ML20113H903

Proposed TS Table 4.3-1 Notation 13 Re Trip Actuating Device Operational Test

ML20113H903
Person / Time
Site:	Seabrook
Issue date:	08/03/1992
From:	NORTH ATLANTIC ENERGY SERVICE CORP. (NAESCO)
To:
Shared Package
ML20113H900	List: ML20113H899 ML20113H903
References
NUDOCS 9208060127
Download: ML20113H903 (2)

Text

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i TABLE 4.3-1 (Continued)

TABLE NOTATIONS (Continued)

(12) Verify the RTD bypass loops flow rate.

4< (13) The TRIP ACTUATING DEVICE OPERATIONAL TEST shall independently verify the OPERABILITY of the undervoltage and shunt trip circuits for the Manual Reactor Trip Function. The test shall also verify the OPERABILITY of the Bypass Breaker trip circuit (s).

(14) Local manual shunt trip prior to pla:ing breaker in service.

(15) Automatic undervoltage trip.

(15) Each channel shall be tested at least every 92 days on a STAGGERED TE51

. BASIS.

(17) These channels also provide inputs to ESFAS, Comply with the applicable MODES and surveillance frequencies of Specification 4.3.2.1 for any por-tion of the channel required to be OPERABLE by Specification 3.3.2.

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• Complete verificaticn of OPERABILITY of the shunt trip circuitry shall be ic:plemented MODE prior occurring 3 or lower, to startup after from Julythe first 30, planned or unplanned shutdown to 1992. ,

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Jh Facsimde (603) 4 74+ 2987 Energy Service Corporation Ted C. Feigenbaum Senior Wee President and Chief Nuclear Officer NYN 92103 July 30,1992 Regional Administrator U. S. Nuclear Replatory Commission Region 1 475 Allendale Road King ot Prussia, PA 19406 Attention: Mr. Thomas T. Martin P.c f e r e n ce: Facility Operating License No. NPF 86, Docket No. 50-443

Subject:

Request for Temporary Waiver of Compliance; Manual Reactor Trip TADOT -

Gentlemen:

North Atlar. tic Energy Service Corporation (North Atlantic) requests a temporary waiver of compliance from the provisions of Seabrook Station Technical Specification Surveillance Requirement 4.3.1.1 as it pertains to the performance of the Trip Actuating Device Operational Test (TADOT) for the Manual Reactor Trip function (See Technical Specification Table 4.31, Functional Unit 1, Manual Reactor Trip). The North Atlantic Independent Safety Engineering Group (ISEG) made a preliminary determination on July 28.

1992, through its evaluation of an INPO Nuclear Network summary of an operational event at another facility, that the 18 month surveillance testing program for the Reactor Trip Breakers ar

• Reactor Trip Bypass Breakers may not have adequately tested one aspect of these breakers trip circuitry pursuant to Surveillance Requirement 4.3.1.1. The ISEG notified plant management of this preliminary determination. Plant management initiated an extensive review of test procedures and related testing associated with the reactor trip breakers.

! On July 29, 1992, at 8:45 AM, it was determined that the 18 month surveillance testing l program was inadequate. This testing program inadequacy notwithstanding, North Atlantic

! has determined that based on extensive surveillance and preoperational testing, and based on the diverse trip features (undervoltage and shunt trip attachment), the Reactor Trip Breakers and Reactor Trip Bypass Breakers are fully functional and capable of opening the breakers in response to a Main Cot' ol Board manual trip actuation or manual safety injection actuation.

The testing inadequacy for the Manual Reactor Trip function TADOT was discussed by Ncrth Atlantic representatives (Messrs. DiProfio, Harpster, Drawbridge, et. al.) with NRC Region I and NRC _ Office of Nuclear Reactor Regulation representatives (Messrs. Linville.

l Lazarus, Dudley, Calvo, Nerses, et. al.) on July 29, 1992 in a conference call from the l Resident inspectors office. During this conference call, North Atlantic requested verbal l authorization for a temporary waiver of compliance from Technical Specification Sut veillance Requirement 4.3.1.1, Table 4.3-1, Functional Uni: 1 as it pertains to the Manual Reactor Trip Function TADOT. The NRC was informed that the Manual Reactor Trip function had been declared inoperable as of 8:45 AM EDT, accordingly Technical Specification 3.0.3 had been x } W( b a member of the Northeast Utilities system

s S . United States Nuclear Regulatory Commission July 30 W Attention: Mr. Thomas T. Martin Page two entered and preparations for a shutdown had commenced. The NRC authorized the temporary waiver of compl:ance at 9:42 AM EDT and directed that the written request be submitted by July 31, 1992.

Descrintion of Conditions:

Seabrook Station Technical Specification Surveillance Requirement 4.3.1.1, Table 4.3-1.

Functional Unit 1 (Manual Reactor Trip) requires a TADOT on the Manual Reactor Trip function which is *o be performed each refueling outage. The Manual Reactor Trip TADOT is subject to Table dotation 13 which requires the following:

"The TRIP AC'l UATING DEVICE OPERATIONAL TEST shall independ:ntly verify the Ui:LRABILITY of the undervoltage and shunt trip circuits for the Manual Rt :or Tr!p Function. The test shall also verify the OPERABILITY of the Bypa i Breaker trip circuits."

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 Breaker 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. Procedure OX1410.04 requires verification that the proper voltage is applied to the shunt trip coils when the Main Control Board manual reactor trip and manual safety injection switches are actuated, however the procedure does not consider that the proper voltage may be present due to the existence of a voltage path thru the Main Control Board indicating lights to the shunt trip coil. North Atlantic will revise Procedure OX1410.04 to require removal- of the indicating lights during performance of the sbunt trip .: oil voltage measurement to ensure a proper test of the shunt trip circuit.

Recuest for Temporary Waiver of Compliancea North Atlantic is providing the justification below which demonstrates that continued operation during the duration of the requested waiver is consistent with protecting the health and safety of the public,

1) Reauirements for Which a Waiver is Reauested:

Nerth - Atlantic requests a vaiver from: the requirements of Technical Specification Surveillance Requirement 4.3.1.1. Table 4.31 Functional Unit 1, Manual Reactor Trip, Table Notation 13. As discussed above, Norta 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 Thunt-trip coil.

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4 United States Nuclear Regulatory Commission July 30,1o92 Attention: Mr. Thomas T. Martin Page three

2) Circumstances of the Situation and Need for Promet Action:

On July 2s.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 was discovered as a result of a evaluation of an INPO Nuclear Network summary of an operational event at another facility. Station management I w as appri% of the issue and directed that a thorough review of reactor trip brtaker procedures be conducted expediently. On July 29,1992 at 8:45 AM it was concluded that the trip breaker testing was not performed in compliance with all aspects of the Technical Specifications. North Atlantic has evaluated the potential to perform the proper testing of the shunt trip circuit. . te to the complexity of the testing involved, North Atlantic feels that it would be impruc - to conduct such a complex test procedure with its attendant trip potential.

3) Compensatorv 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 manual reactor trip actuation or manual safety injection actuation is necessary and does not initiate the reactor trip, North Atlantic 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) Additional Actions 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 Breaker Surveillance) is inadequate with respect to the testing of the sh3 tat trip circuit from the Main Control Board manual reactor trip switch and man'"! safety injectica switch to the shunt trip coil. Procedure OX1410.04 does however fut.y and independently test the undervoltage trip feature of the Reactor Trip Breakers and Reactor Trip Bypass Breakers from the Main Control . Board manual reactor trip switches. Procedure OX1410,04 that independently tests the shunt trip feature of the Reactor Trip Breakers and Reactor Trip Bypass Breakers will be revised to ensure a full test of the shunt trip circuit from the Main Control Board manual reactor trip switch and manual safety injection switch to the shunt trip coil.

United States Nuclear Regulatory Comtnission July 30,1992 Attention: Mr. Thomas T. Martin Page four 4

5 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. However.

<, procedure OX1410.04 will be revised to provide a full and independent test of the shunt trip i and undervoltage trip circuitry associated with the manual safety injection switch.

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5) Evaluation of the Safety Sienificance:

This testing program inadequacy notwithstanding, North Atlantic has determined that based on extensive surveillance and preoperational testing, and based on the diverse trip featutes (undervoltage and shunt trip attachment), the Reactor -Trip Breakers and Reactor Trip l Bypass Breakers are fully functional and capable of opening the breakers in response to a i Main Control Board manual trip actuation or manual safety injection actuation. An evaluation of the safety significance of the shunt trip circuit testing inadequacy is provided M Enclosure 1.

. 6) Duration 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 upcoming refueling outage, the applicable provisions of Technical Specification Surveillance Requirement 4.3.1.1 will be fully i performed, including the Manual Reactor Trip TADOT, Should Seabrook Station experience a planned or unplanned shutdown requiring an entry into MODE 3 or lower prior to the

refueling outage, the Manual Reactor Trip TADOT will be completed prior to plant restart.

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7) _ Basis for No Sienificant Ha7ards:

This testing program inadequacy notwithstanding, North Atlantic has determined that based on extensive surveillance and preoperatianal testing, and based on the -diverse trip features (undervoltage and shunt - trip attachment), the Reactor Trip LBreakers and Reactor 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.

t A No Significan: Hazards 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 in response to. a Main' Control Board manual trip actuation or manual safety injection 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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'I United States Nuclear Regulatory Commission July 30,1992 Attention: hir. Thomas T, Martin Page five Should you have any further questions regarding this request for a temporary waiver of compliance, please contact Mr. Terry L. Harpster, Director of Licensing Services at (603) 474 9521 extension 2765.

Very truly yours,

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Ted C. Feigenbaum TCF:ALL/act Enclosure cc: Document Control De.k United States Nuclear Regulatory Commission Washington, D.C. 20$55 Mr. Willir.a Lt.zarus RPS 3C-Chief U.S. Nuclear Regulatory Commission Region 1 475 Allendale Road King of Prussia, PA 19406 i Mr. Gordon E. Edison, Sr. Project Manager Project Directorate 13 Division of Reactor Projects

! U.S. Nuclear Regulatory Cornmission Washington, DC 20555

! Mr. Noel Dudley l NRC Senior Resident Inspector

!. P.O. Box 1149 l Seabrook, NH 03874 i

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.. 1 EVALUATION OF SAFETY SIGNIFICANCE AND l NO SIGNIFICANT HAZARDS CONSIDERATION FOR l REOUESTED WAlVER OF COMPLIANCE j EVALU ATION OF S AFETY SIGNIFICANCE

North Atlantic has determined that there is no significant safety impact associated with the

temporary waiver of compliance from the requirements of Technical Specification Surveillance

Requirement 4.3.1.1, Table 4.3-1, Functional Unit 1. Manual Reactor Trip. Although the

i. surveillance test did not adequately test one aspect of the manual reactor trip function, 3

there is no reason to believe that any element of the rnanual trip function is not functional, t North Atlantic believes that based on the preoperational and surveillance testing performed.

that the manual reactor trip function is fully functional _and capable of performing its design function if called upon to do so.

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', 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 demonstrates 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 possesses sufficient diverse .and

independent features te enable it to perform its design function.

The surveillance testing performed.on the reactor trip oreakers and the reactor trip bynass l breakers-was inadequate in that the capability of the manual reactor trip swit,;hes, laated on the main control board, to actuate the shunt _ trip coil' was not - posit;vely 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

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sLunt trip coil will actuate to trip the reactor trip breakers and the reactor trip bypass breakers.

it is important to note that the only feature which has not been adequately tested is the capability to_ initiate a manual reactor tr_ip via the shunt trip coil. The ability of the' Reactor i

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 hkely function to.open.the reactor

trip breakers. It is unlikely that a manual reactor trip would-be requiref 'In the unlikely event that.the operator was required to initiate a manual reactor trip nd the signal did not-reach the shunt trip coil, the de energization. of the undervoltage relay would cause the reactor trip breakers to open. ' Additionally, when the undervoltage relay is de energized, the shunt trip B coil is' also de energized, This action closes a contact which will energize the

, ' shunt trip coil and-open the reactor trip breakers.

s Therefore, the 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 in performing the TADOT.

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f-4 DETER \11 NATION OF NO SIGNIFICANT H AZ ARDS CONSIDER A~llON

1. The proposed ternporary wa:c er of compliance does not involve a signifhant increase in the probability or consequences of an accident previousif evaluated.

Although the surveillance test did not adequately test-one aspect of the manual reactor trip function, there is no reason to believe that based on the preoperational and surveillance testing performed, that any element of the manual trip function is not functional. if for some reason manual actuation of the shunt trip failed to operate, the diversity and redundancy of the reactor protection system would still enable it to perform ,its design function. Therefore, since the response of the plant to an accident is unchanged there is-no significant increase in either the probability or consequences of an accident previously evaluated as a result of this temporary waiver of compliance.

2. The proposed temporary waiver of compilance will not create the possibility of a new or different kind of accident from any previously evaluated, The proposed temporary waiver of compliance does not affect the operatica or response of any plant equipment or introduce any new failure meenanisms. Therefore, the previous accident analyses are unchanged and bound all 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 in a margin of safety, The proposed temporary waiver of compliance will not reduce the margin of safety defined in the BASES of any Technical Specification. The BASES of Technical crecification 3.3 1, Reactor Trip System Instrumentation states in part that OPERABILITY of the re'ictor 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 shutdown 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 tempo'rary waiver of compliance will not result in a significant reduction in the margin of safety.

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