ML20099B652
| ML20099B652 | |
| Person / Time | |
|---|---|
| Site: | Seabrook  |
| Issue date: | 07/30/1992 |
| From: | Feigenbaum T NORTH ATLANTIC ENERGY SERVICE CORP. (NAESCO) |
| To: | Martin T NRC OFFICE OF INSPECTION & ENFORCEMENT (IE REGION I) |
| References | |
| NYN-92103, NUDOCS 9208030005 | |
| Download: ML20099B652 (8) | |
Text
e eah o k NH 03874 Telephone (603) 474-9521 k.
j[hhffh Facsimile (603)474 2987 1
'irmrgy Service Corporation Ted C. Feigenbaum M
,1 Senior Vice President and S
Q f..4 Chief Nuclear Officer m
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NYN-92103 E
"5 J uly 30,1992 Regional Administrator S. Nuclear R gulatory Commissi in ni 3,
llendale koad
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of Prussia, FA 19406 i
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t er : ion:
Mr. Thomas T. Martin Facility Operating License No. NPF-86, Docket No. 50 443 rence:
Susject:
Request Icr Temporary Waiver of Compliance; hianual Reactor Trip TADOT
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men-dorth Atlantic Energy Service Corporation (North Atlantic) requests a temporary f
r of compliance from the provisions of Seabrook Station Technical Specification W'
durveillsoce Requirement 4.3.1.1 as it pertains to the performance of the Trip Actuating
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Devise Operational Test (TADOT) for the Manual Reactor Trip function (See Technical h-Speci ication Table 4.3-1, Functional Unit 1, Manual Reau,or Trip). The North Atlantic Indeper. der :
fet-r agineering Group (ISEG) made a preliminary determination on July 28, 1"2, throup a -;luation of an INPO Nuclear Network summary of an operational event c another facility, that the 18 month surveil'.ance testing program for the kcactor Trip ucakers and Reacur Trip Bypass Breakers may _not have adequately tested one asptet of J
these breakc s ' rip circuitry pursuant to Surveillance Requirement 4.3.1.1. The ISEG notil:cil plant management of ILis preliminary determination. Plant management initiated an extenske review of test procedures and related testing associated with the.eactor trip breakers.
On July 29, 1992, at 8:45 AM, it was detecnined that the 18 month surveillance testing program war insdequate. This testing program inadequacy notwithcta-ding, North Atlantic has determined that based on extensive surveillance and preoperational testing, and based on the diverse trip fcatures (undervoltage and shun-trip attachment), the Reactor Trip Breakers and Reac'ar Trip Bypass Breakers are fully functional and capable of opening the breakers in response to a Main Control Board manual trip actuation or manual safety injection actuation.
The testing inahquacy for the Manual Reactor Trip function TADO T,,os discussed by No.rh Atlantic repre.entative. (Messrs DiProfio. Harpster, Drawbridge, et. al.) wito NRC Region I and NRC Office ot' Nuclear Reacter Regulation representatives (Messrs. Linville, Lazarus, Oudley, Calvo, Nerses, et. al.) on July 29. 1992 in a conference call from the
. Resident incpectors office.
During this conference call, N_rth Atlantic requested verbal au borization for a temporary waiver of compliance from Technica' Specification Surveillance Rcquirement 4.3.1.1, Table 4.3-1, Functional Unit I as it pertains to the Manual Reactor Trip Function TADOT. Tie NRC was informed that the Manual Reactor Trip function had been declared inoperable a.' of 8:45 AM EE T, accordingly Technical Specification 3.0.3 had been
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r United States Nuclear Reg :latory Commission J ul - 30 IW2 Alt e ntion:
Mr. Thomas T. Martin
" age two entered and preparations for a shutdown had commenced.
The NkC authorized the temporary waiver of compliance at 9:42 AM EDT and directed that the written request be roubmitted by July 31, 1992.
Ascription of Conditions:
Seabrook Station Technical S pe cific atio '. Surveillance Re wire ment 4.3.1.1 Table 4.3-1, Functional Unit 1 (Manual Reactor Trip) rt';Wes a TADi an the Manual Reactor Trip function which is to be performed each refueling outage. The.Janual Reactor Trip TAtXA is subject to Table Notation 13 which requires the following:
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"The TRIP ACTUATING DEVICE OPERATIONAL TEST shall independently verify the OPERABILITY of the undervoltage and shunt trip circuits for the Manual Reactor Trip !%c:in The test shall also verify the OPERABILITY of the Bypass Breaker trip circuits."
The current surveillance procedure utilized by North Atlantic for the Manual Reac:or Trip function TADOT (Procedure Number OX1410.04 Post Refueling Pre Startup Reactor Trip Dreaker Surveillance) does not adequately verify that the Reactor Trip Breakers and Reactor Trip Bypass Breakers have electric continuity between the shunt trip coil and manual reactor trip switches located on the Main Control Board Proccdure OX1410.04 requires verification that.the proper voltage is applied to the shunt trip coilt when the Main Control Board manual reactor trip and manual rafety injection switches are actuated, however the procedure does not consider that the proper voltage ma-be pmsent due to the existence of a voltage path thru the Main Control Board indicating lights to the : 2unt trip coil. North Atlantic vcill revise " meedure OX1410.04 to aquire removal of the indicating lights during performance of the thunt trip coil voltage measurement to ensure a proper test of the shunt trip Circ.h.
P eouest for Tempora v Waiver of Compliance:
North A.tlantic is providing the justification below which demonstrates that :ontinued 3
operition during the duration of the requested waiver is consistent with protecting the health and rafety of the oublic.
1)
Reauirements for Which a Waiver is Reonested:
North Atlantic requests a w aive r from the requirements of Technical Specification Surveillance Requirement 4.3.1.1, Table 4.3-1 Functional Unit 1, Manual Reactor Trip, Table N.otation 13. As discussed above, North Atlantic has not tested one aspect of the Manual Reactor Trip function during its 18 month surveillance testing program for the Reactor Trip Breakers and Reactor Trip Bypass Breakers and therefore has not fully complied with the intent of Table Notation 13.
In particular, the TADOT for the Manual Reactor Trip function, does not adequately test the shunt trip circuit continuity from the Main Control Board manual reactor trip switches to the s'unt trip cei!.
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' United. States Nuclear Regulatory Commission-
-July 30, _1992 Attention:
Mr. Thomas T. Martin Page threc 2)~
Xircumstances of the Situation and Need for Prompt Action:
On July 28,1992 the North Atlantic Independent Safety Engineering Group ' identified a
. potential testing inadequacy for the reactor trip breakers and reactor trip bypass breakers._
This-potential testing inadequacy war discovered as a result of _ a evaluation of an INPO_'
Nuclear Network summary of an operational event at another facility. Station management was _ apprised of the issue and directed that a thorough review of reactor trip breaker -
procedures be conducted expediently. On July 29,1992 at 8:45 AM it was concluded that the 1! rip-breaker testing was not performed in compliance with all aspects of the_ Technical Specifications; North Atlaritic has evaluated the potential to perform the proper testing of the shunt trip circuit. Due to the complexity of the testing involved. North Atlantic feels that it would be imprudent to conduct such a complex test procedure with its attendant trip potential.
3)
Comnensatory Action:
North Atlantic Operations Department management will brief each operating crew prior to their coming on shift. The briefing will discuss the testing inadequacy and actions to take
'In the event that^ a manurl reactor trip actuation or manual safety injection actuation is necessary and does not initiate the reactor trip.
Nosth Af' antic emergency operating
. procedures provide for the following actions in the event that the reactor trip breakers do not _open when demanded:
- 1. manual inserting rod insertion,
- 2. initiation of an emergency boration, and-
. 3 local: opening of the~ reactor trip breakers and de-energization of the motor generator sets, 4))
A d dition al _ _A ct ion s -
. The current surveillance procedure utilized by North Atlantic for the Manual Reactor Trip.
function TADOT (Procedure Number OX1410.04 Post __ Refueling Pre Startup Reactor Trip
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- Breaker Surveillance) is_ inadequate with respect to the testing:of the shunt trip circuit' from the Main _ Control Board manual reactor trip switch and manual safety injection switch to the shunt trip - coil. - Procedure - OX1410.04.. does however - fully and independently - test - the
- undervoltage trip. feature of tl'c Reactor Trip Breakers arid Reactor Trip Bypass _ Breakers-from the Main Control Board manual reactor trip switches.
Procedure - OX1410.04 that -
independernly tests the shunt. trip feature of the Reactor Trip Breakers and Reactor Trip -
Hypass Breakers will be revised to ensure a full test of the sht,it trip _ circuit from the Main Control 'loard manual reactor trip switch and manual safety injei tion switch to the shunt trip
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4 United States Nuclear Regulatory Commission July 30,1992 Attention:
Mr. Thomas T. Martin Page four North Atlantic notes that Technical Specification Surveillance Requirement 4.3.1.1, Table 4.31, Functional Unit 17, Safety injection input From ESF, does not require independent verification of OPERABILITY of the shunt trip and undervoltage trip circuitry.
110w e ve r, procedure OX1410.04 will be revised to provide a full and independent test of the shunt trip and undervoltage trip circuitry associated with the manual safety injection switch.
5)
Evaluation of the Safety Sienificance:
This testing program inadequacy notivithstanding, North Atlantic ha= determined that based on extensive surveillance and preoperational testing, and based on the diverse trip features
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(undervoltage and shunt trip attachment), the Reetor Trip Breakers and Reactor Trip Bypass Breakers are fully functional and capable of opening the breakers in response to a M ain Control Board nianual trip actuation or manual safety injection actuation.
An evaluation of the safety significance of the shunt trip circuit testing inadequacy is provided in Enclosure 1.
6) hion of Reauested Waiver:
The duration of the requested waiver is until second refueling outage, which is currently scheduled to begin on September 7, 1992.
During the upcEng refueling outage, the applicable provisions ? Technical Specification Surveillance R *;uirement 4.3.1.1 will be fully performed, including tu Manual Reactor Trip TADOT. Should Seabrook Station experience a planned or unplanned shutdown reqtiiring an entry into MODE 3 or lower prior to the refueling outage, the Manual Reactor Trip TADOT will be completed prior to plant restart.
7)
Basis for No Sienificant Hara ds:
This testing program inadequacy notwithstanding, North Atlantic has determined that based on extensive surveillance and preoperational testing, and based on the diverse trip features
.dervoltage and shunt trip attachment), the Reactor Trip Breakers and Reactor Trip s
Bypass Breakers are fully functional and capable of opening the breaker: in response to a Main Control Board mr.nual trip actuation or manual safety it.jection actuation.
j A No Significant liazards Consideration Determination for the requested waiver is provided
^
in Enclosure 1.
8)
Environmental Consecuences:
The requested waiver involves no environmental consequences. The Reactor Trip Breakers and Reactor Trip Bypass Breakers are fully functional and capable of opening the breakers or manual safety injection in response to a Main Control Board manual trip actuation actuation.
Therefore the testing inadequacy does not impact accident analyses or the associated radiological consequences nor does it impact systems associated with the control of radiological or non-radiological effluents.
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United, States Nuclear. Regulatory Commission July 30,1992
- At t e ntior.:
L Mr.LThomas T.: Martin Page five Should you: have any further questions regarding this request for a temporary waiver of
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' compliance, please contact Mr. Terry L. Harpster, Director of Licensing Services at (603).
474 ."21 extension 2765.
Very truly yours, g Q,/
, y.,.. k ;
Ted C. Feigenbaum TCP: A LL/act
- Enclosure.
j cc:
Docurnent Control Desk
. United States Nuclear Regulatory Commission Washington, D.C.
20555 Mr.' William Lazarus l
RPS 3D Chief -
U.S.. Nuclear' Regulatory. Commission -
Region !
~475 Allendale. Road King. of Prussia, PA 19406 1
Mr Gordon IL Edison, Sr. Project Manager l-Project. Directorate I 3 Division-of Reactor Projects -
I U.S.-Nucicar' Regulatory Commission q.y
' Washington, DC '-'20555 Mr? Noel Dudicy
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NRC Senior Resident Inspector.
-P.0,1Dex 1149 Seabrook, NH 03574 y
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e J uly' 30, 1992
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=4 EVALUATION OF SAFETY SIGNIFICANCE AND NO' SIGNIFICANT HAZARDS CONSIDERATION FOR REOUESTED WAIVFR OF COMPLIANCE
~ EVAL.U ATION OF S AFETY SIGNIFICANCE North Atlantic bas determined that'there is no significant safety impact associated with the temporary waiv:r of compliance from the requirements of Technical Specification Surveillance Requirement 4.3.1.1 Table 4,31, Functional Unit 1, Manual Reactor Trip. Although the surveillance test did not adequately test one-aspect of the manual reactor trip function, there is no reason to believe that any element of the manual trip function is not functional.
North' Atlantic believes that based on the preoperational and surveillance testing performed, that the manual reactor trip fu :ction is fully functional and capable of performing its design function if called upon to do so.
The ' reactor trip system possesses several diverse and independent features which enable it to' shutdown the reactor on demand. The operation of any of these features demor strates that the reactor protection system is capable of performing its safety function. Therefore, given that surveillance tests performed on the reactor. trip system did not adequately test one
- aspect of the system, the reactor protection system still posse,ses sufficient diverse and independent. features to enable it to perform its design function.
The surveillance testing performed on the reactor trip br ~akers ad the reactor trip bypass breakers was inadequate in that the capability of the manual reactor trip switches, located on the : main control board, to actuate the shunt trip coil was not positively verified.
However, the procedure does verify the capability of the manual reactor trip switches to trip the reactor via actuation of the undervoltage relay. The procedure also verifies that the
-sh u nt trip coil _will actuate to trip-the reactor trip breakers and the reactor trip bypass l-breakers.
l l-It is important to note that the only _ feature which has not been adequately tested is the capability to initiate a manual reactor trip via the shunt trip coil. The ability of the Reactor
--Solid State Protection System (SSPS) to initiate a reactor trip via the undervoltage coil and
. indirectly energize the shunt trip coil has been verified. ' Should a reactor trip be required this is the_ portion of_ the reactor trip system which would likely function to open the_ reactor
' trip breakers. It is.unlikely that t manual reactor trip would be requised. Ir the unlikely event that the operator was requited to initiate a manual reactor trip and the signal did not reach the shunt; trip coil, the de energization of the. undervoltage relay would cause the reacter. trip breakers _to open. Additionally, when the undervoltage relay ic de-energized, the shunt trip.B coil is also de energized. This action closes o contact which will energire-the shunt trip coil an'd open the reactor 'op breakers.
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- Thereforefthe reactor-_ trip system will continue to function as designed with no adverse impact -as a result of the delay in performing the TADOT on the reactor trip breakers,
- Since the response of the plant is unchanged there is no significant safety impact resulting from the delay k p rforming the TADOT.
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DETEJQtlN ATION OF NO SIGNIFICANT H AZARDS CONSIDER ATION 1.
The proposed temporary waiver of compliance does not involve a significant increase in the probability or consequences of an accident previously evaluated.
- Although the surveillance test did not adequately test one aspect of the manual reactor trip l
function, there is no reason to; believe that based on the preoperatio ial and surveillance testing perfo.med, that ary element of the manual trip function a rot functional. If for eme reason manual actuation of the shunt trip failed to opeate, the diversity and 4
redundancy of the reactar protcetion system would still enable it to nerform.its design function. Therefore, since the response of the plant to an accide it 4 unchanged there is no significant-increase in cither the probability or consequences of an accident previously evaluated as a result of this temporary waiver of compliance, 2.
The proposed temporary waiver of compliance will net create the possibility of a new or different kind of accident fro u any previously evaluated.
l The proposed temporary waiver of compliance does not affect th operation or response of any ' plant equipment or introduce any -new failure mechanisms.
Therefore, the nrevious accident-analyses are unchanged and bound till expected plant transients and there are no new or different accident scenarios introduced.
3.
The proposed temporary waiver of. compliance will not involve a significant reduction l
in a margin of safety.
The proposed temporary waiver of ompliance will not reduce the margin of safety defincd
- in the BASES of any Technical specification. The BASES of Technical Specification 33-1, Reactor Trip System Instrumentation states in part that OPERABILITY of the reactor trip system _ ensures that a reactor-trip will occur _ when needed.
The reactor trip system possesses several diverse and independent features which enable it to shatdown the reactor on demand. The operation of any of these features demonstrates that the reactor protection system is capable of performing its safety function.
Therefore, the assumptions in the BASES of Technical Specifications are not affected and the proposed t mporary waiver of compliance will not result in a significant reduction in the margin of safety.
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