ML18005A572

Discusses Util Understanding of NRC 880714 SER Re Compliance W/Atws Rule 10CFR50.62.In Order to Facilitate Presentation of Clarification,Relevant Text for Safety Evaluation Provided Per Util Clarifying Remarks

ML18005A572
Person / Time
Site:	Harris
Issue date:	08/26/1988
From:	Loflin L CAROLINA POWER & LIGHT CO.
To:	NRC OFFICE OF ADMINISTRATION & RESOURCES MANAGEMENT (ARM)
References
NLS-88-196, TAC-64561, NUDOCS 8809080031
Download: ML18005A572 (7)

Text

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'ACCETMRATED DISTRIBUTION DEMONSTRATION SYSTEM REGULATORY INFORMATION DISTRIBUTION SYSTEM (RIDS)

ACCESSION NBR:8809080031 DOC.DATE: 88/08/26 NOTARIZED: NO FACIL:50-400 Shearon Harris Nuclear Power Plant, Unit 1, Carolina AUTH.NAME AUTHOR AFFILIATION LOFLIN,L.I.

Carolina Power

& Light Co.

RECIP.NAME RECIPIENT AFFILIATION Document Control Branch (Document Control Desk)

DOCKET 05000400 I

ill 05000400 NOTES:Application for permit renewal filed.

SUBJECT:

Discusses util understanding of NRC 880714 SER re compliance w/ATWS Rule 10CFR50.62.

DISTRIBUTION CODE:

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General Distribution

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NLS-88-196 10CFR50.62 United States Nuclear Regulatory Commission.

ATTENTION: Document Control Desk Washington, DC 20555 SHEARON HARRIS NUCLEAR POWER PLANT DOCKET NO. 50-400/LICENSE NO. NPF-63 SAFETY EVALUATION FOR THE SHNPP AMSAC SYSTEM REFERENCE')

Safety Evaluation re:

Shearon Harris Nuclear Power Plant (SHNPP), Unit 1 compliance with the Anticipated Transient Without Scram (ATWS) Rule 10 CFR 50.62 (Tac No. 64561),

dated July 14, 1988 2)

CP&L correspondence dated April 12, 1988 (NLS-88-084);

Item 12, Attachment pages 4 through 7 of 12 Gentlemen:

Carolina Power

& Light (CP&L) has received and reviewed the subject safety evaluation in reference 1.

In order to ensure t:here is a clear underst:anding of our commitments regarding AMSAC design and testing and the staff's concurrence with those commitments, CP&L herein documents our understanding of the safety evaluation on three specific points.

The clarifications that follow deal with statements from Item 12 "Testability at Power" in Section 3.0 "Evaluation and Discussion" of the safety evaluation.

In order to facilitate presentation of the clarifications the relevant text of the safety evaluation is quoted below followed by CP&L's clarifying remarks.

Clarification 1

The safety evaluation states:

"The licensee stated that a complete end-to-end test of the AMSAC system, including the AMSAC outputs through the final actuation device, will be performed during each refueling outage.

With the plant at

power, the system can be tested with the AMSAC outputs bypassed.

The testing capability will consist of a series of overlapping tests.

These tests willverify analog channel

accuracy, and coincidence logic operation, including the operation and accuracy of all timers.

In addition, the self-monitoring and automatic check features of the micro-411 Fayettevilte Street

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processors are always active, and the control room operators will be alerted automatically if any anomaly is detected."

"At power tests will be performed with the AMSAC outputs bypassed.

This bypass will be accomplished through a

permanently installed bypass switch which negates the need to lift leads, pull fuses, trip breakers, or physically block relays.

The discussion of AMSAC system testing ca abilities is correct, however it may lead one to believe that these overlapping tests, including analog channel accuracy, coincidence logic operation and timer operation/accuracy will be performed at power.

Carolina Power

& Light committed to perform these overlapping end-to-end tests during refueling as provided in the staff's guidance associated with the rule (reference 2).

Due to the redundant design of the SHNPP AMSAC processor and the automatic self-test

features, testing at a frequency greater than once per eighteen months was not warranted or committed to.

Analog input channel accuracy testing was committed to be performed as part of the current outage based testing for the steam generator level instruments.

Output actuation capability downstream of the bypass switch can not be performed at power.

Like the input loops, the actuation circuitry will be tested on a refueling basis as part of the existing Auxiliary Feedwater System circuits tests.

Although the AMSAC processors have considerable at-power-testing capabilities, the capabilities are viewed as troubleshooting tools which will come into play only if the system's extensive self-checking capabilities indicate a problem.

Clarification 2

In the last paragraph of Section 12, the safety evaluation stated that "It is the staff's understanding that the licensee will conduct a human-factors review of the controls and indications.used for te ting purposes consistent with the plant's detailed control room design process."

This statement is correct when read within the context of the commitments CP&L made regarding human factors reviews e.g.,

human factors reviews will be performed on control room modifications.

Some of the "indications" used for testing purposes are not in the control room or on the auxiliary control panel and therefore are not subject to human factors reviews.

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Document Control Desk NLS-88-196 / Page 3

Clarification 3

Also in Section 12, the safety evaluation stated "Status outputs to the plant computer and main control board, indicating that a general warning condition exists with AMSAC, will be initiated when the system's outputs are bypassed."

The above statement is correct in that bypass status indication will be in the control room, however, it is not provided to the plant computer.

The only status output provided to the plant computer is for AMSAC 'trip'.

Please refer any questions regarding this submittal to Mr. Steven Chaplin at (919) 836-6623.

Yours very truly, Leonard I.

oflin Manager Nuclear Licensing Section LIL/SDC cc:

Mr. B.

C. Buckley Dr. J. Nelson Grace Mr.

W. H. Bradford

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