Relocation of Technical specification Tables of Instrument Response Time Limits (Generic Letter 93-08)

December 29, 1993



TO:       ALL HOLDERS OF OPERATING LICENSES FOR NUCLEAR POWER REACTORS

SUBJECT:  RELOCATION OF TECHNICAL SPECIFICATION TABLES OF INSTRUMENT RESPONSE 
          TIME LIMITS (Generic Letter 93-08)


The U.S. Nuclear Regulatory Commission (NRC) is issuing this guidance for
requesting a license amendment to relocate tables of instrument response time
limits from technical specifications (TS) to the updated final safety analysis
report.  The NRC developed this line-item TS improvement in response to TS
proposals by applicants for operating licenses.

Licensees that plan to adopt this line-item TS improvement are encouraged to
propose TS changes consistent with the guidance given in Enclosures 1 and 2. 
NRC project managers will review the amendment requests to verify that they
conform to this guidance.  Please contact your project manager or the contact
indicated herein if you have any questions on this matter.  

Licensee action to propose TS changes under the guidance of this generic
letter is voluntary.  Therefore, such action is not a backfit under the
provisions of Section 50.109 of Title 10 of the Code of Federal Regulations
(10 CFR).  The following information, although not requested under the
provisions of 10 CFR 50.54(f), would help the NRC evaluate costs and benefits
for 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 change

The voluntary information collections contained in this request are covered by
the Office of Management and Budget clearance number 3150-0011, which expires
June 30, 1994.  The public reporting burden for this voluntary collection of
information is estimated to average 40 hours per response, including the time
for reviewing instructions, searching existing data sources, gathering and
maintaining the data needed, and completing and reviewing the collection of
information.  Send comments regarding this burden estimate or any other aspect
of this voluntary collection of information, including suggestions for
reducing this burden, to the Information and Records Management Branch 
(MNBB-7714), U.S. Nuclear Regulatory Commission, Washington, D.C. 20555, and



9312170112.

Generic Letter 93-08                 - 2 -                   December 29, 1993


to the Desk Officer, Office of Information and Regulatory Affairs, NEOB-3019,
(3150-0011), Office of Management and Budget, Washington, D.C.  20503.

                                       Sincerely,

                                       /S/'D BY LJCALLAN

                                       L. J. Callan
                                       Acting Associate Director for Projects
                                       Office of Nuclear Reactor Regulation

Enclosures: 
l.  Guidance for A Proposed License Amendment to Relocate Tables of Instrument 
	Response Time Limits from Technical Specifications to the Updated Final 
    Safety Analysis Report
2.  Model Technical Specifications
3.  List of Recently Issued NRC Generic Letters

Technical contact:  T. G. Dunning, NRR
                    (301) 504-1189
.

Generic Letter 93-08                                               Enclosure 1


              Guidance for a Proposed License Amendment To Relocate
    Tables of Instrument Response Time Limits From Technical Specifications
                  to the Updated Final Safety Analysis Report

Introduction

The NRC is issuing the following guidance for preparing a proposed license
amendment to relocate the tables of response time limits for the reactor trip
system (RTS) and the engineered safety features actuation system (ESFAS)
instruments from technical specifications (TS) to the updated final safety
analysis report (FSAR).  The NRC has already implemented this line-item TS
improvement for recently issued operating licenses and in the improved
standard technical specifications.

Discussion

The limiting conditions for operation (LCOs) for RTS and ESFAS instruments
require that these systems be operable with response times as specified in TS
tables for each of these systems.  The surveillance requirements specify that
licensees test these systems and verify that the response time of each func-
tion is within its limits.  Relocating the tables of the RTS and ESFAS
instrument response time limits from the TS to the updated FSAR will not alter
these surveillance requirements.  The updated FSAR will now address the
response time limits for the RTS and ESFAS instruments, including those
channels for which the response time limit is indicated as "NA"; that is, a
response time limit is not applicable.  The updated FSAR will also clarify
response time limits where footnotes are included in the tables that describe
how those limits are applied.  This TS change also allows the licensee to
administratively control changes to the response time limits for the RTS and
ESFAS instruments in accordance with the provisions of 10 CFR 50.59 without
the need to process a license amendment request.  

The LCOs for the RTS and the ESFAS typically specify that the associated
instruments "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 to
remove the reference to response times and simply state that this instrumen-
tation "shall be OPERABLE" as shown for the markup of the Westinghouse
standard technical specifications in Enclosure 2.  This change is applicable
to all plants and is compatible with relocating the referenced tables.  

The surveillance requirements specify that the response time of each trip
function is to be demonstrated to be within its limit at the specified
frequency and do not reference the tables of response time limits.  Therefore,
the surveillance requirements specified in this manner need not be modified to
implement this change.  However, a footnote in the table of response time
limits for the RTS states that neutron detectors are exempt from response time
testing.  To retain this exception, which is stated in the table being removed
from the TS, the surveillance requirements for the RTS should be modified to
add the following statement:

      Neutron detectors are exempt from response time testing.

.

Generic Letter 93-08                 - 2 -                         Enclosure 1


Each licensee that wishes to implement this line-item TS improvement should
confirm that the plant procedures for response time testing include acceptance
criteria that reflect the RTS and ESFAS response time limits in the tables
being relocated from the TS to the updated FSAR.  The licensee should also
provide a commitment to include the RTS and ESFAS response time limits in the
next update of the FSAR.

Licensees would submit any subsequent changes to these limits in the FSAR as
an update of the FSAR as required by 10 CFR 50.71(e).  Related changes to
plant procedures would be subject to the provisions that control changes to
plant procedures as stated in the administrative controls section of the TS.

.

Generic Letter 93-08                                               Enclosure 2



                        Model Technical Specifications


The model technical specifications are based on the "Standard Technical
Specifications 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 INSTRUMENTATION


3.3.1  As a minimum, the Reactor Trip System instrumentation channels and
interlocks of Table 3.3-1 shall be OPERABLE. (delete: with RESPONSE TIMES as
shown in Table 3.3-2.)

      (Change TS 3.3.1 as shown)

4.3.1.2  The REACTOR TRIP SYSTEM RESPONSE TIME of each reactor trip function
shall be demonstrated to be within its limit at least once per 18 months. 
(Add: Neutron detectors are exempt from response time testing.)  Each test
shall include at least one train such that both trains are tested at least
once per 36 months and one channel per function such that all channels are
tested at least once every N times 18 months where N is the total number of
redundant channels in a specific Reactor trip function as shown in the "Total
No. of Channels" column of Table 3.3-1.

      (Make addition to TS 4.3.1.2 as shown in parentheses)


3/4.3.2  ENGINEERED SAFETY FEATURES ACTUATION SYSTEM INSTRUMENTATION

3.3.2  The Engineered Safety Features Actuation System (ESFAS) instrumentation
channels and interlocks shown in Table 3.3-3 shall be OPERABLE with their Trip
Setpoints set consistent with the values shown in the Trip Setpoint column of
Table 3.3-4. (delete: and with RESPONSE TIMES as shown in Table 3.3-5.)

      (Change to TS 3.3.2 as shown)

4.3.2.2  The ENGINEERED SAFETY FEATURES RESPONSE TIME of each ESFAS function
shall 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 at
least once per 36 months and one channel per function such that all channels
are tested at least once every N times 18 months where N is the total number
of redundant channels in a specific ESFAS function as shown in the "Total No.
of Channels" column of Table 3.3-3.

      (Make no change to TS 4.3.2.2)