GO2-97-057, Application for Amend to License NPF-21,modifying Response Time Testing Surveillance Requirements for RPS Instrumentation,Primary Containment Isolation Actuation Instrumentation & ECCS Actuation Instrumentation
| ML17292A756 | |
| Person / Time | |
|---|---|
| Site: | Columbia |
| Issue date: | 03/22/1997 |
| From: | Bemis P WASHINGTON PUBLIC POWER SUPPLY SYSTEM |
| To: | NRC OFFICE OF INFORMATION RESOURCES MANAGEMENT (IRM) |
| Shared Package | |
| ML17292A757 | List: |
| References | |
| GO2-97-057, GO2-97-57, NUDOCS 9704010339 | |
| Download: ML17292A756 (40) | |
Text
CATEGORY.j.
REGULAT(
INFORMATION DISTRIBUTIONSTEM (RIDE)
I ACCESSION NBR:9704010339 DOC.DATE: 97/03/22 NOTARIZED: YES
" FACIL:50-397 WPPSS'uclear Project, Unit 2, Washington Public Powe AUTH.NAME AUTHOR AFFILIATION BEMIS,P.R.
Washington Public Power Supply System RECIP.NAME RECIPIENT AFFILIATION Document Control Branch (Document Control Desk)
SUBJECT:
Application for amend to license NPF-2l,modifying response time testing surveillance'equirements for RPS Instrumentation, Primary Containment Isolation Actuation Instrumentation
& ECCS Actuation Instrumentation.
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WASHINGTONPUBLIC POWER SUPPLY SYSTEM P.O. Box 968
~ Richland, Washington 99352-0968 March 22, 1997 G02-97-057 Docket No. 50-397 wU.S. Nuclear Regulatory Commission Attn: Document Control Desk Washington, D.C.
20555 Gentlemen:
Subject:
WNP-2, OPERATING LICENSE NPF-21 REQUEST FOR AMENDMENT,UNDER EXIGENTCIRCUMSTANCES, TO OPERATING LICENSE REGARDING TECHNICAL SPECIFICATION RESPONSE TIMETESTING
References:
1)
Letter GO2-97-056, JV Parrish (SS) to NRC, "Request for Enforcement Discretion to Technical Specification Response Time Testing Requirements, dated March 20, 1997.
2)
Letter GO2-94-160, JV Parrish (SS) to NRC, "Request for Amendment to the Technical Specifications, Relocation of Technical Specification Tables for Instrument Response Time Limits," dated July 12, 1994.
3)
Letter JW Clifford(NRC) to JV Parrish (SS), "Issuance of Amendment for the Washington Nuclear Power Supply:System Nuclear Project No. 2 (TAC NO. M89907)," dated June 26, 1995.
4)
Generic Letter 93-08, "Relocation of Technical Specification Tables of Instrument Response Time Limits," dated December 29, 1993.
5)
GE Nuclear Energy, BWR Owners'roup Licensing Topical Report, NEDO-32291-A, "System Analysis for the Elimination of Selected Response Time Testing Requirements,"
dated October, 1995.
6)
Letter TP Gwynn (NRC) to JV Parrish (SS), "Response Time Measurement in Accordance with Technical Specification Surveillance Requirements,"
dated March 20, 1997.
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Page 2 REQUEST FOR AMENDMENTTO OPERATINGLICENSEREGARDINGTECHNICAL SPECIFICATION RESPONSE TIMETESTING In accordance with the Code of Federal Regulations, Title 10, Parts 50.59, 50.90 and 2.101, the Supply System hereby submits a request for amendment, under exigent circumstances, to the WNP-2 Operating License.
Specifically, the Supply System is requesting modification of response time testing (R1T) surveillance requirements for Reactor Protection System (RPS)
Instrumentation, Primary ContainmentIsolation Actuation Instrumentation, and Emergency Core Cooling System (ECCS) Actuation Instrumentation.
Approval is requested by April 18, 1997.
This Technical Specification change request is submitted consistent with the Reference 1
commitment and the approval of this change willresolve the need for enforcement discretion.
The proposed change would revise the following surveillance requirements (SR):
SR 3.3.1.1.15 SR 3.3.5.1.7 SR 3.3.6.1.7 SR 3.5.1.8 Reactor Protection System (RPS) Response Time, Functions 3 and 4o Emergency Core Cooling System (ECCS)
Response
Time (relocated);
Primary Containment Isolation System Response Time, Functions 1.a, 1.b, and 1.c; and ECCS Operating (new).
The change to SR 3.3.1.1.15 and SR 3.3.6.1.7 adds a note that allows the sensor to be excluded from response time testing when verifying that the response time is within limits. The ECCS response time testing (SR 3.3.5.1.7) is being relocated to the new ECCS Operating Technical Specification SR 3.5.1.8. A note similar to that added to SR 3.3.1.1.15 and 3.3.6.1.7 is added to the new SR 3.5.1,8 to clarify that no actuation instrumentation response time measurement is required.
No new SR is added to the ECCS Shutdown specification.
The current SR 3.3,5.1.7 requires that the SR be met when the supported system is required to be OPERABLE.
The requirement that the SR be met in MODES 1, 2, and 3, but not in MODES 4 and 5, is therefore a relaxation.
BACKGROUND Reference 2 requested, and Reference 3 authorized, relocation of RPS, Primary Containment Isolation Actuation, and ECCS instrumentation RTT tables from the Technical Specifications to the Final Safety Analysis Report (FSAR) consistent with Reference 4 recommendations.
The RTT tables were relocated to the FSAR and subsequently to the Licensee Controlled Specifications (LCS). The LCS contains technical requirements which do not meet the criteria for inclusion in the WNP-2 Technical Specifications.
The LCS changes must therefore be reviewed in accordance with the requirements of 10CFR50.59.
REQUEST FOR AMENDMENTTO OPERATINGLICENSEREGARDINGTECHNICAL SPECIFICATION RESPONSE TIME TESTING The Supply System reviewed the implementation requirements for the Reference 5 methodology.
In April 1996, the Supply System opted for implementation of the Reference 5 methodology via the 10CFR50.59 process and concluded that the method did not constitute a change to the Technical Specifications, a change in the facility or procedures described in the safety analysis report, or involve tests or experiments not described in the safety analysis report.
The Supply System concluded that there was no unreviewed safety question.
Consistent with Reference 5 guidelines, the Supply System retained, in individual specifications, surveillance requirements for demonstration of instrumentation system response time, within its limit, on an 18 month interval.
Consistent with the Reference 5 guidelines and staff SER, the Supply System concluded that the revised methodology met this requirement.
The decision to implement a change in the methodology used to verify response times are within limits was subjected to further review and was the subject of Special Inspection 96-22 in September 1996.
As a result of that inspection, the staff has concluded that the implementation of the Reference 5 changes involves a change to the Technical Specifications and as such required NRC approval prior to implementation.
Due to the short time period available to prepare this request for amendment to the Technical Specifications, the Supply System has not had the opportunity to review in detail the staff's positions presented in Reference 6 for the basis that a non-compliance with the Technical Specifications has occurred.
As such, the Supply System makes no statement regarding agreement or disagreement with the position presented by the staff.
The proposed Technical Specification changes are supported by an analysis performed by the BWR Owners'roup (Reference 5) demonstrating that other periodic tests required by Technical Specifications, such as channel calibrations, channel checks, channel functional tests, and logic system functional tests, ensure that the instrument response is acceptable.
The Supply System has verified the applicability of the reference analysis to WNP-2.
In addition, two categories of components were included in this change in testing methodology which were not identified in the table of components in Reference 5.
- However, these components are used within the logic circuits addressed in Reference 5. These components were inadvertently omitted from lists provided to General Electric in support of preparation of the Reference 5 tables.
These components have been reviewed for similarity to the items contained within the Reference 5 component tables and have been found to be similar to other equipment referenced in the table.
These components are also subject to periodic functional testing by CFTs and LSFTs.
The Supply System verifies instrument response of these components at an appropriate interval using the alternate methodology described in Reference 5.
Presently the Applicability(and therefore the SR) for the ECCS actuation instrumentation is for all MODES in which the associated ECCS is required to be OPERABLE. This request would change the Applicabilityto MODES 1, 2 and 3.
The basis for this change is that there are no design basis events which credit ECCS during MODES 4 and 5. The response time tests which are typically performed during shutdown condition would identify operability problems that may exist.
In addition, due to the pressure and temperature limitations of MODES 4 and 5, the
4 Page 4 REQUEST FOR AMENDMENTTO OPERATING LICENSEREGARDINGTECHNICAL SPECIFICATION RESPONSE TIMETESTING probability of an accident is reduced, as is the need for ECCS to respond within the times established for MODES 1, 2, and 3. This change has been approved by the staff for the Clinton Power Station and the Perry Nuclear Power Plant as part of their implementation of the Reference 5 recommendations.
Attachment 1 provides the basis for the change request. contains mark-ups of the proposed changes to the Technical Specifications. provides the No Significant Hazards Consideration and Environmental Considerations evaluations.
The Supply System has concluded that the proposed change to the WNP-2 Technical Specifications does not result in a significant hazards consideration.
In addition, the change meets the eligibility criteria for a categorical exclusion as set forth in 10CFR51.22(c)(9).
Therefore, in accordance with 10CFR 51.22(b), an environmental assessment of the change is not required.
The Technical Specification amendment request has been reviewed and approved by the WNP-2 Plant Operations Committee and the Supply System Corporate Nuclear Safety Review Board.
In accordance with 10CFR50.91, the State of Washington has been provided a copy of this letter.
Should you have any questions or desire additional information regarding this matter, please call me or D. A. Swank at (509) 377-4563.
Respectfully
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ce resident Nuclear Operations Mail Drop PE23 Attachments:
1) 2)
3)
Basis for the Change Request.
Revised Technical Specification Pages No Significant Hazards Consideration and Environmental Considerations Evaluations.
cc:
EW Merschoff - NRC RIV KE Perkins, Jr. - NRC RIV, Walnut Creek Field Office TG Colburn - NRR NRC Sr. Resident Inspector - 927N DL Williams - BPA/399 R Wallis - EFSEC PD Robinson - Winston & Strawn
STATE OF WASHINGTON)
)
COUNTY OF BENTON
)
Subject:
Request for Amendment to TS Res on e Time Te tin I, P. R. BEMIS, being duly sworn, subscribe to and say that I am the Vice President, Nuclear Operations for the WASHINGTONPUBLIC POWER SUPPLY SYSTEM, the applicant herein; that I have the fullauthority to execute this oath; that I have reviewed the foregoing; and that to the best of my knowledge, information, and belief the statements made in it are true.
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B Vj e President, Nuclear Operations On this date personally appeared before me P. R. BEMIS, to me known to be the individual who executed the foregoing instrument, and acknowledged that he signed the same as his free act and deed for the uses and purposes herein mentioned.
GIVEN under my hand and seal this~day of 199$
Public in and or e
STATE OF WASHINGTON Residing a My Commission Expires
REQUEST FOR AMEN ENT TO OPERATING LICENSE GARDING TECHNICAL SPECIFICATION RESPONSE TIMETESTING Attachment 1
Page 1 of 5 Back round:
This proposed change would modify the Technical Specifications response time testing requirements for selected instruments.
Specifically, the response time testing requirements to be eliminated include sensors and specified loop instrumentation for Reactor Protection System (RPS), Primary Containment Isolation Actuation, and Emergency Core Cooling System (ECCS).
An analysis has been performed demonstrating that other periodic tests required by'Technical Specifications, such as channel calibrations, channel checks, channel functional tests, and logic system functional tests provide adequate assurance that instrument responses are within acceptance limits. The Reference 1 evaluation concludes that response time tests are ofno safety significance, cause unnecessary personnel exposure, reduce availability of safety systems during shutdown, and are a significant burden to utilityresource, Regulatory Guide 1.118 (Revision 2) states:
. "Response time testing of all safety related equipment, per se, is not required if, in lieu of response time testing, the response time of the safety equipment is verified by functional testing, calibration checks or other tests, or both. This is acceptable ifit can be demonstrated that changes in response time beyond acceptable limits are accompanied by changes in performance characteristics which are detectable during routine tests."
The Reference 1 generic analysis provides the basis for eliminating selected response time testing requirements.
The analysis was performed for two representative BWRs, and its applicability to WNP-2 has been verified by the Supply System.
The list of affected instrument loop components is provided in Table 1 of this attachment.
The analysis includes the identification ofpotential failure modes of components in the affected instrumentation loops which could potentially impact the instrument loop response time.
In addition, plant operating experiences were reviewed to identify response time failures and detection method.
The failure modes identified were then evaluated to determine ifthe effect on response time would be detected by other testing requirements contained in Technical Specifications.
The results of these analyses demonstrate that other Technical Specification testing requirements (channel calibration, channel checks, channel function test, and logic system functional test).
In conjunction with actions taken in response to NRC Bulletin 90-01, "Loss of Fill-Oilin Transmitters Manufactured by Rosemount,"
and Supplement 1, are normally sufficient to identify failure modes or degradations in instrument response time and assure operati'on of the analyzed instrument loops within acceptable limits. Furthermore, all known failure modes that are detected by response time testing are also detected by other Technical Specification tests.
REQUEST FOR AME ENT TO OPERATING LICENSE GARDING TECHNICAL Cr SPECIFICATION RESPONSE TIMETESTING Attachment 1
Page 2 of 5 The Supply System has updated WNP-2 test procedures to direct that the instrument technicians evaluate response time delays in instrumentation.
A Reference 1 survey has concluded that changes in instrument response time delays from instantaneous up to five seconds can be reasonably detected by instrument technicians.
The primary basis for implementation of the Reference 1 methodology is that the qualitative response time, in conjunction with normal instrument loop calibrations and other logic and system functional tests required by Technical Specifications, ensure that the safety system actuations required by the Safety Analysis are unchanged.
Within a trip function, redundancy exists in individual instrument channels (e.g.,
1 out of 2 twice) and diversity exists in most safety trip functions (e.g., neutron flux, water level, drywell pressure).
Also, for most of these instruments, the response'times are insignificant compared to the safety system actuation times.
The Reference 1 evaluations demonstrate that response time testing can be eliminated for the following:
1)
Sensors for selected Reactor Protection System actuation; 2)
AllPrimary Containment Isolation System actuation instrument loops except main steam line isolation valves (MSIVs);
3)
Sensors for MSIV closure actuation; and 4)
AllEmergency Core Cooling System instrument loops.
In addition to application of Reference 1 recommendations, the Supply System addressed the following requirements from Reference 1:
(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 RTI'hall be performed to determine an initial sensor-specific response time value:
WNP-2 workprocesses have been revised to ensure appropriate response time testing is performed prior to installation.
(b)
For transmitters and switches that use capillary tubes, capillary tube testing shall be performed after initialinstallation and after any maintenance or modification activity that could damage the lines.
WNP-2 does not use transmitters or switches that use capillary tubes in applications that require response time testing.
Future use ofinstrumentation using capillary tubes for selected instrument application willbe restricted.
Therefore, this recommendation is not applicable to WNP-2.
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REQUEST FOR AME ENT TO OPERATING LICENSE GARDING TECHNICAL SPECIFICATION RESPONSE TIMETESTING Attachment 1
Page 3 of 5 The NRC SER endorsement of the Reference 1 methodology states that the licensee submittals must state the following in the request, (a)
That calibration is being done with equipment designed to provide a step function or fast ramp in the process variable.
Each applicable calibration procedure was revised to include steps that direct the technician to insert a fast ramp or step function that beginsjust outside the setpoint and continues to a value wellpast the setpoint, (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.
This training has been completed and applicable calibration procedures have been revised, as necessary, to assure monitoringfor response time degradation.
(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 units under test.
Applicable calibration procedures have been revised to require the technicians, at diferent locations, to be in direct communication to verify the response of the instrumentation or associated logic.
(d)
That 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-Oilin Transmitters Manufactured by Rosemount."
Compliance with the guidelines ofSupplement 1 to the NRC Bulletin 90-01 was reviewed and documented in Reference 4.
The Reference 4 evaluation concluded that the Supply System's responses to 90-01 and Supplement 1 conform to the requested actions ofNRC Bulletin 90-01 Supplement l.
(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 RTI's nevertheless acceptable for the particular application involved.
The Supply System has reviewed the vendor information for the Reference 1, Table 1 components and conftrmed that none ofthe manufacturers require periodic response time testing for their instrumentation or logic components.
REQUEST FOR AMEIOIENTTO OPERATING LICENSE GARDING TECHNICAL SPECIFICATION RESPONSE TIMETESTING Attachment 1
Page 4 of 5 WNP-2 specific evaluations demonstrate that response time testing may also be eliminated for the following:
1)
Four (4) Reactor Core Isolation Cooling pressure switches, Barksdale model P1H-M340SS-V; and 2)
Auxiliary relays, manufactured by ASEA (now ABB), model RXMK1 for reactor building ventilation exhaust.
This model of Barksdale pressure switche was not evaluated in the Reference 1 analysis.
The RCIC pressure switches are safety-related, Quality Class Iand provide highly reliable operation.
These switches function to isolate the system when reactor pressure has been reduced to the point where it can no longer support RCIC turbine operation and to provide long term secondary containment leakage control.
These pressure switches are not credited within any WNP-2 accident analysis.
The equipment actuated by these pressure switches are motor operated valves which similarly have no specified required accident mitigation operating closure time limits.
Therefore, a specific pressure switch response time is not necessary to maintain the results of the current accident analysis.
These pressure switches are routinely tested as part of channel calibration, channel functional tests, and logic system functional tests.
The ASEA relay model has a secondary containment isolation function in the reactor building ventilation exhaust, Only ASEA relay model RXMH2 was evaluated and approved by the Reference 1 analysis.
The model RXMK1 is of the same model series as the RXMH2 which was evaluated by the Reference 1 analysis.
Manufacturer's data indicates that the model RXMK1is a faster operating relay than the RXMH2relay as identified by pick-up and drop out times.
The RXMK1 is approximately a half-size model of the RXMH2 and accordingly houses half the contacts and contains half the case mass.
The manufacturer's relay parts list indicates that both models use numerous identical parts.
A review of the manufacturer's component inspection procedures indicate identical or consistent relay inspections and/or testing practices for both models.
The seismic qualification envelopes both models with the same test.
Both passed the minimum contact chatter tests.
The two models have been environmentally qualified by separate tests.-
A review ofNPRDS data indicates no reported failures of the RXMK1 relay type.
One failure of the NRC approved model RXMH2 was reported at one of the Turkey Point plants.
This failure resulted from a displaced contact.
This failure mode is possible with the RXMK1.
However, a review ofWNP-2 operating experience data indicates no reported failures of the E-RLY-CRAX, CRAY, CRBX, or CRBY relays (Model RXMK1 relays).
The low failure rate, coupled with other surveillances, provide assurance of continued functionality.
Elimination of the RTT for these components is consistent with the analysis and review scope of the Reference 1 analysis.
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A REQUEST FOR AMENDMENTTO OPERATING LICENSE 1%ARDING TECHNICAL SPECIFICATION RESPONSE TIMETESTING Attachment 1
Page 5 of 5
References:
1.
GE Nuclear Energy, BWR Owners'roup Licensing Topical Report, NEDO-32291-A, "System Analysis for the Elimination of Selected Response Time Testing Requirements,"
October, 1995.
2.
'PRI, Report No. NP-72-43, "Investigation of Response Time Testing Requirements,"
May 1991.
3.
4.
Letter 602-90-125, GC Sorensen (SS) to NRC "Response to NRC Bulletin 90-01: Loss of Fill-Oilin Transmitters Manufactured," dated July 12, 1990.
Letter JW Clifford (NRC) to JV Parrish, Response to NRC Bulletin 90-01, Supplement 1, "Loss of Fill-Oilin Transmitters Manufactured," dated August 3, 1994.
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TABLE t LPCS/RHR G INSTRUMENTATION Interfacin Refa Energizes relays RHR-RLY-K93A,K95A, K70A, K18A, K28A. K23A. 8 K24A.
IRHR-RLY-K9A IGE IHFA Page 2
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TABLE 1
'PCS INSTRUMENTATION IHPCS DESCRIPTION IFUNCTION I
I DEWCE EPN IMFG IMODEL Level Indicatin Switch Interfacin Rela Senses RPV Level; signal to HPCS-RLY~, K8, K17, and K18 Energize relays HPCS-RLY-K3, K9, K38, and K35 to initiate s
tern start MS%35-21AM BARTON HPCSHLY-K7, K8, K17. and K18 GE 288A HFA Pressure Switch Interfacin Rela Interfacin Rela Senses Dryweli pressure; signal to HPCSHLY-KS, K6, K15, and K16 Ene izerela HPCS-RLY-K24 IEne ize refa HPCS-RLY-K3. K9, K38. and K39 Press Switch MSPS-47A-D SOR HPCS-RLY-K5, K6, K15. and K16 GE HFA HPCS-RLY-K24 IGE IHMA Iniatlon Rela IStarts: DG C!oses: F010, F023. E22BK14 lniatlon Re!a IO ens: F001, F004 Cases: F011 HPCS-RLY-K3 GE IHFA HPCS-RLY~
GE IHFA Iniatlon Reia IStarts: HPCS-P1 E22BK14 GE IHMA Page 4
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TABLE 1 RWCU A INSTRUMENTATION DESCRIPTION RWCV A FLOW Hl FT41 FUNCTION DEVICE EPN MFG IMODEL Differential Pressure Transmitter Converts Differential Pressure to an eiectrical signal for processing by square root extractor RWCUNQRT~ via si nal resistor unit i&SR U-1 for scalin RWCU-FTA1 E31-N041 Rosemount 1153DB5PA S uare Root Extractor Converts electrical signal proportional to differential pressure from RWCU-FT&1 to electrical flowsignal output to Leak RWCU-SQRT~
Detection Sunimer L~um~
E31-K603 Baile 750010AAAE1 Summer Flow Switch Flow Switch Differential Pressure Transmitter Leak Detection Flow Summer.
RWCU hi h differential Itow, div. 1 isolation.
RWCU hi h differential liow, div. 2 Isolation Converts Differential Pressure to an electrical signal for rocessin b sauare root extractor RWCUNQRT~2 LOWUM~
E31 K604 LD-FS45A E31 N605A LChF$4058 E31-N6058 RWCU-Fit E31-N036 Baile Baiie Baile Rosemount 75241 0AAAEI 745110AAAE I 745110AAAE1 11530 BSPA S uare Root Extractor Converts eiecbical signal proportional to differential pressure from RWCU-F i46 to electrical flowsignal output ot Leak RWCUNQRT~
Detection Summer LO<um~
E31-K602 Baile 750010AAAEI Flow Element Differential Pressure to Flow Transmitter RWCU-FT-15 RWCU-FE-11 G33 N011 Vickery Simms HTK51292 Differential Pressure Transmitter Converts Differential Pressure to an electncal signai (or
) RWCU-FT-15 rocessin snuare root extractor RWCUNQRT~
lE31 N015 Rosemount 11530 B5PA Sauare Root Extractor converts electrical signal proponional to differential pressure from RWCU-FT-15 to electrical flowsignal output ot Leak RWCUQQRT&5 Detection Summer LD<um4&t E31 K605 Bailev 75M10AAAEI Page 10
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Interfacln Rela
. TABLE 1 PRIMARYCONTAINMENT INSTRUMENTATION O~nergized from relays MS-RLY-KTCand -K70 to auto-close MS-V-16 822-F01 MS-RLY-K56 822H~
A stat EGP Rela Interfacin Rela Interfacin Re!a Ownergized from relays MS-RLY-K1C and -K10 to auto-close RWCV-V-1 G33-F001 Owner ized from rela MS-RLY-K1C and -K10 MS-RLY-K26 822H-MS-RLY459 822H-K59 G.E.
G.E.
HFA Rel HFA Re!a lnterfacin Rela Interfacin Rela Interfacin Rela interfacin Rela Interfacin Reia Interfactn Rcia Ownergized from relay MS-RLY-K59to auto4ose FOR-V 3 G11-F003 Dwnergtzed from relay MS-RLY-K59to autodose EOR-V 19 G11-F019 Dm ized from rela MS-RLY-K1Cand K10 De-energized from relay MS-RLY-K72to aututose RRC-V 19 835-F019)
Oeene ized from rela MS-RLY-K1Cand K1D Dwnergized from relay MS-RLY-K82for TIP Withdaw Command MS-RLY-K91 822H-K91 MS-RLY-K95 822H-MS-RLY-K72 822H~
MS-RLY~9 822-K99 MS-RLY-K62 822H-K82 MS-RLY-K120 822-K120)
A astat EGP Rela A
stat EGP Reia A
stat EGP Rel A astat EGP Reh A
stat EGP Rela A
stat EGP Reh Page 18