ML20236M924
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Jasonry 30, 1997 l
MDAORA8 cum TO:
John F. Statr, Obscter Prefect Desctersee F2 l
Dwelen of Reacter Protects i and a retoM:
. sered S. wennist. CNet l
Instrwnenteden and Centrais Granch DMeion of Reacter Centrais j
and Hwnen Facters l
SUEJECT:
TASE INTERFACE AGREftdENT RESPONSE SCOPE OF l
TECHMCAL CPEORCATON REQUIRED CHANNEL PUNCTOMAL TEST AT PEACH SQTTOM ( TAC NO. M97160)
Plant Name(s):
Peach Gottorn 2 & 3 Ulsty:
Phaedoistes Electric Co.
TAC No.:
M971SO Docket No.:
50 277/278 Operating Ocense:
DPR 44/DPR 58 Preisct Drectorate:
b2 Preiset Manager:
J. Shoe Review aranch:
teCs/DRCH l
Review Status:
Complete By memorandum dated October 30.1996. Region I requested NRR review of en issue related to the scope of channel functional teeang which is roguered by the Technical Specifications. The issue relates to the boundary betwoon instrument channel functional tesun0 and logic system funcuonal tesung which are performed at different intervals. The attached evolustion provides our response to the Region I request.
Docket Nos. 50 277/278 CONTACT: Hukem Gerg, HIC 8 415-2929
Attachment:
As stated DISTRIBUTION Centrol Files t )
HICS R/F (2)
M.*lO"1
% 7 J. Shoe
- s. sogar ELMENT MARE.,: PeachB.TI.A (97-08) r.e,-
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~c.e,c 0FFICE hic 8:DRCH lC SC: HIC 8 p// l BC:t(LC8, lE l
NARE HGarg N U/
N' JWer W I DATE 01/F/97 01/Jb/97 01//b/97 0FFICIAL. RECORD COPY 9807140329 980624 f
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Jammary 30. 1997 WMORANDUM TO:
John F. Stett. Drector Pro 6sct Drectorate F2 Deveson of Reactor Projects I and u FROM:
Jared S. Warmiel. Cruef enetrumentsoen and Contrats tranch Onesion of Reactor Contrais and Hwnen Factors i
SUSJECT:
TASE INTERFACE AGREEMENT RESPONSE SCOPE OF TECHMCAL SPEQF) CATION REQUIRED CHANNEL FUNCTIONAL TEST AT PEACH SOTTOM ( TAC NO. M97160) i l
Plant Namet.al:
Poech Gottom 2 & 3 uenty:
Phdaden tus sectne Co.
a TAC No.:
M97160 Docket No.:
60 277/278 Operating Uconoo:
DPR 444)PR-56 Propect Drectorste:
F2 Pro 6ect Manager:
J. Shoe Review Branch:
HICS/DRCH Roweew Status:
Complets By memorandum dated October 30,1996. Respan I roguested NRR review of an issue reisted to the scope of channet funceonel tasang which is regured by the Technical Spectnescons. The issue retetes to the boundary betwoon anstrument channel functional tasang and logic system funcnonal tesang which are performed at different intervals. The attached evolusoon provides our response to the Region I request.
Docket Nos. 50-277/278 CONTACT Hukam Garg. HIC 8 415 2929
Attachment:
As stated DISTRIBUTION Centrol Files HICS RM (2)
J. Shoe
- s. sogar DOCW O T IRA.E :...
T I.A (97-08) r.c-r..
Peacn8 OFFICE HIC 8:DRCH lC SC: HIC 8 g// l BC:t(LC8, lE l
l NARE HGarg
/66 ENW '
JWertn?l DATE 01/3t/97 01/ib/97 01/f$/97 0FFICIAL RECORD COPY l
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l TASK INTDtFACE AGREDENT RESPONSE
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BY Tid OFFICE OF NUCLEAR REACTOR REGULATION SCOPE OF INSTRUIENT CHANNEL FUNCTIONAL TESTING Plet.ADELPHIA ELECTRIC CD.
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PEACH BOTTOM UNITS 2 at 2. TAC NO. M97180 l
1.0 INTRODUCTION
Techracal Space 6 canons (TS), in general, remare that Channel FuncDonal Testing (CFT) be performed guerterty and Lope System Funcnonal Tesung (LSFT) be performed at refueling outages for as nefety-taleted instrumentation. Repan I, in its memorandum, dated October 30,1998, roguasted NRA help to define the proper scope of CFT with respect to LSFT.
l This request was made in order to resolve outstandmg inspection issues regarding funcoonal tesang adonefied at Peach Bottom Units 2 and 3. The Phdadelphis Electric Co.
(PECO) et Peach Bottom does not test as relay contacts that input to the logic circuits as part of the CFT. There is a difference of opinion withm the'PECO staff on whether this is acceptatds. One youp with in the PECO staff beiseves that au contacts, including those supplying input to Enyneered Safety Feature (ESF) logic, need to be functionally verified at the time of CFT another believes that the contacts could be tested with the LSFT. This difference of opstmon is based on the ambiguity between the definition of a channel stated in the Updated Final Safety Evaluation Report (UFSAR) Section 7.1.5 and the definition of a CFT stated in the TS.
ATTACHMENT l
1
2 Secoon 7.1.5 of the Peach Gottom UFSAR contame the following definition of a channel:
"A channelis an arrangement of sensors and associataJ components used to monitor plant venatdes and produca discrete outputs used in logic. A channel terminates and loses its idenoty where indnndual channel outputs are combined in logic.*
A CFT is defined in the Peach Bottom TS as fosows:
"A CHANNEL FUNCTIONAL TEST shes be the injection of a simulated or actual signal into the channel as close to the sensor as practicable to verify OPERABILITY.
including requwed alarm, interlock. display, and trip functions, and channel f ailure tripe. The CHANNEL FUNCTIONAL TEST may be performed by means of any series of sequennel, overlapping, or total channel steps, so that the entire channel is tested."
NRC inspectors believe that based on the CFT definition su relay contacts associated with the channel shodd be verified operable. However, the Peach Bottom UFSAR definition of charmel is amtsguous, in that, it states that the channel loses it identity when individual channel outputs are combened in logic. Therefore, Region I issued a TIA to resolve this ambiguity and requested NRR to provide aryswers to the following three basic questions:
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- 1. Where do instrwrent channels and logic systems overlap?
- 2. Does verificanon of relay coil energiration verify operabikty of trip funcoons?
- 3. What is the correct frequency of verifying the proper actueDon of instrument channel meer contacts that provede output into ESF logic?
2.0 EVALUATION NRR has previously provided a response to a request samdar to this TIA (Memorandurn dated February 20,1986, from R. Bemero Dweetor, Division of BWR licensmg, NRR to R.
Staroetecki, Director, Divirion Reactor Projects, Region 1). In the 1986 memorandum, NRR concluded that contacts associated with relays in a channel should be verified operstdo dunne a CFT. However, this memorandum did not clarify the ambiguity between the definition of channel and the definition of CFT. Relays aanmated with a channel are located in the same cabinet with the channel, and the wiring frorn the contacts to the logic cabinet, where the logic is created, is routed in a cable tray or conduit associated with tlw channel. Therefore, the contacts are part of the channel and they do not lose their identity witn the channel. In the logic cabinet, eagnals from aR channels are cornbined to form the desired logic. Herce, et continues to be NRRs pmition that all instrument channel relay
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l contacts which prowWe input to ESF logic shoukt be tested dunn0 a CFT. Based on this, the respones to the three guesnons posed in the TIA could be summanret as fotows:
- 1. The CFT and t.SFT overiep at the roley contacts assocasted with the channel and the CFT ands at thoes contacts. Therefore, the LSFT starts et these contacts.
- 2. Venfication of relay coil energizacon does not confirm the operatsirty of the trip function as contact closure /opereng is not assured.
- 3. The frequency for wentying operability of instrument channel relay contacts that provide output into ESF logic shou 6d be the same as that for a CFT. However, Econsees caa request TS reiamanon in test frequency for relay contacts if it can be justified by cost / benefit analyons for circuits that are difficutt to test hae= of required jumpers.
bfnne of ic.ds, etc.
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Based on our interpretsoon of the defrition for CFT and our review of Attachment 1 of the TIA, we believe that PECO has not been testing as relay contacts associated with the instrument chonnel dunne a CFT as required by the Peach Bottom TS. The licensee should therefore, either revise their procedures to test all instrument channel relay contacts during a CFT or roguest TS relief for the cases where it can be justified by a co,st/ benefit analysis.
In addition, the UFSAR definition of a channel should be clarified to be consist, ant with tlw TS derrition of a CFT.
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3.0 CONCLUSION
Saeed on our review of the Peach Gottom UFSAR and TS as roguested in the Respon i TIA.
NRR concludes that as instrument channel relay contacts shoud be included in a CFT H they eusedy asenn. Intadock. stesday, a channel feaure trip or trip functions. Furthermore.
NRR concludes that PECO hee not been toseng as contacts sesociated with the channel as required by TS and shouCJ nether revies their procedures to include these contacts or roguest TS refief, N justified, to change the frequency of toepng for those contacts.
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