ML20249A353
| ML20249A353 | |
| Person / Time | |
|---|---|
| Site: | Beaver Valley |
| Issue date: | 06/11/1998 |
| From: | Brinkman D NRC (Affiliation Not Assigned) |
| To: | Cross J DUQUESNE LIGHT CO. |
| References | |
| TAC-MA1774, TAC-MA1775, NUDOCS 9806160343 | |
| Download: ML20249A353 (5) | |
Text
- _ _ _ _ _ - - - _ _ _ _
O-t 7g g
i UNITED STATES i
}
NUCLEAR REGULATORY COMMISSION t
WASHINGTON, D.C. 20066-0001
%..... /
June 11, 1998 Mr. J. E. Cross President-Generation Group Duquesne Light Company Post Office Box 4 Shippingport, PA 15077
SUBJECT:
RESPONSE TO REQUEST FOR INTERPRETATION OF TECHNICAL SPECIFICATION REQUIREMENTS FOR CHANNEL CALIBRATION OF RESISTANCE TEMPERATURE DETECTORS (RTDs) AND THERMOCOUPLE, BEAVER VALLEY POWER STATION, UNIT NOS.1 AND 2 (TAC NOS. MA1774 AND MA1775)
Dear Mr. Cross:
By letter dated May 13,1998, the Duquesne Light Company (DLC) requested the Nuclear Regulatory Commission's (NRC) Office of Nuclear Reactor Regulation to provide a written interpretation in accordance with the provisions of NRC Information Notice 97-80, " Licensee
. Technical Specification Interpretations," of Beaver Valley Power Station, Unit No.1 and No. 2 (BVPS-1 and BVPS-2) technical specification (TS) requirements applicable to the channel calibration surveillance requirements ofinstrument channels containing RTDs and thermocouple, in response to DLC's request, the NRC staff has evaluated the BVPS-1 and BVPS-2 TSs and has prepared the following TS interpretation.
The NRC staff notes that DLC's letter references the improved Standard Technical Specifications (STS) of NUREG-1431 as supporting their proposed interpretation of the current Technical Specifications (CTS) definition of a channel calibration. The current BVPS-1 and BVPS-2 TS channel calibration definition is as follows:
"A CHANNEL CALIBRATION shall be the adjustment, as necessary, of the channel so I
that it responds within the required range and accuracy to known values of the parameter which the channel monitors. The CHANNEL CALIBRATION shall encompass the entire l
channel, includino the sensor (emphasis added) and alarm and/or trip functions, and shall 9
include the CHANNEL FUNCTIONAL TEST. The CHANNEL CALIBRATION may be performed by any series of sequential, overlapping or total channel steps such that the entire channelis calibrated."
DLC's position is that it appears that the CTS were not intended to require a calibration of RTD or thermocouple sensors. Rather, calibration ofinstrument channels with RTD or thermocouple sensors may consist of an in place qualitative assessment of sensor behavior and normal calibration of the remaining adjustable devices in the channel. This position is based on
)
language added to the improved STS channel calibration definition noted in boldfaced type below conceming the complete definition.
l
..g 9806160343 990611 PDR ADOCK 05000334 p m 3 m.
!" W.
L i g* A L A WNe w?$. VVhrMe P
PDR l
,;Lr' l
l L_---__---------------------------
i, J. Cross "A CHANNEL CALIBRATION shall be the adjustment, as necessary, of the channel so that it responds within the required range and accuracy to known input. The CHANNEL j
CALIBRATION shall encompass the entire channel, including the required sensor, alarm, interlock, display, and trip functions. Calibration of instrument channels with resistance temperature detector (RTD) or thermocouple sensors may consist of an in-place qualitative assessment of sensor behavior and normal calibration of the remaining adjustable devices in the channel. Whenever a sensing element is replaced, the next required CHANNEL CALIBRATION shall include an in-place cross calibration that compares the other sensing elements with the recently installed sensing element. The CHANNEL CALIBRATION may be performed by means of any series of sequential, overlapping calibrations or total channel steps so that the entire channel is calibrated."
Further, based cn a favorable reply, DLC intends to apply the improved STS interpretation to BVPS-1 and BVPS-2 TSs that address RTDs and thermocouple.
Differences between TS requirements for channel calibrations based on CTS definitions and testing based on improved STS definitions are acknowledged in exist. However, when a surveillance test is done to comply with the current license then testing requirements are explicitly defined by CTS, including any related TS defined terms. Therefore, the NRC staff interpretation of BVPS-1 and BVPS-2 channel calibration TS requirements is that the CTS require testing to include RTD or thermocouple sensors in the instrument channel and failure to test all components results in failure to comply with CTS requirements.
The NRC staff cautions licensees that conversion of pl.;rit-specific TS to improved STS both involves the addition of test requirements and TS limits and the relaxation of tests and the elimination of limits not required to meet the provisions of 10 CFR 50.36(c)(2)(ii). As can be seen from the improved STS definition for a channel calibration, a relaxation of sensor calibration is allowed unless RTD or thermocouple scnsors are replaced. For these operations, in-place qualitative assessment of sensor behavior is not sufficient and the improved STS definition requires in-place cross calibration that compares the other sensing elaments with the recently installed element. This element of the definition was omitted from the DLC discussion of improved STS requirements. NUREG-0800, Rev. 4, June 1997, Branch Technical Position HICB 13," Guidance on Cross-Calibration of Protection System Resistance Temperature Detectors", provides detailed guidance on RTD cross calibration procedures. Further, adoption of improved STS surveihance requirements (SR) for RTDs and thermocouple includes additional testing requirements specified in the SR notes such as verifying rate lag compensation for flow from the core to the RTDs.
The staff reminds licensees that the Commis sion continues to place the highest priority on requests for complete conversions to the improved STS. Licensees using license amendments to adopt portions of the improved STS to existing technical specifications should adopt all related requirements, as applicable, to achieve a high degree of standardization and consistency.
l 4
J. Cross Please contact me at (301) 415-1409 if you have any further questions regarding this issue.
Sincerely,
/s/
Donald S. Brinkman, Senior Project Manager Project Directorate 1-2 Division of Reactor Projects - 1/11 Office of Nuclear Reactor Regulation Docket Nos. 50-334/50-412 cc: See next page DISTRIBUTION Docket File PUBLIC PDI-2 Reading JZwolinski I
RCapra DBrinkman MO'Brien
{
WBeckner i
CSchulten l
JWermiel JMauck OGC ACRS MEvans, RGN-l OFFICE PDI-2/PM / //
PDI-2/W HICB/BC PDl-2/D NAME DBrinkman:
MO'S Memo dated RCapra W DATE 4 //a /98 L////98 06/05/98 6 11/98
/
UFFICIAL RECORD COPY -
l DOCUMENT NAME: BV1774. GEN l
i i
c' --
J. Cross Please contact me at (301) 415-1409 if you have any further questions regarding this issue.
Sincerely, W). $
L==-
Donald S. Brinkman, Senior Project Manager Project Directorate 1-2 Division of Reactor Projects - 1/11 Office of Nuclear Reactor Regulation Docket Nos. 50-334/50-412 cc: See next page t
e J. E. Cross Beaver Valley Power Station, Units 1 & 2 Duquesne Light Company cc:
Jay E. Silberg, Esquire Bureau of Radiation Protection Shaw, Pittman, Potts & Trowbridge Pennsylvania Department of 2300 N Street, NW.
Environmental Resources Washington, DC 20037 ATTN: Michael P. Murphy Post Office Box 2063 Director-Safety and Licensing Harrisburg, PA 17120 Department (BV-A)
Duquesne Light Company Mayor of the Borrough of Beaver Valley Power Station Shippingport PO Box 4 Post Office Box 3 Shippingport, PA 15077 Shippingport, PA 15077
' commissioner Roy M. Smith Regional Administrator, Region i vVest Virginia Department of Labor U.S. Nuclear Regulatory Commission Building 3, Room 319 475 Allendale Road Capitol Complex King of Prussia, PA 19406 Charleston, WVA 25305 Resident inspector Director, Utilities Department U.S. Nuclear Regulatory Commission Public Utilities Commission Post Office Box 298 180 East Broad Street Shippingport, PA 15077 Columbus, OH 43266-0573 Director, Pennsylvania Emergency Duquesne Light Company Management Agency Beaver Valley Power Station Post Office Box 3321 PO Box 4 Harrisburg, PA 17105-3321 Shippingport, PA 15077 ATTN: S. C. Jain, Vice President Ohio EPA-DERR Nuclear Services (BV-A)
ATTN: Zack A. Clayton Post Office Box 1049 Columbus, OH 43266-0149 Dr. Judith Johnsrud National Energy Committee Sierra Club 433 Orlando Avenue State College, PA 16803 Duquesne Light Company l.~
Beaver Valley Power Station PO Box 4 Shippingport, PA 15077 ATTN: R. L. Grand, Division Vice President, Nuclear Operations Group and Plant Manager (BV-SOSB-7)