ML030660349

Issuance of Amendment Elimination of Periodic Pressure Sensor & Protection Channel Response Time Tests

ML030660349
Person / Time
Site:	Harris
Issue date:	03/07/2003
From:	Chandu Patel NRC/NRR/DLPM/LPD2
To:	Scarola J Carolina Power & Light Co
Patel C P, NRR/DLPM, 415-3025
References
TAC MB6230
Download: ML030660349 (21)

Text

March 7, 2003 Mr. James Scarola, Vice President Shearon Harris Nuclear Power Plant Carolina Power & Light Company Post Office Box 165, Mail Code: Zone 1 New Hill, North Carolina 27562-0165

SUBJECT:

SHEARON HARRIS NUCLEAR POWER PLANT, UNIT 1 - ISSUANCE OF AMENDMENT RE: ELIMINATION OF PERIODIC PRESSURE SENSOR AND PROTECTION CHANNEL RESPONSE TIME TESTS (TAC NO. MB6230)

Dear Mr. Scarola:

The Nuclear Regulatory Commission has issued Amendment No. 112 to Facility Operating License No. NPF-63 for the Shearon Harris Nuclear Power Plant, Unit 1. This amendment changes the Technical Specifications in response to your application dated August 30, 2002, as supplemented November 21 and December 16, 2002, and January 23, 2003.

The amendment eliminates the requirements to perform response time testing for several reactor protection system and engineered safety feature functions in conformance with previously approved topical reports.

A copy of the related Safety Evaluation is enclosed. Notice of Issuance will be included in the Commission's regular bi-weekly Federal Register notice.

Sincerely,

/RA/

Chandu P. Patel, Project Manager, Section 2 Project Directorate II Division of Licensing Project Management Office of Nuclear Reactor Regulation Docket No. 50-400

Enclosures:

1. Amendment No. 112 to NPF-63

2. Safety Evaluation cc w/enclosures:

See next page

March 7, 2003 Mr. James Scarola, Vice President Shearon Harris Nuclear Power Plant Carolina Power & Light Company Post Office Box 165, Mail Code: Zone 1 New Hill, North Carolina 27562-0165

SUBJECT:

SHEARON HARRIS NUCLEAR POWER PLANT, UNIT 1 - ISSUANCE OF AMENDMENT RE: ELIMINATION OF PERIODIC PRESSURE SENSOR AND PROTECTION CHANNEL RESPONSE TIME TESTS (TAC NO. MB6230)

Dear Mr. Scarola:

The Nuclear Regulatory Commission has issued Amendment No. 112 to Facility Operating License No. NPF-63 for the Shearon Harris Nuclear Power Plant, Unit 1. This amendment changes the Technical Specifications in response to your application dated August 30, 2002, as supplemented November 21 and December 16, 2002, and January 23, 2003.

The amendment eliminates the requirements to perform response time testing for several reactor protection system and engineered safety feature functions in conformance with previously approved topical reports.

A copy of the related Safety Evaluation is enclosed. Notice of Issuance will be included in the Commission's regular bi-weekly Federal Register notice.

Sincerely,

/RA/

Chandu P. Patel, Project Manager, Section 2 Project Directorate II Division of Licensing Project Management Office of Nuclear Reactor Regulation Docket No. 50-400

Enclosures:

1. Amendment No.112 to NPF-63

2. Safety Evaluation cc w/enclosures:

See next page Distribution:

PUBLIC OGC PDII-2 Rdg. G. Hill (2)

H. Berkow R. Dennig A. Howe P. Loeser E. Dunnington ACRS C. Patel P. Fredrickson, RII cc: Harris Service List Accession Number ML030660349

OFFICE PM:PDII/S2 LA:PDII/S2 OGC SC/PDII-2 NAME CPatel EDunnington RHoefling/ NLO AHowe DATE 2/20/03 2/19/03 2/24/03 3/6/03 OFFICIAL RECORD COPY CAROLINA POWER & LIGHT COMPANY, et al.

DOCKET NO. 50-400 SHEARON HARRIS NUCLEAR POWER PLANT, UNIT 1 AMENDMENT TO FACILITY OPERATING LICENSE Amendment No.112 License No. NPF-63

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

A. The application for amendment by Carolina Power & Light Company, (the licensee), dated August 30, 2002, as supplemented November 21 and December 16, 2002, and January 23, 2003, 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.

2. Accordingly, the license is amended by changes to the Technical Specifications, as indicated in the attachment to this license amendment; and paragraph 2.C.(2) of Facility Operating License No. NPF-63 is hereby amended to read as follows:

(2) Technical Specifications and Environmental Protection Plan The Technical Specifications contained in Appendix A, and the Environmental Protection Plan contained in Appendix B, both of which are attached hereto, as revised through Amendment No. , are hereby incorporated into this license.

Carolina Power & Light Company shall operate the facility in accordance with the Technical Specifications and the Environmental Protection Plan.

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

FOR THE NUCLEAR REGULATORY COMMISSION

/RA/

Allen G. Howe, Chief, Section 2 Project Directorate II Division of Licensing Project Management Office of Nuclear Reactor Regulation

Attachment:

Changes to the Technical Specifications Date of Issuance: March 7, 2003

ATTACHMENT TO LICENSE AMENDMENT NO.112 FACILITY OPERATING LICENSE NO. NPF-63 DOCKET NO. 50-400 Replace the following pages of the 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.

Remove Pages Insert Pages 1-3 1-3 1-5 1-5 3/4 3-1 3/4 3-1 3/4 3-17 3/4 3-17 B 3/4 3-2 B 3/4 3-2

--- B 3/4 3-2a

SAFETY EVALUATION BY THE OFFICE OF NUCLEAR REACTOR REGULATION RELATED TO AMENDMENT NO. 112 TO FACILITY OPERATING LICENSE NO. NPF-63 CAROLINA POWER & LIGHT COMPANY SHEARON HARRIS NUCLEAR POWER PLANT, UNIT 1 DOCKET NO. 50-400

1.0 INTRODUCTION

By letter dated August 30, 2002, as supplemented November 21 and December 16, 2002, and January 23, 2003, the Carolina Power & Light Company (CP&L, the licensee) submitted a request for changes to the Shearon Harris Nuclear Power Plant, Unit 1 (HNP), Technical Specifications (TS). The requested changes would revise the requirement to perform response time testing (RTT) for several reactor protection system (RPS) and engineered safety feature (ESF) functions. The basis for this request is presented in two approved Westinghouse Owners Group (WOG) topical reports, WCAP-13632-P-A, Revision 2, "Elimination of Pressure Sensor Response Time Testing Requirements," and WCAP-14036-P, Revision 1, "Elimination of Periodic Protection Channel Response Time Tests."

The November 21 and December 16, 2002, and January 23, 2003, letters provided clarifying information and did not change the initial proposed no significant hazards consideration determination or expand the scope of the initial application.

2.0 REGULATORY EVALUATION

The current standard technical specifications require nuclear power plants to periodically perform RTT for instrument channels in the RPS, emergency core cooling system (ECCS), and isolation actuation system (IAS). The intent of these tests is to ensure that changes in instrumentation response time beyond the limits assumed in the plants safety analyses are detected and combined with instrument calibrations to ensure that the instrumentation is operating correctly.

The Institute of Electrical and Electronics Engineers (IEEE) Standard 338-1977, which is endorsed in Regulatory Guide (RG) 1.118, Rev. 2, defines a basis for eliminating RTT.

Specifically, Section 6.3.4 of IEEE Standard 338-1977 states, in part, the following basis:

Response time testing of all safety-related equipment, per se, is not required if, in lieu of response time testing, the response time of the safety system equipment is verified by functional testing, calibration check, or other tests, or

both. This is acceptable if it can be demonstrated that changes in response time beyond acceptable limits are accompanied by changes in performance characteristics which are detectable during routine periodic tests.

The WOG performed two analyses to assess the impact of elimination of RTT for instruments and instrument loops. These analyses also discussed alternate test methodologies that would show that the instrumentation was functioning correctly. The first of these analyses was WOG Licensing Topical Report WCAP-13632, "Elimination of Pressure Sensor Response Time Testing Requirements," dated August 1995. It was approved by the NRC staff as documented in a safety evaluation report (SER) dated September 5, 1995. The second, WCAP-14036-P, Revision 1, "Elimination of Periodic Protection Channel Response Time Tests," dated December 1995, was approved by the NRC staff as documented in an SER dated October 6, 1998. Each of these SERs stipulated certain conditions that individual plant licensees must meet when implementing the guidelines in WCAP-13632 and WCAP-14036 on a plant-specific basis. The licensee has used these WCAPs to justify the proposed changes. The licensees amendment request and the NRC staffs acceptance is based on these WCAPs.

3.0 TECHNICAL EVALUATION

The NRC staff has reviewed the licensees regulatory and technical analyses in support of its proposed license amendment. The detailed evaluation is provided in the following subsections.

3.1 TS Changes There are two types of RTT elimination changes contained within the CP&L request. The first is to eliminate periodic pressure sensor RTT in accordance with WCAP-13632, and the second change is to eliminate protective channel RTT for the Reactor Trip System (RTS) and Engineered Safety Feature Actuation Systems (ESFAS) in accordance with WCAP-14036.

For the first change, the licensee proposes to no longer perform RTT on the following sensors:

Barton 752 with Model 351 Sealed Sensor Barton 763 Barton 764 Rosemount 1153 Rosemount 1154 All of these sensor types are listed in the NRC staffs SER dated September 5, 1995, approving WCAP-13632. Since the NRC staff has already reviewed the generic analysis, no further review of these sensor types is required, and the licensee needs only to meet the conditions for plant-specific amendments.

For the second change, the licensee proposed elimination of RTT for the RTS and ESF systems, and instead will depend upon calibration and other periodic testing as described in WCAP-14036 in order to determine the proper operation and functioning of the above system instrumentation. In those cases where the TS require the licensee to verify that a protective system can meet its protective function in a prescribed time, a bounding response time will be

added to those portions of the protective system actually tested for response time in order to determine the total system response time. The requirement to actually measure the response times would be eliminated, and instead, the response times will be verified by summing allocated times for sensors, the process protection system, the nuclear instrumentation system, and the logic system. These allocated values will be added to the measured times for the actuated devices and compared to the overall analysis limits.

The actual TS change is to revise the TS definition for "Engineered Safety Features (ESF)

Response Time" and "Reactor Trip System (RTS) Response Time" to provide for verification of response time for selected components provided that the components and the methodology for verification have been previously reviewed and approved by the NRC. The TS requirements for response time verification will continue to be implemented by surveillance requirements (SRs) 3.3.1.15 and 3.3.2.8.

The specific sections of the HNP TS to be changed are as shown below.

3.1.1 Definitions Section, 1.13 ENGINEERED SAFETY FEATURE RESPONSE TIME, page 1-3.

Proposed Change: Add two sentences to the definition. The definition currently reads:

The ENGINEERED SAFETY FEATURES (ESF) RESPONSE TIME shall be that time interval from when the monitored parameter exceeds its ESF Actuation Setpoint at the channel sensor until the ESF equipment is capable of performing its safety function (i.e., the valves travel to their required positions, pump discharge pressures reach their required values, etc.). Times shall include diesel generator starting and sequence loading delays where applicable.

With the addition of the proposed sentences, the definition will state:

The ENGINEERED SAFETY FEATURES (ESF) RESPONSE TIME shall be that time interval from when the monitored parameter exceeds its ESF Actuation Setpoint at the channel sensor until the ESF equipment is capable of performing its safety function (i.e., the valves travel to their required positions, pump discharge pressures reach their required values, etc.). Times shall include diesel generator starting and sequence loading delays where applicable. The response time may be measured by means of any series of sequential, overlapping, or total steps so that the entire response time is measured. In lieu of measurement, response time may be verified for selected components provided that the components and the methodology for verification have been previously reviewed and approved by the NRC.

3.1.2 Definitions Section, 1.29 REACTOR TRIP SYSTEM (RTS) RESPONSE TIME, page 1-5.

Proposed Change: Add two sentences to the definition. The definition currently reads:

The REACTOR TRIP SYSTEM RESPONSE TIME shall be the time interval from when the monitored parameter exceeds its Trip Setpoint at the channel sensor until loss of stationary gripper coil voltage.

With the addition of the proposed sentences, the definition will state:

The REACTOR TRIP SYSTEM RESPONSE TIME shall be the time interval from when the monitored parameter exceeds its Trip Setpoint at the channel sensor until loss of stationary gripper coil voltage. The response time may be measured by means of any series of sequential, overlapping, or total steps so that the entire response time is measured. In lieu of measurement, response time may be verified for selected components provided that the components and the methodology for verification have been previously reviewed and approved by the NRC.

Evaluation: Addition of these sentences in the above two definitions will allow the licensee to verify the component response times rather than performing an actual RTT.

These changes are in accordance with WCAP-14036-P, Revision 1, and the NRC staff SER approving that report, and are therefore acceptable to the staff.

3.1.3 Section 3/4.3.1, REACTOR TRIP SYSTEM INSTRUMENTATION, SURVEILLANCE REQUIREMENTS paragraph 4.3.1.2, page 3/4 3-1.

Proposed Change: Modify the paragraph to use the term verify rather than demonstrate or test. The paragraph currently reads:

4.3.1.2 The REACTOR TRIP SYSTEM RESPONSE TIME of each Reactor trip function shall be demonstrated to be within its limits, specified in the Technical Specification Equipment List Program, plant procedure PLP-106, at least once per 18 months. Each test shall include at least one train such that both trains are tested at least once per 36 months and one channel per function such that all channels are tested at least once every N times 18 months where N is the total number of redundant channels in a specific Reactor trip function as shown in the Total No. of Channels" column of Table 3.3-1.

With the modifications, the paragraph will state:

4.3.1.2 The REACTOR TRIP SYSTEM RESPONSE TIME of each Reactor trip function shall be verified to be within its limit, specified in the Technical Specification Equipment List Program, plant procedure PLP-106, at least once per 18 months.

Each verification shall include at least one train such that both trains are verified at least once per 36 months and one channel per function such that all channels are verified at least once every N times 18 months where N is the total number of

redundant channels in a specific Reactor trip function as shown in the Total No. of Channels" column of Table 3.3-1.

Evaluation: These modifications will allow the licensee to verify the component response times rather than performing an actual RTT. These changes are in accordance with WCAP-14036-P, Revision 1, and the NRC staff SER approving that report, and are therefore acceptable to the staff.

3.1.4 Section 3/4.3.2, ENGINEERED SAFETY FEATURES ACTUATION SYSTEM INSTRUMENTATION, SURVEILLANCE REQUIREMENTS paragraph 4.3.2.2, page 3/4 3-17.

Proposed Change: Modify the paragraph to use the term verify rather than demonstrate or test. The paragraph currently reads:

4.3.2.2 The ENGINEERED SAFETY FEATURES RESPONSE TIME of each ESFAS function shall be demonstrated to be within its limits specified in the Technical Specification Equipment List Program, plant procedure PLP-106, at least once per 18 months. Each test shall include at least one train such that both trains are tested at least once per 36 months and one channel per function such that all channels are tested at least once per N times 18 months where N is the total number of redundant channels in a specific ESFAS function as shown in the Total No. of Channels" column of Table 3.3-3.

With the modifications, the paragraph will state:

4.3.2.2 The ENGINEERED SAFETY FEATURES RESPONSE TIME of each ESFAS function shall be verified to be within its limit specified in the Technical Specification Equipment List Program, plant procedure PLP-106, at least once per 18 months.

Each verification shall include at least one train such that both trains are verified at least once per 36 months and one channel per function such that all channels are verified at least once per N times 18 months where N is the total number of redundant channels in a specific ESFAS function as shown in the Total No. of Channels" column of Table 3.3-3.

Evaluation: These modifications will allow the licensee to verify the component response times rather than performing an actual RTT. These changes are in accordance with WCAP-14036-P, Revision 1, and the NRC staff SER approving that report, and are therefore acceptable to the staff.

3.1.5 Basis Section on REACTOR TRIP SYSTEM INSTRUMENTATION AND ENGINEERED SAFETY FEATURES ACTUATION SYSTEM INSTRUMENTATION, page B 3/4 3-2.

Proposed Change: Delete the last sentence at the end of the third paragraph, and insert several new sentences. Add a new paragraph between the third and fourth paragraphs.

The third paragraph currently reads:

The measurement of response time at the specified frequencies provides assurance that the reactor trip and the Engineered Safety Features actuation associated with each channel is completed within the time limit assumed in the safety analyses. No credit was taken in the analyses for those channels with response times indicated as not applicable. Response time may be demonstrated by any series of sequential, overlapping, or total channel test measurements provided that such tests demonstrate the total channel response time as defined. Sensor response time verification may be demonstrated by either: (1) in place, onsite, or offsite test measurements, or (2) utilizing replacement sensors with certified response time.

With these modifications, the third and new fourth paragraphs will read:

The measurement of response time at the specified frequencies provides assurance that the reactor trip and the Engineered Safety Features actuation associated with each channel is completed within the time limit assumed in the safety analyses. No credit was taken in the analyses for those channels with response times indicated as not applicable. Response time may be demonstrated by any series of sequential, overlapping, or total channel test measurements provided that such tests demonstrate the total channel response time as defined. Response time may be verified by actual response time tests in any series of sequential, overlapping or total channel measurements or by the summation of allocated sensor, signal processing and actuation logic response times with actual response time tests on the remainder of the channel. Allocations for sensor response times may be obtained from: (1) historical records based on acceptable response time tests (hydraulic, noise or power interrupt tests); (2) inplace, onsite, or offsite (e.g.

vendor) test measurements; or (3) utilizing vendor engineering specifications.

WCAP-13632-P-A, Rev. 2, "Elimination of Pressure Sensor Response Time Testing Requirements," provides the basis and methodology for using allocated sensor response times in the overall verification of the channel response time for specific sensors identified in the WCAP. Response time verification for other sensor types must be demonstrated by test.

WCAP 14036-P-A, Rev. 1, "Elimination of Periodic Response Time Tests, provides the basis and methodology for using allocated signal actuation logic response times in the overall verification of the protection system channel response time. The allocations for sensor, signal conditioning, and actuation logic response times must be verified prior to placing the component into operational service and re-verified following maintenance or modification that may adversely affect response time. In general, electrical repair work does not impact response time provided the parts used for the repair are the same type and value. Specific components identified in the WCAP may be replaced without verification testing. One example where response time could be affected is replacing the sensing element of a transmitter.

Evaluation: These changes describe the rationale that allows the licensee to verify the component response times by using an approved methodology instead of performing an

actual RTT. These changes are in accordance with WCAP-14036-P, Revision 1, as approved by the NRC staff SER and are, therefore, acceptable to the staff.

3.2 Verification of Plant-Specific Conditions The NRC staff stipulated several conditions in the generic SER approving WCAP-13632 that must be met by the individual licensee referencing the topical report before the guidance could be implemented in plant-specific TS change proposals. From the licensee's submittal, the NRC staff verified that the licensee has met or will meet the applicable conditions as follows:

A) Condition: Perform a hydraulic RTT prior to installation of a new transmitter/switch or following refurbishment of the transmitter/switch (e.g., sensor cell or variable damping components) to determine an initial sensor-specific response time value.

Licensee Response: Consistent with the proposed TS changes (including the associated Bases for 4.3.1.2 and 4.3.2.2) the applicable plant procedures include requirements that stipulate that pressure sensor response times must be verified by performance of a hydraulic response time test prior to placing a sensor into operational service and re-verified following maintenance that may adversely affect sensor response time.

Evaluation: This response fulfills the condition in the NRC staff generic SER, and is therefore acceptable to the staff.

B) Condition: For transmitters and switches that use capillary tubes, perform an RTT after initial installation and after any maintenance or modification activity that could damage the capillary tubes.

Licensee Response: Plant procedure revisions (and/or other appropriate administrative controls) will stipulate that transmitters and switches utilizing capillary tubes, e.g.,

containment pressure, is subjected to RTT after initial installation and following any maintenance or modification activity, which could damage the transmitter capillary tubes.

Evaluation: This response fulfills the condition in the NRC staff generic SER, and is therefore acceptable to the staff.

C) Condition: If variable damping is used, implement a method to assure that the potentiometer is at the required setting and cannot be inadvertently changed or perform hydraulic RTT of the sensor following each calibration.

Licensee Response: HNP has no transmitters with variable damping installed in any RTS or ESFAS application for which RTT is required (reference Enclosure 1; Tables 1 and 2);

therefore, no HNP procedure changes are required.

Evaluation: Since HNP does not use sensors that use variable damping, this condition is not applicable.

D) Condition: Perform periodic drift monitoring of all Model 1151, 1152, 1153, and 1154 Rosemount pressure and differential pressure transmitters for which RTT elimination is proposed, in accordance with the guidance contained in Rosemount Technical Bulletin No. 4, and continue to remain in full compliance with any prior commitments to Bulletin 90-01, Supplement 1. As an alternative to performing periodic drift monitoring of Rosemount transmitters, licensees may complete the following actions: (1) ensure that operators and technicians are aware of the Rosemount transmitter loss of fill-oil issue and make provisions to ensure that technicians monitor for sensor response time degradation during the performance of calibrations and functional tests of these transmitters, and (2) review and revise surveillance testing procedures, if necessary, to ensure that calibrations are being performed using equipment designed to provide a step function or fast ramp in the process variable and that calibrations and functional tests are being performed in a manner that allows simultaneous monitoring of both the input and output response of the transmitter under test, thus allowing, with reasonable assurance, the recognition of significant response time degradation.

Licensee Response: During RFO 7 in the spring of 1997, the last Rosemount transmitter covered by NRC Bulletin 90-01 was changed out. Therefore, all of the affected transmitters have either reached the appropriate "time at pressure" criteria required for exclusion or they have been replaced with a refurbished or new transmitter. The concerns identified by NRC bulletin 90-01 have been resolved.

Evaluation: Since HNP does not use Rosemount transmitters for which periodic drift monitoring is required, this condition is not applicable.

The NRC staff confirmed that the licensees responses satisfactorily addressed the above conditions in the NRC staff generic SER, and are therefore acceptable to the staff.

The NRC staff SER approving WCAP-14036 also had a condition that must be met by the individual licensee referencing the topical report before the guidance could be implemented in plant-specific TS change proposals. The condition is as follows.

Condition: Since the performance of RTT is a TS requirement, licensees referencing WCAP-14036 must submit a TS amendment to eliminate that requirement for the identified equipment. In that amendment request, the licensee must verify that the failure modes and effects analysis (FMEA) performed by the WOG is applicable to the equipment actually installed in the licensees facility, and that the analysis is valid for the versions of the boards used in the protection system.

Licensee Response: In its August 30, 2002, submittal, the licensee stated:

The FMEA provided by the WOG in WCAP-14036-(P)(A), Revision 1, is applicable to the installed equipment in the population for which this change request is being submitted with the exception of three summing amp cards that are 6NSA artwork level. These cards are located in Process Instrument Cabinets (PICs) 1 and 2:

Cabinet Slot Card Type PIC-01 0231 6NSA1 PIC-02 0231 6NSA1 PIC-02 0243 6NSA1 The WCAP designated components R294-1 and C83-1 in block G as the most sensitive components to any time response degradation. WCAP-14620, "7300 Printed Circuit Card Revision History," shows that these components were not affected by any of the changes between artwork level 4 and 6. Also no other changes were identified which could degrade the card's time response. Therefore, the changes on this card from the above 4NSA artwork level have been evaluated as having no adverse impact on the time response of the card. Other versions of these cards in use at HNP will not be included in this response time elimination request. The Nuclear Instrumentation System is addressed in section 4.6 of WCAP-14036-P-A, Revision 1.

Evaluation: This response fulfills the condition in the NRC staffs generic SER, and is therefore acceptable to the staff.

3.3 Bounding Response Times In addition to the above conditions, when a plant accident analysis determines that a mitigation system is required to actuate in a certain response time, the testing for that response time is generally required by TS. The license amendment request will eliminate some of the testing previously required. The two topical reports mentioned above provide adequate justification that calibrations and other surveillance testing will prove that the instruments are functioning properly. When the testing is not done to a portion of the instrument loop, but the TS requires the verification of assumptions made in the accident analysis, some assumed or bounding value for the untested portion of the loop must be added to the tested portion to arrive at a total system response time. WCAP-14036 included those maximum or bounding response times for the equipment that was analyzed in that report. WCAP-13632 did not have similar bounding response times approved for the sensors that were addressed in that topical report. The bounding sensor response time value tables shown below and the notes to the tables were included in attachment 1, Tables 1 and 2, in the August 30, 2002, submittal by the licensee.

Table I Reactor Trip System Function / Allocation Time Time Time Time Function Sensor Process SSPS Relays Note 2 Note 4 Note 6 Pressurizer Pressure Rosemount 0.54 Sec. 7300 0.100 Sec. Input + SSPS Logic 0.020 Sec.

High 1154SH9RA Pressurizer Pressure Rosemount 0.54 Sec. 7300 0.100 Sec. Input + SSPS Logic 0.020 Sec.

Low 1154SH9RA Pressurizer Pressure Rosemount 0.54 Sec. 7300 0.100 Sec. Input + SSPS Logic 0.020 Sec.

Low-SI 1154SH9RA Pressurizer Level High N/A N/A N/A N/A N/A N/A Loss of Flow-Single Rosemount 0.15 Sec. 7300 0.100 Sec. Input + SSPS Logic 0.020 Sec.

Loop 1154HP5RA Loss of Flow-Two Rosemount 0.15 Sec. 7300 0.100 Sec. Input + SSPS Logic 0.020 Sec.

Loops 1154HP5RA

Table I Reactor Trip System Function / Allocation Time Time Time Time Function Sensor Process SSPS Relays Note 2 Note 4 Note 6 0.065 Sec.

Power Range Neutron Note 1 N/A RIS WCAP-14036, Input + SSPS Logic 0.020 Sec.

Flux High Setpoint Sect 4.5 0.065 Sec.

Power Range Neutron Note 1 N/A NIS WCAP-14036, Input + SSPS Logic 0.020 Sec.

Flux Low Setpoint Sect 4.5 0.200 Sec.

Power Range High Note 1 N/A NIS WCAP-14036, Input + SSPS Logic 0.020 Sec.

Flux Rate Sect 4.5 OTDT (Vary Neutron Flux) Includes I MSec. 0.401 Sec.

for Isolation Amplifier Note 1 N/A NIS/7300 WCAP-14036, Input + SSPS Logic 0.020 Sec.

per WCAP-14036-P-A, Sect 4.5 Rev.1, Section 4.6 OTDT (Vary Tavg) Note 3 N/A 7300 Note 5 0.4375 Sec. Input + SSPS Logic 0.020 Sec.

OTDT (Vary Dt) Note 3 N/A 7300 Note 5 0.4375 Sec. Input + SSPS Logic 0.020 Sec.

Rosemount OTDT (Vary Pressure) 0.54 Sec. 7300 0.400 Sec. Input + SSPS Logic 0.020 Sec. 1154SH9RA OPDT (Vary DT) Note 3 N/A 7300 Note 5 0.4375 Sec. Input + SSPS Logic 0.020 Sec.

OPDT (Vary Tavg) Note 3 N/A 7300 Note 5 0.4375 Sec. Input + SSPS Logic 0.020 Sec.

SG Water Level Lo-Lo Barton 764 0.400 Sec. 7300 0.100 Sec. Input + SSPS Logic 0.020 Sec.

SG Water Level Low With Feed Flow/Steam N/A N/A N/A N/A N/A N/A Flow Mismatch RCP Undervoltage Note 3 N/A N/A N/A Input + SSPS Logic 0.020 Sec.

RCP Underfrequency Note 3 N/A N/A N/A Input + SSPS Logic 0.020 Sec.

Barton 752 With Containment Press Hi-Model 351 Sealed 1.400 Sec. 7300 0.100 Sec. Input + SSPS Logic 0.020 Sec.

1 SI Sensor Steam Line Pressure Barton 763 0.200 Sec. 7300 0.100 Sec. Input + SSPS Logic 0.020 Sec.

Low-SI RPS Functions Acronyms OPDT - Overpower Temperature NIS - Nuclear Instrumentation System SG - Steam Generator OTDT - Overtemperature Temperature RCP - Reactor Coolant Pump SI - Safety Injection

Table 2 Engineered Safety Feature Function / Allocation Time Time Time Time Function Sensor Process SSPS Relays Note 2 Note 4 Note 6 Pressurizer Pressure Rosemount Input + SSPS Logic +

0.54 Sec. 7300 0.100 Sec. 0.124 Sec.

Low-SI (ECCS) 1154SH9RA Master + Slave Relays Pressurizer Pressure Rosemount Input + SSPS Logic +

Low-Feedwater 0.54 Sec. 7300 0.100 Sec. 0.088 Sec. 1154SH9RA Master + Slave Relays Isolation Pressurizer Pressure Rosemount Input + SSPS Logic +

Low-Containment 0.54 Sec. 7300 0.100 Sec. 0.124 Sec. 1154SH9RA Master + Slave Relays Isolation Phase a Pressurizer Pressure Rosemount Input + SSPS Logic +

Low-Containment Vent 0.54 Sec. 7300 0.100 Sec. 0.088 Sec. 1154SH9RA Master + Slave Relays Isolation Pressurizer Pressure Rosemount Input + SSPS Logic +

Low-Aux Feedwater 0.54 Sec. 7300 0.100 Sec. 0.088 Sec. 1154SH9RA Master + Slave Relays Pumps Pressurizer Pressure Rosemount Input + SSPS Logic +

0.54 Sec. 7300 0.100 Sec. 0.088 Sec.

Low-SW System 1154SH9RA Master + Slave Relays Pressurizer Pressure Rosemount Input + SSPS Logic +

Low-Emergency Fan 0.54 Sec. 7300 0.100 Sec. 0.088 Sec. 1154SH9RA Master + Slave Relays Coolers Pressurizer Pressure Rosemount Input + SSPS Logic +

Low-Control Room 0.54 Sec. 7300 0.100 Sec. 0.088 Sec. 1154SH9RA Master + Slave Relays Emergency HVAC Sg Water Level Lo-Lo Input + SSPS Logic +

(Motor Driven AFW Barton 764 0.400 Sec. 7300 0.100 Sec. 0.124 Sec.

Master + Slave Relays Pumps)

Sg Water Level Lo-Lo Input + SSPS Logic +

(Turbine Driven AFW Barton 764 0.400 Sec. 7300 0.100 Sec. 0.124 Sec.

Master + Slave Relays Pumps)

Sg Water Level Hi-Hi Input + SSPS Logic +

Barton 764 0.400 Sec. 7300 0.100 Sec. 0.160 Sec.

(Feedwater Isolation) Master + Slave Relays Sg Water Level Hi-Hi Input + SSPS Logic +

(Trip Turbine & FW Barton 764 0.400 Sec. 7300 0.100 Sec. O.124 Sec.

Master + Slave Relays Pumps)

Sg Water Level Hi-Hi Input + SSPS Logic +

Barton 764 0.400 Sec. 7300 0.100 Sec. 0.088 Sec.

(Fw Bypass Valves) Master + Slave Relays Containment Pressure Barton 752 with Input + SSPS Logic +

Hi-3 Containment Model 351 Sealed 1.400 Sec. 7300 0.100 Sec. 0.124 Sec.

Master + Slave Relays Spray Sensor Containment Pressure Barton 752 with Input + SSPS Logic+

Hi-3 Containment Model 351 Sealed 1.400 Sec. 7300 0.100 Sec. 0.088Sec.

Master + Slave Relays Isolation Phase B Sensor

Table 2 Engineered Safety Feature Function / Allocation Time Time Time Time Function Sensor Process SSPS Relays Note 2 Note 4 Note 6 Containment Pressure Barton 752 with Input + SSPS Logic +

Hi-2 Steam Line Model 351 Sealed 1.400 Sec. 7300 0.100 Sec. 0.088 Sec.

Master + Slave Relays Isolation Sensor Barton 752 with Containment Pressure Input + SSPS Logic +

Model 351 Sealed 1.400 Sec. 7300 0.100 Sec. 0.124 Sec.

Hi-1 SI (ECCS) Master + Slave Relays Sensor Containment Pressure Barton 752 with Input + SSPS Logic +

Hi-1 Feedwater Model 351 Sealed 1.400 Sec. 7300 0.100 Sec. 0.160 Sec.

Master + Slave Relays Isolation Sensor Containment Pressure Barton 752 with Input + SSPS Logic +

Hi-1 Containment Model 351 Sealed 1.400 Sec. 7300 0.100 Sec. 0.160 Sec.

Master + Slave Relays Isolation Phase a Sensor Containment Pressure Barton 752 with Input + SSPS Logic +

Hi-1 Containment Model 351 Sealed 1.400 Sec. 7300 0.100 Sec. 0.124 Sec.

Master + Slave Relays Ventilation Isolation Sensor Containment Pressure Barton 752 with Input + SSPS Logic +

Hi-1 Aux Feedwater Model 351 Sealed 1.400 Sec. 7300 0.100 Sec. 0.088 Sec.

Master + Slave Relays Pumps Sensor Barton 752 with Containment Pressure Input + SSPS Logic +

Model 351 Sealed 1.400 Sec. 7300 0.100 Sec. 0.088 Sec.

Hi-1 ESW System Master + Slave Relays Sensor Containment Pressure Barton 752 with Input + SSPS Logic +

Hi-1 Emergency Fan Model 351 Sealed 1.400 Sec. 7300 0.100 Sec. 0.088 Sec.

Master + Slave Relays Coolers Sensor Steam Line Pressure Input + SSPS Logic +

Barton 763 0.200 Sec. 7300 0.100 Sec. 0.124 Sec.

Low-SI (ECCS) Master + Slave Relays Steam Line Pressure Input + SSPS Logic +

Low- Feedwater Barton 763 0.200 Sec. 7300 0.100 Sec. 0.124 Sec.

Master + Slave Relays Isolation Steam Line Pressure Input + SSPS Logic +

Barton 763 0.200 Sec. 7300 0.100 Sec. 0.088 Sec.

Low-AFW Pumps Master + Slave Relays Steam Line Pressure Input + SSPS Logic +

Barton 763 0.200 Sec. 7300 0.100 Sec. 0.088 Sec.

Low-ESW System Master + Slave Relays Steam Line Pressure Input + SSPS Logic +

Low- Emergency Fan Barton 763 0.200 Sec. 7300 0.100 Sec. 0.088 Sec.

Master + Slave Relays Coolers Steam Line Pressure Input + SSPS Logic +

Low-Steam Line Barton 763 0.200 Sec. 7300 0.100 Sec. 0.088 Sec.

Master + Slave Relays Isolation Steam Line Pressure Input + SSPS Logic +

Low-Containment Barton 763 0.200 Sec. 7300 0.100 Sec. 0.088 Sec.

Master + Slave Relays Isolation Phase A Steam Line Pressure Input + SSPS Logic +

Low-Containment Barton 763 0.200 Sec. 7300 0.100 Sec. 0.124 Sec.

Master + Slave Relays Ventilation Isolation

Table 2 Engineered Safety Feature Function / Allocation Time Time Time Time Function Sensor Process SSPS Relays Note 2 Note 4 Note 6 0.088 Sec.

Steam Line Pressure Input + SSPS Logic +

Rate High-Steam Line Barton 763 0.200 Sec. 7300 0.100 Sec.

Master + Slave Relays Isolation Differential Pressure Between Steam Line Input + SSPS Logic +

Barton 763 0.200 Sec. 7300 0.100 Sec. 0.124 Sec.

High-Aux Feedwater Master + Slave Relays Isolation Refueling Water Rosemount Input + SSPS Logic +

Storage Tank Lo-Lo 0.48 Sec. 7300 0.100 Sec. 0.088 Sec.

1153DB5RA Master + Slave Relays Level Switchover Radiation Level High SSPS Logic + Master +

Containment Note 7 N/A N/A N/A Note 7 Slave Relays Ventilation Isolation RCS Wide Range Pressure High with SI SSPS Logic + Master +

Note 3 N/A 7300 0.100 Sec. 0.088 Sec.

Alternate Miniflow Slave Relays Valves Engineered Safety Features Actuation System (ESFAS) Function Acronyms AFW - Auxiliary Feedwater FW - Feedwater SI - Safety Injection ECCS - Emergency Core Cooling System HVAC - Heating, Ventilation, Air Conditioning ESW - Emergency Service Water SW - Service Water

Notes Applicable to Tables 1 and 2

1. Neutron detectors are exempt from response time testing per Plant Program Procedure PLP-106, "Technical Specification Equipment List Program and Core Operating Limits Report," Attachment 1 notation.

2. WCAP-13632, Revision 2, Table 9-1, allocated response time for Barton sensors used at HNP is as follows:

Model 752 400 milliseconds Model 763/763A 200 milliseconds Model 764 400 milliseconds Model 351 Sealed Sensor 1 second WCAP-13632, revision 2, did not provide an allocated response time for Rosemount 1154 or 1153 instruments.

HNP uses these model Rosemount transmitters for three functions that require response time testing. This includes RC Flow (Model 1154HP5RA), Pressurizer Pressure (Model 11 54SH9RA), and RWST Level (Model 1153DB5RA). To obtain baseline data as directed in Table 9-1 of WCAP-13632-P-A, Revision 2, the previous response times of all the 1153 and 1154 instruments were reviewed. The longest time of 0.44 seconds was obtained for a pressurizer pressure transmitter on 9/28/95 and 4/28/00. HNP performed a 95/95 statistical analysis of this data from R03 through R010. For each Rosemount transmitter model, a separate 95/95 analysis of the hydraulic ramp data and the noise analysis data was performed. The more conservative response time result from the two testing methods based on a 95/95 analysis was used for the allocated times in the Table for each model. Based on the results of this analysis, the following response times are allocated for each Rosemount model transmitter:

Model 1154HP5RA 0.15 seconds Model 1154SH9RA 0.54 seconds Model 1153DB5RA 0.48 seconds HNP has chosen to use the above sensor time allocation for the Barton and Rosemount models listed above.

3. These sensors were not included in Westinghouse evaluation of Elimination of Response Time Testing. Therefore, allocated sensor time is not used for these variables. These components will continue to be tested as required.

4. WCAP-14036-P-A, Revision 1, evaluated the following 7300 cards for response time elimination with below or older artwork levels:

7NMD 4NCH 4NRA 6NLP 4NSA 9NAL All of these are applicable to HNP. The only exception is that three summing amp cards are 6NSA artwork level.

However, the changes on this card from the above 4NSA artwork level have been evaluated as having no adverse impact on the time response of the card. Other versions of these cards in use at HNP will not be included in this response time elimination request. The Nuclear Instrumentation System is addressed in section 4.6 of WCAP-14036-P-A, Revision 1.

5. An additional 0.0375 sec. is added to the allocation in WCAP-14036-P-A, Revision 1, due to an additional NSA card installed as part of the bypass manifold elimination.

6. WCAP-14036-P-A, Revision 1, was evaluated for response time elimination of HNP relays. The Solid-State Protection System (SSPS) slave relays used are Potter & Brumfield Motor Driven Relays (MDRs). The SSPS input and master relays are G.P. Clare GP1 series, Midtex/AEMCO 156, or Potter & Brumfield KH series type relays. The bounding response time for reactor trip times is 2 times the nominal input relay release time of 10 milliseconds, or 20 milliseconds. The bounding response time allocation for ESE functions is the combination of the longest pick-up or dropout time for each relay in the total circuit signal path for ESF component actuation. Therefore, an additional 36 milliseconds must be allocated for each MDR type separation relay (if installed) between the slave relay and end device. Bounding SSPS response time for ESF functions equals 26 milliseconds (input relay) plus 26 milliseconds (master relay) plus 36 milliseconds (for each slave relay). This equates to 88 milliseconds for functions with one slave relay or 124 milliseconds for ESF functions with two slave relays in series.

7. Response time testing of Radiation Monitors is not required per Plant Program Procedure PLP-106, "Technical Specification Equipment List Program and Core Operating Limits Report," Table Notation 7. However, components downstream of the sensors, including SSPS logic and relays, will continue to be tested as required.

The NRC staff has reviewed these values and the methods by which the values were determined, and has found them acceptable.

3.4 Use of Anticipated Response Times other than Manufacturers Design Response Times The licensee stated that in some instances, the manufacturers design response time data is not available. In those instances, the licensee proposed using a response time value based upon actual values measured during past response time tests at HNP. The licensee provided the data for actual response times by letter dated December 16, 2002.

These administrative values for actual response time were established based upon review of the operating historical response time data. The NRC staff determined a statistically valid administrative value by determination of the mean and 2 sigma standard deviation value of response time (value which represents 95-percent confidence level by definition). The NRC staff then determined the one-sided tolerance limit factor for a normal distribution for a 95/95-percent confidence level. This was done using guidance in Applying Statistics, NUREG-1475, Table T-11b: One sided tolerance limit factor for a normal distribution.

The results of these calculations are as shown below:

Sensor Rosemount 1154HP5RA Function RC Flow Mean 0.046 seconds Std Dev 0.020 seconds Sample Size 21 One-sided tolerance limit factor 2.373 (95/95 Multiplier IAW NUREG 1475)

One-sided tolerance limit 0.094 seconds HNP administrative response time value 0.15 seconds Sensor Rosemount 1154SH9RA Function Pressurizer Pressure Mean 0.392 seconds Std Dev 0.043 seconds Sample Size 7 One-sided tolerance limit factor 3.399 (95/95 Multiplier IAW NUREG 1475)

One-sided tolerance limit 0.539 seconds HNP administrative response time value 0.54 seconds Sensor Rosemount 1153DB5RA Function RWST Level Mean 0.126 seconds Std Dev 0.149 seconds Sample Size 3 One-sided tolerance limit factor 7.656 (95/95 Multiplier IAW NUREG 1475)

One-sided tolerance limit 0.475 seconds HNP administrative response time value 0.48 seconds In each case, the HNP administrative response time value is more conservative than the one-sided tolerance limit; therefore, the licensees values are acceptable to the NRC staff.

Based upon the above review, the NRC staff concludes that the licensee has implemented the provisions of the generic SERs for RTT elimination and satisfied the applicable plant-specific conditions in accordance with the approved WCAP-13632 and WCAP-14036. Therefore, the NRC staff concludes that the proposed HNP TS modifications for selected instrument RTT elimination are acceptable.

4.0 STATE CONSULTATION

In accordance with the Commission's regulations, the State of North Carolina official was notified of the proposed issuance of the amendment. The State official had no comments.

5.0 ENVIRONMENTAL CONSIDERATION

The amendment changes a requirement with respect to installation or use of a facility component located within the restricted area as defined in 10 CFR Part 20 and changes the surveillance requirements. 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 (67 FR 61676). 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) 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 Contributor: Paul J. Loeser Date: March 7, 2003

Mr. James Scarola Shearon Harris Nuclear Power Plant Carolina Power & Light Company Unit 1 cc:

Mr. William D. Johnson Mr. Robert J. Duncan II Vice President and Corporate Secretary Director - Site Operations Carolina Power & Light Company Carolina Power & Light Company Post Office Box 1551 Shearon Harris Nuclear Power Plant Raleigh, North Carolina 27602 Post Office Box 165, Mail Zone 1 New Hill, North Carolina 27562-0165 Resident Inspector/ Harris NPS c/o U. S. Nuclear Regulatory Commission Mr. Robert P. Gruber 5421 Shearon Harris Road Executive Director New Hill, North Carolina 27562-9998 Public Staff NCUC 4326 Mail Service Center Ms. Karen E. Long Raleigh, North Carolina 27699-4326 Assistant Attorney General State of North Carolina Chairman of the North Carolina Post Office Box 629 Utilities Commission Raleigh, North Carolina 27602 Post Office Box 29510 Raleigh, North Carolina 27626-0510 Public Service Commission State of South Carolina Ms. Linda Coleman, Chairperson Post Office Drawer 11649 Board of County Commissioners Columbia, South Carolina 29211 of Wake County P. O. Box 550 Ms. Beverly Hall, Acting Director Raleigh, North Carolina 27602 Division of Radiation Protection N.C. Department of Environment Mr. Gary Phillips, Chairman and Natural Resources Board of County Commissioners 3825 Barrett Drive of Chatham County Raleigh, North Carolina 27609-7721 P. O. Box 87 Pittsboro, North Carolina 27312 Mr. Terry C. Morton Manager Mr. James W. Holt, Manager Performance Evaluation and Support Services Regulatory Affairs CPB 7 Carolina Power & Light Company Carolina Power & Light Company Shearon Harris Nuclear Power Plant Post Office Box 1551 P. O. Box 165, Mail Zone 1 Raleigh, North Carolina 27602-1551 New Hill, North Carolina 27562-0165 Mr. Benjamin C. Waldrep Mr. John R. Caves, Supervisor Plant General Manager - Harris Plant Licensing/Regulatory Programs Carolina Power & Light Company Carolina Power & Light Company Shearon Harris Nuclear Power Plant Shearon Harris Nuclear Power Plant P. O. Box 165, Mail Zone 3 P. O. Box 165, Mail Zone 1 New Hill, North Carolina 27562-0165 New Hill, NC 27562-0165 Mr. John H. ONeill, Jr.

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