ML20113B693

Application for Amends to Licenses NPF-2 & NPF-8,deleting Requirement for Surveillance of Manual SI Input to Reactor Trip Circuitry Until Next Unit Shutdown

ML20113B693
Person / Time
Site:	Farley
Issue date:	06/24/1996
From:	Dennis Morey SOUTHERN NUCLEAR OPERATING CO.
To:	NRC OFFICE OF INFORMATION RESOURCES MANAGEMENT (IRM)
Shared Package
ML20113B694	List: ML20113B693 ML20113B708
References
NUDOCS 9606270266
Download: ML20113B693 (5)

Text

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• South rn Nucitar Op: rating Company

, Post Office Box 1295

. Birmingham, Alabama 35201 t

• Tzicphons (205) 868-5131 L k o.v. uorey Southem Nudear Operating Company Vice President Farley Project the Southern electnc System June 24, 1996 i 1 1

Docket Nos.: 50-348 10 CFR 50.90 l 50-364 U. S. Nuclear Regulatory Commission ATTN. Document Control Desk )

Washington, D.C. 20555 l Joseph M. Farley Nuclear Plant Technical Specifications Change Request j Manual SI Reactor Trip Input Surveillance Requirement Ladies and Gentlemen: )

i On June 20,1996, SNC requested and NRC Staff approved Enforcement Discretion for Farley i Units 1 and 2. The basis for this Enforcement Discretion is described in SNC letter to the  !

NRC dated June 21,1996, which described the Units 1 and 2 cycle-specific change (cycle 14 and 11 respectively).

Enclosed is SNC's request for a Unit I cycle 14 and Unit 2 cycle 11 only Technical Specification change for deletion of the requirement for surveillance of the manual safety injection input to the reactor trip circuitry until the next unit shutdown, following which, this testing will be performed prior to Mode 2 entry described in the SNC June 21,1996 l

Enforcement Discretion letter.

It is requested that the NRC approve the Unit I cycle 14 and Unit 2 cycle 11 specific Table 4.3-1 Technical Specification change. Attachment I contains a Significant Hazards Consideration analysis. SNC has determined that the proposed license amendment will not

. significantly affect the quality of the human environment. Attachment 2 provides page change instructions, revised technical specification pages and marked-up existing technical specification pages.

A copy of the proposed changes is being sent to Dr. D. E. Williamson, the Alabama State j Designee, in accordance with 10 CFR 50.91(b)(1).

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U. S. Nuclear Regulatory Commission Page 2 If there are any questions, please advise. l Respectfully submitted, SOUTHERN NUCLEAR OPERATING COMPANY

$ltrus Dave Morey Swom to and subscribed before me thisc/h day of 0fbut 1996 b

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No'taryPublic 0 My Commission Erpires: 0embD Y "

                                                           /997 0

WAS/ cit:noedntcl. doc Attachments:

1. Significant Hazards Evaluation

2. 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 l

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l l l l ATTACHMENT 1 Significant Hazards Evaluation 1 i l l l l l f 8 f t l I l l i

d Page 1 of 2 Significant Hazards Evaluation Joseph M. Farley Nuclear Plant Manual SI Reactor Trio Inout Technical Specification Change 10 CFR 50.92 EVALUATION As required by 10 CFR 50.91 (a)(1), an analysis is provided to demonstrate that the proposed license amendment to delete the requirement for surveillance of the manual safety injection input to the reactor trip circuitry for the current cycle for each unit until the next unit shutdown, following which, this testing will be performed prior to Mode 2 entry, involves no significant hazards consideration. Proposed Channe The proposed change to the Farley Units 1 and 2 Technical Specification Table 4.3-1 involves a change to Note 4 which deletes the requirement for surveill.a.nce of the manual safety injection input to the reactor trip circuitry for the current cycle for each unit until the next unit shutdown, following which, this testing will be performed prior to Mode 2 entry. Analysis he SI input to the reactor trip system is designed to ensure that if a reactor trip has not already been generated by the reactor protective instrumentation, the ESF automatic actuation logic channels will initiate a reactor trip upon any signal which initiates a safety injection. He SI reactor trip is a diverse signal provided to protect the core in the event of a LOCA. He 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. He 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 of RPS 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 an Ated with the manual reactor trip switches are fully tested each refueling. In addition, shutting the plant down due to forced compliarce 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. For these reasons, SNC proposes to continue operating FNP Units I and 2 for the remamder of each unit's operating cycle or until cach unit is shutdown, following which, this testing will be performed prior to Mode 2 entry, and to revise each unit's technical specifications to allow for this.

Page 2 of 2 Significant Hazards Evaluation  ! Joseph M. Farley Nuclear Plant Manual SI Reactor Trio Inout Technical Soecification Channe 50 92 Evaluation Conformance of the proposed amendments to the standards for a deternunation of no significant hazard as defmed 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.

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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 rupture for either safety injection and/or reactor trip, failure to test the reactor trip function of the manually initiated SI signal for tie , remamder of operatmg cycle or following each units shutdown, prior to Mode 2 entry, would not 1 increase the probability or consequences of an accident previously evaluated. In addition, operator l action required by proeiss will ensure that a reactor trip is verified to have occurred anytime SI i is automatically =cen=*~i 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.

Implementation of the proposed amendment does not introduce any change to the plant 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 l are the reactor manual trip handswitch, reactor trip setpoints set to actuate prior to reaching SI setpoints, and the redundant train manual SI handswitch. 'Iberefore, SNC concludes that the proposed license an-ima=* does not create the possibility of a new or different kind of accident from any accident previously evaluated.

3. 'Ihe proposed license amendment does not involve a significant reduction in a margin of safety.

Changing the surveillance frequency to allow for continued operation with the SI manual 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. 'Iherefore, SNC concludes Msed on the above, that the proposed change does not result in a sieni&==* rW= of margm 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 precedmg analysis, it is concluded that operation of the Farley Nuclear Plant in accordance with the proposed ==aadmant does not involve a significant hazards consideration as defined in 10 CFR 50.92(c).

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