ML20072F340

Application for Amends to Licenses NPF-2 & NPF-8,eliminating Periodic Pressure Sensor Response Time Testing Requirements. Rev 1 to WCAP-13787 & Proprietary Rev 1 to WCAP-13632, Elimination of Pressure... encl.WCAP-13632,Rev 1 Withheld

ML20072F340
Person / Time
Site:	Farley
Issue date:	08/17/1994
From:	Dennis Morey SOUTHERN NUCLEAR OPERATING CO.
To:	NRC OFFICE OF INFORMATION RESOURCES MANAGEMENT (IRM)
Shared Package
ML19304C524	List: ML20072F340 ML20072F348 ML20072F359 ML20072F366
References
NUDOCS 9408230299
Download: ML20072F340 (3)

Text

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Southern Nue: ear Operatng Company Pest Off ce Box 1295 g Wrmmgham. A:abama 35201

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Te ephone (205i 868 5131 t

Rae, o m u ey Southern Nudear Operating Company

$*"%N August 17, 1994 e n mem e m c a ste m Docket Nos. 50-348 10 CFR 50.90 50-364 U. S. Nuclear Regulatory Commission ATTN: Document Control Desk Washington, D. C. 20555 Joseph M. Farley Nuclear Plant Technical Specifications Change Request Elimination of Periodic Pressure Sensor Response Time Testing Requirements Gentlemen:

In accordance with the provisions of 10 CFR 50.90, Southern Nuclear Operating Company (SNC) proposes to amend the Farley Unit I and Unit 2 Technical Specifications to eliminate periodic pressure sensor response time testing requirements. The proposed amendment modifies the Reactor Trip System (RTS) and Engineered Safety Feature Actuation System (ESFAS) Instrumentation Surveillance Requirements 4.31.3 and 4.3.2.3 to indicate that the total channel response time will be periodically " verified" versus " tested" to demonstrate acceptable protection system response time. The associated Bases revision clarifies that allocations for sensor response times may be obtained from: 1) historical records based on acceptable response time tests; 2) inplace, onsite, or oiTsite (e.g., vendor) test measurements, or 3) utilizing vendor engineering specifications. WCAP-13632, Revision 1, " Elimination of Pressure Sensor Response Time Testing Requirements," provides both the technical basis for deleting periodic pressure sensor response time testing and the methodology for verifying the total channel response time using an allocated sensor response time.

1 The proposed Technical Specifications changes are provided in Attachment I. WCAP-13632, Revision 1 (Westinghouse proprietary class 2) and WCAP-13787, Revision 1 (Westinghouse proprietary class 3) are included in Attachment II, along with Westinghouse authorization letter CAW-94-565 and accompanying afridavit, proprietary information notice, and copyright notice. As WCAP-13632, Revision I contains information proprietary to Westinghouse Electric Corporation, it is supported by an alTidavit signed by Westinghouse, the owner of the information. The aflidavit sets forth the basis on which the information may be withheld from public disclosure by the Commission and addresses with specificity the considerations listed in paragraph (b)(4) of Section 2.790 of the Commission's regulations. Correspondence with respect to the copyright or proprietary aspects of the items listed above or the supporting Westinghouse aflidavit should reference CAW-94-565 and should be addressed to Nicholas J. I Liparulo, Manager of Nuclear Safety and Regulatory Activities, Westinghouse Electric l Corporation, P. O. Box 355, Pittsburgh, Pennsylvania 15230-0355. I With regard to the current industry e%rt to minimize the Technical Specifications response l time testing requirements, the Westinghouse Owners Group (WOG) has participated in

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U. S. Nuclear Regulatory Commission Page 2 meetings with the BWR Owners Group (BWROG) and the NRC Staff to ensure that the WOG understood the Staffs concerns outlined in the NRC Safety Evaluation Report for the BWROG Licensing Topical Report, " System Analyses for Elimination of Selected Response ,

4 Time Testing Requirements." WCAP-13632, Revision 1 addresses the Staff concerns and 1 includes a cost benefit evaluation and a safety assessment for increased response times beyond the current limits. In addition, Attachment III of this letter provides a specific response for each question listed in Section 4 of the subject NRC SER.

The significant hazards evaluation is provided in Attachment IV. SNC has determined the proposed changes to the Technical Specifications do not involve a significant hazards consideration as defmed by 10 CFR 50.92. SNC has also determined the proposed changes will not significantly affect the quality of the environment. A copy of the proposed changes has been sent to Dr. D. E. Williamson, the Alabama State Designee, in accordance with 10 CFR 50.91(b)(1).

In that Farley is a lead plant for the Westinghouse Owners Group (WOG), your prompt response to this proposed Technical Specifications change is respectfully requested. The elimination of periodic sensor response time testing will result in reduced radiation exposure and maintenance testing manhours. For Farley, the expected savings will be greater than

$100,000 over the life of the plant; as such, this submittal should be considered as a Cost Beneficial Licensing Action (CBLA). Should there be any questions, please advise.

Respectfully submitted, SOUTHERN NUCLEAR OPERATING COhfPANY f ]7Lt Dave hforey SWORN TO AND SUBSCRIBED BEFORE AfE This / day of bl44.A ,1994 h74Lt4s b

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MGE/citRTTTSSI.MGE Attachments cc: hir. B. L. Siegel hir. S. D. Ebneter hir. T. hi. Ross Dr. D. E. Williamson ,

A'ITACilMENT I FNP Unit 1 Technical Specifications Proposed Changed Pages List FNP Unit 1 Technical Specifications Marked-up Pages FNP Unit 1 Technical Specifications Typed Pages FNP Unit 2 Technical Specifications Proposed Changed Pages List FNP Unit 2 Technical Specifications Marked-up Pages FNP Unit 2 Technical Specifications Typed Pages

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