ML20082P776
| ML20082P776 | |
| Person / Time | |
|---|---|
| Site: | Point Beach  |
| Issue date: | 07/05/1991 |
| From: | Fay C WISCONSIN ELECTRIC POWER CO. |
| To: | Davis A NRC OFFICE OF INSPECTION & ENFORCEMENT (IE REGION III) |
| References | |
| CON-NRC-91-064, CON-NRC-91-64, RTR-REGGD-01.097, RTR-REGGD-1.097 VPNPD-91-216, NUDOCS 9109110055 | |
| Download: ML20082P776 (5) | |
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POMR COMPMY nt w u;w po sc.2cd6 w.o.meew 63205 (asd;22&2m VPNPD 216 NRC 06 4 July 5, 1991 Mr. A. Bart Davist Regional Administrator Office of Inspection & Enforcement, Region III U.S. NUCLEAR REGUIATORY COMMISSION 799 Roosevelt Road Glen Ellyn, Illinois 60137
Dear Mr. Davis:
DOCKET Nos. 50-266 AND BO-301 RESEDNSE TO SPECIAL BAFETY INSPECTION REGULATORY GUIDE 1. 97 IMPLEMENTATION lliEPECTION REPORTS 50-266/91010_& 50-301/91010 POINT BEACH NUCLEAR PLANT. UNITS 1 AND 2 Your letter of June 4, 1991 conveyed the subject inspection report.
The report contained three open items associated with the implernentation of Regulatory Guide 1.97, " Instrumentation for Light-Water-Cooled Nuclear Power Plants to Assess Plant and Environs Conditions During and Following an Accident," Revision 2.
Our response to these open items is provided below:
ODen Iten 3.1.
" Isolation" This item stated that the Foxboro H-line series instrumentation did not have the plant computer inputs isolated from the post-accident monitoring indicators.
It was also stated that the Foxboro H~line instrumentation had no isolation devices installed between t'e indicators v 1 controllers in the secondary current loop.
Regulatory Guide 1.97, Section C.1, Paragraph 1.4 (a), recommends "any equipment that is used for either Category 1 or category 2 should be designated as part of accident-monitoring instrumentation...
The transmission of such signals from such equipment for other use shall be through isolation devices that are designated as part of the monitoring instrumentation and that meet the provisions of this document."
Point Beach Nuclear plant was designed and constructed in the late 1960's, early 19704 s timeframe with Units 1 and 2 achieving i
i commercial operation in December 1970 and October 1972, respectively.
The applicable instraentation design standard in existence at that time was proposed IEEE Standard 279, " proposed g60' 9109120055 910705 N
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Mr..A. Bert Davis July 8, 1991 Page 2 IEEE Criteria for Nuclear Power Plant Protective Systems," dated August 1968.
Chapter 7 of the PBNP PSAR 131ustrates that the intent of-proposed IEEE 8tandard 279 desiyn criteria was reasonably satisfied by the PBNP instrumentation and control systems.
We acknowledge that the original Foxbovo M-line indicator loops at PBNP do not strictly meet the Regulatory Guide 1.97 recommendations for isolation since an isolated secondary loop (typically off a primary protection loop) may contain controllers, annunciation bistables, computer inputs, and recorders in series with the indicator.
In addition, our circuit design was completed-prior to the issuance of the NRC guidance regarding physical independence of-electrical systems (Regulatory Guide 1.75, september 1978) and-the associated IEEE standard for separation of Class 1E equipment and circuits (IEEE Standard 384-1974).
Although not in accordance with recent guidance, separation of safety-related instrumentation was achieved in accordance with Proposed IEEE Standard 279 as described in Section 7.2.1 of the Point Beach FSAR.
Foxboro M~line-driven 4
indicator loops, therefore, do not meet the Regulatory Guide 1.97 separation requirements.
However, we maintain that the overall qualification and reliability of the indication used for the Regulatory Guide.l.97 Category 1 and 2 variables is adequate as installed for meeting the jntent of the Regulatory Guide as elaborated below 1.
-Reliabilitvt PBNP has demonstrated a long history (>20 years) of reliable operation of the Foxboro H-line equipment.
Except-for infrequent isolation module output drift, I&C supervision does not recall any failures of indication loops due to the failure of the output of other devices in the loop.
Also, a review of the PBNP Computerized History And Maintenance Planning System (CHAMPS) revealed no inherent problems with this equipment.
In addition, many of the H-line modules have recently beer refurbished with new capacitors, potentiometers, etc. to maintain this high level of reliability.
2.
Demian The design of the principal components utillied in the primary protection loops (used for-Reactor Protection System and Engineered Safeguards Actuation input) and secondary loops (used for indication, control, and alarm) was performed to the same design criteria.
3.
galibration:
The secondary and protection loop components are maintained and calibrated to the same specifications (except for occasional interin use of spare non-QA modules in secondary loops, when necessary).
Mr. A. B.,rh Davis July 8, 1991 Page 3 i
4.
Englificati nt Instrumentation loop potentially exposed to Q
a harsh environment cannot effect more than one redundant channel.
Since all secondary loop oomponents are located in mild accident environments (i.e., no environmental qualification in required), the demonstrated reliability of this equipment will not be affected by accident conditions.
Seismic verification will be performed per our response to Generic Letter 87-02, " Verification of Seismic Adequacy of Mechanical and Electrical Equipment in Operating Reactors,"
utilizing the seismic Qualification Utility Group (80UG)
Generic Implementation Procedure (GIP).
Revision 2 of the sQUG GIP is currently under review by the NRC Staff.
As noted in our letter NRC-85-93 dated August 30, 1985, seismic verification of instrumentation for Regulatory Guide 1.97 Category 1 and 2 variables per the SQUG GIP will be utilized to meet the seismic qualification requirements of the Regulatory Guide.
In addition, the potential for common mode damage caused by a fire has been addressed in our response to 10CFR50, Appendix R.
5.
Erdundanev:
All category 1 and most category 2 variables with Foxboro H-line-driven indicators have backup qualified indication from the Foxboro Spec 200 instrumentation racks, Which have full separation and isolation characteristics applied from the transmitter through the indication on the Auxiliary Safety Instrumentation Panels (ASIPs).
The following variables with H-line-driven indicators also have backup Foxboro Speo 200 instrumentation H-Line Variabl1 Rgalified spic 200fASIP Backup Contairimert Containment Wide Range PresswcA Pressure steam Generator Steam wonerator Wide Range Narrow Range Level Level Aux. Feedwater Flow Steam Generator Wida Range to steam Generators Level steau Generator RCS Wide Range T **
c Pressure Pressurizer Reactor Vessel Level Level i
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e Mr. A. Bert Davis July s, 1991 Page 4 i
Pressuriser RC8 Wide Range pressure Pressure
- Note:
Since saturated conditions exist in the steam generators, steam tables.can be utilised to determine steam geraerator pressure given steam generator temperature (which is approximately RCs T )
- c 6.
QA_Statust The QA status of indicators on the main control boards was an open issue already identitled in our commitment tracking system.. This evaluation and any subsequent upgrading will be completed by December 1991.
Qgan Item 3.2, MCalibration or Status ef_Atandby Power Instrumentation" This item stated that the status of standby power instrumentation was not included in a surveillance program even though it was identified as Category 2, Type D.
Regulatory Guids 1.97 Section C.1, Paragraph 1.5(a) states " servicing, testing, and calibration programs should be specified to maintain the capability of the monitoring instrumentation..." for-all category 1, 2 and 3 instrumentation.
WE agrees to initiate the calibration checks of Regulatory Guide 1.97 instrumentation used to monitor vital electrical power supplies.
The scope and frequency of any such calibration check will be based on the extent of use-of the instrumentation.
For example, a voltage meter used to confirm only the presence of voltage where accuracy-is not required-may not need to be calibrated over the entire range, but merely verified to be operable at the voltage of interest during operation or periodic testing of the electrical supply.- The development and implementation'of appropriate calibration check procedures and
' associated schedules for these indicators will be completed by May 1992 for Unit 1 and November 1992 for Unit 2.
Onen Itan 3.3. RUnlaue Identification of Instruments on control
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This item stated that category 1 and 2, Type A, B, and c instruments were not uniquely identified in the control room.
Regulatory Guide 1.97 Section C.1, Paragraph 1.4 (b), recommends "the instruments designated as Types A, B, and c and categories 1 1
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Mr. A. Bert Davis July 8, 1991 Pago 5 and 2 should be specifically identified en the control panels so that,the operator can easily discern that they are intended for use under accident conditions."
PBNP has recently installed new Auxiliary Safety Instrumentation Panels (ASIP's--Panels 1 & 2-C20) in the control room.
The purpoco of these panels is to provide indication for post-accident monitoring (PAN) and essentially all of the indicators on the panel are used for that purpose.
Therefore, we feel there is nr need to uniquely identify that each indicator is intended for PAM, as this is well understood by the operators.
On the main control boarde, there is a mix of "PAM" and "non-PAM" indicators.
WE Egreen to provide unique identification (marking or labeling) of their intended use onder accident conditions for Category 1 and 2, Type A, B, and C indicators found on the main control boards in canon where all indicators for a particular variable do not moet our Regulatory Guido 1.97 commitmento.
Note that the Erergoney operating Procodures clsarly inform the operators which variable is to be observed in a given step.
In canos where all of the indicators for any of the above variables (such as pressurizer level) meet our Regulatory Guide 1.97 commitments, unique identification of PAM indicators serves no apparent purpose and Will not be provided.
This will help to maintain the desired neat and clean appearance of the boards and to avoid potential operator confusion due to cluttered control boardn.
The identification of appropriate indicators will be completed by July 1992.
If you have any questions concerning this infornation, please contact us.'
Very truly yours, h
h C. W.
y Vice President Nuclear power Copy to:
NRC Resident Inspector Document control Dock Blind copies to:
Frieling, Krioner, Lipke, Maxfield, Newton, Rodgers (OSRC), Filo A1.4.1