PLA-3850, Responds to NRC 920817 Request for Addl Info on Proposed Power Uprate.Info Supplied by Ge.Geitas Is GE Proprietary Computer Program Used to Automate Drift Evaluations Described in Section 4.4 of NEDC-31336
| ML17157C000 | |
| Person / Time | |
|---|---|
| Site: | Susquehanna  |
| Issue date: | 09/17/1992 |
| From: | Keiser H PENNSYLVANIA POWER & LIGHT CO. |
| To: | Chris Miller Office of Nuclear Reactor Regulation |
| References | |
| PLA-3850, TAC-M83426, TAC-M83427, NUDOCS 9209220022 | |
| Download: ML17157C000 (9) | |
Text
ACCELERATED DISTRIBUTIONDEMONS RATION SYSTEM ii P.,'
REGULAT INFORMATION DISTRIBUTION TEM (RIDS)
ACCESSION NBR;9209220022 DOC.DATE: 92/09/17 NOTARIZED: NO DOCKET FACIL:50-387, Susquehanna Steam Electric Station, Unit 1, Pennsylva 05000387 50-388 Susquehanna Steam Electric Station, Unit 2, Pennsylva 05000388 AUTH.NAME AUTHOR AFFILIATION KEISER,H.W.
Pennsylvania Power 6 Light Co.
RECIP.NAME RECIPIENT AFFILIATION MILLER,C.L.
Project Directorate I-2
SUBJECT:
Responds to NRC 920817 request for addi
-..power:uprate.Info =supplied by GE.GEITAS computer program used to automate drift described in Section 4.4 of NEDC-31336.
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Pennsylvania Power & Light Company Two North Ninth. Street ~ Allentown, PA 18101-1179 ~ 215/774-5151 Harold W. Keiser Senior Vice President-Nuclear 215/7744194
$Ep l7 t992 Director of Nuclear Reactor Regulation Attention: Mr. C. L. Miller, Project Director Project Directorate I-2 Division of Reactor Projects U.S. Nuclear Regulatory Commission Washington, D.C.
20555 SUSQUEHANNA STEAM ELECTRIC STATION RESPONSE TO 8/17/92 RAI ON POWER UPRATE PLA-3 5 FILES A17-8/P
-11 R41-2>>
Docket Nos. 50-387 and 50-388
Reference:
Letter, J.J.
Raleigh to H.W. Keiser, "Request for Additional Information on Proposed Power Uprate, Susquehanna Steam Electric Station, Units 1 and 2 PAC Nos. M83426 and M83427), " dated August 17, 1992.
Dear Mr. Miller:
The purpose of this letter is to transmit PP&L responses to the questions posed in the referenced letter.
The following information has-been supplied to PP&L by General Electric, and PP&L has reviewed it and concurs with it.
NRC 0 es ion 1 The staff notes that different instrumentation is used for some functions than that discusse'd in NEDC-31336.
Therefore, please provide the following information:
For the Barksdale B1T-M12SS-GE and B2T-M12SS-GE instruments; describe how instrument repeatability, static pressure, overpressure, and seismic effects are accounted for (and quantify if appropriate).
b.
For the Barton 228A instrument; describe how static
- pressure, overpressure, and seismic effects are accounted for (and quantify if appropriate).
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9209220022 9209i7 PDR ADOCN 05000387 RDR.
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FILES.+17-2/P88-11/
~R41-2 Mr. C.L. Miller L,D D,'t
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Per Barksdale catalog bulletin 870420 dated
- 1987, reference accuracy (defined by Barksdale as the ability of the switch to repetitively operate at its setpoint) is given as J0.5% of adjustable range (1200 psig in this case).
In the absence of specific callouts, repeatability is included in reference accuracy per ISA-S51.1, Process Instrumentation Terminology.
Static pressure effects are applicable only to differential pressure devices per USNRC Information Notice 85-100.
Error influences due to overpressure and seismic conditions can be considered to be included in reference accuracy ifthe usage of the device is within its design capabilities, which it is. The switches used in this application are designed to a proof pressure of 1800 psig with good resistance to vibration. (Note that the setpoint calculations conservatively use an accuracy term of J1% of adjustable
- range, derived from the GE purchase part drawing for the switch).
lb.
Per Barton product bulletin 288A dated 1982, reference accuracy is given as J1.5% of full scale differential pressure (150 psid in this case).
The bulletin also states that the device has negligible static pressure shift.
In the absence of specific callouts for error influences due to overpressure and seismic conditions, reference accuracy can be considered to encompass these effects ifthe usage of the device is within its design capabilities.
The switches used in this application are designed to a working pressure of 1500 psig and vibration of 3g zero period acceleration (ZPA).
NRC Question 2 NEDC-31336, on page 4%0, states "Confirmation Ratios less than 1.0 indicate conformance."
However, page 1-7 of your setpoint submittal (PLA-3816) includes test interval data with confirmation ratios greater than 1.
Please explain:
a&
How outliers were treated in the determination of the drift rate for the Barton 228 switches.
b.
What is meant by the statement (page 1-5 of PLA-3816) "D = 8.74 psi; for conservatism and appropriate confirmation ratio, let Dl = 13.1 psi".
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II i1 fk 1I FILES A17-2/P88-11/
PLA-3850 R41-2 Mr. C.L. Miller PP&L R n
2a.
Allindividual field test data points submitted to General Electric by PP&L for the Barton 288A were entered into the GEITAS drift evaluation, regardless of whether or not any given data point appeared to be of a suspect nature.
The results of this all-inclusive evaluation show that only three of the data base cells are non-conforming (confirmation ratio greater than 1). Two of these cells have ratios near 1, and thus are borderline acceptable.
The cell with the ratio of 1.7 has only two data points, a relatively small base statistically, indicating a suspicion of spurious data (one can clearly see there is an outlier in the data).
These considerations, along with the fact that 15 out of 18 cells conform (ratio less than 1), lead to the conclusion that a trend of acceptable approach is within the guidelines of NEDC-31336,,(GE Instrument Setpoint Methodology, Section 4.4).,
2b.
The statement means that the estimate ofdriftobtained directly from
'onsideration of the OISD yalu'e (8.74 psi) has,been 'increased to a drift design'llowance of 13.1 psi in order to provide a basis for satisfactory confirmation ratios as discussed in 2a above.
Since OISD values are meant to provide assurance that devices are performing within design allowances, establishing a
design allowance above OISD values is satisfactory, provided the setpoint calculation considers the higher, design allowance value, which is the case here.
Hence, a drift value of 13.1 psi is used consistently as a basis for determination ofboth confirmation ratio and setpoint.
NRC Ques ion 3 It is our position that Topical Reports that have not been reviewed and approved by the staff may be used as the basis for a licensing action.
GEITAS (cited on pages 1-2 and 2-2 of PLA-3816) is such a document. Therefore, please, provide a copy for our review.
PP&LR n e GEITAS is a GE proprietary computer program which is used to automate the drift evaluations described in Section 4.4 of NEDC-31336.
A report which describes GEITAS is being prepared by the BWR Owners'roup and willbe submitted in the near future for NRC review.
P
'r~
C,K FILES A17-2/P88-11/
PLA-3850 R41-2 Mr. C.L. Miller Any questions on this material should be directed to Mr. R. Sgarro at (215) 774-7914.
Very truly yours, H. W. Keiser CC:
NRC33ocument Control Desk~(original)
NRC Region I Mr. G. S.
Barber, NRC Sr. Resident Inspector Mr. J.
J.
Raleigh, NRC Project Manager Mr. R. F. Scholl, NRR/ICSB, OWFN