ML20245J048
| ML20245J048 | |
| Person / Time | |
|---|---|
| Site: | Millstone  |
| Issue date: | 04/26/1989 |
| From: | Office of Nuclear Reactor Regulation |
| To: | |
| Shared Package | |
| ML20245J038 | List: |
| References | |
| GL-83-28, NUDOCS 8905030621 | |
| Download: ML20245J048 (1) | |
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o UNITED STATES.
'T f
g NUCLEAR REGULATORY COMMISSION 7.
fj WASHINGTON, D. C. 20555
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SAFETY EVALUATION BY THE OFFICE OF NUCLEAR REACTOR REGULATION CONCERNING GENERIC LETTER 83-28, ITEM 4.5.2 REACTOR TRIP SYSTEM RELIABILITY ON-LINE TESTING NORTHEAST NUCLEAR ENERGY COMPANY. ET AL.
MILLSTONE NUCLEAR POWER STATION, UNIT NO. 2 DOCKET NO. 50-336 INTRODUCTION AND
SUMMARY
Generic Letter 83-28 was issued by NRC on July.8,1983, indicating actions to be taken by applicants and licensees based on the generic implications of the Salem ATFS events.
Item 4.5 states a staff position which requires on-line functional testing of the reactor trip system, including independent testing of the diverse trip features of the reactor trip breakers, for all plants.
Item 4.5.2 requires applicants and licensees with plants not currently designed to pennit this periodic on-line testing to justify not making modifications to permit such testir.g.
By letters dated November 8,1983 and
' April 2,1987, the licensee, Northeast Nuclear Energy Company, responded to the staff position regarding Item 4.5.2 of Generic Letter 83-28. Our review of these responses finds them to be acceptable.
EVALUATION In their first submittal dated November 8, 1983, the licensee stated that.this item did.not apply.because the Millstone 2 RTS was designed to permit on-line testing of the reactor trip system and that periodic on-line testing would be performed at 18 month intervals.
It was not clear from this response that the plant was designed to permit independent on-line verification of the operability of the shunt and undervoltage trip attachments of the reactor trip breakers. However, in their last submittal they stated that the plant was designed to allow on-line testing of the Reactor Trip System, that independent on-line testing verification of the operability of the reactor trip breaker shunt and ur.dervoltage trip attachments could be performed, and that such testing would be done.
CONCLUSION The staff concludes that this response is acceptable since the licensee's response meets the staff position.
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Principal Contributor:
D. Lasher Date: April 26, 1989 8YObO30621 ByV426 PDR ADOCK 05000336 P
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EGG-NTA-7463 i
Revision 2 I
l TECHNICAL EVALUATION REPORT CONFORMANCE TO ITEM 4.5.2 0F GENERIC LETTER 83-28
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ARKANSAS NUCLEAR ONE-2
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CALVERT CLIFFS-1 AND -2 j
FT. CALHOUN MAINE YANKEE h !N.
i PALISADES j
PALO VERDE-1, -2 AND -3 j
SAN ONOFRE-2 AND -3 i
ST.'LUCIE-l'AND -2 j
WATERFORD-3
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WNP-3 i
F. G. Farmer I
Published September 1987 Idaho National Engineering Lacoratory EG&G Idaho, Inc.
Idaho Falls, Idaho 83415 Prepared for the U.S. Nuclear Regulatory Commission Washington, D.C.
20555 Under DOE Contract No. OE-AC07-76IO01570 FIN Nos. 06001 and 06002
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ABSTRACT This EG&G Idaho, Inc., isport provides a review of the submittals for Combustion Engineering (CE) nuclear plants for conformance to Generic Letter 83-28, Item 4.5.2.-
The report includes the following piants, all CE, and is in partial fulfillment of the following TAC Nos.:
Plant Docket Number TAC Number Arkansas Nuclear One 50-368 53961 Calvert Cliffs-1 50-317 53969 Calvert C11ffs-2 50-318 53970 Ft. Calhoun 50-285 53983 Maine Yankee 50-309 53996 Millstone-2 50-336 54000
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Palisades 50-255 54009 Palo Verde-1 50-528 59173 Palo Verde-2 (OL) 50-529 N/A Palo Verde-3 (OL) 50-530 N/A San Onofrc 50-361 54024 San Onofre-3 50-362 54025 St. Lucie-1 50-335 54028 St. Lucie-2 50-389 54029 Waterford-3 (OL) 50-382 57710 WNP-3 (OL) 50-508 N/A 11
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l-FOREWORD Th'is report is provided as part of the program for evaluating licensee / applicant conformance to Generic Letter 83-28, " Required Actions
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Based'on Generic Implications of Salem ATWS Events." This work is conducted for the U.S. Nuclear Regulatory Commission, Office of Nuelear Reactor Regulation, Division of Engineering and System Technology by EG&G Idaho, Inc.
The U.S. Nuclear Regulatory Commission.-funded the' work under the authorization, B&R 20-19-19-11-3, FIN Nos. 06001 and 06'002.
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jo E4L CONTENTS y.
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ABSTRACT.............................................................
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FOREWORD.............................................................
iii 1.
- INTRODUCTION.....................................................
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REVIEW: REQUIREMENTS.............................................
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GROUP REVIEW RESULTS.............................................
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4 REVIEW RESULTS FOR ARKANSAS NUCLEAR ONE-2.......................
5 4.1 Evaluation................................................
5-4.2 Conclusion.........................................'......
5 5.
REVIEW RESULTS FOR CALVERT' CLIFFS-1 AND -2......................
6 5.1 Evaluation................................................
6 5.2' Conclusion................................................
6 6.
R E V I EW R E S U LT S FO R FT. CA LHOU N..................................
7 6.1 Evaluation................................................
7 6.2:
Conclusion................................................
7 7.
REVIEW RESU LTS FOR MAINE Y ANKEE.................................
8' 7.1 Evaluation................................................
8 7.2 Conclusion................................................
8 8.
REVIEW RESULTS FOR MILLSTONE-2..................................
9 8.1 Evaluation................................................
9 8.2 Conclusion................................................
9 9.
REVIEW RESULTS FOR PALISADES....................................
10 9.1 Evaluation................................................
10 9.2 Conclusion................................................
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REVIEW RESULTS FOR PALO VERDE-1, -2 AND -3......................
11 10.1 Evaluation................................................
11 10.2 Conclusion................................................
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- 11. ; REVIE!! RESULTS FOR SAN ONOFRE-2 AND -3 ~..........................
12 11.1 Evaluation................................................
121 11.2 Conclusion................................................
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- 12.. REVIEW RESULTS FOR ST. LUCIE-1 AND -2...........................
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12.1 Evaluation................................................
13 12.2 Conclusion...............................................
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REVIEW RESULTS FOR WATERFORO-3..................................
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13.1 Evaluation................................................
14 13.2 Conclusion................................................
14 14 R E V I EW R E S U LT S FO R WN P-3........................................
15 14.1 Evaluation................................................
15-i 14.2 -Conclusion................................................
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- 15. GROUP CONCLUSION...............................................
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- 16. -REFERENCES......................................................
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CONFORMANCE TO ITEM 4.5.2 0F GENERIC LETTER 83-28 ARKANSAS NUCLEAR ONE-2 CALVERT CLIFFS-1_AND -2 FT. CALHOUN MAINE YANKEE MILLSTONE-2 PALISADES PALO VERDE-1, -2 AND -3 L
SAN ONOFRE-2 AND -3 1
ST. LUCIE-1 AND -2 WATERFORD-3
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INTRCOUCTION 1
On July 8, 1983, Generic Letter 83-13 was issued by D. G. Eisenhut, Director of the Division of Licensing, Office of Nuclear Reactor Regulation, to all licensees of operating reactors, applicants for operating licenses, and holders of construction permits.
This letter included required actions based on generic implications of the Salem ATWS events.
These requirements have been published in Volume 2 of NUREG-1000,
" Generic Implications of ATWS Events at the Salem Nuclear Power Plant."2 This report documents the EG&G Idaho, Inc., review of the submittals of all the CE plants including Arkansas Nuclear One-2, Calvert Cliffs-1 and -2, Ft. Calhoun, Maine Yankee, Millstone-2, Palisades, Palo Verde-1, -2 and -3, San Onofre-2 and -3, St. Lucie-1 and -2, Waterford-3 and WNP-3 for conformance to Item 4.5.2 of Generic Letter 83-28.
The suomittals from the licensees utilized in these evaluations are referenced in Section 16 of this report.
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REVIEW REQUIREMENTS
- ' Item 4.5.2 (Reactor Trip System Reliability - System Functional Testing - On-Line Testing) requires licensees and applicants with plants not currently designed to permit on-line testing to justify not making
' modifications to permit such testing. Alternatives to on-line testing will be considered where special circumstances exist and where the objective of high reliability can be met in another way.
Item 4.5.2 may be interdependent with Item 4.5.3 when there is a need to justify not performing on-line testing because of the peculiarities of a particular-
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' design.
All portions of the Reactor Trip System that do not have on-line testing capability will be reviewed under the guidelines for this item.
Maintenance and testing of the Reactor Trip Breakers are excluded from this review, as they are evaluated under Item 4.2.
This review of the licensee / applicant submittals will:
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1.
Confirm that the licensee / applicant has identified those portions of the Reactor Trip System that are not on-line testable.
If the entire Reactor Trip System is verified to be on-line testable, no further review is required.
2.
Evaluate modifications proposed by licensees / applicants to permit l
on-line testing against the existing criteria for the design of the protection systems for the plant being modified.
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Evaluate proposed alternatives to on-line testing of the Reactor Trip System for acceptability based on the following:
a.
The licensee / applicant submittal substantiates'the impracticality of the modifications necessary to permit on-line testing, and i
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High Reactor. Trip System availability (comparable to that which p- }
would be possible with'on-line testing) is achieved in another l
way. Any such proposed alternative must be. described in detail
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sufficient to permit an. independent evaluation of the basis and l
analysis provided in lieu of performing on-line testing.. Methods that may be used to demonstrate that the objective of high reliability has been met may include.the following:
1.
Demonstration by systematic analysis that testing at shutdown intervals provides essentially equivalent reliability to that obtained by on-line testing at shorter intervals.
11.
Demonstration that reliability equivalent to that obtained by on-line testing is accomplished by additional redundant and diverse components or by other features.
iii.
Development of a maintenance program based on early replacement of critical components that compensates for the' lack of on-line testing.
Such a program would require analytical justification supported by. test data.
iv.
Development of a test program that compensates for the 1
lack of on-line testing, e.
g., one which uses trend analysis and identification of safety margins for critical 4
parareters of safety-related components.
Such a program would require analytical justification supported by test data.
4 Verify the capability to perform independent on-line testing of the reactor trip system breaker undervoltage and shunt trip attachments on CE plants.
Inferruation from licensees and applicants with CE plants will be reviawed te verify that they require independent on-line testing of the reactor trip breaker undervoltage and shunt trip attachments.
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GROUP REVIEW RESULTS The. relevant submittals from each of the CE reactor plants were reviewed to determine compliance with Item 4.5.2.
First, the submittals from each plant were reviewed to establish that Item 4.5.2 was specifically addressed.
Second, the submittals were evaluated to determine the extent to 'which each of the CE plants complies with tre staff guidelines for Item 4.5.2.
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4 REVIEW RESULTS FOR ARKANSAS NUCLEAR ONE-2 4.1 Evaluation Arkansas Power and Light Company (AP&L), the license for Arkansas L
Nuclear One-2, provided their response to Item 4.5.2 of the Generic Letter l'
on November 5, 1983.
In that response, the licensee states that AP&L performs on-line testing of the Reactor Trip System, inclucing independent verification of the shunt and undervoltage trip attachments to the RTBs.
4.2 Conclusion We find that the licensee's statement that they currently perform on-line testing of the RTS meets the staff position on Item 4.5.2 of the Generic Letter and is, we believe, acceptable.
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REVIEW RESULTS FOR CALVERT CLIFFS-1 AND -2 l
5.1 Evaluation Baltimore Gas and Electric, licensee for Calvert Cliffs-1 and -2, responded to the Generic Letter on November 5,1983, and February 29, 1984. The licensee's responses confirm that Calvert Cliffs is designed to permit on-line testing of the Reactor Trip System and that the shunt and undervoltage trip attachments are independently tested on-line.
l 5.2 ' Conclusion We find that the licensee's statement that they currently perform on-line testing of the RTS meets the staff position ~on Item 4.5.2 of the Generic Letter and is, we believe, acceptable.
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REVIEt;! RESULTS FOR FT. CALHOUN 1
6.1 Evaluation 4
The Omaha Public Power District, the licensee for Ft. Calhoun, l-responded to Item 4.5.2 of the Generic Letter on November 4, 1983.
In that response, the licensee states that Ft. Calhoun performs on-line testing of
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the Reactor Trip System, and that Ft. Calhoun has an older C-E design l
reactor trip system which does not use breakers.
Instead it uses four independent contactors, each of which can be independent,1y tested at power, which meets the requirements of Item 4.5.2 of the Generic Letter for C-E plants.
6.2 Conclusion We find that the licensee's statement that they currently perform on-line testing of the RTS meets the staff position on Item 4.5.2 of the Generic Letter and is, we believe, acceptable.
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REVIEW RESULTS FOR MAINE YANKEE 7.1, Evaluation Maine Yankee Atomic Power cmpany, the licensee for Maine Yankee, responded to Item 4.5.2 of the Generic Letter on November 10, 1983.
In that response the licensee states that Maine Yankee performs on-line -
testing of the Reactor Trip System, and is pursuing modifications that will permit on-line independent testing of the shunt and undervoltage attachments.
7.2 Conclusion We find that the licensee's statement that they perform on-line testing of the RTS meets the staff position on Item 4.5.2 of the Generic Letter and.is, we believe, acceptable.
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REVIEW RESULTS FOR MILLSTONE-2
', i 8.1 Evaluation k
Northeast Utilities, the licensee fer M111 stone-2, responded to f
Item 4.5.2 of ~the Generic Letter on November 8,1983, and April 2,1987.
In those responses the licensee states that M111 stone-2 performs on-line testing of the Reactor Trip System, and that the on-line testing includes
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independent testing of the shunt and undervoltage attachments.-
8.2 Conclusion We find that the licensee's statement that they perform on-line testing of the RTS meets the staff position on Item 4.5.2 of the Generic Letter and is, we believe, acceptable.
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REVIEW RESULTS FOR PALISADES I
9.1 Evaluation Consumers Power Company, the licensee for Palisades, responded to f-Item 4.5.2 of the Generic Letter on February 19, 1985, and July 1, 1985.
In the.latter response the licensee states that Palisades currently performs on-line testing of the Reactor Trip. System, and that Palisades has an older C-E design reactor trip system which does not use breakers.
Instead it uses four independent contactors, each of which can be independently tested at power, which meets the requirements of Item 4.5.2 of the Generic Letter for C-E plants.
9.2 Conclusion We find that tna lic ensee's statement that they perform on-liae testing of the RTS meets tne staff position on Item 4.5.2 of the Generic Letter and is, we believe, acceptable.
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REVIEW RESULTS FOR PALO VERDE-1, -2 AND -3 10.1 Evaluation 4
Arizona.Public Service Company, the licensee for Palo Verde-1 and i
applicant for Palo Verde-2 and -3, responded to Item 4.5.2 of the Generic Letter on November 3, 1983.
In that response, the licensee states that the Palo Verde design allows performance of on-line testing of the Reactor Trip System, and that the applicable procedures for the on-line testing includes independent testing of the reactor trip breaker shunt and undervoltage trip attachments.
10.2 Conclusion-We find that the licensee's statement that they currently perform on-line testing of the RTS at Palo Verde-1 and will perform on-line testing of the RTS at Palo Verde-2 and -3 meets the staff position on Item 4.5.2 of the Generic Letter and is, we believe, acceptable.
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REVIEU RESULTS FOR SAN ONOFRE-2 AND -3 11.1 Evaluation Southern California Edison Company, the licensee for San Onofre-2 and -3, responded to Item 4.5.2 of the Generic Letter on November 29,.1983, October 2, 1985, and June 18, 1987.
In the latter responses, the licensee states that the San Onofre-2 and -3 design allows performance of on-line testing of the Reactor Trip System, and confirmed that the plant is designed to permit independent on-line verification of operability of the reactor trip breaker shunt and undervoltage trip attachments.
11.2 Conclusion j
We find that the licensee's statement that San Onofre-2 and -3 are designed to permit on-line testing of the RTS meets the staff position on Item 4.5.2 of the Generic Letter and is, we believe, acceptable.
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REVIEW RESULTS FOR ST. LUCIE-1 AND -2 12.1 Evaluation q
Florida Power and Light Company, licensee for St. Lucie-1 and -2, l
responded to the Generic Letter on November 8, 1983.
The licensee's response confirms that St. Lucie is designed to permit on-line testing of the Reactor Trip System and that monthly on-line testing of the RTS, including independent testing of the shunt and undervoltage trip attach-ments, is performed.
12.2 Conclusion We find that the licensee's statement that they currently perform on-line testing of the RTS meets the staff position on Item 4.5.2 of the Generic Letter and is, we believe, acceptable.
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REVIEW RESULTS FOR WATERFORO-3 i
9.1 Evaluation Louisiana Power and Light, the licensee for Waterford-3, provided responses to Item 4.5.2 of the Generic Letter on November 4, 1983, and August 12, 1987.
In those responses, the licensee states that Waterfo'rd is designed to permit on-line testing of the Reactor Trip System, and that the applicable procedure is being revised to include the required functional testing of the diverse trip features. The latter response also states that the Waterford design includes the capability to perform independent on-line verification of the shunt and undervoltage trip attachment operability.
9.2 Conclusion We find that the licensee's statement that Waterford-3 is designed to permit on-line testing of the RTS meets the staff position on Item 4.5.2 of the Generic Letter and is, we believe, acceptable.
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- 11. ' REVIEW RESULTS FOR WNP-3 11.1 Evaluation Washington Public Power Supply System, the applicant'for WNP-3, responded to Item 4.5.2 of the Generic Letter on August 23, 1983.
In that response, the applicant states that construction of WNP-3 is currently delayed and that it is not possible to commit to-a schedule for compliance with the requirements of Generic Letter 83-28.
11.2 Conclusion 1
Item 4.5.2 of the Generic Letter will be resolved for WNP-3 during the review and approval process subsequent to resumption of ce struction and licensing ictivities for WNP 3.
Therefore, we consider this Item to be closed for this evaluation.
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GROUP CONCLUSION We conclude that the. licensee / applicant responses for the listed CE plants for Item 4.5.2 of Generic Letter 3-28 are acceptable.. NP 3 is in W
a state of extended construction delay and the staff has closed this Item for this evaluation because it will be resolved during the resumption of licensing activities.
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REFERENCES i
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NRC Letter, D. G. Eisenhut to all licensees of Operating Reactors, Applicants for Operating License, and Holders of Construction Permits,
" Required Actions Based on Generic Implications of Salem ATWS Events t
(Generic Letter 83-28)," July 8, 1983, 2.
Generic Implications of ATWS Events at the Salem Nuclear Power Plant NUREG-1000, Volume 1, April 1983; Volume 2 July 1983.
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Arkansas Power and Light Company letter to NRC, J. R. Marshall to D. G. Eisenhut, Director, Division of Licensing, NRC, " Arkansas Nuclear One Response to Generic Letter 83-28," November 5,1983.
4.
Baltimore Gas and Electric letter to NRC, A. E. Lundvall to D. G. Eisenhut, Director, Division of Licensing, November 5, 1983.
5.
Baltimore Gas and Electric letter to NRC, A. E. Lundvall to D. G. Eisenhut, Director, Division.of Licensing, February 29, 1984.
6.
Dmaha Public Power District letter to NRC, W. C. Jones to O. G. Eisenhut, Director, Division of Licensing, NRC, " Required Actions Based on Generic Implications of Salem ATWS Events (Generic Letter 83-28)," November 4, 1983.
7.
Maine Yankee Atomic Power Company letter to NRC, C. D. Frizzle to Director of Nuclear Reactor Regulation, NRC, " Required Actions Based on Generic Implications of Salem ATWS Events (Generic Letter 83-28),"
November. 10, 1983.
8.
Northeast Utilities letter to NRC, W. G. Counsil to D. G. Eiser. hut, Director, D,ivision of Licensing, November 8,1983.
9, Northeast Utilities letter to NRC, E. J. Mroczka to Document Control Desk, " Generic Letter 83-28, Salem ATWS," Novemoer 8,1983.
10.
Consumers Power Company letter to NRC, James L. Kuemin to Director, Nuclear Reactor Regulation, " Supplemental Response to Generic Letter 83-28," July 1, 1985.
- 11. Arizona Public Service Company letter to NRC, E E. Van Brunt, Jr., to Director, Nuclear Reactor Regulation, Novemoer 3,1983.
12.
Southern California Edison Company letter to NRC, F. R. Nandy to Director, Office of Nuclear Reactor Regulation, " Response to Generic Letter 83-28," November 29, 1983.
13.
Southern California Edison Company letter to NRC, M. O. Medford to Director, Office of Nuclear Reactor Regulation, October 2, 1985.
14 Southern California Edison Comoany letter to NRC, M. O. Medford to Document Control Desk, June 18, 1987.
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Florida Power and Light Company letter to NRC, J. W. Williams, Jr., to f
e O. G. Eisenhut, Diractor, Division of Licensing, " Generic Letter 83-28," November 8, 1983.
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Louisiana Power and Light letter to NRC, K. W. Cook to D. G. Eisenhut, 1
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Director, Division of Licensing, " Required Actions Based on Generic Implications of Salem ATWS Events (Generic Letter 83-28)," November 4, 1983.
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Louisiana Power and Light letter to NRC, K. W. Cook to Document Control Desk, " Response to Generic Letter 83-28, Item 4.5.2, Reactor i
l-Trip System Reliability," August 12, 1987.
- 78. Washington Public Power Supply System letter to NRC, G. C. Sorenson to Director, Division of Licensing, " Nuclear Project No. 3, Response to Generic Letter 83-28, Salem ATWS Event," August 23, 1983.
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