ML20054B675
| ML20054B675 | |
| Person / Time | |
|---|---|
| Site: | La Crosse File:Dairyland Power Cooperative icon.png |
| Issue date: | 04/14/1982 |
| From: | Crutchfield D Office of Nuclear Reactor Regulation |
| To: | Linder F DAIRYLAND POWER COOPERATIVE |
| Shared Package | |
| ML20054B676 | List: |
| References | |
| TASK-06-10.A, TASK-6-10.A, TASK-RR LSO5-82-04-039, LSO5-82-4-39, NUDOCS 8204190049 | |
| Download: ML20054B675 (2) | |
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April 14,1982 Docket No. 50-409
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Dear Mr. Linder:
SUBJECT:
SEP TOPIC VI-10.A. TESTING 0F REACTOR TRIP SYSTEM AND ENGINEERED SAFETY FEATURES, IllCLUDING TIME RESP 0ftSE TESTING - DRAFT SAFETY EVALUATION REPORT FOR LACROSSE
. is our contractor's draft technical evaluation of this topic for your plant. is the staff's draft safety evaluation re-port on this topic. Enclosure 2 is based on Enclosure 1.
The staff has concluded that the program for periodic surveillance and calibration of electrical instrumentation and controls required for the protection of the public health and safety may be inadequate at your plant.
You are requested to review the enclosures to this letter and to provide corrections of fact and confirm that your current test program which is not required by Technical Specifications, meets current licensing criteria or propese revisions to your test program where necessary. Your response is requested within 30 days of receipt of this letter.
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Sincerely, I f p 416 Dennis M. Crutchfield, Chief A D#~ */k 8204190049 820414 Operating Reactors Branch No. 5 6
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Enclosures:
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See next page
- See previous yellow for additional con y nces.
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s hocket No. 50-409 LS05 Mr. Frank Linder General Manager Dairyland Power Cooperative 2615 East Avenue South Lacrosse, Wisconsin 54601
Dear Mr. Linder:
SUBJECT:
SEP TOPIC VI-10. A, TESTING 0F REACTOR TRIP SYSTEM AND ENGINEERED SAFETY FEATURES, INCLUDING TIME RESPONSE TESTING - DRAFT SAFETY EVALUATION REPORT FOR LACROSSE is our contractor's draft technical evaluation of this topic for your plant. is the staff's draft safety evaluation re-port on this topic. is based on Enclosure 1.
The staff has concluded that the program for periodic surveillance and calibration of electrical instrumentation and controls required for the protection of the public health and safety is inadequate at your plant.
Because of the scope and severity of this problem, the staff does not consider it prudent to defer the resolution of our concerns until the integrated assessment of your plant.
Therefore, you are requested to review the enclosures to this letter and to provide corrections of fact and a proposal for a suitable test program with the exception of response time testing, within 30 days of receipt of this letter. The response time testing program may be delayed until the integrated assess-ment.
Sincerely, Dennis M. Crutchfield, Chief Operating Reactors Branch No. 5 Division of Licensing
Enclosures:
As stated cc w/ enclosures:
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9 Mr. F.ank Linder cc Fritz Schubert, Esquire U. S. Environmental Protection Staff Attorney Agency Dairyland Power Cooperative Federal Activities Branch 2615 East Avenue South Region V Office La Crosse, Wisconsin 54601 ATTN: Regional Radiation Representative 230 South Dearborn Street O. S. Heistand, Jr., Esquire Chicago, Illinois 60604 Morgan, Lewis & Bockius 1800 M Street, N. W.
Mr. John H. Buck Washington, D. C.
20036 Atomic Safety and Licensing Appeal Board U. S. Nuclear Regulatory Commission Mr. R. E. Shimshak Washington, D. C.
20555 La Crosse Boi. ling Water Reactor Dairyland Power Cooperative Dr. Lawrence R. Quarles P. O. Box 135 Kendal at Longwood, Apt. 51 Genoa, Wisconsin 54632 Kenneth Square, Pennsylvania 19348 Ms. Anne K. Morse Charles Bechhoefer, Esq., Chairman Coulee Region Energy Coalition Atomic Safety and Licensing Board P. O. Box 1583 U. S. Nuclear Regulatory Commission La Crosse, Wisconsin 54601 Washington, D. C.
20555
- La Crosse Public Library Dr. George C. Anderson 800 Main Street Department of Oceanography La Crosse, Wisconsin 54601 University of Washington Seattle, Washington 98195 U. S. Nuclear Regulatory Commission Resident Inspectors Office Mr. Ralph S. Decker Rural Route #1, Box 276 Route 4, Box 190D
. Genoa, Wisconsin 54632 Cambridge, Maryland 21613 Town Chairman Thomas S. Moore Town of Genoa Atomic Safety and Licensing Appeal Board Route 1 U. S. Nuclear Regulatory Commission Genoa, Wisconsin 54632 Washington, D. C.
20555 Chairman, Public Service Commission Mr. George R. Nygaard of Wisconsin Coulee Region Energy Coalition Hill Farms State Office Building 2307 East Avenue Madison, Wisconsin 53702 Lacrosse, Wisconsin 54601 Alan S. Rosenthal, Esq., Chairman James G. Keppler, Regional Administrator Atomic Safety and Licensing Appeal Board Nuclear Regulatory Commission, Region III U. S. Nuclear Regulatory Commission 799 P.oosevelt Road Washington, D. C.
20555 Glen Ellyn, Illinois 60137 Mr. Frederick Milton Olsen, III 609 North lith Street Lacrosse, Wisconsin 54601 i
SYSTEMATION EVALUATION PROGRAM TOPIC VI-10. A LACROSSE TOPIC:
VI-10. A, Testing of Reactor Trip System and Engineered Safety Features, Including Response Time Testing I.
INTRODUCTION The purpose of this topic 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 times should not exceed those assumed in the plant accident analyses. Accordingly, the test program of the RTS and ESF was reviewed in accordance with the Standard Review Plan, including applicable Branch Technical Positions.
II.
REVIEW CRITERIA The review criteria are presented in Section 2 of EG&G Report 0630J,
" Testing of Reactor Trip System and Engineered Safety Features."
III.
RELATED SAFETY TOPICS AND INTERFACES Topic VI-7. A.3 discusses the question of testing protection systems under conditions as close to design condition as practical. There are not topics that are dependent on the present topic information for their completion.
IV.
REVIEW GUIDELINES Review guidelines are presented in Section 3 of Report 0630J.
V.
EVALUATION The Lacrosse design is evaluated against the review criteria in Section 3.2 and 4.2 of the report. The identified differences from current review criteria are as follows:
1.
Channel Calibration at least once per refueling outage (18 months) for the Intermediate Range Neutron Flux High, the Main Steam Line Isolation Valve-Closure, and the Turbine Stop Valve-Closure is not performed. The Lacrosse Technical Specifications (pages 45, 46 and
- 47) do not require channel calibration for these three parameters.
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r Operating experience at other facilities has shown that the setpoints of bistables and limit switches drift with time.
Experience has also shown that neutron detector characteristics change with exposure.
The turbine stop valve closure signal feeds the half scram logic, but not the full scram logic.
Because no safety credit is taken for the half scram, calibration of the half scram inputs is not required.
2.
The Lacrosse Technical Specifications include in the RPS the Main Condenser Vacuum Low, the Control Rod Drive Accumulators, the Bus Voltages, the Reactor Scram Relays, and the Automatic Scram Logic parameters.
There is no channel check performed on these parameters.
Indications derived from independent instrument channels measuring the same parameters are not available. Accordingly, channel checks of the identified parameters are not required.
3.
The Lacrosse Technical Specifications do not require a channel calibration for the following parameters:
Wide Range and Power Range (channels 5, 6, 7, and 8)
Control Rod Drive Accumulators Bus Voltages Reactor Scram Relays Automatic Scram Logic Neutron detector characteristics are known to change with exposure.
The licensee checks these instruments by a monthly heat balance.
The staff has no details of the heat balance procedure used, and, therefore, cannot conclude that this check can serve as a calibration.
An example of a shortcut in doing a heat balance that can affect the accuracy is to assume a feedwater temperature (as is done in the automatic gain adjustment equipment) without regard to the number of feedwater heaters inservice.
The failure to calibrate this equipment does not meet the requirements of IEEE Std. 279-1971.
The control rod drive accumulator pressure and level sensors provide partial scram inputs only.
Therefore, they are not required for safety and need not be calibrated.
Bus voltage monitors for the 2400 v bus provide signals to both partial and full scram logic. Monitors for the 480 v buses provide full scram inputs.
The failure to calibrate this equipment does not meet the requirements of IEEE Std. 279-1971.
A calibration is not required for the scram relays and the logic because they are not adjustible.
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For each parameter that is not tested during reactor operation, the licensee should provide the information specified in Position D.4 of R.G. 1.22.
For example it does not appear that the condenser vacuum switches can be tested during operation because the switches share a coninon line and all of them would have to be isolated from the condenser and bypassed electrically during testing.
A second example is the bus voltage monitors. These devices historically
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have a low drift rate and are connected to high voltage circuits.
They must be electrically removed from their normal circuits and bypassed to test and this testing can be accomplished when the plant is shutdown.
Similar arguments can be made for the main steamline limit switches and containment pressure indicators.
5.
There are not requirements established in the Lacrosse Technical Specifica-tions for response times for those systems comprising the RPS.
Response
time is a design basis for instrumentation.
Response time testing is required by IEEE Std. 279-1971.
6.
During each reactor shutdown for major refueling or an interval not greater than one year, the valves for the Containment Isolation System are tested to demonstrate their operability.
The Containment Isolation System utilizes the Low Reactor Vessel Water Level parameter, High Con-tainment Building Internal Pressure, High Containment Radiation Monitor, Low Steam Line Pressure, and Low Vacuum, and the High Reactor Pressure parameters.
A daily channel check and periodic channel calibration should be conducted in addition to the channel functional test.
The channel functional tests should also be conducted periodically.
The frequency for calibration functional testing, and channel checks should be established in accordance with Section 6.5 and documented in accordance with Section 6.1 of IEEE Std. 338-1975.
The High Containment Building Internal Pressure is periodically subjected to a channel calibration, but not subjected to a functional test or channel check.
The Low Steam Line Pressure parameter is not subjected to periodic channel checks or channel functional testing. These signals are also used to initiate the Low Pressure Coolant Injection System, the High Pressure Core Spray System, and the Shutdown Condenser System.
All of these instruments are periodically calibrated to satisfy the requirements of IEEE Std. 279-1971 and GDC 21 because they are required for safety.
In addition, periodic functional test and channel checks should be performed.
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{ y VI.
CONCLUSION It is the staff's position that the design of systems which are required for safety shall include provisions for periodic verification that the minimum performance of instruments and control is not less than that which is assumed in the safety analyses.
The bases for this position are General Design Criterion 21, Section 3.9 of IEEE Std. 279-1971, and IEEE Std. 338-1971.
Therefore, the licensee should implement a program for testing and calibrating all reactor protection systems (including engi-neered safety features systems such as containment isolation). As a part of this program, the response time test requirements should be stated in the Technical Specifications in a manner similar to that of the Standard Technical Specifications.
In addition, test and calibration frequencies similar to that of the Standard Technical Specifications should be used unless some other frequency can be established on a well defined technical base.
The staff proposes that the following corrections be made to existing programs by making suitable changes in the Lacrosse test procedures and Technical Specifications:
1.
The licensee should provide for periodic calibration of the following channels:
a.
Intermediate Range Neutron Flux, b.
Main Steam Line Isolation Valve Closure, Wide Range and Power Range (channels 5, 6, 7, and 8), and c.
d.
Bus Voltages.
2.
The licensee should provide a basis, as outlined in Regulatory Guide 1.22, for each calibration or test that cannot be conducted during normal operation except for the parameters evaluated in this report.
3.
The licensee should develop a response time testing program for all reactor protection systems.
l 4.
The licensee should provide the basis for calibrating, testing and checking protection equipment less frequently than the recommendations of the standard Technical Specifications.
5.
The licensee should establish a requirement for periodic channel checks and functional tests of High Containment Building Internal Pressure and Low Steam Line Pressure.
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