NRC Generic Letter 1993-08
-UNITED STATESNU& U )kR REGULATORY COMMISSIOk9WASHINGTON. D.C. 25055December 29, 1993TO: ALL HOLDERS OF OPERATING LICENSES FOR NUCLEAR POWER REACTORS
SUBJECT: RELOCATION OF TECHNICAL SPECIFICATION TABLES OF INSTRUMENT RESPONSETIME LIMITS (Generic Letter 93-08)The U.S. Nuclear Regulatory Commission (NRC) is issuing this guidance forrequesting a license amendment to relocate tables of instrument response timelimits from technical specifications (TS) to the updated final safety analysisreport. The NRC developed this line-item TS improvement in response to TSproposals by applicants for operating licenses.Licensees that plan to adopt this line-item TS improvement are encouraged topropose TS changes consistent with the guidance given in Enclosures I and 2.NRC project managers will review the amendment requests to verify that theyconform to this guidance. Please contact your project manager or the contactindicated herein if you have any questions on this matter.Licensee action to propose TS changes under the guidance of this genericletter is voluntary. Therefore, such action is not a backfit under theprovisions of Section 50.109 of Title 10 of the Code of Federal Regulations(10 CFR). The following information, although not requested under theprovisions of 10 CFR 50.54(f), would help the NRC evaluate costs and benefitsfor licensees who propose the TS changes described in this generic letter:* licensee time and costs to prepare the amendment request* estimate of the long-term costs or savings accruing from this TS changeThe voluntary information collections contained in this request are covered bythe Office of Management and Budget clearance number 3150-0011, which expiresJune 30, 1994. The public reporting burden for this voluntary collection ofinformation is estimated to average 40 hours4.62963e-4 days <br />0.0111 hours <br />6.613757e-5 weeks <br />1.522e-5 months <br /> per response, including the timefor reviewing instructions, searching existing data sources, gathering andmaintaining the data needed, and completing and reviewing the collection ofinformation. Send comments regarding this burden estimate or any other aspectof this voluntary collection of information, including suggestions forreducing this burden, to the Information and Records Management Branch(MNBB-7714), U.S. Nuclear Regulatory Commission, Washington, D.C. 20555, andNRS 7: 00208519006l Generic Letter 93-08-2 -.-' December 29, 1993to the Desk Officer, Office of Information and Regulatory Affairs, NEOB-3019,(3150-0011), Office of Management and Budget, Washington, D.C. 20503.
Sincerely,;anA Associate Director for ProjectsOffice of Nuclear Reactor Regulation
Enclosures:
1. Guidance for A Proposed License Amendment toRelocate Tables of Instrument Response TimeLimits from Technical Specifications to theUpdated Final Safety Analysis Report2. Model Technical Specifications3. List of Recently Issued NRC Generic LettersTechnical contact: T. G. Dunning, NRR(301) 504-1189 Generic Letter 93-08Enclosure 1Guidance for a Proposed License Amendment To RelocateTables of Instrument Response Time Limits From Technical Specificationsto the Updated Final Safety Analysis ReportIntroductionThe NRC is issuing the following guidance for preparing a proposed licenseamendment to relocate the tables of response time limits for the reactor tripsystem (RTS) and the engineered safety features actuation system (ESFAS)instruments from technical specifications (TS) to the updated final safetyanalysis report (FSAR). The NRC has already implemented this line-item TSimprovement for recently issued operating licenses and in the improvedstandard technical specifications.DiscussionThe limiting conditions for operation (LCOs) for RTS and ESFAS instrumentsrequire that these systems be operable with response times as specified in TStables for each of these systems. The surveillance requirements specify thatlicensees test these systems and verify that the response time of each func-tion is within its limits. Relocating the tables of the RTS and ESFASinstrument response time limits from the TS to the updated FSAR will not alterthese surveillance requirements. The updated FSAR will now address theresponse time limits for the RTS and ESFAS instruments, including thosechannels for which the response time limit is indicated as "NA"; that is, aresponse time limit is not applicable. The updated FSAR will also clarifyresponse time limits where footnotes are included in the tables that describehow those limits are applied. This TS change also allows the licensee toadministratively control changes to the response time limits for the RTS andESFAS instruments in accordance with the provisions of 10 CFR 50.59 withoutthe need to process a license amendment request.The LCOs for the RTS and the ESFAS typically specify that the associatedinstruments shall be OPERABLE with RESPONSE TIMES as shown in Table 3.3-2'(RTS) or Table 3.3-5' (ESFAS). An acceptable change to the LCOs would be toremove the reference to response times and simply state that this instrumen-tation 'shall be OPERABLE' as shown for the markup of the Westinghousestandard technical specifications in Enclosure 2. This change is applicableto all plants and is compatible with relocating the referenced tables.The surveillance requirements specify that the response time of each tripfunction is to be demonstrated to be within its limit at the specifiedfrequency and do not reference the tables of response time limits. Therefore,the surveillance requirements specified in this manner need not be modified toimplement this change. However, a footnote in the table of response timelimits for the RTS states that neutron detectors are exempt from response timetesting. To retain this exception, which is stated in the table being removedfrom the TS, the surveillance requirements for the RTS should be modified toadd the following statement:Neutron detectors are exempt from response time testin Generic Letter 93-08 -2 -Enclosure 1Each licensee that wishes to implement this line-item TS improvement shouldconfirm that the plant procedures for response time testing include acceptancecriteria that reflect the RTS and ESFAS response time limits in the tablesbeing relocated from the TS to the updated FSAR. The licensee should alsoprovide a commitment to include the RTS and ESFAS response time limits in thenext update of the FSAR.Licensees would submit any subsequent changes to these limits in the FSAR asan update of the FSAR as required by 10 CFR 50.71(e). Related changes toplant procedures would be subject to the provisions that control changes toplant procedures as stated in the administrative controls section of the T Generic Letter 93-08Enclosure 2K IKModel Technical SpecificationsThe model technical specifications are based on the Standard TechnicalSpecifications for Westinghouse Pressurized Water Reactors," NUREG-0452,Revision 4a; however, the indicated changes are applicable for all plants.3/4.3.1 REACTOR TRIP SYSTEM INSTRUMENTATION3.3.1 As a minimum, the Reactor Trip System instrumentation channels andinterlocks of Table 3.3-1 shall be OPERABLE. with RESPONSE TIMES as shown inTable 3.34--.(Change TS 3.3.1 as shown)4.3.1.2 The REACTOR TRIP SYSTEM RESPONSE TIME of each reactor trip functionshall be demonstrated to be within its limit at least once per 18 months.Neutron detectors are exempt from response time testing. Each test shallinclude at least one train such that both trains are tested at least once per36 months and one channel per function such that all channels are tested atleast once every N times 18 months where N is the total number of redundantchannels in a specific Reactor trip function as shown in the 'Total No. ofChannels" column of Table 3.3-1.(Make addition to TS 4.3.1.2 as shown In Bold typeface)3/4.3.2 ENGINEERED SAFETY FEATURES ACTUATION SYSTEM INSTRUMENTATION3.3.2 The Engineered Safety Features Actuation System (ESFAS) instrumentationchannels and interlocks shown in Table 3.3-3 shall be OPERABLE with their TripSetpoints set consistent with the values shown in the Trip Setpoint column ofTable 3.3-4. end with RESPONSE TIMES as shown in Table 3.3 6.(Change to TS 3.3.2 as shown)4.3.2.2 The ENGINEERED SAFETY FEATURES RESPONSE TIME of each ESFAS functionshall be demonstrated to be within the limit at least once per 18 months.Each test shall include at least one train such that both trains are tested atleast once per 36 months and one channel per function such that all channelsare tested at least once every N times 18 months where N is the total numberof redundant channels in a specific ESFAS function as shown in the MTotal No.of Channels' column of Table 3.3-3.(Make no change to TS 4.3.2.2)
Lnuluburc aGL 93-08December 29, 1993\-J <~ JPage 1 of ILIST OF RECENTLY ISSUED GENERIC LETTERSGenericDate ofseeumIIaneTstsued Tocr. .A-.9-Letter UD-leLL @a,4_, ,93-0793-0693-0589-10,SUPP. 593-04MODIFICATION OF THE TECH-NICAL SPECIFICATION ADMINI-STRATIVE CONTROL REQUIRE-MENTS FOR EMERGENCY ANDSECURITY PLANSRESEARCH RESULTS ONON GENERIC SAFETY ISSUE 106,'PIPING AND THE USE OFHIGHLY COMBUSTIBLE GASES INVITAL AREASLINE-ITEM TECHNICALSPECIFICATIONS IMPROVE-MENTS TO REDUCE SURVEILLANCEREQUIREMENTS FOR TESTINGDURING POWER OPERATIONINACCURACY OF MOTOR-OPERATED VALVEDIAGNOSTIC EQUIPMENTROD CONTROL SYSTEMFAILURE AND WITHDRAWALOF ROD CONTROL CLUSTERASSEMBLIES, 10 CFR 50.54(f)12/28/9310/25/9309/27/9306/28/9306/21/93ALL HOLDERS OF OLsFOR NPRsALL HOLDERS OF OLs ORCPs FOR NPRsALL HOLDERS OF OLs.ORCPs FOR NPRsALL LICENSEES OFOPERATING NUCLEAR POWERPLANTS AND HOLDERS OFCONSTRUCTION PERMITS FORNUCLEAR POWER PLANTSALL HOLDERS OF OLs ORCPs FOR (W)-DESIGNEDNPRs EXCEPT HADDAM NECKALLCPsANDANDHOLDERS OF OLs ORFOR (CE)-DESIGNED(B&W)-DESIGN NPRsHADDAM NECK93-03VERIFICATION OF PLANTRECORDS* 10/20/93ALL HOLDERS OF OLs ORCPs FOR NPRs93-02NRC PUBLIC WORKSHOP ONCOMMERCIAL GRADE PRO-CUREMENT AND DEDICATION03/23/93ALL HOLDERS OF OLs ORCPs FOR NPRs AND ALLRECIPIENTS OF NUREG-0040,"LICENSEE CONTRACTOR ANDVENDOR INSPECTION STATUSREPORT* (WHITE BOOK)OL = OPERATING LICENSECP -CONSTRUCTION PERMITNPR -NUCLEAR POWER REACTORS
'K)Generic Letter 93-08-2 -December 29, 1993to the Desk Officer, Office of Information and Regulatory Affairs, NEOB-3019,(3150-0011), Office of Management and Budget, Washington, D.C. 20503.
Sincerely,orig /s/'d by LCWallanL. J. CallanActing Associate DirectorOffice of Nuclear Reactorfor ProjectsRegulation
Enclosures:
1. Guidance for A Proposed License Amendment toRelocate Tables of Instrument Response TimeLimits from Technical Specifications to theUpdated Final Safety Analysis Report2. Model Technical Specifications3. List of Recently Issued NRC Generic LettersTechnical contact:T. G. Dunning, NRR(301) 504-1189DISTRIBUTION:NRC PDRCentral FilesDORS R/FOTSB R/FFJMiragliaWTRussellJGPartlowSATrebyBKGrimesGHMarcusClGrimesFMReinhartWAReckleyTGDunningAs confirmed by D.was not consideredthe generic letterAllison, CRGR staff on 12/06/93, further CRGR reviewnecessary because no substantive changes were made toas reveiwed by CRGR in response to public comments.*SEE PREVIOUS CONCURREN(OTSB:DORS Tech EdilTGDunning;tgd* MMeJac*07/29/93 07/29/93tor OTSB:DORSFMRei yrt*} 8 4'93,46S$jRR< 2GP4Ifes12/i./93C:OTSB:DORSCIGrimes*09/07/93C:OGCB:DORSGHMarcus*09/08/93PDIV-2WAReckley*09/09/93OGCSATreby*09/14/93ADP: NRRLJCal 1 an*12/22/93DOC NAME: 93-08.IN