ML18026A474

Provides Supplemental Info to 970407 License Amend Request Re Clarification of Scope of Response Time Testing. Calculation,Encl

ML18026A474
Person / Time
Site:	Susquehanna
Issue date:	04/14/1997
From:	Byram R PENNSYLVANIA POWER & LIGHT CO.
To:	NRC OFFICE OF INFORMATION RESOURCES MANAGEMENT (IRM)
Shared Package
ML18026A475	List: ML18026A474 ML18026A476
References
PLA-4608, NUDOCS 9704220043
Download: ML18026A474 (11)

Text

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ACCESSION NBR:9704220043 DOC.DATE: 97/04/14 '. NOTARIZED: NO DOCKET FACIL:50-387 Susqu'ehanna Steam Electric Station, Unit 1, Pennsylva 05000387 50-388 Susquehanna Steam Electric Station, Unit 2, Pennsylva 05000388 AUTH. NAME 'UTHOR AFFILIATION BYRAMFR.G. Pennsylvania Power 6 Light Co.

RECIP.NAME RECIPIENT AFFILIATION Document Control Branch (Document Control Desk)

SUBJECT:

Provides supplemental info to 970407 license amend request re clarification of scope of response time testing.

Calculation, encl.

DISTRIBUTION CODE: A001D COPIES RECEIVED:LTR ENCL SIZE:

TITLE: OR Submittal: General Distribution NOTES: 05000387 G

RECIPIENT COPIES RECIPIENT COPIES ID CODE/NAME LTTR ENCL ID CODE/NAME LTTR ENCL 0 PDl-2 LA 1 1 PD1-2 PD 1 1 POSLUSNYFC 1 1 INTERNAL: ACRS 1 1 ILE T 01 1 1 NRR/DE/ECGB/A 1 1 CB 1 1 NRR/DRCH/HICB 1 1 ,NRR/DSSA/SPLB 1 1 NRR/DSSA/SRXB 1 1 NUDOCS-ABSTRACT 1 1 OGC/HDS2 1 0 EXTERNAL: NOAC 1 1 NRC PDR 1 1 D

NOTES: 1 1 0

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N NOTE TO ALL MRIDS" RECIPIENTS:

PLEASE HELP US TO REDUCE WASTE. TO HAVE YOUR NAME OR ORGANIZATION REMOVED FROM DISTRIBUTION LISTS OR REDUCE THE NUMBER OF COPIES RECEIVED BY YOU OR YOUR ORGANIZATION, CONTACT THE DOCUMENT CONTROL DESK (DCD) ON EXTENSION 415-2083 TOTAL NUM;-"R OF COPIES REQUIRED: LTTR 15 ENCL 14

'.: Pennsylvania Power & Light Company Two North Ninth Street ~ Allentown, PA 18101-1179 ~ 610/774-5151 4

Robert G. Byram Senior Vice President Generation and ChiefiVuclear OfJicer 610/774-7502 Fax: 610/774-5019 APR 14 1997 U.S. Nuclear Regulatory Commission Attn: Document Control Desk Mail Station P 1-137 Washington, DC 20555 SUSQUEHANNA STEAM ELECTRIC STATION SUPPLEMENTAL INFORMATIONSUPPORTING PROPOSED AMENDMENTNOS. 205 AND 168 CLARIFICATIONOF THE SCOPE OF RESPONSE TIME TESTING Docket Nos. 50-387 and 50-388

Reference:

(1) PP&L Letter PLA-4597, "Proposed Amendment No. 205 To License NPF-14 and Proposed" Amendment No. 168 To License NPF-22: Clarification OfThe Scope OfResponse Time Testing, dated April4, 1997.

(2) NRC Letter to B/VR Owner's Group, dated December 28, 1994, transmitting Evaluation of Licensing Topical Report NEDO-32291, "System Analyses for Elimination of Selected Response Time Testing Requirements.

(3) NRC Letter to PP&L, dated July 11, 1995, issuing Amendments No. 148 to Facility Operating License NPF-14 and No. 118 to Facility Operating License NPF-22.

(4) Generic Letter 93-08, "Relocation of Technical Specification Tables ofInstrument Response Time Limits, dated December 29, 1993.

(5) BJVR Owner's Group Licensing Topical Report NEDO-32291, "System Analyses for Elimination ofSelected Response Time Testing Requirements, "dated January 1994.

,The purpose of this letter is to provide supplemental information to support the NRC review of proposed changes to Susquehanna Steam Electric Station (SSES) Unit 1 and Unit 2 Technical Specifications clarifying the scope of response time testing. Submittal of this information was agreed to by PP&L at a teleconference on April 10, 1997 with your Messrs. Poslusny, Loeser and Schulten. The proposed changes to Unit 1 and Unit 2 Technical Specifications were submitted via Reference No. 1 This letter provides information on three topics discussed at the April 10, 1997 teleconference:

(1) PP&L's Application of the B2T Sensor (2) Derivation of Sensor Response Time Administrative Values (3) PP&L's "Response" to Implementation Requirements Delineated in tlie NRC Safety Evaluation Report (Reference No. 2) 9704220043 970414 imjilijiOIiiisimluW~O

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PLAA608 FILES R41-2/A17-2 Document Control Desk To ic No. 1 PP&L's A lication of the B2T Sensor The only application at SSES for the B2T model device is the Reactor Protection System Reactor Steam Dome High Pressure function, for which sensor response time testing requirements have not been eliminated.

T ic No 2 Derivation f Sensor Res onse Time Administrative Values For those channels'whose sensor response time tests have been eliminated, but for which relay response time testing is still required, an assumed administrative value for sensor response time is required. These administrative values, or 'penalties,'ere invoked to "account for the sensor response time in the total channel response time calculations. This is applicable to the Reactor Protection System: Reactor Vessel Water Level - Low Level criteria, the Main Steam Line Isolation: Reactor Vessel Water Level -Low Low Low, Level 1 channel, the Main Steam Line Isolation: Main Steam Line Pressure - Low channel, and the Main Steam Line Isolation: Main Steam Line Flow - High channel. The table below lists each of these signals, along with the total channel response time limit listed in the FSAR, and the administrative value for the sensor response time.

FUNCTION NAME INSTRUMENT ADMINISTRATIVE TOTAL CHANNEL MODEL VALUEASSUMED FOR RESPONSE TIME INSTRUMENT RESPONSE TIME Reactor Protection System: Barton Model 288A 600 milliseconds 1.05 seconds Reactor Vessel Water Level-Low Level 3 Main Steam Line Isolation: Barton Model 760 600 milliseconds 1 second Reactor Vessel Water Level-LowLowLow,Level f Main Steam Line Isolation: Barksdale Model B 1T- 100 milliseconds 1 second Main Stcam Line Pressure- M12SSGE Low Main Steam Line Isolation: Barton Model 288A 200 milliseconds 500 milliseconds Main Steam Line Flow - High In order to determine an assumed administrative value for sensor, response time, PP&L reviewed the operational history (i.e., the measured response times) sirlce 1987. (Note that the necessary "design" data from the manufacturer was not available.) This data was evaluated to determine the longest sensor response time and the longest relay response time for each of the channels.

The sensor 'penalty'i.e., the now assumed sensor response time), was selected based upon the longest sensor and relay response times. This 'penalty'alue was then added to PP&L's procedures for calculating total channel response time.

'or example, the longest instrument response time test result for the Reactor Protection System Reactor Vessel Low Level 3 channels (level switches A-D on both units) is 556 milliseconds. For

PLA-4608 FILES R41-2/A17-2 Document Control Desk the purp'ose of establishing an administrative value for sensor response time testing, this number was rounded up to 600 milliseconds to determine the assumed penalty. 'he relay response time

-test acceptance criterion is the remaining portion of the allowable channel response time (in this example, 1.05 seconds less 600 milliseconds, or 450 milliseconds). Should the relay response time test results exceed this value, the channel would be declared inoperable and the appropriate Technical Specification LCO Action Statements would be entered.

I In response to a request from the NRC staF, PP&L performed an additional statistical analysis to ensure that the selected administrative values for sensor response time were conservative, based on the PP&L empirical data. PP&L calculated a 95% confidence value, and concluded that the administrative limits assumed for the sensor response time were conservative relative to the statistically-determined response times.

At the request of the NRC staff reviewer, the attachment to this letter contains PP&L Calculation No. EC-058-1011, "Sensor Response Time Values for Select RPS and MSIV Isolation Functions." This calculation documents the statistical evaluation referenced above, and includes a compilation of the operational data used to support the derivation of administrative values.

Additionally, as discussed previously and at the April 10, 1997 teleconference, PP&L will submit a change to its ITS submittal, currently under review by the NRC, to describe that the administrative values established for the sensor response times for the four specific functions in question were derived from operational data. The bases clarification will also indicate that this approach was taken due to the fact that the necessary "design" data from the manufacturer was not available.

To ic No. 3 PP&L's "Res onse" to Im lementation Re uirements Delineated in the NRC Safet Evaluation Re rt SER As described in Reference No. 1, the NRC approved (Reference No. 3) PP&L's relocation of response time tables from the Technical Specifications to the FSAR in accordance with Generic Letter 93-08 (Reference No. 4), concluding that the provisions of 10 CFR 50.59 provide an acceptable means to control changes to response times in lieu of a license amendment.

Subsequent to the relocation of response time tables from the Technical Specifications, PP&L applied the provisions of 10 CFR 50.59 to eliminate selected instrument and relay response time testing from the FSAR in accordance with guidelines contained within the BWROG Licensing Topical Report (LTR) (Reference No. 5) and the implementation requirements delineated in the NRC SER for the LTR. These NRC implementation requirements actually consist of statements to be made by licensees within license amendment requests to modify Technical Specification response time tables. However, due to the fact that PP&L relocated the response time testing tables to the FSAR, and thus was able to make changes to the tables under 10 CFR 50.59, such a license amendment request (including implementation requirement statements) was not necessary.

4 PLAA608 FILES R41-2/A17-2 Document Control Desk In response to a request from the stafF on April 10, 1997, PAL's actions taken in response to each of the statements listed in the SER are described below. It should be noted that these actions were exe'cuted as part of PPkL's implementation of the LTR.

The SER states "... licensees must state that they are following the recommendations from EPRI NP-7243 'Investigation of Response Time Testing Requirements'nd therefore are 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 damping components), a hydraulic RTT shall be performed to determine an initial sensor-specific response time value, and" PP&L Acfions: Training has been provided fo appropriate Engineering personnel and Instrumentation & Control (I&C) personnel to assure familiarity with this requirement.

Appropriate plant modification and I&C procedures were revised fo include this requirement.

(b) "For transmitters and switches that use capillary tubes, capillary tube testing shall be performed after initial installation'and after any maintenance or. modification activity that could damage the lines."

PP&L Actions: Training has been provided fo appropriate Engineering personnel and Insfrumentafion & Control (1&C) personnel fo assure familiarify with this requirement.

Appropriafe plant Modification and I&C procedures were revised to include this requirement.

The SER further states that licensee requests must address the items listed below:

(a) "That calibration is being done with equipment designed to provide a step function or fast ramp in the process variable."

PP&L Actions: Existing procedures were defermined to be adequate for fhose instrumenfs with an internal indicator. For blind switches (Static 0 Ring, Barksdale), a post-calibration functional response time fest has been added to the calibration procedures. This fest provides a fast ramp signal to the instrument af plus-or-minus 10 percent of the setpoinl. This is done as part of fhe calibration on an 18-month basis gormerfrequency ofresponse time testing).

PLA4608 FILES R41-2/A17-2 Document Control Desk (b) "That provisions have been made to ensure that operators and technicians are aware of the consequences of instrument response time 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."

PP&L Actions: Training has been provided to Operations and I&Cpersonnel to assure familiarity with this requirement. A statemenf requiring fhat technicians monitor for response time degradation during 1he performance of calibrations and functional tests has been added to the applicable test procedures as a standard prerequisite.

(c) "That surveillance testing procedures have been reviewed and revised if necessary to ensure calibrations and functional tests are being performed in a manner that allows simultaneous monitoring of both the input and output response of the units."

PP&I. Actions: Functional 1ests and calibrations were reviewed and defermined fo be performed in a manner 1hat allows simultaneous moni1oring of both the input and oufput response of the units.

(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 1 to Bulletin 90-01, 'Loss of Fill-Oil in Transmitters Manufactured by Rosemount' PP&I, Actions: None. There are no Rosemount 1ransmi1ters in any of the response time tested loops.

(e) "That for those instruments where the manufacturer recommends periodic RTT as well as calibration to ensure correct function, the licensee has ensured that elimination of RTT is nevertheless acceptable for the particular application involved."

PPdcL Actions: A review of EPRI report NP-7423, "Investigation of Response Time Testing Requiremenfs," and calls to various vendors ensured thaf the above statement ~

was performed. No manufacturer of the instruments for these applications recommends periodic response fime fesfing.

Ifyou have any additional questions, please contact Ms. K.R. Leone at (610) 774-4023.

Very truly yours, R. G. m Attachment

I' PLA-4608 FILES R41-2/A17-2 Document Control Desk copy: NRC Region I Mr. K. Jenison, NRC Sr. Resident Inspector Mr. C. Poslusny, NRC Sr. Project Manager

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ATTACHMENT1 TO PLA-4608 PPAL Calculation No. EC-058-1011 Sensor Response Time Values for Select RPS and MSIV Isolation Functions