ML20198E019
| ML20198E019 | |
| Person / Time | |
|---|---|
| Site: | Limerick  |
| Issue date: | 12/14/1998 |
| From: | NRC (Affiliation Not Assigned) |
| To: | |
| Shared Package | |
| ML20198E017 | List: |
| References | |
| NUDOCS 9812230315 | |
| Download: ML20198E019 (14) | |
Text
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NUCLEAR REGULATORY COMMISSION WASHINGTON, D.C. 20066 4001
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SAFETY EVALUATION BY THE OFFICE OF NUCLEAR REACTOR REGULATION RELATED TO AMENDMENT NOS.132 AND 93 TO FACILITY OPERATING L8 CENSE NOS. NPF-39 AND NPF-85 PECO ENERGY COMPANY MERl'CK GENERATING STATION. UNITS 1 AND 2 DOCKET NOS. 50-352 AND 50-353 l
1.0 INTRODUCTION
4 d
By letter dated August 8,1996, as supplemented by letters dated June 30,1997, and August 26, 1998, PECO Energy Company (the licensee) submitted a request for changes to the Limerick Generating Station (LGS), Units 1 and 2, Technical Specifications (TSs). Additionalinformation was received on June 30,1997 and August 26,1998, in response to telephone conversations with the staff and a Request for Additional Information (RAI) dated September 3,1997. The proposed TS modifications will eliminate response time testing (RTT) requirements for selected sensors cnd specified instrumentation loops for 1) the Reactor Protection System (RPS),2) the isolation System, and 3) the Emergency Core Cooling System (ECCS). The June 30,1997 and August 26,1998 letters provided clarifying information that did not change the initial proposed no significant hazards consiaeration determination.
2.0 BACKGROUND
The Boiling Water Reactor Owner's Group (BWROG) performed an analysis to assess the impact of elimination of RTT for selected instrument loops. This analysis was documented as Licensing Topical Report NEDO-32291, " System Analyses for Elimination of Selected Response Time Testing Requirements," and was submitted for the Nuclear Regulatory Commission (NRC) approvalin January 1994. The NRC approved NEDO-32291 in a generic Safety Evaluation Report (SER) dated December 28,1994 and approved subsequent revisions to NEDO-32291 in a supplemental SER dated May 31,1995. The generic SER included Tables 1 and 2, which respectively lists the make/model ofinstruments/ devices, and systems which were evaluated in NEDO-32291 for RTT elimination. The generic SER states, "The BWROG concluded that the RTI' requirements for the devices identified in Table 1 can be removed from the TSs when the devices are used in systems listed in Table 2." In addition to approving elimination of RTT for selected instrunie Cation, the generic SER stipulated certain conditions that individual plant licensees must me when implementing the NEDO-32291 guidelines on a plant-specific basis.
3.0 EVALUATION As approved by the staff, NEDO-32291 indicated that RTT can be eliminated for the following based on other TS testing which is sufficient to detect instrumentation response degradation:
9812230315 981214 PDR ADOCK 05000352 P
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All ECCS instrument loops; 1
2.
All isolatxm System actuation instrument loops except for main steamline isolation valves (MSIVs);
3.
Sensors for selected RPS actuation; and 4.
Sensors for MSIV closure actuation.
The licensee proposed elimination of the following selected response time testing recisirements from the LGS Units 1 & 2 TSs:
1.
All ECCS actuation instrumentation.
l 2.
Sensors for selected RPS actuation instrumentation.
_ 3.
Sensors for selected MSIV closure actuation instrumentation.
3.1 Specific Changes The specific sections of the LGS Units 1 & 2 TSs to be changed are as follows:
(a) TS Section 3/4.3.1, " Reactor Protection System Instrumentation," Table 3.3.1-2, " Reactor Protection System Response Times," will be revised to eliminate response time testing for applicable sensors for Reactor Vessel Water Level - Low, Level 3.
Prorosed Chanoe: On functional unit 4, Reactor Vessel Water level - Low, Level 3, change the response time from "s 1.05" to "s 1.05'". Add a footnote to the page:
Sensoris eliminated from response time testing for the RPS circuits. Response time testing and conformance to administrative limits for the remaining channel including trip unit and relay logic are required.
Evaluation: This footnote will allow LGS Units 1 & 2 to use manufacturer's response time data, or historical response time data as a substitute for actual measured sensor response time when determining the nyerall system response time, and therefore eliminate the roouirement for a separate measurement of the sensor response time. The remainder of the channel will continue to be tested for response time. This change is consistent with the approved NEDO-32291. The staff finds this acceptable.
(b) TS Bases Sechon 3/4.3.1, " Reactor Protection System Instrumentation," will be mvised to j
make reference to NEDO-32291, as applicable.
1 Prooosed Chance:
Bases Sechon 3/4.3.1, " Reactor Protection System instrumentation," page B 3/4 3-1, last paragraph, will have two lines added. The paragraph will change from:
l The measurement of response time at the specified frequencies provides assurance that the protechve functions===eatad with each channel are completed within the time iimit assumed in the safety analyses. No credit was taken for those channels j
with response times indicated as not applicable. Response time rney be 2
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. 4 demonstrated by any series of sequen'lal, overlapping or total channel test measurement, provided such tests demonstrate the total channel response time as defined. Sensor response time verification may be demonstrated by either (1) inplace, onsite or offsite test messurements, or (2) utilizing replacement sensors with certified response times.
to now read:
The measurement of response time at the specified frequencies provides assurance that the protective functions associated with each channel are completed within the time limit assumed in the safety analyses. No credit was takan 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 measuremen.t, provided such tests demnnstrate the total channel response time as defined. Sensor response time verification may be demonstrated by either (1) inplace, onsite or offsite test measurements, or (2) utilizing replacement sensors with certified response times. Response time testing for the sensors as noted in Table 3.3.12 is not required based on the analysis in NEDO-32291 A. Response time testing for the remaining channel components is required as noted.
Eyaluation: This change in the wording will allow LGS Units 1& 2 to use manufacturer's response time data, or historical response time data as a substitute for actual measured sensor response time when determining the overall system response time, and therefore eliminate the requirement for a separate measurement of the sensor response time. The remainder of the channel will continue to be tested for response time. This change is consistent with the approved NEDO-32291. The sttiff finds this acceptable.
c) TS Section 3/4,3.2, " Isolation Actuation instrumentation," Table 3.3.2-3, will be revised to eliminate response time testing for applicable sensors for Reactor Vessel Water Level-Low, Level 1, and Level 2; Main Steam Line Pressure - Low; and Main Steam Line Flow - High.
Instrumentation response time requirements for the Residual Heat Removal (RHR) Shutdown Cooling Mode isolation, Reactor Water Cleanup (RWCU) System isolation, High Pressure Coolant injection (HPCI) System isolation, Reactor Core isolation Cooling (RCIC) System isolation, and Primary Containment isolation will be eliminated as a result of the proposed TS changes. Further, table notations "a" and "** will be deleted and "###" will be added to reflect these changes.
Procosed Chanoe: Table 3.3.2-3, " Isolation System instrumentation Response Time," pages 3/4 3-23 through 3/4 3-26, will have the following changes:
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.. TRIP FUNCTION RESPONSE TIME FROM IQ 1.
Main Steam Line Isolation a.
- 1) Low, Low-Level 2 13 N.A.
- 2) Low, Low, Low - Level 1 s 1.0*/s 13(***
s 1.0###*
c.
Main Steam Line Pressure - Low s i.0*/s 13(***
s1.0###*
d.
Main Steam Line Flow-High s o.5*/s 13(***
so.5###*
2.
RHR System Shutdown Cooling Mode isolation a.
Reactor Vessel Water Level Low - Level 3 s 13
N.A.
3.
Reactor Water Cleanup System Isolation a.
RWCU A Flow-High s13"
- N.A.
e.
Reactor Vessel Water Level Low, Low - Level 2 s 13(')
N.A.
4.
High Pressure Coolant injection System isolation a.
HPCI Steam Line A Pressure - High s 13(')
N.A.
b.
HPCI Steam Supply Pressure - Low s 13(')
N.A.
5.
Reactor Core isolation Cooling System isolation e
RCIC Steam Line A Pressure - High s 13(*)
N.A.
b.
RCIC Steam Supply Pressure - Low s13(*)
N.A.
6.
Primary Cor.tainment isolation a.
1)
Low, Low - Level 2 s 13(')
N.A.
2)
Low, Low, Low - Level 1 s 13(*)
N.A.
b.
Drywell Pressure - High s 13(')
N.A.
The Table Notations on page 3/4 3-26, will have the following changes:
1.
Footnote (a) will be deleted.
. 2.
Footnote " will be 9eleted.
3.
Add a new footnote ### under note ##. The note will read:
Sensor is eliminated from response time testing for the MSIV actuation logic circuits. Response time testing and conformance to administrative limits for the remaining channel including trip unit and relay logic are required.
Evaluation: The change in the time requirement to "N/A" will allow LGS Units 1 and 2 to use i
manufacturer's response time data, or historical response time data as a substitute for actual measured instrument channel response time when determining the overall system response time, and therefore eliminate the requirerunt for a separate measurement of the response time.
It should be noted that in some sections of the basis, such as section 3/4.3.3, Reactor Protection System instrumentation, the term "N/A"is defined as meaning that no credit is taken for this function. This section states, in paragraph 4, that "no credit was taken for those channels with response times indicated as not applicable." No such statement is present in the basis for the isolation actuation instrumentation, and therefore the use of the "N/A" notation is acceptabte to the staff. Addition of the "###" footncte will allow elimination of the sensor RTT in those cas where the remainder of the channel still requires testing. These changes are consistent with the approved NEDO-32291. The staff finds them acceptable.
d)
TS Bases Section 3/4.3.2, " Isolation Actuation Instrumentation," will be revised to make reference to NEDO-32291, as applicable.
Prooosed Chanae:
Basis section 3/4.3.2," Isolation Actuation Instrumentation," page B 3/4 3-2, will have an additional paragraph added between the current fifth and sixth paragraphs. The end of this section now reads:
Except for the MSIVs, the safety analysis does not address individual sensor response times or the response times of the logic systems to which the sensors are connected. For D.C. operated valves, a 3 second delayis assumed before the valve starts to move. For A.C. operated valves, it is assumed that the A.C. power supply is lost and is restored by startup of the emercancy diesel generators, in this event, a time of 13 seconds is assumed before the valve starts to move. In addition to the pipe break, the failure of the D.C. operated valve is assumed; thus the signal delay (sensor response) is concurrent with the 10-second diesel startup and the 3 second load center loading delay. The safety analysis considers an allowable inventory loss in each case which in tum determines the valve speed in conjunction with the 13-second delay. It follows that checking the valve speeds and the 13-second time for emergency power establishment will establish the response time for the isolation functions.
Operation with a trip set less conservative than its trip setpoint but within its specified Allowable Value is acceptable on the basis that the difference between each Trip Setpoint and the Allowable Value is an allowance for instrument drift specifically allocated for each trip in the safety analyses.
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s n The end of section 3/4.3.2 will now read:
Except for the MSIVs, the safety analysis does not address individual sensor response times or the response times of the logic systems to which the sensors are connected. For D.C. operated valves, a 3 second delay is assumed before the valve starts to move. For A.C. operated valves, it is assumed that the A.C. power supply is i
lost and is restored by startup of the emergency diesel generators. In this event, a time of 13 seconds is assumed before the valve starts to move. In addition to the pipe break, the failure of the D.C. operated valve is assumed; thus the signal delay (sensor response) is concurrent with the 10-second diesel startup and the 3 second load center loading delay. The safety analysis considers an allowable inventory loss in each case which in tum determines the valve speed in conjunction with the 13-second delay. It follows that checking the valve speeds and the 13-second time for emergency power establishment will establish the response time for the isolation functions.
i Response time testing for sensors are not required based on the analysis in NEDO-32291-A. Response time testing of the remaining channel components is required as
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noted in Table 3.3.2-3.
1 Operation with a trip set less conservative than its Trip Setpoint but within its specified Allowable Value is acceptable on the basis that the difference between each Trip Setpoint and the Allowable Value is an allowance for instrument drift specifically allocated for each trip in the safety analyses.
Evaluation: This change is only to make reference to NEDO-32291, and therefore explain the basis and background for the modification of the TS's. The staff finds this change acceptable.
e)
TS Section 3/4.3.1, Table 3.3.3-3, "Emergancy Core Cooling System Response Times," will be revised to include an annotation indicating that ECCS actuation instrumentation is i
eliminated from RTT for Core Spray (CS), Low Pressure Coolant injection (LPCI) system, and HPCI system.
Procosed Chance: Table 3.3.3-3. " Emergency Core Cooling System Response Times,"
page 3/4 3-39, will have the following changes:
t TRIP FUNCTION RESPONSE TIME (Seconds)
FROM IQ 1.
Core Spray System s 27 s 27 #
2.
Low Pressure Coolant injection Mode of RHR System s 40 s 40 #
i 4.
High Pressure Coolant injection System s 60 s 60 #
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I A footnote # will be added. The note will read:
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"# ECCS actuation Instrumentation is eliminated from response time testing."
1 Evaluation: The addition of the notation to the response time requirement anel the addition of the note "#" will allow LGS Units 1& 2 to use manufacturer's response time data, or historical response time data as a substitute for actual measured actuation instrumentation response time when determining the overall system response tima, and therefore eliminate the requirement for a separate measurement of the actuation instrumentation response time. The remainder of the system will continue to be tested wr response time. This change is consistent with the approved NEDO-32291. The staff finds this acceptable.
3 j
3.2 AdditionalInstruments Not Listed in Staff SER The licensee, in their request for elimination of RTT, imiuded sensors not specifically discussed in NEDO-32291, and therefore not listed in Table 1 of the staff SER for NEDO-32291. The licensee's August 8,1996, submittalincluded Amerace ETR, EGP, and GPl relays, Bailey 745 Switch, and the GE CR2940 relay for RTT elimination. This was instrumentation not listed in NEDO-32291 and, therefore, not approved in the staff SER.
In the August 26,1998, letter responding to the staff RAI, the licensee stated:
In cur submittal for elimination of selected RTT we requested that various Amerace ETR, EGP c,nd GP relays be eliminated. Amerace is used in the LGS component record list (CRL) description of these instruments from which our submittal tables were developed. Amerace is the manufacturer of Agastat GP/EGP family of relays that are part identified in our request. Therefore, all EGP and GP/GPl Agastat relays identified in our submittal request as Amerace are bounded by the SER Table 1.
Likewise, the Bailey 745 ' Switch' description used in the LGS CRL is identified in the NEDO and is identified in the SER Table 1 as a 745 ' Alarm Unit' under 'Extemal Devices.' Therefore, the Bailey 745 ' Switches" referenced in Table 1 of our submittal request are bounded by the SER Table 1.
Our original submittal incorrectly identified various ETR relays in the HPCI (Table 2) and RCIC (Table 4) Steam Line DP-High. In accordance with NEDO-32291, Chapter 7, time delay relays are not to be included in elimination of RTT because they require calibration for response verification and to assure setpoint accuracy. The time delay relays are also tested as part of Logic System Functional Tests. Therefore, in accordance with the NEDO, we withdraw the associated ETR relays from our request.
Likewise, the GE CR2940 relays identified in our submitta! Table 1 - NSSS RWCU Differential Flow-High are switches, not relays, and are not identified in the SER Table 1. Therefore, in accordance with the NEDO, we withdraw the associated GE CR2940 switches from our request.
There are no changes necessary to the TS marked-up pages that were provided as part of our submittal."
8-The above explanation is acceptable to the staff since it confirms that the additional equipment l
proposed for RTF elimination is covered by the NEDO-32291 analysis, and therefore, inclusion of the Amerace ETR UGP and GPl relays and the Bailey 745 Switch in this request for elimination of RTT is acceptable.
3.3 Use of Anticipated Response Times other than Manufactures Design Response Times The licensee stated that in some instances, manufacturer's 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 LGS Units 1 and 2. The licensee provided the data for actual response times by letter dated August 26,1998, as a response to i
the staff RAI dated September 3,1997. In addition, the licensee stated:
The estimated response time that will be used for those portions of the system no longer tested, when determining overall system response time, is listed in Table 1.
)
The value for estimated response time for the RWCU differential flow trip function is j
based on historical test data. This value is a combined value for the Bailey Controls I
trip units, square root converters, signal converters, Agastat (Amerace) relays, and Eagle Timers used to provide the trip functions. A sample of response time test data l
from 1992-1996 was retrieved and evaluated using %ndard MATHCAD (Version 6) function for determining the mean (mean) and standard deviation (stdev) for a sample population. The estimated response time was verified to be greater than the mean plus two standard deviations. Refer to Exhibit page 6 for the sample data, 4
eva!uation, and results.
l The values for estimated response time for Rosemount differential pressure transmitters are based on historical test data. A sample of response time data from 1992-1998 was retrieved and evaluated using standard MATHCAD (Version 6) functions as described in the previou3 paragraph. Separate evaluations are provided to correspond to grcupings of trip functions and allotted response times used in the response time test precedures. Refer to Exhibit pages 15 for the sample data, evaluations, and results.
The value for estimated response time for Rosemount trip units is based on engineering judgment. The value is supported by testing perfonned by General Electric Co., to support the Analog Transmitar/ Trip Unit System For Engineered Safeguard Sensor Trip Inputs upgrade project in LTR NEDO-21817-A. Testing of a model 510 master / slave trip unit tandem combination resulter; in a maximum measured time delay of 1.5 msec. A more conservative va!ue of 2 msec will be used.
Based on the similarity of design of the model 510 and 710 trip units, this estimated I
response time will also be used for model 710 trip units. Response time test procedures verify the combined response time of trip units and Agastat relays.
I Consequently, historic response time data is not available for the trip unit alone.
i However, since the response time of the trip unit is expected to be two orders of magnitude less than the transmitter response time, and 3-4 orders of magnitude less
l 9
than the trip function response time, the trip unit contribution to trip function response time is insignificant.
The value for estimated response time for Agastat (Amerace) general purpose relays is based on manufacturer's supplied data.
These administrative values for actual response time were established based upon review of LGS operating historical response time data. The staff requested that LGS determine a statistically valid administrative value by determination of the mean and 2 sigma standard deviation value of response time (value which represents 95% confidence level by definition).
The staff then determined the one-sided tolerance limit factor for a normal distribution for a 95/95% 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:
1 Sensor Rosemount 1153/1151, RC 5/9 Function High Drywell Pressure High Reactor Pressure HPCI Steam Supply Pressure RCIC Steam Supply Pressure Low Reactor Pressure RWCU Flow HPCI Steam. Supply Clow RCIC Steam Supplf Flow Mean 71.03 Std Dev 60.10 Mean + 2*Std Dev 191.23 Sample Size 87 l
One sided tolerance limit factor 1.950 (95/95 Multiplier IAW NUREG 1475)
One sided tolerance limit 188 msec.
LGS administrative response time value 200 msec.
Sensor Rosemount 1153/1151, RC 5 Function Reactor Vessel Water Level j
Mean 93.33 l
Std Dev 42.90 Mean + 2*Std Dev 179.14 Sample Size 24 One sided tolerance limit factor 2.309 (95/95 Multiplier IAW NUREG 1475)
One sided tolerance limit 192 msec.
LGS administrative response time value 230 msec.
Sensor Rosemount 1153/1151, RC 7 Function MSL Flow J
4
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l 10-Mean i
80.52 Std Dev 95.68 Mean + 2*Std Dev 271.88 Sample Size 96 One sided tolerance limit factor 1.934 (95/95 Multiplier IAW NUREG 1475)
One sided tolerance limit 266 LGS administrative response time value 355 msec Sensor Rosemount 1153/1151, RC 4 Function Reactor Vessel Water Level '
Mean 122.5 Std Dev 84.09 Mean + 2*Std Dev 290.69 Sample Size 24 One sided tolerance limit factor 2.309 (95/95 Multiplier IAW NUREG 1475)
One sided tolerance limit 194 msec.
LGS administrative response time value 450 msec.
Sensor Rosemount 1153/1151, RC 5 1
Function Reac:or Vessel Water Level Mean 162.71 Std Dev 133.40 Mean + 2*Std Dev 429.50 l
Sample Size 48 One sided tolerance limit factor 2.081 l
(95/95 Multiplier IAW NUREG 1475)
One sided tolerance limit 440 msec.
l LGS administrative response time value 480 msec.
Sensor Bailey 745 Trip Unit Bailey 752 Converter l
Bailey 750 Square Rooter l
l Agastat GPl Relay Function RWCU Differential Flow-High Mean 45.06 i
Std Dev
.645 l
Mean + 2*Std Dev 46.351 Sample Size 22 l
One sided tolerance limit factor 2.349 l
(95/95 Multiplier IAW NUREG 1475)
One sided tolerance limit 45.58 seconds LGS administrative respor.ce time value 47 seconds t
4-d n In each case, the LGS administrative response time value is more conservative than the one-sided i
tolerance lim;t, and therefore, the licensee's values are acceptable to the staff.
4.0 VERIFICATION OF NEDO-32291 PLANT-SPECIFIC CONDITIONS The staff stipulated several conditions in the generic SER approving NEDO-32291 which must be met by the individual licensee referencing NEDO-32291 before its guidance could be implemented in plant-specific TS change proposals. From the LGS Units 1 & 2 licensee submittals, the staff verified that the licensee has met the applicable conditions as follows:
4.1 Condition
Confirm the applicability of the generic analyses to the plant.
Licensee's Response: PECO Energy Company has confirmed the generic applicability of NEDO-32291 to LGS, Units 1 and 2. As indicated in Appendix A of NEDO-32291, PECO Energy Company was a participating utility in this evaluation. PECO Energy Company has also confirmed that the components discussed within the scope of this TS change request have been evaluated in NEDO-32291.
The staff concurs with this response.
4.2 Condition
The licensee's revision request shall be submitted as shown in Appendix l of the BWROG LTR.
The staff has determined that the submittal fulfills this condition.
4.3 Condition
The licensee shall state that they are following the recommendations from EPRI NP-7243 and, therefore, shall perform the following actions:
(a)
Prior to installation of a new transmitter / switch or following refurbishment of a transmitter / switch (e.g., sensor cell or variable damping components), a hydraulic RTT shall be performed to determine an initial sensor-specific response time value.
h Licensee Response: " Prior to installation of a new transmitter / switch or following refurbishment of a transmitter / switch (e.g., sensor cell or variable damping components), a hydraulic response time test will be performed to determine an initial L
sensor specific response time value. If this TS change request is approved, the applicable LGS, Units 1 and 2, procedures will be revised, as appropriate, to incorporate this recommendation in conjunction with implementing the proposed TS changes.*
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The staff concurs that when these procedure changes are made, this condition will be met.
l (b)
For transmitters and switches that use capillary tubes, capillary tube testing shall be performed after initial installation and after any maintenance or modification activity that could damage the capillary tubes.
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Licensee Response: "For transmitters and switches that use capillary tubes, capillary i
tube testing shall be performed after initialinstallation and after any maintenance or modification activity that could damage the capillary tubes. For those transmitters and switches within the scope of this proposed TS change that utilize capillary tubes, capillary tube testing will be performed after installation and 4
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after any maintenance or modification activity, as appropriate "
l The staff concurs that this response meets the above condition.
4 4
4.4 Condition
The licensee must confirm the following:
4 (a)
That calibration is being done with equipment designed to provide a step function or fast ramp in the process variable, j
1.icensee Response: ' Applicable station calibration procedures will be revised, as appropriate, to include guidance to input a fast ramp or step change to system i
components during calibration. This new guidance will ensure that the response of the transmitter (s) to an input signal (i.e., fast ramp or step input change) is prompt, and in all cases occurs within less than five (5) seconds.'
l The staff concurs that when these procedure changes are made, this condition will be met.
(b)
That provisions have been made to ensure that operators and technicians, through an appropriate training program, are aware of the consequences ofinstrument response time degradation, and that applicable procedures have been reviewed and revised as necessary to assure that technicians monitor for response time
.l degradation during the performance of calibrations and functional tests, Licensee Response: "The applicable station calibration procedures will be revised, 4
as appropriate, to assure that technicians monitor for response degradation during the performance of calibrations and functional tests. Any necessary procedure revisions will be completed in conjunction with implementing the proposed TS changes."
The staff concurs that when these procedure changes are made, this condition will be met.
(c)
That surveillance testing procedures have been reviewed and revised if necessary to ensure calibrations and functional tests are being performed in a manner that allows simultaneous monitoring of both the input and output response of units under test, Licensee Response: " Surveillance tes/ng procedures will be revised, as appropriate, to ensure that calibrations and functional tests are being performed in a manner that allows simultaneous monitoring of both the input and output response of components being tested."
The staff concurs that when these procedure changes are made, this condition will be met.
.e 4
g i (d)
That for any request involving the elimination of RTT for Rosemount pressure transmitters, the licensee is in compliance with the guidelines of Supplement 1 to NRC Bulletin 90-01," Loss of Fill-Oilin Transmitters Manufactured by Rosemount."
Licensee Response: PECO Energy Company's compliance with the guidance stipulated in NRC Bulletin 90-01, Supplement 1, was reviewed by the staff as documented in a letter dated November 19,1993. The staffs evaluation of the response to NRC Bulletin 90-01, Supplement 1, concluded that PECO Energy's actions satisfied the requested actions specified in Supplement 1.
The staff concurs that this condition has been met.
(e)
That for those instruments where the manufacturer recommends periodic RTT as well as calibration to ensure correct functioning, the licensee has ensured that elimination of RTT is nevertheless acceptable for the particular application involved.
Licensee Response: PECO Energy Company reviewed the vendor recommendations for those devices for which RTT elimination is proposed and confirmed that there are no manfacturer recommendations for periodic response time testing.
The staff concurs that this condition has been met.
5.0
SUMMARY
i Based upon the above review, the staff concludes that the licensee has followed the provisions of the generic SER and plant-specific considerations for RTT elimination in accordance with NEDO-32291. Therefore, the staff concludes that the proposed LGS Units 1 & 2 TS modifications for selected instrument RTT elimination are acceptable.
6.0 STATE CONSULTATION
In accordance with the Commission's regulations, the Pennsylvania State official was notified of the proposed issuance of the amendments. The State official had no comments.
7.0 ENVIRONMENTAL CONSIDERATION
The amendments change a requirement with respect to installation or use of a facility component located within the restricted area as defined in 10 CFR Part 20. The NRC staff has determined tha the amendments involve 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 amendments involve no significant hazards consideration, and there has been no public comment on such finding (61 FR 57489). Accordir: gly, the amendments meet the eligibility criteria for categorical exclusion set forth in 10 CFR 51.22(c)(9). Pursuant to 10 CFR 51.22(b) no environmentalimpact statement or environmental assessment need be prepared in connection with the issuance of the amendments.
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8.0 CONCLUSION
l The Commission has concluded, based on the considerations discussed above, that: (1) there is
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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 comphance with the Commission's regulabons, and (3) the issuance of the amendments will not be inirnical to the common defense and secunty or to the health and safety of the public.
Principal Contnbutor: P. Looser Date: December 14, 1998 o
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