ML20010C897

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Forwards Safety Evaluation for SEP Topic VI-10.A Re Testing of Reactor Trip Sys & ESF Including Response Time Testing. Licensee Should Implement Program for Response Time Testing of All Reactor Protection Sys
ML20010C897
Person / Time
Site: Oyster Creek
Issue date: 08/18/1981
From: Crutchfield D
Office of Nuclear Reactor Regulation
To: Finfrock I
JERSEY CENTRAL POWER & LIGHT CO.
References
TASK-06-10.A, TASK-6-10.A, TASK-RR LSO5-81-08-035, LSO5-81-8-35, NUDOCS 8108210185
Download: ML20010C897 (4)


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August 18, 1981 Docket No. 50-219

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LS05-81-08-035 j

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Mr. I. R. Finfrock, Jr.

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'*c #m Vice President - Jersey Central V

Power & Light Company

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Post Office Box 388 95

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Forked River, flew Jersey 08731

Dear Mr. Finfrock:

"UBJECT: SEP TOPIC VI-10.A. TESTING 0F Rr. ACTOR TRIP SYSTEM AND ENGIllEERED SAFETY FEATURES, IllCLUDI!!G RESP 0fiSE TIME TESTING, SAFETY EVALUA-TION FOR OYSTER CREEK The ca. closed staff safety evaluation is based on a contractor document that has been made available to you previously. This evaluation supports the findings of the staff safety evaluation of Topic VI-10. A and proposes mod-ifications to the Technical Specifications and some equipment to implement a response time testing program.

The need to actually irnplement these changes will be determined during the integrated safety assessment. This topic assessment nay be revised in the future if your facility design is changed or if NRC criteria relating to this topic are modified before the integrated assessment is completed.

Sincerely, Detais M. Crutchfield, Chief Operating Reactors Branch ro. 5 Division of Licensing 3 C)T 6

Enclor"re:

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0 Mr. I. R. Fi nf rock, J r.

Cc G. F. Trowbridge, Esquire Gene Fisher Shaw, Pittman, Potts and Trowbridge Bureau Chief 1800 ti Street, N. W.

Bureau of Radiation Protection Washington, D. C.

20036 380 Scotts Road Trenton, New Jersey 08628 J. B. Lieberman, Esquire Berlack Israels & Liebermm Comissioner 26 Broadway New Jersey Department of Energy New York, New York 10004 101 Comerce Street Newark, New Jersey 07102 Natural Resources Defense Council 91715th Street, N. W.

Licensing Supervisor Washington, D. C.

20006 Oyster Creek Nuclear Generating Station J. Knubel P. O. Box 388 08731

/, Forked River, New Jersey BWR Licensing Manager Jersey Central Power & Light Co@any Madison Aver.ue at Punch Bowl Rc,ad Resident Inspector Morri town, Ne ' Jerse, 07960 c/o U. S. NRC P. O. Box 445 Joseph W. Fe.rraro, Jr., Esquire Forked River, New Jersey

  • 08731 Deputy Attorney General.

State of New Jersey Department of Law and Public Safety 1100 Rayn,und Boulevard Newark, New Jersey 07012 Ocean County Library Brick Town 3 hip branch 401 Chambers Bridge Road Brick Town, New Jersey 08723 Mayor Lacey Township P. O. Box 475 Forked River, New Jersey 08731 Cortnissioner Dcpartment of Public Utilities State of New Jersey 101 Comerce Street Newark, New Jersey 07102 U. S. Environmer:tal Protection Agency Region IT Office ATTN. EIS COORDINATOR 26 Fecaral Plaza New York, New York 10007

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l TOPIC VI-10.A, TESTING OF REACTOR TRIP dYSTEf1 AND ENGINEERED SAFETY FEATURES, INCLUDING RESPONSE TIME TESTING i

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INTRODUCTION The purpose of this T;pic is to review the reactor trip system (RTS) and engineered safety features (ESF) test program for verification of RTS and ESF operability on a periodic basis and to verify RTS and ESF response time in order to assure the operability of the RTS and ESF.

Response

i times should not exceed those assumed in the plant accident analyses.

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Accordingly, the test program of the RTS and ESF was reviewed in accord-j ance with the Standard Review Plan, including applicable Branch Technical j

Positions.

II.

REVIEW CRITERIA The review criteria are presented in Section 2 of EG&G Report 0382J, 1

" Testing of Reactor Trip System and Engineered Safety Features, Including j

Resoonse Time Testing".

l III.

RELATED SAFETY TOPICS AND INTERFACES Topics VI-7. A.3 discusses the question of testing protection systems under conditions as close to design condition as practical.

There are no topics j

that are dependent on the present topic information for their completion.

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j IV., REVIEW GUIDELINES Review guidelines are presented in Sections 3 & 4 of Report 0382J.

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V.

EVALUATION The Oyster Creek Technical Specification surveillance requirements (Table 4.1.1) do not identify the instrument (channel) for each safety system.

Therefore, it is possible that no (or incomplete) surveillance could be performed on sensors and/or logic channels for some safety systems, j

To be more specific, as discussed in Section 3 of Report 0382J:

1 The plant Technical Specifications do not require a test of the' reactor mode switch and some instruments are not specifically identified for RTS system testing.

Although required in Toble 4.1.2, no dual channel (scram) test is performed by Oyster Creek.

(Operation:1 problems prevent this test during reactor operation.)

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The plant Technical Specifications do not requ'.re periodic system response-time measurements (as assumed in FSAR) from sensor to actuated equipment.

VI.

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-CONLLUSION 1

It is the staff's position that the design of systems which are re-i quired for safety shall include provisions for periodic verification i

I that the minimum performance of instruments and control is not less j

than that which was assumed in the safety analyses.

The bases for this position are General Design Criterion 21, Section 3.9 of IEEE l

Std. 279-1971, and IEEE Std. 338-1977.

Therefore, the licensee should implement a program for response time testin of all reactor protection systems (including engineered safety features systems such as cantainment isolation).

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Futhermore, the staff proposes that Table 4.1.1 of the Technical Specifications be modified such that each instrument and logic path is specified. The basis for this requirement is to reduce the likely-l hood that a device required to protect the public heath and safety will be misssed during the periodic surveillance program, i

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