ML20247B744
| ML20247B744 | |
| Person / Time | |
|---|---|
| Issue date: | 05/06/1998 |
| From: | Boger B NRC (Affiliation Not Assigned) |
| To: | England L BWR OWNERS GROUP |
| Shared Package | |
| ML20247B617 | List: |
| References | |
| FOIA-98-173 NUDOCS 9805080260 | |
| Download: ML20247B744 (2) | |
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-t UNITED STATES I
j NUCLEAR REGULATORY COMMISSION
't WASHINGTON, D.C. 20555-0001
%...../
ATTACHMENT 1 Mr. L. A. England BWR Owners Group Chairman P.O. Box 220 St. Francisville, Louisiana 70775
Dear Mr. England:
SUBJECT:
BWR OWNERS GROUP LICENSING TOPICAL REPORT NED0-32291, " SYSTEM ANALYSES FOR ELIMINATION OF SELECTED RESPONSE TIME TESTING REQUIREMENTS," JANUARY 1994 The NRC staff has completed its review of the subject topical report submitted by the BWR Owners Group by letter dated January 14, 1994.
The encloscre provides the staff's Safety Evaluation Report.
The topical report provided information to demonstrate that selected response time testing (RTT) requirements could be eliminated by showing that changes in response time beyond acceptable limits would be detected by other means.
After review of the tcpical report, the staff has determined that:
.(a)
In general, operational history has shown that degradation of i
instrumentation response times beyond acceptable limits is being detected during the performance of calibrations and surveillance tests.
(b)
The majority of allowable instrumentation response times are much longer than instrument circuits require for signal process;ng from sensor input to final output signal.
(c)
Elimination of RTT will 1) reduce the time when safety systems are out of service or incapable of responding to a degraded plant condition,
{
- 2) reduce the potential for inadvertent essential safety function 1
actuatians, 3) reduce the. complexity of 7fuelirg outages, t d 4) reduce i
personnel radiation exposure.
l On the basis of the above, the staff concludes that RTT can be eliminated from technical specifications for the selected instrumentation identified in the topical report and accepts NE00-32291 for reference in license amendment applications with the conditions discussed below.
l When submitting plant-specific license amendment (Technical Specifications (TS) change) requests, in addition to the request as shown in Appendix I of the topical report, the TS markup tables as shown in Appendix H, and a list of effected instrument loop components as shown in Appendix C.1, licensees must CONTACT:
Paul Loeser, NRR/HICB 504-2825 1
9805000260 990506 PDR FOTA CHAPMAN 98-173 PDR
(
-L.A. England state that they are following the recommendations from EPRI Np-7243 (Ref. 4) and, therefore, are administratively requiring 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 J
damping components), a hydraulic RTT shall be performed to determine an initial sensor-specific response time value, and (b)'
For transmitters and switches that use capillary tubes, RTT shall be performed after initial installation and after any maintenance or modification activity that could damage the capillary tubes.
Licensees must also state the following.in their requests:
I
_(a)
That calibration is being done with equipment designed to provide a step function or fast ramp in the process variable, (b)
That provisions have been made to ensure that operators and technicians are aware of the consequences of instrument response tima degradation, and that applicable procedures have been reviewed and revised as necessary to assure-that technicians monitor for response time degradation during the performance of calibrations and functional tests, (c)
That surveillance testing procedures have been reviewed'and revised if necessary to ensure calibrations and functional test are being performed in a manner that allows simultaneous monitoring of both the input and output response of units under test, (d)
That for any request involving the elimination of RTT for Rosemount pressure transmitters, the licensee is in full compliance with the guidelines of Supplement I to Bulletin 90-01, " Loss of Fill-0il in Transmitters Manufactured by Rosemount," and (e)
That for the e instruments where tht nar. Facturer recommends periodic RTT as well as calib.4 tion to ensure correct function, concurrence is obtained from the manufacturer that elimination of RTT is acceptable.
Should you have any questions or wish further clarification, please call me at l
(301) 504-1003, or Paul Loeser at (301) 504-2825.
l Sincerely, Bruce A. Boger, Director Division of Reactor Controls and Human Factors Office of Nuclear Reactor Regulation
Enclosure:
As stated I