 - 100%)

16. RCIC Turbine Tripped Indication

17. RCIC Turbine Bearing Oil Pressure Low Indication

18. RCIC LP Bearing Oil Temperature High Indication Accident Monitoring; TS Table 4.3.7.5-1; Items

1. Reactor Vessel Pressure

2. Reactor Vessel Water Level

3. Suppression Chamber Water Level

4. Suppression Chamber Water Temperature

5. Suppression Chamber Air Temperature

6. Primcry Containment Pressure

7. Drywell Air Temperature

10. Safety / Relief Valve Position Indicators 20

Attachment 1 l

13. Neutron Flux l- Note that the radiation monitors specified in these TS Tables are i evaluated in a separate group in this Change Request.

4 The TS SRs listed below require that each of the specified monitoring l instrumentation shall be demonstrated operable by performing a channel calibration "at least once per 18 months."

j TS SR 4.3.7.6.a.2 - source range n.onitor channels TS SR 4.3.7.8.1.c - chlorine detection system subsystems L TS SR 4.3.7.8.2.c - toxic gas detection system subsystems TS SR 4.3.7.10.c - loose-parts detection system TS SR 4.4.2.1.b - acoustic monitor'for each safety / relief valve-l The proposed change involves changing the calibration interval from "at least once per 18 months" to "at least once per 24 months."

. In addition, the proposed change involves an administrative change to

] the format / layout of TS page 3/4 4-7. The format / layout of this page

was inadvertently changed when proposed in Technical Specification-Change Request (TSCR) No. 92-01-0, submitted to the NRC on May 15, 1992, and approved by the NRC through issuance -of Amendment Nos. 56 and 21 for LGS, Units 1 and 2, respectively. Since a change to the text on this page is proposed in this Change Request, we also propose to change the format / layout of . this page back to its original form with the -

exception of any changes to the text as a result of TSCR.No. 92-01-0 or i

this Change Request.

j. The subject TS SRs currently require the calibrution testing of . the subject instrumentation nominally every 18 months. The calibration -

surveillance is performed to ensure that the instrument is; properly aligned so that- actuation takes place at the previously; evaluated i

setpoint to provide the required safety function.- By increasing the refueling cycle length,- the time interval -for- the calibration _

, surveillance of the subject instrumentation will be increased. However, l as currently required by LGS TS, functional tests are. performed during the-refueling cycle more frequently _han.the calibration surveillance.

These functional tests detect failures in the instrumentation channels, except for-field devices, such as transmitters,:that are only. tested once every 18 months. Gross' instrumentation failures _are detected by '

alarms or comparison with redundant-and independent indications.

Inctrumentation purchased for these functions.are highly reliable. The monitoring. instrumentation that is_ classified as safety related meets the1 stringent design criteria of safety related status. This-includes redundancy- and . independent: channels which -ensures a- high confidence' of r

system. performance even with.the failure of a single component. Based on the above discussion, we have concluded that the impact on the

monitoring instrumentation availability, if. any,1s -small as a result of l

the change to 24 month surveillance intervals.

l The monitoring instrumentation that is classified as non-safety related also has been designed to criteria that provides reliability.

( 21 l

i

[ Attachment 1 i

Requirements for non-safety related . instrumentation that is classified as Category 2 instruments in accordance with the guidance provided in 4 NRC Regulatory Guide 1.97, " Instrumentation for Light-Water-Cooled ~

Nuclear Power Plants to Assess Plant and Environs Conditions During and Following an Accident," include the following:

4 a) environmental qualification, b) high reliable, battery backed power source, c) QA requirements consistent with the importance to safety i of the instrumentation, and d) diverse or backup instrument channels.

Other non-safety related inatrumentation is inherently . designed to I perform its intended function. .For example, seismic instrumentation 37 I designed to operate during a seismic event. Further, for the seismic-4 instrumentation there are redundant, mechanical instruments that consist 4 of a stylus and scratch plate. These mecnanical instruments provide j backup information in the c ant of an instrument failurs. Based on the i

above discussion, we have concluded that the impact on instrument-availability, if any, is small as a result of the change in the subject-l surveillance interval.

To verify the above conclusions,- an evaluation of a historical search of the surveillance tests for each instrument was performed. The search

l. Identified all f ailed or partially f ailed tests, and then ea: 5 f ailed or partially failed test was reviewed and evaluated. The purp e of this 4 evaluation was to demonstrate that the increasoa libration surveillance interval would not increase the period an instit ient would i be unavailable. The results- of this search support the above conclusions that the impact on instrument availability, if any, is small as a result of the change to the subject surveillance interval.

A second evaluation performed an instrument' drif t analysis for the

increase in the calibration interval to a maximum of 30 months. The

- purpose of this evaluation was?to determine whether or not projected drift values for 30 months-are-within the existing surveillance test drif t ellowances. The instrument drif t analysis was performed using the GE methodology previously described in response to Item No. 2 under the generic discussion regarding NRC .GL No. 91-04, Enclosure 2. The analysis was - performed for the Unholtz-Dickie ,- Model . Nos . P22 and P22MHA-2,- loose parts detection- system instrumentation (TS SR-4.3.7.10.c); the Simmond9' Precision, Model Nos. '10701F11060' and 10701D11000, suppression povl . water temperature accident monitoring-instrumentation (TS Table 4.3.7.5-1, Item 4); the NDT. Corp., Model-No.

104D, safety relief valve acoustic monitoring / valve position indication instrumentation (TS SR 4.4.2.1.b and TS Table-4.3.7.5-1, Item 10); the-Leeds & Northrup (L&N), Model No. Speedomax M, reactor vessel pressure accident monitor 1'g instrumentation.(TS Table 4.3.7.5.-1, Item 1), and reactor vessel water level accident monitoring instrumentation-(TS Table 4.3.7.5-1, Item 2); the Woodward RCIC turbine speed indication remote ~

shutdown monitoring instrumentation (TS Table 1.3.7.4-1, Item 12); the Limitorque, Model No. A6P6, RHR heat exchanger bypass valve position 4

indication . emote shutdown monitoring instrumentation (TS Table 4.3.7.4-1, Item 15,; and the Square D, Model No. 9012 ACW-3, RCIC turbine 22

Attachment 1 bearing low oil pressure indication remote shutdown monitoring instrumentation (TS Table 4 '. 3 . 7 . 4 - 1, Item 17). The results of tne ana)ysis-indicated that the projected-30 month drift values for these instruments do not - exceed the existing surveillance test allowances.

Based on the drift analysis, we have concluded that an increase in-the surveillance interval to accommodate a 24 month refueling cycle will not affect these instruments with respect to drift. ,

The following instrumentaticn was evaluated based on justification other than the drift analysis.

Although the instruments in TS SR 4.3.7.6.a.2 and/or TS Table 4.3.7.5-1, Item 13, have an 18 month calibration interval, they also have a more frequent testing requirement which includes a calibration check. Since the more frequent testing requirement is unchanged, a drift evaluation for the 18 month calibration interval change is not required.

Rosemount transmitters provide input to-the following TS instrum m y channels: TS Table 4.3.7.4-1, Items 1, 2 , 4, 6, 8-11, 13, and, 14;-and TS Table 4.3.7.5-1, Items 2, 3, and 6. Drift values for 30 mcnths are published for Rosemount transmitters in Rosemount Report D8900126, and these published values are within the surveillance test drift allowances. Therefcre, an -increase in the surveillance interval to accommodate a 24 month refueling cycle does not affect these Rosemount transmitters with respect to drift.-

Rosemount trip units are functionally checked and setpoint verified mere frequently, and if necessary, recalibrated. These more frequent testing requirements remain unchanged. Therefore, an increase in the surveillance interval to accommodate a 24 month fuel cycle does not affect the Rosemount trip units with respect to-drift.

Limit switches are mechanical devices that require mechanical adjustment only; drift is not applicable to-these devices. Therefore, an increase in the surveillance interval to accommodate a 24 month fuel cycle does.

not affect limit switches with respect-to drift.

Seismic monitoring instrumentation, manuf actured by Kinemetrics, Models FBA-3, SMA-3 and TS-3, doa's n0t have suf ficient historical data to determine a 30 month drift valun using the GE-drift computer program.

However, Kinemetrics has providea us with a letter indicating that the calibration interval for this instrumentation can be increased to 30 months. Based on the.Information provided by Kinemetrics, the calibration interval of the following TS instrument channels can be increased to accommodate a 24 month refueling cycle:-Table 4.3.7.2-1, Items 1.a.1 .6, 1.b.1 .5, 1.c.1; and 3.a.

The seismic-instruments that provide input to TS Table 4.3.7.2-1, Items 2.b- and 2.c, are triaxial peak acceleration recorders, Engdahl

. Enterprises, Moual No. PAR 400, designed to record the peak accelerations in three orthogonal directions that the instruments' mounting locations experience during a seismic event. These instruments are passive devices which use the _ mechanical energy imparted to them during a seismic event to record the data. The acceleration data is recorded on 23

-,--m,. - . - - . - - - - - . . - - . - - - -

Attachment 1 a replaceable medium within the instruments; the data is not transmitted to any other location. The data is retrieved after the-seismic event, and is used to verity design analyses in support of justitying plant

!vtegrity and operability.

These seismic instruments are part of the plant's seismic instrumentation system that includes peak acceleration recorders, time-hirtory accelerographs, response spectrum analyzer, seismic switch and seismic trigger. The seismic instrumentation mounted on Unit 1 and common structures and components satisfies the seismic instrumentation requirements for both Units 1 and 2. These instruments are not important to safety in that.they are not needed for safe shutdown nor do they interface with or control any "ucture, system, or component which is important to safety. In addition, these instruments do not control or initiate any protective or mitigating action. Also, these instruments do not present the plant operators with any on-line information which is used by the operators for the initiation of any protective or mitigating accions.

The manufacturer recommends periodic replacement of some of the components (e.g., gasket, 0-rings) or the peak acceleration recorders.

This recommended replacement period exceeds 30 months. The peak acceleratica recorders contain an indicating desiccant which, according to the manuf ar:turer's recommendation and surveillance test directions, is replaced only when the desiccant iicates that it is moist (i.e., a color change from blue to pink). Since these instruments are sealed devices, the probability that the proposed extended surveillance period will fully expend the capacity of the desiccant and result in a failure of the instruments due to corronion is very low. The manufacturer of these instruments has found a calibration interval of 30 months to be acceptable.

The proposed change in the_ surveillance frequency of these instruments do not introduce any new failure modes to the instruments,'and there is no indication that lengthening t he calibration period will significantly increase the probability of occurrence of the existing failure modes of the instruments. Therefore we have concluded that an increase in the surveillance interval to accommodate a 24 month refueling cycle will have negligible, if any, impact on this seismic monitoring instrumentation.

The same type of device (i.e., TS Table 4.3.7.2-1, Item 2.a) was previously evaluated for an increase in the. surveillance interval to accommodate a 24 month refueling cycle in TSCR No. 92-01-0 submitted to the NRC on May 15 ,. 1992, and approved by the NRC on August 20, 1992 through issuance of Amendment Nos. 56 and 21 for LGS, Units 1 and 2, respectively.

The chlorine detection tnstrument loops (TS SR 4.3.7.8.1.c) have a more frequent test)ng regt.. ment which includes a calibration check. Since the more frequent toit.', requirement is unchanged, a drift evaluation for an increase in ti calibration interval to accommodate a 24 month fuel cycle is not required.

24

r Attachment 1 The seismic recording channel (TS Table 4.3.7.2-1, Item 4) has a more f requent testing requirement which includes a calibration check. Since the more frequent testing requirament is unchanged, a drift evaluation for an increase in the calibration inter al to accommodate a 24 month fuel cycle is not required. ,

The calibration data for the temperature instrumentation manufactured by Bailey for drywell/ suppression chamber air temperature loops (Td Table 1 4.3.7.4.-1, Item 7, and TS Table 4.3.7.5-1, Items 5 and 7) has been >

reviewed. This review indicates that from May, 1986 to August, 1990 for Unit 1 and from July, 1989 to March, 1991 for Unit 2, the calibration checks identified the as-found values within limits. Minor adjustments were made to the as-found values to bring the as-left values closer to the setpcint. Based on the review of existing data that shows essentially no drift for periods of 18 months and greater (for Unit 1),

the surveillance interval for the Bailey instrumentation can be increased to accommodate a 24 month fuel cycle. Further, those inctruments will continue to be monitored for drift using the trending program being established for instrument drift.

The loose parts monitoring instrumentation (TS SR 4.3.7.10.c) except for the sensors, has a more frequent testing requirement which includes a calibration check. Since the more frequent testing requirement is unchanged, a drift evaluation for an increase in the calibration '

inte_ val to accommodate a 24 month fuel cycle is not required.

A review of the surveillanco tests anacciated with the RCIC low pressure becring oil temperature instrumentation (TS Table 4.3.7.4-1, Item 18)  :

indicates that for Unit 1, no calibration adjustments were required for 42 months. For Unit 2, no calibration adjustments were required for 23 months. Therefore, the historical data supports the increase in the calibration interval for this instrumentation to aupport a.24 month refueling cycle. Note, a 30 month drif t value was not calculated-by the GE drift computer program for this instrumentation because there is an insufficient number of data points for a- statiscical evaluation.

Further, those instruments will continue to be monitored for drif t using the trending program being established for instrument drift.

The - instrument loops for the sunpression chamber water temperature indication on the remote shutdos. panel (TS Table 4. 3. 7. 4-1, Item 5) have been recently installed, and therefore, insufficient historical calibration data for thwe instrument loops exists to determine a 30 month drift value using the GE drift computer orogram. For Unit 1, the only calibration data available is~from an' initial calibration check.

For Unit 2, there is data on'An initial calibration check and data from a calibration check performe C 18 months later. Data-from the second calibration check for Unit 2 indicates that the as-found readings were acceptable and rocalibration was not required. Although a : minimal amount of *aistorical calibration data exists, the results .of the existing calibrations show satisfactory drift within- existing surveillane test drif t allowances. Further, the drift identified was on~ half of the allowable surveillance. test ~ value. Based on the existing calibration data for 18 months that shows drift only half of the allowable value, the surveillance interval for these instruments can 25.

i l j Attachm:nt 1 I

be increased to support a 24 month refueling cycle. Also, those I instruments will continue to be monitored for drift using the trending program being established for instrument drift.

4 i Based on the above evaluations, we have concluded that the impact on l seismic, remoto shutdown, and accident on monitoring instrument i i availability, if any, is small as a result of the 24 month surveillanco interval changes.

(6) Radiation / Effluents Monitoring Instrumentation TS Table 4.3.1.1-1; Item 6 ; page 3/4 3-7 j TS Table 4.3.2.1-1; Items 1.b, 6.c, 6.0, 7.c.1, 7.c.2, and 7.d; 4 pages 3/4 3-27, 3/4 3-30, and 3/4 3-31

]

TS Table 4.3.7.1-1; Items 1, 2.a.1, 2.b, and 3; page 3/4 3-66 TS Table 4.3.7.4-1; Item 19; pago 3/4 3-83 TS Tablo 4.3.7.5-1; Items 11 and 12; page 3/4 3-07 TS Table 4.3.7.12-1; Item 4.a; page 3/4 3-107 TS SR 4.4.3.1.a; pago~3/4 4-0 TO SRs 4.3.1.1, 4.3.2.1, 4.3.7.1, 4.3.7.4.1, 4.3.7.5, and 4.3.7.12 require that each instrumentation channel shall be damonstrated operable i by performing a channel calibration at the frequency shown in TS Tables .

i 4.3.1.1-1, 4.3.2.1-1, 4.3.7.1-1, 4.3.7.4-1, 4.3.7.5-1, and 4.3.7.12-1,

• respectively. The calibration interval in these TS Tables is designated with an "R" which is defined in Table 1.1 of the Definitions Section of TS as "At least once per 18 months (550 days)." The "R" designation remains unchanged by-this Chango Request. However, since a change to the definition of " R" to accommodato a 24 month refueling cycle is proposed separately within a subsequent group in this Change Request, the impact of an increase in the-calibration interval-to accommodato a 24 month refueling cycle - on the subject instrumentation is ovaluated 4 within this group. This evaluation is specific to the instrumentation channels listed below.

Reactor Protection System; TS Table 4.3.1.1-1; Item

6. Main Steam Line Radiation - High i Isolation Actuation; TS Table 4.3.2.1-1; Items l 1. Main Steam Line Isolation

b. Main Steam Line Radiation - High

6. Primary Ct.1tainment Isolation

c. North Stack Effluent Radiation - High

e. Reactor Enclosure Ventilation Exhaust Duct Radiation -

High

7. Secondary Containment Isolation c.1 Refueling Area Unit i Ventilation Exhaust Duct Radiation 26 w- -e y.# y g 9p g w9 4 y .m.-. _ , , . .~

9 p4 ,9 ..,. , , , ,

- - . - - _ - - - __ . - _- ~. - _.

k Attachmsnt 1 I

- High 3

c.2 Refueling Area Unit 2 Ventilation Exhaust Duct Radiation

., - High

d. Reactor Enclosure Ventilation Exhaust Duct Radiation -

High Radiation Monitoring; TS Table 4.3.7.1-1; Items f 1. Main Control Room Normal Fresh Air Supply Radiation Monitor

2. Area Monitors i

a. Criticality Monitors i

1) Spent Fuel Storage Pool

b. Control Room Direct Radiation Monitor i

3. Reactor Enclosure Cooling Water Radiation Monitor Remote Shutdown System; TS Table 4.3.7.4-1; Item

19. Residual Heat Removal (RHR) Heat Exchanger Discharge Line High

l Radiation Indication

Accident Monitoring; TF Table 4.3.7.5-1; Items

11. Primary Containment Post LOCA Radiation Monitors

, 12. North Stack Wide Range Accident Monitors Offqas Monitoring; TS Table 4.3.7.1.7-1; Item

4. Main Condenser offgas pre-treatment radioactivity monitor (steam 4 jet-air ejector)

a. Noble gas activity monitor TS SR 4.4.3.1.a requires that the reactor coolant system leakage detection systems shall be demonstrated operable by performing a channel calibration of the primary containment atmosphere gaseous radioactivity

monitoring system "at least once per 18 months." The proposed change involves changing this calibration interval to "at least once por 24

months."

The subject TS SRs currently require the calibration testing of the

, subject instrumentation nominally every 18 months. The ca.libration surveillance is performod to ensure that the instrument.is properly aligned so that actuation takes place at the previously evaluated setpoint to provide the required safety function. By increasing the' refueling cycle length,-the-time interval for calibration surveillance of the subject instrumentation will be increased. However, as currently-required by the LGS TS, functional tests are performed during the refueling -cycle more frequently than the calibration surveillance.

These functional tests detect failures of the instrumentation channels, except for field devices, such as transmitters, that are only tested once every 18 months. Gross instrumentation failures are detected by alarms or comparison with redundant and independent indications.

e 27

._ _ _ _ ~ . . __ _ . _. _ .. - . _ _ - _ _

Attachmsnt 1 i

Instrumentation purchased f or thes9 functions are highly reliable. The radiation /offluents monitoring instrumentation that in classified as >

safety related meets the stringent design criteria of safety related status. This includes redundancy and independent channels which ensures a high confidence of system performanco even with the failure of a single compone.it. Based on the above discussion, we have concluded that

. the impact on instrument availability, if any, is small as a result of j the change to 24 month surveillance intervals.

Portions of the radiation /of fluents monitoring instrumentation aro non-

! safety related. Again, there are multiple and diverse instrument channels that provide backup information in the event of a single channel failure.

To verify this conclusion, an evaluation of a historical search of the surveillance tests for each instrument was performed. The search Identified all f ailed or partially f ailed tests, and then each failed or

! partially failed test was reviewed and evaluated. The purpose of this 1 ovaluation was to demonstrate that the increased calibration i surveillance interval would not increase the period an instrument would i be unavailable. The results of this search support the above

, conclusions that the impact on instrument availability, if any, is small 2

as a result of the change in the surveillance interval.

• A second evalu tion performed an instrument drift analysis for the increase in the calibration interval to a maximum of 30 months. The purpose of this evaluation was to determine whether or not projected 3

drift values for 30 months are within existing surveillance-test drift allowances. The instrument drift analysis was performed using the GE

! methodology previously described in response to Item No. 2 under the 4

generic discussion regarding NRC GL No . 04, Enclosure 2. The

} analysis was performed for the Brooks, Model No. 3602-10D2E1 A, . flow a indicating switch for the Reactor enclosure cooling water radiation monitor (TS Table 4.3.7.1-1, Item 3); the General Electric (GE) Model No.145C3284AAG001, radiation recorder for the reactor enclosure cooling water radiation monitor (TS Table 4.3.7.1-1, Item 3), and radiation indicating switch for the primary containment atmosphere gaseous radioactivity monitoring systems (TS SR 4.4.3.1.a) ; the GE, Model No.

238X660G007, radiation indicating switch for the main condenser of fgas -

noble gas activity monitor (TS Table 4.3.7.12-1, Item 4.a); the GE, Model No. 237X892G005, radiation indicating switch for the spent fuol storage pool criticality monitor (TS Table 4.3.7.1-1, Item 2.a.1); the General Atomic, Model No. RD-23, radiation elements for (1) the main control room normal fresh air supply radiation monitor (TS Table 4.3.7.1-1, Item 1),.(2) the primary containment isolation - north stack effluent radiation monitor-(TS Table 4.3.2.1-1, Itom 6.c), and (3) the north stack wide range accident monitor (TS Table 4.3.7.5-1, Item 12);

and the General Atomic, Model No. RD-23-20, radiation element for the-primary containment post - LOCA radiation monitors (TS Table 4.3.7.5-1, Item 11). The results of the analysis indicated that the projected 30 month drift values for these instruments do not exceed the existing surveillance test allowances. Based on the drif t analysis, we have concluded that an increase in the surveillance interval to accommodate a 24 - month refueling cycle will not affect these instruments with 28

Attachment 1 l

respect to drift.

The thanfollowing the drift instrumentation analysis. was evaluated based on justification other United Electric flow switches, model J274D-232, main Item condenser of fgas-noble gas activity monitors (TS Tableprovide4.3.7.12-1, input to the 4.a). These switches presently have more requirements which include a calibration check. Since frequent testing the more frequent testing 30 monthrequirement remains unchanged, these switches do not require a drift evaluation.

The downscale and high voltage trip instrumentation manufactured by GE for the primary containment gaseous radiation monitor (TS SR 4.4.3.1.a) was not evaluated using the GE computer program based on the fact that insufficient data was available due to numerous setpoint changes.

review of the functional tests for these setpoints indicate that theA setpoints have not been recalibrated over a period of 46 months.

historical data supports an increase in the calibration interval toThis months. 30

)

GE's NUMAC microprocessor based instrumentation has instrumentation associated with the following radiation replaced existing loops: TS Table 4. 3.1.1 - 1, Item 6 and TS Table 4.3.2.1-1, Item monitoring 1.b. The NUMAC instrumentation is to evaluate 30 month drift using a replacement with insuf ficient historical data the GE drift computer program.

However, GE conclusion has 30 that provided us with documented data that supports the month drift values do not surveillance test drift exceed existing allowances. Therefore, based on GE's documentation, the calibration interval for the loops using NUMAC instrumentation can be increasedradiation monitoring month refueling cycle. to support the 24 with the following radiation monitoring TS 6.e, 7.c.1, 7.c.2, loopsGE radiation monitoring Table 4. 3. 2.1-1, Item and 7.d; and TS Table 4. 3. 7.1-1, Item 2.b. These monitor's setpoints and if required, areare checked during a more frequent functional test, recalibrated.

Since this more frequent testing requirement is unchanged, a 30 month drift evaluation is not required.

Existing Bailey radiation monitoring recorders for the Unit 1 and Unit 2 refueling 4.3.2.1-1, area ventilation exhaust duct radiation monitors (TS Table recorders. Items The 7.c.1 and 7.c.2toshall be replaced with Westronics modification replace the recorders provides justification that the accuracy, meet existing surveillance test allowances.including drift for 30 months, shall telecon with the vendor. Therefore, based This has been confirmed by on the replacement of recorders with allowances, 30 month interval the calibration accuracies that for the shall meet recorders can besurveillance extended test to accommodate a 24 month refueling cycle.

Based on the above evaluations, we have concluded that the impact on radiation / effluent monitoring inctrument availability, if any, is small 29

Attachment 1 as a > sult of the 24 month surveillance interval changes. ,

i i (1; Co m o.. 7od Block Instrumentation i

Yq MUe 4. 3.6-1; Item 5.a; page 3/4 3-61 l

! PS SR 4.3.6 requires that each control rod block trip systems and  !

instrumentation channels shall be demonstrated operable by periorming a l channel calibration at the frequency shown in TS Table 4.3.6-1. The  :

' calibration interval for the subject instrumentation in Tablo 4.3.6-1 is  !

l designated with an "R" which is defined in Table 1.1 of the Definitions l

Section of TS as "At least once per 18 months (550 days)." The "R" designation remains unchanged by this Change Request. However, since a change to the definition of "R" to accommodate a 24 month refueling cycle is proposed separately within a subsequent group in this change 1 Request, the impact of an increase in the calibration interval to accommodate a 24 month refueling cycle on the subject control rod block instrumentation is evaluated within this group. This evaluation is

, specific to the-control rod block instrumentation channel listed below, f

4 TS Table 4.3.6-1; Item i

5. Scram Discharco Volume

a. Water Level - high The subject TS SR currently requires the calibration testing of the subject instrumentation nominally every 18 months. The calibration surveillance is performed to ensure that the instrument is properly aligned so that actuation takes place at the previously evaluated 4

setpoint to provide the required safety function. By increasing the refueling cycle length, the time interval for calibration of the subject instrumentation will be increased. However, as currently required by l LGS TS, functional tests are performed during the operating cycle at

more frequent intervals than the calibration surveillance. These i

functional tests detect f ailures of the instrumentation channels, except for field devices, such as transmitters, that are only tested once every 18 months. Gross instrumentation failures are detected by alarms or comparison with redundant and independent indications.

The control rod block instrumentation is classified'as safety related.

Instrumentation purchased for this function is highly reliable and meets the stringent design criteria of safety related status. This includes redundancy and. independent channels which ensures a high confidence of system performance even with the failure of a single component. Based on the above discussion, we have concluded-that impact.on instrument  ;

availability, if any, is small as a result of the change to 24 month surveillance intervals.

To verify the above conclusion, an evaluation of a historical search of the surveillance tests for each instrument was performed. The search identified all failed or partially f ailed tests,- and then each f ailed or partially failed test was reviewed and evaluated. The purpose of this l evaluation was Lto demonstrate that the increased calibration i surveillance interval would not increase the period an instrument would l 30 l

L r

Attachmont 1 i

j: be unavailable. The results of this search support the above l j- conclusions that the impact on instrument availability, if any, is small l

as a result of the change in the subject surveillance intorval.

k A second evaluation performed an instrument drift analysis for the increase in the calibration interval to a maximum of 30 months. The i purpose of this evaluation was to determine whether or not projected 1 i drift values for 30 months are within existing surveillance test drift  ;

i allowances. The instrument drift analysis was performed using the GE. 1

, methodology previously described in response to item No. 2 under the j generic discussion regarding NRC GL No. 91-04, Enclosure 2. The

! analysis was_ performed for the Magnetrol, Model No. 57-3003-006, level i switch for the scram discharge volume high water level instrument-1 cha...iel (TS Table 4.3.6-1, item 5.a). .The results of the_ analysis 4 indicated that the projected 30 month drift velues_for this instrument

! does not exceed the existing surveillance test allowances. Based on the 4

drift analysis, we have concluded that an increase in the surveillance

! interval to accommodate a 24 month refueling cycle will not affect this j instrument with 1;ospect to drift.

Based on the above evaluations, we have concluded that the impact '

control rod block instrument availability, if any, is small as a resu.t ,

of the 24 month surveillance interval changes;  ;

i

, (8) Recirculation Pump Trip Instrur,entation l

l TS Table-4.3.4.1-1; Items 1.and 2; page 3/4 3-45 TS Table 4.3.4.2-1; Items 1 and 2; page 3/4 3-51

(

l TS SR 4.3.4.1.1 requires that each anticipated transient withoist scram j (ATWS) recirculation pump trip (RPT) - system instrumentation shall be i demonstrated operable by performing a channel calibration at the l frequency shown in TS Table 4.3.4.1-1. TS SR 4.3.4.2.1 requires that L each end-of-cycle (EOC) RPT system instrumentation channel shall - be -

' demonstrated operable by performing a channel calibration at

- the frequency shown in Table 4.3.4.2-1. The calibration interval in these tables is-designated with an "R" which is defined in' Table 1.1 of the Definitions-section of_TS as "At least once per 18 months (550 days)."

~ The "R" designation remains unchanged by this Change Request. However, since a change -to the definitipn of "R" to accommodate a 24 - month -

refueling cycle is proposed sepaltately within a subsequent group in~the Change Request, the impact of an Mcrease in the calibration interval to

[ _ accommodate' a 24 month _ refueling- cycle on the ATWS and EOC-APT

instrumentation is evaluated within this _ group.

- ThisJevaluation is-j.

specific to the RPT instrumentation _ channels list below.

ATWS RPT Actuation; TS Table 4.3.4'.1-1; Items u

l 1. Turbine'stop valve-closure .

2. Turbine control-valve -fast closure i..

i EOC-RPT System; TS Table 4.3.4.2-It Items

! t

1. Turbine stop_ valve - closure i

31'-

,,t't+g--T 1W- p-N h- f N

Attachment 1

2. Turbine control valve - fast closure The subject TS SRs currently require the calibration testing of the subject instrumentation nominally every 18 months. The calibration survejllance is perf ormed to ensure that the instrument is properly aligned so that actuation takes place at the previously evaluated setpoint to provide the required safety function. By increasing the refueling cycle length, the time interval for calibration surveillance of the subject instrumentation will be increased. However, as currently l required by LGS TS, functional tests are performed during the refueling cycle more frequently than the calibration surveillance. These functional tests detect f ailures of the instrumentation channels, except for field devices, such as transmitters, that are only tested once every 18 months. Gross instrumentation failures are detected by alarms or comparison with redundant and independent indications.

Instrumentation purchased for these functions are highly reliable and meet the stringent design criteria of safety related status. - All RPT instrumentation (i.e., ATWS and EOC)is designed with redundant and independent channels which provide means to verify proper instrumentation performance during operation, and adequate redundancy to ensure a high confidence of system performance even with the failure of a single component. Based on the above discussion, we have concluded that the impact on instrumentation availability, if any, is small as a result of the change to 24 month surveillance intervals.

To verify this conclusion, an evaluation of a historical search of the surveillance tests for each instrument was performed. The search identified all f ailed or partially f ailed tests, and then each f ailed or partially failed test was reviewed and evaluated. The purpose of this evaluation was to demonstrate that the increased calibration surveillance J nterval would not increase the period an instrument would

be unavailable. The results of this search support the above

' conclusions that the impact on instrument availability, if a'ny, is small as a result of the change in the surveillance interval.

) A second evaluation performed an instrument drift analysis for the i increase in the calibration interval to a maximum of 30 months. The

purpose of this evaluation was to determine whether or not projected

drift values for 30 months are within existing surveillance test drift allowances. The instrument drift analysis was performed using the GE methodology previously described in response to Item No. 2 under the generic discussion regarding NRC GL No. 04, Enclosure 2.- The analysis was performed for the GE, analog trip unit, (1) level switch for the ATWS RPT reactor vessel water level channel (TS Table 4.3.4.1-1,

, Item .1) , and (2) pressure switch for the ATWS RPT reactor vessel pressure channel (TS Table 4.3.4.1-1, Item 2). The results of the-analysis indicated that the projected 30 month drift values for these instruments do not exceed the existing surveillance test ' allowances.

2 Based on the drift analysis, we have concluded that an increase'in the surveillance interval to accommodate a 24 month refueling cycle will not affect these instruments with respect to drift.

The following instrumentation was evaluated based on justification other 32

Attachmsnt 1 than the drift analysis.

Rosemount transmitters provide inputs for the following channels: TS Table 4.3.4.1-1, Items 1 and 2. Drift values for 30 months are published for Rosemount transmitters in Rosemount Report D8900126, and these published values are within the surveillance test drift allowances. Therefore, an increase in the surveillance interval to accommodate a 24 month refueling cycle does not affect those Rosemount transmitters with respect to drift.

Limit switches are mechanical devices that require mechanical adjustment only; drift is not applicable to these devices. Therefore, an increase in the surveillance interval to accommodate a 24 month fuel cycle does not affect limit switches with respect to drift.

The pressure switch for-the main turbine control valve (MTCV) electro-hydraulic control (EllC) system pressure has been evaluated using the GE drift computer program. This evaluation showed that these instruments (ITT Barton pressure switches for Unit 1 and Barksdale for Unit 2) experienced significant drift. This drift was found to be 88 psi for the Barksdale pressure switches and ill psi for the ITT Barton pressure switches. This drift exceeds the current allowable drif t of 60 psi which is identified in NEDC 31336, and the more conservative 35 psi

identified in the surveillance tests which reflects the TS requirement i for the End-of-Cycle Recirculation Pump Trip (EOC-RPT) . The function of

! this pressure input is to provide an anticipatory reactor scram and the EOC-RPT in the event of the fast closure of the MTCVs which could l result in a significant pressure transient following a generator load reject.

After reviewing the accident scenario _and considering the potential impact to the analysis performed for this event, we have concluded that the only impact f rom drif t in the non-conservative direction would be to the response time of the reactor scram and EOC-RPT signal. As identified in the NEDC-31336, upon initiation of the event (i.e.,

generator load reject), the fast acting solenoid valve will energize 1

allowing the trip oil to drain. The pressure will decrease . from a nominal 1600 psi to 0-psi within-8-10 milliseconds. At approximately 400 psig, the disk dump valve will open-to allow the MTCV to start to l

fast close.- Since it takes approximately 10 milliseconds for pressure to reach zero, we have concluded that-the 200 psi of drift would, in the worst case, cause an additional time delay of no greater that 3 milliseconds. This 3 millisecond . time delay will be added to- the overall response time of the trip. The " Transient Protection Parameters Verification Form" (GE Form OPL-3) identifies that the time-between when the MTCV starts to fast close and the pressure switch actuates will be no greater than 30 milliseconds. OPL-3 also identifies an additional 250 milliseconds allowed for the RPS and control rods to start to insert. Historically, the response times for these functions has been-

, in the-order of 150 milliseconds, allowing significant margin to the input . allowed .for in OPL-3. The response time for the EOC-RPT is required to be 175 milliseconds as specified in TS. Again, historically these response times have been significantly lower'than that input into the analysis.

1 i

33 n

Attachmsnt 1

In addition to the impact of drif t on the response time, it should also

be understood that the logic for these trips provides redundancy which j would make it highly unlikely that all instruments composing a channel j would drift to the same degree and in the same direction. Considering any potential drift in the conservative direction, it has been

- determined that this is not a concern since the coincident logic for i these trips should prevent any spurious reactor scrams or EOC-RPTs, and any drif t high will be identified during the operating cycle and require j corrective action. When evaluating the maximum drift projected by the  ;

3 BWROG program and determining the potential impact on the plant's safety l 4 analysis, we have concluded that this potential drift has a negligible l 1 impact and does not increase the consequence of an accident previously )

evaluated in the SAR.

During the third refueling outage (1R03) for Unit 1 and the first refueling outage (2R01) for Unit 2 at LGS, modifications were performed i on the EHC system to eliminate severe pressure oscillations and -l vibration of EHC piping. These modifications to the EHC system have

- only been in place for one full cycle of operation on Unit 1. Based on l

the results of the calibrations performed during the fourth refueling 3

outage (IR04) for Unit 1, the instrument drift was reduced within the 1 allowable surveillance test values. It is being postulated that'the severe drift problem could have been caused by the EHC system vibration and pressure oscillations. ,

Based on the above observation, we have concluded that the surveillance ,

I interval can be increased to a nominal 24 months since data for one full cycle shows that the cause of the severe drift problem has been satisfactorily reduced and that the severe drif t has a negligible impact on the accident analysis, Further, these instrumonts will continue to l be monitored for drift using the trending program being established for instrument drift.

Based on the above evaluations, we have concluded that the impact on RPT j instrument availability, if any,.is small as a result of the 24 month surveillance interval changes.

(9) Electrical Protection Instrumentation TS Table 4.3.3.1-1; Items 5.a and 5.b; page 3/4 3-41

, TS SR 4.8.4.1.a.1; Items a, b, and c; page 3/4-8-21 ,

TS SR 4.8.4.1.a.2; page 3/4-8-22 TS SR 4.8.4.3.b; page 3/4 8-28 1

TS SR 4.3.3.1 requires that each emergency core cooling system (ECCS) actuation instrumentation channel shall be demonstrated operable by performing a channel functional test and channel calibration at the-frequency shown in TS Table 4.3.3.1-1. This evaluation is specific to the ECCS instrumentation channels listed below.

TS Table 4.3.3.1-1; Items

5. Loss of Power i

34 1_

I

Attachment 1 t

j

~l:

a. 4.16 kV Emergency Bus Undervoltage (Loss of Voltage)

b. 4.16 kV Emergency Bus Undervoltage (Degraded Voltage)

The channel functional test interval for TS Table 4.3.3.1-1, Item 5.a a and the calibration interval for TS Table 4.3.3.1-1, Item 5.b are designated with an "R" which is defined in Table 1.1 of the Definitions

! Section of the TS as "At least once per 18 months (550 days)." The "R" l

designation remains unchanged by this Change Request. However, since a change to the definition of "R" to accommodate a 24 month refueling cycle is proposed separately within a subsequent group in this Change Request, the impact of an increase in the functional test and .

calibration intervals for the subject ECCS instrumentation to accommodate a 24 month refueling cyclo is evaluated within this group.

TS SRs 4.8.4.1.a.1.a, 4.8.4.1.a.1.b, and 4 . 8. 4 .1. a .1. c , requi re that each of the primary containment penetration conductor overcurrent j protective devices shown in Table 3.8.4.1-1 be demonstrated operable at least once per 18 months. Medium voltage 4.16kV circuit breakers are verified to be operable by selecting, on a rotating basis, at least 10%

l of the circuit breakers and performing:

I A channel calibration of the associated protective relays, a) i b) An integrated system functional test which includes simulated >

automatic actuation of the system and verifying that each relay and associated circuit breakers and overcurrent control i circuits function as designed, c) For each circuit breaker found inoperable during these functional tests, an additional representative sample of at

, least 10% of all the circuit breakers of the inoperable type

. shall also be functionally tested until no more failures are

found or all circuit breakers of that type have been functionally tested.

. TS SR 4.8.4.1.a.2 requires that the 480 VAC circuit breakers chown in Table 3.8.4.1-1 be demonstrated operable at least once per 18 months by selecting, on a rotating basis, a representative sample of at least 10%

of each type of the circuit breaker.

Testing of these circuit breakers shall consist of injecting a current with a value equal to 300% of the pickup of the long time delay trip element and 150% of the pickup of the short time delay trip element, and verifying that the circuit breaker operates within the ~ time delay 4

bandwidth for that current specified by the manufacturer. The instantaneous element shall be tested by injecting a current equal to 120% of the pickup value of the element and verifying that the circuit breaker trips instantaneously with no intentional time delay. Molded case circuit breaker testing shall also follow this procedure except that generally no . more than two trip elements, time delay and instantaneous, will be involved; and for instantaneous magnetic only breakers the . instantaneous element will be tested by injecting a current equal to -20%/+40% of the pickup value of the element. Circuit breakers found inoperable during functional testing shall be restored to OPERABLE 35

Attachm:nt 1 status prior to resuming operation. For each circuit breaker found inoperable during these functional tests, an additional representative sample of at least 10% of all the circuit breakers of the inoperable type shall also be functionally tested until no more failures are found or all circuit breakers of that type have been functionally tested.

TS SR 4.8.4.3.b requires that the Reactor Protection System (RPS) electric power monitoring channels be demonstrated operable at least once per 18 months. This is verified by demonstrating the operability of the overvoltage, undervoltage, and underfrequency protective instrumentation by performance of a channel calibration including simulated automatic actuation of the protective relcys, tripping logic, and output circuit breakers. The following setpoints shall be verified:

overvoltage 5132 VAC, undervoltage 2109 VAC, and underfrequency 257 Hz.

The proposed change involves changing the surveillance frequency from "at lease once per 18 months" to "at least once per 24 months."

The onsite electric power system for LGS Units 1 and 2 is divided into two major categories: Class IE and non-Class 1E. This review evaluates the electrical protection devices for the 4kV emergency . bus undervoltage relays, RPS output breakers, RPS electrical power monitoring relays, 4kV primary containment overcurrent protective relays, and 480-Volt primary containment circuit breakers. The Class IE power system supplies all Class 1E loads that are needed for safe and orderly shutdown. The on-site Class 1E electric power system is divided into . four independent divisions per unit. Any combination of.three-out-of-four divisions of Class 1E_ power in each unit can shutdown the unit safely and maintain it in a safe shutdown condition.

The design of the electric power systems complies with position statements of Regulatory Guide 1.53, " Application of the Single Failure Criterion to Nuc1 car Power Plant Protection System." Consistent with the single failure criterion, only one failure is assumed to occur in the system following.a design basis event. No single component failure results in the simultaneous loss.of AC power to the four divisions. A single failure cannot propagate to another load division. Furthermore, each of the subject components required to be tested by the subject surveillance requirements is provided with redundant capability. Based on the designed redundancy and reliability of the subject systems, we have concluded that the impact, if any, on component availability is '

small from the change in the subject surveillance. interval.

To verify this conclusion, an evaluation of a historical search of the surveillance tests for each instrument was performed. The search identified all failed or partially failed tests, and then each f ailed or partially failed test was reviewed and evaluated. The purpose of-this evaluation was to demonstrate that the increased calibration surveillance interval would not increase the period an instrument would i be unavailable. The results of this search support the above l l

t conclusions that the impact on instrument availability,. if any, is small ,

as a result of the change in the subject surveillance interval.  ;

A second evaluation performed an instrumcat drift analysis for the increase in the calibration interval to a maximum of 30 monthe. The 1

36 r

Attachmunt 1 purpose of this evaluation was to determine whether or not projected drift values for 30 months are within existing surveillance test drift allowances. The instrument drift analysis was performed using the GE methodC.ogy previously described in response to Item No. 2 under the generic discussion regarding NRC GL No. 91-04, Enclosure 2. This analysis was performed for the Gould-Brown Boveri, Model Nos. 211T4175 and 211U4175, and GE, Model No. 12SFF31 CIA, protective relays for the RPS electric power monitoring channels (TS SR 4.8.4.3.b); and the GE, Model Nos. 12HFC21B1A and 12IFC66KDIA, protective relays for the primary containment penetration conductor overcurrent protective devices (TS SR 4.8.4.1.a.1, Items a, b, and c). The results of the analysis indicate that the projected 30 Fonth drift values for these instruments do not exceed the existing surveillance test drift allowances. Based on the drift analysis, we hat? concluded that an increase in the surveillance interval. to accommodat- a 24 month refueling will not affect those instruments with respect to drift.

The following instrumentation was evaluated based on justification other than the drift analysis.

The ,u t coil devices associated with TS SR 4.8.4.3 b were not included in t.., drift study baced on the fact that these components are not affected by drift. Tnerefore, an increase in the survuillance interval to accommodate a 24 month refueling cycle does not af fset these devices with respect to drift. Protective devices. associated with TS Table 4.3.3.1-1, Item 5.b, were not included in the drift study based on the fact that a more frequent functional test is performed for these relays which includes a calibration check. Since this more frequent testing requirement remains unchanged, a drif t evaluation for an increase in the calibration interval to accommodate a 24 month refueling cycle is not required.

Based on the above evaluations, we have concluded that the impact on electrical protection instrument availability, if any, is small as a result of the 24 month surveillance interval changes.

(10) Miscellaneous Instrumentation TS SR 4.1. 3. 5.b.1; Items a and b; page 3/4 1-10 TS SR 4.3.8.2.c; page 3/4 3-111 TS Table 4.3.9.1-1; Item 1; page 3/4 3-115 TS SR 4.1.3.5.b.1 requires that each control rod scram accumulator shall be demonstrated operable "at least once per 18 months" by performing:'a) a channel -functional test of the leak. detectors, and b) . a channel calibration-of the pressure detectors, and verifying an alarm setpoint of equal to or-greater than 955 psig on decreasing pressure. TS SR 4.3.B.2.c requires that the turbine %verspeed protection system shall be demonstrated operable "at least-once per 18 months" by performing a channel calibration of the turbine overspeed protection instrumentation.

The proposed change involves changing the surveillance interval-(i.e.,

for 'he channel functional test and/or the channel calibration, as spt. fied) for this instrumentation to "at least once per 24 months."

37

Attcchmant 1 TS SR 4.3.9.1 requires that each feedwater/ main turbine trip system actuation instrumentation channel shall be demonstrated operable by performing a channel calibration at the frequency shown in TS Table 4.3.9.1-1. The calibration interval in TS Table 4.3.9.1-1 is designated with an "R" which is defined in Table 1.1 of the Definitions Section of the TS as "At least once per 18 months (550 days) ." The "R" designation remains unchanged by this Change Request. However, since a change to the definition of "R" to accommodate a 24 month refueling cycle is proposad separately within this Change Request, the impact of an increase in the calibration interval to accommodate a 24 mont refueling cycle on the feedwator/ main turbine trip system instrumentation is evaluated within this group. l This evaluation is specific to the instrument channel listed below. J J

TS Table 4.3.9.1-1; Item  !

1. React vessel water level - high, level 8 The subject TS SRs currently require the calibration testing of the i

subject instrumentation nominally every 18 months. The calibration surveillance is performed to ensure that the instrument is properly aligned so that actuation takes place at the previously evaluated setpoint to provide the required safety function. By increasing the refueling cycle length, the time interval for calibration surveillance

. of the subject instrumentation will be increased. However, as currently required by LGS TS, functional tests are performed during the operating cycle more frequently than the calibration surveillance. These

, functional tests detect failures of the instrumentation channels, except for field devices, such as transmitters, that are only tested once overy

, 18 months. Gross instrumentation failures ar0_ detected by alarms or

comparison with redundant and independent indications.

. The miscellaneous instrumentation evaluated in this group (i.e. , turbine

, overspeed protection and feedwater/ main turbine trip actuation) is

! classified as non-safety related. However, there are multiple and 4

diverse instrument channels that provide backup information in the event of a single channel failure.

. The functional surveillance test, required by TS SR 4.1.3.5.b.1.a, is

performed to ensure that the instrument is operational within its design '

range. By increasing the refueling cycle-length, the time interval for the functional surveillance test of the subject instrumentation will be increased. The level switch functions to indicate a leak in_-the HCU

, accumulator seal. This function is only to provide an indication of a potential failure of the accumulator seal which would prevent the HCU from performing its safety function. The switch serves no active safety function. Furthermore, during the operating cycle, these switches are only exposed -to a nitrogen environment which should reduce _ the likelihood of any corrosive mechanism preventing the switches from providing accurate indication.

Based on the above discussion, we have concluded - that the impact on instrument availability, if any, is small as a result of the change to 24 month surveillance intervals.

38 i

, .- , . - ~ - ,

Attachmsnt 1

$ To verify this conclusion, an evaluation of a historical search of the

] surveillance tests for each instrument was performed. The rearch i identified all f ailed or partially f ailed tests, and then each f ailed or

]~ partially failed test was reviewed and evaluated. The purpose of this

! evaluation was to demonstrate that the increased calibration

[ surveillance interval would not increase the period an instrument would l be unavailable. The results of this search supports- the above j conclusions that the impact on instrument availability, if any, is small as a result of the change in the subject surveillance interval.

! A second evaluation performed an instrument drift analysis for the.

l Ancrease in the calibration interval to a maximum of 30 months. The

purpose of this evaluation was to determine whether or . not' projected j drift values for 30 months are within existing surveillance test drift i allowances. The instrument drift analysis was performed using.the GE methodology previously_ described in response to Item No. 2 under the

generic discussion regarding NRC GL No. 91-04, Enclosure 2. The i analysis was performed for-the-i GE, Model No. 994D129G005, -turbine overspeed protection instrumentation

] (TS SR 4.3.8.2.c); and Bailey, Model No. 745110AAAA1, level switch for i the feedwater/ main turbine trip reactor' vessel water- level 4 "s'crumentation (TS Table- 4. 3. 9.1-1, Item 1)'. The results of the f, c alys!s indicated that the projected 30 month drift values for these l' instruments do not exceed the existing surveillance test allowances.

Based on the drift analysis, we have concluded that an increase in the

! surveillance interval to accommodate a 24 month refueling cycle will not i affect these instruments with respect to.driit.

i-I The following instrumentation was evaluated based on justification other j than the drift analysis.

[ Rosemount transmitters provide input to TS Table l 4. 3. 9.1-1,- -Item - 1.

Drift values for 30 months are published for Rosemount transmitters in i.

Rosemount Report D8900126, and these published _- values _ are within. the surveillance test drift al2owances. Therefore an increase- in the surveillance interval to accommodate a 24 month refueling cycle does not affect these Rosemount transmitters:with-respect to drift.

[ Rosemount trip units are functionally. checked.and the setpoint verified

, more frequently,-and if necessary, recalibrated._ These more frequent

testing requirements remain unchanged. - Therefore,'an7 increase'in the

surveillance interval to accommodate a 24 month fuel . cycle - does not -5 4 affect the-Rosemount trip units with respect to drift.

4 The pressure' switches for the hydraulic ~ control unit'(HCU)l Accumulators '

(TS SR 4.1.3.5.b.1.b) have been: evaluated?using the GE drift computer .

progn n. - This evaluatiorc showed :that the drif t for 'an 18 month period i exceeued the current surveillance test allowance.- :The'drif t problem was -l Identified'in GE Service'Information? Letter (SIL) No._'429._ This.SIL L identified that a significant amount ofcdrift was occurring /with these

pressure switches and recommended that the' alarm - setpoint - for? these

. switches be. raised to allow for this drift. LGS evaluated this problem and submitted Technical Specification Change Request (TSCR)_ No. 89-12 to .

l the NRC to'1r>wer the TS setpoint to equal- to ar greater than 955 psig on

~

'l L

= 39 .

-, ,- - _ - - ,, .. ., . ..m. -, ._;.._.._....__..m. - _ . . _.m

l Attcchmsnt 1 decreasing pressure. The NRC evaluated this change and determined that l the change was acceptable. In this evaluation, the safety significance '

i of these pressure switches was also discussed. This discussion identified that the pressure switches serve as a warning to the operators to ensure that with the loss of a control rod drive (CRD) pump, there is still suf ficient pressure to ensure the control rods will be cble to be scrammed. With 185 separate pressure switches, it is improbable that the majority of the pressure switches would drift significc 41y in the non-conservativo direction. Therefore, the operator would still have a significant number of back-up indications of a potential loss of the control rod scram function.

Furthermore, as required by TS SR 4.1.3.5.a, the pressure in the scram accumulators is checked to be greater than or equal-to 955 psig every 7 days. -If an accumulator is found with low pressure less than 955 psig without the corresponding alarm, action will be taken to recalibrate the pressure switch. Finally, as shown in the drif t study for these instruments, the substantial portion of drift occurs around the seven month interval. Between seven (7) months and 30 months, dri't is not as ,

significant. Based on the above discuulon, the fact that the drift problem with these switches has been evaluated by GE in SIL No. 429, and that the TS change was approved by the NRC in the SER for TSCR No. 89-12, we conclude that the change for an increase to a 24 month-calibration frequency is acceptable. Further, these instruments will

continue to be monitored for drift using the trending program being l established for instrument drift.

l l

Based on the above evaluations, we have concluded that the impact on miscellaneous instrument availability, if any, is small as a result of the 24 month surveillance interval changes. >

l l (11) Emergency Diesel Generators (EDGS) .

TS SR 4.8.1.1.2.e; Items 1 through 13; pages 3/4 8-4 through 3/4 8-7 Bases Sections 3/4.8.1; page B 3/4 8-2 l TS SR 4.8.1.1.2.0, Items 2 through 7 und 9 through 13, require that the

(- Emergency Diesel Generators (EDGs) be demonstrated operable "at least i

once each refueling cycle" by verifying the following.

Each EDG has the capability to reject a load of greater than or

l. equal to that of the RHR Pump Motor (992kW) for while maintaining l voltage at 4285 i420 volta and frequency at 60 11.2 Hz.

L Each.EDG has the capability to reject a load of 2850 kW without L tripping. The generator voltage shal1~ not exceed 4784 volts during l and following the load rejection.

l j

Upon simulating a loss-of-offsite power.

l a) De-energization of the emergency busses is accompanied by load l shedding from the emergency busses.

40 I .

I l.

Attachment 1 b) The EDG starts on the auto-start signal, energizes the emergency busses within 10 seconds, and energizos the auto-connected loads through the individual load timors and operates for greator than or equal to 5 minutos while its generator is loaded with the shutdown loads. After energization, the steady-stato voltage and frequency of the emergency busses shall be maintained at 4285 1420 volts and 60 '

11.2 Hz during this test.

- The EDG starts on the auto-start signal and operates on standby for  ;

greater than or equal to 5 minutos upon the initiation of an Emergency Core Cooling Systems (ECCS) actuation test signal, without loss-of-of fsite power. The generator voltage and frequency shall reach 4285 1420 volts and 60 11.2 Hz within 10 seconds after the auto-start signal; the steady-stato genarator voltage and frequency shall be maintained within these limits during this test.

Upon simulating a loss-of-of feito power in conjunction with an ECCS actuation tost signal.

a) The load sheds and the emergency.bussos do-energizo.

b) The EDG starts on the auto-start signal, energizes the ,

emergency bussos within 10 seconds, onorgizes the auto-connected shutdown loads through the individual load timers, and operates for greator than or equal to 5 minutes while its  ;

generator is loaded with the omorgency loads.

After energization, the steady-state voltage and frequency of-the omorgancy busses shall be maintained at 4285 1420 volts and 60 11.2 Hz during this test.

All a womatic EDG trips, except engine overspeed and generator differential overcurrent, are automatically bypassed upon an ECCS actuation signal.

The auto-connected loads to each EDG do not exceed the 2000-hour rating of 3100 kW.

The EDG's capability tot a) synchronize with the offsite power source while the generator is loaded with its emergency loads upon a simulated restoration of offsite power, b) transfer its loads to the offsito power source, and c) be restored to its standby status.

The EDG operating in a test mode and connected to its bus, a simulated ECCS actuation signa 1' overrides the test mode by:

a) returning the EDG to standby operation, and b). automatically energizing the emergency it-is with offsite 41

Attechm nt 1 power.

The automatic loads sequence timers are operable with the interval between each load block within i 10% of its design interval.

The following EDG lockout features prevent the EDG from starting only when required a) control room switch in Pull-to Lock (with Local / Remote Switch in Remote),

! b) Local / Remote Switch in Local, and c) Emergency Stop The proposed change would reword-the TS SR 4.8.1.1.2.e from "At least once each refueling cycle" to "At the following frequency."

In addition, the proposed change would add the words "Every 24 months" to the beginning of TS SRs 4.8.1.1.2.e.2 through .7 and .9 throuOn .13.

The proposed change would also require a change to Bases Section 3/4.8.1 to indicate an exception to the 18 month testing interval guidance

, provided in Regulatory Guide 1.108, " Periodic Testing of Diesel Generator Units Used as Onsite ElectrJe Power Systems at Nuclear Power Plants," Revision 1, dated Auguet 1977.

The standby AC power supply system consists of four EDGS per LGS unit.

The EDGS are sized so that any three EDGS can supply all the necesnary

power requirements for one unit in the Design Basis Accident condition.

The EDGS are designed to start and be able to accept load within 10

, seconds. Four independent 4kV engineered cafety feature switchgear i assemblies are provided for each unit. Each EDG feeds an independent 4kV bus for each unit. In addition, each EDG starts automatically upon

, a Loss of Offsite Power (LOOP) or detection of a Loss-of-Coolant Accident (LOCA). The necessary safety related loads are applied in a preset time sequence. Each generator operates independently and without paralleling during a LOOP or LOCA signal. Because of the system

,, redundancy, and the fact that any significant failures of the EDGS or associated components would be detected during the performance of TS required monthly surveillance testing, the impact on system availability, if any, is small. A historical review of surveillance test results did not identify any evidence of failures which would invalidate this conclusion.

! ?S SR _ 4 . 8.1.1. 2. e , Items 1 and 8, currently require the EDGs - be .

demonstrated operable "at least once each refueling cycle" by performing l the following.

Subjecting the diesel to an inspection in accordance with  ;

procedures prepared in conjunction- with. Its ' manufacturer's '

recommendations for this class of standby service.  ;

Verifying the diesel generator operat is for at least 24 hours2.777778e-4 days <br />0.00667 hours <br />3.968254e-5 weeks <br />9.132e-6 months <br />.

-During the first 2 hours2.314815e-5 days <br />5.555556e-4 hours <br />3.306878e-6 weeks <br />7.61e-7 months <br /> of this test, the diusel generator shall l be loaded to an indicated 2950-3050 KW and during the remaining 22 l 42 l

^

Attachment 3 hours3.472222e-5 days <br />8.333333e-4 hours <br />4.960317e-6 weeks <br />1.1415e-6 months <br /> of this test, the diesel generator shall be loaded to an 4

Indicated 2700 - 2000 KW. Within 5 minutes after completing this 24 - hour test, perf orm Surveillance Requirement 4. 8.1.1. 2.e. 4.b) .

Ths proposed change would add the words "Every 18 months" to the  :

beginning of TS SRs 4.8.1.1.2.e.1 and .8 due to the previously I identified proposed change to the wording of TS SR 4.8.1.1.2.e, and j because these TS SRs will continue to be performed on an 10 month basis.

Therefore, this proposed change is considered to be an administrative i change to maintain the current surveillance frequency for TS SRs 4.8.1.1.2.e.1 and .8.

Based on the above evaluations, we have concluded that the impact on system availability, if any, is small as a result of the 24 month surveillance interval changes.

(12) Define Group TS Table 1.1; page 3/4 1-9  ;

TS Table 4.3.7.2-1; Item 2.a; page 3/4 3-72 j 4 TS SR 4.1.5.d; pago 3/4 1-20 TS SR 4.6.3.2; page 3/4 6-18 1 TS SR 4.8.1.1.1.b; page 3/4 8-3 J TS SR 4.8.2.1.d; page 3/4 8-11 TS SR 4.8.2.1.o; page 3/4 8-12 TS SR 4.8.2.1.fi page 3/4 8-12 4 TS Bases; Section 4.0.2; page B 3/4 0-4 Table 1.1 of the Definitions Section of TS defines the " Surveillance Frequency Notation" used throughout the LGS TS. Table 1.1 currently defines the "R" surveillance frequency notation as "At least once per 18 months (550 days)." To accommodate a 24 month refueling cycle, the proposed change involves (1) adding the words "(Refueling Interval)" to the "R" notation, and (2) changing the definition'of "R" to "At least once per 24 months (731 days)." This is considered a_ generic change to the-TS based on the fact that each TS line item with a designated frequency of "R" will be impacted when the_ definition of "R" is changed.

Ilowever, all line items impacted by the change to the-definition of "R" have been individually evaluated in previous groups within this Change Request, and in TGCR No. 92-02-0. _ Based on- the results of the evaluations performed for each individual affected TS line item, we have ,

conc 1Lded that the impact, if any, on-instrument availability is small as a. result of the change to 24 month refueling cycles.

In addition,-to' accommodate those surveillance frequencies that remain unchanged by this Change Request but are currently designated with the "R" notation, the proposed chenge involves adding a new surveillance frequency notation of "E" with a corresponding definition of "At_least once per 18 months (550 days)" to TS Table 1.1 Any specific changes to tho' individual TS line items have been identified and evaldated in previous groups within this Change Request. This change is considered an administrative change since it simply provides ' a mechattism for maintaining the current 18 month surveillance frequency for specific TS line items for which a change to accommodate a 24 month refueling cycle 43 i

i

, -. . ~ - -- .. - __. __ .- .- .. ._ - -

! Attachment 1 could not be or was not justified.

Table 4.3.7.2-1, Item t.a is being changed as a result of the change to the Definitions section of the TS. This proposed change is an adm".nistrative change which involves removing the asterisk and corresponding footnote, and replacing it with the standard designation l Of "R". This TS line item was changed as a result of TSCR No. 92-01-0.

l The change to a 24 month surveillance frequency to this item was avaluisted and found acceptable by the NRC through the issuance of

..mendment Nos. 56 and 21 for LGS , Units 1 and 2, respectively.

l The following TS SRs specify "during shutdown" ur "during COLD SHUTDOWN l l or REFUELING" a part of the surveillance frequency: T5 SRs 4.1.5.d,  !

4.6.3.2, 1. 8 .1.1 t . t', 4.8.2.1.d, 4.8.2.1.e, 4.8.2.1.f. The changes ,

being proposed re :ove these words in accordance with the - guidance l provided in N% GL No. 41-04. GL No. 91-04 states thac, "Because the ,

I terms " Hot" and " Cold Shutdown" are defined in the Technical l Spovificatione ne cperating codes or conditions, the Ldded restriction j to perfovm certeln surveillances during shutdown may be misinterpreted.

l This re8ttJction onsures that a surveilleace would only bo performed I when it is consistent with safe plan $ aperation. However, this l consideration is valia for other surveille uos that are performed during power operation, plant otartup, or shutde T., but is not-addressed by

! restricting the conduct of these surveillances. The stare concludes

! that the TS need not restrict surveillances as only being performed daring shutdown. " The removal of the restriction to per'orm certain TS st rveillances during shutdown has been evaluated. Ba' sed on the fact tnM. the performance of all surveillances is administrative 1y controlled to ensure they are performed during safe plant conditions, this change is considered to be a clarifying change to the LGS TS to make.all requirements consistent and to avoid potential misunderstandings as indicated in GL No. 91-04.

Finally, a change to the Bases Section 4.0.2 is proposed to change "18 months" to "24 months." This change is considered only an administratira change based on the fact that the change is only being

, made to ensure the TS Bases remain consistent with the TS requirements.

In addition, the sentence "Likewise, it is not the intent that REFUELING INTERVAL surveillances be performed during power operation unless it is consistent with safe plant operation." is proposed to be added to the l

Lases to provide clarification to TS Section 4.0.2 in.accordance with the Guidance provided in GL No. 91-04.

Safety Assessment' Summary Tho proposed TS changes involve a change in the surveillance testing l intervals. from 18 months to 24 months to f acilitate the current change in the LGS, Units 1 and 2 refueling cycles from 18 months to 24 months. The i proposed changes are to the surveillance frequencies only, and do not involve

a change te the TS surveillance requirements themselves or the way in which I the surveillances are performed. Additionally, the impact of the proposed TS Ohanges on the availability of equipment or systems required to mitigate the consequences of an accident, if any, is small based on other-more frequent

testing or the availability of redundant systems or equipment. A review of 44 l

l l

Attachment 1 i

surveillance test history demonstrated that there was no evidence of any fajlures that would invalidate the abova conclusions.

Information Supporting a Findin'] of No Significant Hazards Consideration We have concluded that the proposed changes to the LGS *S, to facilitate a change from 18 month to 24 month refueling cycles, do not constitute a Sigulficent llazards Consideration. In support of this determination, an evaluation of each of the three standards set forth in 10CFR50.92 is provided  ;

below.  ;

l

1. The_ proposed TS_ changes do not involve a significant increase in the probability or, consequences of a n_ accident previously evaluated.

The proposed TS changes involve a change in the surveillance testing intervals to facilitate the current change in the LGS Unit 1 and Unit 2 refueling cycles from 18 months to 24 months. The proposed TS changes do not physically impact the plant nor do they impact any design or functional requirements of the associated

syrtoms. That is, the proposed TS changes do not degrade the

! performance or increase the challengeb of any safety systems assumed to f u r.: tion in the accident analysis. The proposed TS i changes do not impact the TS surveillance requirements themselves 4

nor the way in which the surveillances are performed. In addition, the proposed TS changes do not introduce any new accident

, initiators since no accidents previously evaluated have as their initiators anything related to the change in the frequency of i surveillance testing. Also, the proposed TS changes do not affect 1 the availability of equipment or systems required to mitigate the i

consequences of an accident because of other, more frequent testing or the availability of redundant systems or equipment. Furthermore, an historical review of surveillance test results indicated that there was no evidence of any failures that would invalidate the above conclusions. Therefore, the proposed TS changes do not

-l increase the probability or consequences of an accident previously evaluated.

l 2

2. The proposed TS changes do not create the possibility of a new or dif ferent kind of accident f rom any accident previously evaluated.

The proposed Te changes involve a change in the surveillance 4

testing intervals to facilitate the current change in the LGS Unit 1 and Unit 2 refueling cycles from 18 months to 24 months. The proposed TS-changes do not introduce nor increase the_ number of f ailure mechanisnis of a new or dif ferent type than those previously evaluated since there are no physical changes being made to the facility. Additionally, the. surveillance test requirements themselves, other than the frequency, and the way surveillance i

tests are performed will remain unchanged. Furthermm e, an historical review of surveillance test results indicated that there

, was no evidence of any failures that would invalidate the1above i conclusions. Therefore, the proposed TS changes do not create the L

possibility of- a new or dif ferent - kind of accident from any

[

l Attachmont 1 i

previously evaluated.

4

3. The proposed TS changes do not involve a sigg ficant reduction in a margin of safety.

i Although the proposed TS chan es will result in an increase in the l 1

interval between surveillh e tests, the impact on system i availability, if any, is shall based on other, more frequent i testing ur redundant systems c,r equipment. Furthermore, a review  !

of surveillance test history demonstrated that there is no evidence of any f ailures that would impact the availability of the systems.

Therefore, the assumptions in the plant licensing basis are not  ;

Impacted, and the proposed TS changes do not redueo the margin of i j cafety of the affected equipment / components.

]

4 Information Supporting an Environmental Assessment An environmental assessment is not required for the changes proposed by this Change Request because the requested changes conform to the criteria for

" actions eligible for categorical exclusion," as specified in 1DCFR51.22(c)(9). The requested changes will have no impact on the onvironment. The requested changes do not involve a significant _ hazards

! consideration as discussed in the preceding section. The requested changes i

do not involve a significant change in the types or significant increase in

the amounts of any effluents that may be released offsite. In addition, the proposed changes do not involve a significant increase in individual or cumulative occupational radiation oxposure.

Conclusion l The Clant Operations Review Committee and the Nuclear Review Board have reviewed these proposed changes to the TS and have concluded that they do not

involve en unreviewed safety question, or a significant ~ hazards consideration, and will not endanger the hea1G. and safety of the public.

e 1

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