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| number = ML20204B576
| number = ML20204B576
| issue date = 03/20/1987
| issue date = 03/20/1987
| title = Forwards Info Re ATWS Mitigating Sys Actuation Circuitry (Amsac),Per P O'Connor 860922 Request.Approval of Submittal Requested Before 870701 to Support AMSAC Installation Prior to Startup Following Third Refueling Outage in Fall 1988
| title = Forwards Info Re ATWS Mitigating Sys Actuation Circuitry (Amsac),Per P Oconnor 860922 Request.Approval of Submittal Requested Before 870701 to Support AMSAC Installation Prior to Startup Following Third Refueling Outage in Fall 1988
| author name = Withers B
| author name = Withers B
| author affiliation = WOLF CREEK NUCLEAR OPERATING CORP.
| author affiliation = WOLF CREEK NUCLEAR OPERATING CORP.
Line 16: Line 16:


=Text=
=Text=
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NUCLEAR OPERATING CORPORATION March 20, 1E37 U.S. Nuclear Regulatory Comnission ATTN: Document C::ntrol Desk Washington, D.C.
NUCLEAR OPERATING CORPORATION March 20, 1E37 U.S. Nuclear Regulatory Comnission ATTN: Document C::ntrol Desk Washington, D.C. 20555 Letter: WM 87-0100 Re:       Docket No. 50-482 Ref:       1. Letter dated 09/22/86 from PO'Connor, NRC, to GLKoester, KG&E
20555 Letter: WM 87-0100 Re:
: 2. Letter KMLNRC 86-195 dated 10/31/86 from GLKoester, KG&E, to HRDenton, NRC Subj-     ATWS Mitigating System Actuation Circuitry -
Docket No. 50-482 Ref:
1.
Letter dated 09/22/86 from PO'Connor, NRC, to GLKoester, KG&E 2.
Letter KMLNRC 86-195 dated 10/31/86 from GLKoester, KG&E, to HRDenton, NRC Subj-ATWS Mitigating System Actuation Circuitry -
10 CFR 50.62 Gentlemen:
10 CFR 50.62 Gentlemen:
Attachinents 1 and 2 provide the Wolf Creek Generating Station ' Anticipated Transients Without Scram (ATWS) Mitigating Sp lem Actuation Circuitry (AMSAC)   information requested in Reference 1.                           Attachment 1, which is identical for both Wolf Creek Generating Station and the Callaway Plant, provides the plant-specific design details and attachment 2 provides a description of the Wolf Creek quality assurance program to be applied to the non-safety related AMSAC equipment.
Attachinents 1 and 2 provide the Wolf Creek Generating Station ' Anticipated Transients Without Scram (ATWS) Mitigating Sp lem Actuation Circuitry (AMSAC) information requested in Reference
The information contained in the attachments is sufficient to demonstrate the adequacy of the AMSAC                   design         to     meet     the requirenents of
: 1.,
which is identical for both Wolf Creek Generating Station and the Callaway Plant, provides the plant-specific design details and attachment 2 provides a description of the Wolf Creek quality assurance program to be applied to the non-safety related AMSAC equipment.
The information contained in the attachments is sufficient to demonstrate the adequacy of the AMSAC design to meet the requirenents of
~
~
10CFR50.62(c) (1) at Wolf Creek Generating Station.                           AMSAC will provide an l-         alternate means of tripping the turbine and actuating auxiliary feedwater l         flow in a manner diverse from the reactor trip system.                           Actuation of AMSAC will occur as a result of low water 1cral in the steam generators utilizing l
10CFR50.62(c) (1) at Wolf Creek Generating Station.
existing sensors and circuitry. After the specific AMSAC design details are finalized,   they will be integrated into plant operating procedures and training, as appropriate.
AMSAC will provide an l-alternate means of tripping the turbine and actuating auxiliary feedwater l
8703250099 870320 2 PDR   ADOCK 0500 M
flow in a manner diverse from the reactor trip system.
PO. Box 411 I Burlington, KS 66839 Phone: (316) 364-8831 An Equal Oppertunity Employer M F }CVET ON
Actuation of AMSAC will occur as a result of low water 1cral in the steam generators utilizing l
existing sensors and circuitry. After the specific AMSAC design details are finalized, they will be integrated into plant operating procedures and training, as appropriate.
8703250099 870320 PDR ADOCK 0500 2
M N
PO. Box 411 I Burlington, KS 66839 Phone: (316) 364-8831 O
An Equal Oppertunity Employer M F }CVET


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1 wt 87-9199 f'
1 wt 87-9199 Page 2 f'
Page 2 Although this information was originally scheduled in Reference 2 to be submitted by March 1,.1987, the Staff verbally granted an extension to March 29,   1987 to allow time for Wolf Creek and Callaway to coordinate a cannon submittal on the design information. However, Staff approval of this plant-specific submittal is still requested prior to July 1,                         1987 in order to support AMSAC installation prior to start-up following the third refueling outage currently scheduled for Fall 1988.                 'Ihis allows sufficient time for proper scheduling and procurenent activities and implementation of any changes which may result from the staff review.
Although this information was originally scheduled in Reference 2 to be submitted by March 1,.1987, the Staff verbally granted an extension to March 29, 1987 to allow time for Wolf Creek and Callaway to coordinate a cannon submittal on the design information. However, Staff approval of this plant-specific submittal is still requested prior to July 1, 1987 in order to support AMSAC installation prior to start-up following the third refueling outage currently scheduled for Fall 1988.
'Ihis allows sufficient time for proper scheduling and procurenent activities and implementation of any changes which may result from the staff review.
If you have any questions concerning this submittal, please contact 'me or Mr. O. L. Maynard of my staff.
If you have any questions concerning this submittal, please contact 'me or Mr. O. L. Maynard of my staff.
Very truly yours,
Very truly yours,
Line 38: Line 49:
BEM:wbb Attachments cc: ' P0'Connor (2)
BEM:wbb Attachments cc: ' P0'Connor (2)
JCummins RMartin.
JCummins RMartin.
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  .                                                                                                               l Attachment 1~
l
PIANT-SPECIFIC ~ DESIGN DETAILS REGARDING ATWS MITIGATING SYSTEM ACTUATION CIRCUITRY CALIAWAY PIANT AND WOLF CREEK GENERATING STATION IhIRODUCTION Reference 1 provided generic design options for use by                               ;
. ~
Westinghouse plants in addressing the requirements af 10 CFR 50.62, " Requirements for Reduction of Risk from Anticipated Transients Without Scram (ATWS) Events for Light-Water-Cooled Nuclear Power Plants."                           Reference 2 reported the completion of an NRC staff review of the generic design information in Reference 1 and identified plant-specific design information 4
PIANT-SPECIFIC ~ DESIGN DETAILS REGARDING ATWS MITIGATING SYSTEM ACTUATION CIRCUITRY CALIAWAY PIANT AND WOLF CREEK GENERATING STATION IhIRODUCTION Reference 1 provided generic design options for use by Westinghouse plants in addressing the requirements af 10 CFR 50.62,
required by the NRC staff to verify compliance with 10 CFR 50.62. The plant-specific information applicable to Callaway l                   Plant and Wolf Creek Generating Station is provided in the i                     following paragraphs.
" Requirements for Reduction of Risk from Anticipated Transients Without Scram (ATWS) Events for Light-Water-Cooled Nuclear Power Plants."
DESIGN CONCEPT AMSAC Desian ODtion The AMSAC design employs Option 1 r* Reference 1.                           The design will use existing steam generat.+ level transmitters to actuate a turbine trip and initiate auxiliary feedwater flow.         The AMSAC will also initiate closure of steam genera-
Reference 2 reported the completion of an NRC staff review of the generic design information in Reference 1 and identified plant-specific design information required by the NRC staff to verify compliance with 10 CFR 4
                    - tor blowdown isolation and sample isolation valves.
50.62.
ATWS is defined in 10 CFR 50.62 as "an anticipated operational occurrence as defined in Appandix A of this part followed by the failure of the reactor trip portion of the protection system specified in General Design Criterion 20 of Appendix A of this part."                               In the Callaway and Wolf Creek designs, the reactor trip portion of the protection system and the Balance of Plant (BOP) Engineered Safety Features Actuation System (ESFAS) are separate systems.                               The Reactor Trip System (RTS) employs the output of the Westinghouse Solid State Protection System (SSPS) to trip the reactor trip breakers resulting in a reactor scram.                                   The BOP ESFAS manufactured by Consolidated controls Corporation, receives an input signal from the SSPS to actuate various safeguards
The plant-specific information applicable to Callaway l
    ,_,--,,-,.,e,.,       . , . - -  ,.-__.,_..._,_,---x-
Plant and Wolf Creek Generating Station is provided in the i
following paragraphs.
DESIGN CONCEPT AMSAC Desian ODtion The AMSAC design employs Option 1 r*
Reference 1.
The design will use existing steam generat.+ level transmitters to actuate a turbine trip and initiate auxiliary feedwater flow.
The AMSAC will also initiate closure of steam genera-
- tor blowdown isolation and sample isolation valves.
ATWS is defined in 10 CFR 50.62 as "an anticipated operational occurrence as defined in Appandix A of this part followed by the failure of the reactor trip portion of the protection system specified in General Design Criterion 20 of Appendix A of this part."
In the Callaway and Wolf Creek designs, the reactor trip portion of the protection system and the Balance of Plant (BOP) Engineered Safety Features Actuation System (ESFAS) are separate systems.
The Reactor Trip System (RTS) employs the output of the Westinghouse Solid State Protection System (SSPS) to trip the reactor trip breakers resulting in a reactor scram.
The BOP ESFAS manufactured by Consolidated controls Corporation, receives an input signal from the SSPS to actuate various safeguards
,_,--,,-,.,e,.,
,.-__.,_..._,_,---x-
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equipment including the auxiliary fes.dwater (AFW) pumps and the steam generator blowdown isolation and sample isolation valves. The existing turbine trip on reactor trip signal is the P-4 permissive generated by opening the reactor trip breakers.
equipment including the auxiliary fes.dwater (AFW) pumps and the steam generator blowdown isolation and sample isolation valves.
For the Callaway and Wolf Creek AMSAC design, an AMSAC logic cabinet will be installed in the Control Room.         The space allotted for the cabinet was incorporated into the original design of the plants.     Existing narrow range steam generator level transmitters ,        not used in the steam generator level control system, will provide signals to the non-Class lE AMSAC Oircuits via qualified isolation devices.
The existing turbine trip on reactor trip signal is the P-4 permissive generated by opening the reactor trip breakers.
The coincidence logic for AMSAC initiation is 3/4 low steam generator level signals with one channel provided for each of the four steam generators.* Outputs from AMSAC will provide a signal to the     BOP ESFAS through qualified, Class 1E isolation relays to start the AFW pumps.       The AFW pump start signal will also close steam generator blowdown and sample isolation valves   This use of the existing BOP ESFAS system will provide for the required diversity from the RTS without further complicating the plant safety systems.         AMSAC will also provide a signal to the main turbine electrohydraulic control (EHC) system for turbine trip.             The auxiliary feedwater flow response time and turbine trip response time are consistent with Reference 1 requirements.           Figure 1 provides the conceptual design and layout of the AMSAC.
For the Callaway and Wolf Creek AMSAC design, an AMSAC logic cabinet will be installed in the Control Room.
The space allotted for the cabinet was incorporated into the original design of the plants.
Existing narrow range steam generator level transmitters not used in the steam generator level control system, will provide signals to the non-Class lE AMSAC Oircuits via qualified isolation devices.
The coincidence logic for AMSAC initiation is 3/4 low steam generator level signals with one channel provided for each of the four steam generators.*
Outputs from AMSAC will provide a
signal to the BOP ESFAS through qualified, Class 1E isolation relays to start the AFW pumps.
The AFW pump start signal will also close steam generator blowdown and sample isolation valves This use of the existing BOP ESFAS system will provide for the required diversity from the RTS without further complicating the plant safety systems.
AMSAC will also provide a signal to the main turbine electrohydraulic control (EHC) system for turbine trip.
The auxiliary feedwater flow response time and turbine trip response time are consistent with Reference 1 requirements.
Figure 1 provides the conceptual design and layout of the AMSAC.
The Callaway and Wolf Creek main control board alarms have been designed to employ the " dark board" concept to improve human factors performarce of the plant operators.
The Callaway and Wolf Creek main control board alarms have been designed to employ the " dark board" concept to improve human factors performarce of the plant operators.
This principle requires, to the extent possible, that alarms illuminate to show an abnormal condition.       If conditions are normal, the panel alarms remain darkened.         Also, to avoid confusion from excessive alarms in the control room, the number of alarms has been kept as low as possible. Only two AMSAC-related alarm windows will be placed on the main control board:     an AMSAC Urgent alarm, and an AMSAC Bypass /Offnormal alarm. The AMSAC Urgent alarm indicates that the AMSAC initiation sequence has started and that, after an appropriate time delay, AMSAC will trip the main turbine and start the AFW pumps. The AMSAC Bypass /Offnormal alarm is used to provide the control room operators indication of abnormal or unusual situations affecting AMSM
This principle requires, to the extent possible, that alarms illuminate to show an abnormal condition.
* Consideration is being given to the use of programmable logic control (PLC) in the AMSAC logic.     The AMSAC low level setpoint is below the RPS low-low level setpoint consistent with Reference 1.
If conditions are normal, the panel alarms remain darkened.
Also, to avoid confusion from excessive alarms in the control room, the number of alarms has been kept as low as possible.
Only two AMSAC-related alarm windows will be placed on the main control board:
an AMSAC Urgent
: alarm, and an AMSAC Bypass /Offnormal alarm.
The AMSAC Urgent alarm indicates that the AMSAC initiation sequence has started and that, after an appropriate time delay, AMSAC will trip the main turbine and start the AFW pumps.
The AMSAC Bypass /Offnormal alarm is used to provide the control room operators indication of abnormal or unusual situations affecting AMSM Consideration is being given to the use of programmable logic control (PLC) in the AMSAC logic.
The AMSAC low level setpoint is below the RPS low-low level setpoint consistent with Reference 1.
2
2


such as a failure of the C-20 permissive circuitry, a maintenance bypass condition, loss of power supply, and self diagnostics trouble.                                                                         (The full range of AMSAC offnormal conditions is dependent on supplier options.)
such as a
Reference 2 identified 14 plant-specific items to be addressed by utilities.                                                                                     Responses   to these items are provided below.
failure of the C-20 permissive circuitry, a
ITEM 1:                           DIVERSITY The plant-specific submittal should indicate the degree of diversity that exists between the AMSAC equipment and the.
maintenance bypass condition, loss of power supply, and self diagnostics trouble.
existing Reactor Protection System.                                                                                   Equipment diversity to the extent reasonable and practicable to minimize the potential for common cause failures is required from the sensors output to, but not including, the final actuation device, e.g., existing circuit breakers may be used for the auxiliary feedwater initiation. The sensors need not be of a diverse design or manufacture.                                                                                     Existing protection system instrument-sensing lines, sensors, and sensor power supplies may be used.                                             Sensor and instrument sensing lines should be selected such that adverse interactions with existing control systems are avoided.
(The full range of AMSAC offnormal conditions is dependent on supplier options.)
Reference 2 identified 14 plant-specific items to be addressed by utilities.
Responses to these items are provided below.
ITEM 1:
DIVERSITY The plant-specific submittal should indicate the degree of diversity that exists between the AMSAC equipment and the.
existing Reactor Protection System.
Equipment diversity to the extent reasonable and practicable to minimize the potential for common cause failures is required from the sensors output to, but not including, the final actuation
: device, e.g.,
existing circuit breakers may be used for the auxiliary feedwater initiation.
The sensors need not be of a diverse design or manufacture.
Existing protection system instrument-sensing lines, sensors, and sensor power supplies may be used.
Sensor and instrument sensing lines should be selected such that adverse interactions with existing control systems are avoided.


===Response===
===Response===
Existing                               steam                       generator                 water   level transmitters, sensing lines and sensor power supplies will be used for input to AMSAC.                                                     The AMSAC equipment will be of a different design and diverse from the Westinghouse Reactor Protection System (RPS).                                                       This diversity will exist from the RPS isolators (7300 loop power supply cards) to the AMSAC output relays.                                 Existing RPS sensor power supplies will provide power to the level transmitters and perform an isolation function.                                     Power supplies for the non-safety-related AMSAC equipment are diverse in that they will be powered from 125VDC non-1E instrument power from the plant-designated PK system.                             AMSAC will initiate AEW flow via the Consolidated Controls Corporation (CCC) ESFAS system that starts the motor- and turbine-driven AFW pu.11ps (by opening the latter's steam supply valves) and isolates steam generator blowdown and sampling by means of the ArW Actuation Signal (AFAS).
Existing steam generator water level transmitters, sensing lines and sensor power supplies will be used for input to AMSAC.
The AMSAC equipment will be of a different design and diverse from the Westinghouse Reactor Protection System (RPS).
This diversity will exist from the RPS isolators (7300 loop power supply cards) to the AMSAC output relays.
Existing RPS sensor power supplies will provide power to the level transmitters and perform an isolation function.
Power supplies for the non-safety-related AMSAC equipment are diverse in that they will be powered from 125VDC non-1E instrument power from the plant-designated PK system.
AMSAC will initiate AEW flow via the Consolidated Controls Corporation (CCC)
ESFAS system that starts the motor-and turbine-driven AFW pu.11ps (by opening the latter's steam supply valves) and isolates steam generator blowdown and sampling by means of the ArW Actuation Signal (AFAS).
AMSAC initiates turbine trip by means of a separate signal to the existing General Electric turbine control circuitry.
AMSAC initiates turbine trip by means of a separate signal to the existing General Electric turbine control circuitry.
Thus, the circuitry for AFW initiation and turbine trip is diverse from the RPS, which consists of the 7300 Process Protection System (PPS) and SSPS cabinets, from the steam 3
Thus, the circuitry for AFW initiation and turbine trip is diverse from the RPS, which consists of the 7300 Process Protection System (PPS) and SSPS cabinets, from the steam 3
l l
l l


generator level transmitter power supplies, including the required isolation devices, to the AFW pumps and to the EHC system for turbine trip.         This is based on the existing diversity and independence between the BOF ESFAS and the RTS.
generator level transmitter power supplies, including the required isolation devices, to the AFW pumps and to the EHC system for turbine trip.
The steam generator level sensors used as input to AMSAC are different than those used to drive the steam generator level control system.       This will alleviate any concern that an adverse interaction will exist between AMSAC and existing control systems.
This is based on the existing diversity and independence between the BOF ESFAS and the RTS.
ITEM 2:   IDGIC POWER SUPPLIES The plant-specific submittal should discuss the logic power supply design. According to the rule, the AMSAC logic power supply is not required to be safety-related (Class lE).
The steam generator level sensors used as input to AMSAC are different than those used to drive the steam generator level control system.
However, logic power should be from an instrument power supply that is independent from the reactor protection system (RPS) power supplies.       Our review of additional information submitted by WOG indicated that power to the logic circuits will utilize RPS batteries and inverters.                   The staff finds this     portion   of   the   design             unacceptable;               therefore, independent power supplies should be provided.
This will alleviate any concern that an adverse interaction will exist between AMSAC and existing control systems.
ITEM 2:
IDGIC POWER SUPPLIES The plant-specific submittal should discuss the logic power supply design.
According to the rule, the AMSAC logic power supply is not required to be safety-related (Class lE).
: However, logic power should be from an instrument power supply that is independent from the reactor protection system (RPS) power supplies.
Our review of additional information submitted by WOG indicated that power to the logic circuits will utilize RPS batteries and inverters.
The staff finds this portion of the design unacceptable; therefore, independent power supplies should be provided.


===Response===
===Response===
The power input to the AMSAC equipment, with the exception of the Class lE level transmitters and isolation
The power input to the AMSAC equipment, with the exception of the Class lE level transmitters and isolation devices, will be from non-Class lE buses with battery backup.
        .                              devices, will be from non-Class lE buses with battery backup.
This supply will be independent from the RPS power input.
This supply will be independent from the RPS power input.
The RPS power supply is from Class lE dc buses NK01, NK02, NK03, and NK04 via Class lE inverters (FSAR Fig. 8.3-6). The AMSAC power supply will be from non-Class lE dc buses PK01, PK02, PK03, or PK04 (FSAR Figs. 8.3-6 and 8.3-7) and will allow AMSAC to function during a loss of offsite power.                                 The I                                       use   of this independent power source will substantially l                                       decrease the probability of a common mode failure on demand.
The RPS power supply is from Class lE dc buses NK01, NK02, NK03, and NK04 via Class lE inverters (FSAR Fig. 8.3-6).
l                                       (Failure occurring or detected only during an actual need or test.)
The AMSAC power supply will be from non-Class lE dc buses PK01, PK02, PK03, or PK04 (FSAR Figs.
8.3-6 and 8.3-7) and will allow AMSAC to function during a loss of offsite power.
The I
use of this independent power source will substantially l
decrease the probability of a common mode failure on demand.
l (Failure occurring or detected only during an actual need or test.)
Direct current power for the BOP ESFAS is supplied from three independent Class lE buses (NK01, NK02, and NK04.)
Direct current power for the BOP ESFAS is supplied from three independent Class lE buses (NK01, NK02, and NK04.)
These buses have separate chargers with battery backup as shown in Callaway FSAR (Wolf Creek USAR) Figure 0.3-6.                                 Loss of power to any of these buses is annunciated in the control room. Although these buses also supply power to 4
These buses have separate chargers with battery backup as shown in Callaway FSAR (Wolf Creek USAR) Figure 0.3-6.
Loss of power to any of these buses is annunciated in the control room.
Although these buses also supply power to 4


e l
e the RPS, as indicated above, their use is justified owing to the low probability of common mode failure on demand occurring simultaneously with an ATWS event.
the RPS, as indicated above, their use is justified owing to                                                                                                                                           l the low probability of common mode failure on demand occurring simultaneously with an ATWS event.
The PK 125 volt dc system includes four batteries, four battery
The PK 125 volt dc system includes four batteries, four battery                             chargers,                       four                     main switchboards,                                     and     eight distribution switchboards.
: chargers, four main switchboards, and eight distribution switchboards.
On loss of ac power, or the failure of a charger, the batteries supply power to their respective 125 volt dc buses (PK01, PK02, PK03, or PK04) .                                                                 Buses PK01 and PK02 primarily serve the non-safety-related control and instrumentation loads through 125 volt dc distribution panels.                                                                                                       Buses PK03 and PK04 primarily serve the non-safety-related inverter loads.
On loss of ac power, or the failure of a charger, the batteries supply power to their respective 125 volt dc buses (PK01, PK02, PK03, or PK04).
ITEM 3:                           SAFETY-RELATED INTERFACE The plant-specific submittal should show that the implementation is such that the existing protection system continues to meet all applicable safety criteria.
Buses PK01 and PK02 primarily serve the non-safety-related control and instrumentation loads through 125 volt dc distribution panels.
Buses PK03 and PK04 primarily serve the non-safety-related inverter loads.
ITEM 3:
SAFETY-RELATED INTERFACE The plant-specific submittal should show that the implementation is such that the existing protection system continues to meet all applicable safety criteria.


===Response===
===Response===
The existing protection system will continue to meet all applicable safety criteria because                                                                                                   qualified         isolation devices will separate the non-safety-related AMSAC equipment from the existing safety-related Westinghouse 7300 process cabinets, solid state protection system (SSPS), and BOP engineered safety feature actuation system (ESFAS) equipment.
The existing protection system will continue to meet all applicable safety criteria because qualified isolation devices will separate the non-safety-related AMSAC equipment from the existing safety-related Westinghouse 7300 process
.                  Existing separation criteria will continue to be met between safety-related and non-safety-related equipment as described in the Callaway Plant and Wolf Creek Generating Station FSARs (Section 8.3) which use Regulatory Guide 1.75 and IEEE 279-j                   1971 as design bases.
: cabinets, solid state protection system (SSPS),
ITEM 4:                         QUALITY ASSURANCE The plant-specific submittal should provide information regarding compliance with Generic Letter 85-06, " Quality Assurance Guidance for ATWS Equipment that is not Safety-Related."
and BOP engineered safety feature actuation system (ESFAS) equipment.
ResDonse Quality Assurance requirements for non-safety-related AMSAC equipment are provided per                                                                                     the                   Quality     Assurance provisions defined in Attachment 2.
Existing separation criteria will continue to be met between safety-related and non-safety-related equipment as described in the Callaway Plant and Wolf Creek Generating Station FSARs (Section 8.3) which use Regulatory Guide 1.75 and IEEE 279-j 1971 as design bases.
t 5                                                                                                       s
ITEM 4:
  -r-,     -  -n., .y   , , , - - _ . - - - - - - - - . - - . . - . . , . , , - . . - -    ----....-----,..m-.ww       ._,..------.----.-.,--.-,-------,._,w-      -
QUALITY ASSURANCE The plant-specific submittal should provide information regarding compliance with Generic Letter 85-06,
                                                                                                                                                                                  .,w-----,- -
" Quality Assurance Guidance for ATWS Equipment that is not Safety-Related."
                                                                                                                                                                                                  ,. - n -,.-< - - - - - -
ResDonse Quality Assurance requirements for non-safety-related AMSAC equipment are provided per the Quality Assurance provisions defined in Attachment 2.
t 5
s
-r-,
-n.,
.y
----....-----,..m-.ww
._,..------.----.-.,--.-,-------,._,w-
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n -,.-< - - - - - -


ITEM 5:         MAINTENANCE BYPASSES The   plant-specific     submittal         should discuss   how maintenance at power is accomplished and how good human factors         engineering practice is incorporated into the continuous indication of bypass status in the control room.
ITEM 5:
MAINTENANCE BYPASSES The plant-specific submittal should discuss how maintenance at power is accomplished and how good human factors engineering practice is incorporated into the continuous indication of bypass status in the control room.


===Response===
===Response===
                                                ' Surveillance and maintenance of AMSAC and AMSAC sensor inputs will be performed using approved procedures.                   To avoid AMSAC actuation during maintenance or surveillance of the AMSAC system or sensor inputs, the AMSAC output signals will be bypassed via a permanently installed bypass switch at the AMSAC panel.             Normal maintenance at power will not involve lifting of leads, pulling               fuses,       tripping breakers, or physically blocking relays.
' Surveillance and maintenance of AMSAC and AMSAC sensor inputs will be performed using approved procedures.
Indication of AMSAC maintenance bypasses will be continuously indicated via the AMSAC Bypass /Offnormal alarm window on the main control board.                   The normally dark window will be illuminated whenever the bypass switch is in the
To avoid AMSAC actuation during maintenance or surveillance of the AMSAC system or sensor inputs, the AMSAC output signals will be bypassed via a permanently installed bypass switch at the AMSAC panel.
                                    " bypass" position.             This alarm window, as well as the AMSAC urgent alarm window, will be designed consistent with the original Detailed Control Room Design Review (DCRDR) approved by the NRC.
Normal maintenance at power will not involve lifting of
ITEM 6:         OPERATING BYPASSES The plant-specific submittal should state that operating 4
: leads, pulling
bypasses are . continuously indicated in the control room,
: fuses, tripping
                                - provide the basis for the 70 percent or plant-specific operating bypass level, discuss the human factors design aspects of the continuous                   indication,     and discuss the diversity and independence of the C-20 permissive signal (defeats the block of AMSAC).
: breakers, or physically blocking relays.
Indication of AMSAC maintenance bypasses will be continuously indicated via the AMSAC Bypass /Offnormal alarm window on the main control board.
The normally dark window will be illuminated whenever the bypass switch is in the
" bypass" position.
This alarm window, as well as the AMSAC urgent alarm window, will be designed consistent with the original Detailed Control Room Design Review (DCRDR) approved by the NRC.
ITEM 6:
OPERATING BYPASSES The plant-specific submittal should state that operating bypasses are. continuously indicated in the control room, 4
- provide the basis for the 70 percent or plant-specific operating bypass level, discuss the human factors design aspects of the continuous indication, and discuss the diversity and independence of the C-20 permissive signal (defeats the block of AMSAC).


===Response===
===Response===
The plant-specific C-20 permissive setpoint for Callaway and Wolf Creek is 40 percent power. The basis for 40 percent power was prwided in Reference 3.                       The input signals for deriving C-20 will be provided by the two main turbine first stage impulse pressure transmitters.                       The turbine impulse pressure signals are derived from existing protection system sensing lines, sensors, and power supplies.                         The logic portion of the C-20 signal is processed in the AMSAC cir-cuitry and is diverse from the SSPS.                       In the event of a
The plant-specific C-20 permissive setpoint for Callaway and Wolf Creek is 40 percent power.
,                                  turbine trip, removal of the C-20 permissive signal is delayed for a period of time consistent with reference 1 to avoid blocking AMSAC before it can perform its function.
The basis for 40 percent power was prwided in Reference 3.
The input signals for deriving C-20 will be provided by the two main turbine first stage impulse pressure transmitters.
The turbine impulse pressure signals are derived from existing protection system sensing lines,
: sensors, and power supplies.
The logic portion of the C-20 signal is processed in the AMSAC cir-cuitry and is diverse from the SSPS.
In the event of a turbine
: trip, removal of the C-20 permissive signal is delayed for a period of time consistent with reference 1 to avoid blocking AMSAC before it can perform its function.
6
6


AMSAC will be enabled by 2/2 turbine impulse pressure transmitters above 40 percent power.         Also, AMSAC will be automatically blocked if one of these transmitters indicates power below 40 percent.         These are normal conditions. In keeping with the " dark board" human factors concept for the main control boards, the above normal conditions will not result in alarm indications on the main control board.         If the AMSAC is not enabled above 40 percent power, the AMSAC Bypass / Offnormal alarm will sound and illuminate on the main control board.
AMSAC will be enabled by 2/2 turbine impulse pressure transmitters above 40 percent power.
ITEM 7:   MEANS FOR BYPASSING The plant-specific submittal should state that the means for bypassing is accomplished with a permanently installed, human factored, bypass switch or similar device, and verify that disallowed methods mentioned in the guidance are not utilized.
Also, AMSAC will be automatically blocked if one of these transmitters indicates power below 40 percent.
These are normal conditions.
In keeping with the " dark board" human factors concept for the main control boards, the above normal conditions will not result in alarm indications on the main control board.
If the AMSAC is not enabled above 40 percent power, the AMSAC Bypass / Offnormal alarm will sound and illuminate on the main control board.
ITEM 7:
MEANS FOR BYPASSING The plant-specific submittal should state that the means for bypassing is accomplished with a permanently installed, human factored, bypass switch or similar device, and verify that disallowed methods mentioned in the guidance are not utilized.


===Response===
===Response===
The means for bypassing AMSAC during testing and maintenance will be accomplished with a permanently installed bypass switch and will not use any of the disallowed methods mentioned in Reference 2.
The means for bypassing AMSAC during testing and maintenance will be accomplished with a permanently installed bypass switch and will not use any of the disallowed methods mentioned in Reference 2.
ITEM 8:   MANUAL INITIATION The plant-specific submittal should discuss how a manual turbine     trip     and   auxiliary   feedwater   actuation   are accomplished by the operator.
ITEM 8:
MANUAL INITIATION The plant-specific submittal should discuss how a manual turbine trip and auxiliary feedwater actuation are accomplished by the operator.
Resoonse The main turbine is tripped by depressing the red trip pushbutton on the EHC control panel in the main control room.
Resoonse The main turbine is tripped by depressing the red trip pushbutton on the EHC control panel in the main control room.
Auxiliary feedwater actuation is accomplished by operating the manual auxiliary feedwater actuation switches in the main control room.       No additional manual initiation capability is required for AMSAC equipment.
Auxiliary feedwater actuation is accomplished by operating the manual auxiliary feedwater actuation switches in the main control room.
ITEM   9:   ELECTRICAL     INDEPENDENCE FROM EXISTING REACTOR PROTECTION SYSTEM The plant-specific submittal should show that electrical independence is achieved.       This is required from the sensor output to the final actuation device at which point non-safety-related circuits must be isolated from safety-related circuits by qualified Class 1E isolators.         Use of existing isolators is acceptable. However, each plant-specific 7
No additional manual initiation capability is required for AMSAC equipment.
ITEM 9:
ELECTRICAL INDEPENDENCE FROM EXISTING REACTOR PROTECTION SYSTEM The plant-specific submittal should show that electrical independence is achieved.
This is required from the sensor output to the final actuation device at which point non-safety-related circuits must be isolated from safety-related circuits by qualified Class 1E isolators.
Use of existing isolators is acceptable.
However, each plant-specific 7


                      .'                                                                                                                                                              l 1
1 j
* j submittal should provide an analysis and tests which demon-strate that the existing isolator will function under the                                                                                                   -
submittal should provide an analysis and tests which demon-strate that the existing isolator will function under the maximum worst case fault conditions.
maximum worst case fault conditions.                                           The required method for qualifying either the existing                                       or diverse                       isolators is                                         ;
The required method for qualifying either the existing or diverse isolators is presented in Appendix A.
presented in Appendix A.                                                                                                                                     I Bosponse l
I Bosponse AMSAC inputs will be isolated from the RPS by sensor power supplies with isolated outputs.
AMSAC inputs will be isolated from the RPS by sensor power supplies with isolated outputs.                                                           These power supplies are supplied by Westinghouse as part of the 7300-Series Process Protection System.                                       They have been subjected to test faults and noise tests as part of their original qualifica-tion testing.                           This testing is - documented in WCAP-8892-A, which has received prior NRC review and approval (see FSAR Section 7.1.2.2.1) . This testing was performed.at voltage /
These power supplies are supplied by Westinghouse as part of the 7300-Series Process Protection System.
current levels that exceed the levels to which the isolator could be exposed.                                 The isolators were also subjected to additional testing to simulate static, magnetic, crcss talk, i                       and random noise.                           Existing 7300-Series isolator cards will be used to the extent possible; however, additional 7300-Series isolator cards may be added to isolate AMSAC input channels.                           These cards will be part of the 7300 Series Process Protection System and are qualified by the testing documented in WCAP-8892-A.
They have been subjected to test faults and noise tests as part of their original qualifica-tion testing.
AMSAC cutput. signals to BOP ESFAS will be isolated by qualified isolation relays. These relays have not yet been selected;                     however,           they will           be required to provide electrical separation at the maximum voltage / current levels                                                                                                 !
This testing is - documented in WCAP-8892-A, which has received prior NRC review and approval (see FSAR Section 7.1.2.2.1).
,                        to which they could be exposed.                                             The testing supporting
This testing was performed.at voltage /
                        . qualification                       will be consistent with the methodology outlined in Appendix A of Reference 2.
current levels that exceed the levels to which the isolator could be exposed.
The isolators were also subjected to additional testing to simulate static, magnetic, crcss talk, i
and random noise.
Existing 7300-Series isolator cards will be used to the extent possible; however, additional 7300-Series isolator cards may be added to isolate AMSAC input channels.
These cards will be part of the 7300 Series Process Protection System and are qualified by the testing documented in WCAP-8892-A.
AMSAC cutput. signals to BOP ESFAS will be isolated by qualified isolation relays. These relays have not yet been selected;
: however, they will be required to provide electrical separation at the maximum voltage / current levels to which they could be exposed.
The testing supporting
. qualification will be consistent with the methodology outlined in Appendix A of Reference 2.
)
)
The entire AMSAC design will meet the electrical separation criteria established for Callaway Plant and Wolf
The entire AMSAC design will meet the electrical separation criteria established for Callaway Plant and Wolf Creek Generating Station per FSAR Section 8.3, which uses
=
=
Creek Generating Station per FSAR Section 8.3, which uses Regulatory Guide 1.75 and IEEE 279-1971 as design bases.
Regulatory Guide 1.75 and IEEE 279-1971 as design bases.
ITEM 10:                   PHYSICAL SEPARATION FROM EXISTING REACTOR PROTE_Q-TION SYSTEM Physical separation from existing reactor protection system is not required, unless redundant divisions and channels in the existing reactor trip system are not phys-ically separated.                             The implementation must be such that separation criteria applied to the existing protection system are not violated.                                         The plant-specific submittal should respond to this concern.
ITEM 10:
PHYSICAL SEPARATION FROM EXISTING REACTOR PROTE_Q-TION SYSTEM Physical separation from existing reactor protection system is not
: required, unless redundant divisions and channels in the existing reactor trip system are not phys-ically separated.
The implementation must be such that separation criteria applied to the existing protection system are not violated.
The plant-specific submittal should respond to this concern.
8
8
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_,_.,-,-,.#y---
                                                                                  .                  .__,,,,_...,_--.---,,r           n- - =we- ---.--e.--s-=--wr-=- - . - + . - -----
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_. . _            .-.        ~_ .              .                      . . -- -.
~_.


===Response===
===Response===
The AMSAC equipment will be physically separated from the existing RPS, and cable routing for AMSAC will be completed using the separation criteria described in FSAR/USAR Section 8.3.1.4.       This will ensure that physical separation criteria of existing protection systems are not violated. Figure 1 also provides information about physical separation.
The AMSAC equipment will be physically separated from the existing RPS, and cable routing for AMSAC will be completed using the separation criteria described in FSAR/USAR Section 8.3.1.4.
ITEM 11:       ENVIRONMENTAL QUALIFICATION The plant-specific submittal should address the environ-mental qualification of ATWS equipment for anticipated operational occurrences only, not for accidents.
This will ensure that physical separation criteria of existing protection systems are not violated. Figure 1 also provides information about physical separation.
,              Response The AMSAC cabinet and input isolators will be located in the control room area, which is a mild environment area, temperature controlled by redundant Class 1E air conditioning units.       The equipment will be required to operate within an ambient temperature range of 60 0F to 84 0F. The above will be satisfied       by manufacturer     certification   that   supplied equipment can operate within applicable environmental extremes.
ITEM 11:
ENVIRONMENTAL QUALIFICATION The plant-specific submittal should address the environ-mental qualification of ATWS equipment for anticipated operational occurrences only, not for accidents.
 
===Response===
The AMSAC cabinet and input isolators will be located in the control room area, which is a mild environment area, temperature controlled by redundant Class 1E air conditioning units.
The equipment will be required to operate within an 0
0 ambient temperature range of 60 F to 84 F.
The above will be satisfied by manufacturer certification that supplied equipment can operate within applicable environmental extremes.
The AMSAC output isolation relays will be Class 1E relays qualified for environmental conditions associated with anticipated operational occurrences.
The AMSAC output isolation relays will be Class 1E relays qualified for environmental conditions associated with anticipated operational occurrences.
Documentation requirements         from Reference   4 are not applicable to this equipment.
Documentation requirements from Reference 4
ITEM 12:     TESTABILITY AT POWER Measures are to be established to test, as appropriate, non-safety-related ATWS equipment prior to installation and periodically.       Testing of AMSAC may be performed with' AMSAC in bypass.         Testing of AMSAC outputs through the final actuation devices will be performed with the plant shutdown.
are not applicable to this equipment.
!              The plant-specific submittals should present the test program and state that the output signal is indicated in the control room in a manner consistent with plant practices including human factors.
ITEM 12:
TESTABILITY AT POWER Measures are to be established to test, as appropriate, non-safety-related ATWS equipment prior to installation and periodically.
Testing of AMSAC may be performed with' AMSAC in bypass.
Testing of AMSAC outputs through the final actuation devices will be performed with the plant shutdown.
The plant-specific submittals should present the test program and state that the output signal is indicated in the control room in a manner consistent with plant practices including human factors.


===Response===
===Response===
l                   Specific test provisions of AMSAC will be dependent on l             the supplier and equipment selected, but testing prior to
l Specific test provisions of AMSAC will be dependent on l
,              operation will be performed to ensure that the equipmen,t 9
the supplier and equipment selected, but testing prior to operation will be performed to ensure that the equipmen,t 9
l 4
l 4


                                                          ' functions       correctly. The system will be bypassed for testing. Periodic testing of AMSAC will be performed with a frequency consistent with manufacturer's recommendations to ensure reliability.         Testing of AMSAC through the final actuation devices will be performed every refueling outage.
' functions correctly.
AMSAC equipment will be capable of being tested at power,   in bypass, in accordance with approved procedures.
The system will be bypassed for testing.
Bypassing AMSAC for testing and returning it to service will be controlled by administrative procedures similar to those currently used for other maintenance / testing activities. The bypass indication will be provided automatically in the control room via the AMSAC Bypass /Offnormal alarm on the main control board.       Actuation of AMSAC will be indicated via the
Periodic testing of AMSAC will be performed with a frequency consistent with manufacturer's recommendations to ensure reliability.
;                                                          AMSAC Urgent alarm on the main control board.
Testing of AMSAC through the final actuation devices will be performed every refueling outage.
ITEM 13:   COMPLETION OF MITIGATIVE ACTION AMSAC shall be designed so that, once actuated, the completion of mitigating action shall be consistent with the plant turbine trip and auxiliary feedwater circuitry.       Plant-specific submittals should verify that the protective action, once initiated, goes to completion, and that the subsequent return to operation requires deliberate operator action.
AMSAC equipment will be capable of being tested at
j                                                           Response                                                       -
: power, in bypass, in accordance with approved procedures.
Bypassing AMSAC for testing and returning it to service will be controlled by administrative procedures similar to those currently used for other maintenance / testing activities.
The bypass indication will be provided automatically in the control room via the AMSAC Bypass /Offnormal alarm on the main control board.
Actuation of AMSAC will be indicated via the AMSAC Urgent alarm on the main control board.
ITEM 13:
COMPLETION OF MITIGATIVE ACTION AMSAC shall be designed so that, once actuated, the completion of mitigating action shall be consistent with the plant turbine trip and auxiliary feedwater circuitry.
Plant-specific submittals should verify that the protective action, once initiated, goes to completion, and that the subsequent return to operation requires deliberate operator action.
j
 
===Response===
AMSAC will be designed so that, once actuated (after low i
AMSAC will be designed so that, once actuated (after low i
levels have been concurrently present in 3 of 4 S/G's for 25 seconds), the completion of mitigating action will occur.
levels have been concurrently present in 3 of 4 S/G's for 25 seconds), the completion of mitigating action will occur.
There will not be any manual AMSAC reset capability.       It will automatically reset after the C-20 permissive changes state,
There will not be any manual AMSAC reset capability.
(                                                         which is approximately 120 seconds after p:. ant power level is decreased below 40 percent.         This reset will not affect the turbine trip or auxiliary feedwater actuation circuitry.
It will automatically reset after the C-20 permissive changes state,
(
which is approximately 120 seconds after p:. ant power level is decreased below 40 percent.
This reset will not affect the turbine trip or auxiliary feedwater actuation circuitry.
Deliberate operator action is required to reset the turbine trip and auxiliary feedwater actuation circuitry.
Deliberate operator action is required to reset the turbine trip and auxiliary feedwater actuation circuitry.
AMSAC will provide a trip signal to the 125VDC trip bus in the turbine EHC cabinet. The 125V trip directly energizes the Mechanical Trip Solenoid Valve.           In addition, the 24v trip circuit is operated (cross-tripped) and the 125V trip bus is locked up.         Further, pressure switch contacts lock-up the hydraulic control system when the Mechanical Trip Valve and Emergency Trip System are tripped, and the generator circuit breaker is open. Reset of the turbine for return to operation could only be accomplished after the AMSAC signal is removed, reactor trip breakers are reset, and a master reset button is pressed.
AMSAC will provide a trip signal to the 125VDC trip bus in the turbine EHC cabinet.
The 125V trip directly energizes the Mechanical Trip Solenoid Valve.
In addition, the 24v trip circuit is operated (cross-tripped) and the 125V trip bus is locked up.
Further, pressure switch contacts lock-up the hydraulic control system when the Mechanical Trip Valve and Emergency Trip System are tripped, and the generator circuit breaker is open.
Reset of the turbine for return to operation could only be accomplished after the AMSAC signal is removed, reactor trip breakers are reset, and a master reset button is pressed.
10 t
10 t
  ~ , . . , - - - - - - - , -.,- ,, -. - -,-- - - - -..~ - - -                                                                 - , _ - . - - - , - -
~,.., - - - - - - -, -.,-,, -. - -,-- - - - -..~ - - -
,,n,-


AFW pumps will be started when BOP ESFAS receives a signal from AMSAC.         As described in FSAR Table 7.1-2, BOP ESFAS has been designed to meet the requirements of IEEE 279-1971, specifically IEEE 279, Paragraph 4.16, for completion of mitigative action.       AFW is restored to standby by clearing the actuation signal, pressing reset buttons, and securing pumps.
AFW pumps will be started when BOP ESFAS receives a signal from AMSAC.
ITEM 14:   TECHNICAL SPECIFICATIONS Technical Specification requirements related to AMSAC will have to be addressed by plant-specific submittals.
As described in FSAR Table 7.1-2, BOP ESFAS has been designed to meet the requirements of IEEE 279-1971, specifically IEEE 279, Paragraph 4.16, for completion of mitigative action.
Rtsponse Technical Specification recuiremer.ts         for AMSAC are unnecessary as they would not enhance overall plant safety beyond that afforded by planned administrative controls.         In addition, AMSAC should not be included in the Technical Specifications since the system does not meet the AIF nor NRC staff criteria for inclusion in the Technical Specifications.
AFW is restored to standby by clearing the actuation signal, pressing reset buttons, and securing pumps.
The surveillance interval and actions required due to an AMSAC failure will be administrat-tvely controlled via plant procedures. This position is consistent with the WOG position on this issue as discussed in References 5 and 6.
ITEM 14:
TECHNICAL SPECIFICATIONS Technical Specification requirements related to AMSAC will have to be addressed by plant-specific submittals.
Rtsponse Technical Specification recuiremer.ts for AMSAC are unnecessary as they would not enhance overall plant safety beyond that afforded by planned administrative controls.
In
: addition, AMSAC should not be included in the Technical Specifications since the system does not meet the AIF nor NRC staff criteria for inclusion in the Technical Specifications.
The surveillance interval and actions required due to an AMSAC failure will be administrat-tvely controlled via plant procedures.
This position is consistent with the WOG position on this issue as discussed in References 5 and 6.
11
11


REFERENCES
REFERENCES 1.
: 1. WCAP-10858P-A,   AMSAC Generic Design Package,                 October 1986.
WCAP-10858P-A, AMSAC Generic Design Package, October 1986.
: 2. NRC ' Safety Evaluation of Topical Report                 (WCAP-10858)
2.
                "AMSAC   Generic   Design Package"   (attachment             to NRC letters dated 9/22/86 to Union Electric and Kansas Gas &
NRC ' Safety Evaluation of Topical Report (WCAP-10858)
"AMSAC Generic Design Package" (attachment to NRC letters dated 9/22/86 to Union Electric and Kansas Gas &
Electric).
Electric).
: 3. Westinghouse   Owners   Group letter   OG-87-10,               dated 2/26/87:   Addendum 1 to WCAP-10858P-A.
3.
: 4. 10 CFR 50.49, Environmental Qualification of Electric Equipment Important to safety for Nuclear Power Plants.
Westinghouse Owners Group letter OG-87-10, dated 2/26/87:
: 5. Westinghouse Owners Group letter OG-171, dated 2/10/86:
Addendum 1 to WCAP-10858P-A.
4.
10 CFR 50.49, Environmental Qualification of Electric Equipment Important to safety for Nuclear Power Plants.
5.
Westinghouse Owners Group letter OG-171, dated 2/10/86:
WOG Comments on Proposed AMSAC Technical Specifications.
WOG Comments on Proposed AMSAC Technical Specifications.
: 6. Westinghouse Owners Group letter 03-181, dated 4/11/86:
6.
Westinghouse Owners Group letter 03-181, dated 4/11/86:
WOG Comments on AMSAC Design Specifications.
WOG Comments on AMSAC Design Specifications.
i MHF-39 12
i MHF-39 12


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            .                    p Attachment 2 LQUALITY ASSURANCE GUIDANCE FOR ATWS EQUIINEfff THAT IS NOI' SAFETY RELATED A
LQUALITY ASSURANCE GUIDANCE FOR ATWS EQUIINEfff THAT IS NOI' SAFETY RELATED A
WOLF CREEK GENERATING STATION 1.0     Organization The Quality organization will evaluate compliance- with the quality.
WOLF CREEK GENERATING STATION 1.0 Organization The Quality organization will evaluate compliance-with the quality.
                            -assurance guidance contained in Generic Letter 85-06. In addition to the Quality. organization     the existing       engineering,     materials management, document control, operations, and maintenance organizations will - be involved in the quality controls established for           AMSAC equipment.. These organizations may_ call upon the Quality Division to
-assurance guidance contained in Generic Letter 85-06.
            -                provide support where deemed necessary..
In addition to the Quality. organization the existing engineering, materials management, document control, operations, and maintenance organizations will - be involved in the quality controls established for AMSAC equipment..
                    -2.0     Program The existing body of procedures and practices will be employed by Wolf Creek Nuclear Operating Corporation to direct activities associated with
These organizations may_ call upon the Quality Division to provide support where deemed necessary..
                            'the quality controls applied to AMSAC.
-2.0 Program The existing body of procedures and practices will be employed by Wolf Creek Nuclear Operating Corporation to direct activities associated with
    .                3.0     Design Control Existing engineering procedures provide for measures to ensure that design specifications' are included or correctly translated into design documents and that a 10CFR50.59 review is performed.
'the quality controls applied to AMSAC.
I                     4.0     Procurement Document Control Existing design and procurement procedures ensure that appropriate technical and quality requirementa are incorporated into procurement documents.
3.0 Design Control Existing engineering procedures provide for measures to ensure that design specifications' are included or correctly translated into design documents and that a 10CFR50.59 review is performed.
5.0     ' Instructions, Procedures and Drawings Procedures, instructions, and/or drawings will be utilized to control activities affecting the quality of the AMSAC design, installation, maintenance and_ testing. Maintenance activities will be based on the appropriate use of vendor information unless adequate engineering rationale indicates that the use of         any   such   information is inappropriate or unnecessary.
I 4.0 Procurement Document Control Existing design and procurement procedures ensure that appropriate technical and quality requirementa are incorporated into procurement documents.
6.0     Document Control Measures are in place within Wolf Creek Nuclear Operating Corporation to control changes to and the issuance of AMSAC related documents.
5.0
7.0     Control of Purchased Itens and Services Receipt inspection and/or performance testing will ensure that purchased hardware conforms to the applicable requirements of the procurement documents.
' Instructions, Procedures and Drawings Procedures, instructions, and/or drawings will be utilized to control activities affecting the quality of the AMSAC design, installation, maintenance and_ testing.
Maintenance activities will be based on the appropriate use of vendor information unless adequate engineering rationale indicates that the use of any such information is inappropriate or unnecessary.
6.0 Document Control Measures are in place within Wolf Creek Nuclear Operating Corporation to control changes to and the issuance of AMSAC related documents.
7.0 Control of Purchased Itens and Services Receipt inspection and/or performance testing will ensure that purchased hardware conforms to the applicable requirements of the procurement documents.
a
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l 4
4 8.0 Identification and Control of Purchased Items Existing warehousing. storage. measures will be used. including.any necessary steps to protect environnentally sensitive equipment / material..
8.0   Identification and Control of Purchased Items Existing warehousing . storage . measures will be used . including .any necessary steps to protect environnentally sensitive equipment / material. .
!9.0 Control of Special Processes Appropriate. industry accepted codes and standards will be used to control any special processes which could affect nuclear safety..
                  !9.0   Control of Special Processes Appropriate . industry accepted codes and standards will be used to control any special processes which could affect nuclear safety..
10.0 Inspection
10.0 Inspection
                        , Inspections will be specified in the installation process to ensure that critical parameters are in accordance with the design documents. Such inspections will be performed by knowledgeable individuals who did not do     the installation work,' but who 'may- be from the same line organization.
, Inspections will be specified in the installation process to ensure that critical parameters are in accordance with the design documents.
t                  11.0 Testing Testing of AMSAC will.be performed prior to operation and periodically thereafter.     'Ihe test -results will be reviewed to ensure that test requirements have been met.                             ,
Such inspections will be performed by knowledgeable individuals who did not do the installation work,' but who 'may-be from the same line organization.
11.0 Testing t
Testing of AMSAC will.be performed prior to operation and periodically thereafter.
'Ihe test -results will be reviewed to ensure that test requirements have been met.
12.0 Control of Measuring and Test Equipment Existing plant procedures will be used to control,. calibrate and adjust measuring and test equipment associated with AMSAC at pre-established
12.0 Control of Measuring and Test Equipment Existing plant procedures will be used to control,. calibrate and adjust measuring and test equipment associated with AMSAC at pre-established
                          -intervals..
-intervals..
13.0 Handling, Storage and Shipping Good industry practice will be used in handling, shipping and storage of AMSAC     equipment.     Manufacturer's reconnendations with regard ~ to maintenance of the equipment (including cleaning and preservation) will be addressed as indicated under Item 5.0.
13.0 Handling, Storage and Shipping Good industry practice will be used in handling, shipping and storage of AMSAC equipment.
14.0 Inspection, Test and Operating Status Status indication for AMSAC equipment will be provided as specified in Attachment 1 of this submittal.
Manufacturer's reconnendations with regard ~ to maintenance of the equipment (including cleaning and preservation) will be addressed as indicated under Item 5.0.
15.0 Nonconformances Any nonconformance identified during the installation or operation phases   of AMSAC will be controlled in accordance with existing procedures which provide for documented identifification, resolution and correction.
14.0 Inspection, Test and Operating Status Status indication for AMSAC equipment will be provided as specified in of this submittal.
15.0 Nonconformances Any nonconformance identified during the installation or operation phases of AMSAC will be controlled in accordance with existing procedures which provide for documented identifification, resolution and correction.
2
2
: l.     ,.*-
 
16.0 Corrective Action System Nonconformances are dispositioned and corrected as stated above. As part of this process, a review is made to determine if measures need to be          taken to preclude repetition of any condition which is classified as significantly adverse to quality.
l.
16.0 Corrective Action System Nonconformances are dispositioned and corrected as stated above.
As a review is made to determine if measures need to part of this process, taken to preclude repetition of any condition which is classified as besignificantly adverse to quality.
17.0 Records Records will be maintained of the 10 CFR 50.59 reviews performed as well as doctanentation indicating.coupliance with the requirements of the ATWS -
17.0 Records Records will be maintained of the 10 CFR 50.59 reviews performed as well as doctanentation indicating.coupliance with the requirements of the ATWS -
rule (10 CFR- 50.62) .
rule (10 CFR-50.62).
18.0 Audits Measures will be taken to ensure that aporopriate quality controls are instituted with regard to .AMSAC.                                                                                                         Line management will review the design, installation and operation phases of AMSAC and take whatever actions                       are                 deemed necessary to correct any identified quality deficiencies.
18.0 Audits Measures will be taken to ensure that aporopriate quality controls are instituted with regard to.AMSAC.
Line management will review the
: design, installation and operation phases of AMSAC and take whatever actions are deemed necessary to correct any identified quality deficiencies.
3
3
                                                                      ---                  - - - - _ _ _ . _ _ _ _ _ _ _ _ _ _ . , _ _ _ . _ , _ _ _ _ _ _}}
- - - - _ _ _. _ _ _ _ _ _ _ _ _ _., _ _ _. _, _ _ _ _ _ _}}

Latest revision as of 20:39, 7 December 2024

Forwards Info Re ATWS Mitigating Sys Actuation Circuitry (Amsac),Per P Oconnor 860922 Request.Approval of Submittal Requested Before 870701 to Support AMSAC Installation Prior to Startup Following Third Refueling Outage in Fall 1988
ML20204B576
Person / Time
Site: Wolf Creek 
Issue date: 03/20/1987
From: Withers B
WOLF CREEK NUCLEAR OPERATING CORP.
To:
NRC OFFICE OF INFORMATION RESOURCES MANAGEMENT (IRM)
References
10CFR50.62, WM-87-0100, WM-87-100, NUDOCS 8703250099
Download: ML20204B576 (18)


Text

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NUCLEAR OPERATING CORPORATION March 20, 1E37 U.S. Nuclear Regulatory Comnission ATTN: Document C::ntrol Desk Washington, D.C.

20555 Letter: WM 87-0100 Re:

Docket No. 50-482 Ref:

1.

Letter dated 09/22/86 from PO'Connor, NRC, to GLKoester, KG&E 2.

Letter KMLNRC 86-195 dated 10/31/86 from GLKoester, KG&E, to HRDenton, NRC Subj-ATWS Mitigating System Actuation Circuitry -

10 CFR 50.62 Gentlemen:

Attachinents 1 and 2 provide the Wolf Creek Generating Station ' Anticipated Transients Without Scram (ATWS) Mitigating Sp lem Actuation Circuitry (AMSAC) information requested in Reference

1.,

which is identical for both Wolf Creek Generating Station and the Callaway Plant, provides the plant-specific design details and attachment 2 provides a description of the Wolf Creek quality assurance program to be applied to the non-safety related AMSAC equipment.

The information contained in the attachments is sufficient to demonstrate the adequacy of the AMSAC design to meet the requirenents of

~

10CFR50.62(c) (1) at Wolf Creek Generating Station.

AMSAC will provide an l-alternate means of tripping the turbine and actuating auxiliary feedwater l

flow in a manner diverse from the reactor trip system.

Actuation of AMSAC will occur as a result of low water 1cral in the steam generators utilizing l

existing sensors and circuitry. After the specific AMSAC design details are finalized, they will be integrated into plant operating procedures and training, as appropriate.

8703250099 870320 PDR ADOCK 0500 2

M N

PO. Box 411 I Burlington, KS 66839 Phone: (316) 364-8831 O

An Equal Oppertunity Employer M F }CVET

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1 wt 87-9199 Page 2 f'

Although this information was originally scheduled in Reference 2 to be submitted by March 1,.1987, the Staff verbally granted an extension to March 29, 1987 to allow time for Wolf Creek and Callaway to coordinate a cannon submittal on the design information. However, Staff approval of this plant-specific submittal is still requested prior to July 1, 1987 in order to support AMSAC installation prior to start-up following the third refueling outage currently scheduled for Fall 1988.

'Ihis allows sufficient time for proper scheduling and procurenent activities and implementation of any changes which may result from the staff review.

If you have any questions concerning this submittal, please contact 'me or Mr. O. L. Maynard of my staff.

Very truly yours,

__=W Bart D. Withers President and Chief Executive Officer i

BEM:wbb Attachments cc: ' P0'Connor (2)

JCummins RMartin.

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PIANT-SPECIFIC ~ DESIGN DETAILS REGARDING ATWS MITIGATING SYSTEM ACTUATION CIRCUITRY CALIAWAY PIANT AND WOLF CREEK GENERATING STATION IhIRODUCTION Reference 1 provided generic design options for use by Westinghouse plants in addressing the requirements af 10 CFR 50.62,

" Requirements for Reduction of Risk from Anticipated Transients Without Scram (ATWS) Events for Light-Water-Cooled Nuclear Power Plants."

Reference 2 reported the completion of an NRC staff review of the generic design information in Reference 1 and identified plant-specific design information required by the NRC staff to verify compliance with 10 CFR 4

50.62.

The plant-specific information applicable to Callaway l

Plant and Wolf Creek Generating Station is provided in the i

following paragraphs.

DESIGN CONCEPT AMSAC Desian ODtion The AMSAC design employs Option 1 r*

Reference 1.

The design will use existing steam generat.+ level transmitters to actuate a turbine trip and initiate auxiliary feedwater flow.

The AMSAC will also initiate closure of steam genera-

- tor blowdown isolation and sample isolation valves.

ATWS is defined in 10 CFR 50.62 as "an anticipated operational occurrence as defined in Appandix A of this part followed by the failure of the reactor trip portion of the protection system specified in General Design Criterion 20 of Appendix A of this part."

In the Callaway and Wolf Creek designs, the reactor trip portion of the protection system and the Balance of Plant (BOP) Engineered Safety Features Actuation System (ESFAS) are separate systems.

The Reactor Trip System (RTS) employs the output of the Westinghouse Solid State Protection System (SSPS) to trip the reactor trip breakers resulting in a reactor scram.

The BOP ESFAS manufactured by Consolidated controls Corporation, receives an input signal from the SSPS to actuate various safeguards

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equipment including the auxiliary fes.dwater (AFW) pumps and the steam generator blowdown isolation and sample isolation valves.

The existing turbine trip on reactor trip signal is the P-4 permissive generated by opening the reactor trip breakers.

For the Callaway and Wolf Creek AMSAC design, an AMSAC logic cabinet will be installed in the Control Room.

The space allotted for the cabinet was incorporated into the original design of the plants.

Existing narrow range steam generator level transmitters not used in the steam generator level control system, will provide signals to the non-Class lE AMSAC Oircuits via qualified isolation devices.

The coincidence logic for AMSAC initiation is 3/4 low steam generator level signals with one channel provided for each of the four steam generators.*

Outputs from AMSAC will provide a

signal to the BOP ESFAS through qualified, Class 1E isolation relays to start the AFW pumps.

The AFW pump start signal will also close steam generator blowdown and sample isolation valves This use of the existing BOP ESFAS system will provide for the required diversity from the RTS without further complicating the plant safety systems.

AMSAC will also provide a signal to the main turbine electrohydraulic control (EHC) system for turbine trip.

The auxiliary feedwater flow response time and turbine trip response time are consistent with Reference 1 requirements.

Figure 1 provides the conceptual design and layout of the AMSAC.

The Callaway and Wolf Creek main control board alarms have been designed to employ the " dark board" concept to improve human factors performarce of the plant operators.

This principle requires, to the extent possible, that alarms illuminate to show an abnormal condition.

If conditions are normal, the panel alarms remain darkened.

Also, to avoid confusion from excessive alarms in the control room, the number of alarms has been kept as low as possible.

Only two AMSAC-related alarm windows will be placed on the main control board:

an AMSAC Urgent

alarm, and an AMSAC Bypass /Offnormal alarm.

The AMSAC Urgent alarm indicates that the AMSAC initiation sequence has started and that, after an appropriate time delay, AMSAC will trip the main turbine and start the AFW pumps.

The AMSAC Bypass /Offnormal alarm is used to provide the control room operators indication of abnormal or unusual situations affecting AMSM Consideration is being given to the use of programmable logic control (PLC) in the AMSAC logic.

The AMSAC low level setpoint is below the RPS low-low level setpoint consistent with Reference 1.

2

such as a

failure of the C-20 permissive circuitry, a

maintenance bypass condition, loss of power supply, and self diagnostics trouble.

(The full range of AMSAC offnormal conditions is dependent on supplier options.)

Reference 2 identified 14 plant-specific items to be addressed by utilities.

Responses to these items are provided below.

ITEM 1:

DIVERSITY The plant-specific submittal should indicate the degree of diversity that exists between the AMSAC equipment and the.

existing Reactor Protection System.

Equipment diversity to the extent reasonable and practicable to minimize the potential for common cause failures is required from the sensors output to, but not including, the final actuation

device, e.g.,

existing circuit breakers may be used for the auxiliary feedwater initiation.

The sensors need not be of a diverse design or manufacture.

Existing protection system instrument-sensing lines, sensors, and sensor power supplies may be used.

Sensor and instrument sensing lines should be selected such that adverse interactions with existing control systems are avoided.

Response

Existing steam generator water level transmitters, sensing lines and sensor power supplies will be used for input to AMSAC.

The AMSAC equipment will be of a different design and diverse from the Westinghouse Reactor Protection System (RPS).

This diversity will exist from the RPS isolators (7300 loop power supply cards) to the AMSAC output relays.

Existing RPS sensor power supplies will provide power to the level transmitters and perform an isolation function.

Power supplies for the non-safety-related AMSAC equipment are diverse in that they will be powered from 125VDC non-1E instrument power from the plant-designated PK system.

AMSAC will initiate AEW flow via the Consolidated Controls Corporation (CCC)

ESFAS system that starts the motor-and turbine-driven AFW pu.11ps (by opening the latter's steam supply valves) and isolates steam generator blowdown and sampling by means of the ArW Actuation Signal (AFAS).

AMSAC initiates turbine trip by means of a separate signal to the existing General Electric turbine control circuitry.

Thus, the circuitry for AFW initiation and turbine trip is diverse from the RPS, which consists of the 7300 Process Protection System (PPS) and SSPS cabinets, from the steam 3

l l

generator level transmitter power supplies, including the required isolation devices, to the AFW pumps and to the EHC system for turbine trip.

This is based on the existing diversity and independence between the BOF ESFAS and the RTS.

The steam generator level sensors used as input to AMSAC are different than those used to drive the steam generator level control system.

This will alleviate any concern that an adverse interaction will exist between AMSAC and existing control systems.

ITEM 2:

IDGIC POWER SUPPLIES The plant-specific submittal should discuss the logic power supply design.

According to the rule, the AMSAC logic power supply is not required to be safety-related (Class lE).

However, logic power should be from an instrument power supply that is independent from the reactor protection system (RPS) power supplies.

Our review of additional information submitted by WOG indicated that power to the logic circuits will utilize RPS batteries and inverters.

The staff finds this portion of the design unacceptable; therefore, independent power supplies should be provided.

Response

The power input to the AMSAC equipment, with the exception of the Class lE level transmitters and isolation devices, will be from non-Class lE buses with battery backup.

This supply will be independent from the RPS power input.

The RPS power supply is from Class lE dc buses NK01, NK02, NK03, and NK04 via Class lE inverters (FSAR Fig. 8.3-6).

The AMSAC power supply will be from non-Class lE dc buses PK01, PK02, PK03, or PK04 (FSAR Figs.

8.3-6 and 8.3-7) and will allow AMSAC to function during a loss of offsite power.

The I

use of this independent power source will substantially l

decrease the probability of a common mode failure on demand.

l (Failure occurring or detected only during an actual need or test.)

Direct current power for the BOP ESFAS is supplied from three independent Class lE buses (NK01, NK02, and NK04.)

These buses have separate chargers with battery backup as shown in Callaway FSAR (Wolf Creek USAR) Figure 0.3-6.

Loss of power to any of these buses is annunciated in the control room.

Although these buses also supply power to 4

e the RPS, as indicated above, their use is justified owing to the low probability of common mode failure on demand occurring simultaneously with an ATWS event.

The PK 125 volt dc system includes four batteries, four battery

chargers, four main switchboards, and eight distribution switchboards.

On loss of ac power, or the failure of a charger, the batteries supply power to their respective 125 volt dc buses (PK01, PK02, PK03, or PK04).

Buses PK01 and PK02 primarily serve the non-safety-related control and instrumentation loads through 125 volt dc distribution panels.

Buses PK03 and PK04 primarily serve the non-safety-related inverter loads.

ITEM 3:

SAFETY-RELATED INTERFACE The plant-specific submittal should show that the implementation is such that the existing protection system continues to meet all applicable safety criteria.

Response

The existing protection system will continue to meet all applicable safety criteria because qualified isolation devices will separate the non-safety-related AMSAC equipment from the existing safety-related Westinghouse 7300 process

cabinets, solid state protection system (SSPS),

and BOP engineered safety feature actuation system (ESFAS) equipment.

Existing separation criteria will continue to be met between safety-related and non-safety-related equipment as described in the Callaway Plant and Wolf Creek Generating Station FSARs (Section 8.3) which use Regulatory Guide 1.75 and IEEE 279-j 1971 as design bases.

ITEM 4:

QUALITY ASSURANCE The plant-specific submittal should provide information regarding compliance with Generic Letter 85-06,

" Quality Assurance Guidance for ATWS Equipment that is not Safety-Related."

ResDonse Quality Assurance requirements for non-safety-related AMSAC equipment are provided per the Quality Assurance provisions defined in Attachment 2.

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ITEM 5:

MAINTENANCE BYPASSES The plant-specific submittal should discuss how maintenance at power is accomplished and how good human factors engineering practice is incorporated into the continuous indication of bypass status in the control room.

Response

' Surveillance and maintenance of AMSAC and AMSAC sensor inputs will be performed using approved procedures.

To avoid AMSAC actuation during maintenance or surveillance of the AMSAC system or sensor inputs, the AMSAC output signals will be bypassed via a permanently installed bypass switch at the AMSAC panel.

Normal maintenance at power will not involve lifting of

leads, pulling
fuses, tripping
breakers, or physically blocking relays.

Indication of AMSAC maintenance bypasses will be continuously indicated via the AMSAC Bypass /Offnormal alarm window on the main control board.

The normally dark window will be illuminated whenever the bypass switch is in the

" bypass" position.

This alarm window, as well as the AMSAC urgent alarm window, will be designed consistent with the original Detailed Control Room Design Review (DCRDR) approved by the NRC.

ITEM 6:

OPERATING BYPASSES The plant-specific submittal should state that operating bypasses are. continuously indicated in the control room, 4

- provide the basis for the 70 percent or plant-specific operating bypass level, discuss the human factors design aspects of the continuous indication, and discuss the diversity and independence of the C-20 permissive signal (defeats the block of AMSAC).

Response

The plant-specific C-20 permissive setpoint for Callaway and Wolf Creek is 40 percent power.

The basis for 40 percent power was prwided in Reference 3.

The input signals for deriving C-20 will be provided by the two main turbine first stage impulse pressure transmitters.

The turbine impulse pressure signals are derived from existing protection system sensing lines,

sensors, and power supplies.

The logic portion of the C-20 signal is processed in the AMSAC cir-cuitry and is diverse from the SSPS.

In the event of a turbine

trip, removal of the C-20 permissive signal is delayed for a period of time consistent with reference 1 to avoid blocking AMSAC before it can perform its function.

6

AMSAC will be enabled by 2/2 turbine impulse pressure transmitters above 40 percent power.

Also, AMSAC will be automatically blocked if one of these transmitters indicates power below 40 percent.

These are normal conditions.

In keeping with the " dark board" human factors concept for the main control boards, the above normal conditions will not result in alarm indications on the main control board.

If the AMSAC is not enabled above 40 percent power, the AMSAC Bypass / Offnormal alarm will sound and illuminate on the main control board.

ITEM 7:

MEANS FOR BYPASSING The plant-specific submittal should state that the means for bypassing is accomplished with a permanently installed, human factored, bypass switch or similar device, and verify that disallowed methods mentioned in the guidance are not utilized.

Response

The means for bypassing AMSAC during testing and maintenance will be accomplished with a permanently installed bypass switch and will not use any of the disallowed methods mentioned in Reference 2.

ITEM 8:

MANUAL INITIATION The plant-specific submittal should discuss how a manual turbine trip and auxiliary feedwater actuation are accomplished by the operator.

Resoonse The main turbine is tripped by depressing the red trip pushbutton on the EHC control panel in the main control room.

Auxiliary feedwater actuation is accomplished by operating the manual auxiliary feedwater actuation switches in the main control room.

No additional manual initiation capability is required for AMSAC equipment.

ITEM 9:

ELECTRICAL INDEPENDENCE FROM EXISTING REACTOR PROTECTION SYSTEM The plant-specific submittal should show that electrical independence is achieved.

This is required from the sensor output to the final actuation device at which point non-safety-related circuits must be isolated from safety-related circuits by qualified Class 1E isolators.

Use of existing isolators is acceptable.

However, each plant-specific 7

1 j

submittal should provide an analysis and tests which demon-strate that the existing isolator will function under the maximum worst case fault conditions.

The required method for qualifying either the existing or diverse isolators is presented in Appendix A.

I Bosponse AMSAC inputs will be isolated from the RPS by sensor power supplies with isolated outputs.

These power supplies are supplied by Westinghouse as part of the 7300-Series Process Protection System.

They have been subjected to test faults and noise tests as part of their original qualifica-tion testing.

This testing is - documented in WCAP-8892-A, which has received prior NRC review and approval (see FSAR Section 7.1.2.2.1).

This testing was performed.at voltage /

current levels that exceed the levels to which the isolator could be exposed.

The isolators were also subjected to additional testing to simulate static, magnetic, crcss talk, i

and random noise.

Existing 7300-Series isolator cards will be used to the extent possible; however, additional 7300-Series isolator cards may be added to isolate AMSAC input channels.

These cards will be part of the 7300 Series Process Protection System and are qualified by the testing documented in WCAP-8892-A.

AMSAC cutput. signals to BOP ESFAS will be isolated by qualified isolation relays. These relays have not yet been selected;

however, they will be required to provide electrical separation at the maximum voltage / current levels to which they could be exposed.

The testing supporting

. qualification will be consistent with the methodology outlined in Appendix A of Reference 2.

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The entire AMSAC design will meet the electrical separation criteria established for Callaway Plant and Wolf Creek Generating Station per FSAR Section 8.3, which uses

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Regulatory Guide 1.75 and IEEE 279-1971 as design bases.

ITEM 10:

PHYSICAL SEPARATION FROM EXISTING REACTOR PROTE_Q-TION SYSTEM Physical separation from existing reactor protection system is not

required, unless redundant divisions and channels in the existing reactor trip system are not phys-ically separated.

The implementation must be such that separation criteria applied to the existing protection system are not violated.

The plant-specific submittal should respond to this concern.

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Response

The AMSAC equipment will be physically separated from the existing RPS, and cable routing for AMSAC will be completed using the separation criteria described in FSAR/USAR Section 8.3.1.4.

This will ensure that physical separation criteria of existing protection systems are not violated. Figure 1 also provides information about physical separation.

ITEM 11:

ENVIRONMENTAL QUALIFICATION The plant-specific submittal should address the environ-mental qualification of ATWS equipment for anticipated operational occurrences only, not for accidents.

Response

The AMSAC cabinet and input isolators will be located in the control room area, which is a mild environment area, temperature controlled by redundant Class 1E air conditioning units.

The equipment will be required to operate within an 0

0 ambient temperature range of 60 F to 84 F.

The above will be satisfied by manufacturer certification that supplied equipment can operate within applicable environmental extremes.

The AMSAC output isolation relays will be Class 1E relays qualified for environmental conditions associated with anticipated operational occurrences.

Documentation requirements from Reference 4

are not applicable to this equipment.

ITEM 12:

TESTABILITY AT POWER Measures are to be established to test, as appropriate, non-safety-related ATWS equipment prior to installation and periodically.

Testing of AMSAC may be performed with' AMSAC in bypass.

Testing of AMSAC outputs through the final actuation devices will be performed with the plant shutdown.

The plant-specific submittals should present the test program and state that the output signal is indicated in the control room in a manner consistent with plant practices including human factors.

Response

l Specific test provisions of AMSAC will be dependent on l

the supplier and equipment selected, but testing prior to operation will be performed to ensure that the equipmen,t 9

l 4

' functions correctly.

The system will be bypassed for testing.

Periodic testing of AMSAC will be performed with a frequency consistent with manufacturer's recommendations to ensure reliability.

Testing of AMSAC through the final actuation devices will be performed every refueling outage.

AMSAC equipment will be capable of being tested at

power, in bypass, in accordance with approved procedures.

Bypassing AMSAC for testing and returning it to service will be controlled by administrative procedures similar to those currently used for other maintenance / testing activities.

The bypass indication will be provided automatically in the control room via the AMSAC Bypass /Offnormal alarm on the main control board.

Actuation of AMSAC will be indicated via the AMSAC Urgent alarm on the main control board.

ITEM 13:

COMPLETION OF MITIGATIVE ACTION AMSAC shall be designed so that, once actuated, the completion of mitigating action shall be consistent with the plant turbine trip and auxiliary feedwater circuitry.

Plant-specific submittals should verify that the protective action, once initiated, goes to completion, and that the subsequent return to operation requires deliberate operator action.

j

Response

AMSAC will be designed so that, once actuated (after low i

levels have been concurrently present in 3 of 4 S/G's for 25 seconds), the completion of mitigating action will occur.

There will not be any manual AMSAC reset capability.

It will automatically reset after the C-20 permissive changes state,

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which is approximately 120 seconds after p:. ant power level is decreased below 40 percent.

This reset will not affect the turbine trip or auxiliary feedwater actuation circuitry.

Deliberate operator action is required to reset the turbine trip and auxiliary feedwater actuation circuitry.

AMSAC will provide a trip signal to the 125VDC trip bus in the turbine EHC cabinet.

The 125V trip directly energizes the Mechanical Trip Solenoid Valve.

In addition, the 24v trip circuit is operated (cross-tripped) and the 125V trip bus is locked up.

Further, pressure switch contacts lock-up the hydraulic control system when the Mechanical Trip Valve and Emergency Trip System are tripped, and the generator circuit breaker is open.

Reset of the turbine for return to operation could only be accomplished after the AMSAC signal is removed, reactor trip breakers are reset, and a master reset button is pressed.

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AFW pumps will be started when BOP ESFAS receives a signal from AMSAC.

As described in FSAR Table 7.1-2, BOP ESFAS has been designed to meet the requirements of IEEE 279-1971, specifically IEEE 279, Paragraph 4.16, for completion of mitigative action.

AFW is restored to standby by clearing the actuation signal, pressing reset buttons, and securing pumps.

ITEM 14:

TECHNICAL SPECIFICATIONS Technical Specification requirements related to AMSAC will have to be addressed by plant-specific submittals.

Rtsponse Technical Specification recuiremer.ts for AMSAC are unnecessary as they would not enhance overall plant safety beyond that afforded by planned administrative controls.

In

addition, AMSAC should not be included in the Technical Specifications since the system does not meet the AIF nor NRC staff criteria for inclusion in the Technical Specifications.

The surveillance interval and actions required due to an AMSAC failure will be administrat-tvely controlled via plant procedures.

This position is consistent with the WOG position on this issue as discussed in References 5 and 6.

11

REFERENCES 1.

WCAP-10858P-A, AMSAC Generic Design Package, October 1986.

2.

NRC ' Safety Evaluation of Topical Report (WCAP-10858)

"AMSAC Generic Design Package" (attachment to NRC letters dated 9/22/86 to Union Electric and Kansas Gas &

Electric).

3.

Westinghouse Owners Group letter OG-87-10, dated 2/26/87:

Addendum 1 to WCAP-10858P-A.

4.

10 CFR 50.49, Environmental Qualification of Electric Equipment Important to safety for Nuclear Power Plants.

5.

Westinghouse Owners Group letter OG-171, dated 2/10/86:

WOG Comments on Proposed AMSAC Technical Specifications.

6.

Westinghouse Owners Group letter 03-181, dated 4/11/86:

WOG Comments on AMSAC Design Specifications.

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LQUALITY ASSURANCE GUIDANCE FOR ATWS EQUIINEfff THAT IS NOI' SAFETY RELATED A

WOLF CREEK GENERATING STATION 1.0 Organization The Quality organization will evaluate compliance-with the quality.

-assurance guidance contained in Generic Letter 85-06.

In addition to the Quality. organization the existing engineering, materials management, document control, operations, and maintenance organizations will - be involved in the quality controls established for AMSAC equipment..

These organizations may_ call upon the Quality Division to provide support where deemed necessary..

-2.0 Program The existing body of procedures and practices will be employed by Wolf Creek Nuclear Operating Corporation to direct activities associated with

'the quality controls applied to AMSAC.

3.0 Design Control Existing engineering procedures provide for measures to ensure that design specifications' are included or correctly translated into design documents and that a 10CFR50.59 review is performed.

I 4.0 Procurement Document Control Existing design and procurement procedures ensure that appropriate technical and quality requirementa are incorporated into procurement documents.

5.0

' Instructions, Procedures and Drawings Procedures, instructions, and/or drawings will be utilized to control activities affecting the quality of the AMSAC design, installation, maintenance and_ testing.

Maintenance activities will be based on the appropriate use of vendor information unless adequate engineering rationale indicates that the use of any such information is inappropriate or unnecessary.

6.0 Document Control Measures are in place within Wolf Creek Nuclear Operating Corporation to control changes to and the issuance of AMSAC related documents.

7.0 Control of Purchased Itens and Services Receipt inspection and/or performance testing will ensure that purchased hardware conforms to the applicable requirements of the procurement documents.

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4 8.0 Identification and Control of Purchased Items Existing warehousing. storage. measures will be used. including.any necessary steps to protect environnentally sensitive equipment / material..

!9.0 Control of Special Processes Appropriate. industry accepted codes and standards will be used to control any special processes which could affect nuclear safety..

10.0 Inspection

, Inspections will be specified in the installation process to ensure that critical parameters are in accordance with the design documents.

Such inspections will be performed by knowledgeable individuals who did not do the installation work,' but who 'may-be from the same line organization.

11.0 Testing t

Testing of AMSAC will.be performed prior to operation and periodically thereafter.

'Ihe test -results will be reviewed to ensure that test requirements have been met.

12.0 Control of Measuring and Test Equipment Existing plant procedures will be used to control,. calibrate and adjust measuring and test equipment associated with AMSAC at pre-established

-intervals..

13.0 Handling, Storage and Shipping Good industry practice will be used in handling, shipping and storage of AMSAC equipment.

Manufacturer's reconnendations with regard ~ to maintenance of the equipment (including cleaning and preservation) will be addressed as indicated under Item 5.0.

14.0 Inspection, Test and Operating Status Status indication for AMSAC equipment will be provided as specified in of this submittal.

15.0 Nonconformances Any nonconformance identified during the installation or operation phases of AMSAC will be controlled in accordance with existing procedures which provide for documented identifification, resolution and correction.

2

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16.0 Corrective Action System Nonconformances are dispositioned and corrected as stated above.

As a review is made to determine if measures need to part of this process, taken to preclude repetition of any condition which is classified as besignificantly adverse to quality.

17.0 Records Records will be maintained of the 10 CFR 50.59 reviews performed as well as doctanentation indicating.coupliance with the requirements of the ATWS -

rule (10 CFR-50.62).

18.0 Audits Measures will be taken to ensure that aporopriate quality controls are instituted with regard to.AMSAC.

Line management will review the

design, installation and operation phases of AMSAC and take whatever actions are deemed necessary to correct any identified quality deficiencies.

3

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