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| | issue date = 04/14/1997 | | | issue date = 04/14/1997 |
| | title = Provides Supplemental Info to 970407 License Amend Request Re Clarification of Scope of Response Time Testing. Calculation,Encl | | | title = Provides Supplemental Info to 970407 License Amend Request Re Clarification of Scope of Response Time Testing. Calculation,Encl |
| | author name = BYRAM R G | | | author name = Byram R |
| | author affiliation = PENNSYLVANIA POWER & LIGHT CO. | | | author affiliation = PENNSYLVANIA POWER & LIGHT CO. |
| | addressee name = | | | addressee name = |
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| {{#Wiki_filter:4~~'@VV'i''J.'EGULATE INFORMATION DISTRIBUTIO+YSTEM (RIDE)C-~~*ACCESSION NBR:9704220043 DOC.DATE: | | {{#Wiki_filter:4~ ~'@VV' i''J.'EGULATE INFORMATION DISTRIBUTIO+YSTEM (RIDE) |
| 97/04/14'.NOTARIZED: | | C |
| NOFACIL:50-387 Susqu'ehanna SteamElectricStation,Unit1,Pennsylva 50-388Susquehanna SteamElectricStation,Unit2,Pennsylva AUTH.NAME'UTHORAFFILIATION BYRAMFR.G.
| | - *~ ~ |
| Pennsylvania Power6LightCo.RECIP.NAME RECIPIENT AFFILIATION DocumentControlBranch(Document ControlDesk) | | 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) |
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| ==SUBJECT:== | | ==SUBJECT:== |
| Providessupplemental infoto970407licenseamendrequestreclarification ofscopeofresponsetimetesting.Calculation, encl.DISTRIBUTION CODE:A001DCOPIESRECEIVED:LTR ENCLSIZE:TITLE:ORSubmittal:
| | Provides supplemental info to 970407 license amend request re clarification of scope of response time testing. |
| GeneralDistribution NOTES:DOCKET050003870500038805000387GRECIPIENT IDCODE/NAME PDl-2LAPOSLUSNYFC INTERNAL:
| | Calculation, encl. |
| ACRSNRR/DE/ECGB/A NRR/DRCH/HICB NRR/DSSA/SRXB OGC/HDS2EXTERNAL:
| | DISTRIBUTION CODE: A001D COPIES RECEIVED:LTR ENCL SIZE: |
| NOACNOTES:COPIESLTTRENCL111111111111101111RECIPIENT IDCODE/NAME PD1-2PDILET01CB,NRR/DSSA/SPLB NUDOCS-ABSTRACT NRCPDRCOPIESLTTRENCL1111111111110D0~E.NNOTETOALLMRIDS"RECIPIENTS:
| | TITLE: OR Submittal: General Distribution NOTES: 05000387 G |
| PLEASEHELPUSTOREDUCEWASTE.TOHAVEYOURNAMEORORGANIZATION REMOVEDFROMDISTRIBUTION LISTSORREDUCETHENUMBEROFCOPIESRECEIVEDBYYOUORYOURORGANIZATION, CONTACTTHEDOCUMENTCONTROLDESK(DCD)ONEXTENSION 415-2083TOTALNUM;-"ROFCOPIESREQUIRED:
| | 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 |
| LTTR15ENCL14
| | NOTES: 1 1 0 |
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| | E. |
| | 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 |
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| ''.:'.Pennsylvania Power&LightCompanyTwoNorthNinthStreet~Allentown, PA18101-1179
| | '.: Pennsylvania Power & Light Company Two North Ninth Street ~ Allentown, PA 18101-1179 ~ 610/774-5151 4 |
| ~610/774-5151 4RobertG.ByramSeniorVicePresident Generation andChiefiVuclearOfJicer610/774-7502 Fax:610/774-5019 APR141997U.S.NuclearRegulatory Commission Attn:DocumentControlDeskMailStationP1-137Washington, DC20555SUSQUEHANNA STEAMELECTRICSTATIONSUPPLEMENTAL INFORMATION SUPPORTING PROPOSEDAMENDMENT NOS.205AND168CLARIFICATION OFTHESCOPEOFRESPONSETIMETESTINGDocketNos.50-387and50-388 | | 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 |
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| ==Reference:== | | ==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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| | PDR ADOCK 05000387 P PDR |
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| (1)(2)(3)(4)(5)PP&LLetterPLA-4597, "Proposed Amendment No.205ToLicenseNPF-14andProposedAmendment No.168ToLicenseNPF-22:Clarification OfTheScopeOfResponseTimeTesting,"datedApril4,1997.NRCLettertoB/VROwner'sGroup,datedDecember28,1994,transmitting Evaluation ofLicensing TopicalReportNEDO-32291, "SystemAnalysesforElimination ofSelectedResponseTimeTestingRequirements.
| | 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. |
| "NRCLettertoPP&L,datedJuly11,1995,issuingAmendments No.148toFacilityOperating LicenseNPF-14andNo.118toFacilityOperating LicenseNPF-22.GenericLetter93-08,"Relocation ofTechnical Specification TablesofInstrument ResponseTimeLimits,"datedDecember29,1993.BJVROwner'sGroupLicensing TopicalReportNEDO-32291, "SystemAnalysesforElimination ofSelectedResponseTimeTestingRequirements, "datedJanuary1994.,Thepurposeofthisletteristoprovidesupplemental information tosupporttheNRCreviewofproposedchangestoSusquehanna SteamElectricStation(SSES)Unit1andUnit2Technical Specifications clarifying thescopeofresponsetimetesting.Submittal ofthisinformation wasagreedtobyPP&Latateleconference onApril10,1997withyourMessrs.Poslusny, LoeserandSchulten.
| | 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. |
| TheproposedchangestoUnit1andUnit2Technical Specifications weresubmitted viaReference No.1Thisletterprovidesinformation onthreetopicsdiscussed attheApril10,1997teleconference:
| | 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. |
| (1)PP&L'sApplication oftheB2TSensor(2)Derivation ofSensorResponseTimeAdministrative Values(3)PP&L's"Response" toImplementation Requirements Delineated intlieNRCSafetyEvaluation Report(Reference No.2)~/9704220043 970414PDRADOCK05000387PPDRimjilijiOIiiisimluW~O PLAA608FILESR41-2/A17-2 DocumentControlDeskToicNo.1-PP&L'sAlicationoftheB2TSensorTheonlyapplication atSSESfortheB2TmodeldeviceistheReactorProtection System-ReactorSteamDomeHighPressurefunction, forwhichsensorresponsetimetestingrequirements havenotbeeneliminated.
| | 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. |
| TicNo2-Derivation fSensorResonseTimeAdministrative ValuesForthosechannels'whose sensorresponsetimetestshavebeeneliminated, butforwhichrelayresponsetimetestingisstillrequired, anassumedadministrative valueforsensorresponsetimeisrequired.
| | '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 |
| Theseadministrative values,or'penalties,'ere invokedto"accountforthesensorresponsetimeinthetotalchannelresponsetimecalculations.
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| Thisisapplicable totheReactorProtection System:ReactorVesselWaterLevel-LowLevelcriteria, theMainSteamLineIsolation:
| | 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 |
| ReactorVesselWaterLevel-LowLowLow,Level1channel,theMainSteamLineIsolation:
| | -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. |
| MainSteamLinePressure-Lowchannel,andtheMainSteamLineIsolation:
| | 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. |
| MainSteamLineFlow-Highchannel.Thetablebelowlistseachofthesesignals,alongwiththetotalchannelresponsetimelimitlistedintheFSAR,andtheadministrative valueforthesensorresponsetime.FUNCTIONNAMEReactorProtection System:ReactorVesselWaterLevel-LowLevel3MainSteamLineIsolation:
| | 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. |
| ReactorVesselWaterLevel-LowLowLow, LevelfMainSteamLineIsolation:
| | 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. |
| MainStcamLinePressure-LowMainSteamLineIsolation:
| | 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. |
| MainSteamLineFlow-HighINSTRUMENT MODELBartonModel288ABartonModel760Barksdale ModelB1T-M12SSGEBartonModel288AADMINISTRATIVE VALUEASSUMEDFORINSTRUMENT RESPONSETIME600milliseconds 600milliseconds 100milliseconds 200milliseconds TOTALCHANNELRESPONSETIME1.05seconds1second1second500milliseconds Inordertodetermine anassumedadministrative valueforsensor,responsetime,PP&Lreviewedtheoperational history(i.e.,themeasuredresponsetimes)sirlce1987.(Notethatthenecessary "design"datafromthemanufacturer wasnotavailable.)
| | 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. |
| Thisdatawasevaluated todetermine thelongestsensorresponsetimeandthelongestrelayresponsetimeforeachofthechannels.
| | |
| Thesensor'penalty'i.e.,
| | 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. |
| thenowassumedsensorresponsetime),wasselectedbaseduponthelongestsensorandrelayresponsetimes.This'penalty'alue wasthenaddedtoPP&L'sprocedures forcalculating totalchannelresponsetime.'orexample,thelongestinstrument responsetimetestresultfortheReactorProtection SystemReactorVesselLowLevel3channels(levelswitchesA-Donbothunits)is556milliseconds.
| | 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: |
| For PLA-4608FILESR41-2/A17-2 DocumentControlDeskthepurp'oseofestablishing anadministrative valueforsensorresponsetimetesting,thisnumberwasroundedupto600milliseconds todetermine theassumedpenalty.'herelayresponsetime-testacceptance criterion istheremaining portionoftheallowable channelresponsetime(inthisexample,1.05secondsless600milliseconds, or450milliseconds).
| | (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. |
| Shouldtherelayresponsetimetestresultsexceedthisvalue,thechannelwouldbedeclaredinoperable andtheappropriate Technical Specification LCOActionStatements wouldbeentered.I'InresponsetoarequestfromtheNRCstaF,PP&Lperformed anadditional statistical analysistoensurethattheselectedadministrative valuesforsensorresponsetimewereconservative, basedonthePP&Lempirical data.PP&Lcalculated a95%confidence value,andconcluded thattheadministrative limitsassumedforthesensorresponsetimewereconservative relativetothestatistically-determined responsetimes.AttherequestoftheNRCstaffreviewer, theattachment tothislettercontainsPP&LCalculation No.EC-058-1011, "SensorResponseTimeValuesforSelectRPSandMSIVIsolation Functions."
| | Appropriate plant modification and I&C procedures were revised fo include this requirement. |
| Thiscalculation documents thestatistical evaluation referenced above,andincludesacompilation oftheoperational datausedtosupportthederivation ofadministrative values.Additionally, asdiscussed previously andattheApril10,1997teleconference, PP&LwillsubmitachangetoitsITSsubmittal, currently underreviewbytheNRC,todescribethattheadministrative valuesestablished forthesensorresponsetimesforthefourspecificfunctions inquestionwerederivedfromoperational data.Thebasesclarification willalsoindicatethatthisapproachwastakenduetothefactthatthenecessary "design"datafromthemanufacturer wasnotavailable.
| | (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." |
| ToicNo.3-PP&L's"Resonse"toImlementation Reuirements Delineated intheNRCSafetEvaluation RertSERAsdescribed inReference No.1,theNRCapproved(Reference No.3)PP&L'srelocation ofresponsetimetablesfromtheTechnical Specifications totheFSARinaccordance withGenericLetter93-08(Reference No.4),concluding thattheprovisions of10CFR50.59provideanacceptable meanstocontrolchangestoresponsetimesinlieuofalicenseamendment.
| | PP&L Actions: Training has been provided fo appropriate Engineering personnel and Insfrumentafion & Control (1&C) personnel fo assure familiarify with this requirement. |
| Subsequent totherelocation ofresponsetimetablesfromtheTechnical Specifications, PP&Lappliedtheprovisions of10CFR50.59toeliminate selectedinstrument andrelayresponsetimetestingfromtheFSARinaccordance withguidelines contained withintheBWROGLicensing TopicalReport(LTR)(Reference No.5)andtheimplementation requirements delineated intheNRCSERfortheLTR.TheseNRCimplementation requirements actuallyconsistofstatements tobemadebylicensees withinlicenseamendment requeststomodifyTechnical Specification responsetimetables.However,duetothefactthatPP&Lrelocated theresponsetimetestingtablestotheFSAR,andthuswasabletomakechangestothetablesunder10CFR50.59,suchalicenseamendment request(including implementation requirement statements) wasnotnecessary. | | Appropriafe plant Modification and I&C procedures were revised to include this requirement. |
| 4PLAA608FILESR41-2/A17-2 DocumentControlDeskInresponsetoarequestfromthestafFonApril10,1997,PAL'sactionstakeninresponsetoeachofthestatements listedintheSERaredescribed below.Itshouldbenotedthattheseactionswereexe'cuted aspartofPPkL'simplementation oftheLTR.TheSERstates"...licensees muststatethattheyarefollowing therecommendations fromEPRINP-7243'Investigation ofResponseTimeTestingRequirements'nd therefore arerequiring thefollowing actions:(a)"Priortoinstallation ofanewtransmitter/switch orfollowing refurbishment ofatransmitter/switch (e.g.,sensorcellorvariabledampingcomponents),
| | The SER further states that licensee requests must address the items listed below: |
| ahydraulic RTTshallbeperformed todetermine aninitialsensor-specific responsetimevalue,and"PP&LAcfions:Traininghasbeenprovidedfoappropriate Engineering personnel andInstrumentation
| | (a) "That calibration is being done with equipment designed to provide a step function or fast ramp in the process variable." |
| &Control(I&C)personnel toassurefamiliarity withthisrequirement. | | 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). |
| Appropriate plantmodification andI&Cprocedures wererevisedfoincludethisrequirement. | | |
| (b)"Fortransmitters andswitchesthatusecapillary tubes,capillary tubetestingshallbeperformed afterinitialinstallation'and afteranymaintenance or.modification activitythatcoulddamagethelines."PP&LActions:Traininghasbeenprovidedfoappropriate Engineering personnel andInsfrumentafion | | 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 |
| &Control(1&C)personnel foassurefamiliarify withthisrequirement. | | . response time degradation during the performance of calibrations and functional tests." |
| Appropriafe plantModification andI&Cprocedures wererevisedtoincludethisrequirement. | | 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. |
| TheSERfurtherstatesthatlicenseerequestsmustaddresstheitemslistedbelow:(a)"Thatcalibration isbeingdonewithequipment designedtoprovideastepfunctionorfastrampintheprocessvariable."
| | (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&LActions:Existingprocedures weredefermined tobeadequateforfhoseinstrumenfs withaninternalindicator. | | 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. |
| Forblindswitches(Static0Ring,Barksdale),
| | (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. |
| apost-calibration functional responsetimefesthasbeenaddedtothecalibration procedures.
| | (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." |
| Thisfestprovidesafastrampsignaltotheinstrument afplus-or-minus 10percentofthesetpoinl.
| | 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 ~ |
| Thisisdoneaspartoffhecalibration onan18-monthbasisgormerfrequency ofresponsetimetesting). PLA4608FILESR41-2/A17-2 DocumentControlDesk(b)"Thatprovisions havebeenmadetoensurethatoperators andtechnicians areawareoftheconsequences ofinstrument responsetimedegradation, andthatapplicable procedures havebeenreviewedandrevisedasnecessary toassurethattechnicians monitorfor.responsetimedegradation duringtheperformance ofcalibrations andfunctional tests."PP&LActions:TraininghasbeenprovidedtoOperations andI&Cpersonnel toassurefamiliarity withthisrequirement.
| | was performed. No manufacturer of the instruments for these applications recommends periodic response fime fesfing. |
| Astatemenf requiring fhattechnicians monitorforresponsetimedegradation during1heperformance ofcalibrations andfunctional testshasbeenaddedtotheapplicable testprocedures asastandardprerequisite.
| | Ifyou have any additional questions, please contact Ms. K.R. Leone at (610) 774-4023. |
| (c)"Thatsurveillance testingprocedures havebeenreviewedandrevisedifnecessary toensurecalibrations andfunctional testsarebeingperformed inamannerthatallowssimultaneous monitoring ofboththeinputandoutputresponseoftheunits."PP&I.Actions:Functional 1estsandcalibrations werereviewedanddefermined fobeperformed inamanner1hatallowssimultaneous moni1oring ofboththeinputandoufputresponseoftheunits.(d)"Thatforanyrequestinvolving theelimination ofRTTforRosemount pressuretransmitters, thelicenseeisinfullcompliance withtheguidelines ofSupplement 1toBulletin90-01,'LossofFill-OilinTransmitters Manufactured byRosemount' PP&I,Actions:None.TherearenoRosemount 1ransmi1ters inanyoftheresponsetimetestedloops.(e)"Thatforthoseinstruments wherethemanufacturer recommends periodicRTTaswellascalibration toensurecorrectfunction, thelicenseehasensuredthatelimination ofRTTisnevertheless acceptable fortheparticular application involved." | | Very truly yours, R. G. m Attachment |
| PPdcLActions:AreviewofEPRIreportNP-7423,"Investigation ofResponseTimeTestingRequiremenfs,"
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| andcallstovariousvendorsensuredthaftheabovestatement
| | 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 |
| ~wasperformed.
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| Nomanufacturer oftheinstruments fortheseapplications recommends periodicresponsefimefesfing.Ifyouhaveanyadditional questions, pleasecontactMs.K.R.Leoneat(610)774-4023.
| | . ~ |
| Verytrulyyours,R.G.mAttachment I' PLA-4608FILESR41-2/A17-2 DocumentControlDeskcopy:NRCRegionIMr.K.Jenison,NRCSr.ResidentInspector Mr.C.Poslusny, NRCSr.ProjectManager
| | ATTACHMENT1 TO PLA-4608 PPAL Calculation No. EC-058-1011 Sensor Response Time Values for Select RPS and MSIV Isolation Functions}} |
| .~ | |
| ATTACHMENT 1TOPLA-4608PPALCalculation No.EC-058-1011 SensorResponseTimeValuesforSelectRPSandMSIVIsolation Functions}}
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Category:CORRESPONDENCE-LETTERS
MONTHYEARPLA-5120, Forwards Change J to SSES Security Training & Qualification Plan.Without Encl1999-10-22022 October 1999
Forwards Change J to SSES Security Training & Qualification Plan.Without Encl
ML18040B2951999-09-0808 September 1999
Requests Info Re Any NRC or Susquehanna Documented Concerns with MSIV Reliability Prior to Plant Trip & Assurance to Public That NRC Able to Detect Mgt Problems Early
PLA-5094, Forwards,For Review,Change 00 to SSES Physical Security Plan.Without Encl1999-08-24024 August 1999
Forwards,For Review,Change 00 to SSES Physical Security Plan.Without Encl
ML18040A9741999-07-0808 July 1999
Forwards Rev 30 to SSES Emergency Plan, Adding EAL to Account for Potential Conditions Associated with Dry Cask Storage Sys Being Installed at Plant
ML20207G5051999-06-0707 June 1999
Informs That NRC Office of NRR Reorganized Effective 990328.As Part of Reorganization,Divison of Licensing Project Management Created
PLA-5072, Forwards Change Nn to SSES Physical Security Plan.Util Determined That Changes Do Not Decrease Safeguards Effectiveness of Plan,Per 10CFR50.54(p).Encl Withheld from Public Disclosure,Per 10CFR73.211999-06-0404 June 1999
Forwards Change Nn to SSES Physical Security Plan.Util Determined That Changes Do Not Decrease Safeguards Effectiveness of Plan,Per 10CFR50.54(p).Encl Withheld from Public Disclosure,Per 10CFR73.21
ML18040A9731999-05-24024 May 1999
Submits Response to RAI Re Exemption from Biennial Exercise Schedule.Changing of Drill Date Will Not Reduce Level of Emergency Preparedness at Plant
ML20195B2181999-05-20020 May 1999
Forwards Proprietary Decommissioning Status Rept for 10% Interest in Sses,Units 1 & 2.Proprietary Info Withheld,Per 10CFR2.790
ML18040B2901999-04-30030 April 1999
Forwards Summary Rept of Safety Evaluations Approved During Period from 961024-981029,per 10CFR50.59(b).Format of Rept, Listed
PLA-5041, Forwards Proprietary & Redacted Decommissioning Rept of Financial Assurance for Util 90% Interest in Sses,Units 1 & 2,per 10CFR50.75(f)(1).Proprietary Info Withheld,Per 10CFR2.7901999-03-29029 March 1999
Forwards Proprietary & Redacted Decommissioning Rept of Financial Assurance for Util 90% Interest in Sses,Units 1 & 2,per 10CFR50.75(f)(1).Proprietary Info Withheld,Per 10CFR2.790
ML18040A9691999-03-12012 March 1999
Forwards Revised Proposed Amend 227 to License NPF-14, Proposing Changes to ANFB-10 Critical Power Correlation & MCPR Safety Limits
ML17164A9891999-03-12012 March 1999
Informs That Util 990312 Ltr (PLA-5040) Submitted to NRC, Missing Encl C.Requests to Replace Package in Entirety with Encl
ML18040A9721999-03-11011 March 1999
Requests That Date for full-participation SSES Exercise, Scheduled for Week of 991115,be Changed Due to FEMA Region III Scheduling Conflicts.Fema Requests That Exercise Date Be Changed to Week of 001031
PLA-4852, Forwards non-redacted Version of Pp&L,Inc Corporate Auditing Rept 739459-2-98,dated 980210.Informs That Document Contains Info to Be Withheld IAW 10CFR2.7901999-02-18018 February 1999
Forwards non-redacted Version of Pp&L,Inc Corporate Auditing Rept 739459-2-98,dated 980210.Informs That Document Contains Info to Be Withheld IAW 10CFR2.790
ML20203G5821999-02-17017 February 1999
Second Final Response to FOIA Request for Documents. Documents Listed in App C Being Released in Entirety. Documents Listed in App D Being Withheld in Part (Ref FOIA Exemption 5)
ML20202F4761999-01-29029 January 1999
First Partial Response to FOIA Request for Documents.Records in App a Encl & Being Released in Entirety.App B Records Being Withheld in Part (Ref FOIA Exemption 7C)
ML18040A9671999-01-29029 January 1999
Notifies That Util Implemented Severe Accident Mgt Strategy in Accordance with Ltr Dtd 950327.Emegency Plan Revs Which Were Required to Implement Strategy Were Submitted by Ltr Dtd 981125
ML18040A9681999-01-29029 January 1999
Requests Exemption from Requirements of 10CFR50 App E,Items IVF.2.b & C,To Allowed to Reschedule Federally Observed Full Participation Emergency Exercise for SSES from Wk of 991115 to Wk of 001031
ML18040A9651999-01-12012 January 1999
Submits Addl Info Re Proposed Amend 184 to License NPF-22 for ANFB-10 Critical Power Correlation & MCPR Safety Limits
ML18030A1021998-12-16016 December 1998
Forwards Tables as Requested During 981202 Telcon Re Proposed Amend 184,dtd 980804,re ANFB-10 Critical Power Correlation & MCPR Safety Limits.Tables Provide Roadmap Identifying Applicability of References to TSs
ML18030A4331998-11-25025 November 1998
Forwards Rev 29 to SSES Emergecny Plan.Changes Has Been Made Without Commission Approval as It Does Not Decrease Effectiveness of Plan & Plan as Changed Continues to Satisfy Applicable Requirements of App E to 10CFR50
ML20195J9101998-11-18018 November 1998
Forwards Notice of Withdrawal of Application for Amends to Facility Operating Licenses (Notice).Notice Has Been Filed with Ofc of Fr.Amends Would Have Revised TS to Eliminate HPCI Pump auto-transfer on High Suppression Pool Level
ML20155F7201998-11-0303 November 1998
Final Response to FOIA Request for Documents.Documents Listed in App B Being Encl & Being Released in Entirety. Documents Listed in App C Being Withheld in Part (Ref Exemption 7C)
ML18026A2941998-10-19019 October 1998
Forwards SSES ISI Outage Summary Rept for Unit 1 Tenth Refueling & Insp Outage
ML18030A4321998-10-12012 October 1998
Forwards Rev 28 to SSES Emergency Plan, IAW Requirements of 10CFR50.54q.Change Is Summarized
PLA-4993, Forwards Change Mm to SSES Physical Security Plan.Encl Withheld,Per 10CFR73.211998-10-12012 October 1998
Forwards Change Mm to SSES Physical Security Plan.Encl Withheld,Per 10CFR73.21
ML18030A1001998-10-12012 October 1998
Forwards Rev 27 to SSES Emergency Plan. Changes Become Effective Upon Implementation of Improved Tech Specs
ML18030A4311998-09-29029 September 1998
Forwards Rev 27 & 28 to SSES Emergency Plan
ML20151W4951998-09-10010 September 1998
Informs That as Part of NRC Probabilistic Risk Assessment Implementation Plan,Commission Assigned Two Senior Reactor Analysts (Sras) to Each Regional Ofc.T Shedlosky & J Trapp Has Been Assigned SRAs for Region I
IR 05000387/19980081998-09-0808 September 1998
Provides Response to Violations Noted in Insp Repts 50-387/98-08 & 50-388/98-08.Corrective Actions:Current Administrative Controls on Fuel Level in EDG Day Tanks Will Remain in Effect Until TS Change is Approved
ML18030A0991998-09-0808 September 1998
Provides Response to Violations Noted in Insp Repts 50-387/98-08 & 50-388/98-08.Corrective Actions:Current Administrative Controls on Fuel Level in EDG Day Tanks Will Remain in Effect Until TS Change Is Approved
ML18026A4961998-08-31031 August 1998
Responds to NRC 980731 Ltr Re Violations Noted in Insp Repts 50-387/98-03 & 50-388/98-03.Corrective Actions:Procurement & Affected User Group Personnel Visited EDG Vendor Facilities to Appraise Vendor Work Practices & Discuss Expectations
IR 05000387/19980031998-08-31031 August 1998
Responds to NRC 980731 Ltr Re Violations Noted in Insp Repts 50-387/98-03 & 50-388/98-03.Corrective Actions:Procurement & Affected User Group Personnel Visited EDG Vendor Facilities to Appraise Vendor Work Practices & Discuss Expectations
ML20202F5501998-07-17017 July 1998
Responds to PP&L Corp Auditing Repts 739459-97,739459-1-97 & 739459-2-98 Re SSES Investigations Into Missed Alarm Tests
ML20236P9451998-07-15015 July 1998
Forwards Emergency Response Data Sys Implementation Documents Including Data Point Library Updates for Oconee (Number 255),Dresden (Number 257) & Susquehanna (Number 258)
ML18030A4291998-07-0808 July 1998
Forwards Final Version of SSES TS Implementing Improved TS of NUREG-1433.Implementation of Proposed Amend Is Predicted on NRC Issuance of Amends & Proposed to Not Exceed 90 Days from Date of Amend Issue
ML18017A2181998-07-0808 July 1998
Forwards Final Version of SSES TS Implementing Improved Tech Specs of NUREG 1433.Implementation of Proposed Amend Is Predicated on NRC Issuance of Amends & Is Proposed to Not Exceed 90 Days from Date of Amend Issuance
ML18026A2901998-06-0909 June 1998
Forwards Rev 26 to Emergency Plan IAW 10CFR50.54q.Summary of Changes Listed
ML18026A2891998-05-22022 May 1998
Submits Withdrawal of Expedited Review/Approval of Tech Specs/Bases 3/4.3.7.11 & 3/4.11.2.6 & Response to Request for Addl Info Re Offgas Sys Mods
ML18026A4941998-05-12012 May 1998
Responds to NRC Request to Resubmit Proposal to Change TS for Plant,Units 1 & 2,to Support Implementation of Improved TS & to Implement Provisions of GL 86-10 Re Relocation of Plant'S Fire Protection Program from TS to Another Document
ML20202H1331998-04-16016 April 1998
Partially Deleted Ltr Re Concerns Raised to NRC Concerning PP&L Susquehanna Facility
NUREG-0619, Informs That Staff Finds PP&L 980330 Request for Relief from Requirements of Section 4.3 of NUREG-0619,exams of Feedwater Nozzle Bore & Inner Radius for Another Operating Cycle to Be Acceptable1998-04-15015 April 1998
Informs That Staff Finds PP&L 980330 Request for Relief from Requirements of Section 4.3 of NUREG-0619,exams of Feedwater Nozzle Bore & Inner Radius for Another Operating Cycle to Be Acceptable
ML20216B6811998-04-0101 April 1998
First Partial Response to FOIA Request for Documents. Forwards Documents Listed in App a Being Released in Entirety
ML17159A2341998-03-30030 March 1998
Forwards LER 97-007-01,per 10CFR50.73(a)(2)(i)(B).Revised LER Submitted to Modify Previous Position W/Regards to Entry Into TS 3.0.3 for Event
PLA-4865, Forwards Listed non-redacted Pp&L,Inc Corporate Auditing Repts.Informs That Document Contains Info to Be Withheld IAW 10CFR2.7901998-03-11011 March 1998
Forwards Listed non-redacted Pp&L,Inc Corporate Auditing Repts.Informs That Document Contains Info to Be Withheld IAW 10CFR2.790
ML17159A1781998-03-0202 March 1998
Forwards Proposed Amends 203 & 161 to License NPF-14 & NPF-22,revising Tech Specs to Be Consistent w/NUREG-1433,rev 1, Std Tech Specs for GE Plants,Bwr 4.
PLA-4856, Forwards Proposed Amends to Licenses NPF-14 & NPF-22, Revising TS to Be Consistent w/NUREG-1433,rev 1, Std TS for GE Plants,Bwr 4. Proposed TS Consistent w/NUREG-1433,rev 1, Encl1998-03-0202 March 1998
Forwards Proposed Amends to Licenses NPF-14 & NPF-22, Revising TS to Be Consistent w/NUREG-1433,rev 1, Std TS for GE Plants,Bwr 4. Proposed TS Consistent w/NUREG-1433,rev 1, Encl
PLA-4854, Provides Summary of Investigations That PP&L Performed in Response to Concerns Identified by Former Nuclear Plant Operator.Summary Requested by Cj Anderson on 9802131998-02-27027 February 1998
Provides Summary of Investigations That PP&L Performed in Response to Concerns Identified by Former Nuclear Plant Operator.Summary Requested by Cj Anderson on 980213
ML20203M5071998-02-26026 February 1998
Final Response to FOIA Request for Documents.Records in App a Being Placed in PDR & Encl.Records in App B Partially Withheld (Ref FOIA Exemption 6)
ML20203B5931998-02-23023 February 1998
Ack Receipt of & Wire in Amount of $55,000 in Payment for Civil Penatly Proposed by NRC Ltr . Corrective Actions Will Be Examined During Future Inspections
1999-09-08
[Table view]
Category:INCOMING CORRESPONDENCE
MONTHYEARPLA-5120, Forwards Change J to SSES Security Training & Qualification Plan.Without Encl1999-10-22022 October 1999
Forwards Change J to SSES Security Training & Qualification Plan.Without Encl
ML18040B2951999-09-0808 September 1999
Requests Info Re Any NRC or Susquehanna Documented Concerns with MSIV Reliability Prior to Plant Trip & Assurance to Public That NRC Able to Detect Mgt Problems Early
PLA-5094, Forwards,For Review,Change 00 to SSES Physical Security Plan.Without Encl1999-08-24024 August 1999
Forwards,For Review,Change 00 to SSES Physical Security Plan.Without Encl
ML18040A9741999-07-0808 July 1999
Forwards Rev 30 to SSES Emergency Plan, Adding EAL to Account for Potential Conditions Associated with Dry Cask Storage Sys Being Installed at Plant
PLA-5072, Forwards Change Nn to SSES Physical Security Plan.Util Determined That Changes Do Not Decrease Safeguards Effectiveness of Plan,Per 10CFR50.54(p).Encl Withheld from Public Disclosure,Per 10CFR73.211999-06-0404 June 1999
Forwards Change Nn to SSES Physical Security Plan.Util Determined That Changes Do Not Decrease Safeguards Effectiveness of Plan,Per 10CFR50.54(p).Encl Withheld from Public Disclosure,Per 10CFR73.21
ML18040A9731999-05-24024 May 1999
Submits Response to RAI Re Exemption from Biennial Exercise Schedule.Changing of Drill Date Will Not Reduce Level of Emergency Preparedness at Plant
ML20195B2181999-05-20020 May 1999
Forwards Proprietary Decommissioning Status Rept for 10% Interest in Sses,Units 1 & 2.Proprietary Info Withheld,Per 10CFR2.790
ML18040B2901999-04-30030 April 1999
Forwards Summary Rept of Safety Evaluations Approved During Period from 961024-981029,per 10CFR50.59(b).Format of Rept, Listed
PLA-5041, Forwards Proprietary & Redacted Decommissioning Rept of Financial Assurance for Util 90% Interest in Sses,Units 1 & 2,per 10CFR50.75(f)(1).Proprietary Info Withheld,Per 10CFR2.7901999-03-29029 March 1999
Forwards Proprietary & Redacted Decommissioning Rept of Financial Assurance for Util 90% Interest in Sses,Units 1 & 2,per 10CFR50.75(f)(1).Proprietary Info Withheld,Per 10CFR2.790
ML17164A9891999-03-12012 March 1999
Informs That Util 990312 Ltr (PLA-5040) Submitted to NRC, Missing Encl C.Requests to Replace Package in Entirety with Encl
ML18040A9691999-03-12012 March 1999
Forwards Revised Proposed Amend 227 to License NPF-14, Proposing Changes to ANFB-10 Critical Power Correlation & MCPR Safety Limits
ML18040A9721999-03-11011 March 1999
Requests That Date for full-participation SSES Exercise, Scheduled for Week of 991115,be Changed Due to FEMA Region III Scheduling Conflicts.Fema Requests That Exercise Date Be Changed to Week of 001031
PLA-4852, Forwards non-redacted Version of Pp&L,Inc Corporate Auditing Rept 739459-2-98,dated 980210.Informs That Document Contains Info to Be Withheld IAW 10CFR2.7901999-02-18018 February 1999
Forwards non-redacted Version of Pp&L,Inc Corporate Auditing Rept 739459-2-98,dated 980210.Informs That Document Contains Info to Be Withheld IAW 10CFR2.790
ML18040A9681999-01-29029 January 1999
Requests Exemption from Requirements of 10CFR50 App E,Items IVF.2.b & C,To Allowed to Reschedule Federally Observed Full Participation Emergency Exercise for SSES from Wk of 991115 to Wk of 001031
ML18040A9671999-01-29029 January 1999
Notifies That Util Implemented Severe Accident Mgt Strategy in Accordance with Ltr Dtd 950327.Emegency Plan Revs Which Were Required to Implement Strategy Were Submitted by Ltr Dtd 981125
ML18040A9651999-01-12012 January 1999
Submits Addl Info Re Proposed Amend 184 to License NPF-22 for ANFB-10 Critical Power Correlation & MCPR Safety Limits
ML18030A1021998-12-16016 December 1998
Forwards Tables as Requested During 981202 Telcon Re Proposed Amend 184,dtd 980804,re ANFB-10 Critical Power Correlation & MCPR Safety Limits.Tables Provide Roadmap Identifying Applicability of References to TSs
ML18030A4331998-11-25025 November 1998
Forwards Rev 29 to SSES Emergecny Plan.Changes Has Been Made Without Commission Approval as It Does Not Decrease Effectiveness of Plan & Plan as Changed Continues to Satisfy Applicable Requirements of App E to 10CFR50
ML18026A2941998-10-19019 October 1998
Forwards SSES ISI Outage Summary Rept for Unit 1 Tenth Refueling & Insp Outage
ML18030A4321998-10-12012 October 1998
Forwards Rev 28 to SSES Emergency Plan, IAW Requirements of 10CFR50.54q.Change Is Summarized
ML18030A1001998-10-12012 October 1998
Forwards Rev 27 to SSES Emergency Plan. Changes Become Effective Upon Implementation of Improved Tech Specs
PLA-4993, Forwards Change Mm to SSES Physical Security Plan.Encl Withheld,Per 10CFR73.211998-10-12012 October 1998
Forwards Change Mm to SSES Physical Security Plan.Encl Withheld,Per 10CFR73.21
ML18030A4311998-09-29029 September 1998
Forwards Rev 27 & 28 to SSES Emergency Plan
ML18030A0991998-09-0808 September 1998
Provides Response to Violations Noted in Insp Repts 50-387/98-08 & 50-388/98-08.Corrective Actions:Current Administrative Controls on Fuel Level in EDG Day Tanks Will Remain in Effect Until TS Change Is Approved
IR 05000387/19980081998-09-0808 September 1998
Provides Response to Violations Noted in Insp Repts 50-387/98-08 & 50-388/98-08.Corrective Actions:Current Administrative Controls on Fuel Level in EDG Day Tanks Will Remain in Effect Until TS Change is Approved
ML18026A4961998-08-31031 August 1998
Responds to NRC 980731 Ltr Re Violations Noted in Insp Repts 50-387/98-03 & 50-388/98-03.Corrective Actions:Procurement & Affected User Group Personnel Visited EDG Vendor Facilities to Appraise Vendor Work Practices & Discuss Expectations
IR 05000387/19980031998-08-31031 August 1998
Responds to NRC 980731 Ltr Re Violations Noted in Insp Repts 50-387/98-03 & 50-388/98-03.Corrective Actions:Procurement & Affected User Group Personnel Visited EDG Vendor Facilities to Appraise Vendor Work Practices & Discuss Expectations
ML18017A2181998-07-0808 July 1998
Forwards Final Version of SSES TS Implementing Improved Tech Specs of NUREG 1433.Implementation of Proposed Amend Is Predicated on NRC Issuance of Amends & Is Proposed to Not Exceed 90 Days from Date of Amend Issuance
ML18030A4291998-07-0808 July 1998
Forwards Final Version of SSES TS Implementing Improved TS of NUREG-1433.Implementation of Proposed Amend Is Predicted on NRC Issuance of Amends & Proposed to Not Exceed 90 Days from Date of Amend Issue
ML18026A2901998-06-0909 June 1998
Forwards Rev 26 to Emergency Plan IAW 10CFR50.54q.Summary of Changes Listed
ML18026A2891998-05-22022 May 1998
Submits Withdrawal of Expedited Review/Approval of Tech Specs/Bases 3/4.3.7.11 & 3/4.11.2.6 & Response to Request for Addl Info Re Offgas Sys Mods
ML18026A4941998-05-12012 May 1998
Responds to NRC Request to Resubmit Proposal to Change TS for Plant,Units 1 & 2,to Support Implementation of Improved TS & to Implement Provisions of GL 86-10 Re Relocation of Plant'S Fire Protection Program from TS to Another Document
ML17159A2341998-03-30030 March 1998
Forwards LER 97-007-01,per 10CFR50.73(a)(2)(i)(B).Revised LER Submitted to Modify Previous Position W/Regards to Entry Into TS 3.0.3 for Event
PLA-4865, Forwards Listed non-redacted Pp&L,Inc Corporate Auditing Repts.Informs That Document Contains Info to Be Withheld IAW 10CFR2.7901998-03-11011 March 1998
Forwards Listed non-redacted Pp&L,Inc Corporate Auditing Repts.Informs That Document Contains Info to Be Withheld IAW 10CFR2.790
PLA-4856, Forwards Proposed Amends to Licenses NPF-14 & NPF-22, Revising TS to Be Consistent w/NUREG-1433,rev 1, Std TS for GE Plants,Bwr 4. Proposed TS Consistent w/NUREG-1433,rev 1, Encl1998-03-0202 March 1998
Forwards Proposed Amends to Licenses NPF-14 & NPF-22, Revising TS to Be Consistent w/NUREG-1433,rev 1, Std TS for GE Plants,Bwr 4. Proposed TS Consistent w/NUREG-1433,rev 1, Encl
ML17159A1781998-03-0202 March 1998
Forwards Proposed Amends 203 & 161 to License NPF-14 & NPF-22,revising Tech Specs to Be Consistent w/NUREG-1433,rev 1, Std Tech Specs for GE Plants,Bwr 4.
PLA-4854, Provides Summary of Investigations That PP&L Performed in Response to Concerns Identified by Former Nuclear Plant Operator.Summary Requested by Cj Anderson on 9802131998-02-27027 February 1998
Provides Summary of Investigations That PP&L Performed in Response to Concerns Identified by Former Nuclear Plant Operator.Summary Requested by Cj Anderson on 980213
ML20216B7031998-02-22022 February 1998
Partially Deleted Ltr Requesting Copy of OI Rept on Plant, Unit 2,case 1-96-039
PLA-4851, Provides Info That Was Requested by Cj Anderson on 980213 Re Former Util Employee Concern on Radwaste Control Room Offgas Panel Alarm Testing1998-02-18018 February 1998
Provides Info That Was Requested by Cj Anderson on 980213 Re Former Util Employee Concern on Radwaste Control Room Offgas Panel Alarm Testing
ML20203M5791998-02-10010 February 1998
Enters Appeal Due to Lack of Response to FOIA Request 97-473
ML18030A0971998-02-0202 February 1998
Forwards Proprietary Response to RAI Re Proposed License Amend 209 to TS Supporting Cycle 11 Reload.Proprietary Info Withheld,Per 10CFR2.790
ML20203G6071998-01-26026 January 1998
Forwards Redacted Version of Pp&L,Inc Corporate Auditings Interim Rept 739459-97,dtd 971015 & Affidavit Pursuant to 10CFR2.790 Justifying That Redacted Portions Be Withheld from Public Disclosure.Without Rept
IR 05000387/19970031998-01-0606 January 1998
Provides Updated Response to Violations Noted in Insp Repts 50-387/97-03 & 50-388/97-03.Corrective Actions:Util Currently Scheduling Issuance of All Procedural Revs by End of First Quarter 1998
ML18017A2931998-01-0606 January 1998
Provides Responses to Improved TS Section 3.8 Per 970324 NRC Rai.Schedule 980628 for Improved TS Implementation. Submittal of Revised Specifications Is Planned for Jan 1998
ML18030A4071998-01-0606 January 1998
Provides Updated Response to Violations Noted in Insp Repts 50-387/97-03 & 50-388/97-03.Corrective Actions:Util Currently Scheduling Issuance of All Procedural Revs by End of First Quarter 1998
PLA-4828, Expresses Appreciation for Support Received by Former Project Manager C Poslusny1997-12-29029 December 1997
Expresses Appreciation for Support Received by Former Project Manager C Poslusny
IR 05000387/19970041997-12-22022 December 1997
Resolves Commitments Made in Response to NOV Issued As Part of NRC Insp Repts 50-387/97-04 & 50-388/97-04 Dtd 970805. Proposed FSAR QA Program Description Changes,Reason for Changes & Basis Included for Approval
ML18026A4901997-12-22022 December 1997
Resolves Commitments Made in Response to NOV Issued as Part of NRC Insp Repts 50-387/97-04 & 50-388/97-04 Dtd 970805. Proposed FSAR QA Program Description Changes,Reason for Changes & Basis Included for Approval
ML20203M5741997-12-0505 December 1997
FOIA Request for Copy of Latest OI Rept on Susquehanna Ses Including All Exhibits & for Any Other Communication Between NRC & Susquehanna Ses/Pp&L
PLA-4818, Forwards Redacted Version of Pp&L,Inc Corporate Auditings Rept 739459-1-97,dtd 971201 & Affidavit Pursuant to 10CFR2.790 Justifying That Redacted Portions Be Withheld from Public Disclosure.Without Rept1997-12-0404 December 1997
Forwards Redacted Version of Pp&L,Inc Corporate Auditings Rept 739459-1-97,dtd 971201 & Affidavit Pursuant to 10CFR2.790 Justifying That Redacted Portions Be Withheld from Public Disclosure.Without Rept
1999-09-08
[Table view] |
Text
4~ ~'@VV' iJ.'EGULATE INFORMATION DISTRIBUTIO+YSTEM (RIDE)
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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
~
E.
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
~/
PDR ADOCK 05000387 P PDR
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
