ML18022A974

Forwards RAI Re Proposed TSs Change Eliminating Pressure Sensor Response Time Testing Requirements for Plant

ML18022A974
Person / Time
Site:	Harris
Issue date:	09/22/1995
From:	Le N NRC (Affiliation Not Assigned)
To:	Robinson W CAROLINA POWER & LIGHT CO.
References
TAC-M91722, WCAP-13632, NUDOCS 9510110011
Download: ML18022A974 (8)

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UNITED STATES NUCLEAR REGULATORY COMMISSION WASHINGTON, D.C. 20555-0001 September 22, 1995 Mr.

W.

R. Robinson, 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:

REQUEST FOR ADDITIONAL INFORMATION REGARDING THE PROPOSED TECHNICAL SPECIFICATIONS CHANCRE ELIMINATING PRESSURE SENSOR

RESPONSE

TIME TESTING REQUIREMENTS SHEARON HARRIS NUCLEAR POWER PLANT, UNIT 1

(TAC NO.

M91722)

Dear Mr. Robinson:

By letter dated March 3, 1995, Carolina Power

& Light Company (CP&L) proposed the elimination of periodic response time testing (RTT) Tech'nical Specification requirements for selected pressure and differential pressure sensors in certain Reactor Trip System and Engineered Safety Features Actuation System instrumentation channels for Shearon Harris Nuclear Power.

Plant, Unit 1

(SHNPP).

In the proposed change

request, CP&L stated that the technical justification for the elimination of sensor RTT is contained in Westinghouse Electric Corporation report WCAP-13632, Revision 1, "Elimination of Pressure Sensor

Response

Time Testing Requirements,"

dated December 1993.

In August

1995, Westinghouse Electric Corporation issued WCAP-13632, Revision 2, which superseded Revision 1.

By Safety Evaluation Report (SER) dated September 5,

1995, the staff approved WCAP-13632, Revision 2, as a basis for eliminating RTT requirements for selected pressure and differential pressure sensors.

This generic SER listed several actions that licensees must take when eliminating RTT requirements.

In order to facilitate the staff review of the CP&L's March 3,

1995, submittal, you are requested to review information relating to the conditions specified in the staff's generic SER and provide additional information as provided in Enclosure 1.

The staff's generic SER approving WCAP-13632, Revision 2, is provided as Enclosure 2.

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9510110011 950922 PDR ADOCK 05000400 P

PDR

This requirement affects nine or fewer respondents and, therefore, is not subject to the Office of Management and Budget review under P.L.96-511.

Sincerely Docket No. 50-400

Enclosures:

As stated cc: w/enclosures:

See next page FILENAME G 'HARRISiHAR91722. RAI (Original Signed By)

Ngoc B. Le, Project Manager Project Directorate II-1 Division of Reactor Projects I/II Office of Nuclear Reactor Regulation Distribution g)ocket&ij.e~

ACRS (4)

PUBLIC DVerrelli, RII PDII-1 RF KKarwoski SVarga DMcDonald JZwolinski OGC NAME

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EDunnin on DATE 09/4'5 COPY es No OFFICE LA: PD I I-1 D:PD I-1 PM: PD I I-1 NLe +t4 09 C

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Mr.;W,.R. Robinson Carolina Power

& Light Company Shearon Harris Nuclear Power Plant Unit 1

CC:

Mr. R.

E. Jones General Counsel Legal Department Carolina Power

& Light Company Post Office Box 1551

Raleigh, North Carolina 27602 Resident Inspector/Harris NPS c/o U.S. Nuclear Regulatory'ommission 5421 Shearon Harris Road New Hill, North Cakolina 27562-9998 Karen E.

Long Assistant Attorney General State of North Carolina Post Office Box 629

Raleigh, North Carolina 27602 Public Service Commission State of South Carolina Post Office Drawer 11649

Columbia, South Carolina 29211 Regional Administrator, Region Il U.S. Nuclear Regulatory Commission 101 Marietta St.,

N.W. Suite 2900 Atlanta, Georgia 30323 Mr. Dayne H. Brown, Director Division of Radiation Protection N.C. Department of Environmental Division of Radiation Protection Commerce

& Natural Resources Post Office Box 27687

Raleigh, North Carolina 27611-7687 Mr. J.

Cowan Manager Nuclear Services and Environmental Support Department Carolina Pdwer

& Light Company Post Office Box 1551 Mail OHS7

Raleigh, North Carolina 27602 Mr. J.

W. Donahue Plant'anager Harris Plant Carolina Power

& Light Company Shearon Harris Nuclear Power Plant Post Office Box 165, MC: Zone 1

New Hill, North'Carolina"27562-0165 Mr. Robert P. Gruber Executive Director Public Staff NCUC Post Office Box 29520

Raleigh, North Carolina 27626 Chairman of the North Carolina Utilities Commission Post Office Box 29510 Raleigh, North Carol ina 27626-0510 T.

D. Walt

Manager, Regulatory Affairs Carolina, Power.

& Li.ght Company Shearon Harris Nuclear Power Plant P. 0.

Box 165,.Mail Zone 1

New Hi 1 1, North Carol ina 27562-0165 Mr. Vernon Malone, Chairman Board of County Commissioners of Wake County P. 0.

Box 550

Raleigh, North Carolina 27602 Mr, Henry Dunlap, Chairman Board of County Commissioners of Chatham County P. 0.

Box, 111 Pittsboro, North Carolina 27312

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t ENCLOSURE 1

RE VEST FOR ADDITIONAL INFORMATION (1)

In August'995-,

Westinghouse Electric Corporation issued WCAP-13632; Revision 2, which superseded WCAP-13632, Revision 1.

Subsequently, by Safety Evaluation Report (SER) dated September 5,

1995 (Enclosure 2),

the staff approved WCAP-13632, Revision 2, "Elimination of Pressure Sensor

Response

Time Testing Requirements,"

as a basis for eliminating RTT requirements for selected pressure and differential pressure sensors.

Please revise your March 3, 1993 submittal to reference WCAP-

13632, Revision 2.

(2)

The staff's SER approving WCAP-13632, Revision 2, stated that licensees must take the following actions when eliminating pressure and differential pressure sensor.RTT requirements:

t (a)

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.

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(b)

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.

(c)

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.

Please address each of these actions and state how these actions will be implemented.

(3)

The staff's SER approving WCAP-13632, Revision 2, noted that loss of fill-oil in pre-July 1989 and post-July 1989 manufactured Model

1151, 1152,

1153, and 1154 Rosemount pressure and differential pressure transmitters is a credible failure mode that could potentially affect sensor response time independently of sensor output.

As a result, this failure mode may not be detected during other routine surveillance requirements.

To address this potential failure mode, the staff's SER stated that licensees proposing to eliminate RTT requirements for all Model

1151, 1152,

1153, and 1154 Rosemount pressure and differential pressure transmitters must take the following action:

"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,

"Loss of Fill-Oil in Transmitters Nanufactured by Rosemount."

As an alternative to performing periodic drift monitoring of Rosemount transmitters, licensees may complete the following action's'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."

In the March 3, 1995 letter, CP&L proposed to eliminate RTT requirements for Model 1153 and 1154 Rosemount transmitters installed in the pressurizer

pressure, reactor. coolant flow, and refueling water storage tank level i'nstrumentation channels.

Please address the above action and state how the action will be implemented.

Please include any information relating to prior Bulletin 90-01, Supplement 1,

commitments for these transmitters.

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