ML20140D855
| ML20140D855 | |
| Person / Time | |
|---|---|
| Site: | Hope Creek  |
| Issue date: | 02/03/1986 |
| From: | Corbin McNeil Public Service Enterprise Group |
| To: | Adensam E Office of Nuclear Reactor Regulation |
| References | |
| NUDOCS 8602030124 | |
| Download: ML20140D855 (4) | |
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Pubhc Service Electric and Gas Company i
Cctbin A. McNeill, Jr.
Pubhc Service Electnc and Gas Company P.O. Box 236, Hancocks Bridge, NJ 08038 609 339-4800 Wce Presscent -
Nuclear i
i Director of Nuclear Reactor Regulation United States Nuclear Regulatory Commission 7920 Norfolk Avenue
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Bethesda, Maryland 20814 Attention:
Ms. Elinor Adensam, Director i
Project Directorate 3 j.
Division of BWR Licensing i
Dear Ms. Adensam:
BAILEY 862 SOLID STATE LOGIC MODULE HOPE CREEK GENERATING STATION 1
DOCKET NO. 50-354 4
Public Service Electric and Gas Company (PSE&G) hereby submits the attached in response to your request for additional information pertaining to Bailey 862 Solid State Logic Modules (SSLM) as discussed between representatives of PSE&G and the NRC on January 14 and 16, 1986 and directly in meetings between Messrs.
J. Mauck (NRC) and B.A.
Preston l
(PSS&G) on January 23, 1986.
i In the event you require additional information or clarification, PSE&G will be available to meet with you.
Sincerely, 1
4 8602030124 B60203 PDR ADDCK 05000354 A
PDR Attachment C
D.H. Wagner USNRC-Licensing Project Manager j
R.W.
Borchardt 1] p USNRC Senior Resident Inspector l
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t
o e
ATTACHMENT I BAILEY 862 SSLM 4
J 1.
In response to your concern pertaining to clarification of the statement presented in letter from C.A. McNeill (PSE&G) to E. Adensam (NRC) dated December 23, 1985 concerning applicability of the single failure criterion to Bailey 862 SSLM, PSE&G provides the following statement.
l This statement was agreed upon in discussions between representatives of PSE&G and the NRC on January 16, 1986.
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" Minimum number of operable channels per trip system as stated in Technical Specification Table 3.3.2-1 satisfy single failure criteria."
2.
In response to your concern pertaining to testability l
of the Bailey 862 SSLM's the following is provided.
The Bailey 862 logic performs logic combination of input signals and provides status indication and activates output driver relays to actuate equipment of a given plant system.
This function is similar to that performed l
by electro-mechanical relays at other nuclear plants.
The response to FSAR Question 421.22 identifies that on a contact level basis the safety-related systems (except PCIS and ADS) are capable of being tested at power as necessary to troubleshoot or verify suspect components or functions.
This includes those portions of the safety-related systems that utilize the Bailey 862 logic.
lf 3.
As stated by PSE&G during the January 16, 1986 telecon, it is PSE&G's contention that the Bailey 862 SSLMs are adequately exercised during plant operation as a result of required Technical Specification surveillance testing and normal plant operating evolutions.
Exercising of the SSLM is defined as, for a given input a designed output is provided.
While this does not verify all logic functions associated with a module it does however provide a mechanism by which common mode failure can be detected and provides a high degree of confidence that the module will perform its intended function.
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O 2
2 i
This section of the response is included to describe normal exercising of the Bailey 862 logic modules utilized by safety-related systems.
A de ailed investigation was performed on three of the safety-related systems identified in the response to FSAR Question 421.22 to determine how many of the Bailey 862 logic modules were exercised by routine plant surveillance testing.
The systems selected for 1
investigation were the FRVS, SACS and PCIS.
The results I
of the investigation are as follows:
1.
FRVS - Of a total of 43 Bailey 862 logic modules in the system, 25 are exercised by monthly surveillance procedures (58%).
The remaining 18 modules that i
are not exercised provide no safety-related control function.
Thus 100% of the 862 logic modules providing safety related control functions are exercised monthly by routine FRVS surveillance testing.
2.
SACS - Of a total of 92 Bailey 862 logic modules, 64 are exercised by quarterly surveillance procedures (70%).
Of the remaining 28 modules, only 4 provide safety-related control functions.
Thus 94% of the 862 logic modules providing safety-related control functions are exercised quarterly by routine SACS surveillance testing.
3.
PCIS - There are no routine surveillance procedures performed on the PCIS that exercise any of the 16 Bailey 862 logic modules in the system (0%).
There is, however, a logic system functional test performed once per 18 months which does demonstrate 4
the operability of the 16 logic modules.
Of the remaining safety-related systems identified in the response to FSAR Question 421.22 it is estimated that the percentage of Bailey 862 logic modules exercised by routine surveillance will be similar to the percentages associated with SACS and FRVS.
In addition, exercising of the Bailey 862 logic modules will also occur as a result of routine plant operating lineup shifts thus providing additional assurance of SSLM operational readiness.
4.
The following is provided in response to your request for additional information pertaining to the PSE&G I
position with respect to Regulatory Guide 1.22 " Periodic
' Testing of Protection System Actuation Functions" item D.4.a,b, and c.
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3 4a The PCIS and ADS are not tested during reactor operation, for the reasons as stated in response to FSAR question 421.22.
However, it is noted that testing of these systems and all safety-related systems conform with the requirements of IEEE 279-1971 Section 4.10.
4b As stated in parts 2 and 3 of this letter, it was demonstrated that a high percentage of the systems utilizing Bailey 862 logic modules, are tested on a regular basis through normal operation of the plant and by routine surveillance testing.
It is our engineering judgement that this testing and plant operations would identify any common mode failure that could jeopardize the safety function of these systems.
4c All safety-related systems and related equipment can be routinely tested when the reactor is shut down.
With respect to the above and considering the requirements of the Technical Specifications it is PSE&G's contention that the Bailey 862 logic is adequately exercised during reactor operation which provides a high degree of assurance that any potential fault including common mode, will be detected without the need for additional surveillance requirements.
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