ML20029B400

Grants Temporary Waiver of Compliance Re Reactor Trip Sys, Per 910228 Request

ML20029B400
Person / Time
Site:	Haddam Neck File:Connecticut Yankee Atomic Power Co icon.png
Issue date:	03/01/1991
From:	Greenman E Office of Nuclear Reactor Regulation
To:	Mroczka E CONNECTICUT YANKEE ATOMIC POWER CO.
References
GL-83-28, NUDOCS 9103070209
Download: ML20029B400 (5)

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March 1, 1991 Docke+. Nc. 50-213 Mrv Edward J. Mroczb Senior Vice President Nucicar Engineering and Operations Connecticut Yankee Atomic Power Comp 3ny Northeast Nuclear Energy Company P.-0. Box 270 Hartford, Connecticut 06141-0270

SUBJECT:

- HADDAM HECK PLANT - NRR TEW ORARY UAIVER OF COMPLTANCE RELATED TO.THE REACTOR TRIP SYSTEM

-By letter dated February 28, 1991, Connecticut-Yankee Atomic Power Company (CYAPCO), on behalf of the Haddam Neck _ Plant, requested a Temporary Waiver of 5

. Compliance and an emergency amendment to Operating License No. DPR-61. The.

waiver would allow the plant to continue to operate until the emergency amendment is issued. On Wednesday, february 27,1991, at 10:00 am,- CYAPC0 determined that Surveillance Requirement 4.3.1. Table 4.3-1, item-16, " Reactor strip System Breakers," had not been performed as required by the Technical

Specifications (TS)'during three plant startups since the last time the

-surveillance had been performed on July 23, 1990. CYAPC0 has stated the

design of;the reactor trip system is such that performance of the surveillance

' test would result in a reactor shutdown. The waiver and amendment are necessary

.because Technical Specification 4.0.3 requires that-failure to perform Surveillance Requirement 4.3.1 within the allowed surveillance-interval

-constitutes a noncompliance with the operability requirements-for a Limiting Condition for Operation of the reactor trip system and would require the plant to.be in' hot standby =within 6 hours6.944444e-5 days <br />0.00167 hours <br />9.920635e-6 weeks <br />2.283e-6 months <br />.

During review of'the Haddam Neck Plant's Technical Specification Surveillance Database' Tracking System, CYAPC0 discovered-a'n error = in' the database.

Procedure-HOP 2.1-2, " Reactor Startup" was referenced as implementing TS Table 4.3-1, Item-16 " Reactor Trip System Breakers." CYAPC0 has determined that Lthis procedure-specifies that the trip breakers be cycled by manually tripping

the reactor and does not explicitly verify the ] roper actuation-of the shunt trip and undervoltage trip devices as required by Surveillance-Requirement

-4.3.1.

CYAPC0 reviewed its plant procedures and determined that procedure SUR 5.5-50, "72-SCRAM-A, B,--Trip Acteating Device Test of Reactor Trip Breakers" does address this requirement. However, while this procedure does specify this requirement every startup it allows a minimum of 6 months between test and plant startup. -While_the previous TSs had no requirement for this i

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Mr. Edward J. Mroczka March 1,1991 surveillance, procedure SUR 5.5-60 was implemented in response to Generic letter 83-20 to assure RTB reliability. With the_ implementation of the upgraded TS, Surveillence Requirement 4.3.1 requires that this surveillanca be perforned not more than 31 days prior to each plant :tartup.

This surveillance was last performed on July 23, 1990.

This surveillance was not performed prior to the startups on September 3, September 15, and November 14, 1990.

The reactor trip breakers (RTB) at the Haddam Meck Plant are Westinghouse 08-50 and have been very reliable.

The licensee has stated there have been no failures of the undervoltage and shunt trip elements of these breakers over the 19 years of plant operation.

As noted above the RTBs are tested at a minimum each refueling outage. The surveillance test procedures verify that shunt and undervoltage elements operate independently to trip. The vendor performs maintenance on the breakers each refueling.

In addition, CYAPC0 is testing the Ribs in accordance with the preventative maintenance and surveillance programs detailed in and corriitted to in their response to Generic Letter (GL) 83-28.

CYAPC0 also stated in a conference call on February 28, 1991, that based on their reviews of the response time test of the RTBs there was no discernable trend.

The RTBs were last tested July-23, 1990, approximately 7 months ago. The plant has had several lono uninterrupted operating cycles (e.g. two of which were longer than' 400 days) with no test or maintenance of RTBs. As stated-

- above even with these long intervals between test and maintenance, there have been no failures.

Prior to each startup including the three referenced above, the. reactor trip breakers are partially tested. Just prior to the control rods being fully inserted, the operators press-the reactor trip " push buttons" on the main control board to verify that the RTBs open successfully.

This provides some additional assurance that the RTBs are operable and would trip if called c

upon to perform their safety function.

The NRC acknowledges-that implementation of the new-TS was an extensive

= effort. We believe that the requirements in TS 4.3.1, Item 16 are clearly -

stated. Further,- while your application was submitted prior to the expiration of 24. hour LCO, lead-time for_NRC review-and evaluation was minimal.

Because of the excellent operating experience of the'RTBs at Haddam Neck Plant and the existence of preventative-maintenance and-surveillance programs for the RTBs based on GL 83-28, the staff concludes no compensatory measures are required.

The staff has-also concluded that the additional assurance of _ RTR operability provided by these missed surveillances does not warrant a plant shutdown.

Based on our review of CYAPCO's request and justification provided by letter dated-February 28, 1991, and its commitment to provide the results of the next RTB test and any_-trends that may appear, we conclude that the operation of the Haddam Neck Plant in;conformance with TS Table 4.3-1,-Item 16 as amended by y y y

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o Mr. Edward J. Mroczka 3-liarch 1,1991 this request provides an acceptable level of safety and does not present any undue risk to the health and safety of the public.

This letter confirms our oral response of February 28, 1991, to your request and grants a temporary waiver of coropliance with the cited TS requirements end will be in effect while we temp 19te the processing of an emergency license amendment.

Sincerely, Original signed by Edward G. Greerman, Acting Assistant Director for Region 1 Reactors Division of Reactor Projects. 1/11 Office of Nuclear Reactor Regulation cc:

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Mr. Edward J. Mroczka Connecticut Yankee Atomic Power Company Haddam Neck Plant cc:

Gerald Garfield, Esquire R. M. Kacich, Manager Day, Berry and Howard Generation Facilities _ Licensing Counselors at Law:

Northeast Utilities Service Company City Place t Office Box 270 Hartford, Connecticut 06103-3499 etford,-Connecticut 06141-0270 1

' W.- D. Romberg, Vice President D. O. Nordquist Nuclear Operations Director of Quality Services Northeast Utilities Service Company Northeast Utilities Service Company Post Office Box 270

-Hartford, Connecticut.

Post Office Box 270 06141-0270 Hartford, Connecticut 06141-0270-Kevin McCarthy,_ Director-Regional Administrator Radiation Control Unit.

Re Department of Environmental Protection U.gion I S. Nuclear Regulatory Commission State Office' Building 475 Allendale Road Hartford. Connecticut = 06106 King of Prussia, Pennsylvania 19406 Bradford S. Chase, Under Secretary Board of. Selectmen Energy Division Town Hall-

=0ffice of Policy and Management Haddam, Connecticut 06103 80 Washington Street Hartford, Connecticut 06106 J. T. Shediosky, Resident Inspector Haddam Neck Plant

' J. P. Stetz, Nuclear Station Director c/o-U. S. Nuclear-Regulatory Commission

.Haddam Neck Plant'

- Post Office Box 116

~ Connecticut Yankee Atomic Power Company East Haddam Post Office-RFD 1,' Post Office Box 127E-East Haddam.. Connecticut 06423 East Hampton, Connecticut 06424 G.: H.- Bouchard Nuclear-Unit Director iHaddam Neck Plant Connecticut -Yankee _ Atomic Power Company RFD 1, Post Office Box 127E East -Hampton, Connecticut 06424

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