ML20151D413

Safety Evaluation Supporting Util 831105 Responses to Generic Ltr 83-28,Item 4.5.2 Re Reactor Trip Sys Reliability Online Testing

ML20151D413
Person / Time
Site:	Arkansas Nuclear
Issue date:	07/12/1988
From:	Office of Nuclear Reactor Regulation
To:
Shared Package
ML20151D411	List: ML20151D410 ML20151D413
References
GL-83-28, NUDOCS 8807250107
Download: ML20151D413 (1)

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/ps,ucoq'o,, UNITED STATES

!" n NUCLEAR REGULATORY COMMISSION g p WASHINGTON, D. C. 20555

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SAFETY EVALUATION BY TdE OFFICE OF NUCLEAR REACT 0P REGULATION

, RELATED TO GENUJC LETTER 83-28, ITriM 4.5.2 1

REACTOR TRIP SYSTEM RELIABILITY, ON-LINE TESTING ARKANSAS POWER AND LIGHT COMPANY ARKANSAS NUCLEAR ONE, UNIT NO. 2 DOCKET NO. 50-368 j

1.0 INTRODUCTION

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SUMMARY

Generic Letter 83-28 was issued by the Nuclear Regulatory Coninission en July 8, 1983, indicating actions to be taken by applicants and licensees based on the generic implications of the Salem ATWS events. Item 4.5 states a staff position which requires on-line functional testing of the l reacter 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 perr.it this i periodic on-line testing to justify not making modifications to permit '

such testing. By .W/two Oversize Diagrams.Aperture Cards Are Available in PDR|letter dated November 5, 1983]], the licensee, Arkansas Power and Light Company, responded to the staff position regarding Item 4.5.2 of Generic Letter 83-28. Our review of this response finds it to be acceptable.

2.0 EVALUATION l

The licensee states that they perform on-line testing of the reactor trip '

system, including independent testing of the undervoltage and shunt trip attachments of the reactor trip breakers.

3.0 CONCLUSION

The staff finds that Arkansas Nuclear One Unit 2 is designed to permit on-line functional testing of the reactor trip system, including independent testing of the diverse trip features of the reactor trip breakers. Thus, the applicant meets the staff position of Item 4.5.2 of Generic Letter 83-28.

Principal Contributor: A. Toalston Dated: July 12,1988 gf2$ho P

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EGG-NTA-7463 TECHNICAL EVALUATION REPORT REACTOR TRIP SYSTEM RELIABILITY CONFORMANCE TO I

ITEM 4.5.2 OF GENERIC LETTER 83-28 i ARKANSAS NUCLEAR ONE, UNIT 2 j CALVERT CLIFFS UNITS 1 AND 2 FT. CALHOUN MAINE YANKEE MILLSTONE UNIT 2 PALISADES PALO VERDE UNITS 1, 2 AND 3 SAN ONOFRE UNITS 2 AND 3 ST. LUCIE UNITS 1 AND 2 WATERFORD SES UNIT 3 WNP 3 I

I F. G. Farmer Published January 9, 1987  !

l hcacter trip mystem IdahoisNational Engineering Laboratory

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Idaho Falls, Idaho 83415 Prepared for the U.S. Nuclear Regulatory Commission Washington, D.C. 20555 Under DOE Contract No. DE-AC07-76ID01570 FIN Nos. D6001 and D6002 f

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ABSTRACT I This EGhG Idaho, Inc. report provides a review of the submittals for l Combustion Engineering (CE) nuclear plants for conformance to Generic Letter 83-28, Item 4.5.2.

The report includes the following plants, all CE, and is in partial fulfillment of the f ollowing TAC Nos. :

Plant Docket Number i TAC Number Arkansas Nuclear One, Unit 2 50-36R 53961 Calvert Cliffs Unit 1 50-317 53969 Calvert Cliffs Unit 2 50-318 53970

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Ft. Calhoun 50-285 53983 Maine Yankee s

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. 50-309 53996 l Millstone Unit 2 50-336 54000 Palisades '

50-255 54009 Palo Verde Unit 1 50-528 59173 Palo Verde Urst 2 (OL) 50-529 N/A Palo Verde Ur,it 3 (DL) 50-530 N/A San Onofre4Lnit 2sev=2upn.wiet us c sees poo361i. 6..c u sc...ge..ers54024 s,.. .e.

Scn Onofre Jni t 3 50-362 54025 St. Lucie I, nit 1 50-335 54028 St. Lucie Unit 2 50-389 54029 Waterford SES Unit 3 (DL) 50-382 57710 WNP 3 (OL) 50-508 N/A l

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FOREWORD This report is provided as part of the program f or evaluating licensee / applicant conformance to Generic Letter 83-28, "Required Actions Based on Generic Implications of Salem ATWS Events. " This work is conducted for the U. S.

Nuclear Regulatory Commission, Office of Nuclear Reactor Regulation, Division of PWR Licensing-A by EG&G Idaho, Inc.

l The U. S. Nuclear. Regulatory Commission funded the work under the I

cuthorization, B&R 20-19-19-11-3, FIN Nos. D6001 and D6002.

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CONTENTS ABSTRACT ............................................................. ii FOREWORD ............................................................. iii

1. INTRODUCTION .................................................... 1

2. REVIEW REQUIREMENTS ............................................. 2

3. GROUP REVIEW RESULTS ............................................ 5 1

4. REVIEW RESULTS FOR ARKANSAS NUCLEAR ONE, UNIT 2 ................. 6

, 4.1 Evaluation ................................................ 6 4.2 Conclusion ................................................ 6

5. REVIEW RESULTS FOR CALVERT CLIFFS UNITS 1 AND 2 ................. 7 5.1 Evaluation ................................................ 7 5.2 Conclusion ................................................ 7

6. REVIEW RESULTS FOR FT. CALHOUN .................................. 8 6.1 Evaluation ................................................ B 6.2 Conclusion ................................................ 8

7. REVIEW RESULTS FOR MAINE YANKEE ................................. 9 7.1 Evaluation ................................................ 9 7.2 Conclusion ................................................ 9

8. REVIEW RESULTS FDR MILLSTDNE UNIT 2.............................. 10 8.1 Evaluation ................................................ 10 8.2 Conclusion ................................................ 10

9. REVIEW RESULTS FOR PALISADES .................................... 11 9.1 Evaluation ................................................ 11 9.2 Conclusion ................................................ 11

10. REVIEW RESULTS FDR PALO VERDE UNITS 1, 2 AND 3 .................. 12

. 10.1 Evaluation ................................................ 12 10.2 Conclusion ................................................ 12 iv

1 1. ' REVIEW RESULTS FOR SAN ONOFRE UNITS 2 AND 3 .................'.... __

13 Evaluation ................................................

11.1 13 11.2 Conclusion ................................................ 13 12.

REVIEW RESULTS FOR ST. LUCIE UNITS 1 AND 2 ...................... 14 12.1 Evaluation ................................................ 14 12.2 Conclusion ................................................ -

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REVIEW RESULTS FOR WATERFORD SES UNIT 3 ......................... 15 13.1 Evaluation ................................................ 15 13.2 Conclusion ................................................ 15 1

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REVIEW RESULTS FOR WNP 3 ........................................ 16 14.1 Evaluation ................................................ 16 14.2 Conclusion ................................................ 16 15.

GROUP CONCLUSION ................................................ 17' 16.

REFERENCES ...................................................... 18 k

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1 TECHNICAL EUALUATION REPORT

• j REACTOR TRIP SYSTEM RELIABILITY l l I CONFORMANCE TO I ITEM 4.5.2 OF GENERIC LETTER 83-28 ARKANSAS NUCLEAR ONE. UNIT 2 CALVERT CLIFFS UNITS 1 AND 2 FT. CALHOUN MAINE YANKEE MILLSTONE UNIT 2 PALISADES PALO VERDE UNITS 1. 2 )ND 3 SAN ONOFRE UNITS 2 AND 3 ST. LUCIE UNITS 1 AND 2 WATERFORD SES UNIT 3 WNP 3

1. INTRODUCTION On July 8, 1983, Generic Letter 83-285 was issued by D. G. Eisenhut, Director of the Division of Licensing, Office of Nuclear Reactor Regulation, j to all licensees of operating reactors, applicants for operating licenses, l end holders of construction permits. This letter included req'uired actions based on generic implications of the Salem ATWS events. These requirements have been published in Volume 2 of FUREG-1000, "Generic Implications of ATWS Events at the Salem Nuclear Power Plant."*

This report documents the EG&G Idaho, Inc. t'eview of the submittals of c11 the CE plants including Arkansas Nuclear One, Unit 2, Calvert Cliffs Units 1 and 2, Ft. Calhoun, Maine Yankee, Millstone Unit 2, Palisades, Palo Verde Units 1, 2 and 3, San Dnof ra Units 2 and 3, St. Lucie Units 1 and 2 Waterf ord SES Unit 3 and WNP 3 for conf ormance to Item 4.5.2 of Generic Letter 83-28. The submittals from the licensees utilized in these ovaluations are referenced in Section 16 of this report.

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2. 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 justif y 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 perf orming on-line testing because of the peculiarities of a particular design. '

l All portions of the Reactor Trip System that do not have on-line l testing capability will be reviewed under the guidelines for this items However, the existence of on-line testability for the Reactor Trip Breaker l 1

undervoltage and, shunt trip attachments on Westinghouse, B&W and CE plants l the silicon controlled rectifiers in the CRDCS on BOW plants; and the scram pilot and backup scram valves on GE plants will only be confirmed hert since they are specifically addressed in Items 4.4 and 4.5.1. Maintenance and testing of the Reactor. Trip Breakers are also excluded from this review, as {

they are evaluated under Item 4.2. This review of the licensee / applicant cubmittals will:

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, with those exceptions addressed above, no further ruview is required.

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Evaluate modifications proposed by licensees / applicants to permit on-line testing against the existing criteria f or the design of the protection systems for the plant being modified.

3. Evaluate proposed alternatives to on-line testing of the Reactor Trip System for acceptability base 4 on the following:

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e. The licansoe/cpplicant cubmittal cubotentiates tha impracticality of the modifications necessary to permit on-line testing, and

b. High Reactor Trip System availability Acomparable to that which would be possible with on-line testing) is achieved in another way. Piy such proposed alternative must be described in detail sufficient to permit an independent evaluation of the basis and 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:

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1. Demonstration by systematic analysis that testing at shutdown intervals prov(des essentially equivalent reliability to that obtained by on-line testing at shorter intervals.

ii. 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 lack of on-line testing, e. g. , one which uses trend analysis and identification of saf ety margins f or critical parameters of safety 1related components. Such a program would require analytical justification suppcrted by test

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4. Verify the capability to perform independent on-line testing of the reactor trip system breaker undervoltage and shunt trip attachments on 3

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Information from licansoas end cpplicents with CE plante

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will be reviewed to verify that they require independent oh-line testing of the reactor trip breaker undervoltage and shunt trip attachments.

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3. GROUP REVIEW RESULTS The relevant submittals from each of the CE reactor plants were l 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 cddressed. Second, the submittals were evaluated to determine the extent to which each of the CE plants complies with the staff guidelines for 1

Item 4.5.2.

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4. REVIEW RESULTS FOR ARKANSAS NUCLEAR ONE, UNIT 2 4.1 Evaluation Arkansas Power and Light Company (AP&L), the license for Arkansas Nuclear One, provided their response to item 4.5.2 of the Generic Letter on November 5, 1983. In that response, the licensee states that AP&L performs on-line tasting of the Reactor Trip System, including independent verification of the shunt and undervoltage trip attachments to the RTBs.

4.2 Conclusion 9

We find that the licensee's statemqnt 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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. 5. REVIEW RESULTS FOR CALVERT CLIFFS UNfTS 1 AND 2 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.

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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6. REVIEW RESULTS FOR FT. CALHOUN 6.1 Evaluation l

The Omaha Public Power District, the licensee for Ft. Calhoun, 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 t' Heactor Trip System, that Ft. Calhoun has contactors rather than reactor tv-ia breakers, and therefore Ft. Calhoun does not have a diverse trip feature.

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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- 7. REVIEW RESULTS,FOR MAINE YANKEE 7.1 Evaluation Maine Yankee Atomic Power Company, the licensee for Maine Yankee, responded to Item 4.5.2 of the Generic Letter on November 10, 1983. In that J recponse 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 Conclusien 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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8. REVIEW RESULTS FOR MILLSIONE UNIT 2 __

l 8.1 Evaluation 1

Northeast Utilities, the licensee f or Millstone 2, responded to Item 4.5.2 of the Generic Letter on November 3, 1983. In that response the licensee states that Millstone 2 performs on-line testing of the Reactor Trip System. However, the response also states that independent testing of the shunt and undervoltage attachments is performed at eighteen month interval s it is not clear from the response that the plant is designed to i

i permit independent on-line verification of operability of the shunt and undervoltage attachments.

B.2 Conclusion We find that the licensee's position on Item 4.5.2 of the Generic Letter is unacceptable. The licensee must confirm that the plant has the capability to perform independent on-line testing of the shunt and undervoltage attachments.

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9. REVIEW RESULTS FOR PALISADES 9.1 Evaluation Consumers Power Company, the licensee for Palisades, responded to 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, that Palisades has contactors rather than reactor trip breakers, and therefore Palisades does not have a diverse trip feature.

9.2 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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10. REVIEW RESULTS FOR PALO VERDE UNITS 1, 2 AND 3 10.1 Evaluation Arizona Public Service Company, the licensee for Palo Verde Unit 1 and cpplicant for Palo Verde Units 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 l of the RTS at Palo Verde 2 and 3 meets the staf f position on Item 4.5.2 of the Generic Letter and is, we believe, acceptable. l l

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11. REVIEW RESULTS FOR SAN ONOFRE UNITS 2 AND 3 -

11.5 Evaluation Southern California Edison Company, tha licensee for San Onofre Units 2 cnd 3, responded to Item 4.5.2 of the Generic Letter on November 29, 1983, and October 2, 1985. In the latter response, the licensee states that the San Onofre Unit 2 and 3 design allows performance of on-line testing of the Reactor Trip System. However, it is not clear from the responses 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 We find that the licensee's responses are inadequate to evaluate the extent of compliance with the staff position on Item 4.5.2 of the Generic Letter and are, therefore, unacceptable. The licensee is required to confirm that the plants have the capability to perf orm on-line independent verification of reactor trip breaker shunt and undervoltage trip attachment operability. .

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. 12. REVIEW RESULTS FOR ST. LUCIE UNITS 1 AND 2 12.1 Evaluation Florida Power and Light Company, licensee for St. Lucie Units 1 and 2 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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13. REVIEW RESULTS FOR WATERFORD SES UNIT 3 I

9.1 Evaluation l

Louisiana Power and Light, the licensee for Waterford 3, provided a response to Item 4.5.2 of the Generic Letter on November 4, 1983. In that

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response, the licensee states that Waterf ord 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. It is not clear from the response that the on-line testing of the diverse trip features includes independent 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 staf f position on Item 4.5.2 of I the Generic Letter and is, we believe, acceptable, provided the licensee l confirms that Waterford 3 has the capability to perform independent on-line verification of the shunt and undervoltage trip attachment operability.

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11. REVIEW RESULTS FOR WNP 3 11.1 Evaluation j 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 I with the requirements of Generic Letter 83-28.

e 11.2 Conclusion Item 4.5.2 of the Generic Letter wi'11 be resolved for WNP 3 during the review and approval process subsequent to resumption of construction and licensing activities f or WNP 3. Therefore, we consider this Item to be closed for this evaluation.

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15. GROUP CONCLUSION I

We conclude that the licensee / applicant responses for' the listed CE plants for Item 4.5.2 of Generic Letter 83-20 are acceptable, with the Gxception of those for Millstone Unit 2, San Onofre Units 2 and 3 and Waterford 3, which were found to be incomplete as indicated in the plant cpecific review results. WNP 3 is in a state of extended construction delay cnd the staff has closed this Item for this evaluation because it will be resolved during the resumption of licensing activities.

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13. REFERENCES

1. NPC 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 (Generic Letter 83-28)," July 8, 1983.

2. Generic Imolications of ATWS Events at the Salem Nuclear Power Plant NUREG-1000, Volume 1, April 1983; Volume 2, July 1983.

3. 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. l Baltimore Gas and Electric letter to NRC, A. E. Lundvs11 to l 4.

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. Omaha Public Power District letter to NRC, W. C. Jones to I D. G. Eisenhut, Director, Division of Licensing, NRC, "Required Actions l 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 83-29)," f November 10, 1983. 1 D. Northeast Utilitias letter to NRC, W. G. Counsil to D. G. Eisenhut,  !

Director, Division of Licensirig, November 8, 1983.

9. Consumers Power Company letterr to NRC, James L. Kuomin to Director, Nuclear Reactor Regulation, "Supplemental Response to Generic Letter 83-28," July 1, 1985.

10. Arizona Public Service Company letter to NRC, E. E. Van Brunt, Jr., to Director, Nuclear Reactor Regulation, November 3, 1983.

11. Southern California Edison Company letter to NRC, F. R. Nandy to Director, Of fice of Nuclear Reactor Regulation, "Response to Generic Letter 83-28," November 29, 1983.

12. Southern Calif ornia Edison Company letter to NRC, M. O. Medford to Director, Of fice of Nuclear Reactor Regulation, October 2, 1985. ,

13. Florida Power and Light Company letter to NRC, J. W. Williams, Jr., to D. G. Eisenhut, Director, Division of Licensing, "Generic Letter 83-28," November 8, 1983.

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14. Louisiana Power and Light letter to NRC, K. W. Cook to D. G. Eisenhut, Director, Division of Licensing, "Required Actions Based on Generic Io.plicatioris of Salem ATWS Events (Generic Letter 83-28),"

November 4, 1983.

15. 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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