ML20140E550

Forwards Schedule for Submitting Addl Info & Justification of Nonconformance of Core Exit Thermocouples & Subcooling Margin Monitors,Per 840202 SER on Util Response to Generic Ltr 82-28 & NUREG-0737,Item II.F.2

ML20140E550
Person / Time
Site:	Trojan File:Portland General Electric icon.png
Issue date:	01/04/1985
From:	Withers B PORTLAND GENERAL ELECTRIC CO.
To:	Eisenhut D Office of Nuclear Reactor Regulation
References
RTR-NUREG-0737, RTR-NUREG-737, TASK-2.F.2, TASK-TM GL-82-28, TAC-45175, NUDOCS 8501110130
Download: ML20140E550 (21)

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Ebrt D. Withers Vce Presdort January 4, 1985 Trojan Nuclear Plant Docket 50-344 License NPF-1 Mr. Darrell G. Eisenhut, Director Division of Licensing Office of Nuclear Reactor Regulation U.S. Nuclear Regulatory Cotamission Washington DC 20555

Dear Mr. Eisenhut:

WUREG-0737. Item II.F.2. Inadequate Core Cooling Instrumentation The NRC Safety Evaluation Report of February 2, 1984 provided the results of your review of PGE's response to Generic Letter 82-28. " Inadequate Core Cooling Instrumentation (ICCI) System". Your review concluded that PGE should provide a schedule for submitting additional information to either justify the nonconformance of our core exit thermocouples (CETs) and subcooling margin monitors (SMMs) with the design requirements of NUREG-0737 or provide a plan and schedule for upgrading these systems.

The additional information requested is provided in Attachment 1.

Attachmentu 2 and 3 contain an evaluation of the extent to which the SMMs and CETs will comply with the NUREC-0737 Item II.F.2, Attachment 1 and Appendix B requirements, respectively. This information includes a connitment for an upgrade of the CETs. The modification will include the installation of environmentally qualified cables inside containment and environmentally and seismically qualifying the reference junction boxes.

The CET cables inside Containment will be sepacated and their input to the primary display will be isolated from the backup display. This modification is further described in the Attachments to this letter and i is scheduled to be completed by the end of the 1987 refueling outage. We do not plan to upgrade the SMMs, as they are considered adequate to l perform their function. The SMMs were contracted for prior to issuance of MrkEG-073; in a good-faith effort to meet the NUREG-0578 requirements ,

ar cl.a.exfied by NRC letter of October 30, 1979. 1 l

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121 S W Salmon Street, Port:and. Oregon 97204 L-

N M BOctricC0fT4MM1y Mr. Darrell G. Eisenhut January 4, 1985 Page 2 Paragraph 3.7 of Supplement 1 to NURgG-0737 indicates that any regulatory position that would require the removal or major modification of existing emergency response facilities or equipment requires the review and approval of either the Director of the Office of Nuclear Reactor Regulation or Inspection and Enforcement.

Sincerely, Bart D. Withers Vice President Nuclear Attachment c: Mr. Lynn Frank, Director State of Oregon Department of Energy Mr. John B. Martin Regional Administrator, Region V U.S. Nuclear Regulatory Commission

Trojan Nuclear Plant Mr. D. G. Eisenhut Docket 50-344 January 4, 1985 License NPF-1 Attachment 1 Page 1 of 4 Response to Request for Additional Information On Inadequate Core Coolina Instrumentation

1. NRC Request: The indicator described in the licensee's letter of March 18, 1983, Withers to Eisenhut, Attachment B. Page 1, response item 2a is not satisfactory either as a primary or secondary display for the requirements of TMI Action Item II.F.2. However, the dis-play device described in the response item 2b appears to be satis-factory as a primary display if it is confirmed that the following features are provided:

a. Alarm setpoints can be adjusted.

b. The primary display is electrically independent and isolated from the backup display (see also Question 4 following).

c. Components used for the primary display which are not accessible for maintenance during Plant operation are environmentally qualified.

d. The primary display is powered from a highly reliable battery backed bus.

PGE Response:

a. The alarm setpoints on the Plant computer are adjustable.

b. The primary display and backup display will be electrically isolated from each other and will be powered from separate Class 1E power sources to the extent stated in Attachment 3, criterion 2, as part of the scheduled modification to the CETs.

c. The portions of the CET system located in harsh environments will be environmentally qualified. All other components used for the primary display are located in mild environments and, therefore, environmental qualification is not a concern.

d. The primary display is powered from a highly reliable, battery-backed Class 1E bus.

,2. NRC Request: The proposed design for the backup display appears to utilize the same readout and signal conditioning hardware as the subcooling margin monitor. Since qualified equipment is required for the backup display, please confirm that the equipment used in the implementation of the design has successfully passed environ-mental and seismic testing in accordance with Regulatory Guides 1.89 (NUREG-0588) and 1.100.

Trojan Nuclear Plant Mr. D. G. Eisenhut Docket 50-344 January 4, 1985 License NPF-1 Attachment 1 Page 2 of 4 PGE Response: The backup display for the CETs consists of two SMMs.

This display is located in a mild environment and is not subject to enviccamental quellfication requirements. The SMNs were installed in accordance with NUREG-0578 requirements as clarified by the NRC

-letter of October 30, 1979, which did not require seismic qualifica-tion; therefore, the SMMs have not been seismically tested. We do not plan to replace the SMMs with qualified components because the SMNs were installed in a good-faith effort to meet the requirements as they then existed.

3. NRC Request: It is stated that "the two subcooling margin monitors together have the capability to selectively read any of 16 thermo-couples". The licensee should clarify whether each monitor device individually has the capability of reading all 16 core exit thermocouples.

PGE Response: The backup display consists of two SMNs. Each SMN has the capability to read eight thermocouples. Thus, the two SMus together have the capability to selectively read any of 16 different thermocouples (four from each core quadrant).

4. NRC Request: The subcooling margin monitor receives input signals from a mix of Class 1E and non-Class lE instrumentation sources.

Furthermore, it is not clear that the subcooling margin computer and display are adequately seismically and environmentally qualified.

Clarify that in all instances, Class 1E equipment is protected by qualified isolation devices that preclude the possibility of adverse interaction between Class 1E and non-Class 1E devices or signals, and that the subcooling margin computer and display are seismically and environmentally qualified.

PGE Response: The CET upgrade will include the installation of signal isolators to electrically isolate the CET input to the Stet from the primary display. The RTD and pressure inputs will also be similarly isolated or will be evaluated to verify that adverse interactions between Class 1E and non-Class 1E devices or signals cannot occur. The modification to environmentally and seismically qualify the CETs inside Containment will result in all inputs to the Stels being environmentally and seismically qualified in accordance

'with the Plant design basis. The SMNs, however, are not seismically '

qualified, as this was not required by the NUREG-0578 requirements as clarified by the NRC's October 30, 1979 letter. These monitors were installed in good faith under those requirements and, there-fore, we do not plan to remove them and install seismically quali- ,

fled replacements. The Stats are located in a mild environment and i are not subject to environmental qualification requirements.

5. NRC Request

The use of reference junction compensation equipment inside containment creates the risk that thermocouple indications i

Trojan Nuclear Plant Mr. D. G. Eisenhut Docket 50-344 January 4, 1985 Licenss NPF-1 Attachment 1 Page 3 of 4 could become inaccurate under certain accident conditions. Corfirm that all reference junction compensation for the Slet and core exit thermocouple backup display is located outside containment or explain how . reference junction compensation will be accomplished under adverse conditions if the reference junctions are located in containment.

PGE w .ponse: The scheduled modification to the CETs will result in the replacement of in-Containment cabling and connectors with envi-ronmentally qualified mineral-insulated cabling and stainless steel multi-pin connectors. The existing reference junction boxes will be replaced with qualified equivalents; however, it is not known at this time whether the new reference junction boxes will be located inside or outside the containment. The location is dependent upon the selection of vendor. If the reference junction boxes are located inside containment, then a review for accuracy of reference junction compensation will be performed as part of the system environm6ntal qualification review.

6. NRC Request: Provide justification for the adequacy of the CET system during the interim period until upgrading can be completed.

PGE Response: The schedule for achieving this upgrade is dependent upon completion of all engineering activities and procurement of components. We estimate we will complete this upgrade during the 1987 refueling outage based on estimated equipment delivery schedules. There is a slight possibility of completing the modif1-cation during the 1986 refueling outage; however, this possibility relies on an optimistic schedule for equipment delivery.

In the interim, the following will be available to the operator to aid in diagnosing inadequate core cooling conditions:

1. The Reactor Vessel Level Instrument System (RVLIS) is currently scheduled to be operational by July 1,1985.

2. The Stets are operational and the operators are well acquainted with these monitors.

3. The existing CETs are available and readout on the Plant com-puter and the Honeywell precision indicator. In July 1985, the SPDS will become operational and will also display the CETs.

Sixteen of the CETs also indicate on the Stets.

4. The existing qualified Reactor Coolant System pressure trans-mitters and hot les RTD can also be utilized to determine degrees subcooling.

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Trojan Nuclear Plant Mr. D. G. Eisenhut Docket 50-344 January 4, 1985 License WPF-1 Attachment 1 Page 4 of 4 Additionally, credit can be taken for redundant trains of the Emergency Core Cooling System which make the probability for occurrence of an inadequate core cooling situation very small.

7. NRC Request: Provide the current status of the RVLIS modifieration program and justification for the schedule for completion of the RVLIS modification.

PGE Response: We are werently working with Westinghouse to resolve problems with the RVLIS electronics. Additionally, the RVLIS has partially lost fill and will be refilled during the 1985 refueling outage. A modification will be made to the system at that tire to prevent 3iss of fill in the future. Provided that these problems can be er.colved RVLIS should be operational by July 1, 1985.

Operation in the interim is justified for the same reasons stated in our response to NRC Question 6 above, with the exception of Item 1.

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Trojan Nuclear Plant Mr. D. G. Eisenhut Docket 50-344. January 4, 1985

License NPF-1 Attachment 2 Page 1 of 5 l

COMPLIANCE WITH NUREG-0737, II.F.2, ATTACHMENT 1 DESIGN AND QUALIFICATION CRITERIA FOR PRESSURIZED-WATER REACTOR INCORE THERM 0 COUPLES

1. Criterion 1 Thermocouples located at the core exit for each core quadrant, in conjunction with core inlet temperature data, shall be of sufficient number to provide indication of radial distribution of the coolant enthalpy (temperature) rise across representative regions of the core. Power distribution symmetry should be considered when deter-mining the specific number and location of thermocouples to be pro-vided for diagnosis of local core problems.

Response to Criterion 1 i

The Trojan Nuclear Plant has 65 CETs installed in the reactor vessel.

The cabling to all 65 CETs will be upgraded as clarifled herein and will be sufficient to provide indication of the radial temperature profile and power distribution symmetry. A display of the CET loca-tions is shown on Updated FSAR Figure 4.4-19.

2. Criterion 2 There should be a primary operator display (or displays) having the capabilities which follow:

a. A spatially oriented core map available on demand indicating the temperature or temperature difference across the core at each i core exit thermocouple location,

b. A selective reading of core exit temperature, continuous on

, demand, which is consistent with parameters pertinent to operator actions in connection with plant-specific inadequate core cooling i.

procedures. For example, the action requirement and the dis-played temperature might be either the highest of all operable thermocouples or the average of five highest thermocouples.

c. Direct readout and hard-copy capability should be available for gli thermocouple temperatures. The range should extend from 200*F (or less) to 1,800*F (or more),

d. Trend capability showing the temperature-time history of I representative core exit temperature values should be available on demand.  ;

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.6' Trojan Nuclear Plant Mr. D. G. Eisenhut-Docket 50-344- January 4, 1985 License NPF-1 Attachment 2 Page 2 of 5

e. . Appropriate alarm capability should be provided consistent with operator procedure requirements,

f. h operator-display device interface shall be human-factor designed to provide rapid access to requested displays.

Response to Criterion 2 CET readings are displayed via the Plant computer on high-speed printer and CRT display' devices. A spatially oriented core map printout is available from a printer which provides the CET tempera-tures, temperature rises, and relative fuel assembly powers at each CET location. The average CET temperature and location of the hottest CET are also listed on the map. In addition, a summary map printout is available that lists the individual CRT temperatures in ascending order. Storage and trending capability exists which pro-vides the capability to'obtain a one-minuto-old core map, the current core map, or one of the hourly core maps (total of 24) that can be stored in the computer.

h Plant computer can monitor CET temperatures from less than 200*F up to 2,300*F. The computer also provides an automatic reference junction box temperature correction based on the measured temperature within the reference junction box. h CET inputs are scanned every eight seconds by the Plant computer. In the event that a CET input goes out of range (temperature too high or too low), the control room operator will be alerted by an audible alarm and flashing segment on the CRT display, and a printout of the summary map of the CET read-ings will automatically occur. Alarm setpoints are adjustable. The readout devices are located in the main control room to enhance operator accessibility. The Plant computer has been evaluated as part of the Detailed Control Room Design Review as discussed in response to Criterion 4.

3. Criterion 3 A backup display (or displays) shou *d be provided with the capability for selective reading of a minimum of 16 operable thermocouples, four from each core quadrant, all within a time interval no greater than six minutes. h range should extend from 200*F (or less) to 2,300*F (or more).

I Response for Criterion 3 i

l- The backup display consists of two subcooling margin monitors (Slet),

! which each receive inputs from eight CETs. Thus, the two Slots together have the capability to selectively read any of 16 CETs, four from each core quadrant, all within a time interval of six minutes.

Trojan Nuclear Plant Mr. D. G. Eisenhut Docket 50-344 January 4, 1985 License NPF-1 Attachment 2 Page 3 of 5 Data from individual CETs can be displayed by using a thumbwheel selector switch and pressing the individual sensor button on the SMN. If the indicated data shows that the CgT input is disabled or out of range, then the sensor input can be manually disabled. The appropriate temperature status lights are de-energized when the sensors are disabled or out of range. The SMMs can indicate CgT temperatures from less than 200*F up to 2,300*F.

4. Criterion 4 The types and locations of displays and alarms should be determined by performing a human-factors analysis taking into consideration:

a. The use of this information by an operator during both normal and abnormal plant conditions,

b. Integration into emergency procedures,

c. Integration into operator training, and

d. Other alarms during emergency and need for prioritization of alarms.

Response to Criterion 4 The Detailed Control Room Design review has conducted a human factors analysis of the primary and backup displays for abnormal or emergency conditions, and no significant deficiencies regarding the displays and alarms in conjunction with inadequate core cooling concerns were

! identified.

< The CgTs have been integrated into the existing emergency procedures.

j Trojan is committed to implementation of Revision 1 to the Westing-l house Owners Croup Emergency Response Guidelines in accordance with our schedules submitted in response to Supplement 1 to NUREG-0737.

5. Criterion 5 The instrumentation must be evaluated for conformance to Appendix B,

" Design and Qualification Celteria for Accident Monitoring Instru-mentation", as modified by the provisions of Items 6 through 9, which follow.

I gesponse to Criterion 5 i

l A detailed assessment of conformance to Appendix B is included in

Attachment 3.

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r Trojan Nuclear Plant Nr. D. G. Eisenhut Docket 50-344 January 4, 1985 License NPF-1 Attachment 2 Page 4 of 5

6. Criterion 6 The prisery and backup display channels should be electrically independent, energized from independent station Class 1E power sources, and physically separated in accordance with Regulatory Guide 1.75 up to and including any isolation device. The primary display and associated hardware beyond the isolation device need not be Class 1E, but should be energized from a high-reliability power source, battery backed, where momentary interruption is not tolerable. The backup display and associated hardware should be Class 1E.

Response to Criterion 6 The primary and backup displays are normally energized from Class 1E power sources and the CET inputs to both displays will be electrically isolated from each other as a result of the proposed modification of the CETs. The backup display is not Class 1E. See Attachment 3 Criterion 2 for further discussion of electrical separation.

7. Criterion 7 The instrumentation should be environmentally qualified as described l in Appendix B, Item 1, except that seismic qualification is not i required for the primary display and associated hardware beyond the isolator / input buffer at a location accessible for maintenance following an accident.

Resoonse to Criterion 7 Environmental and seismic qualification are addressed in the l

evaluation of conformance to Appendix B (Attachment 3).

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8. Criterion 8 The primary and backup display channels should be designed to provide 99 percent availability for each channel with respect to functional capability to display a minimum of four thermocouples per core quadrant. The availability shall be addressed in Technical specifications.

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! Response to Criterion 8 The availability of the SMNs is currently included in Technical

' specification 3.3.3.9 of the Trojan Technical specifications and, upon completion of system upgrading, the CETs will be added to this Technical Specification in response to NRC Genaric Letter 83-37.

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Trojan Nuclear Plant Mr. D. G. Eisenhut Docket 50-344 January 4, 1985 License NPF-1 Attachment 2 Page 5 of 5 Neither the primary or backup displays were documented as being designed with a 99 percent availability goal and a commitment to such a goal cannot be provided. It is considered sufficient for these instruments to be included in the Technical Specifications.

9. Criterion 9 The quality assurance provisions cited in Appendix B. Item 5 should 4- be applied except for the primary display and associated hardware beyond the isolation device.

Response to Criteelon 9 The quality assurance provisions cited in Appendix 8. Item 5 are addressed in Attachment 3.

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Trojan Nuclear Plant Mr. D. G. Eisenhut

-Docket 50-344 January 4, 1985 License NPF-1 Attachment 3 Page 1 of 10 COMPLIANCE WITH NUREG-0737 APPENDIX B DESIGN AND QUALIFICATION CRITERIA FOR THE SUBC00 LING MARGIN MDEITORS AND CORE EXIT THERMOCOUPLES

1. Criterion I h instrumentation should be environmentally qualified in accor-dance with Regulatory Guide 1.89 (NUEEG-0588). Qualification applies to the complete instrumentation channel from sensor to display where the display is a direct-indicating meter or recording device. Where the instrumentation channel signal is to be used in a computer-based display, recording and/or diagnostic program, quali-fication applies to and includes the channel isolation device. h location of the isolation device should be such that it would be accessible for maintenance during accident conditions. h seismic portion of environmental qualification should be in accordance with Regulatory Guide 1.100. h instrumentation should continue to read within the required accuracy following, but not necessarily during, a safe shutdown earthquake. Instrumentation, whose ranges are required to extend beyond those ranges calculated in the most severe design basis accident event for a given variable,'should be quali-fled using the following guidance.

h qualification environment shall be based on tha design basis accident events, except the assumed maximum of the value of the monitored variable shall be the value equal to the maximum range for the variable. N monitored variable shall be assumed to approach this peak by extrapolating the most severe initial ramp associated with the design basis accident events. h decay for this variable shall be considered proportional to the decay for this variable

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associated with the design basis accident events. No additional qualification margin needs to be added to the extended range variable. All environmental envelopes except that pertaining to the variable measured by the information display channel shall be those associated with the design basis accident events.

h above environmental qualification reluirement does not account for steady-state elevated levels that may occur in other environ-mental parameters associated with the extended range variables. For example, a sensor-measuring Containment pressure must be qualified for the measured-process variable range, but the corresponding ambient temperature is not acchanistically linked to that pressure.

Rather, the ambient temperature value is the bounding value for design basis accident event analyzed in Chapter 15 of the Final Safety Analysis Report (FSAR). h extended range requirement is to ensure that the equipment will continue to provide information should conditions degrade beyond those postulated in the safety analysis. Since variable ranges are nonsechanistically determined,

Trojan Nuclear Plant Mr. D. G. Eisenhut Docket 50-344 January 4, 1985 License NPF-1 Attachment 3 Page 2 of 10 extension of associated parameter levels is not justifiable and has, therefore, not been required.

Response to criterion 1 The installed CETs are Type K thermocouples. As allowed by Footnote 3 in Table 3 of Regulatory Guide 1.97, Revision 3, that part of the CET systc1t that is inside the reactor vessel is con-sidered environmentally qualified. The remainder of the CETs inside containment will be environmentally qualified. The primary display and associated computer are located in a mild environment and, as such, are not subject to environmental qualification requirements.

Seismic qualification of the CETs will be in accordance with the Plant design basis as a minimum, up to the primary display, which is not seismically qualified as allowed by NUREG-0737. Item II.F.2.,

Attachment 1, criterion 7.

The SMNs are located in a mild environment and, as such, are not subject to environmental qualification requirements. The inputs to the SMN will be environmentally qualified. The SIEt has not been seismically qualifled.

The' applicable isolation devices will be located in a mild environment and will be accessible for maintenance.

The requirement relating to qualification of instrumentation far beyond those ranges calculated in the most severe design basis accident is not considered applicable and will not be included within the scope of the environmental qualification documentation.

2. Criterion 2 No single failure within either the accident-monitoring instrumenta-tion, its auxiliary supporting features, or its power sources con-current with the failures that are a condition or result of a specific accident should prevent the operator from being presented

-the information necessary for him to determine the safety status of the plant and to bring the plant to a safe condition and maintain it in a safe condition following that accident. Where failure of one accident-monitoring channel results in ambiguity (that is, the redundant displays disagree) which could lead the operator to defeat or fall to accomplish a required safety function, additional information should be provided to allow the operator to deduce the actual conditions in the plant. This may be accomplished by:

(a) providing additional independent channels of information of the same variable (addition of an identical channel), (b) providing an

c; Trojan Nuclear Plant Mr. D. G. Eisenhut Docket 50-344 January 4, 1985 License NPF-1 Attachment 3 Page 3 of 10 independent channel which monitors a different variable bearing a known relationship to the maaltiple channels (addition of a diverse channel), or (c) providing the capability, if sufficient time is available, for the operator to perturb the measured variable and determine which channel has failed by observation of the response on each instrumentation channel. Redundant or diverse channels should be electrically independent, energized from a station Class 1E power source, and physically separated in accordance with Regulatory Guide 1.75 up to and including any isolation device. At least one channel should be displayed on a direct-indicating or recording device. (NOTE: Within each redundant division of a safety system, redundant monitoring channels are not required.)

Response to criterion 2 h CETs will not meet single failure criteria in that the system is generally a non-Class 1E system despite the environmental and seismic qualification of the in-Containment equipment. h SMKs will meet some of the principles of single failure criteria such as:

a. h SMKs are redundant and are powered from separate trains of power.

b. The Stets-will not share any cosmon inputs.

c. The Stets will be electrically isolated from the primary CET display.

The displays, as well as their inputs, will be energized from Class 1E power sources although the circuits will not be designed as Class 1E.

h cabling for the CET inputs to the backup display (ie, the Slets) will be physically separated in accordance with the Trojan Updated FSAR separation criteria; however, the cabling for the primary dis-play will not be physically separated. The CET cabling above the reactor vessel cannot meet these separation criteria without compromising the capability for each Stet to monitor all four core quadrants. For this reason, the cabling will be separated after exiting the area above the reactor vessel.

In addition, the primary dispisy power source will not be entirely independent of the backup display power source. As stated before, the backup display consists of two Slets, one powered from Train A and the other powered from Train B. h primary display is also powered from a Train B source. Thus, a loss of Train B would result in the loss of the primary display as well as half of the backup display. This is considered acceptable since the remaining Slet

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Trojan Nuclear Plant Mr. D. G. Eisenhut Docket 50-344 January 4, 1985 License NPF-1 Attachment 3 Page 4 of 10 would still be operable and would provide indication of 8 CETs, 2 in each core quadrant.

Information ambiguity due to a failed thermocouple channel will be readily resolvable since all 65 thermocouples will be upgraded. Any disparity between SNK displays will be resolvable by evaluation of the inputs (RTDs and RCS pressure) to the SMNs which are also displayed in the control room.

3. Criterion 3 The instrumentation should be energized from station Class 1E power sources.

Response to criterion 3 The power sources for the SMMs and CETs will be from class 1E power sources.

4. Criterion 4 An instrumentation channel should be available prior to an accident, except as provided in Paragraph 4.11. " Exemption", as defined in IEEE Standard 279 or as specified in Technical Specifications.

Response to Celterion 4 The availability of the SMMs is currently addressed in the Technical Specifications. The availability of the 16 CETs which read out on the SnNs will be included in a future revision of the Technical Specifications.

5. Criterion 5 The recommendations of the following regulatory guides pertaining to quality assurance should be followed:

1.28 " Quality Assurance Program Requirements (Design and Construction)".

1.30 " Quality Assurance Requirements for the Installation, Inspection, and Testing of Instrumentation and Electric Equipment".

1.38 " Quality Assurance Requirements for Packaging, Shipping, Receiving, Storage, and Handling of Items for Water-cooled Nuclear Power Plants".

Trojan Nuclear Plant Mr. D. G. Eisenhut Docket 50-344 January 4, 1985 License NPF-1 Attachment 3 Page 5 of 10 1.58 " Qualification of Nuclear Power Plant Inspection.

Examination, and Testing Personnel".

1.64 " Quality Assurance Requirements for the Design of

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Nuclear Power Plants".

1.74 " Quality Assurance Tera.s and Definltions".

1.88 " Collection, Stcrage, and Maintenance of Nuclear Power Plant Quality Assurance Records".

1.123 " Quality Assurance Requirements for Control of Procurement of Items and Services for Nuclear Power Plants".

1.144 " Auditing of Quality Assurance Programs for Nuclear ,

Power Plants".

Task RS 810-5 " Qualification of Quality Assurance Program Audit Personnel for Nuclear Power Plants" (guide number to be inserted).

2 Reference to the above regulatory guides (except Regulatory Guides 1.30 and 1.38) is being made pending issuance of a regulatory guide endorsing NQA-1 (Task RS 002-5), now in progress.

Response to Cel.terion 5 The subject Regulatory Guides have been integrated into the Nuclear Quality Assurance Program (PGE-8010) in accordance with the PGE In-House Position document. Compliance with these Regulatory Guides is discussed in the Introduction and Supplement 2 to PGE-8010. This

, report has been submitted to the NRC for review in accordance with the Quality Assurance Program requirements. Based on this, the quality assurance requirements are considered to be met. In accor-dance with Criterion 9 of Attachment 1, these quality assurance requirements do not apply to the primary display.

6. Celterion 6 Continuous indication (it may be by recording) display should be provided at all times. Where two or more instruments are needed to cover a particular range, overlapping of instrument span should be provided.

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-f Trojan Nuclear plant - Mr. D. G. Eisenhut Docket 50-344 January 4, 1985 l License NPF-1 Attachment 3 Page 6 of 10 Response to Criterion 6 Indication for the CETE is discussed in the response to criterion 2 in Attactament 2. Overlapping of instrument span is not necessary in this case. Continuous subcooling margin indication is available provided the operator selects 1.his position on the selector switch.

7. Criterion 7 Recording of instrumentation readout information should be provided.

Where trend or transient information is essential for operator information or action. the recording should be analog strip chart or stored and displayed continuously on demand. Intermittent displays, such as data loggers and scanning recorders, may be used if no significant transient response information is likely to be lost by such devices.

Response to Criterion 7 Recording of CET temperature is available on the primary display as discussed in Attachment 2, criterion 2.. Overlapping of instrument span is not necessary in this case. The Stets do not include a pro-vision for recording nor is recording of subcooling margin con-sidered critical for operator response. Continuous indication is >

available and alarms are available to warn of loss and potential loss of subcooling margin. In addition, all the RCS RTD and one RCS pressure input to the Slets are recorded and the CETs are recorded to the extent stated above.

8. Criterion 8 The instruments should be specifically identified on the control panels so that the operator can easily discern that they are intended for use under accident conditions.

Response to Criterion 8 5 This requirement was evaluated as part of the Detailed Control Room Design Review and it was concluded that such identification would unnecessarily clutter the control panels and could potentially result in operator misinterpretation during critical periods.

j Consequently, the displays will not be marked in such a special manner. ,

9. Criterion 9

The transmission of signals from the instrument or associated sensors for other use should be through isolation devices that are I

Trejan Nuclear Plant Mr. D. G. Eisenhut Docket 50-344 January 4, 1985 License NPF-1 Attachment 3 Page 7 of 10 designated as part of monitoring instrumentation and that meet the provisions of this document.

Response to Criterion 9 The CET input to the SMM will be isolated frca the primary display as a result of the proposed modification. The RTD and pressure inputs to the SNMs will be isolated from their respective circuits, and the isolation devices are designed to meet the specified pro-visions in that they are seismically qualified and are designed for use in Class 1E circuits.

10. Criterion 10 Means should be provided for checkind, with a high degree of confi-dance, the operational availability of each monitoring channel, including its input sensor, during reactor operaticn. This may be accomplished in various ways. For example:

a. By perturbing the monitored variable.

b. By introducing and varying, as appropriate, a substitute input to the sensor of the same nature as the measured variable.

c. By cross-checking between channels that bear a known relation-ship to each other and that have readouts available.

Response to Celterion 10 CET availability is readily verified by comparison with other CgTs.

The SNMs may be compared with each other. In addition, subcooling margin may be manually calculated and then compared to the SMM.

11. Criterion 11 Servicing, testing, and calibrating programs should be specified to maintain the capability of the monitoring instrumentation. For those instruments where the required interval between testing will be less than the normal time interval between generating station shutdowns, a capability for testing during power operation should be provided.

Response to Criterion 11 Servicing, testing, and calibrating programs have been specified for the SMMs. Capability for testing during power operation is not required. The SMM surveillance requirements have also been included in the Trojan Technical Specifications.

Trojan Nuclear Plant Mr. D. G. Eisenhut Docket 50-344 January 4, 1985 License NPF-1 Attachment 3 Page 8 of 10

12. Criterion 12 Whenever means for removing channels from service are included in the design, the design should facilitate administrative control of the access to such removal means.

Response to Criterion 12 Removal of channels from service and adjustments to circuits are controlled by approved Plant procedures. The administrative control of this equipment is in effect.

13. Criterion 13 The design should facilitate administrative control of the access to all setpoint adjustments, module calibration adjustments, and test points.

Response to Criterion 13 Administrative controls era already considered to be in effect where necessary as stated in tn= response to Criterion 12.

14. Criterion 14 The monitoring instrumentation design should minimize the develop-ment of conditions that would cause meters, annunciators, recorders, alarms, etc, to give anomalous indications potentially confusing to the operator.

Response to Criterion 14 The CET primary display and the SMMs have been evaluated as part of the Detailed Control Room Design Review and no significant deficiencies I were found in this regard. In addition, the CETs and SHMs have been in operation for several years and have not demonstrated indication anomalies. The planned modifications will not affect the reliability in this regard.

15. Criterion 15 The instrumentation should be designed to facilitate the recogni-tion, location, replacement, repair, or adjustment of malfunctioning l

components or modules.

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Trojan Nuclear Plant Mr. D. G. Eisenhut Docket'50-344 January 4, 1985 License NPF-1 Attachment 3 Page 9 of 10 Resoonse to criterion 15 The CETs and Slets are designed such that a malfunctioning channel will be apparent due to inconsistent indication. Normal trouble-shooting techniques will be applied to locate malfunctioning components.

16. Criterion 16 To the extent practical, monitoring instrumentation inputs should be from sensors that directly measure the desired variables.

Response to Criterion 16 The CETs provide direct indication of incore temperature. Subcool-ing margin is calculated from inputs which directly measure the required parameters.

17. Criterion 17 To the extent practical, the same instruments should be used for accident monitoring as are used for the normal operations of the plant to enable the operator to use, during accident situations, instruments with which the operator is most familiar, llowever, where the required range of monitoring instrumentation results in a loss of instrumentntion sensitivity in the normal operating range, separate instru ents. should be used.

Response to Criterion 17 The CET primary display is the same display as is used during normal operation. The Slets are intended to act as accident-monitoring instrumentation and are located in the control room on Panel C09, the post-accident monitoring panel. The SMNs are available continu-ously during normal operation and, therefore, the operators will be familiar with the instrument rendout.

18. Criterion 18 1

Periodic testing should be in accordance with the applicable por-tions of Regulatory Guide 1.118 pertaining to testing of instruments

< channels.

Response to Criterion 18 i.

j Regulatory-Quide 1.118 endorses, with some clarification, IEEE 338-1977, "IEEE Standard Criteria for the Periodic Testing of Nuclear Power Generation Station Safety Systems". IEEE 338-1977 i

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Trojan Nuclear Plant Mr. D. G. Eisenhut Docket 50-344 January 4, 1985 License NPF-1 Attachment 3 Page 10 of 10 applies to safety systems and Regulatory Guide 1.118 states the following:

The term " safety system" is used in IEEE Standard 338-1977 in

, wany places. For the purpose of this guide, " safety system" should be understood to mean, collectively, the electric, instrumentation and controls portion of the protection system; the protective action systems; and the auxiliary or supporting features that must be operable for the protection system and protective action system to perform their safety-related functions.

The provision of indication for inadequate core cooling is not con-4 sidered a protective function. The indication of these parameters is intended only to assist the operators in verifying that other j protective systems are operating as designed. As such, indication circuits appear to be outside the scope of Regulatory Guide 1.118.

The operability of the SMMs is already addressed by channel avail-ability and surveillance requirements specified in the Trojan Tech-nical Specifications. In accordance with NRC Generic Letter 83-37, the CETs will also be included in the Technical Specifications upon completion of the system upgrade. By including this instrumentation i

in our Technical Specifications, operability requirements and periodic surveillance tests will be established which are consistent with other accident-monitoring instrumentation. This approach is

' considered acceptable in lieu of meeting Regulatory Guide 1.118.

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