ST-HL-AE-5304, Submits Response to NRC GL 96-01, Testing of Safety-Related Logic Circuits
| ML20107G496 | |
| Person / Time | |
|---|---|
| Site: | South Texas  |
| Issue date: | 04/17/1996 |
| From: | Cloninger T HOUSTON LIGHTING & POWER CO. |
| To: | NRC OFFICE OF INFORMATION RESOURCES MANAGEMENT (IRM) |
| References | |
| GL-96-01, GL-96-1, ST-HL-AE-5304, NUDOCS 9604230254 | |
| Download: ML20107G496 (5) | |
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flouston I.ighting & Power April 17, 1996 ST-ilL-AE-5304 File No.: G03.08 10CFR50.54(f)
U. S. Nuclear Regulatory Commission Attention: Document Control Desk Washington, D. C. 20555-0001 South Texas Project Units I and 2 Docket Nos. STN 50-498, STN 50-499 Response to NRC Generic Letter 96-01,
" Testing of Safety-Related Logic Circuits" Pursuant to 10CFR50.54(f), the South Texas Project submits this response to NRC Generic Letter 96-01," Testing of Safety-Related Logic Circuits."
The Nuclear Regulatory Commission staff has requested that licensees take the following actions:
- 1. Compare electrical schematic drawings and logic diagrams for the reactor protection system, emergency diesel generator load shedding and sequencing, and actuation logic for the engineered safety features systems against plant surveillance test procedures to ensure that all portions of the logic circuitry, including the parallel logic, interlocks, bypasses and inhibit circuits, are adequately covered in the surveillance procedures to fulfill the Technical Specification requirements, This review should also include relay contacts, control switches, and other relevant electrical components within these systems, utilized in the logic circuits performing a safety function.
- 2. Modify the surveillance procedures as necessary for complete testing to comply with the technical specifications. Additionally, the licensee may request an amendment to the technical specifications if relief from certain testing requirements can be justified.
Generic Letter 96-01 requests that completion of these actions be accomplished prior to startup from the firsj rpfueling outage commencing one year after issuance of this generic letter.
9604230254 960417 PDR ADOCK 05000498 P
PDR A program for review and enhancement of surveillance procedures was performed l
at the South Texas Project which substantially addressed the scope of review identified in Il Project Manager on Behalf of the Participants in the South Texas Project
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a ST-HL-AE-5304 File No.: G03.08 Page 2 Generic Letter 96-01. The Surveillance Procedure Enhancement Program was developed by the South Texas Project to incorporate good human factor principles as well as to ensure that the surveillance procedures accurately reflect the design basis and adequately perform their intended function. The objectives of the enhancement program were:
To ensure surveillances are technically adequate to ensure equipment will perform the intended safety function; To comply with Technical Specifications; To establish a documented technical basis for future reference; and To minimize the risk of reactor trips or actuation of Engineered Safety Features.
Future procedure enhancements will follow the Improved Technical Specifications implementation schedule using similar procedure development techniques that were used in the surveillance procedure enhancement program.
Existing South Texas Project procedures require that surveillance procedures be reviewed for technical accuracy. In addition to ensuring proper tracking of Technical Specification n:quirements in the surveillance program database and implementation of acceptance criteria and testing methodology, factors essential to appropriate revision and review of surveillance procedures are included in a checklist. Implementation of this checklist is expected to result in surveillance procedures that are complete and technically accurate as they are reviewed and revised Generic Letter 96-01 also states that:
Some licensees may have already performed the requested reviews and taken appropriate corrective actions. These licensees do not need to perform any additional reviews unless modifications have been made to the logic circuits for the identified systems. In these cases, modifications should be reviewed, and full functional testing of the modification conducted following modifications to safety-related logic circuits. Furthermore, routine surveillance testing should not be relied upon for confirming proper performance of logic circuits following modifications.
The South Texas Project reactor protection system, standby diesel generator load shedding and sequencing, and actuation logic for the engineered safety features systems have been reviewed for actuation logic modifications made since implementation of the surveillance procedure enhancement program. The South Texas Project will verify that
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ST-HL-AE-5304 File No.: G03.08 Page 3 4
where modifications were made, full functional testing was completed at the time of modification completion and procedures were changed as needed, i
Procedural requirements are in place to ensure that plant modifications are reviewed for impact on surveillance procedures. Plant procedures require that testing to verify full functionality be performed after installation of a modification. Procedures require that functional testing ensure the design basis function (s) of the component or integrated system is accomplished in all required modes and conditions.
The Nuclear Regulatory Commission provided clarification of a number of issues related to Generic Letter 96-01 at the Atlanta workshop on March 19, 1996.
Consequently, the South Texas Project will perform an additional review of the surveillance procedures for the reactor protection system, standby diesel generator load shedding and sequencing, and actuation logic for the engineered safety features systents ensuring that the issues identified in the Generic Letter have been addressed consistent with the clarification provided at the workshop.
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Rather than establishing a completion schedule based upon startup from a refueling outage, required modifications to procedures will be completed concurrent with the implementation of the Improved Technical Specifications, currently scheduled for completion by December 31,1997. Operability concerns will be addressed and resolved as they are identified.
If there are any questions, please contact either Mr. P. L.
er at (512) 972-8392, or me at (512) 972-8787.
. H.
nin Vice re ' ent, N
c Engineer ng PLW/bc l
y Houston Lighting & Power Company.
ST-HL-AE-5304 South Thzag Project Electric Generating Station File No.: G03.08 Page 4 c:
Leonard J. Callan Rufus S. Scott Regional Administrator, Region IV Associate General Counsel U. S. Nuclear Regulatory Commission Houston Lighting & Power Company 611 Ryan Plaza Drive, Suite 400 P. O. Box 61067 Arlington, TX 76011-8064 Houston, TX 77208 Thomas W. Alexion Institute of Nuclear Power Project Manager, Mail Code 13H15 Operations - Records Center U. S. Nuclear Regulatory Commission 700 Galleria Parkway Washington, DC 20555-0001 Atlanta, GA 30339-5957 David P. Loveless Dr. Joseph M. Hendrie Sr. Resident Inspector 50 Bellport Lane c/o U. S. Nuclear Regulatory Comm.
Bellport, NY l1713 P. O. Box 910 Bay City, TX 77404-0910 Richard A. Ratliff Bureau of Radiation Control J. R. Newman, Esquire Texas Department of Health Morgan, Lewis & Bockius 1100 West 49th Street 1800 M Street, N.W.
Austin, TX 78756-3189 Washington, DC 20036-5869 U. S. Nuclear Regulatory Comm.
M. T. Hardt/W. C. Gunst Attn: Document Control Desk City Public Service Washington, D. C. 20555-0001 P. O. Box 1771 San Antonio, TX 78296 J. C. Lanicr/M. B. Lee J. R. Egan, Esquire City of Austin Egan & Associates, P.C.
Electric Utility Department 2300 N Street, N.W.
721 Barton Springs Road Washington, D.C. 20037 Austin, TX 78704 Central Power and Light Company J. W. Beck ATTN: G. E. Vaughn/C. A. Johnson Little Harbor Consultants, Inc.
P. O. Box 289, Mail Code: N5012 44 Nichols Road Wadsworth, TX 77483 Cohassett, MA 02025-1166
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UNITED STATES OF AMERICA NUCLEAR REGULATORY COMMISSION l
In the Matter of
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Ilouston Lighting & Power
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Docket Nos. 50-498
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Compar./. et al.,
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50-499 l
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South Texas Project
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Units 1 and 2
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AFFIDAVIT I, T 11. Cloninger, being duly sworn, hereby depose and say that I am Vice President, Nuclear Engineering, of Ilouston Lighting & Power Company; that I am duly authorized to sign and file with the Nuclear Regulatory Commission the attached response to NRC Generic Letter 96-01," Testing of Safety - Related Circuits" that I am familiar with the content thereof; and that the matters set forth therein -
tr e and correct to the best of my knowledge and belief.
- f. I. Clo ng' Vice P sic t,
Nucl ar ineering i
STATE OF TEXAS
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l COUNTY OF M ATAGORDA )
Texas, this / 9 ged and sworn jo before me, a Notary Public in and for the State Subscr day of /pr./
,1996.
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