ML20236N052

Forwards TIA Response by NRR Re Scope of Channel Functional Testing Required by Plant TSs

ML20236N052
Person / Time
Site:	Peach Bottom
Issue date:	04/09/1997
From:	Stolz J NRC (Affiliation Not Assigned)
To:	Hehl C NRC OFFICE OF INSPECTION & ENFORCEMENT (IE REGION I)
Shared Package
ML20236J990	List: IA-98-155, Responds to 980513 Request from Duquesne Light Co to Provide Written Interpretation of Beaver Valley Power Station,Unit 1 & 2 TSs Requirements for Channel Calibration of Rtds & Thermocouples IR 05000482/1991021 ML20236J987 ML20236K746 ML20236K751 ML20236K780 ML20236K784 ML20236K803 ML20236K816 ML20236K840 ML20236K853 ML20236K883 ML20236K902 ML20236K916 ML20236K936 ML20236K963 ML20236L549 ML20236L558 ML20236L563 ML20236L580 ML20236L584 ML20236L590 ML20236L597 ML20236L653 ML20236L921 ML20236L955 ML20236L971 ML20236M014 ML20236M020 ML20236M034 ML20236M057 ML20236M117 ML20236M138 ML20236M148 ML20236M911 ML20236M924 ML20236M966 ML20236M983 ML20236M996 ML20236N007 ML20236N047 ML20236N052 ML20236N066 ML20236N221 ML20236N240 ML20236N257 ML20236N271 ML20236N288 ML20236N323 ML20236N333 ... further results
References
FOIA-98-155 TAC-M97160, NUDOCS 9807140378
Download: ML20236N052 (4)

Text

.____ __________ - - _ - _ _ _ - .

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MEMORANDUM T0: Charles W. Hehl, Director APn1 9, 199/

2, .

Division of Reactor Projects, Region I k FROM: John F. Stolz, Director /s/ L. 01shan for I

. Project Directorate I-2 l Division of Reactor Projects - I/II

SUBJECT:

office of Nuclear Reactor Regulation hk TASK INTERFACE AGREEMENT RESPONSE - SCOPE OF TECHNICAL SPECIFICATION REQUIRED CHANNEL FUNCTIONAL TEST AT PEACH BOTTOM ATOMIC POWER STATION, UNITS 2 AND 3 (TAC NO. M97160)

By memorandum dated October 30, 1996 Region I requested NRR review of an

- issue related to the scope of channel functional testing required by the Peach Bottom Technical Specifications (TSs). The issue relates to the boundary between instrument channel functional testing and logic system functional testing which are performed at different intervals. The attached evaluation, prepared by the Instrumentation and Controls Branch in NRR, provides a response to the Region I request.

NRR has concluded that the Peach Bottom channel functional test surveillance practices meet the staff's interpretation of the TS requirements in that at least one relay contact is monitored during the channel functional test to confim channel relay operability. However, because the staff has determined )

that the channel functional test definition in the Peach Bottom TSs (which is consistent with the NUREG-1433 definition) contains the potential for misunderstanding the TS requirements, the staff will interact with industry representatives in order to clarify the wording in the generic definition of channel functional test and related instrumentation and control testing terminology in the TSs. The staff, thereafter, will interact with PECO Energy Company to incorporate any revised definitions as appropriate.

Attachment:

As stated cc w/att: J. R. Johnson, RGN-II J. L. Caldwell, RGN-III A. T. Howell, RGN-IV CONTACT: J. Shea, NRR (301) 415-1428 DISTRIBUTION:  !

Docket File JStolz JWermiel AChaffee l PDI-2 Reading JShea EMarinos RZimmerman SVarga i M0'Brien HGarg CGrimes WPasciak, RI TLiu WSchmidt, SRI CSchulten JRoe JMoore, 0GC WRuland, RI MBoyle (E-mail MLB4)

EAdensas EHoller, 0GC TColburn BBoger

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• NAME MM Nd N JWermiel CGrimes JSMz EHo11er DATE k/9/97 k # /97 4/08/97 4/08/97 $/d/97 3/28/97 0FFICIAL LECORD COPY j DOCUMENT NAME: G:\5HEA\ PEACH \PB97160. IIA i

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l i Region I issued a TIA to resolve whether All relay contacts associated with a channel should be tested to verify operability, and requested NRR to provide answers to the following three basic questions:

1. Where do instrument channels and logic systems overlap?

2. Does verification of relay coil energization verify operability of trip functions? .

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3. What is the correct frequency of verifying the proper tctuation of instrument channel relay contacts that provide output into ESF logic?

2.0 EVALUATION NRR provided a response to a similar TIA in a memorandum dated February 20, 1986, from R. Bernero, Director, Division BWR Licensing, NRR to R.

Starostocki, Director, Division Reactor Projects, Region I. 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 TS ,

definition of CFT for Susquehanna, which is typical for plants that adopted  :

the previous STS, reads as follows:

" A CHANNEL FUNCTIONAL TEST shall be

a. Analog channels - the injection of a simulated signal into the channel as close to the sensor as practicable to verify OPERABILITY including alarm and/or trip functions and channel failure trips.

b. 81 stable channels - The injection of a simulated signal into the sensor to verify 0PERABILITY including alarm and/or trip functions.

The CHANNEL FUNCTIONAL TEST may be perforined by any series of sequential, overlapping, or total channel steps such that entire channel is tested." -

The February 20, 1986 memorandum's interpretation that all relay contacts (including master and slave contacts) associated with a channel must be tested during a CFT is not correct. The CFT definition above was intended to -

t demonstrate channel operability by verifying that at least one contact has

changed state. If the design of the channel is such that additional. contacts l associated with channel relays can be verified operable, then it is desirable 4 to do so as part of the CFT. However, if the design is such that jumpering or lifting of leads is necessary for tarifying 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.

e The Peach Botton TSs and the improved STS definition of CFT states, ". . .

verify OPERABILITY including required alarm, interlock, dis >1ay, and trip functions and channel failure trips." In this definition tse "and/or" language was removed and the term " required" was added to characterize the intentof"and/or." However, that language change has caused the interpretation that all relay contacts associated with a channel are required to be verified operable during a CFT.

The purpose of CFT was not intended to test the change of state of all channel relay contacts. In the improved STS conversion, the licensee considered the definition change as administrative and the staff accepted the new definition because this change in definition was not intended to increase the scope of CFT. Testing of all contacts during CFT is considered unnecessary since change of state of one contact could infer change of state of all other contacts, associated with a relay. The operability of all contacts is assured during LSFT. The probability of failure of individual contacts based on past history is low, and therefore, the staff has not required licensees to monitor all relay contacts during the more frequent CFT. Thus, the staff concludes that PECO is satisfying the objectives of the CFT.

In order to avoid further misinterpretation of the TS requirements for CFT, the staff will work with industry representatives to develop a more clearly worded CFT definition in the improved STS. Based on the staff position above for CFT,. the staff has determined that PECO has been adequately conducting CFT at Peach Bottom. Therefore, the response to the three questions posed in the Region I TIA could be summariz'ed as follows:

1. The CFT and LSFT overlap at the relay contacts associated with the l

channel and the CFT ends 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.

l 2. . Verification of relay coil energization 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 whether particular.

contacts are included in the CFT or LSFT. Verifying contact operability for all contacts is acceptable on the LSFT frequency provided at least one contact is vertfled operable during the (more frequent) CFT.

3.0 CONCLUSION

The staff concludes that the Peach Botton CFT surveillance practices meet the staff's interpretation of the TS CFT requirements in that at least one relay

1 contact is monitored However, because the ,during staff has the CFT to confim determined channel that the relay channel operability.

functional test I

definition in the Peach Botton TS definition) contains the potential (which is consistent with for misunderstanding the the NUREG-1433 TS requirements, the staff will interact with industry representatives in order to clarify the wording in the generic definition of CFT and related I&C testing terminology in the TSs.

Date: April 9, 1997 e

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