ML20043C567

Discusses Identification of Slave Relays Tested Using Alternative Methodology,Per 900402 Commitment.Encl Tabulation Identifies Test Type,Applicable Procedures & Equipment & Impact of Improper Documentation

ML20043C567
Person / Time
Site:	Comanche Peak
Issue date:	06/01/1990
From:	William Cahill TEXAS UTILITIES ELECTRIC CO. (TU ELECTRIC)
To:	NRC OFFICE OF INFORMATION RESOURCES MANAGEMENT (IRM)
References
TXX-90202, NUDOCS 9006050331
Download: ML20043C567 (18)

Text

-

P P (i

i_

1 B

I , M

?* lllll"l' 'llllllll Log # TXX 90202

!.-  :: File # 907.3

~

F 3 Ref # 10CFR50.34(b)

RIELECTRIC June 1, 1990 Wike J. Cahill, Jr.

becuttw Vwe Prendent U. S. Nuclear Regulatory Commission Attn Document Control Desk Washington D. C. 20555

^

SUBJECT:

COMANCHE PEAK STEAM ELECTRIC STATION (CPSES)

DOCKET NO. 50 445 IDENTIFICATION OF SLAVE RELAYS TESTED USING ALTERNATE METHODOLOGY U

REF: TV Electric letter logged TXX-90129 from Mr. William J. Cahill, Jr.,

to NRC, dated April 2, 1990 m

_ Gentlemen:

y- On September 8, 1989, TU Electric FSAR Section 7.3 was amended to describe an additional method (e.g., installing jumpers, lifting leads) for testing Engineered Safety Features (ESF) Systems slave relays. A working session was

- held at CPSES on January 30, 1990, between TU Electric and the NRC to discuss 5 the applicable circuits to be tested using the additional methodology and the E use of jumpers or lifting leads to conduct testing. In the referenced letter, 5 TV Electric committed to provide documentation regarding each circuit being terted by June 1, 1990.

Identified in the attached tabulation is the test type, applicable procedures and equipment, impact of improper restoration, and potential design changes.

Also attached are simplified sketches of the test circuit- configuration for E- each test case.

E Table I describes the utilization of jumpers and lif ted leads for "Go Testing" (actual equipment operation). Table II describes the utilization of jumpers g

and lifted leads for Westinghouse circuits that are supplied with " block circuits" (prevents equipment movement). Table III describes the utilization

, of jumpers or lifted leads to prevent equipment actuation during testing. In each test case, TV Electric concludes that the current test methodology is

- justified without a design change.

[ In summary, TU Electric has reviewed the slave relay tests which utilize jumpers or lif ted leads as part of the test configuration. In all cases, the L-

- current test configuration is considered justified since failure to remove a jumper or properly re-land leads either would not create an unsafe condition.

or for those few cases where failure to remove a jumper or properly re-land a g lead would create a condition that is undesirable, procedures are in place

=

h T988E h

M8886 PDC

=

400 North Olive Street LB. 81 Dallas, Texas 75201 OM F 81 i

=..

l TXX 90202 Page 2 of 2 which explicitly require the removal of test jumpers and/or the re landing of leads. Based on the current test frequency of once per quarter T'J Electric feels that the existing procedures provide adequate assurance that the equipment is restored to its pre-test condition and will perform as intended when required.

If there are any questions, please contact Randy Morrison at (817) 897-5679 or Veronica Cornell at (214) 812-8886.

Sincerely, William J. Cahill, Jr.

By:

J. S. Marshall Generic Licensing Manager VPC/vid Attachment c; Mr. R. D. Martin, Region IV Resident Inspectors, CPSES (3)

. . - - . . . - . - _ . _ . .____._.__m_m_______,._.

___ ____. _________m_s____________,,_,.___. _ ,,,,___ ,, __

e

=

.'*% >[-

TABLE I JUMPERS / LIFTED IEADS IN "GO TEST" CIRCUITS f

-

• u g.

• NEEDED TO ENSURE ADEQUATE TESTING _,

• 3

.5 g CIRCUIT FIGURE CONSEQUENCES OF y SLAVE DEVICE JUMPR/IFTD REASON NEEDED FAII11RE TO RESTORE y K644 E

I-1 1 RHR HX JUMPR - Installed to simulate SI Signal JMPR is in series with K644 g (OPT-453A DUTLET 'across to ensure "P" overrides "SI" contact which opens on CT n OPT-476A) VALVE normally (othezvise would need to test spray signal. Failure to open K608 K608 & K644 simultaneously). remove jumper only isdalbits contacts ability 'to manus 117 open valve fully.

POTENTIAL FOR DESIGN CHANGES CONCI11SION A design change could be made by installing a new " blocking relay" Since a design change would be difficult, to provide a contact in parallel with the K608 contact. However this resulting in non-standard usage of the would be a non-standard application of the blocking relay (i.e. traditional block testing scheme and produce an actuation signal vice block an actuation signal). since automatic protective actions are Additionally the testing scheme requires the K608 contact to be not affected if the jumper is inadvertent 1,,

simulated both opened and closed while K644 remains latched. Again, left in place, use of a jumper in this case use of blocking relay to perform this function is non-standard since is justified and a design changc is neither the blocking relay normally remains energized for the duration of the necessary nor desirable.

test. Use of a blocking relay to replace the need for a jumper would therefore require the use of an additional test switch and non standard operation from the Safeguards Test Cabinet.

l ~- .

p

.g g.

TABLE I #

JUMPERS / LIFTED LEADS IN "GO TEST" CIRCUITS - *"{'- e NEEDED TO ENSURE ADEQUATE TESTING . *$ .,

u" en

-4 CONSEQUENCES OF Y.

CIRCUIT FIGURE SLAVE DEVICE JUMPR/LPTD REASON NEEDED FAILURE TO RESTORE $

2 I-2 2 K631A FIRE JMPR - Installed to simulate a fire. Failure to remve jumper is S (OPT-462A PROT. across signal to 1) ensure KXA631 vill detectable since valve vill OPT-485A) CONT. normally override fire signal, 2) ensure not remain closed during ISOL. open fire KXA631 contacts have re-closed restoration performed upon VALVE detection after testing. test completion.

contacts POTENTIAL FOR L ESIGN CHANGES CONCLUSION Again, a new " blocking relay" could be used in a non standard See Item I-1 Conclusions, above. Also, since .;

fashion to elimir ste the need for this jumper during testing. failure to remve the jumper is detectable, See previous description for K608 contact in K644 test (CET I-1). this testing methodology is justified and a design change is neither necessary nor desirable.

4 4

' IN TABLE I 2:

• *y JUMPERS / LIFTED LEADS IN "GO TEST" CIRCUITS ,e NEEDED TO ENSURE ADEQUATE TESTING -sg

~

og

-4 CONSEQUENCES OF Y' CIRCUIT FIGURE SLAVE DEVICE JUMPR/LFTD REASOW NEEDED . FAILURE TO RESTORE S 2

I-3 3 K610 FIRE PUMP JMPR - Installed around SI Jumper is installed around a 0 (OPT-468A BRKR across sequencer (SIS) contact to confirmatory contact which is OPT-492A) normally allow the series K610 not otherwise caused to close open SI contact to trip fire pump during testing. Failure to Sequencer breaker. Testing of K610 recove jumper leaves the SIS contacts does not cycle the contacts in their safeguards sequencer, therefore these (conducting) condition.

contacts must be simulated closed through use of a jumper.

POTENTIAL FOR DESIGN CHANGES CONCI1]SION The need for use of a jumper could be eliminated by deleting Since failure to remove the jumper leaves the confirmatory trip signal from the SIS. the confirmatory contacts in their safeguards (conducting) condition, continued use of thi current test methodology is justified and a design change is not necessary. "

(

• IN TABLE I 27

_,q.

JUMPERS / LIFTED i.EADS IN "GO TEST" CIRCUITS ,g NEEDED TO ENSURE ADEQUATE TESTING -*g o

CIRCUIT FIGURE SLAVE DEVICE CONSEQUENCES OF y JUMPR/LFTD REASON NEEDED FAIlllRE TO RESTORE '<

I-4 4 K616 SERVICE WTR IFID Lead Since K616 starts both the 8 (OPT-407A, PUMP BRKR This portion of the SSWP g interrupts SSWP and the CCWP, this control circuit is isolated n OPT-494A) "SSWP start lead must be lifted to during an actual SI since the on CCVP disable the SSWP auto start lifted lead is in series with start" on CCVP start feature, sequencer-lockout relay circuit. This ensures the SSWP start contacts which open on SI.

observed during testing was Therefore, failure to re-land due to K616 actuation. lead places this branch of the NOTE: Auto start on CCVP circuit in its (open) Safeguards start is not a safety conditions.

related function, but is rather a coaumercial consideration for enhanced plant operation.

POTENTIAL FOR DESIGN CHANGES CONCLUSION The need for lifting leads could be elioninated by re-assigiung Since failure to re-land the lifted lead does these two pumps to separate slave relays. not interfere with the operation of the pump's control circuit during ESF actuation, continued use of current test methodology is justified and a design change is not necessary.

' T-  ?

~ ' ' ' ' ' '~

• S ' "

! t , . . 7 L e,

'. - - i.,.. . . fi

- 'my EE TABIE II -

?E JUMERS/LIPTED IK 'NE57ENGEOUSE REDCKBD* CIRCBITS e MEEDED N RNSURE ADEQUATE TEST 1H .

R$

~*

/

. o

-4 CONSEQUEN ES OF N' CIRCUIT FIWEE SLAVE DEVIM JUNFR/IFID REASCE BEEDED FAIEDRE N REST 0GE &

. O II-1 $ K611 FRE WATRE 1 IFID Lead The W Interlock contacts Lifted lead is in Interlock, O K612 ISOL VLVS NIV CKT .(closed if W Interlocks not SFGDS portion of tk PVIV K613 (1-RV-2134, not met) are in parallel control circuit. Lands only (OPT-406A) etc.) with the slave relay lifted during shutdoam interrupts contacts beisqg tested. testistg. Failure to re-land "Neintain Therefore, when testing is detectable since oLL puep Closed

• these slave relays with will start. (0pposite ten 11er signal from the N Interlocks not met, duep SUVs keep, valve freer Teodvater a lead in series with the opening.

Interlocks PV Interlock contacts nuet be liEted to allow for proper operation of the slave relay ' Block Test

• l'aF-Since the W Interlocks are met (i.e. W Interlock contacts open) with the plant operating at power, this lead will not need to be 11 feed durisqq normai *at power' quarterly slave relay testisqq.

POTENTIAL PDR DESIGW CRANGES CONCIBSION An additional block testing sisve and associated laaps (4 per train) Since failure to re-land lifted lead is could be added for each of these circuits. %ein, this is detectable and the lifted lead is not in an cpplication of a blocking relay in a "non standard' fashion. series with a safety feature and since the need to life lead only occurs when testing with plant shutdown, a design change is neither necessary nor desirable.

.j g l

l TABLE II

. IE JUMPERS / LIFTED IN " WESTINGHOUSE BIDCKED" CIRCUITS

~ ' ,,n

,a NEEDED TO ENSURE ADEQUATE TESTING -s g ._

5 g.

CONSEQUENCES OF -A .

CIRCUIT FIGURE SLAVE DEVICE JUMPR/IFTD REASON NEEDED FAII11RE TO RESTORE h e

II-2 6 K602 VCT Suction JMPR - across Jumper needed to simulate Failure to remove jumper

^

(OPT-464A, Valve normally open WST suction valve open to would result in VCT valve n OPT-488A) IEV-112B W ST suction allow use of " block testing" closing concurrently with; (IEV-112C) Valve limit lights in the VCT Suction WST valve openkap upon Switch Valve Safeguards Test receipt'of f tjing sway Contacts Cabinet Circuit. over signkl. This increases possibility of momentarily

• reducing charging pump suction flow during the swap over process.

POTENTIAL FOR DESIGN CHANGES CONCLUSION A design change could be made to use a spare contact from the Current procedures are adequate to ensure existing blocking relay (which would close in the " block" condition) removal of jumper subsequent to testing.

l parallel with the WST limit switch contacts in the VCT valve Therefore, a design change is considered not l control circuit. This would require additional test lamps on the necessary.

Safeguards test cabinet as well as installation of cabling between the Control Room and tha valve's motor control center in the Safeguards Building. Again, this is an application of a blocking relay in a i

I non-standard fashion.

. . . . - - ..~ _____._ - ~

- 1 ,r >

. E. A. ,

41 TABLE III e-*

JUMPERS /LIETED LEADS MEEDED TO PREVENT AC WATION* *

• o CIRCUIT FIGURE SLAVE DEVICE JUMPR/IFTD CONSEQUENCES OF Y REASON NEEDED FAIIDRE 10 MS1DM &

III-2 8 K630 1-8152 1 JMPR- Need to insta11 JMPR then 2

(OPT-461A,, (1-8160) across lift field lead to prevent Failure to re-land leed would R result in spurious closure of OPT-484A 'latdown ISOL normally de-energizing solenoid and Valve closed closing valve. (Valves valve (i.e. detectable).

contacts l-8152 and 1-8160 cannot be Failure to remove jumper slave relay exercised during pcwer would result in valve not being tested operation since this closing on an SI signal..

would result in a loss of 1 IFTD Lead nomal letdown ficw, which in series would stop the pre-heating with relay of the charging vetor contacts going back through the being tested use regenerative heet (silow use exchanger. This lack of of DMN) pre-heating would cause an unnecessary thermal shock to the charging line penetration -

FSAR - 7.1.2.5 - Iten 20.)

NOTE: Securing letdown also '

requires securing charging -

see Iten III-1 for additional impact.

i POTENTIAL FOR DESIGN CRANGES, CONCEDSION Each one of these circuits vould require the addition of an entire Current procedures are adequate to ensure block test scheme to preclude the need to lift leads /insta11 removal of Juapers subsequent to testing.

Jumpers. Ircorporatior. of each of these block test circuits Therefore, a design change is considered involves test switch changeout, installation of additional not necessary.

i block test relays as veil as pulling new cables into the Control Room.  ;

• Digital Multi-Meter (DMM) to be used in each case to monitor slave relay contact state changes.

i i

~

f -

. wy l

E. N TABLE III $

JUNPERS/ LIFTED 1EADS NEEDED TO PREVENT COMPONENT ACITIATION DURING TESTING

• cs

• CIRCUIT FIGURE SLAVE DEVICE c0NSEQUENCES OF Y JUNPR/IFTD REASON NEEDED FAIIDRE 10 RESIORE Y III-1 7 R602 1-8105 IFTD Lead - E (OPT-464A, (1-8106) Interrupts Need to lift lead to Failure to re-land lead wouldy prevent closure of result in valve not closing "

OPT-488A) Rormal "close" charging ISOL Valve. on an SI signal.

Charging signal from (Valves 1-8105 and Isolation relay 1-8106 cannot be Valve contacts exercised during power being operation since this tested would interrupt nomel charging flow which could ,

result in loss of

~

pressurizer level control-

FSAR 7.1.2.5. Item 19.)

MOTE: Securing charging  !

j also requires securing [

ietdown - see Item III-2

\ for additional Japact.

l t

POTENTIAL EDR DESIGN CNANGES ogyggygggy s

Each one of these circuits would require the addition of an entire Current procedures are adequate to ensure i block test scheme to preclude the need to lift leads / install removal of Juapers subsequent to testing.

jumpers. Incorporation of each of these block test circuits Therefore, a design change is considered i

involves test switch changeout, installation of additional not necessary. '

block test relays'as veil as pulling new cables into the Control '

Room.

s i

• Digital Multi-Neter (DNN) to be used in each case to monitor sisve relay contact state changes.

Attach =nt'to TXX 90202

.Page 9 of,16 pH l lE

%UTO'hd 1'

- class' %Uto';d

" 'oPsN' VALVE CONTROL HANDSWITCH CONTACTS

.l l Test - -cLoss - -cLoss K608 CONTACTS JuuPER - -on al = -on si ACTUATES ON SI l

L 120 VAC -l l i

K644 CONTACTS OPEN ON 'P'h I C[ ACTUATES ON CT SPRAY SIGNAL ('P')

l

, OPENS WHEN . CLOSED IF I VALVE CLOSES --/ - -yALyg 33 .

l To as% OPEN pd - -LESS THAN VALVE LIMIT j POSITION 17% OPEN SWITCHES l

l

cloes oPEN MOV MOTOR l

CONTROLLER i-FIGURE 1 SIMPLIFIED RHR OUTLET CONTROL VALVES (CKT I-1)

Attach:ent to' TXX 90202 '

.Page 10 of 16,

,H  :

l.

(

tLost " pd' Auro'

• AUTO'p( (('orgt HANDSWITCH cLosas 4 opens KXA 631 CONTACTS

- - ON PH A p- ON PH A ACTUATES ON PH A ISOL 120 VAC

]-

$EIE- M #

SIONAL Tzar JUMPta FIRE DETECTION SIGNAL (RELAY DE-ENERGIZE 8 p ON FIRE SIGNAL) cLoss open MOV MOTOR L ONTROLLER FIGURE 2 SIMPLIFIED FIRE PROTECTION CONTAINMENT ISOL VALVES (CKT I-2)

.c -e ,.w- .m

Attach ent to TXX-90202

.Page 11 of 16 I i-

+

c "

on ." . K610 CONTACTS ACTUATES ON SI

~

CLOSES 125 VDC ofE RE4 PENS --

Test NM SISEQUENCER.

STEP 1 CONTACT 99 SEC WE -

l SHUNT TRIP r

t l

FIGURE 3 SIMPLIFIED FIRE PUMP 01 BREAKER SHUNT TRIP CIRCUIT (CET I-3)

AttachSnt to TXX 90202 Page 1,2 of 16

'+

' START'" [ ' AUTO'yd HANDSWITCH r

oN'" K616 CONTACTS ACTUATES ON SI

' OPPOSITE '

closas ~

ON LOW " TRADr88W PRESS PRESS SWITCH 125 VDC cloess .TIIIS TRAIN' E

clasaD CCW PUMP BRER POSITION OPENS ON sg SI SEQUENCER ascLOess WHEN SIS p .4, AUTOMATIC l

LOCKOUT Tuns LEAD

. LIFTED DURING TEST I

l CLOSING ,

COIL  !

1 l

l 1

i FIGURE 4 l 1

1 SIMPLIFIED SERVICE WATER PUMP START CIRCUIT (CKT I-4) l

)

l

Attegh:ent to TXX-90202

.Page 13 of 16 l

.+

I'ctost' ,

HAND 8 WITCH-SFGDS TEST CAB yIEx"7 BLOCKING REIAY a CONTACTS 1 ' BLOCK TEST' 3

l CIAGE cLoss -- ctcus A oN Inw-- K611.K612.K613 oN rwt - - on as - - TAvo ar " -

FWI SLAVE RELAYS ax TxIP e

125 VDC THIS m LIPTED DURINo TEST- 4 PENS,, FW INTERLOCK M INTtze uzT LOGIC CONTACT.

(AILOWS FWIV TO OPEN WHEN HAND 8 WITCH '

MOVED PROM

'CLOSE')

SFGD8 TEST CAB p 4oPEN DURINo

'stocx TasT' BLOCKING RELAY CONTACTS m ENERGIZE anAT o f,gy,

/ T HYDRAULIC

$7py7g /oVN S soV . OIL DUMP N2 TO CLoeE PwtVALVs ygrw! SOLENOIDS l

I 1

l FIGURE 5 l

SIMPLIFIED FEED WATER ISOLATION VALVE CONTROL CIRCUIT (CKT II-1)

Attach 9ent to TXX 90202

=

..Page 14 of 16

.S  :

G

" "t:sces*

,, ydwVro' HAND 8 WITCH SFODS TEST CAB 0

yd E [ "yg*,7 BLOCKING RELAY CONTACTS 1[y) ' BLOCK TEST'

\/ LAMP s

120 VAC K603 CONTACT

". ",, E

. ACTUATES ON s1 Test JNN

] RWST SUCTION h p dcLosse aweTVALVE NY ON WHEN VALVE POSITION LIMIT SWITCH

-:] .

" MOV MOTOR CONTROLLER FIGURE 6 SIMPLIFIED VOT OUTLET ISOLATION VALVE CONTROL CIRCUIT (CKT II-2)

Attagh2ent to TXX-90202

..Page 15 of 16 V

,d i

'cLoes'"

. [ pd'AtnO' HAND 8 WITCH 120 VAC -

~~ E

- K602 CONTACT ACTUATE 8 ON SI THIS LsAD NtnuMOTEST cm MOV MOTOR CONTROLIER FIGURE 7 SIMPLIFIED NORMAL CHARGTNG ISOLATION VALVE CONTROL CIRCUIT (CET III-1)

Attach 2ent to TXX 90202

.Page 16 of 16 -

,H '

s orsr ",. "., yd' AUTO' HAND 8 WITCH O

J m @ dph7dE K630 CONTACT ACTUATES ON PH A l ISOLATION SIGNAL 118 VAC . ],, a rU o r ,

O g$7gg8" opsn VALVE LIMIT SWITCH

, VALVE to open CONTROL SOLENOID FIGURE 8 SIMPLIFIED ISOL VALVE CONTROL CIRCUIT (CKT III-2)

. . . . . _ _