Text

Issuance of Amendment No. 132 Revise Technical Specifications 3.3.1, Reactor Trip System Instrumentation, and 3.3.2, Engineered Safety Feature Actuation System Instrumentation
	ML18213A369
Person / Time
Site:	Ginna
Issue date:	11/13/2018
From:	V Sreenivas; Plant Licensing Branch 1
To:	Bryan Hanson; Exelon Generation Co
	Sreenivas V, NRR/DORL/LPL1, 415-2596
References
	EPID L-2017-LLA-0388
	Download: ML18213A369 (23)
	v • d • e

UNITED STATES NUCLEAR REGULATORY COMMISSION WASHINGTON, D.C. 20555-0001 November 13, 2018 Mr. Bryan C. Hanson Senior Vice President Exelon Generation Company, LLC President and Chief Nuclear Officer Exelon Nuclear 4300 Winfield Road Warrenville, IL 60555

SUBJECT:

R. E. GINNA NUCLEAR POWER PLANT - ISSUANCE OF AMENDMENT NO. 132 TO REVISE TECHNICAL SPECIFICATIONS 3.3.1, "REACTOR TRIP SYSTEM INSTRUMENTATION," AND 3.3.2, "ENGINEERED SAFETY FEATURE ACTUATION SYSTEM INSTRUMENTATION" (EPID L-2017-LLA-0388)

Dear Mr. Hanson:

The U.S. Nuclear Regulatory Commission (the Commission) has issued the enclosed Amendment No. 132 to Renewed Facility Operating License No. DPR-18 for the R. E. Ginna Nuclear Power Plant in response to your application dated November 16, 2017.

The amendment revises Technical Specifications 3.3.1, "Reactor Trip System Instrumentation,"

and 3.3.2, "Engineered Safety Feature Actuation System Instrumentation," to reflect the standard technical specification wording for Westinghouse plants with installed bypass capability. These changes also revise the required action notes in Technical Specifications 3.3.1 and 3.3.2.

A copy of the safety evaluation is also enclosed. A notice of issuance will be included in the Commission's biweekly Federal Register notice.

Sincerely, V. Sreenivas, Project Manager Plant Licensing Branch I Division of Operating Reactor Licensing Office of Nuclear Reactor Regulation Docket No. 50-244

Enclosures:

1. Amendment No. 132 to Renewed DPR-18

2. Safety Evaluation cc: Listserv

UNITED STATES NUCLEAR REGULATORY COMMISSION WASHINGTON, D.C. 20555-0001 EXELON GENERATION COMPANY, LLC DOCKET NO. 50-244 R. E. GINNA NUCLEAR POWER PLANT AMENDMENT TO RENEWED FACILITY OPERATING LICENSE Amendment No. 132 Renewed License No. DPR-18

1. The U.S. Nuclear Regulatory Commission (the Commission) has found that:

A. The application for amendment by Exelon Generation Company, LLC (the licensee), dated November 16, 2017, complies with the standards and requirements of the Atomic Energy Act of 1954, as amended (the Act), and the Commission's rules and regulations set forth in 10 CFR Chapter I; B. The facility will operate in conformity with the application, the provisions of the Act, and the rules and regulations of the Commission; C. There is reasonable assurance (i) that the activities authorized by this amendment can be conducted without endangering the health and safety of the public, and (ii) that such activities will be conducted in compliance with the Commission's regulations; D. The issuance of this amendment will not be inimical to the common defense and security or to the health and safety of the public; and E. The issuance of this amendment is in accordance with 10 CFR Part 51 of the Commission's regulations and all applicable requirements have been satisfied.

Enclosure 1

2. Accordingly, the license is amended by changes as indicated in the attachment to this license amendment, and paragraph 2.C.(2) of Renewed Facility Operating License No. DPR-18 is hereby amended to read as follows:

(2) Technical Specifications The Technical Specifications contained in Appendix A, as revised through Amendment No. 132, are hereby incorporated in the renewed license. Exelon Generation shall operate the facility in accordance with the Technical Specifications.

3. This license amendment is effective as of its date of issuance and shall be implemented within 60 days.

FOR THE NUCLEAR REGULATORY COMMISSION 9~D~

James G. Danna, Chief Plant Licensing Branch I Division of Operating Reactor Licensing Office of Nuclear Reactor Regulation

Attachment:

Changes to the Renewed Facility Operating License and Technical Specifications Date of Issuance: November 1 3 ,* 2 O1 8

ATTACHMENT TO LICENSE AMENDMENT NO. 132 R. E. GINNA NUCLEAR POWER PLANT AMENDMENT TO RENEWED FACILITY OPERATING LICENSE NO. DPR-18 DOCKET NO. 50-244 Replace the following pages of the Renewed Facility Operating License No. DPR-18 and Appendix A, Technical Specifications, with the attached revised pages. The revised pages are identified by amendment number and contain marginal lines indicating the areas of change.

Renewed Facility Operating License Remove Insert 3 3 Technical Specifications Remove Insert 3.3.1-2 3.3.1-2 3.3.1-4 3.3.1-4 3.3.1-5 3.3.1-5 3.3.1-6 3.3.1-6 3.3.1-9 3.3.1-9 3.3.1-10 3.3.1-10 3.3.2-2 3.3.2-2 3.3.2-3 3.3.2-3 3.3.2-4 3.3.2-4

(b) Exelon Generation pursuant to the Act and 10 CFR Part 70, to possess and use four (4) mixed oxide fuel assemblies in accordance with the RG&E's application dated December 14, 1797 (transmitted by letter dated December 20, 1979), as supplemented February 20, 1980, and March 5, 1980; (3) Exelon Generation pursuant to the Act and 10 CFR Parts 30, 40, and 70 to receive, possess, and use at any time any byproduct, source, and special nuclear material as sealed neutron sources for reactor startup, sealed sources for reactor instrumentation and radiation monitoring equipment calibration, and as fission detectors in amounts as required.

(4) Exelon Generation pursuant to the Act and 10 CFR Parts 30, 40, and 70, to receive, possess and use in amounts as required any byproduct, source or special nuclear material without restriction to chemical or physical form, for sample analysis or instrument calibration or associated with radioactive apparatus or components; and (5) Exelon Generation pursuant to the Act and 10 CFR Parts 30 and 70, to possess, but not separate, such byproduct and special nuclear materials as may be produced by the operation of the facility.

C. This license shall be deemed to contain and is subject to the conditions specified in the following Commission regulations in 10 CFR Part 20, Section 30.34 of Part 30, Section 40.41 of Part 40, Sections 50.54 and 50.59 of Part 50, and Section 70.32 of Part 70; and is subject to all applicable provisions of the Act and rules, regulations and orders of the Commission now or hereafter in effect; and is subject to the additional conditions specified below:

(1) Maximum Power Level Exelon Generation is authorized to operate the facility at steady-state power levels up to a maximum of 1775 megawatts (thermal).

(2) Technical Specifications The Technical Specifications contained in Appendix A, as revised through Amendment No. 132, are hereby incorporated in the renewed license.

Exelon Generation shall operate the facility in accordance with the Technical Specifications.

(3) Fire Protection Exelon Generation shall implement and maintain in effect all provisions of the approved fire protection program that comply with 10 CFR 50.48(a) and 10 CFR 50.48(c), as specified in the licensee's amendment request dated March 28, 2013, supplemented by letters dated December 17, 2013; January 29, 2014; February 28, 2014; September 5, 2014; September 24, 2014; December 4, 2014; March 18, 2015; June 11, 2015; August 7, 2015; and as approved in the safety evaluation report dated November 23, 2015.

Except where NRC approval for changes or deviations is required R. E. Ginna Nuclear Power Plant Amendment No. 132

RTS Instrumentation 3.3.1 CONDITION REQUIRED ACTION COMPLETION TIME D. As required by Required D.1 Action A.1 and referenced ------------------

by Table 3.3.1-1. -NOTE-

1. For Functions 2a, 2b, 5, 6, 7b, 8, and 13, one channel may be bypassed for up to 4 hours4.62963e-5 days 0.00111 hours 6.613757e-6 weeks 1.522e-6 months for surveillance testing.

2. The inoperable channel may be bypassed for up to 4 hours4.62963e-5 days 0.00111 hours 6.613757e-6 weeks 1.522e-6 months for surveillance testing of other channels.

Place channel in trip. 6 hours6.944444e-5 days 0.00167 hours 9.920635e-6 weeks 2.283e-6 months E. As required by Required E.1 Reduce THERMAL POVVER 2 hours2.314815e-5 days 5.555556e-4 hours 3.306878e-6 weeks 7.61e-7 months Action A. 1 and referenced to < SE-11 amps.

by Table 3.3.1-1.

OR E.2

- NOTE-Required Action E.2 is not applicable when:

a. Two channels are inoperable, or

b. THERMAL POWER is

< SE-11 amps.

Increase THERMAL 2 hours2.314815e-5 days 5.555556e-4 hours 3.306878e-6 weeks 7.61e-7 months POWER to~ 8% RTP.

F. As required by Required F.1 Open RTBs and RTBBs Immediately upon Action A.1 and referenced upon discovery of two discovery of two by Table 3.3.1-1. inoperable channels. inoperable channels AND R.E. Ginna Nuclear Power Plant 3.3.1-2 Amendment 132

RTS Instrumentation 3.3.1 CONDITION REQUIRED ACTION COMPLETION TIME H.3 Restore channel to 48 hours5.555556e-4 days 0.0133 hours 7.936508e-5 weeks 1.8264e-5 months OPERABLE status.

I. Required Action and 1.1 Initiate action to fully insert Immediately associated Completion all rods.

Time of Condition H not met. AND 1.2 Place the Control Rod Drive 1 hour1.157407e-5 days 2.777778e-4 hours 1.653439e-6 weeks 3.805e-7 months System in a condition incapable of rod withdrawal.

J. As required by Required J.1 Action A.1 and referenced ------------------

- NOTE-by Table 3.3.1-1. Plant temperature changes are allowed provided the temperature change is accounted for in the calculated SOM.

Suspend operations Immediately involving positive reactivity additions.

AND J.2 Perform SR 3.1.1.1. 12 hours1.388889e-4 days 0.00333 hours 1.984127e-5 weeks 4.566e-6 months AND Once per 12 hours1.388889e-4 days 0.00333 hours 1.984127e-5 weeks 4.566e-6 months thereafter K. As required by Required K.1 Action A.1 and referenced ------------------

- NOTE-by Table 3.3.1-1. 1. For Functions 7a and 9b, one channel may be bypassed for up to 4 hours4.62963e-5 days 0.00111 hours 6.613757e-6 weeks 1.522e-6 months for surveillance testing.

2. The inoperable channel may be bypassed for up to 4 hours4.62963e-5 days 0.00111 hours 6.613757e-6 weeks 1.522e-6 months for surveillance testing of other channels.

Place channel in trip. 6 hours6.944444e-5 days 0.00167 hours 9.920635e-6 weeks 2.283e-6 months R.E. Ginna Nuclear Power Plant 3.3.1-4 Amendment 132

RTS Instrumentation 3.3.1 CONDITION REQUIRED ACTION COMPLETION TIME L. Required Action and L.1 Reduce THERMAL POVVER 6 hours6.944444e-5 days 0.00167 hours 9.920635e-6 weeks 2.283e-6 months associated Completion to < 8.5% RTP.

Time of Condition K not met.

M. As required by Required M.1 Action A.1 and referenced by Table 3.3.1-1.

-NOTE-

1. For Function 9a, one channel may be bypassed for up to 4 hours4.62963e-5 days 0.00111 hours 6.613757e-6 weeks 1.522e-6 months for surveillance testing.

2. The inoperable channel may be bypassed for up to 4 hours4.62963e-5 days 0.00111 hours 6.613757e-6 weeks 1.522e-6 months for surveillance testing of other channels.

Place channel in trip. 6 hours6.944444e-5 days 0.00167 hours 9.920635e-6 weeks 2.283e-6 months N. As required by Required N.1 Restore channel to 6 hours6.944444e-5 days 0.00167 hours 9.920635e-6 weeks 2.283e-6 months Action A.1 and referenced OPERABLE status.

by Table 3.3.1-1.

0. Required Action and 0.1 Reduce THERMAL POVVER 6 hours6.944444e-5 days 0.00167 hours 9.920635e-6 weeks 2.283e-6 months associated Completion to< 30% RTP.

Time of Condition M or N not met.

P. As required by Required P.1 Action A. 1 and referenced by Table 3.3.1-1.

- NOTE-The inoperable channel may be bypassed for up to 4 hours4.62963e-5 days 0.00111 hours 6.613757e-6 weeks 1.522e-6 months for surveillance testing of other channels.

Place channel in trip. 6 hours6.944444e-5 days 0.00167 hours 9.920635e-6 weeks 2.283e-6 months Q. Required Action and Q.1 Reduce THERMAL POVVER 6 hours6.944444e-5 days 0.00167 hours 9.920635e-6 weeks 2.283e-6 months Associated Completion to< 50% RTP.

Time of Condition P not met. AND R.E. Ginna Nuclear Power Plant 3.3.1-5 Amendment 132

RTS Instrumentation 3.3.1 CONDITION REQUIRED ACTION COMPLETION TIME Q.2.1 Verify Steam Dump System 7 hours8.101852e-5 days 0.00194 hours 1.157407e-5 weeks 2.6635e-6 months is OPERABLE.

OR

\

Q.2.2 Reduce THERMAL POWER 7 hours8.101852e-5 days 0.00194 hours 1.157407e-5 weeks 2.6635e-6 months to< 8% RTP.

R. As required by Required R.1 Action A.1 and referenced by Table 3.3.1-1.

-NOTE-One train may be bypassed for up to 4 hours4.62963e-5 days 0.00111 hours 6.613757e-6 weeks 1.522e-6 months for surveillance testing provided the other train is OPERABLE.

Restore train to OPERABLE 6 hours6.944444e-5 days 0.00167 hours 9.920635e-6 weeks 2.283e-6 months status.

s. As required by Required S.1 Action A.1 and referenced by Table 3.3.1-1. -------------------

-NOTE-For Functions 16c, 16d, and 16e, one channel may be bypassed for up to 4 hours4.62963e-5 days 0.00111 hours 6.613757e-6 weeks 1.522e-6 months for surveillance testing.

Verify interlock is in required state for existing plant 1 hour1.157407e-5 days 2.777778e-4 hours 1.653439e-6 weeks 3.805e-7 months conditions.

OR S.2 Declare associated RTS Function channel(s) 1 hour1.157407e-5 days 2.777778e-4 hours 1.653439e-6 weeks 3.805e-7 months inoperable.

Amendment 132 R.E. Ginna Nuclear Power Plant 3.3.1-6

RTS Instrumentation 3.3.1 SURVEILLANCE FREQUENCY SR 3.3.1.4 Perform TADOT. In accordance with the Surveillance Frequency Control Program SR 3.3.1.5 Perform ACTUATION LOGIC TEST. In accordance with the Surveillance Frequency Control Program SR 3.3.1.6 - NOTE -

Not required to be performed until 7 days after THERMAL POWER is~ 50% RTP, but prior to exceeding 90% RTP following each refueling.

Calibrate excore channels to agree with incore In accordance with detector measurements. the Surveillance Frequency Control Program SR 3.3.1.7 - NOTE-

1. Not required to be performed for source range instrumentation prior to entering MODE 3 from MODE 2 until 4 hours4.62963e-5 days 0.00111 hours 6.613757e-6 weeks 1.522e-6 months after entering MODE 3.

2. The RTS input relays are excluded from this surveillance for Functions 2a, 5, 6, ?a, 7b, 8, 9a, 9b, and 13.

In accordance with Perform COT.

the Surveillance Frequency Control Program SR 3.3.1.8 - NOTE-

1. Not required for power range and intermediate range instrumentation until 4 hours4.62963e-5 days 0.00111 hours 6.613757e-6 weeks 1.522e-6 months after reducing power< 6% RTP.

2. Not required for source range instrumentation until 4 hours4.62963e-5 days 0.00111 hours 6.613757e-6 weeks 1.522e-6 months after reducing power< 5E-11 amps.

I

3. The RTS input relay is excluded from this surveillance for Function 2b.

R.E. Ginna Nuclear Power Plant 3.3.1-9 Amendment 132

RTS Instrumentation 3.3.1 SURVEILLANCE FREQUENCY SR 3.3.1.8 Perform COT. In accordance with (continued) the Surveillance Frequency Control Program SR 3.3.1.9 ---------------------------------*

-NOTE-Setpoint verification is not required.

Perform TADOT. In accordance with the Surveillance Frequency Control Program SR 3.3.1.10 *--------------------------------*

- NOTE-Neutron detectors are excluded.

Perform CHANNEL CALIBRATION. In accordance with the Surveillance Frequency Control Program SR 3.3.1.11 Perform TADOT. In accordance with the Surveillance Frequency Control Program SR3.3.1.12 *--------------------------------*

- NOTE-Setpoint verification is not required.

Perform TADOT. Prior to reactor startup if not performed within previous 31 days SR3.3.1.13 - -- - - - - - - - - - - - - - - - - - - - - - - - - - - - - - - - - - - - -

l

- NOTE -

The RTS permissive input relays are excluded from this surveillance for Functions 16c, 16d, and 16e.

Perform COT. In accordance with the Surveillance Frequency Control Program RE. Ginna Nuclear Power Plant 3.3.1-10 Amendment 132

ESFAS Instrumentation 3.3.2 CONDITION REQUIRED ACTION COMPLETION TIME F. As required by Required F.1 Action A.1 and referenced by Table 3.3.2-1.

-NOTE-

1. For Functions 4c and Sb, one channel may be bypassed for up to 4 hours4.62963e-5 days 0.00111 hours 6.613757e-6 weeks 1.522e-6 months for surveillance testing.

2. The inoperable channel may be bypassed for up to 4 hours4.62963e-5 days 0.00111 hours 6.613757e-6 weeks 1.522e-6 months for surveillance testing of the other channels.

Place channel in trip. 6 hours6.944444e-5 days 0.00167 hours 9.920635e-6 weeks 2.283e-6 months G.1 Bein MODE 3.

G. Required Action and 6 hours6.944444e-5 days 0.00167 hours 9.920635e-6 weeks 2.283e-6 months associated Completion AND Time of Condition D, E, or F not met. 12 hours1.388889e-4 days 0.00333 hours 1.984127e-5 weeks 4.566e-6 months G.2 Be in MODE 4.

H. As required by Required H.1 Restore channel to 48 hours5.555556e-4 days 0.0133 hours 7.936508e-5 weeks 1.8264e-5 months Action A.1 and referenced OPERABLE status.

by Table 3.3.2-1.

I. As required by Required 1.1 Restore train to OPERABLE 6 hours6.944444e-5 days 0.00167 hours 9.920635e-6 weeks 2.283e-6 months Action A.1 and referenced status.

by Table 3.3.2-1.

J. As required by Required J.1 Action A.1 and referenced by Table 3.3.2-1.

-NOTE-

1. For Functions 1c, one channel may be bypassed for up to 4 hours4.62963e-5 days 0.00111 hours 6.613757e-6 weeks 1.522e-6 months for surveillance testing.

2. The inoperable channel may be bypassed for up to 4 hours4.62963e-5 days 0.00111 hours 6.613757e-6 weeks 1.522e-6 months for surveillance testing of the other channels.

Place channel in trip. 6 hours6.944444e-5 days 0.00167 hours 9.920635e-6 weeks 2.283e-6 months R.E. Ginna Nuclear Power Plant 3.3.2-2 Amendment 132

ESFAS Instrumentation 3.3.2 CONDITION REQUIRED ACTION COMPLETION TIME K. Required Action and Be in MODE 3. 6 hours6.944444e-5 days 0.00167 hours 9.920635e-6 weeks 2.283e-6 months associated Completion Time of Condition H, I, or AND J not met.

Be in MODE 5. 36 hours4.166667e-4 days 0.01 hours 5.952381e-5 weeks 1.3698e-5 months L. As required by Required L.1 Action A.1 and referenced - NOTE-by Table 3.3.2-1. 1. For Functions 1d and 1e, one channel may be .

bypassed for up to 4 hours4.62963e-5 days 0.00111 hours 6.613757e-6 weeks 1.522e-6 months for surveillance testing.

2. The inoperable channel may be bypassed for up to 4 hours4.62963e-5 days 0.00111 hours 6.613757e-6 weeks 1.522e-6 months for surveillance testing of the other channels.

Place channel in trip. 6 hours6.944444e-5 days 0.00167 hours 9.920635e-6 weeks 2.283e-6 months M. Required Action and M.1 Be in MODE 3. 6 hours6.944444e-5 days 0.00167 hours 9.920635e-6 weeks 2.283e-6 months associated Completion Time of Condition L not AND met.

M.2 Reduce pressurizer 12 hours1.388889e-4 days 0.00333 hours 1.984127e-5 weeks 4.566e-6 months pressure to < 2000 psig.

N. As required by Required N.1 Declare associated Auxiliary Immediately Action A.1 and referenced Feedwater pump inoperable by Table 3.3.2-1. and enter applicable condition(s) of LCO 3.7.5, "Auxiliary Feedwater (AFW)

System."

SURVEILLANCE REQUIREMENTS

- NOTE-Refer to Table 3.3.2-1 to determine which SRs apply for each ESFAS Function.

SURVEILLANCE FREQUENCY SR 3.3.2.1 Perform CHANNEL CHECK. In accordance with the Surveillance Frequency Control Pro ram R.E. Ginna Nuclear Power Plant 3.3.2-3 Amendment 132

ESFAS Instrumentation 3.3.2 SURVEILLANCE FREQUENCY I

SR 3.3.2.2

-NOTE-The ESFAS input relays are excluded from this surveillance for Functions 1c, 1d, 1e, 4c, and Sb.

Perform COT. In accordance with the Surveillance Frequency Control Program SR3.3.2.3

-NOTE-Verification of relay setpoints not required.

Perform TADOT. In accordance with the Surveillance Frequency Control Program SR 3.3.2.4 -NOTE-Verification of relay setpoints not required.

Perform TADOT. In accordance with the Surveillance Frequency Control Program SR 3.3.2.5 Perform CHANNEL CALIBRATION In accordance with the Surveillance Frequency Control Program SR 3.3.2.6 Verify the Pressurizer Pressure-low and Steam In accordance with line Pressure-Low Functions are not bypassed the Surveillance when pressurizer pressure > 2000 psig. Frequency Control Program SR3.3.2.7 Perform ACTUATION LOGIC TEST. In accordance with the Surveillance Frequency Control Program R.E. Ginna Nuclear Power Plant 3.3.2-4 Amendment 132

UNITED STATES NUCLEAR REGULATORY COMMISSION WASHINGTON, D.C. 20555-0001 SAFETY EVALUATION BY THE OFFICE OF NUCLEAR REACTOR REGULATION RELATED TO AMENDMENT NO. 132 TO RENEWED FACILITY OPERATING LICENSE NO. DPR-18 EXELON GENERATION COMPANY, LLC R. E. GINNA NUCLEAR POWER PLANT DOCKET NO. 50-244

1.0 INTRODUCTION

By letter dated November 16, 2017 (Agencywide Documents Access and Management System (ADAMS) Accession No. ML17321A107), Exelon Generation Company, LLC (the licensee),

submitted a license amendment request (LAR) for changes to the R. E. Ginna Nuclear Power Plant (Ginna) Technical Specifications (TSs) to reflect wording for plants with installed bypass capability. Portions of the letter dated November 16, 2017, contain sensitive unclassified non-safeguards information and have been with~eld from public disclosure pursuant to Section 2.390 of Title 10 of the Code of Federal Regulations ( 10 CFR).

The requested changes would revise certain required action notes in TS 3.3.1, "Reactor Trip System Instrumentation," Conditions D, K, M, and S, and Surveillance Requirements (SRs) 3.3.1.7, 3.3.1.8, and 3.3.1.13. These changes would also revise required action notes in TS 3.3.2, "Engineered Safety Feature Actuation System Instrumentation," Conditions F, J, and L, and SR 3.3.2.2. The required action notes are being revised to allow for the testing of a channel in bypass, and the SRs are being revised to exclude the Reactor Trip System (RTS) and Engineered Safety Feature Actuation System (ESFAS) input relays during the performance of a Channel Operational Test (COT).

The hardware changes are not reviewed as part of this safety evaluation. The licensee stated that the hardware changes necessary to facilitate testing in bypass will be implemented in accordance with 10 CFR 50.59.

2.0 REGULATORY EVALUATION

2.1 Proposed Changes The proposed changes would revise certain required action notes to allow testing a channel in bypass, and certain SRs to exclude the RTS and ESFAS input relays during the performance of a COT. These changes include the required action notes in TS 3.3.1, Conditions D, K, M, and Enclosure 2

S; the required action notes in TS 3.3.2, Conditions F, J, and L; and SRs 3.3.1.7, 3.3.1.8, 3.3.1.13, and 3.3.2.2. These TS changes are detailed below.

The following Note 1 is being added to TS 3.3.1, CONDITION D, REQUIRED ACTION D.1:

1. For Functions 2a, 2b, 5, 6, 7b, 8, and 13, one channel may be bypassed for up to 4 hours4.62963e-5 days 0.00111 hours 6.613757e-6 weeks 1.522e-6 months for surveillance testing.

The existing note in the REQUIRED ACTION of CONDITION D is being renumbered as Note 2.

The following Note 1 is being added to TS 3.3.1, CONDITION K, REQUIRED ACTION K.1:

1. For Functions 7a and 9b, one channel may be bypassed for up to 4 hours4.62963e-5 days 0.00111 hours 6.613757e-6 weeks 1.522e-6 months for surveillance testing.

The existing note in the REQUIRED ACTION of CONDITION K.1 is being renumbered as Note 2.

The following Note 1 is being added to TS 3.3.1, CONDITION M, REQUIRED ACTION M.1:

1. For Function 9a, one channel may be bypassed for up to 4 hours4.62963e-5 days 0.00111 hours 6.613757e-6 weeks 1.522e-6 months for surveillance testing.

The existing note in the REQUIRED ACTION of CONDITION M.1 is being renumbered as Note 2.

The following note is being added to TS 3.3.1, CONDITION S, REQUIRED ACTION S.1:

NOTE: For Functions 16c, 16d, and 16e, one channel may be bypassed for up to 4 hours4.62963e-5 days 0.00111 hours 6.613757e-6 weeks 1.522e-6 months for surveillance testing.

The following Note 2 is being added to SR 3.3.1. 7:

2. The RTS input relays are excluded from this surveillance for Functions 2a, 5, 6, 7a, 7b, 8, 9a, 9b, and 13.

The existing note in SR 3.3.1. 7 is being renumbered Note 1.

The following Note 3 is being added to SR 3.3.1.8:

3. The RTS input relay is excluded from this surveillance for Function 2b.

The following Note is being added to SR 3.3.1.13:

NOTE: The RTS permissive input relays are excluded from this surveillance for Functions 16c, 16d, and 16e.

The following Note 1 is being added to TS 3.3.2, CONDITION F, REQUIRED ACTION F.1:

1. For Functions 4c and 5b, one channel may be bypassed for up to 4 hours4.62963e-5 days 0.00111 hours 6.613757e-6 weeks 1.522e-6 months for surveillance testing.

The existing note in the REQUIRED ACTION of CONDITION F is being renumbered as Note 2.

The following Note 1 is being added to TS 3.3.2, CONDITION J, REQUIRED ACTION J.1:

1. For Functions 1c, one channel may be bypassed for up to 4 hours4.62963e-5 days 0.00111 hours 6.613757e-6 weeks 1.522e-6 months for surveillance testing.

The existing note in the REQUIRED ACTION of CONDITION J is being renumbered as Note 2.

The following Note 1 is being added to TS 3.3.2, CONDITION L, REQUIRED ACTION L.1:

1. For Functions 1d and 1e, one channel may be bypassed for up to 4 hours4.62963e-5 days 0.00111 hours 6.613757e-6 weeks 1.522e-6 months for surveillance testing.

The existing note in the REQUIRED ACTION of CONDITION Lis being renumbered as Note 2.

The following note is being added to SR 3.3.2.2:

NOTE: The ESFAS input relays are excluded from this surveillance for Functions 1c, 1d, 1e, 4c, and 5b.

The licensee's proposed changes will allow the following functions in the RTS and ESFAS instrumentation to be tested in bypass following implementation of the bypass test instrumentation modification:

TS Table 3.3.1-1, "Reactor Trip System Instrumentation" Function 2a - Power Range Neutron Flux - High (Nuclear Instrumentation System (NIS))

Function 2b - Power Range Neutron Flux - Low (NIS)

Function 5 - Overtemperature I!:,,T Function 6 - Overpower I!:,,T Function 7a - Pressurizer Pressure - Low Function 7b - Pressurizer Pressure - High Function 8 - Pressurizer Water Level - High Function 9a - Reactor Coolant Flow - Low - Single Loop Function 9b - Reactor Coolant Flow - Low - Two Loops Function 13 - Steam Generator Water Level - Low Low Function 16c - Reactor Trip System Interlocks - Power Range Neutron Flux, P-8

Function 16d - Reactor Trip System Interlocks - Power Range Neutron Flux, P-9 Function 16e - Reactor Trip System Interlocks - Power Range Neutron Flux, P-10 TS Table 3.3.2-1, "Engineered Safety Feature Actuation System Instrumentation" Function 1c - Safety Injection - Containment Pressure - High Function 1d - Safety Injection - Pressurizer Pressure - Low Function 1e - Safety Injection - Steam Line Pressure - Low Function 4c - Steam Line Isolation - Containment Pressure - High High Function 5b - Feedwater Isolation - SG Water Level - High 2.2 Regulatory Requirements and Guidance The U.S. Nuclear Regulatory Commission's (NRC) regulatory requirements related to the content of the TSs are set forth in 10 CFR 50.36, "Technical specifications." This regulation requires that the TSs include items in the following five specific categories: (1) safety limits, limiting safety system settings, and limiting control settings; (2) limiting conditions for operation (LCOs); (3) SRs; (4) design features; and (5) administrative controls. The regulation does not specify the particular requirements to be included in plant TSs.

As discussed in 10 CFR 50.36(c)(2), LCOs are the lowest functional capability or performance levels of equipment required for safe operation of the facility. When LCOs are not met, the licensee shall shut down the reactor or follow any remedial action permitted by the TSs until the LCOs can be met.

As discussed in 10 CFR 50.36(c)(3), SRs are requirements relating to test, calibration, or inspection to assure that the necessary quality of systems and components is maintained, that facility operation will be within safety limits, and that the LCOs will be met. The LAR proposes to specify that one channel may be bypassed for surveillance testing for up to 4 hours4.62963e-5 days 0.00111 hours 6.613757e-6 weeks 1.522e-6 months for certain RTS and ESFAS instrumentation.

The regulation at 10 CFR 50.36(a)( 1) states, in part, that "[a] summary statement of the bases or reasons for such specifications, other than those covering administrative controls, shall also be included in the application, but shall not become part of the technical specifications."

Accordingly, along with the proposed TS changes, the licensee also submitted TS Bases changes corresponding to the proposed TS changes.

The regulation at 10 CFR 50.92(a) states that in determining whether an amendment to a license will be issued, the Commission will be guided by the considerations which govern the issuance of initial licenses to the extent applicable and appropriate. The regulation in 10 CFR 50.40(a) states that in determining that a license will be issued to an applicant, the Commission will be guided by considerations including whether the processes to be performed, the operating procedures, the facility and equipment, the use of the facility, and other technical specifications, or the proposals, in regard to any of the foregoing collectively provide reasonable assurance that the applicant will comply with the regulations in this chapter, including the regulations in part 20 of this chapter, and that the health and safety of the public will not be endangered.

The regulation at 10 CFR 50.54(jj), conditions the operating license such that structures, systems, and components subject to the codes and standards in 10 CFR 50.55a must be

designed, fabricated, erected, constructed, tested, and inspected to quality standards commensurate with the importance of the safety function to be performed.

The NRC staff also reviewed the LAR based on the following regulatory guidance documents:

NUREG-0800, Revision 3, "Standard Review Plan for the Review of Safety Analysis Reports for Nuclear Power Plants: LWR [Light-Water Reactor] Edition," March 2010 (ADAMS Accession No. ML100351425).

NUREG-1431, Revision 4, Volume 1, "Standard Technical Specifications -

Westinghouse Plants: Specifications" (STS), April 2012 (ADAMS Accession No. ML12100A222).

2.3 Descrjption of Bypass Test Instrumentation The NIS power range, RTS, and ESFAS functions utilize a two-out-of-four coincidence logic from redundant channels to initiate protective actions. In the current design, the analog channel comparators are placed in the "tripped" condition during channel testing or if a channel is inoperable. Routine testing of a channel in the tripped position can result in the potential for an

unnecessary reactor trip if a second comparator trips in a redundant channel, which can be caused by a human error, spurious transient, or channel failure.

With the implementation of this TS change, the licensee can avoid a spurious reactor trip because the partial trip conditions that would have been present are eliminated. The coincidence logic, with a channel in bypass, becomes two-out-of-three for the remaining channels. In this case, the logic requires signals from two additional channels to actuate the protective function. This provides the benefits of reducing challenges to the plant safety systems that may result from spurious actuations, human error, or channel failure.

The current TS 3.3.1 and 3.3.2 allow an inoperable channel to be placed in bypass for up to 4 hours4.62963e-5 days 0.00111 hours 6.613757e-6 weeks 1.522e-6 months to allow testing of other channels. Therefore, the length of time a channel may be placed in bypass (during which the two-out-of-three logic is applicable) is not changed by the proposed TS changes.

Two types of bypass test instrumentation will be used to bypass these functions: 1) permanently installed bypass test panels will be used to bypass the NIS power range functions and 2) a portable test box will be used to bypass the RTS and ESFAS system functions. The use of the portable test box requires the installation of permanent connection panels wired to the RTS and ESFAS input relays. This design will allow the use of the temporary portable test box without the use of temporary jumpers during the performance of the COT. In order to use the bypass test capability planned to be installed, the licensee revised the TS Tables 3.3.1 and 3.3.2 required action notes and SRs identified in Section 2.1 of this safety evaluation.

3.0 TECHNICAL EVALUATION

3.1 Evaluation of TS Changes As described in Section 2.1 of this safety evaluation, the licensee is proposing to revise the Ginna TS required action notes to allow testing a channel in bypass, and to revise certain SRs to exclude the RTS and ESFAS input relays during the performance of a COT. The Technical Specification Task Force (TSTF) Traveler TSTF 418, Revision 2, "RPS and ESFAS Test Times and Completion Times (WCAP 14333)," March 2003 (ADAMS Accession No. ML030650848),

as approved in the letter dated April 2, 2003 (ADAMS Accession No. ML030920633),

established that bypass testing is an acceptable method of testing a channel without placing it in a trip condition. In addition, NUREG 1431, Revision 4, has incorporated TSTF 418 for plants with installed bypass test capability.

The NRC staff reviewed the technical discussion of the proposed changes (see Section 2.1 of this safety evaluation) provided in the LAR to ensure that the reasoning was logical, complete, and clearly written, as described in Chapter 16 of NUREG-0800. Specifically, the staff reviewed the proposed changes for continued compliance with the regulations in 10 CFR 50.36 and for consistency with conventional terminology and with the format and usage rules embodied in the TSs.

10 CFR 50.36(c)(2)(i) requires that the TSs include LCOs, which are the lowest functional capability or performance levels of equipment required for safe operation of the facility. No changes are being proposed to the lowest functional capability or performance levels for these functions. Therefore, TS 3.3.1 and TS 3.3.2 continue to comply with this regulation.

10 CFR 50.36(c)(2)(i) additionally requires that when an LCO of a nuclear reactor is not met, the licensee shall shut down the reactor or follow any remedial action permitted by the TSs until the condition can be met. Per 10 CFR 50.40(a), the remedial actions in the TS must, in part, provide reasonable assurance that the health and safety of the public will not be endangered. New notes are being added to the required action in TS 3.3.1, Conditions D, K, M, and S; and TS 3.3.2, Conditions F, J, and L; to specify that one channel may be bypassed for up to 4 hours4.62963e-5 days 0.00111 hours 6.613757e-6 weeks 1.522e-6 months for surveillance testing. These notes are applicable to: TS 3.3.1 Functions 2a, 2b, 5, 6, 7a, 7b, 8, 9a, 9b, 13, 16c, 16d and 16e; and TS 3.3.2 Functions 1c, 1d, 1e, 4c and 5b; as described in Section 2.1. The length of time that a channel may be placed in bypass has previously been reviewed in TSTF-418 (ADAMS Accession No. ML030920633) and incorporated in NUREG-1431. Additionally, the current Ginna TS 3.3.1 and TS 3.3.2 include notes that allow an inoperable channel to be bypassed for up to 4 hours4.62963e-5 days 0.00111 hours 6.613757e-6 weeks 1.522e-6 months for surveillance testing of other channels. Therefore, the length of time a channel may be placed in bypass is not changed by the proposed TS changes. The NRC staff finds that the proposed required action notes are consistent with the STS wording for plants with installed bypass testing capability, and align the Ginna TS with NUREG-1431. The continued operation during testing time permitted by the notes is minimal and does not create a danger to public health and safety.

10 CFR 50.36(c)(3) requires TSs to include items in the category of SRs, which are requirements relating to test, calibration, or inspection to assure that the necessary quality of systems and components is maintained, that facility operation will be within safety limits, and that the LCOs will be met. A note is being added to SRs 3.3.1. 7, 3.3.1.8, 3.3.1.13, and 3.3.2.2, to exclude the input relays from the respective surveillances. These notes are applicable to: TS 3.3.1 Functions 2a, 2b, 5, 6, 7a, 7b, 8, 9a, 9b, 13, 16c, 16d, and 16e; and TS 3.3.2 Functions 1c, 1d, 1e, 4c, and 5b; as described- in Section 2.1 of this safety evaluation. The LAR states that the RTS and ESFAS input relays will continue to be tested (i.e., tripped) during the channel calibration (SRs 3.3.1.10 (RTS relays) and SR 3.3.2.5 (ESFAS relays)) in accordance with the frequencies specified in the surveillance frequency control program. The staff reviewed the proposed changes to the surveillance testing requirements to determine if the SRs would assure that the necessary quality of systems and components is maintained, that facility operation will be within safety limits, and that the limiting conditions for operation will be met under 10 CFR_50.36(c)(3). The exclusion of the RTS and ESFAS input relays during surveillance testing reduces the potential for an inadvertent reactor trip during surveillance testing. The NRC staff finds this to be an acceptable change to the Ginna TS, and the SRs, as modified, and finds that the necessary quality of systems and components is maintained because the RTS and ESFAS input relays will continue to be tested (i.e., tripped) during the channel calibration (SRs 3.3.1.10 (RTS relays) and SR 3.3.2.5 (ESFAS relays)).

3.2 Technical Conclusion Based on the above review, the NRC staff concludes that the proposed TS changes meet the applicable requirements in 10 CFR 50.36(c)(3) and 10 CFR 50.40(a). The NRC staff, therefore, finds that the proposed changes to TS 3.3.1 and TS 3.3.2 to permit bypass testing are acceptable.

4.0 STATE CONSULTATION

In accordance with the Commission's regulations, the New York State official was notified of the proposed issuance of the amendment on August 6, 2018. The State official had no comments.

5.0 ENVIRONMENTAL CONSIDERATION

The amendment changes requirements with respect to the installation or use of a facility component located within the restricted area as defined in 10 CFR Part 20 and changes SRs.

The NRC staff has determined that the amendment involves no significant increase in the amounts and no significant change in the types of any effluents that may be released offsite and that there is no significant increase in individual or cumulative occupational radiation exposure.

The Commission has previously issued a proposed finding that the amendment involves no significant hazards consideration, and there has been no public comment on such finding published in the Federal Register on February 6, 2018 (83 FR 5281 ). Accordingly, the amendment meets the eligibility criteria for categorical exclusion set forth in 10 CFR 51.22(c)(9).

Pursuant to 10 CFR 51.22(b ), no environmental impact statement or environmental assessment need be prepared in connection with the issuance of the amendment.

6.0 CONCLUSION

The Commission has concluded, based on the considerations discussed above, that (1) there is reasonable assurance that the health and safety of the public will not be endangered by operation in the proposed manner, (2) there is reasonable assurance that such activities will be conducted in compliance with the Commission's regulations, and (3) the issuance of the amendment will not be inimical to the common defense and security or to the health and safety of the public.

Principal Contributors: Samir Darbali Daniel Warner Date: November 13, 2018

SUBJECT:

R. E. GINNA NUCLEAR POWER PLANT - ISSUANCE OF AMENDMENT NO. 132 TO REVISE TECHNICAL SPECIFICATIONS 3.3.1, "REACTOR TRIP SYSTEM INSTRUMENTATION," AND 3.3.2, "ENGINEERED SAFETY FEATURE ACTUATION SYSTEM INSTRUMENTATION" (EPID L-2017-LLA-0388) DATED NOVEMBER 13, 2018 DISTRIBUTION:

PUBLIC RidsACRS_MailCTR Resource RidsNrrDeEicb Resource RidsNrrDorlLpl1 Resource RidsNrrDssStsb Resource RidsNrrLALRonewicz Resource RidsNrrPMREGinna Resource RidsRgn1 MailCenter Resource DWarner, NRR SDarbali, NRR ADAMS Access1on No.: ML18213A369 *b , memoran d um **b,v e-ma1*1 OFFICE NRR/DORL/LPL 1/PM NRR/DORL/LPL 1/LA NRR/DE/EICB/BC* NRR/DSS/STSB/BC**

NAME VSreenivas JBurkhardt; LRonewicz RAlvarado VCusumano DATE 9/25/2018 08/07/2018; 09/25/2018 07/23/2018 08/17/2018 OFFICE OGC-NLO** NRR/DORL/LPL 1/BC NRR/DORL/LPL 1/PM '

NAME DRoth Joanna VSreenivas DATE 09/18/2018 11/09/2018 11/13/2018 OFFICIAL RECORD COPY

v t e Letter Sequence Approval
EPID:L-2017-LLA-0388, R. E. Ginna, License Amendment Request to Revise Technical Specifications for Selected Reactor Trip System and Engineered Safety Feature Actuation System Instrumentation Channels to Incorporate Bypass Test Capability (Approved, Closed)
Initiation Request Acceptance Administration Withholding Request Acceptance Questions Answers Results Approval Other:
MONTHYEAR2017-12-12 [Table View]

ML18213A369

Text

SUBJECT:

Dear Mr. Hanson:

Enclosures:

Attachment:

1.0 INTRODUCTION

2.0 REGULATORY EVALUATION

3.0 TECHNICAL EVALUATION

4.0 STATE CONSULTATION

5.0 ENVIRONMENTAL CONSIDERATION

6.0 CONCLUSION

SUBJECT:

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