Information Notice No. 97-28: Elimination of Instrument Response Time Testing Under the Requirements of 10 CFR 50.59
NUCLEAR REGULATORY COMMISSION
OFFICE OF NUCLEAR REACTOR REGULATION
WASHINGTON, D.C. 20555
May 30, 1997
NRC INFORMATION NOTICE 97-28: ELIMINATION OF INSTRUMENT RESPONSE TIME TESTING
UNDER THE REQUIREMENTS OF 10 CFR 50.59
All holders of operating licenses or construction permits.
The U.S. Nuclear Regulatory Commission (NRC) is issuing this information
notice to alert addressees to changes to licensee-controlled documents made
in accordance with Section 50.59 of Title 10 of the Code of Federal
Regulations (10 CFR 50.59) that resulted in improper elimination of a
technical specification (TS) surveillance test. It is expected that
recipients will review the information for applicability to their facilities
and consider actions, as appropriate, to avoid similar problems. However,
suggestions contained in this information notice are not NRC requirements;
therefore, no specific action or written response is required.
Description of Circumstances
In accordance with the provisions of Generic Letter (GL) 93-08, "Relocation of
Technical Specification Tables of Instrument Response Time Limits," dated
December 29, 1993, licensees may submit license amendment requests to remove
existing tables of response time limits from the plant TSs to the final safety
analysis report (FSAR). As stated in GL 93-08, the NRC intends to allow
changes to response time limits in accordance with 10 CFR 50.59 without NRC
approval while not eliminating the requirement to conduct response time
In January 1994, the owners group for boiling-water reactor nuclear power
plants (the BWR Owners Group) submitted licensing topical report NEDO-32291,
"System Analyses for Elimination of Selected Response Time Testing
Requirements," for NRC review. On December 28, 1994, the NRC issued a safety
evaluation report generically approving the use of this report to justify
elimination of certain response time testing requirements.
The NRC has learned that several BWR licensees have implemented NEDO-32291 by
adding a footnote to FSAR tables of instrument response time limits for
several safety-related functions, namely reactor protection, containment
isolation, and emergency core cooling. These footnotes listed sensors
eliminated from response time testing in accordance with 10 CFR 50.59 and, in
some cases, allowed that response time testing was no longer required
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May 30, 1997
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for the function. However, the TSs for these plants still require response
time testing of these instruments. Consequently, these licensees did not test
the response times of certain instruments and thereby violated the TSs.
These circumstances arose because the affected licensees used the generically
approved NEDO-32291 guidance to modify tables of instrument functions
requiring response time testing without realizing that such modifications
affected plant TSs. Changes to TSs are not permitted without NRC approval of
a license amendment request for such changes.
These particular circumstances did not result in a significant safety or
operability concern. The instruments in question were tested in accordance
with the approved NEDO-32291 document. Some of the licensees involved
submitted license amendment requests for these response time testing changes.
The NRC has granted enforcement discretion while reviewing these requests.
This information notice requires no specific action or written response. If
you have any questions about the information in this notice, please contact
one of the technical contacts listed below or the appropriate Office of
Nuclear Reactor Regulation (NRR) project manager.
signed by S.H. Weiss for
Marylee M. Slosson, Acting Director
Division of Reactor Program Management
Office of Nuclear Reactor Regulation
Technical contacts: P. J. Loeser, NRR
C. S. Schulten, NRR
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