ML20206M875
| ML20206M875 | |
| Person / Time | |
|---|---|
| Site: | Susquehanna  |
| Issue date: | 02/20/1986 |
| From: | Bernero R Office of Nuclear Reactor Regulation |
| To: | Starostecki R NRC OFFICE OF INSPECTION & ENFORCEMENT (IE REGION I) |
| Shared Package | |
| ML20206M839 | List:
|
| References | |
| NUDOCS 8607010306 | |
| Download: ML20206M875 (4) | |
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8 UNITED STATES
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NUCLEAR REGULATORY COMMISSION o
o WASHING TON. D. C. 20555 a
%,..... f FEB 20 E MEMORANDUM FOR: -
ostecki, Director Division Reactors Projects, Region I FROM:
R. Bernero, Director Division BWR Licensing, NRR
SUBJECT:
CHANNEL FUNCTIONAL TESTS - TECHNICAL SPECIFICATION INTERPRETATION of testing is necessary to meet the Technical Specificatio channel functional test (CFT), and whether PP&L's testing methods for CFTs are acceptable.
You requested NRR's position in your December 12, 1985, memorandum.
After reviewing your memorandum and the appropriate Technical Specifications NRR staff's position is that channel functional tests for instrumentation channels must test all components up to the point where single action signals are combined.
In our review we also find that PP&L's methods for CFT are no t
acceptable because certain components (e.g., relays) in the channel upstream of the combinatorial logic are excluded from the CFT.
Technical Specification 1.6 defines channel functional test as follows:
"A CHANNEL FUNCTIONAL TEST shall be Analog channels - the injection of a simulated signal into the channel a.
alarm and/or trip functions and channel failure trips.as b.
Bistable channels - the injection of a simulated signal into the sensor to verify OPERABILITY including alarm and/or trip functions.
The CHANNEL FUNCTIONAL TEST may be performed by any series of sequ overlapping, or total channel steps such that the entire channel is tested."
This definition is based upon industry standards (IEEE-279 and 380) which defin a " channel" as:
"An arrangement of components and modules as required to generate a single protective action signal when required by a generating station condition.
A channel loses its identity where single action signals are combined."
8607010306 860625 DR ADOCK 05000387 PDR
.. s FEB 202 A CFT must therefore test to the point where single action signals are combined.
An entire channel includes all contacts, relays, indications and alanns which precede the combinatorial logic.
In the example circuit provided with your December 12, 1985 memorandum (Figure 1, Enclosure 1 to this memorandum) the channel extends to the K45 contacts and status indication light (W).
The E41-K45 relay and status indication should be included in the CFT.
The definition proposed by the licensee would terminate the channel at a point that does not include the channel status indication.
The licensee's contention that " channel" may be defined other than as in the industry standards because the Technical Specifications use the modifier
" instrumentation" is unacceptable.
The other arguments presented by the licensee dealt with the problems of using jumpers, lifting leads, and potential manpower impacts.
While these may provide grounds for revising the frequency of testing of certain components, they do not provide grounds for altering the intended testing method.
This input has been provided by the Division of Human Factors Technology Tech-nical Specification Review Group.
Robert M. Bernero, Director Division of BWR Licensing cc:
D. Eisenhut W. Russell T. Novak F. Miraglia T. Speis s.
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FIGURE 1 HPCI HIGH LEVEL TURBINE TRIP
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Lis-821-No2H8 r--__ K45 1
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CHANNEL
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kil H "
LEVE L TRIP TRIP SnTEr4
- K45 is a relay in one channel of the HPCI high reactor vessel level trip system.
- K56 (contact only shown) is a relay in the other channel.
Kil is the high reactor vessel level trip relay. A contact from this relay activates a turbine trip relay.
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