ML17292A591
| ML17292A591 | |
| Person / Time | |
|---|---|
| Site: | Columbia  |
| Issue date: | 11/13/1996 |
| From: | Colburn T NRC (Affiliation Not Assigned) |
| To: | NRC (Affiliation Not Assigned) |
| References | |
| NUDOCS 9611190165 | |
| Download: ML17292A591 (31) | |
Text
November 13, 1996 L.ICENSEE:
Washington Public Power Supply System FACILITY:
WPPSS Nuclear Project No.
2 (WNP-2)
SUBJECT:
MEETING
SUMMARY
INSTRUMENT RESPONSE TIME TESTING On October 4,
- 1996, personnel from the Washington Public Power Supply System (the licensee) met with members of the NRC staff in Rockville, Maryland, to discuss the licensee's instrument response time verification program.
The meeting was requested by the licensee to address staff concerns regarding (I) the conduct of selected instrument response time testing at WNP-2 as required by technical specifications, and (2) implementation of NED0-32291, "System Analyses for Elimination of Selected
Response
Time Testing Requirements,"
in accordance with the staff's December 28, 1994, safety evaluation.
A list of attendees is provided in Attachment 1.
The licensee provided a presentation of the background and chronology associated with their implementation of the NEDO document for WNP-2 including related licensing documents.
The licensee included a discussion of its instrument selection criteria, safety analysis, response time verification methodology, procedural modifications and training.
The licensee stated that the response time verification performed at WNP-2 includes all components including sensors, constitutes an alternative methodology for performing response time testing, and continues to meet all technical specification requirements.
The licensee concluded that it implemented an acceptable response time verification methodology consistent with the WNP-2 licensing basis including the technical specification requirements.
The staff indicated that it would consider the additional information provided by the licensee in making its determination on compliance with technical specification response time testing requirements and the acceptability of the licensee's implementation of the NEDO document.
No proprietary information was discussed or provided to the staff at the meeting.
Original signed by:
Timothy G. Colburn, Senior Project Manager Project Directorate IV-2 Division of Reactor Projects III/IV Office of Nuclear Reactor Regulation Docket No. 50-397 Attachments:
1.
Attendance List 2.
Licensee's Handout cc w/atts:
See next page DOCUMENT NAME:
WNP10496.HTS OFC EPey TColburn PDIV-2 LA PDIV-2 PH
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UNITED STATES NUCLEAR REGULATORY COMMISSION WASHINGTON, D.C. 205554001 November 13, 1996 LICENSEE:
Washington Public Power Supply System FACILITY:
WPPSS Nuclear Project No.
2 (WNP-2)
SUBJECT:
MEETING
SUMMARY
INSTRUMENT RESPONSE TIME TESTING On October 4,
- 1996, personnel from the Washington Public Power Supply System (the licensee) met with members of the NRC staff in Rockville, Maryland, to discuss the licensee's instrument response time verification program.
The meeting was requested by the licensee to address staff concerns regarding (1) the conduct of selected instrument response time testing at WNP-2 as required by technical specifications, and (2) implementation of NED0-32291, "System Analyses for Elimination of Selected
Response
Time Testing Requirements,"
in accordance with the staff's December 28, 1994, safety evaluation.
A list of attendees is provided in Attachment 1.
The licensee provided a presentation of the background and chronology associated with their implementation of the NEDO document for WNP-2 including related licensing documents.
The licensee included a discussion of its instrument selection criteria, safety analysis, response time verification methodology, procedural modifications and training.
The licensee stated that the response time verification performed at WNP-2 includes all components including sensors, constitutes an alternative methodology for performing response time testing, and continues to meet all technical specification requirements.
The licensee concluded that it implemented an acceptable response time verification methodology consistent with the WNP-2 licensing basis including the technical specification requirements.
The staff indicated that it would consider the additional information provided by the licensee in making its determination on compliance with technical specification response time testing requirements and the acceptability of the licensee's implementation of the NEDO document.
No proprietary information was discussed or provided to the staff at the meeting.
Docket No. 50-397 Timothy G.
Co urn, Senior Project Manager Project Directorate IV-2 Division of Reactor Projects III/IV Office of Nuclear Reactor Regulation Attachments:
1.
Attendance List 2.
Licensee's Handout cc w/atts:
See next page
Washington Public Power Supply System Nuclear Project No.
2 cc w/atts:
Hr. Greg O. Smith Hail Drop 927M)
WNP-2 Plant General Manager Washington Public Power Supply System P. 0.
Box 968
- Richland, Washington 99352-0968 Hr. Al E. Mouncer (Mail Drop 396)
Chief Counsel Washington Public Power Supply System P.O.
Box 968
- Richland, Washington 99352-0968 Mr. Frederick S. Adair, Chairman Energy Facility Site Evaluation Council P. 0.
Box 43172 Olympia, Washington 98504-3172 Hr. David A. Swank (Mail Drop PE20)
- Manager, Regulatory Affairs Washington Public Power Supply System P.O.
Box 968
- Richland, Washington 99352-0968 Mr. Paul R. Bemis (Hail Drop PE20)
Vice President, Nuclear Operations'ashington Public Power Supply System P.O.
Box 968
- Richland, Washington 99352 Regional Administrator, Region IV U.S. Nuclear Regulatory Commission Harris Tower 5 Pavilion 611 Ryan Plaza Drive, Suite 400 Arlington, Texas 76011-8064 Chairman Benton County Board of Commissioners P.O.
Box 69
- Prosser, Washington 99350-0190 Hr. R.
C. Barr, Senior Resident Inspector U.S. Nuclear Regulatory Commission P.O.
Box 69
- Richland, Washington 99352-0968 H. H. Philips, Jr.,
Esq.
Winston
& Strawn 1400 L Street, N.W.
Washington, DC 20005-3502 Hr. Rodney L. Webring (Hail Drop PE08)
Vice President, Operations Support/PIO Washington Public Power Supply System P. 0.
Box 968
- Richland, Washington 99352 Hs.
Lourdes C.
Fernandez (Hail Drop PE20)
- Manager, Licensing Washington Public Power Supply System P. 0.
Box 968
- Richland, Washington 99352 Hr. J.
V. Parrish Chief Executive Officer 3000 George Washington Way Washington Public Power Supply System P.O.
Box 968 Hail Drop 1023
- Richland, Washington 99352-0968
STRIBUTION w Atts I and 2:
>'ocket File~
PUBLIC~
PDIV-2 Reading*
TColburn*
- KPerkins, WCFO*
~wAtt I:
FHiragl ia/AThadani RZimmerman (RPZ)
JHitchell, EDO JRoe EAdensam WBateman EPeyton ACRS*
OGC*
EJordan (JKR) meeting Participants
- Hard copies
OCTOBER 4
1996 Attachment 1
MEETING WITH WASHINGTON PUBLIC POWER SUPPLY SYSTEM INSTRUMENT RESPONSE TIME TESTING STTEIIOAN E LIEi 5RC R. Zimmerman J.
Roe B. Bateman J.
Dyer J.
Wermiel M. Reinhart J.
Moore T. Colburn J. Mitchell C. Schulten T.
Wambach D. Trimble P. Loeser A. Hodgdon WPPSS P.
Semis R. Webring D. Swank J. Swailes T. Meade BWROG K. Donovan D. Hoffman NEI D. Waters inston 8 Strawn attorne for W PSS P.
Robinson
Attachment 2
MEETING WITH WASHINGTON PUBLIC POWER SUPPLY SYSTEM INSTRUMENT RESPONSE TIME TESTING OCTOBER 4, 1996 HANDOUT MATERIALUSED AT THE MEETING
RESPONSE TIME VERIFICATIONPROGRAM
'I NRC/Supply System One White Flint October 4, 1996
I l
AGENDA
- 1. INTRODUCTION
- 2. WNP-2BACKGROUND
- 3. WNP-2 IMPLEMENTATION
- 4. WNP-2 LICENSING BASIS 5.
CONCLUSIONS 6.
CLOSING RE
BAKRD NOVEMBER 1977 REGULATORY GUIDE 1.118, REVISION 1
ISSUED REGULATORYGUIDE 1.118, REVISION 1 STATES "This guide describes a
method acceptable to the NRC staff of complying with the Commission's regulations with respect to the periodic testing of the protection system and electric power systems for systems import'mt to safety."
BAKRDT REGULATORYGUIDE 1.118, REVISION 1 STATES IN RELATIONTO IEEE 338-1975:
"Therefore, instead of Section 6.3.4 of the standard, the following should be llSCd:
'Response time testing of all safety system equipment per se is not required if, in lieu of response time testing, the response time of safety system equipment is verified by functional testing and or calibration checks where it can be demonstrated that changes in response time beyond acceptable limits are always accompanied by changes in performance characteristics that are detectable during these routine periodic functional tests and/or calibration checks.'"
BAKRDT DECEMBER 20, 1983 WNP-2 LICENSE ISSUED,
- RPS, IAS, AND ECCS TO BE TESTED IAWIEEE 338-1975 AS DOCUMENTED IN FSAR TABLE7.1-3 JANUARY 14, 1994 BWROG ALTERNATE RESPONSE TIME VERIFICATION METHODOLOGY, NED0 32291, SUBMITTEDFOR REVIEW DECEMBER 28, 1994 NRC SER RELATED TO LICENSING TOPICAL REPORT NEDO 32291 ISSUED
BAKRDT DECEMBER 8, 1995 TECHNICAL SPECIFICATION AMENDMENT FOR "IMPROVED" TECHNICAL SPECIFICATION CONVERSION SUBMITTED BY THE SUPPLY SYSTEM MARCH 19, 1996 10CFR50.59 SAFETY EVALUATION COMPLETED FOR USE OF ALTERNATE
RESPONSE
TIME VERIFICATION METHODOLOGYAT WNP-2 JUNE 1996 WNP-2 RE-START WITH
- ALTERNATE
RESPONSE
TIME VERIFICATION PURSUANT TO WNP-2 TECHNICAL SPECIFICATION REQUIREMENTS
P-2 IMPLEME TATI WNP-2 PARTICIPATIONIN NEDO DEVELOPMENT WNP-2 PLANT SPECIFIC APPLICABILITYTO NEDO 32291 CONFIRMED, JUSTIFICATION PROVIDED FOR TWO ADDITIONALCOMPONENT GROUPS NED0 32291 PROVIDES AN ACCEPTABLE ALTERNATE RESPONSE TIMEVERIFICATIONMETHODOLOGY RWCU B LOWDOWN ISOLATION
RESPONSE
TIME VERIFICATION METHOD NOT MODIFIED SINCE IT DID NOT MEET THE IEEE 338 AND SER CRITERIA FOR ACCEPTABILITY
P-2 IMPLEME TATI IA,C TECHNICIANS TRAINED ON ALTERNATE RESPONSE TIME VERIFICATIONMETHODOLOGYAND REQUIREMENTS APPROPRIATE TECHNICAL SPECIFICATION SURVEILLANCE TEST PROCEDURES REVISED VENDOR RECOMMENDATIONSWERE REVIEWED APPLICABLE ROSEMOUNT TRANSMITTER COMMITMENTS MAINTAINED NO CAPILLARYTUBE INSTRUMENTS USED
LI E I
E AL ATI REGULATORYGUIDE 1.118, REVISION 1 STATES "This guide describes a
method acceptable to the NRC staff of complying with the Commission's regulations with respect to the periodic testing of the protection system and electric power systems for systems important to safety."
LI E I
E AL ATI REGULATORYGUIDE 1.118, REVISION 1 STATES IN RELATIONTO IEEE 338-1975:
"Therefore, instead of Section 6.3.4 of the standard, the following should be llsed:
'Response time testing of all safety system equipment per se is not required if, in lieu of response time testing, the response time of safety system equipment is verified by functional testing and or calibration checks where it can be demonstrated that changes in response time beyond acceptable limits are always accompanied by changes in performance characteristics that are detectable during these routine periodic functional tests and/or calibration checks.'"
LI E I
10CFR50.55a (h) Protection systems. For construction permits issued after January 1,
- 1971, protection systems must meet the requirements set forth in editions or revisions of the Institute of Electrical and Electronics Engineers Standard: "Criteria for Protection Systems for Nuclear Power Generating Stations," (IEEE 279) in effect on the formal docket date of the application for a construction permit. Protection systems may meet the requirements set forth in subsequent editions or revisions of IEEE 279 which become effective.
LI E I
Criterion 21 Protection system reliability and testability. The protection system shall be designed for high functional reliability and inservice testability commensurate with the safety functions to be performed.
Redundancy and independence designed into the protection system shall be sufficient to assure that (l) no single failure results in loss of the protection function and (2) removal from service of any component or channel does not result in loss of the required minimum redundancy unless the acceptable reliability of operation of the protection system can be otherwise demonstrated.
The protection system shall be designed to permit periodic testing of its functioning when the reactor is in operation, including a
capability to test channels independently to deterinine failures and losses of redundancy that may have occurred.
OTHER RELEVANTCRITERIA 13, 22, 23, 24, 25, 26, 27
LI E I
WNP-2 TECHNICALSPECIFICATION REQUIREMENTS 1.36 REACTOR PROTECTION SYSTEM RESPONSE TME shall be the time interval from when the monitored parameter exceeds its trip setpoint at the channel sensor until deenergization of the scram pilot valve solenoids.
The response time may be measured by any series of sequential, overlapping, or total steps such that the entire response time is measured.
4.3.1.3 The REACTOR PROTECTION SYSTEM RESPONSE TIME of each reactor trip functional unit shall be demonstrated to be within its limitat least once per 18 months.
Neutron detectors are exempt from response time testing.
Each test shall include at least one channel per trip system 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 system.
LI E I
WNP-2 TECHNICALSPECIFICATION REQUIREMENTS 1.19 The ISOLATIONSYSTEM RESPONSE TME shall be that time interval from when the
.monitored par~uneter exceeds its isolation actuation setpoint at the channel sensor until the isolation valves travel to their required positions.
Times shall include diesel generator starting and sequence loading delays where applicable.
The response time may be measured by any series of sequential, overlapping or total steps such that the entire response time is measured.
4.3.2.3 The ISOLATIONSYSTEM RESPONSE TIME of each isolation trip function shall be demonstrated to be within its limitat least once per 18 months.
Radiation detectors are exempt from response time testing.
Each test shall include at least one channel per trip system 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 isolation trip system.
LI E I
WNP-2 TECHNICALSPECIFICATION REQUIREMENTS 1.12 The EMERGENCY CORE COOLING SYSTEM (ECCS) RESPONSE TIME shaH be
- that time interval from when the monitored parameter exceeds its ECCS actuation setpoint at the channel sensor until the ECCS equipment is capable of performing its safety function, i.e., the valves travel to their required positions, pump discharge pressures reach their required values, etc.
Times shall include diesel generator starting and sequence loading delays where applicable.
The response time may be measured by any series of sequential, overlapping or total steps such that the entire response time is measured.
4.3.3.3 The ECCS RESPONSE TIMEof each ECCS trip function shaH be demonstrated to be within the limitat least once per 18 months.
Each test shall include at least one channel per trip system such that aH channels are tested at least once every N times 18 months where N is the total number of redundant channels in a specific ECCS trip system.
LI ENSIN EVALUATION ONT THE STAFF STATED IN THE SER FOR NEDO 32291 "the guidance in IEEE 338 is satisfied by performance of calibration as an alternative to specific RTT for delays greater than five seconds."
THE STAFF ALSO STATED IN THE SER FOR NEDO 32291 "The staff has deternuned that calibration and other surveillance testing, combined with technician awareness of the RTT requirement, will adequately ensure that the response time is verified for the devices identified in Table 1 when the devices are used in systems listed in Table 2."
LI E I
THE ABOVE STAFF POSITIONS DESCRIBE AN ACCEPTABLE ALTERNATE RESPONSE TIME VERIFICATION METHOD AS REQUIRED BY RG 1.118 ALTERNATE RESPONSE TIME VERIFICATION/DEMONSTRATION CONTINUES AT WNP-2 PER THE REQUIREMENTS OF TSs/RG
- 1. 118/IEEE-338/NEDO/SER
LIE I
ONCLUSI NS REGULATORY GUIDE 1.118, REVISION 1 AND IEEE 338-1975 PROVIDE WNP-2 WITHTHE FLEXIBILITYTO USE ALTERNATERESPONSE TIME VERIFICATIONMETHODOLOGIES NEDO 32291 AND THE ASSOCIATED SER PROVIDE A REVIEWED AND APPROVED ALTERNATE
RESPONSE
TIME VERIFICATION METHODOLOGY WNP-2 IMPLEMENTED AN ACCEPTABLE
RESPONSE
TIME VERIFICATIONMETHODOLOGY CONSISTENT WITH THE LICENSING BASIS FOR WNP-2, INCLUDING THE TECHNICAL SPECIFICATION REQUIREMENTS
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November 13, 1996 LICENSEE:
Washington Public Power Supply System FACILITY:
WPPSS Nuclear Project No. 2,(WNP-2)
SUBJECT:
MEETING
SUMMARY
INSTRUMENT RESPONSE TIME TESTING On October 4,
- 1996, personnel from the Washington Public Power Supply System (the licensee) met with members of the NRC staff in Rockville, Maryland, to discuss the licensee's instrument response time verification program.
The meeting was requested by the licensee to address staff concerns regarding (1) the conduct of selected instrument response time testing at WNP-2 as required by technical specifications, and (2) implementation of NED0-32291, "System Analyses for Elimination of Selected
Response
Time Testing Requirements,"
in accordance with the staff's December 28, 1994, safety evaluation.
A list of attendees is provided in Attachment l.
The licensee provided a presentation of the background and chronology associated with their implementation of the NEDO document for WNP-2 including related licensing documents.
The licensee included a discussion of its instrument selection criteria, safety analysis, response time verification methodology, procedural modifications and training.
The licensee stated that the response time verification performed at WNP-2 includes all components including sensors, constitutes an alternative methodology for performing response time testing, and continues to meet all technical specification requirements.
The licensee concluded that it implemented an acceptable response time verification methodology consistent with the WNP-2 licensing basis including the technical specification requirements.
The staff indicated that it would consider the additional information provided by the licensee in making its determination on compliance with technical specification response time testing requirements and the acceptability of the licensee's implementation of the NEDO document.
No proprietary information was discussed or provided to the staff at the meeting.
Original signed by:
Timothy G. Colburn,'enior Project Manager Project Directorate IV-2 Division,of Reactor Projects III/IV Office of Nuclear, Reactor Regulation Docket No. 50-397 Attachments:
1.
Attendance List 2.
Licensee's Handout cc w/atts:
See next page DOCUMENT NAME:
WNP10496.HTS OFC NAME DATE PDIV-2 LA PDIV-2 PH TColburn kl
]3/96 EPey on l
96 OFFICIAL RECORD COPY
r5 r
)
,f I
II