ML20236R466

Proposed Tech Specs Eliminating Periodic Response Time Testing Requirements on Selected Sensors & Selected Protected Channels

ML20236R466
Person / Time
Site:	Vogtle
Issue date:	07/13/1998
From:	SOUTHERN NUCLEAR OPERATING CO.
To:
Shared Package
ML20236R465	List: ML20236R463 ML20236R466
References
NUDOCS 9807220052
Download: ML20236R466 (20)

Text

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ENCLOSURE 3 TECHNICAL SPECIFICATION MARK-UPS i

Definitions 1.1 i

1.1 Definitions (continued)

$ - AVERAGE G shall be the average (weighted in proportion to DISINTEGRATION ENERGY the concentration of each radionuclides in the reactor coolant at the time of sampling) of the sum of the average beta and gama energies per disintegration (in Mev) for isotopes, other than )

iodines, with half lives > 14 minutes, making up  !

at least 95% of the total noniodine activity in the coolant.

1 ENGINEERED SAFETY The ESF RESPONSE TIME shall be that time l FEATURE (ESF) RESPONSE interval from when the monitored TIME 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 responsetimeismeasured.j LEAKAGE shall be:

LEAKAGE

[

f' a. Identified LEAKAGE 11 lt-ll , $ lN C O.$ V N h (

. 1. LEAKAGE, such as that from pump seals or (C 5po&C //*8 'Mdy valve packing (except reactor coolant pump g (RCP) seal water injection or leakoff), '

f NI that is captured and conducted to SC/tc/(C/(#rff[MM!I $kyctionsystemsorasumporcollecting

, rowefeh%M-Me LEAKAGE into the containment atmosphere l

gb 2.

CO MMk from sources that are both specifically

/% #N/Mg gf., located and known either not to interfere with the operation of leakage detection e g g j g A g g 8fg/f t or not to be pressure boundary

[I 3. Reactor Coolant System (RCS) LEAKAGE g g yg d through a steam generator (SG) to the Secondary System;

Me. M/2C. j (continued)

Vogtle Units 1 and 2 1.1-3 Amendment No. 96 (Unit 1)

Amendment No. 74 (Unit 2)

!' E3-1

! 9007220052 990713 -

l PDR ADOCK 05000424 P PDR .

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ENCLOSURE 3 TECHNICAL SPECIFICATION MARK-UPS l

Definitions 1.1

]

1.1 Definitions (continued)  !

l

$ - AVERAGE E shall be the average (weighted in proportion to DISINTEGRATION ENERGY the concentration of each radionuclides in the i reactor coolant at the time of sampling) of the sum of the avera e beta and amma energies per )

disintegration ( n MeV) for sotopes, other than 1 iodines, with half lives > 14 minutes, making up at least 95% of the total noniodine activity in the coolant.

1 ENGINEERED SAFETY The ESF RESPONSE TIME shall be that time FEATURE (ESF) RESPONSE interval from when the monitored TIME 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 requiredvalues,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 step}s so that the entire response time is measured.

LEAKAGE shall be:

LEAKAGE

[

Identified LEAKAGE fllltlj,ftMQ.$WWltllh)a.

f

1. LEAKAGE, such as that from pump seals or (C 5po4C //*d 'Md8/ valve packing (except reactor coolant pump g (RCP) seal water injection or leakoff),

f NI that is captured and conducted to ction systems or a sump or collecting Sf/(c/tC/C###f0fM[

PfOVicltl*lb//

M69h YC ggI- 2. LEAKAGE into the containment atmosphere COM from sources that are both specifically located and known either not to interfere

/8f #N/Mp with the operation of leakage detection ary/cd/u heh una, ;," *

• 6' ar'$'ar' 6 "ad'r' 80 3. Reactor Coolant System (RCS) LEAKAGE ggg r yg f through a steam generator (SG) to the Secondary System; Ms. A!/tC. j (continued)

Vogtle Units 1 and 2 1.1-3 Amendment No. 96 (Unit 1)

Amendment No. 74 (Unit 2)

E3-1 9907220052 990713 i_

PDR ADOCK 05000424 I P PDR g b

ENCLOSURE 3 f TECHNICAL SPECIFICATION MARK-UPS Definitions 1.1

~

,+ ~

I.1 Definitions PHYSICS TESTS a. Described in Chapter 14 of the FSAR; (continued)

b. Authorized under the provisions of 10 CFR 50.59; or

c. Otherwise approved by the Nuclear Regulatory Commission.

PRESSURE AND The PTLR is the unit specific document that TEMPERATURE LIMITS provides the reactor vessel pressure and REPORT (PTLR) temperature limits, including heatup and cooldown rates and the nominal PORV setpoints for the cold overpressure protection system, for the current reactor vessel fluence period. These pressure and temperature limits shall be determined for each fluence period in accordance with Specification 5.6.6. Unit operation within these operating limits is addressed in individual specifications.

QUADRANT POWER TILT QPTR shall be the ratio of the maximum upper RATIO (QPTR) excore detector calibrated output to the average '

of the upper excore detector calibrated outputs, )

or the ratio of the maximum lower excore detector '

calibrated output to the average of the lower excore detector calibrated outputs, whichever is {

greater.

RATED THERMAL POWER RTP shall be a total reactor core heat transfer (RTP) rate to the reactor coolant of 3565 MWt. 2 REACTOR TRIP The RTS RESPONSE TIME shall be that time interval SYSTEM (RTS) RESPONSE from when the monitored parameter TIME exceeds its RTS 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. lrt //gy o(pHgesytt.rtygry (4f Me, }/nrt. re tdf bt Vf#l0*t f l

se tclec/cserMe4isfto/'WIM H,e creponenfs adMe M cud i

prvoriTu/ ton hete be*1prwio81/

twiewen' aml 4fporto'hy Me '

(continued)

Vogtle Units 1 and 2 1.1-5 Amendment No. 96 Unit 1 Amendment No. 74 Unit 2 E3-2 '

1 L ..

k ENCLOSURE 3-TECHNICAL SPEC 1FICATION MARK-UPS Ilnsert I to page B 3.3-59 '

' Response time may be verified by actual response time tests in any series of sequential, ov'erlapping 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 time's may be obtained from: (1) historical records based on acceptable response time

. tests (hydraulic, noise, or power interrupt tests), (2) in place, onsite, or offsite (e.g. vendor) test

. measurements, or (3) utilizing vendor engineering specifications. WCAP-13632-P-A Revision 2,

~ " Elimination of Pressure Sensor Response Time Testing Requirements" provides the basis and

, methodology for using allocated sensor respons'e times in the overall verification of the channel response 1 time for specific sensors identified it.'the WCAP.. Response time verification for other sensor types must be demonstrated by test.

~ WCAP-14036-P Revision 1, " Elimination of Periodic Protection Channel Response Time Tests" provides ,

. , . the basis and methodology for using allocated signal processing and 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 in .

operational service and re-verified following maintenance that may adversely affect response time. In general, electrical repair work does not impact response time provided the parts used for repair are of 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 assembly of a .

transmitter.

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ENCLOSURE 3 TECHNICAL SPECIFICATION MARK-UPS RTS Instrumentation 5 3.3.1 BASES SURVEILLANCE SR 3.3.1.15 (continued)

REQUIREMENTS calculated assuming the time constants are set at their nominal values. The response time may be measured by a Series of overlapping tests such that the entire response f' time is measured.

t Insert i Q*"/ As appropriate, each channel's response must be verified every 18 months on a STAGGERED TEST SA515. Testing of the final actuation devices is included in the testing.

Response times cannot be determined during unit operation because equipment operation is required to measure response times. Experience has shown that these components usually pass this surveiUance when performed at the 18 month Frequency. Therefore, the Frequency was concluded to be acceptable from a reliability standpoint.

~

SR 3.3.1.15 is modified by a Note stating that neutron detectors are excluded from RTS RESPONSE TIME testing. This Note is necessary because of the difficulty in generating an appropriate detector input signal. Excluding the detectors is acceptable because the principles of detector operation ensure a virtually instantaneous response.

I SR 3.3.1.16 SR 3.3.1.16 is the performance of a COT for the low fluid oil pressure portion of the Turbine Trip Functions as described in SR 3.3.1.7 except that the Frequency is after i each entry into M)DE 3 for a unit shutdown and prior to exceeding the P-9 interlock trip setpoint. The surveillance is modified by two Notes. Note 1 states that the surveillance may be satisfied if performed within the previous 31 days. Note 2 states that verification of the setpoint is not required. The Frequency ensures that the turbine trip on low fluid oil pressure channels is OPERABLE after each unit shutdown and prior to entering the Mode of Applicability (above the P.9 power range neutron flux interlock) for this instrument function. 4 REFERENCES 1. FSAR, Chapter 7.

. l L (continued) f s 3.3-59 Revision No. O yogtle Units 1 and 2 m

i

L' ,

ENCLOSURE 3-

. . TECHNICAL SPECIFICATION MARK-UPS Insert 2 to page B 3.3-60 Y .u  ;,

10, ' WCAP-13632 P-A Revision 2,"$limination of Pressure Sensor Response Time Testing Requirements" Aug.,1995.

'11. . WCAP-14036-P Revision 1, " Elimination of Periodic Protection Channel Response Time Tests" Dec.,1995.

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ENCLOSURE 3 TECHNICAL SPECIFICATION MARK-UPS RTS Instrumentation B 3.3.1 BASES REFERENCES 2. FSAR, Chapter 6.

(continued)

3. FSAR, Chapter 15.

4. IEEE-279-1971.

5. 10 CFR 50.49.

6. WCAP-ll269, Westinghouse Setpoint Methodology for Protection Systems; as supplemented by:

Amendments 34 (Unit 1) and 14 (Unit 2), RTS Steam Generator Water Level - Low Low, ESFAS Turbine Trip and Feedwater Isolation SG Water Level - High High, and ESFAS AFW SG Water Level - Low Low.

Amendments 48 and 49 (Unit 1) and Amendments 27 and 28 (Unit 2), deletion of RTS Power Range Neutron Flux High Negative Rate Trip.

Amendments 60 (Unit 1) and 39 (Unit 2), RTS Overtemperature AT setpoint revision.

Amendments 57 (Unit 1) and 36 (Unit 2), RTS l Overtemperature and Overpower AT time constants and Overtemperature AT setpoint.

Amendments 43 and 44 (Unit 1) and 23 and 24 (Unit '

2), revised Overtemperature and Overpower AT trip setpoints and allowable values.

7. WCAP-10271-P-A, Supplement 2 Rev. 1, June 1990.

8. FSAR, Chapter,16.

9. Westinghouse Letter GP-16696, November 5, 1997. l TIWsit]7ZT+ \

U I

l Vogtle Units 1 and 2 8 3.3-60 Rev. 1-6/98 l f-Y l i

l E3-6 -

L.

ENCLOSURE 3

~

~ TECHNICAL SPECIFICATION MARK-UPS

..~

Insen 3 to page B 3.3108 s

g 73 ,

Response time may be verified by actual response time tests in any series of sequential, overlapping or i total channel measurements, or by the summat?on of allocated sensor, signal processing and actuation .

11ogic 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 Revision 2,

" Elimination of Pressure Sensor Response Time Testing Requirements" provides the basis and L 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 te'st.

i f WCAP-14036-P Revision 1, " Elimination of Periodic Protection Channel Respoase Time Tests" provides

, the basis and methodology for using allocated signal processing and actuation logic response times in the J 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 in i P Operational service and re-verified following maintenance that may adversely affect response time. In general, electrical repair work does 'not impact response time provided the parts used for repair are of the {

V i same type and value. Specific components identified in the WCAP may be replaced without verification

! testing. One example where response time could be'afrected is replacing the sensmg assembly of a -

- transmitter.

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1 ENCLOSURE 3 TECHNICAL SPECIFICATION MARK-UPS ESFAS Instrumentation B 3.3.2 BASES i SURVEILLANCE SR 3.3.2.7 (continued)

! REQUIREMENTS l The Frequency of 18 months is based on the assumption of an 1 18 month calibration interval in the determination of the i magnitude of equipment drift in the setpoint methodology.

This SR is modified by a Note stating that this test should includeverificationthatthetimeconstantsareadjustedto

the prescribed values where applicable. The steam line '

pressure-low and steam line pressure negative rate.high functions have time constants specified in their setpoints.

1 SR 3.3.2.8 l

This SR ensures t n individual channel E5F RESPONSE TIMES are less than or equal to the manieue values assumed in *the accident analysis. Response Ties testing acceptance criteria are included in the FSAR, Chapter 16 (Ref. 8).

Individual component response times are not modeled in the analyses. The analyses model the overall or total elapsed time, from the point at which the parameter exceeds the Trip l Setpoint value at the sensor, to the point at which the l equipeont in both trains reaches the required functional state (e.g., pumps at rated discharge pressure, valves in full open or closed position).

For channels that include dynamic transfer functions (e.g.,

lag, lead / lag, rate / leg, etc.), the response time test may be perfomed with the transfer functions set to one with the i

resulting esasured response time compared to the appropriate FSAR response ties. Alternately, the response time test can be perfomed with the time constants set to their nominal L value provided the required response time is analytically s

calculated assuming the time constants are set at their nominal values. The response time may be esasured by a series of overlapping tests such that the entire response l- g , ties is esasured.

) 'E5F RESPONSE TIME tests are conducted on an 18 month STAGGERED TEST SA515. Testing of the final actuation devices, which make up the bulk of the response time, is included in the testing of each channel. The final actuation device in one train is tested with each channel.

Therefore, rtaggered testing results in response time l

(continued) ,

3 3.3 10s Revision No. O i vogtle Units 1 and 2 i

l

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_ _ - _ _ _ - . . _ _ _ - _ _ - - _ ___ - _ _ - _ ____ _ _ - - _ _ _ ~ _ - - _ _ _ _

ENCLO5URE 3 -

l-g TECHNICAL SPECIFICATION MARK-UPS

( . In. sert'4 to page B 3.3-109 -

110. ' WCAP-13632 "-A Revision 2,." Elimination of Pressure Sensor j -- Response Time Testing Requirements" Aug.,1995.

.11.  : WCAP-14036-P Revision 1, " Elimination of Periodic Protection Channel Response Time Tests" Dec.,1995.

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L--.____-_-__ _ _ -

ENCLOSURE 3 TECHNICAL SPECIFICATION MARK-UPS ESFAS Instrumentation B 3.3.2 BASES REFERENCES

• Amendments 43 and 44 (Unit 1) and 23 and 24 (Unit (continued) 2), revised ESFAS Interlocks Pressurizer P-Il trip setpoint and allowable value.

7. WCAP-10271-P-A, Supplement 2, Rev. 1, June 1990.

8. FSAR, Chapter 16.

f M 9. Westinghouse Letter GP-16696, November 5, 1997. l

/IWsMTM M

I i

I 1

)

I

l. Vogtle Units 1 and 2 8 3.3-109a Rev. 1-6/98 I

I E3-10 l

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Definitions 1.1 1.1 Definitions (continued)

.E - AVERAGE weighted in proportion to

-DISINTEGRATION ENERGY . E shall'be the the average concentration of eac (h radionuclides in the reactor coolant at the time of sampling sum of the avera ies per disintegration (geforbeta in MeV andother Isotopes, samma than energ? o iodines with half live)s.> 14 minutes, making up at leask g5% of the total noniodine activity in the coolant.

ENGINEERED SAFETY The ESF RESPONSE TIME shall be that time FEATURE (ESF) RESPONSE interval from when the monitored TIME parameter exceeds its ESF actuation setpoint at the channel sensor until the ESF equipment is capable of performing its safety function (i.e. \ons, posit the valves travel topressures their required pump discharge reach their required values, etc.). Times shall include diesel delays, generator starting and where applicable. Thesequence.

response loading 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.

LEAKAGE LEAKAGE shall be:

.a. Identified LEAKAGE

1. LEAKAGE such as that from pump seals or f

valve pa,cking (except reactor coolant pump (RCP that)is captured and conducted toseal water injection o collection systems or a sump or collecting _

tank;

2. LEAKAGE into the containment atmosphere l- from sources that are both specifically located and known either not to interfere

with the operation of leakage detection systems or not to be pressure boundary LEAKAGE; or I 3.

Reactor LEAKAGE through aCoolant System (RCS)G) steam generator (S to the Secondary System; (continued)

Vogtle Units 1 and 2 1.1-3 Amendment No. (Unit 1)

Amendment No. (Unit 2) 1.

l

i, Definitions 1.1 1.1 Definitions l PHYSICS TESTS a. Described in Chapter 14 of the FSAR; '

l.

' (continued)

b. Authorized under the provisions of I 10 CFR 50.5g; or

c. Otherwise approved by the Nuclear Regulatory Commission.

PRESSURE AND. The PTLR is the unit specific document that TEMPERATURE LIMITS provides the reactor vessel pressure and .

REPORT (PTLR) temperature limits,. including heatup and cooldown rates and the nominal PORV setpoints for the cold overpressure protection system, for the current reactor vessel fluence period. These pressure and temperature limits shall be determined for each fluence period in accordance with Specification 5.6.6. Unit operation within these-operating limits is addressed in individual specifications.

QUADRANT POWER TILT QPTR shall be the ratio of the maximum upper RATIO (QPTR) excore detector calibrated output to the average of the upper excore detector calibrated outputs, or the ratio of the maximum lower excore detector calibrated output to the average'of the lower excore detector calibrated outputs, whichever is greater.

RATED THERMAL ~ POWER RTP shall be a total reactor core heat transfer (RTP) rate to the reactor coolant of 3565 MWt.

REACTOR TRIP The RTS RESPONSE TIME shall be that time interval SYSTEM (RTS) RESPONSE from when the monitored parameter exceeds its RTS trip setpoint at the channel

~

TIME i 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 l measured. In lieu of measurement, response time I may be verified for selected components provided that the components and the methodology for verification have been previously reviewed and )

approved by the NRC.

I i

(continued) o Vogtle Units 1'and 2 1.1-5 Amendment No. (Unit 1)

Amendment No. (Unit 2)

l I

RTS Instrumentation B 3.3.1 BASES SURVEILLANCE SR 3.3.1.15 (continued)

REQUIREMENTS calculated assuming the time constants are set at their nominal values. The response time may be measured by a series of overlapping tests such that the entire response <

time is measured.'

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 resp 6nse times may be obtained from:

(1) historical records based on acceptable response time tests (hydraulic, noise, or power interrupt tests),.(2) in-place, onsite,'or offsite (e.g., vendor) test measurements, or (3) utilizing vendor engineering specifications. WCAP-13632-P-A Revision 2, " Elimination of Pressure Sensor Respor.se 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 Revision 1, " Elimination of Periodic Protection Channel Response Time Tests," provides the basis and method 61ogy for using allocated signal processing and actuation logic response times in the overall verification of the protection sy. stem channel response time. The allocations for sensor, signal conditioning and actuation logic response times must be verified prior to placing the component in operational service and re-verified following maintenance that may adversely affect response time. In general, electrical repair work does not impact response time provided the parts used for repair are of 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 assembly of a transmitter.

I As appropriate, each channel's response must be verified l every 18 months on.a STAGGERED TEST BASIS. Testing of the

l. final actuation devices is included in the testing.

l Response times cannot be determined during unit operation because equipment operation is required to measure response (continued)

Vogtle Units 1 ~and 2 B 3.3-59 Revision No.

W-__--_ . - _ _ _ . - . - _ _ - _ . _ . - _ _ _ - _ _ _ - . _ _ _ . -.

RTS Instrumentation B 3.3.1 BASES SURVEILLANCE }]L 3.3.1.15 (continued)

REQUIREMENTS times. Experience has shown that these components usually pass this surveillance when performed at the 18 month Frequency. Therefore, the Frequency was concluded to be acceptable from a_ reliability standpoint.

SR 3.3.1.15 is utdified by a Note stating that neutron detectors are excluded from RTS RESPONSE TIME testing. This Note is necessary because of the difficulty in generating an appropriate detector input signal. Excluding the detectors is acceptable because the principles of detector operation ensure a virtually instantaneous response.

SR 3.3.1.16 SR 3.3.1.16 is the performance of a COT for the low fluid oil pressure portion of the Turbine Trip Functions as described in SR 3.3.1.7 except that the Frequency is after each entry into MODE 3 for a unit shutdown and prior to exceeding the P-9 interlock trip setpoint. The surveillance is modified by two Notes. Note I states that the surveillance may be satisfied if performed within the previous 31 days. Note 2 states that verification of the setpoint is not required. The Frequency ensures that the turbine trip on low fluid oil pressure channels is OPERABLE after each unit shutdown and prior to entering the Mode of Applicability (above the P-9 power range neutron flux interlock) for this instrument function, i

REFERENCES 1. FSAR, Chapter 7.

I (continued)

Vogtle Units 1 and 2 B 3.3-59a Revision No.

RTS Instrumentation 8 3.3.1 BASES i

THIS PAGE INTENTIONALLY LEFT BLANK.

(continued) j -Vogtle Units 1.and 2 B 3.3-59b Revision No.

l

u

= RTS Instrumentation B 3.3.1 i BASES REFERENCES (continued) 2. FSAR, Chapter 6.

3. FSAR, Chapter 15.

4. IEEE-279-1971.

5. 10 CFR 50.49.

6. WCAP-ll269, Westinghouse Setpoint Methodology for Protection' Systems; as supplemented by:

r

• Amendments 34 (Unit 1) and 14 (Unit 2), RTS Steam Generator Water Level - Low Low, ESFAS Turbine Trip and Feedwater Isolation SG Water Level - High High, and ESFAS AFW SG Water Level - Low Low.

5

• Amendments 48 and 49 (Unit 1) and Amendments 27 and 28 (Unit 2), deletion of RTS Power Range Neutron Flux High Negative Rate Trip.

Amendments 60 (Unit 1) and 39 (Unit 2), RTS Overtemperature AT setpoint revision.

Amendments.57 (Unit 1) and 36 (Unit 2), RTS Overtemperature and Overpower AT time constants and Overtemperature AT setpoint.

Amendments 43 and 44 (Unit 1) and 23 and 24 (Unit 2), revised Overtemperature and Overpower AT trip setpoints and allowable values.

7. WCAP-10271-P-A, Supplement 2, Rev. 1, June 1990.

8. FSAR, Chapter 16.

9. Westinghouse Letter GP-16696, November 5, 1997.

10 WCAP-13632-P-A Revision 2, " Elimination of Pressure Sensor Response Time Testing Requirements," August 1995.

11. WCAP-14036-P Revision 1, "Eliminati a of Periodic Protection Channel Response Time Tests," December 1995.

Vogtle Units 1 and 2 B 3.3-60 Revision No.

ESFAS Instrumentation B 3.3.2 BASES SURVEILLANCE SR 3.3.2.7 (continued)

REQUIREMENTS The Frequency of 18 months is based on the assumption of an 18 month calibration interval in the determination of the magnitude of equipment drift.in the setpoint methodology.

.This SR is modified by a Note stating that this test should

, include verification that the time constants are adjusted to ')

i the prescribed values where applicable. The steam line l pressure-low and steam line pressure negative rate-high functions have time constants specified in their setpoints. ]

SR 3.3.2.8 This SR ensures the individual channel ESF RESPONSE TIMES are less than or equal to the maximum values assumed in the accident analysis. Response Time. testing. acceptance criteria are included in the FSAR, Chapter 16 (Ref. 8).

Individual component response times-are not modeled in the analyses. The analyses model the overall or total elapsed time, from the point at which the parameter exceeds the Trip Setpoint value at the sensor, to the point at which the equipment in both trains reaches the required functional state (e.g., pumps at rated discharge pressure, valves in full open or closed position).

For channels that include dynamic transfer functions (e.g.,

lag, lead / lag, rate / lag, etc.), the response time test may i be. performed with the transfer functions set to one with the  !

~r resulting measured response time compared to the appropriate  !

FSAR response time. Alternately, the response time test can '

be performed with the time constants set to their nominal value provided the required response time is analytically  ;

calculated assuming the time constants are set at their i nominal values. The response time may be measured by a series of overlapping tests such that the~ entire response  :

time is measured. l Response time may be verified by actual response time tests i 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 frcm:

(continued)

.Vogtle Units I and 2 B 3.3-108 Revision No.

i J

ESFAS Instruscntation B 3.3.2 BASES SURVEILLANCE- SR 3.3.2.8 (continued)

REQUIREMENTS (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. EAP-13632-P-A Revision 2, " Elimination of Pressure Sensor Response. Time Testing Requirements,"

provides'the basis and methodology for using allocated

• ensor response times in the overall verification of the channel response time for specific sensors identified in the EAP. Response time verification for other sensor types must be demonstrated by test.

E AP-14036-P Revision 1, " Elimination of Periodic Protection Channel Response Time Tests," provides the basis and methodology for using allocated signal processing and ,

actuation logic respeise 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 in operational. service and re-verified following maintenance'that may adversely affect response time. In general, electrical repair work does not impact response time provided the parts _used for repair are of the same type and value. Specific components identified in the EAP may be replaced without verification testing. One example where response time could be affected is replacing the sensing assembly of a transmitter. ,

ESF RESPONSE TIME tests are conducted on an 18 month STAGGERED TEST BASIS. Testing of the final actuation devices, which make up the bulk of the response time, is included in the testing of each channel. The final actuation device in one train is tested with each channel.

Therefore, staggered testing results in response time i

(continued)

Vogtle Units 1 and 2 B 3.3-108a Revision No.

L I

l l 3

ESFAS Instrumentatica B 3.3.2 BASES THIS PAGE INTENTIONALLY LEFT BLANK.

4 Vogtle Units 1 and 2 8 3.3-108b Revision No.

(

j

ESFAS Instrumentation B 3.3.2 BASES REFERENCES' (continued)

• Amendments 43 and 44 (Unit 1) and 23 and 24 (Unit ,

2), revised ESFAS Interlocks Pressurizer P-11 trip setpoint and allowable value.

7. WCAP-10271-P-A, Supplement 2, Rev. 1, June 1990.

I

8. FSAR, Chapter 16~. I

9. Westinghouse Letter GP-16696, November 5, 1997.

10. WCAP-13632-P-A Revision 2, " Elimination of Pressure Sensor Respon.a Time Testing Requirements," August 1995.

11. WCAP-14036-P Revision 1, " Elimination of Periodic Protection Channel Response Time Tests," December 1995.

-Vogtle Units 1 and 2 8 3.3-109a Revision No.

T-

. ENCLOSURE 4

. OWNER'S GROUP LETTERS i

l 0 0 98-005 WCAP 14036-P, Rev.1 l WCAP 14037 NP, Rev.1

, January 22,1998

?

Document Control Desk l U S. Nucient Regulatory Conmussion j- W-A aa. DC 20555 0001

, 1 Attenuoa: Cluef, Informance Management Branch, f

Division ofInspecues and Support Programe

Subject:

Wesunshouse Owners Group Tr " ' of n - - m WCAP-lMMP. Rev.1 (f.-rbw) and WCAP-1403't,NP.

Rev.1 (N= "reme==,L F - '"F" - " of Par 2 i Fr --r-2 = Ch -

l * --- ---- Timan Testa" (MUMP WM

' This letter transtruts fiResa (15) copies of the report WCAP-14036-P, Rev. ! (Propnetary) and twelve (12)

' copies of the report WCAP 14037-NP, Rev.1 (Non-Propnetary), all enutled "Elinunanon of Penodic Protecuoe Channel Response Tune Tests", dated January 5,1996.

Also anached are:

1. One (1) copy of the Applicence of Withholding Propnetary Informanon from Public Disclosure, CAW-981198 (Non-propnetary).

2. One (1) copy of Affidavit CAW 98 1198 (Non-propnetary).

3. One (1) copy of the Copynght NoSos.

4. One (1) copy of the Propnetary Informanon Nouce This report (WCAP 14036 P, Rev.1) primdes the Wesunghouse Owners Group (WOG) technical documentauon and methodology to support the eliminanon of penodic response ume tesung for the electronic signal pocess ng porcon of the reactor prosecues circuitry. The WOG is subnutting this licensing topical report. WC AP 14036-P, Rev. I, under the NRC licensing topical report program for review and acceptance for referencing in licensing i i

accons. The objective is that once approved, each WOG rnember may reference this report in implemenung tNse tesung rei===aa== for their plant. The Wesunghouse Owners Group lead plant for first unplementauon is So sthern Nuclear Operanas Company's Vogtle plant. The anucipated Vogtle plant License AW- Request (l.AR) subnuttal is scheduled for February 28,1998. The WOG requests your support in reviewmg this report and is idenuffsng an SER need date of January 31,1999.

I I

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ENCLOSURE 4 OWNER'S GROUP LF/ITERS Page 2 OG-95 005 January 22.1998 As tlus report, WCAP 14036-P Rev.1, contams mformanca propnetary to Westmghouse Electne Corporanon. it l is bems transrmited mth af5 davits signed by Westmshouse, the owner of the mformanon. ne affidavits set forth the basis on wiuch the aformanon be mthheld from public disclosure by the Comrmssion and addresses with specificity the consideranons listed in paragraph (b)(4) of Secnon 2.790 of the Commission's regulations.

Accordagly, at is respecovely requested that the aformanon wiuch is propnetary be mthheld from public disclosure m accordance mth 10CFR Seenos 2.790 of the Comnussion's regulanons.

Correspondence with respect to the propnetary aspect of the Applica.1ons for Withholding or the supportmg Westmshouse afEdavits should reference CAW-93 il93 as appropnase and should be addressed to Mr. H.A. Sepp, Manager Regulatory and Licensms Engmeenng, Wesunghouse Electnc Corporanon, P.O. Box 355, Pmsburgh, PA 15230-0355.

Invoices associated with the review of this WCAP should be addressed to:

Mr. Andrew P. Drake, Project Manager Westmshouse Owners Group Weennshouse Electne Corporance (Mad Stop ECE 516)

P.O. Box 355 Pittsburgh, PA 15230-0355 Very truly yours, T.V. Greene, Chairman Westmghouse Owners Group

. JDC/TVG/

attachments / enclosures cc: WOG Steenns Committee (IL)

WOG Primary Representanves (IL)

WOG Licensms Subcommaaes Representanves (IL)

T.H. Clonager Houston Lighong & Power (IL)

J. Badey, TVA(IL)

Claudia Craig, USNRC (IL)

M.M. DeWitt, E ECE 5-43 (IL)

N.J. Lipendo. E, ECE 4-15 (IL)

A.P. Draks, E - ECE 5 16 (1L)

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ENCLOSURE 4 OWNER'S GROUP LETTERS OG 98-005 Janua.y 22,1998 bec: D1. Antolonch ECE 4 07A (IL, IA)

H A. Sepp ECE 4 07A (IL, IA)

E.A. Drams ECE 4 01 (IL)

J D. Andracbek ECE 447A(IL)

C E. Morgan ECE 4-07A (IL, IA)

G R. Andre' ECE 4 28 (IL)

S B. Fowler ECE 4-22 (IL)

R.B. Miller - ECE 4-07A (IL; 5 A. Binger ECE 516(IL)

K.J. Vavrek ECE 5-16 (IL)

S R. Bemas ECE 516 (IL)

J D. Campbsil ECE 5-16 (IL,l A)

S M. DiTommaso ECE 516 (IL)

P A. Chaboy ECE 4-15 (ll, I A)

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I ENCLOSURE 4 OWNER'S GROUP LETTERS L

1 0

Westinghouse Energy Systems noss l Elettnc Corporation "sw 'wim 'm: nu DATE 01/22/98 CAW.98-il93 Document Control Desk U.S. Nuclear Regulatory Commission Washin8 ton, DC 20555 Attention: Mr. Samuel J. Collins APPLICATION FOR WTTHHOLDINO PROPRIETARY INFORMATION FROM PUBLIC DISCLOSURE

Subject:

WCAP 14036-P Revision I, " Elimination of Periodic Protection Channel Response Time Tests.*

Dear Mr. Collins:

ne proprietary information for which withholding is being requested in the above-referenced report is further identitled in Amdavis CAW-981193 signed by the owner of the proprietary information, Westinghouse Electric Corporation. The affidavit, which accompanies this letter, 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 10 CFR Section 2.790 of the Commission's regulations.

Accordingly, this letter authorizes the uttllration of the accompanying Amdavit by Southern Nuclear Operating Company (SNC).

Correspondence with respect to the proprietary aspects of the application for withholding or the Westinghouse affidavit should reference this leaar, CAW-95-1198, and should be addressed to the undersigned.

Very truly yours.

N.J.Li lo, Manager Equipment Design and Regulatory Engineering Enclosures cc: Kevin Bohrer/NRC (12H5) i l

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ENCLOSURE 4 OWNER'S GROUP LETTERS CAW 98119s AFFIDAVir COMMONWEALTH OF PENNSYLVANIA:

ss COUNTY OF ALLEGHENY:

Before me, the undersigned authority, personally appeared Henry A. Sepp, who, being by me duly sworn according to law, deposes and says that he is authorized to execute this Affidavit on behalf of Westinghouse Electnc Corporation (" Westinghouse") and that the averraents of fact set forttiin this Affidavit are true and correct to the best of his knowledge, informanon, and belief:

sA Henry A.bSepp, .5[adger Regulatory and Licensing Engineering Sworn to and subsenbed befo thisf#AL day o _ >> M .1993

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ENCLOSURE 4 e

OWNER'S GROUP LETTERS

-f g 2- CAW 931193 l'

(1) I am Manager, Regulasory and Licensing Engineering, in the Nuclear Service Division, of the Westinghouse Electric Corporation and as such, I have been spec Acally delegated the function of reviewing the proprietary informanon sought to be withheld from public disclosure in connection with nucteer power plant licensing and rulemaking proceedings, and am authorized to apply for its withholding on behalf of the Westinghouse Energy Systems Business Unit.

(2) I am making this AfAdavit in conformance with the provisions of 10CFR Section 2.790 of the

, Commission's regulations and in conjunction wis the Westinghouse application for witholding a: companying &is Affidavit.

(3) I have personal knowledge of the critona and procedures unlised by the Westinghouse Energy Systems Business Unit in designanns informanos as a trade secret, privileged or as conndential comunercial or financial laibraanoa.

(4) Pursuant to the provisions of paragraph (b)(4) of Section 2.790 of the Comminion's regulations, the following is Airmshed for consideranon by the Commussion in determinmg whether the information sought to be withheld from public disclosure should be withheld.

(i) The infonnanoa sought to be withheld from public disclosure is owned and has been held in conndence by W==FM I

(ii) The informance is of a type customarily held in coandence by Wesunghouse and not customardy disclosed to the public. Watinghouse has a rational basis for determuung the types of informanon customarily held in confidence by it and, in that connection, utilizes a system to deterame when and whoser to hold certain types of informanon in coandence. The application of &at system and the substance of that system constitutes Westinghouse policy and provides the rational basis required.

Under sa system, informanon is held in confidence if it falls in one or more of

' several types, the release of which might result in the loss of an existing or potential competitive advantage, as follows:

(a) The informanos reveals the distinguishing aspects of a process (or component, structure, tool, method, etc.) where prevention of its use by any of Westinghouse's compeuters without license from Westinghouse constitutes a compeutive economac advantage over other compames.

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L_

p ENCLOSURE 4 OWNER'S GROUP LETTERS l

l

• I*

CAW-93 !!93 i

(b) It consists of supporting data, including test data, reluive to a process (or componeet, structure, tal, method, etc.), the application of which data secures a competitive economic advantage, e.g., by opt i mimme or improved marketability.

(c) Its use by a competitor would reduce his expendiaire of resources or improve his competitive position in the design, manufacture, shipment, installation, assurance of quality, or licensing a similar product.

(d) It reveals cost or price informanoa. production capacities, budget levels, or commercial strategies of Westinghouse, its customers or suppliers.

(e) It reveals aspecu of past, present, or thaare Westinghouse or customer ihnded development plans and programs of poteorial commercial value to Westinghouse.

(f) It contains pasentable ideas, for which passet protection may be desirable.

There are sound policy reasons behind the Westinghouse system which include the following:

(a) De use of such informanon by Westinghouse gives Westaghouse a competitive advantage over its competitors. It is, therefore, withheld from disclosure to protect the Westinghouse compeuuve position.

(b) It is informanon which is marketable in many ways. De extent to which such information is available to competitors dimininhan the Westinghouse ability to soil products and services involving the use of the informanon.

(c) Use by our competitor would put Westinghouse at a competitive disadvantage by reducing his expenditure of resources at our expense.

(d) Each component of proprietary informanon pertinent to a particular compeutive advantage is potentially as valuable as the total competitive advantage If competitors acquire components of proprietary information, any one componeet may be the key to the entire puzzle, thereby depriving W =Y c of a competitive advantage.

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l

ENCLOSURE 4 OWNER'S GROUP LETTERS 1: <

^>

+

CAW.981193 1

(e)

Unrestricted disclosure would jeopardize the position of protnianaca of 1 Westinghouse in the world rnarket, and thereby give a market advantage to the compeution of those countries.

(f) no Westinghouse capacity to ir set corporate assets in research and development depends upon the success in obtauung and rn=2ntmiams a compeutive advantage

\

(iii) ne informance is being transaused to the Comaussion is confidence and, under the provisions of 10CFR Section 2.790, it is to be received is confWoce by the. -

Commission.

l (iv) The informauon sought to be protected is not available is public sources or available informanos has not been previously employed la the same original manner or method to the best of our knowledge and belief.

1 (v) ne proprietary informanoa sought to be withheld in this subminal is that which is appropriamly marked la *Eliannation of Penodic Protocuon Channel Response Time Tests, WOG Program MUMP.3041 Revision l', WCAF.14036 Revision 1 (Proprietary), January 5,1996. . His informanon is being transmined by the I Westinghouse Owoors Group (WOG) leaar and Applicados for Withholding Proprietary informanos from Public Disclosure, to the Document Control Desk.

Assoonoa Samuel J. Collins. The proprietary information as submined for use by SNC for the Vogde Generating Units I and 2 is expected to be applicable in other licenses submittals in response to certata NRC requirements for jusufication of the elirrunation of response time testing (R1T) requirements.

His informanon is part of that which will enable Westinghouse to:

(a) Provide documentation in support of methods for the eliminauon of protection channel response time testing requirements.

(b) Provide the applicable engineering evaluation and/or failure modes and effects i

analysis which establishes jusuficanos for RTT elinunanos of protecnoa j chassel response tune teenas. l l

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ENCLOSURE 4 OWNER'S GROUP LETTERS

$- CAW-95-il93 (c) Provide a methodology for substituting response times in lieu of values obtamed from RTT for each protection channel.

Further this informanon has substantial commercial value as follows:

(a) Westinghouse plans to soil the use of similar informanon to its customers for purposes of the elinunanon of response time testing (RTT) requirements.

(b) Westinghouse can sell support and defenas of the methodology in the licensing process.

Public disclosure of this proprietary informanon is likely to cause substantial harm to the compositive position of Westinghouse because it would enhance the abdity of competitors to provide similar a=ulogies and licensing defense services foiF commercial power reactors without commensurais expenses. Also, public disclosure of the informauon would enable others to use the informanon to meet NRC requirements for licensing documentation without purchasing the right to use the informanon.

The development of the technology described in part by the informanon is the result of applying the results of many years of experience in an intensive Westinghouse effort

, and the expenditure of a considerable sum of money, l

In order for compeutors of Westinghouse to duplicate this information, similar tachaical programs would have to be performed and a sigmficant manpower effort, having the requisite talent and experience, would have to be expended for developing the methodology.

l l

Further the deponent sayeth not.

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ENCLOSURE 4 i OWNER'S GROUP LETTERS 1

i Proprietary informanon Notice i

Transnuned herewith are proprietary and/or non-proprietary versions of documents furnished to the l j

NRC in connection with requets for genenc and/or plant-specinc review and approval.

In order to conform to the requirements of 10 CFR 2.790 of the Commission's regulations concerning the protection of proprietary information so subautted to the NRC, the information which is )

proprimary in the proprietary versions is contained within brackets, and wbwe the proprietary information has been deleted in the non-proprietary versions, only the brackets remain (the informanon that was contamed within the brackets in the proprietary versions having been deleted). The jusuncation for claiming the informanon se designated as proprietary is indicated in both versions by means of lower case leuers (a) through (f) contamed within parentheses located as a superscript .-

immediately following the brackets seclosing each item of information being identined as proprietary or in the margin opposite such informassoa. These lower case laaers refer to the types of information Westinghouse customarily holds in conndence idenuned in Sections (4)(li)(a) through (4)(ii)(f) of the affidavit accompanying this transmittal pursuant to 10 CFR 2.790(b)(1).

l l

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ENCLOSURE 4 OWNER'S GROUP LETTERS Copyright Notice The reports transmitted berewith each bear a Westinghouse copyright notice. Die NRC is permitted to make the number of copies of the informanon contaaned in these reports which are necessary for its internal use in connection with generic and plant-specinc reviews and approvals as well as the issuance, denial, amendment, transfer, renewal, modincmion, suspension. revocation, or violation of a license, pernut, order, or regulation subject to the requirenmots of 10 CFR 2.790 regarding restnctions on public disclosure to the extent such informanon has been identined as proprietary by Westinghouse, copyright protection not withstanding. With respect to the non$ropnetary versions of these reports, the NRC is permined to make the number of copies beyond those necessary for its internal use which are necessasy in order to have one copy available for public viewing in de appropriate docks files in the public document room in Washington, DC and in local public document rooms as may be regired by NRC regulations if the number of copies submitted is insufRcient for this purpose. The NRC is not authorized to make copies for the personal use of ==% of the public who make use of the NRC public document rooms. Copies made by the NRC must include the copyright notice in all instances and the proprietary notice if the original was ideconed as proprietary.

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ENCLOSURE 4 OWNER'S GROUP LETTERS  ;

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0 l l

1 Westfrigflouse Erierg Systems se ass Electnc Corporation "snewswa mmm OG 96417 February 27,1996 WCAP 13632 P A WCAP 13787 NP A  !

Project Number 694 Document Contml Desk U.S. Nuclear Regulacry Coman==me Washingios, DC 20555-0001 Attention: Chief. Planning, Program and management Support Branch Subject Westinghouse Owners Group Trumsmittal of Romertar WCAP 13632-P A IPnerietani Anoroved and WCAP-13787 A IM= 5;." ;;rvi Amented Entitled *EHand=neta= of Prvssure Senser Ressomas Time Testian Reamirements' This letter transmita tweety three (23) copies of the report WCAP 13632 P A (Pmprietary] Approved and twelve (12) copies of WCAP 13787 A (Non Proprietary, Approved all entitled 'E!!mination of Pressure Sensor Response Time Testing Requiremsats', dated Jaanary ,1996.

Reforence: CAW 95 466, dated 8/2/95.

De above reference transmitted the following documents to Document Control Desk.

1. One (1) copy of the Application of Withholdlag Proprietary Information from Public Disclosure, CAW 95-866 (Non-proprietary),

2. Ot.e (1) copy of AfBdsvit CAW 95 866 (Non-proprietary).

3. One (1) copy of the Copyright Notica.

4 One (1) copy of the Pmpnetary Information Notice.

This leser transmits the approved versions of the proprietary and non-proprietary WCAPs in accordance with the procedures established ja NUREG 0390. Previous versions of these reports were transmmed to the NRC by Southers Nuclear Operating Company letter of 81195, as part of the liccase amendment l request for the Farley Nuclear Plaat, one of the Westinghouse Owners Group lead plants for response time

test elimiaauos. De NRC SER approving the WCAP states that WCAP 13632 may be referenced in I

ticense ====dment applications for all Westiaghoues pressunzed water reactors.

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ENCLOSURE 4 OWNER'S GROUP LETTERS Page 2 00 96417 February 27,1996 l

i As WCAF 13632 P A metains information proprietary to Westinghomas Esctric Corporation controlled with affidavits tranammed previossly and signed by Westinghouse, the owner of the {

information. The affidavits set forth the basis ne which tLe informataos be withheld from public {

disclosure by the cCo==iamag and addresses with specificity the consadorations listed is paragr

' of Secupe 2.790 of the h=a==aa's regulations. WJagly,it la respectfully requessed that the infonestaos which is propnetary be withheld fmm public disclooms is accordance with 10CFR Section 2.790 of the Commissica's regulations.

Correspondence with respect to the peoppstary aspect of the Applications for Withholding or the suppornag Westinghouse affidsvis should referemos CAW-95-466 as appropnate and should be addressed to Mr NJ. Lipasulo, Manger, Nacient Safety Reguissory and I. mensing Activities, Westinghouse Dectne Corporsuoe, P.O. Bos 355, Pinsburgh, PA 15230 0355.

Very truly yoers,

_ J Licensing haa==sen==

Westinghouse Owners Groep LWJDC#s attachments /esciosures cc: Westinghoens Owners Geosp Steenag Commines (1L)

Westinghouse Owners Osoap Prunary Representatives (1L)

! Weedaghouse Owners Gg Liceassag Subcommittee Reptseestatives (1L)

NJ. Uparola, E(IL) l KJ, Voytail, X (1L) i-i i E4-13

ENCLOSURE 5 VOGTLE RESPONSES TO NRC BULLETINS 90-01 AND 90-01 SUPPLEMENT 1 c.o.a . po ce,m At sa C 8 wo- .o. 5,8 ms q -o 03 o v' eo o iSs***#

1 "' M ; ; G I N "*'

July 17, 1990 s DEL Near Owavs ELV-01884 0479

./50-424

~DocketsNg[150-425 ,

U. S. Nuclear Regulatory Commission' ATTN: Document Control Desk Washington, D.C. 20555 V0GTLE ELECTRIC GENERATING PLANT - UNITS 1 AND 2 NRC BULLETIN 90-01, LOSS OF FILL-0!L IN TRANSMITTERS MANUFACTURED BY ROSEMOUNT Gentlemen:

NRC Bulletin 90-01, " Loss of Fill-Oli in Transmitters Manufactured by Rosemount," was issued on March 9, 1990, to all holders of operating licenses or construction permits. The bulletin requires licensees to take actions to ensure that Model 1153 Series B, Model 1153 Series D, and Model 1154 transmitters manufactured by Rosemount that may be leaking fill-oil are in compliance with 10 CFR 50. Appendix A General Design Criteria 21, and 10 CFR 50.55a(h).

Specifically, the bulletin requires actions to ensure continued, safe and reliable operation of reactor protection or engineered safety features actuation systems by implementing requested actions necessary to ensure the operational integrity of the input sensors.

Licensees are required to provide a response within 120 days after receipt of

'the bulletin that:

A. ~

Co'nfirms that the requested actions for Operating Reactors (items 1-5 of the bulletin) have been completed.

B. Identifies the indicated manufacturer, the model number, the system the transmitter was utilized in, the approximate amount of time at pressure, the corrective actions taken, and the disposition of Rosemount transmitters that are believed to have exhibited symptoms indicative of loss of fill-oil or have been confirmed to have experienced a loss of fill-oil.

C. Identifies the system in which the Model 1153 Eeries B, Model 1153 Series D, and Model 1154 transmitters from the manufacturing lots that have been identified by Rosemount as having a high failure fraction due to loss of fill-oil are utilized and provides a schedule for replacement of these transmitters which are in use in the reactor protection or engineered safety features actuation systems.

ES-1 I

ENCLOSURE 5 VOGTLE RESPONSES TO NRC BULLETINS 90-01 AND 90-01 SUPPLEMENT 1 Georgia Power d .

U. S. Nuclear Regulatory Comission ELV-01884 Page 2

~

In response, Georgia Power Company (GPC) has implemented actions to meet the intent of items 1 - 5 of the bulletin. The attached enclosure provides a discussion of each of the requested actions along with GPC's response. An enhanced surveillance program will be implemented as described in the enclosure; however, should more effective methods become available in the future, the progra,e may be revised accordingly. The,information requested above in B and C, is algprovided in the enclosure.

?

Mr. W G. Hairston, !!!, states he is Senior Vice President of Georgia Power m' Company and is authorized to execute this oath on behalf of Georgia Power Company, and to the best of his knowledge and belief, the facts set forth in this letter are true.

GEORGIA POWER COMPANY by: /2.[ m W. G. Hairston, 111 , , . ..

Sworn to and subscribed before me this l'/kay of .4,[:,1990. ,

l J ,

to n ,du.."/7.M hotary Pgblic s..... ,'. ~ (7.5 !** FV WGH,11!/AFS/gm '

Enclosures:

1. VEGP Requested Act106s

2. Transmitters Confirmed or Believed to Have Exhibited Loss of Fill-Oli xc: Georeia Power Comoany Mr. C. K. McCoy Mr. G. Bockhold, Jr.

Mr. R. M. Odom Mr. P. D. Rushton NORMS L LS. Nuclear Reculatory Comission Mr. B. R. Bonser, Senior Resident inspector, Vogtle Mr. S. D. Ebneter, Regional Administrator i

Mr. T. A. Reed, Licensing Project Manager, NRR j

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ENCLOSURE 5 VOGTLE RESPONSES TO NRC BULLETINS 90-01 AND 90-01 SUPPLEMENT 1 ENCLOSURE 1 V0GTLE ELECTRIC GENERATING PLANT - UNITS 1 AND 2 NRC BULLETIN 90-01 LOSS OF FILL-0IL IN TRANSMITTERS MANUFACTURED BY ROSEMOUNT REQUESTED ACTIONS

1. Beketinitem1: NRC Recuested Action Identify Model 1153 Series B,1153 Series D, and Model 1154 pressure or ~',;-

differential pressure transmitters, excluding Model 1153 Series 8, 1153 ,

Series D, and Model 1154 transmitters manufactured by Rosemount subsequent to July 11, 1989, that are currently utilized in either safety-related systems or systems installed in accordance with 10 CFR 50.62 (the ATWS rule).

GPC Resoonse:

GPC has identified the Model 1153 Series B,1153 Series D, and Model 1154 pressure or differential pressure transmitters manufactured by Rosemount that are currently used in either safety-related systems or systems install o in accordance with 10 CFR 50.62. Fifty-six of the subject transmitters are currently utilized on Unit I and 56 are currently utilized on Unit 2.

2. Bulletin Item 2- NRC Recuested Action Determine whether any transmitters identified in item 1 are from the manufacturing lots that have been identified by Rosemount as having a high failure fraction due to loss of fill-oil. Addressees are requested not to utilize transmitters from the suspect lots in the reactor protection or engineered safety features actuation systems; therefore, addressees are requested to develop and implement a program to replace, at the earliest appropriate opportunity, transmitters from these suspect lots in use in the reactor protection or engineered safety features actuation bystems.

GPC Resoonse:

GPC identified one transmitter at Vogtle Electric Generating Plant (VEGP) within the scope of Item 1 that was from the mamafacturing lots identified by Rosemount as having a high failure fraction due to loss of fill-oil. The transmitter was utilized in a Unit I engineered safety features actuation system, the ESF Chilled Water System, in accordance with the guidelines estabitshed by NRCB 90-01, the transmitter was replaced via maintenance work order 19001650 with a Model 1153 Series B transmitter manufactured subsequent to July 11, 1989.

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! -ENCLOSURES l '

VOGTLE RESPONSES TO -

, t NRC BULLETINS 90-01 AND 90-01 SUPPLEMENT 1 y

L ENCLOSURE 1 (CONTINUED)

V0GTLE ELECTRIC GENERATING PLANT - UNITS 1 AND 2

• NRC BULLETIN 90-01, LOSS OF FILL-OlL IN TRANSMITTERS MANUFACTURED BY ROSEMOUNT s.

REQUESTED ACTIONS

3. Bulletin item 3? NRC Reaussted Action m

Rev'tew plant. records (for example, the three most recent calibration '

records) associated with the transmitters' identified in item 1 above to determine whether any of these transmitters may have already exhibited symptoms' indicative of loss of fill-oil. Appropriate operability acceptance criteria should be developed and applied to transmitters identified as having exhibited symptoms indicative of loss of fill-oil from this plant record review. Transmitters identified as having exhibited symptoms indicative of-loss of fill-oil that do not conform to the operability acceptance criteria should De addressed in accordance with the applicable technical specification. Transmitters identified as having exhibited symptoms indicative of loss of fill-oil that do not conform to the operability acceptance criteria and are not addressed in the technical

[ specifications should be replaced at the earliest appropriate opportunity.

GPC Resnonse; Vogtle Electric Generating Plant Unit I completed its second refueling outage in April, 1990. Our data bank of calibration information does not contain enough information which can be trended to produce meaningful

.results. A review of our available data has not indicated that any of the .

. instruments installed have exhibited any symptoms indicative of loss of fill-oil..

Vogtle Electric Generating Plant Unit 2 is preparing for its first refueling l 2 outoge in September of this year (1990). Our data bank of calibration information does not contain enough information which can be trended to preduce meaningful results. A r'eview of our available data indicates that 2PT6161, an instrument utilized in the Electrohydraulic Controls (EHC) .

System to monitor EHC system hydraulic pressure, trended downward during its first period of service, an anomaly in the conservative direction. The data, obtained from the calibration of this instrument during the upcoming Unit 2 refueling outage, will be trended against the previous data to i determine if the instrument has experienced a downward shift as a result of I loss of fill-oil.

, In addition to the review of plant records for the transmitters identified l ' in Item 1, a review of past work history for Rosemount 1153 hries B, !!53 Series D, and Model 1154 transmitters that had been udlized in either

, -safety-related systems or systems installed in accordance with 10 CFR 50.62

'. (the ATWS rule), and had been replaced, was performed. This review determined that in August 1987. GPC replaced two Rosemount 1153DBSPA transmitters which were suspected of loss of fill-oil, ci.,

fu ES-4 F

- _m._.E-__.di____.__._-__ m-. _ , _ _ . _ _ . _ . _ _ . _ _ _ _ _ _ _

ENCLOSURE 5

. VOGTLE RESPONSES TO NRC BULLETINS 90-01 AND 90-01 SUPPLEMENT 1 I

ENCLOSURE (CONTINUED)

V0GTLE ELECTRIC GENERATING PLANT - UNITS 1 AND 2 NRC BULLETIN 90-01, LOSS OF FILL-0!L IN .

TRANSMITTERS MANUFACTURED BY ROSEMOUNT REQUESTED ACTIONS Transmitters confirmed or believed to have exhibited loss of fill-oil are

- igttfied in Enclosure 2.

4. Bull'etin item 4? NRC Recustted Action Develop and implement an enhanced' surveillance program to monitor transmitters identified in item 1 for' symptoms of loss of fill-oil. This enhanced surveillance program should consider the following or equally effective actions: ,

A. Ensuring appropriate licensee personnel are aware of the symptoms that a transmitter, both during operation and during calibration activities, l may exhibit if it is experiencing a loss of fill-oil and the need for l prompt identification of transmitters that may exhibit these symptoms. ]

~

B. Enhanced transmitter monitoring to' identify sustained transmitter drift.

C. Review of transmitter performance following planned or unplanned plant '

4

- transients or tests to identify sluggish transmitter response.

D. Enhanced awareness of sluggish transmitter response to either indressing or decreasing test pressures during calibration activities.

L E. Development and implementation of a program to detect changes in process noise. . 'l F. Development and application to transmitters identified as having exhibited symptoms indicative of loss of fill-oil of an appropriate operability acceptance criteria. Transmitters identified as having exhibited symptoms indicative of loss of fill-oil that do not conform to i the operability acceptance criteria should be addressed in accordance '

)

with the applicable technical specification. Transmitters identified as j having exhibited symptoms indicative of loss of fill-oil that do not ~j

' conform to the operability acceptance criteria and are not addressed in the technical specifications should be replaced at the earliest appropriate opportunity.

GPC Retoonte:

GPC has reviewed.the existing program that monitors the operability and ensures the reliability of Rosemount transmitters. GPC is modifying the existing program to improve the cognizance of plant personnel to the

- symptoms which the transmitters may exhibit as an indication that they may El-3 s

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ENCLOSURE 5 -

'VOGTLE RESPONSES TO-NRC BULLETINS 90-01 AND 90-01 SUPPLEMENT 1 I

4 ENCLOSURE 1 (CONTINUED)

V0GTLE ELECTRIC GENERATING PLANT - UNITS 1 AND 2 NRC BULLETIN 90-01. LOSS OF FILL-OlL IN .

TRANSMITTERS MANUFACTURED BY ROSEMOUNT REQUESTED ACTIONS be experiencing a loss of fill-oil. The improvements to the program are based, as much as practical, on the diagnostic measures provided in Rofginount Technical Bulletin No. 4 and include the following:

A. Provided additional training for instrument and controls' technicians on-' ;w in

September 25, 1989. This training was implemented in order to provide assurance that appropriate personnel had been made aware of the symptoms that a transmitter may exhibit during operation and calibration a activities if it is experiencing a loss of fill-oil.

C. A review of the 56 transmitters installed in engineered safety features actuation systems, each for Unit I and 2. has been completed. Enhanced monitoring has not been established for transmitters experiencing normal system pressure less than or equal to 250 psig. Exclusion is justified since, according to Rosemount, the time period involved in fill-oil loss "at pressures less than or equal to 250 psig is extended to the extent that normal scheduled calibration activities are sufficient to identify 6: symptoms indicative of fill-oll loss before the reliability of the . .

instrument is compromised. This exclusion involves 38 transmitters each

.for Unit I and 2. .

Eleven of the transmitters identified in item 1 are installed in each Unit 1 and 2 Auxiliary Feedwater system. These transmitters are usually

. in standby and are subjected to the normal system pressure of 1200 to 1600 psig for only a few hours during monthly and quarterly system operation surveillance and solid state protection system slave relay surveillance. Therefore, these transmitters are excluded from enhanced monitoring since the review of the normally scheduled calibration data will be suffletent to identify a loss of fill-oil before the reliability ~

of any of the instruments is compromised. ~ .f ,

1 Three instruments identified in item 1 are utilized in each Unit I and 2 reactor protection system. The instruments are part of the

' electrohydraulic controls (EHC) system and are subjected to a normal operating pressure of 1600 psig while the unit is on line. These

' instruments monitor hydraulic pressure at the main turbine control

' valves, and upon a " fast close control valve" solenoid actuation provide

!;? a signal to the reactor protection system that the turbine has tripped.

C toss of fill-oil in these transmitters would cause e failure in the l , conservative direction providing a trip signal to the reactor protection

, system. Two failures out of these three transmitters would trip the l reactor. A single failure would produce a turbine trip alarm which M -could be investigated while the. system remained operable. While the unit is on line, the instruments are subjected to a constant pressure.

Therefore, each instrument can be checked against the other two El-4

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r ENCLOSURE 5 VOGTLE RESPONSES TO NRC HULLETINS 90-01 AND 90-01 SUPPLEMENT 1 l

1 ENCLOSURE 1 (CONTINUED)  !

l V0GTLE ELECTRIC GENERATING PLANT - UNITS 1 AND 2 - l NRC BULLETIN 90-01, LOSS OF FILL-Oll IN '

TRANSMITTERS MANUFACTURED BY ROSEMOUNT REQUESTED ACTIONS i

periodically to verify that the instrument reading remains constant. l

's GPC has determined that the most prudent action to take with respect to these instruments is to monitor readings quarterly until such time as i the instruments can be replaced.

+

l The remaining 8 transmitters identified in part 1 (4 per Unit) monitor I steam pressure of the steam generators and are subjected to a normal I system operating pressure of $85 psig. Readings will be recorded for )

these transmitters, to be compared with readings from comparison i transmitters. The readings will be taken, as a minimum, at monthly I intervals and trended. ,

Monitoring may be adjusted in the future based on a review of the

• j results. This monitoring will continue until such time as the I transmitters can be replaced by transmitters manufactured subsequent to l July 11, 1989.

The comparison checks and/or trending results will serve as the initial .

acceptance criteria to determine the need for further assessment.  !

Calibration of the transmitter and the associated calibration acceptance  !

criteria will provide determination of the transmitter's capability to l perform its safety function.

Transmitters identified as having exhibited-symptoms indicative of loss  !

of fill-oil that do not conform to operability acceptance criteria will be addressed in accordance with the applicable unit's Technical Specifications. Transmitters identified as having exhibited symptoms indicative of loss of fill-oil that do not conform to operability acceptance criteria and are not addressed in the Technical Specifications will be replaced at the earliest convenient opportunity.  !

C. One hundred and eight VEGP calibration procedures for 1153 Series B pressure and differential pressure transmitters will be revised so that the program ensures that the symptoms indicative of loss of fill-oil will be identified during the performance of the calibration process.

These changes include the following:

o Confirmation that the transmitter performance does not exhibit sluggish response (i.e., output does not lag input changes).

o Confirmation that as-found data does not reflect a sustained zero or span shift.

El-5 E5-7

q ENCLOSURE 5 l VOGTLE RESPONSES TO l- NRC BULLETINS 90-01 AND 90-01 SUPPLEMENT 1 i-ENCLOSURE I (CONTINUED) t V0GTLE ELECTRIC GENERATING PLANT - UNITS 1 AND 2 )

NRC BULLETIN 90-01, LOSS OF FILL-0!L IN .

TRANSMITTERS MANUFACTURED BY ROSEMOUNT REQUESTED ACTIONS

)

i o Confirmation that as-found data does not indicate an inability to o erate over the entire calibration range.

5. Bulletin item St NRC Recuested Action Documentandmaintaininaccordancewithexistingplantproceduresabis't for continued plant operation covering the time period from the present until such time that the Model 1153 Series 8,1153 Series D, and Model 1154 transmitters from the manufacturing lots that have been identified by Rosemount as having a high failure fraction due to loss of fill-oil in use in the reactor protection or engineered safety features actuation Lystems, can be replaced. In addition, while performing the actions requested above, I addressees may identify transmitters exhibiting symptoms indicative of loss of fill-oil that do not conform to the established operability acceptance criteria and are not addressed in the technical specifications. As these transmitters are identified, this basis for continued plant operation should 3 be updated to address these transmitters covering the time period from .the time these transmitters are identified until such time that these .

transmitters can be replaced. When developing and updating this basis for continued plant operation, addressees may wish to consider transmitter diversity and redundancy, diverse trip functions (a separate trip function that may also provide a corresponding trip signal), special system and/or component tests, or (if necessary) immediate replacement of certain suspect transmitters.

GPC Resconse; As stated in the response to Bulletin item 2, GPC identified one transmitter installed at VEGP that was from one of the manufacturing lots identified by Rosemount as having a high failure fraction due to loss of fill-oil. The transmitter, serial number 412885, was installed in VEGP Unit l's ESF Chilled Water System under Master Parts List (MPL) identification number ITDC4193. The transmitter was replaced upon determination that it came from a suspect lot; therefore, the development of a basis for continued operation is not applicable.

For those transmitters that are identified as exhibiting symptoms indicative of a loss of fill-oil that do not conform to operability acceptance criteria

'and are not addressed in the technical specifications, a basis for continued operation will be developed if the transmitters cannot be immediately  !

replaced. '

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ENCLOSURE 5 l VOGTLE RESPONSES TO NRC BULLETINS 90-01 AND 90-01 SUPPLEMENT 1

' Uw= amens ce==  %

,- peu once so. tres 1 206 122 v".s D .wuoen M A

vesse p= pes l wesowenancreesem February 26, 1993

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. ELV-05225 003019

- Docket Mos. 50 424 Npf $.a .

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U. S. Nuclear Regulatory Commission ATTN: Document Control Desk & ~

Washington, D. C. 20555

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V0GTLE ELECTRIC GENERATING PLANT ...-

NRC SULLETIN 90 01, SUPPLEMENT 1

)

LOSS OF FILL-0!L IN TRANSMITTERS - + i; . +

MANUFACTURED BY ROSEMOUNT Gentlemen: __- '.,. w. py N?5hp d

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NRC Sulletin 90-01, Supplement 1, " Loss of F111-011 in Transmitters Manufactured.

by Rosemount," was issued on December 22, 1992, to all holders of operating .<,

licenses or construction permits for nuclear power reactors. Supplement 1 ',

the bulletin updates the infomation provided in the original bulletin and;,to; ' ,"*

requests that licensees take actions to resolve the loss of fill-oil issue ~for Rosemount transmitters manufactured prior to July 11, 1989. The requested i- actions described in the supplement supersede the actions requested in the ~

original bulletin, issued on March 9, 1990. Within 60 days after receipt of the supplement licensees are required to provide a response that includes the

. following: '

~

1. A statement whether the licensee will take the actions requested,

2. With regard to the requested actions that the license's is taking: ~ -p'-et

a. A list of the spec'ific actions that the licensee will complete to meet Item 1 of Requested Actions for Operating Reactors provided in this '*c.

supplement, including justifications as appropriate. G.

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!- b. The schedule for completing licensee actions to meet Item 1 of Requested Actions provided in this supplement. '4W

c. When completed, a statement confiming that Items 1 and 2 of Requested Actions for Operating Reactors provided in this supplement have been completed.

l- 3. A statement identifying those actions requested by the NRC that the licensee is not taking and an evaluation which provides the bases for not taking the requested actions. .

E5-10

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ENCLOSURES VOGTLE RESPONSES TO NRC BULLETINS 90-01 AND 90-01 SUPPLEMENT I GeorgiaPowerd U. S. Nuclear Regulatory Commission Page 2 In response to NRC Bulletin 90-01, Supplement 1. Georgia Power Company (GPC) will implement actions to meet the intent of Item 2. The enclosure provides a

d. - 'ssion of each of the NRC requested actions, along with GPC's response. The inicemation and schedule requested by reporting requirements 2a and 2b are a*so provided in the enclosure as part of the GPC response to each ites. Y 51, Mr. C. K. McCoy states he is Vice President of Georgia Power Company a..Lefe .. nd is %  ;-

authorized to execute this cath on behalf of Georgia Power Company, and to the best of his knowledge and belief, the facts set forth in this letter are true. -~

$1ncerely,

Q.E/M K. McCoy % '*

Sworn to a subscribed before me , r. .

this Mday of 6eh1%993. ' , ,

g ,g), g g E

. Notary Public .. ,

Commission Expires: " # "

CKK/DLB/geb ~

Enclosure -

xc: Georoia Power Company -

Mr. W. 8. Shipman, General Manager

• Mr. M. Sheibant, Plant Engineer Supervisor pp NORMS "'

.a:

U. S.' Nuclear Reculatory Co wissio'n.'Washinoton. D. C. *

• ?

Mr. D. S. Hood, Licensing Project Manager, MRR .-

"~

U. S. Nuclear Reculatory Commission. Recion 11

~

Mr. S. D. Ebneter, Regional Administrator Mr. B. R. Bonser, Senior Resident Inspector, Vogtle aV-05225 003019 I

E5-11

ENCLOSURES VOGTLE RESPONSES TO NRC BULLETINS 90-01 AND 90-01 SUPPLEMENT 1 ENCLOSURE V0GTLE ELECTRIC GENERATING PLANT NRC BULLETIN 90-01, SUPPLEMENT 1 LOSS OF FILL-OlL IN TRANSMITTERS jjgUFACTURED "lY ROSEMOUNT REQUESTED ACTIONS

1. Sunnlement 1. Itemt '1 and la.

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. . ..a .e ,.

..c. o. > hm......--s. 4. mdw.w ,-o M @ Ik%,.. ,y

. Review plint records and identify any Rosemount Model 1153 Series B, Model i.

7153 Series D, and Model 1154 transmitters manufactured before July 11, 1909, that are used or may be used in the future in alther safety related systems or systems installed in accordance with 10 CFR 50.62 (the ATWS rule), and

.. w~

a. Expeditiously replace, or monitor for the life of the transmitter on a monthly basis using an enhanced surveillance monitoring program, any

• transmitters that have a normal operatteg pressure greater than 1500 pst .:.

and that are installed in reactor protection trip systems. ESF actuattoas or ATWS systems. Action for those transmitters that have not met the ,m Rosemount psi month threshold criterion should be expedited. At their~ Y ,#~

discretion, licensees may monitor using an enhanced surveillance program at least once every refueling cycle, but not exceeding 24 months,. %% m transmitters in this category if the appropriate psi-month threshold .c , l criterion recommended by Rosemount has been reached, and the monitoring T interval its is justified specific based upon safety function. Thetransmitter performance justification in service should show that a and^f *. jr sufficiently high level of reliability for the function is provided by the redundancy or diversity of applicable instrumentation and control systems, commensurate with the importance of the function, when considered in conjunction with the overall performance of she reactor protection trip system, ESF actuation system, or ATWS system. Provide to the NRC a copy of the licensee justification to extend the enhanced surveillance program beyond the monthly test interval for transmitters that have reached the appropriat psi-month threshold criterion recommended, by Rosemoun .g,g Georeia Power Comeany Reteense .ZI

s. ...~c . . . .

. .;e w fVW::::

Vogtle Electric Generating Plant (VEGP) utilizes six transmitters, three -

per unit, that have a normal operating pressure greater than 1500 pst and -, , ,

are installed in reactor protection trip systems, engineered safety -

features (ESF) actuation systems, or anticipated transient without scraa (ATWS) systems. These transmitters have 'oesn replaced with Rosemount '-

transmitters manufactured after July 11, 1989, or that have been refurbished in response to the loss of fill-oil issue.

t l

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l

ENCLOSURES VOGTLE RESPONSES TO

- NRC BULLETINS 90-01 AND 90-01 SUPPLEMENT 1 ENCLOSURE (CONTINUED)

V0GTLE ELECTRIC GENERATING PLANT NRC BULLETIN 90 01. SUPPLEMENT 1 LOSS OF FILL-CIL IN TRANSMITTERS MANUFACTURED BY ROSEMOUNT REQUESTED ACTIONS

2. taaalement 1. Item lb Replace, or monitor for the life of the transmitter on a quarterly basis using an enhanced surveillance monitoring program, any transmitters that have a normal operating pressure greater than 1500 pst and that are used in safety related applications but are not installed in reactor protection trip syO.eas. ESF actuation systems, or ATWS systems. At their discretion, licensees may sonitor using an enhanced surveillance program at least once every refueling cycle, but not exceeding 24 months, transmitters in this category if the appropriate psi month threshold criterion recommended by

.Rosemount has been reached, and the monitoring interval is justified based upon transmitter performance in service and its specific function. Provide to the NRC a copy of the licensee justification to extend the enhanc?d surveillance program beyond the quarterly test interval for transmitte.s that have reached the appropriate psi-month threshold criterion recoonended by Rosemount.

Geornia Power Connany Resnonse Transmitters with a normal operating pressure greater than 1500 psi that are used in safety-related applications but are not installed in reactor protection trip systems. ESF actuation systems, or ATWS systems are not

, utilized at VEGP.

3. suaalement 1. Item it Replace, or monitor at least once every refueling cycle, but not exceeding 24 months, using an enhanced surveillance program untti the transmitter reaches the appropriate psi-month threshold criterion recommended by Rosemount, any transmitters that have a normal operating pressure greater than 500 pst and 1ess than or caual to 1500 ost and are installed in reactor protection trip systems, ESF actuation systems, or ATWS systems.

peornia Power Connany Resoonse VEGP utilizes 22 of these transmitters,11 per unit, in the auxiliary feedwater system. The normal operating pressure for these transmitters varies from 1200 psi to 1500 psi. These transmitters are usually in i

E5-13 i:  %

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ENCLOSURE 5 VOGTLE RESPONSES TO NRC BULLETINS 90-01 AND 90-01 SUPPLEMENT 1 1

ENCLOSURE (CONTINUED)

V0GTLE ELECTRIC GENERATING PLANT NRC BULLETIN 90-01 SUPPLENENT 1 LOSS OF FILL-0!L IN TRANSMITTERS MANUFACTURED BY ROSEMOUNT REQUESTED ACTIONS standby and are subjected to their normal operating pressure when the unit is in modes 2, 3, or 4 and for only a few additional hours during monthly and quarterly system operation surveillance and solid state protection system slave relay surveillance. One transmitter in each unit has already bee replacad with a transmitter manufactured or refurbished after July 11, 1989.

Eighteen of these transmitters, nine for each unit, are calibrated tu accordance with an 18 month calibration schedule; the other four, two for each unit, are calibrated in accordance with a 24-month calibration schedule.

The calibration data for these transmitters, excluding the two that have been replaced, are thea trended in accordance with our enhanced surveillance program to ensure that any transmitter exhibiting symptoms indicative of a loss of fill cil is promptly identified and addressed.

4. Kunnlement 1. Item Id.

Replace or monitor at least once every refueling outage, using an enhanced survalliance monitoring program untti the transmitter reaches the appropriate psi month threshold criterion recommended by Rosemount, any transmitters used in safety related systems that have a normal operating pressure greater'than 500 psi and lesn than or equal to 1500 psi, and that are not installed in reactor protection trip systems, ESF actuation systems, or ATWS systems. '

Georcia power Cnanany Resnonze f

Vogtle Electric Generating Plant utilizes eight transmitters, four for each '

unit, in the main steam system for the atmospheric relief valves. Four of the transmitters have been replaced with Rosemount transmitters that were manufactured or refurbished after July 11, 1989. The other four transmitters' are scheduled for replacement dJring 1993. Untti they can De replaced,~an enhanced surveillance is performed monthly on the transmitters. The pressure reading of the subject transmitter is compared to other trannitters, not of This the same make and model, that are monitoring the same process fluid.

comparison ensures that any transmitter exhibiting symptoms indicative of s loss of fill oil will be promptly identified and addressed.

3-h ES-14 l )

I l

l-ENCLOSURE 5 VOGTLE RESPONSES TO i'

NRC BULLETINS 90-01 AND 90-01 SUPPLEMENT 1 ~

4 ENCLOSURE (CONTINUED)

V0GTLE ELECTRIC GENERATING PLANT NRC BULLETIN 90-01, SUPPLEMENT 1 LOSS OF FILL-07L IN TRANSMITTERS MANtlFACTURED BY ROSEMDUNT REQUESTED ACTIONS

5. Sunnlement 1. Item le.

At licensee discretion, exclude from the enhanced surveillance prograd a transmitters that have a normal operating pressure greater than 500 psi and less than or equal to 1500 psi that have reached the appropriate psi-month threshold criterion recommended by Rosemount (60,000 psi-months or 130,000 psi months depending on the range code of the transmitter). A high degree of confidence should be maintained for detecting failure of these transmitters caused by a loss of fill-oil and a high degree of reliability should be maintained for the function consistent with its safety significance.

Geornia Power tomaany Resonnte Vogtle Electric Generating Plant has no transmitters which have reached'the appropriate psi month thrsshold criterion recommended by Rosemount.

6. Sunnlement 1. Item 1f.

At Itcensee discretion, exclude from the enhanced surveillance program any transmitters that have a normal operating pressure less than or equal to 500 e

psi. A high degree of confidence should be maintained for detecting failure of these transmitters caused by a loss of fill oil and a high degree of reliability should be maintained for the function consistent with its safety significance.

Genrain Power enanany Resannte Vogtle Electric Generating Plant will exclub from the enhanced surveillance program any transmitters that have a normal operating pressure less than or equal to 500 psi.

7. tunnlanwnt 1. Item 2.

Evaluate the enhanced surveillance monitoring program to ensure that the program provides measurement data with an accuracy range consistent with that needed for comparison with manufacturer drift criteria for determining degradation caused by a loss of fill-oil.

-4

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1 ENCLOSUPI5 VOGTLE RESPONSES TO NRC BULLETINS 90-01 AND 90-01 SUPPLEMENT 1 ENCLOSURE (CONTINUED)

V0GTLE ELECTRIC GENERATING PLANT NRC BULLETIN 90 01 SUPPLEMENT I LDSS OF FILL-0!L IN TRANSMITTERS MANUFACTURED BY ROSEM00W REQUESTED ACTIONS CPc R m qnF1 ~~

W f In establishing the enhanced surveillance monitoring program GPC ensured that the program provided measurement data with an accuracy r,ange consistent l with that needed for comparison with manufacturer drift criteria for {

i determining degradation caused by a loss of fill-oil. This was achieved by using the manufacturer's drift data criteria and evaluating each transmitter on an individual basis. This ensures that transmitters exhibiting symptoms indicative of loss of fill cil are promptly identified and any transmitter exhibiting loss of fill-oil is addressed before the operability of the instrument is challenged. -

)

E516 l

)

l

ENCLOSURE 5 VOGTLE RESPONSES TO NRC HULLETINS 90-01 AND 90-01 SUPPLEMENT 1

{

i o.a o w ca,u,,

Pos o" Bo 25 B e g sm Alaoama.i'201

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GeorgiaPower Q'g,"*j "*" CORRECTED COPY ,,,, ,un ,n m,,c ,a,,,n July 11, 1994 LCV. 0331 $

Docket Nos. 50-424 50-425 TAC Nos. 85457 85458 U. S. Nuclear Regulatory Commission ATTN: Document Control Desk .

Washington, D. C. 20555 VOGTLE ELECTRIC GENERATING PLANT STATUS OF ACTION IN RESPONSE TO NRC BULLETIN 90-01, SUPPLEMENT 1 ,

LOSS OF FILL-OIL IN TRANSMITTERS MANUFACTURED BY ROSEMOUNT {

Ladies and Gentlemen:

NRC Bulletin 90-01, Supplement 1, " Loss of Fill-Oil in transmitted Manufactured by Rosemount", was issued on December 22,1992, to all holders of operating licenses or construction permits for nuclear power reactors. Supplement I to the bulletin updated the information provided in the original bulletin and requested that licensees take actions to resolve the loss of fill-oil issue for Rosemount transmitters marnifactured prior to July 11, 1989. On February 26,1993, Georgia Power Company issued letter ELV-05225 advising the NRC of the actions that were being taken in response to the actions required in NRC Bulletin 90-01, Supplement 1.

The purpose of this letter is so provide confirmation that the actions to which Georgia Power Company (GPC) committed in the associated Bulletin response lettar dated February 26,1993, are complete for Vogtle Electric Generating Plant. This letter also provides clarification concerning the method utilized for maintaining a high degree of 3

confidence for both detecting failure of these transmitters caused by a loss of fill-oil and I for maintaining a high degree of reliability for the continued functioning of the instrument consistent with its safety significance.

! i I

E5-17 i I  !

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j

L ENCLOSURE 5 VOGTLE RESPONSES TO NRC BULLETINS 90-01 AND 90-01 SUPPLEMENT 1 l

" : Power s'.

U. S. Nuclear Regulatory Commission Page 2 of 3 Geogpa Power Company stated in letter number ELV-05223 dated February 26,1993, that any transmitters used in safety-related systems and that have a normal operating pressure greater than 500 psi and less than or equal to 15N psi, and not installed in l

reactor protection trip systems, or ATWS would be replaced. During 1993, the remaining installed transmitters which met this criteria, (utilized in the main steam system for the atmospheric relief valves), were replaced.

In accordance with the provisions of the subject Supplement to NRC Bulletin 90-01, item IF, Georgia Power Company excluded from the enhanced surveillance program those transmitters that have a normal operating pressure less than or equal to 500 psi.

Vogtle Electric Generating Plant maintains a high degree of confidence for detecting a transmitter failure due to a loss of fill oil and for maintaining continued transmitter safety significance function reliability. This level of confidence is provided through periodic transmitter calibration every 18-24 months and also by the addition of a transmitter performance checklist, utilized during these calibrations, which addresses the action to be taken if a sluggish response is encountered.

Should a sluggish transmitter response be noted, the transmitter is considered suspect for fill-oilloss. The appropriate engineering support personnel would be contacted for assistance. Previous calibration data can be trended to determine if the transmitter is exhibiting a zero shift consistent with a loss of fill-oil. Other dit.;,nostic testing, such as bench testing the instrument, can also be performed. If an engineering evaluation determines that the transmitter is experiencing symptoms indicative of a loss of fill-oil, the proper corrective action such as replacement, refurbishment, or a bench test would be required to assure continued transmitter operability.

Please contact this office ifyou have any questions.

Sincerely, f($19" C. K McCoy CKM/AFS/DLB xc: (Distribution next page)

LCV-0331 ES-18

ENCLOSURE 5 VOGTLE RESPONSES TO NRC BULLETINS 90-01 AND 90-01 SUPPLEMENT 1 Georgia Power A U. S. Nuclear Regulatory Commission Page 3 of 3 xc: Geornia Power comoany Mr. J. B. Beasley, Jr.

Mr. M. Sheibani NORMS U. S. Nort==r R->I= tory Co... . n:aii Mr. S. D. Ebneter, Regional Admmistrator Mr. D. S. Hood, Licensing Project Manager, NRR Mr. B. R. Bonner, Senior Reddent inspector l

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