ML20127A315
| ML20127A315 | |
| Person / Time | |
|---|---|
| Site: | 05000000, San Onofre |
| Issue date: | 10/14/1982 |
| From: | Mattson R Office of Nuclear Reactor Regulation |
| To: | Eisenhut D Office of Nuclear Reactor Regulation |
| Shared Package | |
| ML082410334 | List: |
| References | |
| FOIA-85-243, RTR-NUREG-0212, RTR-NUREG-212 NUDOCS 8211040325 | |
| Download: ML20127A315 (2) | |
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OCT 141382 a
MEMORANDUM FOR:
D. Eisenhut, Director Division of Licensing FROM:
R. Mattson, Director Division of Systems Integration
SUBJECT:
COMBUSTION ENGINEERING STANDARD TECHNICAL SPECIFICATIONS (NUREG-0212) - PROPOSED REVISION 3 - RELAY TESTING
Reference:
(1) CE Letter (A. Scherer) to NRC (D. Hoffman) dated.
August 11, 1982, " Standard Technical Specifications for CE PWR's (NUREG-0212), Proposed Revision 3".
(2)
SCE Letter (R. Dietch) to NRC (H. Denton) dated July 23,1982, " Docket No. 50-361, Amendment
' Application No. 8, San Onofre Nuclear Generating Station, Unit 2."
(3)
SCE Letter (K. Baskin) to NRC (F. Miraglia) dated August 16,-1982, " Docket Nos. 50-361 and 50-352, San Onofre Nuclear Generating Station, Units 2 and 3".
In ~ esponse to D. Skovholt's verbal request on September 8,1982, r
the following discusses the Instrumentation and Control Systems Branch (ICSB) position on Engineered Safety Feature Actuation System (ESFAS) subgroup relay surveillance requirements for Combustion Engineering-(CE) plants.
Combustion Engineering has requested (reference 1) that the proposed revision 3 to the CE Standard Technical Specifications be modified to extend the sur-veillance of ESFAS subgroup relays from the present 6-month interval to an 18-month (refueling) interval. As a basis for this proposed modification, CE has referred to information submitted by Southern California Edison (SCE) on the San Onofre, Units 2 and 3, docket (references 2 and 3).
Enclosed is a memorandum (T. Speis to T. Novak) dated August 30, 1982 which provides the ICSB evaluation of the SONGS 2 and 3 information.
It appears from re-ferences 2 and 3 and discussions between the applicant and staff in a meet-Conta-t:
R. Stevens, ICSB X29456 h?
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2-D. EisGnhut e
ing held July 29, 1982 that the assignment of SONGS ESFAS actuated equip-ment to the ESFAS subgroup relays has compromised to a large extent the capability of testing the complete actuation circuitry at power and thus, may not fully comply with current regulatory guidance. The staff has con-cluded that the San Onofre 2 & 3 applicant has provided insufficient inform-ation to justify their proposed 18-month. test interval.
Several concerns remain as described in the enclosed memorandum.
Based on the above discussion, and that in the attached me:crandum on San Onofre 2 & 3, it is the ICSS position that the proposed revision 3 to the CE Standard Technical Specifications should continue to reflect the 6-month test interval for ESFAS subgroup relay surveillance. Changing the interval to 18 months would conflict with fundamental regulatory practice, as called out by Regulatory Guide 1.22 and IEEE Std. 338. We are particularly con-cerned that acceptance of an 18-month test interval in th'e Standard
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- hnical Specifications would encourage designs which could not be fully
. tested with the plant at power. This would effectively eliminate the possibility of increasing the test frequency if the relay reliability during actual plant operation were found to be lower than assumed by the
It should be reiterated that applicants, on a case-by-case basis, may obtain relief from the 6-month test interval for those ESFAS subgr:up relays which are identified as not capable of being tested while the plant is at power i
provided that sufficient justification is submitted. Justification for relief i
i should include information showing that-the actuated equipment assignments to the subgroup relays were made in a manner to minimize the number of com-i ponents which cannot be tested with the plant at power.
If there are any questions, please ' contact the ICSB.
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cyr Roger J. M tson, D rector Division d'f Systems ' tegration, NRR
Enclosures:
As stated" cc:
T. Speis F. Rosa C. Rossi I
T. Dunning l
R. Stevens J. Rosenthal D. Skovholt D. Hoffman D. Erinkman
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