ML20044C292

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Forwards Documents Re Proposed Generic Ltr on Relocation of Tech Spec Tables for Instrument Response Time Limits for Placement in PDR
ML20044C292
Person / Time
Issue date: 03/17/1993
From: Marcus G
Office of Nuclear Reactor Regulation
To: Vanduser K
NRC OFFICE OF INFORMATION RESOURCES MANAGEMENT (IRM)
Shared Package
ML20044B591 List:
References
NUDOCS 9303220052
Download: ML20044C292 (9)


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UNITED STATES 3

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,E NUCLEAR REGULATORY COMMISSION E

WASHINGTON, D.C 20555 o%..o /

March 17,1993 4

MEMORANDUM FOR:

Karen M. VanDuser Document Management Branch Division of Information Services Office of Information Resources Management FROM:

Gail H. Marcus, Chief Generic Communications Branch Division of Operating Reactor Support l

SUBJECT:

ASSOCIATED DOCUMENTS FOR PROPOSED GENERIC LETTER ON THE RELOCATION OF THE TECHNICAL SPECIFICATION TABLES FOR l

INSTRUMENT RESPONSE TIME LIMITS The Technical Specifications Branch in NRR has prepared the enclosed draft generic letter regarding the relocation of the technical specification tables for instrument response time limits. The Committee to Review Generic Requirements has reviewed and concurred in this draft generic letter. The Generic Communications Branch in NRR is preparing to publish the draft generic letter in the Federal Reaister for public comment.

By copy of this memorandum, we are providing the enclosed documents to the Public Document Room. The enclosures are (I) the draft generic letter as concurred by the CRGR and (2) the CRGR Review Package.

We request that you provide us with the Nuclear Documents System accession number for this memorandum so that we can include the accession number in the Federal Reaister notice. The accession number may be provided to the contact listed below by telephone or E-Mail.

l Du Gail H. Marcus, Chief Generic Communications Branch Division of Operating Reactor-Support Office of Nuclear Reactor Regulation

Enclosure:

As stated CONTACT:

T. J. Kim, NRR (301) 504-284I (E-Mail TJK3) s

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'n UNITED STATES 3,

.i NUCLEAR REGULJiTORY COMMISSION

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ALL HOLDERS OF OPERATING LICENSES FOR NUCLEAR POWER REACTORS

SUBJECT:

RELOCATION OF TECHNICAL SPECIFICATION TABLES ON INSTRUMENT RESPONSE TIME LIMITS (Generic Letter 93- )

The U.S. Nuclear Regulatory Commission (NRC) is issuing this guidance for requesting a licenso 2mendment to relocate tables of instrument response time limits from technical specifications (TSi to the updated final safety analysis report (FSAR). The NRC developed this line-item TS improvement in. response to TS proposals by applicants for operating licenses.

Licensees that plan to adopt this line-item TS improvement are encouraged to propose TS changes consistent with the enclosed guidance in Enclosures 1 and 2.

NRC project managers will review the amendment requests to verify that they conform to the guidance.

Please contact your project manager or the contact indicateo herein if you have questions on this matter.

Any action by licensees to propose technical specifications changes in accordance with the guidance of this generic letter is voluntary and, therefore, not a backfit under 10 CFR 50.109. The following information, although not requested under the provisions of 10 CFR 50.54(f), would help the NRC to evaluate licensees' costs to propose TS changes in accordance with this generic letter.

1.

The licensee's time and costs to prepare the amendment request.

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2.

An estimate of the licensee's long-term costs or savings as a result of j

this TS change.

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This request is covered by Office of Management and Budget Clearance Number

-l 3150-0011, which e:xpires June 30, 1994 The estimated-average number of l

burden hours is 40 person hours per licensee response, including' those needed l

to assess the new recommendations, search data sources, gather and analyze the

[.i data, and prepare the required letters. Send commea*3 regarding this burden

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estimate or any other aspect of this collection of information, including

-i suggestions for reducing this burden, to the Information and Records i

Management Branch (MNBB 7714), Division of Information Support Services, j

Office of Information and Resource Management, U.S. Nuclear Regulatory Commission, Washington, D.C. 20555 and to Ronald Minsk, Office of Information I

and Regulatory Affairs (3150-0011), NE0B-3019, Office of Management and l

Budget, Washington, D.C. 20503.

i Sincerely, t

i James G. Partlow Associate Director for Projects Office of Nuclear Reactor Regulation l

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Enclosures:

j As stated l

1

Contact:

Tom Dunnir.g,- NRR

.j (301) 504-1189 i

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Generic Letter 93-

. Enclosure 1 Guidance for a Proposed License Amendment to Relocate l

Tables of Instrument Response Time Limits from Technical Specifications j

to the Updated Final Safety Analysis Report Introduction The U.S. Nuclear Regulatory Commission (NRC) is issuing the following guidance for preparing a proposed license amendment to relocate the tables of response f

i time limits for the reactor trip system (RTS) and the engineered safety features actuation system (ESFAS) instruments from technical specifications (TS) to the updated final safety analysis report (FSAR).

The NRC.has already l

implemented this line-item TS improvement for recently issued operating j

licenses and in the improved standard technical specifications.

i Discussion i

The limiting conditions for operation (LCO) for RTS and ESFAS instruments require that these systems be operable with response times as specified in:TS tables for each of these systems. The surveillance requirements specify that j

l licensees test these systems and verify that the response time of each func-tion is within its limits.

Relocating the tables for the RTS and ESFAS instrument response time limits from the TS to the updated FSAR will not alter

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these surveillance requirements. However, this-TS change allows the-licensee to administratively control changes to the response time limits for the RTS and ESFAS instruments in accordance with the provisions of 10 CFR 50.59 without the need to process a license amendment re_ quest.

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5 The LC0 for the RTS and the ESFAS typically speci_fy that the associated instruments "shall be OPERABLE with RESPONSE TIMES as shown in Table 3.3-2"-

'(RTS)'or " Table 3.3-5" (ESFAS). An acceptable change to the LCO would-be to 1

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d remove the reference to response times and simply state that this instrumen-i tation "shall be OPERABLE" as shown for the markup of the Westinghouse standard technical specifications in Enclosure 2.

This change is compatible i

with relocating the referenced tables.

The surveillance requirements specify that the response time of each trip function is to be demonstrated to be within its limit at the specified frequency and do not reference the tables of response time limits. Therefore, l

i the surveillance requirements specified in this manner need not be modified to implement this change. However, a footnote in the table of response time

-l limits for the RTS states that neutron detectors are exempt from response time testing. To retain this exception, which is stated only in the table being removed from the TS, the surveillance requirements for the RTS should be~

modified to add the following statement:

j Neutron detectors are exempt from response time testing.

Each licensee that wishes to implement this line-item TS improvement should confirm that the plant procedures for response time testing include acceptance.

j criteria that reflect the RTS and the ESFAS response time. limits in the tables l

being relocated from the TS to the updated FSAR. The licensee should also l

provide a commitment to include the RTS and the ESFAS response time limits in the next update of the FSAR.

I Licensees would submit any subsequent changes to these limits in the FSAR as l

an update of the FSAR as required by 10 CFR 50.71(e).

Related changes to I

plant procedures would be subject to the provisions that control changes to plant procedures as stated in the administrative controls section of the TS.

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9 Generic Letter 93-l Model Technical Specifications The model technical specifications are based on the " Standard Technical Specifications for Westinghouse Pressurized Water Reactors," NUREG-0452, l

Revision 4a.

3/4.3.1 REACTOR TRIP SYSTEM INSTRUMENTATION 3.3.1 As a minimum, the Reactor Trip System instrumentation channels and interlocks of Table 3.3-1 shall be OPEhABLE. with RESPONSE TIMES a: shown in i

i Tabic 3.3 2.

(Change TS 3.3.1 as shown) 4.3.1.2 The REACTOR TRIP SYSTEM RESPONSE TIME of each Reactor trip function shall be demonstrated to be within its limit 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 c' annels-tre 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.

(No change to TS 4.3.'1.2) 31_4.3.2 ENGINEERED SAFETY FEATURES ACTUATION SYSTEM INSTRUMENTATION i

3.3.2 The Engineered Safety Features Actuation System (ESFAS) instrumentation channels and interlocks shown in Table 3.3-3 shall be OPERABLE with their Trip Setpoints set consistent with the values shown in the Trip Setpoint column of Table 3.3-4. and..ith RESPONSE TIMES a; shcwn in Table 3.3 S.

(Change TS 3.3.2 as shown) 4.3.2.2 The ENGINEERED SAFETY FEATURES RESPONSE TIME of each ESFAS function-l l

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I shall be demonstrated to be within the limit at least once per 18 months.

j 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 j

are-tested at least-once every N times 18 months where N is the total number of redundant channels in a specific ESFAS function as shown in the " Total No.

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of Channels" column of Table 3.3-3.

(No change to TS 4.3.2.2) 3 4

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