ML20107H069
| ML20107H069 | |
| Person / Time | |
|---|---|
| Site: | Wolf Creek  |
| Issue date: | 04/18/1996 |
| From: | Maynard O WOLF CREEK NUCLEAR OPERATING CORP. |
| To: | NRC OFFICE OF INFORMATION RESOURCES MANAGEMENT (IRM) |
| References | |
| GL-96-01, GL-96-1, WO-96-0068, WO-96-68, NUDOCS 9604240027 | |
| Download: ML20107H069 (6) | |
Text
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WQLF CREEK NUCLEAR OPERATING CORPORATION Otto L Maynard vic. Pr.o.ni mani over ion
- Apri1 18, 1996 WO 96-0068 U. S. Nuclear Regulatory Commission ATTN: Document Control Desk Mail Station P1-137 Washington, D.
C.
20555
Reference:
Letter WO 95-0181, dated December 13, 1995, to USNRC from O. L. Maynard
Subject:
Docket No. 50-482:
Response to Generic Letter 96-01,
" Testing of Safety Related Logic Circuits" Gentlemen:
The attachment to this letter provides Wolf Creek Nuclear Operating Corporation's (WCNOC) 60 day respont e to Generic Letter 96-01.
This information is being provided in accordance with the reporting requirements of the Generic Letter.
The Reference made a commitment to convert to the Improved Standard Technical Specifications. This commitment has been factored into WCNOC's response.
If you should have any questions regarding this submittal, please contact me at (316) 364-8831, extension 4450, or R. D. Flannigan at extension 4500.
Very truly yours, Otto L. Maynard OLM/jra Attachment cc:
L.
J.
Callan (NRC), w/a W. D. Johnson (NRC), w/a J.
F. Ringwald (NRC), w/a J. C. Stone (NRC) ', w/a 9604240027 960410 PDR ADOCK 05000402 p
- 'a U U.I Q P O. Box 411/ Burlington KS FA839 / Phone: (316) 364-8831 An Equal Opportunity Employer M/F/HC/ VET
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STATE OF KANSAS
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SS COUNTY OF[COFFEY
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Otto L. Maynard, of lawful age, being first duly sworn upon oath says that he is' Vice President Plant Operations of -Wolf Creek Nuclear Operating Corporationi that he has read the foregoing document and knows the content thereofi. that he has executed that same for.and on. behalf of said Corporation with full power and authority to do so; and that the facts therein stated are true and correct to the best of hia knowledge, information and belief.
By 44/
OttW 6. Maynard
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Vice President Plant Operations
-SUBSCRIBED and sworn to before me this j day of h
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1996.
men. G. CW MARY E. GIFFORD '
Notary Public
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My Appt Experes f 0.(jitatepf Kansas Netary Pubhe.
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Expiration Date l
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t Attechtnent to WO 96-0068
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Page 1 of 4 Response to Generic Letter 96-01
" Testing of Safety-Related Logic Circuits
INTRODUCTION Wolf Creek Generating Station (WCGS) is a four-loop Westinghouse Pressurized Water Reactor.
The Reactor Protection System (RPS) and Engineered Safety Features (ESP) use the Westinghouse 7300 Process System and Solid State Protection System (SSPS).
Balance of the plant (BOP) Engineered Safety Features Actuation System (ESFAS) and Load Shedder and Emergency Load Sequencer (LSELS) Systems were designed and provided by Consolidated Controls Corporation.
REQUESTED ACTIONS On January 10, 1996, the NRC issued Generic Letter 96-01.
The Generic Letter requested the following actions:
(1)
Compara electrical schematic drawings and logic diagrams for the reactor protections system, emergency diesel generator (EDG) load shedding and sequencing, and actuation logic for the engineered safety features systems against plant surveillance test procedures to ensure that all portions of the logic circuitry including the parallel logic, interlocks, bypasses and inhibit circuits, are adequately covered in the surveillance procedures to fulfill the Technical Specification requirements.
This review should also include relay contacts, control
- switches, and other relevant electrical components within these systems, utilized in the logic circuits performing a safety function.
(2)
Modify the surveillance procedures as necessa y for complete testing to comply with the technical specifications.
Additionally, the licensee may request an amendment to the technical specifications if
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relief from certain testing requirements can be justified.
REQUIRED RESEQllSE The Generic Letter required the following responses:
(1)
Within 60 days of the date of this Generic Letter, a written response indicating whether or not the addressee will implement the actions requested above.
If the addressee intends to implement the requested actions, submit a schedule for completing implementation.
If an addressee chooses not to take the requested actions, submit a description of any proposed alternative course of action, the schedule for completion the alternative course of action (if applicable), and the alternative course of actions.
(2)
Within 30 days of completion of the requested actions, a response confirming completion.
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Attachment to WO 95-0068 Page 2 of 4 WCNOC REMPONSE Wolf Creek Nuclear Operating Corporation (WCNOC) intends to implement the requested actions for logic system testing as discussed and clarified below CONVERSION TO STANDARD TECHNICAL SPECIFICATIONS
- WCNOC, in conjunction with three other utilities, is in the process of converting to the Improved Standard Technical plans to submit Specifications (ISTS).
WCNOC in late 1996 for NRC approval,
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this conversion.
In accordance with the a license amendment requesting guidance Letter workshop, March 19, 1996, provided in the Generic the Generic Letter reviews will be based on the ISTS.
In the event the submittal date for the Technical Specification Conversion amendment request will still be completed to the ISTS.is delayed beyond January 10, 1997, the review IDENTICAL SAFETY TRAINS The systems and components within the scope of this Generic Letter are typically identical redundant identical, but separate procedures for the individual traintrains or channels and theref WCNOC's intent or channel.
It is to group these similar procedures and to perform review of on of the common groups.
If there are differences between the trains or e
channels, these differences, as a minimum will be reviewed in the applicable procedures.
If deficiencies are noted in the reviewed procedure, then the remainder of the procedures in that group will be reviewed for existence of that deficiency and revised as Specifications.
necessary to comply with the Technical the workshop.
This is consistent with the NRC response to question #11 from SCHEDULE The proposed completion of these actions is by March 31, 1998.
Completion will be accomplished in conjunction with the proposed implementation ISTS.
This schedule provides for an orderly and efficient review of of the surveillance procedures in conjunction with the the ISTS.
The schedule has been developed to supportimplementation activities of for ISTS the four plant effort conversion.
Four utilities; Pacific Gas and Electric Co.
(Diablo Canyon power Plant),
TU Electric (Comanche Peak Steam Electric Station)
Electric Co.
(Callaway) and WCNOC (Wolf Creek Generating Station), have
, Union entered into a combined effort to convert to the ISTS.Thio group of date of December 1996. utilities has committed to submit amendment requests to the NRC with a target To support this submittal, with the NRC for the review and implementation of the conversion.
The a schedule was developed
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completion of the Generic Letter request has been developed in order to be 1
consistent cooperative efforts between the four utilities.with the conversion plan and sched I
this joint collaboration on both projects.
This schedule will facilitate
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Attachm2nt to WO 96-0068 Page 3 of 4 l
SCOPE Listed below are the current Technical Specification requirements.
These sections have been provided for information purposes.
The actual Generic Letter review will be completed in accordance with the equivalent sections of the ISTS.
The reactor protection system, EDG load shedding and sequencing, and actuation logic for the ESF systems are currently contained in the Technical Specifications sections 3.3.1, 3.8.1.1, and 3.3.2 respectively.
For the RPS and ESF logics, current Technical Specifications required testing is bounded by testing of Table 4.3-1 and 4.3-2 defined as Actuation Logic Test Trip Actuation Device Operation Test (TADOT), Master Relay Test and Slave Relay Test.
EDG load shedding and sequencing testing required by current Technical Specifications is defined by Surveillance Requirements 4.8.1.1.2g.4),
4.8.1.1.29 5),
4.8.1.1.2g 6),
4. 8.1.1. 2g. 7 ),
4. 8.1.1. 2g. 9),
4. 8.1.1. 2g.10 ) and 4.8.1.1.2g.12).
WCNOC intends to perform review of logic testing to the equivalent sections of the ISTS.
CREDIT FOR PREVIOUS REVIEW EFFORTS WCGS's Technical Specifications are a relatively current version within the industry and were used te develop the current surveillance procedures.
The significant development of these procedures occurred in the early 1980s to support licensing of the plant, and took advantage of Industry Operating Experience at the time.
Addir.ionally, relevant Industry Operating Experiences have been incorporated in pro:edure revisions.
At this time, WCNOC believes that the following areas have been adequately reviewed in accordance with the intent of the Generic Letter Westinghouse 7300 Process Instrument Loops:
Although only the bistable inputs to the SSPS are within the scope of the Generic Letter (workshop Questions #12 and #20), the entire process loops have been confirmed to be adequately tested.
The design and testing methodology have been well developed and documented by Westinghouse and are described in Updated Safety Anslysis Report (USAR) Sections 7.2 and 7.3.
The USAR, vendor technical manuals and schematics, and site specific interconnect drawings were used to develop the surveillance procedures.
The actuation of the bistables and the inputs to the SSPS are confirmed by the surveillance procedures.
Westinghouse SSPS:
The design of the SSPS includes semiautomatic testing of the logic.
The design and testing methodology have been well developed and documented by Westinghouse and are described in USAR Sections 7.2 and 7.3.
The USAR, vendor technical manuals and schematics, and site specific interconnect drawings were used to develop the surveillance procedures.
The procedures for logic tests overlap the 7300 process instrument tests and test through the master relays and coil continuity of the slave relays.
.Attachm:nt to WO 96-0068 Page 4 of 4 i
Westinghouse Slave Relays:
These relays are designed with a test feature to individually actuate the relays.
The design and testing methodology have been well developed and documented by Westinghouse and are described in USAR Section 7.3.
The USAR, vendor technical manuals and schematics, and site specific drawings were used to develop the surveillance procedures.
The procedures for slave relay tests actuate the testable actuation devices to the extent possible and use contact continuity for the remaining testable actuation devices.
The Consolidated Controls Corporation design of ESFAS and LSELS includes an Automatic Test Insertion (ATI) System to automatically and continuously inject test signals to verify the functional integrity of critical ESFAS and LSELS circuits. Test signals are generated during specific time intervals or " steps" (42 steps for ESFAS, 85 steps for LSELS).
During each step the actual response to the test signal is compared to the expected response which is stored in a non-volatile memory (PROMS). If actual and expected responses do not agree - the ATI System will annunciate the comparison failure, and display the failed step number.
The ATI system is identified in Section 7.3 of the USAR and serves to prove functionality of logic circuitry internal to the ESFAS and LSELS cabinets.
The ATI table in the vendor technical manuals for these systems show that all logic combinations, including sequence timing, are tested.
This testing overlaps other calibrations and integrated test procedures.
If additional portions of the reviews within the scope of the Generic Letter are later identified to already have been performed consistent with the Generic Letter intent, they will be discussed in the response due within 30 days of completion of the requested actions.