ML20236M983

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Forwards TIA Response to 961030 Region I Request to Review Issue Related to Scope of Channel Functional Testing Required by Ts.Memo Supersedes Memo
ML20236M983
Person / Time
Site: Peach Bottom  Constellation icon.png
Issue date: 02/18/1997
From: Wermiel J
NRC (Affiliation Not Assigned)
To: Stolz J
NRC (Affiliation Not Assigned)
Shared Package
ML20236J990 List: ... further results
References
FOIA-98-155 TAC-M97160, NUDOCS 9807140349
Download: ML20236M983 (8)
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  • February 18, 1997 AEMDRASCUM TO: John F. Stott, Director Protect Directorate b2 {

OMeien of Reactor Projects I and N PROM: Jared S. Warmist, Chief enetrumenestion and Controls Branch DMelon of Reactor Contrais and Human Factors

SUBJECT:

TASK INTERFACE AGREEMENT RESPONSE - SCOPE OF TECHNICAL SPECIFICATION REQUIRED CHANNEL FUNCTIONAL TEST AT PEACH SOTTOM ( TAC NO. M97180)

Plant Nome (s): Peach Bottom 2 & 3 Utaty: Phaedolphia Electric Co.

TAC No.: M97160 Docket No.: 50 277/278 Opersting Uconse: DPR 44/DPR 56 Protect Drectorste: F2 Propect Manager: J. Shes Review tranch: HICS/DRCH l

Review Status: Comsdete By memorendum dated October 30,1996, Region I roguested NRR review of an issue reisted to the scope of channel functional teenng which is required try the Technical SpecrRcetions. The leeus relates to the boundary between instrument channel functional testing and logic system functionsi testing which are performed at different intervels. The attached evolustion provides our response to the Region I request. This rnemorandum supersedes my snamorendum to you on this outsoct dated January 30,1997, and includes our poohion with regard to other Econsocs who have not adopted the improved TS.

Docket Nos. 50 277/278 CONTACT: Hukam Gerg. HlCB l 415 2929 Attachmenc As oested g%NN DISTRIBUTION g Centrespase 65C8 RM (2)

J. Shoe s.sogar XUENT NAME.:, PeachB.TI.A (97-08)

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Fetruary 18, 1997 MEMORANDUM TO: John F. Statr, Drector Project Directorate 12 Dhneion of Reactor Projects I and il FROM: Jared S. Wermiel, Chief instrumentation and Controls Branch Devianon of Reactor Controls

  • and Human Factors

SUBJECT:

TASK INTERFACE AGREEMENT RESPONSE - SCOPE OF TECHNICAL SPECIFICATION REQUIRED CHANNEL FUNCTIONAL TEST AT PEACH BOTTOM ( TAC NO. M97160)

Plant Name(s): Peach Bottom 2 & 3 Utdity: Philadelphia Electric Co.

TAC No.: M97160 Docket No.: 50 277/278

, Operating License: DPR 44/DPfi 56 Project Drectorate: 12 Project Meneger: J. Shos Review tranch: HICS/DRCH Review Status: Complete By memorandum dated October 30,1996, Region I requested NRR review of an issue reisted to the ecoes of channel functional testing which is required by the Technical Specifications. The leeus relates to the tMxedary between instrument channel functional tasane and logic system functional testing which are performed at different intervals. The attached evolustion provides our tesponse to the Region I roguest. This memorandum supersedes my memorandum to yrs on this subsect dated January 30,1997, and includes our poorpon with regard to other ascensees who have not adopted the improved TS.

Docket Nos. 50 277/278 CONTACT: Hukam Garg, HIC 8 415 2929

Attachment:

As stated DISTRIBLITION Central Filer.

HIC 8 R/F (2)

J. Shoe

s. sogar DOCLMDIT NAPE: Peach 8.TIA (97-08)

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ILARE HGare H(9 era M / JWr4Tel DATE 01/ f6/97 Y Ol//l/97 102//V/97 0FFICIAL RECORD COPY

O p k" UNITED STATES NUCLEAR REGULATORY COMMISSION wAammaron, o.c. seeswam TASK INTERFACE AGREEMENT RESPONSE BY THE OFFICE OF NUCLEAR REACTOR REGULATION SCOPE OF INSTRUMENT CHANNEL FUNCTIONAL TESTING PHILADELPHIA ELECTRIC CO.

PEACH BOTTOM UNITS 2 & 3 TAC NO. M97160

1.0 INTRODUCTION

Technical Specifications (TS), in general, require that Channel Functional Testing (CFT) be performed guarterly and Logic System Functional Testing (LSFT) be performed at refueling outages for all safety-related instrumentation. Region I, in its memorandum, dated October 30,1996, requested NRR help to define the proper scope of CFT with respect to LSFT.

This request was made in order to resolve outstanding inspection issues regarding functional testing identified at Peach Bottom Units 2 and 3. The Philadelphia Electric Co.

(PECO) at Peach Bottom does not test all relay contacts that input to the logic circuits as part of the CFT. There is a difference of opinion within the PECO staff on whether this is acceptable. One group with in the PECO staff believes that all contacts, including those supplying input to Engineered 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 opinion is based on the licensee's understanding of 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

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. l 2-Section 7.1.5 of the Peach Bottom UFSAR contains the following definition of a channel:

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'A channel is an arrangement of sensors and associated components used to monitor plant variables and produce discrete outputs used in logic. A channel terminates ard loses its identity where individual channel outputs are combined in j logic." l I

l A CFT is defined in the Peach Bottom TS as follows:

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'A CHANNEL FUNCTIONAL TEST shall be the injection of a simulated or actual signal into the channel as close to the sensor as practicable to verify OPERABILITY, i

including required alarm, interlock, display, and trip functions, and channel failure trips. The CHANNEL FUNCTIONAL TEST may be performed by means of any series of sequential, overlapping, or total channel steps, so that the entire channel is l tested."

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. l NRC inspectors believe that based on the CFT definition s!! relay contacts associated with  ;

1 the channel should be verified operable. Therefore, Region Iissued a TIA to resolve this I e

i issue and requested NRR to provide answers to the following three basic questions:

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1. Where do instrument channels and logic systems overlap?
2. Does verification of relay coil energiration verify operability of trip functions?
3. What is ti,e correct frequency of verifying the proper actuation of instrument channel relay contacts that provide output into ESF logic?

2.0 EVALUATION NRR has previously provided a response to a request similar to this TIA (Memorandum dated February 20,1986, from R. Bernero, Director, Division of BWR licensing, NRR to R.

Starostocki, Director, Division Reactor Projects, Region 1). In the 1986 memorandum, NRR concluded that contacts associated with relays in a channel should be verified operable during a CFT. In the 1986 memorandum, the definition of CFT for Susquehanna reads as follows:

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" A CHANNEL FUNCTIONAL TEST shall be

a. Analog Channels The injection of a simulated signalinto the channel as close to the sensor as practicable to verify OPERABILITY including alarm and/or trip functions and channel failure trips.

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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 sequential, overlapping, or total channel steps such that entire channel is tested."

Based on this definition of CFT, it is the staff's position that the previous interpretation in the February 20,1986 memorandum, that all contacts of relay (s) (master as well as slave) associated with a channel be verified operable is not correct. Our present interpretation of the definition of CFT with the 'and/or" statement requires licensees to demonstrate operability of relays by verifying that at least one contact has changed state, if the design of the channel is such that additional contacts associated with the relay can be verified operable, then it is desirable to do so as part of the CFT. However, if the design is such that jumpering or lifting of leads is necessary for verifying contact operability, then the CFT need not include these contacts. These contacts would be included in the LSFT. This staff position is applicable to all plants including Susquehanna that have 'and/or" in their definition of CFT in their TS.

On the other hand, the Peach Bottom TS definition of CFT states, *-verify OPERABILITY l Including alarm, interlock, display, and trip funct!.ns and channel failure trips.". Therefore, based on this definition, it is the staff's position that all relay contacts associated with a channel are required to be verified operable since in order to confirm the functions (interlock, display and trip) stated, the contact must be demonstrated to be operable. This position is applicable to all plants which have "and" in the definition of CFT in their TS.

e 5-it should also be noted that the Peach Bottom TS definition for CFT is derived from the definition in the improved TS (ITS) and is used by other plants which have converted to l

the ITS. The definition of CFT for plants that have not converted to the ITS it similar to I the definition of CFT used by Susquehanna. Therefore, based on this clarification response to the three questions posed in the TIA could be summarized as follows:

1. The CFT and LSFT overlap at the relay contacts associated with the channel and the CFT ands at those contacts. Therefore, the LSFT starts at these contacts and when a contact is not demonstrated operable during a CFT it must be demonstrated operable during LSFT.
2. Verification of relay coil energiration does not confirm the operability of the trip function as contact closure / opening is not assured.
3. The frequency for verifying operability of instrument channel relay contacts that provide input to ESF logic depends on the TS definition of CFT (use of and/or vs.

and) as stated above.

Based on our review of the UFSAR definition of " channel", the Peach Bottom TS definition of CFT and our review of Attachment 1 of the TIA, we believe that PECO has not been testing all relay contacts associated with the instrument channel during a CFT as required by the Peach Bottom TS. The licenses should therefore, either revise their procedures to test allinstrument channel relay contacts during a CFT or request TS relief for the cases where it can be justified.

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3.0 CONCLUSION

Based on our review of the Peach Bottom UFSAR and TS, and Susquehanna TS as requested in the Region i TIA, NRR concludes that for plants with TS similar to Peach Bottom (those with "and* in the CFT definition),all instrument channel relay contacts should be included in a CFT if they supply alarm, interlock, display, a channel failure trip or trip functions. Furthermore, NRR concludes that PECO has not been testing all contacts associated with the channel as required by TS and should either revise their procedures to include these contacts or request TS relief,if justified, to change the frequency of testing for those contacts. For those operating plants with TS similar to Susquehanna (those with "and/or" in the CFT definition), verification of operability of at least one contact associated with the channel relay is acceptable.

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