ML14184A350
| ML14184A350 | |
| Person / Time | |
|---|---|
| Site: | Robinson  |
| Issue date: | 03/04/1983 |
| From: | Varga S Office of Nuclear Reactor Regulation |
| To: | Utley E CAROLINA POWER & LIGHT CO. |
| References | |
| NUDOCS 8303160671 | |
| Download: ML14184A350 (4) | |
Text
DISTRIBUTION Docket MR 04 1983 NR PDR Docket No. 50-261 NSIC ORB#1 Rdg DEisenhut OELD Mr. E. E. Utley, Executive Vice President JoTayor Power Supply and Engineering & Construction ACRS-10 Carolina Power and Light Company CParrish Post Office Box 1551 MGrotenhuis Raleigh, North Carolina 27602 Greu GRequa Gray
Dear Mr. Utley:
SUBJECT:
BLOCKING OF STEAM LINE HIGH DIFFERENTIAL PRESSURE SAFETY INJECTION SIGNAL DURING COOLDOWN During inspection and review of PWR facilities, it was noted that some PWR facilities blocked the Safety Injection System in a manner not consistent with the Technical Specifications for that facility. We have completed a review of all PWR's and found that there is a question in this regard for your facility which is identified in the enclosure to this letter.
Please respond to the concern identified within 30 days from the receipt of this letter.
The reporting and/or recordkeeping requirements of this letter affect fewer than ten respondents; therefore, OMB clearance is not required under P.L.96-511.
Sincerely, triginal signed by&
S. A. Varga Steven A. Varga, Chief Operating Reactors Branch #1 Division of Licensing
Enclosure:
As stated c~c w/enclosure:
See.next page 8303160671 830304 PDR ADOCK 05000261 P
PDR ORB1:ORB#1 A OFFICE.
R SURNAME R.
iGrotenhuis DATE 8 00 R
O O FFICIAL. R9........................................................................-.......................
NRC FORM 318 (10-80) NRCM 0240 OFFICIAL RECORD COPY USGPO: 1981-335-960
Mr. E. E. Utley Carolina Power and Light Company cc: G. F. Trowbridge, Esquire Shaw, Pittman, Potts and Trowbridge 1800 M Street, N.W.
Washington, D. C. 20036 U. S. Nuclear Regulatory Commission Resident Inspector's Office H. B. Robinson Steam Electric Plant Route 5, Box 266-1A Hartsville, South Carolina 29550 James P. O'Reilly Regional Administrator -
Region II U. S. Nuclear Regulatory Commission 101 Marietta Street - Suite 3100 Atlanta, Georgia 30303
ENCLOSURE DISCREPENCIES IN TECHNICAL SPECIFICATION REQUIREMENTS FOR ESF CHANNEL OPERABILITY Technical Specifications set forth the operability. requirements for engineered safety feature actuation (ESF) channels which specify actions which are to be taken when ESF channels are inoperable. For those plants which use the format of the current Standard Technical Specifications, the operability requirements are stated in terms of defined operating modes. Thus during some operating modes the operability requirements are not applicable. For older plants the operability requirements of ESF channels are determined based on the action statements imposed when the minimum operability requirements are not met.
Generally, the action is identified as either hot shutdown or cold shutdown.
When an operating bypass is provided which prevents the actuation of ESF systems, the Technical Specifications indicate the conditions under which the interlock or blocking action takes place. This.precludes a conflict with the operability requirements under conditions where the ESF channel is rendered inoperable due to an operating bypass. The failure to identify conditions under which safety actions are blocked by the operating bypass, is considered a violation of the operability requirements for that channel.
Thus, in order to preclude such conflicts, Technical Specifications should be explicit with regards to identifying the conditions under which operating bypasses will block ESF channels.
While current Standard.Technical Specifications identify operating bypasses, it has been found that some Westinghouse plants do not currently identify all operating bypasses under the operability requirements of ESF channels. This concern has been identified as multiplant action B-32. Therefore, a review was conducted of the operability requirements for ESF channels for all licensed Westinghouse plants. The channels which initiate safety injection on low pressurtzer pressure always include an operating bypass to permit plant shut down. The channels which sense steam line breaks and acutate safety injection and/or steam line isolation may or may not include a manually initiated operating bypass. In some cases the FSAR includes sufficient detail that identifies operating bypasses. In other cases, the use of the Standard Technical Specification format provides sufficient assurance that operating bypasses have been adequately addressed. Operating bypasses provided to block safety injection may or may not block steam line isolation where these safety actions are initiated by the same ESF channels. Since the FSAR's for many of the older plants do not address operating bypasses, this review could not confirm that the Technical Specifications relfect conditions under which ESF channels may be inoperable due to an operating bypass.
-2 During this review, a number of errors and other problems were identified in the Technical Specifications for some plants.
The plants identified in this review should be advised that the failure to identify conditions under which safety actions are blocked by an operating bypass is considered a violation of the Technical Specification operability requirements when those channels are blocked by an operating bypass. Licensees should be required to propose changes to their Technical Specifications if these problems exist. Also, for those plants for which other problems have been noted, they should take appropriate action to resolve the concerns identified.
The H. B. Robinson Steam Electric Plant Unit No. 2 has been found to have the following discrepancy:
Column 3 of Table 3.5-3 indicates the condition under which SAFETY INJECTION initiated on High Steam Flow in 2/3 Steam Lines Coincident with LOW T-avg or Low Steam Pressure may be blocked.
In Table 3.5-4, the same channels initiate STEAM LINE ISOLATION, however column 3 does not indicate any conditions for which this safety action may be bypassed. If STEAM LINE ISOLATION is blocked when SAFETY INJECTION is blocked, Table 3.5-4 should be revised to reflect the conditions under which the operability requirements are not applicable..