View source for B11796, Forwards Response to Generic Ltr 85-09 Requesting Proposed Tech Specs Needed to Meet Requirements of Generic Ltr 83-28, Item 4.3 Re Reactor Trip Sys Reliability.No Changes to Tech Specs Required

{{Adams
| number = ML20198A480
| issue date = 10/18/1985
| title = Forwards Response to Generic Ltr 85-09 Requesting Proposed Tech Specs Needed to Meet Requirements of Generic Ltr 83-28, Item 4.3 Re Reactor Trip Sys Reliability.No Changes to Tech Specs Required
| author name = Fee W, Opeka J
| author affiliation = CONNECTICUT YANKEE ATOMIC POWER CO.
| addressee name = Zwolinski J
| addressee affiliation = NRC OFFICE OF NUCLEAR REACTOR REGULATION (NRR)
| docket = 05000213
| license number = 
| contact person = 
| document report number = B11796, GL-83-28, GL-85-09, GL-85-9, NUDOCS 8511050136
| package number = ML20198A483
| document type = CORRESPONDENCE-LETTERS, INCOMING CORRESPONDENCE, UTILITY TO NRC
| page count = 4
}}

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CONNECTICUT YANKEE ATOMIC POWE R COMP A NY d E R L I N,  CONNECTICUT P o BOR 270   H ARTFOAD. CONNECTICUT 06141-0??0 T ELE PHONE 203 4 65-5000 October 18,1985 Docket No. 50-213 Bil796 Director of Nuclear Reactor Regulation Attn:       Mr. 3. A. Zwolinski, Chief Operating Reactors Branch #5 U.S. Nuclear Regulatory Commission Washington, D.C. 20555 References-        (1)  H. L. Thompson, Jr., letter to Westingbouse PWR Licensees and Applicants, Generic Letter 85-09, dated May 23,1985.
W 7. A. !wolinski letter to W. G. Counsil, dated November 28,
:P (3) L L s,.colinski letter to W. G. Counsil, dated March 14, 1985.
(4) 3.F.OgR.2 fetter to 3. R. Miller, dated May 9,1985.
(5)  W. G. Counsil setter to W. A. Pt.ulson, dated October 4,1984.                        ,
(6)  3. A. Zwolinski letter to 1. F. Opeka, dated July 1,1985.
Gentlemen:
Haddam Neck Plant
(.,*sig.se to Cgric Letter 85-09 and Generic Letter 83-28, Item 4.5.3 In RcMry e (I.), Generic Letter (GL) 85-09, licensces were requested to submit propor.' To ci.racal Specifications needed to meet the requirements of GL 83-23, item to plant  4.3T6cr ve4'.nical Specifications as concluded in the            w.ng follo  ithe guidance excerpt  from            provided Reference (2,v "In respon. 3 to item 4.3, Reactor Trip System Reliability (Automatic Actuation of Shunt Trip Attachments for Reactor Trip Breakers), you 8(CYAPCO) noted that the original design included actuation of the inndervoltage and shunt trip attachments of the reactor trip breakers by the protection system as well as by a manually initiated reactor trip and that these trip features are designated as safety-related.
Since design changes are not required in order to conform to the requirements of Item 4.3 of the generic letter, there are no corresponding change requirements related to the plant technical specifications."
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Therefore, unless notified otherwise, no further action will be taken in response to Reference (1).
With regard to item 4.5 (4.5.2 and 4.5.3), Reference (2) acknowledged that the design of the reactor trip system does not include the capability of on-line testing and that independent testing of diverse trip features were performed during planned and unplanned outages. At that time NRC Staff's review was ongoing. In Reference (3), additional information was requested for, among other items, Items 4.5.2 and 4.5.3. Reference (4) pointed out that our response to item 4.5.2 was forwarded via Reference (5).            In Reference (6) under Item 4.2.1, Periodic Maintenance Program for Reactor Trip Breakers (RTB), your SER stated that ICSB is still reviewing our response to 4.5.2 concerning on-line testing of RTBs and that their preliminary review found our position with respect to on-line testing acceptable. If ICSB's final review finds our maintenance interval and position with respect to on-line testing acceptable then bypass breakers will not be required and the open items identified in Reference (3) with respect to Item 4.5.3 should be closed.         With this letter all requests for additional information on Generic Letter 83-28 have been responded to.
During recent conversations with your Staff additional information was requested concerning Item 4.5, (4.5.2 and 4.5.3) Reactor Trip System Reliability. provides our response.
Very truly yours, CONNECTICUT YANKEE ATOMIC POWER COMPANY
                                        . Opeka     /
Senior Vice President By: W. F. Fee Executive Vice President

r Attachment 1

==Reference:==
(1)  W. G. Counsil letter to 3. A. Zwolinski, dated February 1, 1985.
4.5.2      REACTOR TRIP SYSTEM RELIABILITY (SYSTEM FUNCTIONAL TESTING)
Reference (1) (item 4.5.2) provides the technical basis for not requiring on-line testing of reactor trip breakers. The purpose of this attachment is to provide additional information as requested by the Staff.
The first concern raised by the Staff was to verify that the reactor trip breakers are tested upon completion of maintenance and individual shunt trip and undervoltage trip checks. Attached are copies of our preventative maintenance procedures, PMP 9.5-23 and PM 9.5-40.
o    PMP 9.5-23, Rev. 8: Preventative Maintenance of Reactor Trip and Isolation Breakers This       prxedure insures that prescribed preventative maintenance is performed including lubrication and contact surface inspection. Step 6.56 of this procedure requires that procedure PM 9.5 40 be performed.
o    PM 9.5-40, Revision 6: Periodical Functional Test of Reactor Trip Breakers This procedure insures that the shunt trip device and the undervoltage device are tested individually.            After verification that each device operates properly, the breaker is operated 10 times to insure operability.
A complete test of the reactor trip breaker utilizing both procedures will cause the breaker           to be operated approximately 30 times.
The Staff also requested additional information on the reliability of the Haddam Neck reactor trip switchgear breakers. We have reviewed all records documenting reactor trip breaker operability    ,
and noted 176 unscheduled plant shutdowns from power. In addition to the 176 unscheduled shutdowns, approximately 354 operations are estimated due to normal shutdown, testing and maintenance activities. Of a total of 530 operations over a 19 year period, no failure indications or breaker degradation were noted. This data supports our position that the existing reactor trip breakers, coupled with our preventative maintenance program, have proven to be highly reliable devices in our reactor protection system.
Regarding maintenance history, the following is noted:

o    No failures of RTBs to trip or indications of failure have occurred.
o    A thorough maintenance and inspection program has been followed including documented procedures which reference and include the manufacturer instruction books, technical bulletins and correspondence. The program includes the use of manufacturer personnel for breaker maintenance on a routine basis.
Regarding system design, the following is noted:
o     The Haddam Neck Plant RTS design simultaneously de-energizes the undervoltage device and energizes the shunt trip device to insure automatic trip actuation.
o     The RTS breakers.are fail-safe since their control power is 4
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derived from the same 125 volt DC bus that supplies the control rod drive stationary grippers.
1 o     System testing is thorough since present procedures allow for trending and engineering analysis upon failure of a breaker.
In addition, present test procedures operate a breaker approximately 30 times through maintenance and verification requirements.
In summary, the RTBs are trended, evaluated, maintained, and thoroughly tested during each refueling outage. Additionally, the   ~,
RTBs are included on the Shutdown Work List so that periodic testing is done whenever the reactor is shutdown and the testing has not been done in the previous six months. Maintenance and inspection of the RTBs have revealed no indications of failure to i       trip during the past 19 years of operation. The Haddam Neck design actuates both the undervoltage device and shunt trip coil simultaneously which adds reliability to RTB operation. The data revealing no failures in 19 years tends to substantiate a highly reliable design. Modification of the present RTS to allow on-line testing does not seem prudent at this time due to the proven design (no failures) and present trending process of breaker operation. Modification would add complexity to the system, thereby allowing a potential for errors which could needlessly challenge the reactor trip system. The cost of changing the present scheme to allow on-line testing would add negligible safety gain to an already proven reactor trip breaker scheme.
Based on the above, CYAPCO believes that the present RTS scheme, combined with the maintenance, inspection, test, and
,       trending program, provide an acceptable alternative to the i
installation of bypass breakers and on-line testing.

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P'. ,4T 'PER ATIONS REVIEW C0ualTTEE APPROVAL Cennecticut Yankee Preventive Maintenance Procedure
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gg      g No. PM 9.5-40                                        I                                   b-Maintenance                                                                          -
PERIODICAL FUNCTIONAL TEST OF                                fa*
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                                                        ,       APP       BY ST      SUPE INTENDENT nw             . - -
EFFECTIVE DATE                    '
1.0 OBJECTIVE                                                    ~         ~
1.1 This procedure provides the steps necessary to perform periodic functional test on reactor trip breakers.
2.0 LICENSE OR ADMINISTRATIVE REOUIREMENTS 2.1 Nonapplicable.

==3.0 REFERENCES==

3.1 Westinghouse Instruction Book Rod ?ower Supply (CY File M-I-W-3-21).
1 2
3.2 Westinghouse Letter CYS-74-24 dated April 4. 1974 3.3 Connecticut Yankee Accident Prevention Manual.                                        -
3.4 Production Plant Instructions for Clearance Tagging, Electrical and Mechanical.
3.5 Westinghouse Letter, NSD-TB 83-02 Rev. 1 & 83-03.                                       l 4.0 PREREOUISITES 4.1 The Shift. Supervisor shall sign the Checkoff to acknowledge that involved reactor operational personnel are aware that the reactor trip breakers are being taken out of or returned to service.
4.2 Reactor shutdown all control rods fully inserted.
4.3 Rod power supply system tagged out in accordance with the attached Tag List.
4.4 Work Permit has been issued.
4.5 Necessary equipment for cleaning and testing reactor trip breakers
     .                available.
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5.0 PRECACTIOFS 5.1    Ensure reactor trip breakers are oeenergized before cleaning anc inspection.
5.2 Keep hands clear of moving parts of breakers when breakers are required to be operated.
5.3 Comply with Production Plant Instruction fer Clearance Tagging, Electrical and Mechanical.
6.0 PROCEDURE
* 6.1 P,rior to performing any maintenance operate the breakers manually and observe that the undervoltage trip device trips the breaker.                     Record on Check List.
6.2 Clean the reactor trip breakers and the rod power supply MG set isolation breakers with vacuum cleaning and dusting with a brush.
6.3 Visually inspect the breakers and entire enclosure for broken parts, loose bolts, or excessive wear.
6.4 Remove the undervoltage trip device for each breaker to be tested and operate the device manually. Observe manual operation for stickiness or binding. Record on Check List.
    .9  '
6.5 Remove old lubricant from the undervoltage trip device by cleaning with a solvent suitable for use on electrical equipment. (" Swoosh",
Penetone. Arco Cleaner, etc.).
NOTE:        Do not apply the solvent to coils, wires, or other                                ,
9 electrically insulated parts.                                                   i 6.6 Liberally apply lubricant to identified points of the UVTA. (See attachment II for lubrication points.) Manually exercise the UVTA while lubricant is being applied.
NOTE:     .
Insure that lubricant is thoroughly mixed prior to application. Lubricant to be Westinghouse 53701 GW or Holykote M-88.
6.7 Reinstall the undervoltage trip devices.                                                       l 6.8 HOLbPOINTNO. 1 - No work to proceed beyond this point until                                    1 inspector has inspected breakers. Record results on Inspection Plan.
6.9 Operate each breaker manually and observe that it's undervoltage trip device trips the breaker.                                                            ~
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       ,  .5       7.0 TESTING 7.1 Establish cc =unications between switchgear and the control roon.
7.2 If a red tag clearance was issued, remove the tagging.                       If a blue tag clearance was issued continue with Step 7.3.
7.3 Start both rod drive M.G. sets and adjust and output voltage to 125                                  l VCD. Do not close the M.G. set isolation breakers.
l 7.4 Remove the fuses from the shunt trip circuits on A and B reactor trip                                !
breaker.
7.5 Cl'ose one M.G. set isolation breaker.
7.6 Close A and B reactor trip breakers from the main control board.
7.7 Trip the reactor trip breakers from the main control board.                        Observe            !
undervoltage trip device operation and that reactor trip breakers A                                 '
and B open.
7.8 Repeat Step 7.6.                                                                          .
7.9 Repeat Step 7.7.
Q                7.10 Open the M.G. set isolation breaker.
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7.11 Install new fuses in the undervoltage trip circuit and the shunt trip I
circuits for A & B reactor trip breaker (6 fuses required).
NOTE:      "A" trip circuit fuse ASFU1 and ASFU2 "B" trip circuit fuse BSFUI and BSTU2 Under voltage trip circuit fuse UVTUI and UVTU2 7.12 Apply blocking to the reset lever of the undervoltage trip devices on both reactor trip breakers.           Enter in jumper log.
7.13 Close one M.G. set isolation breaker.
NOTE:       Have control room insure there are no reactor trip signals prior to step 7.14, 7.14 Close reactor trip breakers A and B from the main control board.
7.15 Trip reactor trip breakers A and B from the main control board.
7.16 Repeat Step 7.14.
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r.M 9.5-40 Revielen 6
                                                                                                     'n;35A)      CE3 0 1 $2' 7.17 Repeat Step 7.15.
  .<Gs 7.18 Open the MG set isolation breakers.
7.19 Remove blocking on the undervoltage trip devices on reactor trip breakers A and B, clear entry from jumper log.
7.20 Close both MG set isolation breakers.
7.21 Close reactor trip breakers A and B from the main control board.
7.22 Trip reactor trip breakers A and B from the main control board.
7.23 Repeat Step 7.21 and 7.22 ten times.
l 7.24 If the inspection and test was satisfactory, clear all tagging and                                          l complete required sections of Work Permit.
7.25 Job If any part of the inspection or test was unsatisfactory notify the Supervisor.
7.26 Clear tagging if not cleared in Step 7.23.                                                                 l k
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Conrec:icut Yankee prvrentive : nterance Procecure No. p."        c.5-40
               ?IRICLIC 7s"CU C"AL TIST 07 REACTOR TRI? 3REAKERS 8.0 CHECKLIST                                                                 INITIALS 8.1    Involved reactor operational personnel have been informed that reactor trip breakers are being removed from service per Step 4.1.
Shift Supe rvis or                    Date 8.2 Reactor shut down, all rods inserted, per Step 4.2.
8.3 Rod power supply system tagged out per etep 4.3.
8.4 Precautions read and understood.
8.5 Reactor trip breaker undervoltage trip devices
                          .did/did not trip the breakers per Step 6.1.
8.6 Undervoltage trip devices operate satisfactorily per Step 6.4.
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8.7 Vndervoltage trip devices on both reactor trip 'reaker relubricated per Step 6.6. -
l 8.8 Undervoltage trip devices on both MG set isolation breakers relubricated per Step 6.6.                                               l 8.9 Visual inspection satisfactory per Step 6.6.                                        g 8.10 Undervoltage trip devices reinstalled per Step 6.7.
g 8.11 The undervoltage trip devices trip the reactor trip breakers per Step 6.9.
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8.12 The undervoltage trip devices trip the MG set isolation breakers per Step 6.9.
l 8.13 Communications established with control room per Step 7.1.
8.14 Tagging cleared (if applicable) per Step 7.2.
8.15 Both rod drive MG sets started per Stap 7.3.

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1"I T I.'.L S 3.15 Tases re ..al 2 :: ahunt : rip cir:cits en A a 3 Reactor trip breakers per Step 7.4 8.17 One MG set isolation breaker closed.
8.18 A & B reactor trip breakers closed per Step 7.6.
8.19 A & B reactor trip breakers opened undervoltage trip devices operate properly per Step 7.7.
8.20 A a 3 reacter trip breakers close per Step 7.8.
8.21 A'& B reactor trip breakers open. UndervoltaSe trip devices operate per 7.9.
8.22 The MG set isolation breakers open per Step 7.10.
8.23 New fuses installed in the undervoltage and shunt trip circuits per Step 7.11.
8.24 Blocking applied to undervoltage trip devices on both reactor trip breakers per Step 7.12 and entered in jur.per log.
c,           8.25 One MG isolation breaker closed per Step 7.13.
8.26 A & B reactor trip breakers close per Step 7.14.
8.27 A & B reactor trip breakers trip per S'tep 7.15.
8.28 A & B reactor trip breakers close per Step 7.16.
8.29 A & B reactor trip breakers trip per Step 7.17.
8.30 The MG set isolation breakers open per Step 7.18, 8.31 Blocking. removed on the undervoltage trip devices.
Jumper Log entry clear per Step 7.19.
8.32 Both MG set isolation breakers close per Step 7.20.
8.33 A & B reactor trip breakers close per S'tep 7.21.
8.34 A & B reactor trip breaker trip per Step 7.22.
8.35 A & B reactor trip breakers tested per Step 7.23.
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     ^    .                                                                                                        I:!T*.'LS a.36 Test ano inspection satisfactory, tagging cleared per Step 7.24.
8.37 Test and inspection unsatisfactory, Job Supervisor                                                                       i notified per Step 7.25.
8.38 Tagging cleared.                                                                                                          '
8.39 Retest required.
g 8.40 The Shift Supervisor shall acknowledge the testing of                                                                   I 1
section 7.0, has been completed and that he has cycled both reactor trip breakers and observed that they operate properly to prove equipment
* operability.
Shif t Supervisor J
8.41 Involved reactor operational personnel have been                                                                       1 informed that reactor trip breakers are being returned to service per Step 4.1.
Shif t Supervisor                  Date c
9.0 ACCEPTANCE CRITERIA 9.1 Reactor trip breakers A & B undervoltage and shunt trip devices trip the breakers.
9.2 i
MG set isolation breakers undervoltage trip devices trip the breakers when operated manually.
Date Recorded by Electrician                             Date Approved by Job Supervisor                          Date Reviewed by Department Head                         Date eg/.-                                                                                                        I l
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TAG LIST FOR PERICOIC M CTIONAL TEST OF REACTOR TRIP BREAKERS Tag Title                                      Location   Position         Color
: 1. MGl-1A 480V Supply Breaker                                    Bus 4-3A     Open   ,
Red / Blue
: 2. 1.'G-IA 4cCV Supply Breaker DC Control Knife Switch                                       Bus 4-lC     Open         Red / Blue
: 3.   "A" Isolation Breaker close                                  Rod Power Pushbutton.                                                  Supply A      Off          Red / Blue
: 4.  "A" Start Regulator                              -
Rod Power Pushbutton                                                    Supply A      Off          Red / Blue
: 5. MG1-1B 4807 Supply Breaker                                    Bus 7 16A    Open          Red / Blue
: 6. MGl-1B 480V Supply Breaker DC Control Knife Switch                                       Bus 7-18C    Open          Red / Blue "Q       7.  "B" Isolation Breaker close                                   Rod Control
    -12        Pushbutton                                                    Supply B,    Off           Red / Blue
: 8.  "B" Start Regulator Rod Control                                    4 Pushbutton                                                    Supply B     Off           Red / Blue
: 9. Breaker No. 12                                                1A DC Bus    Off          Red / Blue 4
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PH 9.5-40                           REACTOR TRIP AND ISOLATION BREAKERS P;fCEDURE                                                                                                                                                                __. _. , __
gTEMS TO BE INSPECTED                                     IH5PEC110H RESULT 5 LINE HO.                                                                                                                 INSPECTOR SIGN A TURE                                isAit Inspect and verify all breakers tested are ready to be returned to service.
6.8            "lA" isolation breaker 6.8             "lB" isolation breaker 6,8             "A"    reactor trip breaker 6.8              "B"    reactor trip breaker Verify all taes c1 cared. and all breakers and switches                                                _
tagned out have been returned to normal.
Verify all fuses re-installed.
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