ML20113A810

Forwards Basis for Notice of Enforcement Discretion for TS Table 4.3-1

ML20113A810
Person / Time
Site:	Farley
Issue date:	06/21/1996
From:	Dennis Morey SOUTHERN NUCLEAR OPERATING CO.
To:	NRC OFFICE OF INFORMATION RESOURCES MANAGEMENT (IRM)
Shared Package
ML20113A813	List: ML20113A810 ML20113A814
References
NUDOCS 9606250351
Download: ML20113A810 (8)

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. South 2rn Nucitar Op3 rat.ng Company

. . Post Ones Box 1295 Birmingham. A11bama 35201 Taliphone (205) 868-5131 1 Ema o... uor.y Southern Nudear Operating Company Vice President ,

Farley Project the Southem electnc System ,

June 21,1996 l

Docket Nos.: 50-348 '

50-364  !

U. S. Nuclear Regulatory Commission ATTN: Document Control Desk Washington, D.C. 20555 ,

i Joseph M. Farley Nuclear Plant Manual Safety Injection Reactor Trip Input  :

Request for Enforcement Discretion Ladies and Gentlemen:

1 Technical Specification Table 4.3-1, " Reactor Trip System Instrumentation Surveillance  :

Requirements," Functional Unit 18, Safety Injection Input from ESF, states that a chanel functional test is required once per 18 months. In addition, Note 4 to the Technical i

Specifications requirement states, " Manual ESF functional input check every 18 months."

Contrary to this requirement, it has been determined that the manual Safety Injection (SI) ESF

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input to the Reactor Trip System has not been tested within the last 18 months. As discussed i per telephone-conference with NRC staff on the evening of June 20,1996, enforcement i discretion was requested and approved to allow continued operation ofFNP Units 1 and 2.

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Attachment 1 provides the basis for Notice of Enforcement Discretion for Technical Specification Table 4.3-1.

If there are any questions, please advise.

Respectfully submitted, 1

9606250351 960621 PDR ADOCK 05000348

8) )/lqv P PDR Dave Morey Sworn to andsubscribed before me thisa t day of 1996 baalYezwu Y(sa/w

' Notary Public ff My Commission Erpires: e24 /997 MJA/ cit:safinjpt. doc

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U. S. Nuclear Regulatory Commission Page 2 1

Attachments:

1. Basis for Notice ofEnforcement Discretion for Technical Specification .

Table 4.3-1.

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2. Marked Up Proposed Technical Specification Pages l

3. Typed Changed Technical Specification Pages '

cc: Mr. S. D. Ebneter, Region II Administrator Mr. B. L. Siegel, NRR Senior Project Manager ,

Mr. T. M. Ross, FNP Sr. Resident Inspector Dr. D. E. Williamson, State Department of Public Health I

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Attachment 1 Request for Enforcement Discretion I

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Request for Enforcement Discretion i

1. The Technical Specification that will be violated.

Technical Specification Table 4.3-1 Reactor Trip System Instrumentation Surveillance Requirements Functional Unit 18, Safety Injection Input from ESF, states that a channel functional test is required once per 18 months. In addition, note 4 to the Technical Specification requirement states, " Manual ESF functional input check every 18 months."

Contrary to this requirement, it has been determined that the manual Safety Injection (SI) ESF input to the reactor trip system has not been tested within the last 18 months.  ;

2. Circumstances surrounding the situation, including root causes, the need for prompt action, and identification of any relevant historical events.

This situation was discovered because of questions asked during FNP's review of GL 96-01

" Testing of Safety-Related Logic Circuits " During the review no current procedure could be found that periodically tests the manual SI ESF input to the reactor trip system. It was determined upon review of the specific procedures referenced by the surveillance tracking master list that the procedures do not completely test the circuit. Specifically, the internal manual SI handswitch contacts that input to the reactor trip breaker shunt trip coils to cause ,

the reactor trip breakers to open have not been tested. The root cause of this event is i personnel error. Although this feature was tested in pre-operational testing, surveillance procedures developed during plant initial startup did not address testing of these particular contacts. Prompt action is needed to avoid undesirable transients potentially associated with unit shutdown due to forced compliance for non-safety significant issues. This specific event has never occurred before at FNP.

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3. Safety basis for the request, including an evaluation of the safety significance i and potential consequences of the proposed course of action. j Safety Analysis DESCRIPTION OF THE AMENDMENT REQUEST SNC proposes to amend, for both FNP units, Technical Specification Table 4,3-1 functional unit 18, " Safety Injection Input from ESF" channel functional test requirements for both FNP units to allow for continued operation for the remainder of the operating cycle. Following any unit shutdown, prior to Mode 2 entry this testing will be performed. See Attachment 2 for i marked up technical specification pages.

EVALUATION The SI input to the reactor trip system is designed to ensure that if a reactor trip has not i already been generated by the reactor protective instmmentation, the ESF automatic actuation ,

logic channels will initiate a reactor trip upon any signal which initiates a safety injection. The i SI reactor trip is a diverse signal provided to protect the core in the event of a LOCA. The manual SI input to the reactor trip system is a redundant feature of the reactor trip system.

Operations procedures currently direct the operator to ensure that the reactor is tripped (not critical) following any safety injection signal. In fact, operating procedures direct the operator to manually trip the reactor prior to initiating SI. Review of FNP FSAR and accident analyses indicate that the manual SI input to the reactor trip system is not taken credit for in any accident or transient analysis.  !

The SI function of the handswitch contacts is tested on a regular basis in accordance with unit .

technical specifications. FNP maintenance history has shown no problems with these  :

handswitch contacts and therefore, we believe that no problems exist with the particular l contacts in question. Testing of a single handswitch can result in reactor trip and safety injection signal being generated for both trains ofRPS and ESF. Testing of manual actuation features at power is not recommended by the FSAR because this can cause unnecessary transients on the plant that would adversely affect plant safety. The shunt trip and undervoltage trip circuits associated with the manual reactor trip switches are fully tested each i refueling. In addition, shutting the plant down due to forced compliance for non-safety ,

significant issues also can potentially result in undesirable transients. Finally, because of the redundant features associated with the reactor trip system, above 35% reactor power, actuation of the handswitch would cause a reactor trip by tripping of the main turbine which is a protection feature that is currently tested by site surveillances procedures.

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For these reasons, SNC proposes to continue operating FNP Units 1 and 2 for the remainder I of each unit's operating cycle or until any unit shutdown, following which prior to Mode 2  !

entry this testing will be performed, and to revise each unit's technical specifications to allow for this.

ANALYSIS Conformance of the proposed amendments to the standards for a determination of no significant hazard as defined in 10 CFR 50.92 (three factor test) is shown in the following:

1. Operation of the Farley Nuclear Plant Units 1 and 2 in accordance with the proposed license amendment does not involve a significant increase in the probability or consequences of an accident previously evaluated.

Since the SI manual actuation handswitch is not taken credit for in any transient or accident analyses, including LOCA, non-LOCA, and steam generator tube mpture for either safety

injection and/or reactor trip, failure to test the reactor trip function of the manually initiated l SI signal for the remainder of operating cycle or until any unit shutdown prior to Mode 2 i

entry would not increase the probability or consequences of an accident previously evaluated. In addition, operator action required by procedures will ensure that a reactor trip is verified to have occurred anytime SI is automatically actuated and prior to manual SI actuation.

2. The proposed license amendment does not create the possibility of a new or different kind of accident from any accident previously evaluated.

I Implementation of the proposed amendment does not introduce any change to the plant l design basis. Any hypothetical failure of the handswitch contacts to cause a failure to manually trip the reactor is compensated for by the redundant trip features associated with the reactor trip system. Examples are the reactor manual trip handswitch, reactor trip setpoints set to actuate prior to reaching SI setpoints, and the redundant train manual SI l handswitch. Therefore, SNC concludes that the proposed license amendment does not l create the possibility of a new or different kind of accident from any accident previously evaluated.

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l 3. The proposed license amendment does not involve a significant reduction in a margin of i safety.

Changing the surveillance frequency to allow for continued operation with the SI manual l input to reactor trip system not tested does not involve a reduction in the margin of safety because of the redundant features associated with the reactor trip system and because of operator actions required by emergency response procedures (ERPs). In addition, for power levels above 35% RTP, the SI handswitch has been shown to result in the intended function by tripping the reactor through the turbine trip logic. Therefore, SNC concludes based on the above, that the proposed change does not result in a significant reduction of margin with respect to plant safety as defined in the Final Safety Analysis Report or the bases of the FNP technical specifications.

CONCLUSION Based on the preceding analysis, it is concluded that operation of the Farley Nuclear Plant in accordance with the proposed amendment does not involve a significant hazards consideration l as defined in 10 CFR 50.92.

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4. The basis for the conclusion that the noncompliance will not be of potential detriment to the public health and safety and that neither an unreviewed safety question nor a significant hazard consideration is involved.

Since no credit is taken for the SI manual handswitch in any transient or accident analyses, including LOCA, non LOCA, and steam generator tube rupture, there is no detriment to the public health and safety and neither an unreviewed safety question nor a significant hazard consideration is involved.

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5. The basis for the conclusion that the noncompliance will not involve adverse consequences to the environment.

The proposed amendment request does not affect normal operation of the units and does not alter any accident analysis results. Therefore, this will not involve any significant change in the types or amounts of effluents that may i e released offsite and no increase in the individual or cumulative occupational radiation exposure. Therefore, this request for enforcement discretion does not involve any irreversible environmental consequences.

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6. Proposed compensatory measures, y

Procedural guidance for manual initiation of reactor trips will be reviewed with on shift licensed crews. Discussions will include the failure to have adequately tested the SI initiation l manual handswitch and to ensure that, prior to any manual initiation of SI, the reactor is tripped in accordance with established operating procedures.

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7. Justification for the duration of the noncompliance.

Thejustification for the duration of the noncompliance is that redtmdancy exists in the reactor trip system and that the SI manual initiation handswitch is not taken credit for in any analyzed accident or transient. The SI function of the handswitch contacts is tested on a regular basis in accordance with unit technical specifications. FNP maintenance history has shown no problems with these handswitch contacts, and therefore, SNC believes that no problems exist with the particular contacts in question. Testing of a single handswitch can result in reactor trip and safety injection signal being generated for both trains ofRPS and ESF, Testing of manual actuation features at power is not recommended by the FSAR because this can cause unnecessary transients on the plant that would adversely affect plant safety. The shunt trip and undervoltage trip circuits associated with the manual reactor trip switches are fully tested each l refueling. In addition, shutting the plant down due to forced compliance for non-safety significant issues also can potentially result in undesirable transients. Finally, because of the redundant features associated with the reactor trip system, above 35% reactor power, l actuation of the handswitch would cause a reactor trip by tripping of the main turbine which is a protection feature that is currently tested by site surveillance procedures.

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Consequently, operation with the SI manual initiation handswitch not tested for the reactor trip function is acceptable until a Technical Specification amendment can be submitted by SNC and approved by the NRC.

8. Review by the Plant Operations Review Committee.

This request for enforcement discretion has been reviewed and approval has been recommended by the organization tasked to advise the General Manager - Nuclear Plant on all matters related to nuclear safety at Farley Nuclear Plant, i.e., the Plant Operations Review Committee.

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9. Satisfaction of NOED criteria.

This NOED is intended to avoid undesirable transients as a result of forcing compliance with a license condition and, thus, minimizmg potential safety consequences and operational risks.

No credit is taken in safety analyses for the function of manual initiation of SI to cause a reactor trip. Consequently, to shutdown and test this function will not provide any additional margin of safety; however, it will result in unnecessary operational transients without any benefit. Southern Nuclear believes that it has met the criteria for NOED as provided in NRC Inspection Manual Part 9900: 10 CFR Part 2 Appendix C Enforcement Discretion.

10. M~arked-up Technical Specification pages showing the proposed changes.

A copy of the referenced marked up FNP technical specification pages is prosided in Attachment 2.

11. Prior adoption of approved line-item improvements to the technical specifications of the improved technical specifications would not have obviated the need for the NOED request.

SNC has committed to adopt improved technical specifications; however, in this case no benefit would have been gained by the early implementation.

12. Additional information requested by NRC Staff.

At this time no additional information has been requested by the staff.

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