NRC Generic Letter 1985-09

NRC Generic Letter 1985-009: Technical Specifications for Generic Letter 1983-028, Item 4.3

ML031140404
Person / Time
Site:	Beaver Valley, Millstone, Salem, Mcguire, Indian Point, Kewaunee, Catawba, Harris, Point Beach, Watts Bar, Sequoyah, Braidwood, Summer, Prairie Island, Seabrook, Surry, North Anna, Turkey Point, Haddam Neck, Ginna, Diablo Canyon, Callaway, Vogtle, Waterford, Farley, Robinson, South Texas, San Onofre, Cook, Comanche Peak, Yankee Rowe, Zion, McGuire, 05000000, Trojan
Issue date:	05/23/1985
From:	Thompson H L Office of Nuclear Reactor Regulation
To:
References
GL-83-028 GL-85-009, NUDOCS 8505210122
Download: ML031140404 (17)

aNt IL J X :.UNITED STATES ..NUCLEAR REGULATORY COMMISSION--- i WASHINGT0ND.C.20555 --.May 23, 1985TO ALL WESTINGHOUSE PRESSURIZED WATER REACTOR LICENSEES AND APPLICANTSGentlemen:SUBJECT: TECHNICAL SPECIFICATIONS FOR GENERIC LETTER 83-28, ITEM 4.3(Generic Letter 85-09)Reference: "Safety Evaluation, Generic Westinghouse Modificationsfor Reactor Trip System Automatic Actuation Using ShuntCoil Trip Attachments;' August 10, 1983, Letter fromDarrell G. Eisenhut, Director, Division of Licensingto J. J. Sheppard, Chairman, Westinghouse Owners Group.Item 4.3 of Generic Letter 83-28, "Required Actions Based on GenericImplications of Salem ATWS Events," established the requirement for theautomatic actuation of the shunt trip attachment for Westinghouse plants.Also, licensees are to submit any needed Technical Specification changerequests as soon as practical following staff review and approval of themodified design.In the staff's evaluation of the Westinghouse generic design modifications(reference), the staff concluded that Technical Specification changes shouldbe proposed by licensees to explicitly require independent testing of theundervoltage and shunt trip attachments during power operation and independenttesting of the control room manual switch contacts during each refuelingoutage. The staff concluded that these tests are necessary to ensure reliablereactor trip breaker operation. In the staff's review of the plant-specificresponses to the generic letter, some licensees have indicated that changesto the Technical Specifications are not required for their plants. In suchcases, the staff has found that the existing Technical Specifications do notaddress the concerns mentioned above and the staff has indicated that therequired Technical Specification changes should be submitted.Therefore, licensees are requested to submit proposed Technical Specificationchanges which are responsive to the guidance noted in the enclosure. Theenclosed guidance will be used to revise the Standard Technical Specificationsfor Westinghouse plants, and it will be used by the staff as a basis to reviewchanges to Technical Specifications submitted by licensees and for the reviewof proposed Technical Specifications for operating license applications.For plants which have implemented the shunt trip modifications, a schedule forsubmittal of proposed Technical Specification changes should be establishedthrough discussions with the individual Project Manager for each facility.In addition, discussions with the individual Proejct Managers should establisha schedule for plants which have not implemented the shunt trip modifications.Proposed Technical Specifications should be submitted as soon as practicalfollowing staff review and approval of the modified design. For operatinglicense applicants, proposed Technical Specifications should include requiremen_ owhich are responsive to the enclosed guidance. a {t! --^ -'_0,5'06210 /Z -ZI

ENCLOSURETECHNICAL SPECIFICATION CHANGESFOR REACTOR TRIP BREAKERS(WESTINGHOUSE PLANTS)

BACKGROUND

As a consequence of the Salem ATWS event, Item 4.3 of Generic Letter 83-28established the requirement for the automatic actuation of the shunt tripattachment for reactor trip breakers. Further, licensees are to submit anyneeded technical specification change requests prior to declaring the modifiedsystem operable. A number of the responses from operating reactors haveindicated that no technical specification changes are required.The staff has reviewed the guidance provided in the Standard TechnicalSpecifications (STS) for Westinghouse Plants, NUREG-0452, and finds thatadditional clarification of both the limiting conditions of operation andsurveillance requirements are appropriate as a result of the staff'sevaluation of design modifications to include automatic actuation of theshunt trip attachments. The STS for Westinghouse plants will be revisedto include the changes noted herein. Pending formal revision of the STS,this document provides guidance to licensees and operating license applicantson appropriate technical specifications in response to Item 4.3 of theGeneric Letter.

\.- I-2-DISCUSSIONThe operability requirements for the reactor trip breakers are specified inTable 3.3-1 of the STS. The specification states that both reactor tripbi-eakers shall be operable in Modes 1 and 2. In addition, both breakers areto be operable when in Modes 3, 4, and 5 if the breakers are in the closedposition and the control rod drive system is capable of rod withdrawal. Theaction statements for an inoperable breaker require that the plant be in atleast hot standby within six hours for Modes 1 and 2, and that the breaker berestored to operable status in 48 hours5.555556e-4 days <br />0.0133 hours <br />7.936508e-5 weeks <br />1.8264e-5 months <br /> or opened in the next hour when operatingin Modes 3, 4, or 5.With the addition of the automatic actuation of the shunt trip attachment (STA),diverse features exist to effect a reactor trip for each breaker. If one ofthese diverse trip features is inoperable, a decision would have to be made withregard to the operability status of the reactor trip breaker. The definitionof OPERABLE-OPERABILITY in Section 1.0 of the STS states that a component shallbe operable or have operability when it is capable of performing its safetyfunction. Since either trip feature being operable would initiate a reactortrip on demand, it would be overly conservative to treat a breaker as inoperableif one of these diverse trip features were inoperable. However, on the otherhand, the reliability of the reactor trip system would be reduced if eachdiverse trip feature is not maintained in an operable status.

-3-The reactor trip breaker surveillance test should independently verify theoperability of the shunt and undervnltage trip features of the reactor tripbreakers as part of a single sequential test procedure. Therefore, thesurveillance test which Identifies a failure of one diverse trip featurealso confirms the operability of the other trip feature. As a consequence,there is a high degree of confidence that the operable trip feature wouldbe capable of initiating a reactor trip in the next 48 hours5.555556e-4 days <br />0.0133 hours <br />7.936508e-5 weeks <br />1.8264e-5 months <br />. Accordingly,an additional action statement will be included in the STS for the reactor tripbreakers to permit continued plant operation for up to 48 hours5.555556e-4 days <br />0.0133 hours <br />7.936508e-5 weeks <br />1.8264e-5 months <br /> with one ofthe diverse trip features inoperable before further action needs to betaken. The additional action statement is as follows:ACTION -With one of the diverse trip features (undervoltage orshunt trip attachment) Inoperable, restore it to OPERABLE statuswithin 48 hours5.555556e-4 days <br />0.0133 hours <br />7.936508e-5 weeks <br />1.8264e-5 months <br /> or declare the breaker inoperable and applyACTION 12. The breaker shall not be bypassed while one of thediverse trip features is inoperable except for the time requiredfor performing maintenance to restore the breaker to OPERABLE status.The Westinghouse generic design modification includes test features whichpermit the independent testing to verify the operability of the shunt andundervoltage trip attachments. Some licensees have proposed changes to thesurveillance requirements specified in Table 4.3-1 to specifically note the

-4 -requirement for independent testing of the diverse trip features. As notedabove, operability as applied to the diverse trip features of breakers mayhave different degrees of safety significance. In order to be consistent withthe intent of the test features provided, the following notation will beincluded in Table 4.3-1 for reactor trip breakers:"The TRIP ACTUATING DEVICE OPERATIONAL TEST shall independentlyverify the OPERAFILITY of the undervoltage and shunt tripattachments of the Reactor Trip Breakers."In the evaluation of Westinghouse generic design, the staff noted that theprocedures for testing the breakers did not include verification of theoperability of the control room manual reactor trip switch contacts and wiringin the manual initiation circuits. However, it was noted that a procedure forthis test was being developed by Westinghouse Owners Group. In its conclusions,the staff noted that licensees should propose technical specification changesto explicitly provide for periodic independent testing of the control roommanual switch contacts during each refueling outage.Table 4.3-1 of the STS specifies that the manual reactor trip function betested at least once per 18 months. However, unlike the modification forautomatic actuation of the shunt trip attachments, test features are notincorporated in the design for most plants to facilitate the independenttesting of the shunt and undervoltage trip circuits for the manual reactortrip function. As noted in the staff's evaluation of the Westinghouse generic

-5-design, the surveillance tests for the manual reactor trip may be performedin a manner to verify the operability of the reactor trip switch contacts andwiring to the circuit breakers. This test may be performed by voltagemeasurements at terminal blocks of the reactor trip breakers and it is notnecessary to physically trip the breakers during this test.Two precautions are applicable if this method of testing is implemented. Oneis that the "Block auto shunt trip" switch would have to be used to precludesensing the application of power to the shunt trip coil via the automatic shunttrip feature. The second is that with the breaker in a tripped condition,voltage would be measured across the combination of the shunt trip coil andseries breaker "a" auxiliary contact due to the presence of the breaker closedposition status light located in parallel with the normally open manual reactortrip switch contacts. If voltage measurements are used for this test, theindicating light would have to be removed or other appropriate action takensuch that measurements would not be ambiguous.Therefore, the following notation will be added to Table 4.3-1 of the STS tobe consistent with the intent of the staff's evaluation of the manual reactortrip function:"The TRIP ACTUATING DEVICE OPERATIONAL TEST shall Independentlyverify the OPERABILITY of the shunt and undervoltage trip circuitsfor the Manual Reactor Trip Function."

-6-The current STS do not address surveillance requirements for the reactor tripbypass breakers. In the evaluation of the Westinghouse generic design modifi-cations, the staff noted that it would require that the operability of the bypassbreakers be verified prior to it being placed into service. In response to thisrequirement, some licensees have noted that the bypass breakers are maintainedin a racked out position during normal operation and the required testing isperformed by moving the breaker to the test position. In the test position, theoperability of the shunt trip attachment is verified via the local shunt tripswitch at the breaker. Following this test, the breaker is racked into theoperate position and closed to permit testing of its associated reactor tripbreaker. Since the operation of the undervoltage trip attachment for the bypassbreakers are actuated by the opposite train of the protection systems, it hasbeen proposed to test this feature during refueling outages. Finally it wasnoted that the testing of the manual reactor trip function which is performedduring refueling outages includes operation of the bypass breakers to verifythe operability of the manual trip circuit(s).The staff conclusion is that the above proposed methods for testing bypassbreakers is acceptable. The basis for this conclusion includes recognitionof the fact that a readily available means does not exist to permit testing ofthe automatic trip feature of bypass breakers and that confirmation of theoperability of the shunt trip attachment when the breaker is placed in serviceprovides additional assurance that the bypass breaker could be tripped via amanual reactor trip. Therefore, if a bypass breaker is not tripped via itsundervoltage trip attachment due to a valid automatic trip signal during breakertesting, or a manual reactor trip is intentionally initiated, greater assurancewill be provided for the capability to trip a bypass breaker.

-7 -As a consequence of the staff review of Westinghouse plants with relay logicit was recognized that for some plants the manual reactor trip function doesnot actuate the shunt trip attachment of bypass breakers, but rather theundervoltage trip attachment. Further, the capability is provided from theprotection system racks to individually trip each bypass breaker manually.Therefore, for plants with this design the bases for testing the operabilityof bypass breakers, when they are placed in service for testing of reactortrip breakers, would be met by a trip of the undervoltage trip attachment ofthe bypass breakers initiated manually from the protection system racks.Also with regards to the test of the manual reactor trip function for plantswith this design, this test should confirm the operability of the undervoltagetrip.Accordingly, Table 4.3-1 of the STS will be revised to include surveillancetest requirements for reactor trip bypass breakers as follows:1. Shunt trip attachment operability tests prior to placing thebreaker in service.2. Undervoltage trip attachment operability tests at least once per18 months.3. Manual reactor trip operability tests at least once per 18 mnnths.(l)(1) If the shunt trip attachment is actuated on a manual reactor trip,the test shall independently verify the operability of the undervoltageand shunt trip circuits.

-8-For plants that do not actuate the shunt trip attachment of the bypass breakerson a manual reactor trip, item 1 would be replaced by a remote manual undervoltagetrip attachment operability test when the bypass breaker is placed in servicefor reactor trip breaker testing.Enclosed are marked-up pages of the applicable STS tables with these changes.Until such time that these changes are incorporated in the STS, proposedchanges to plant specific technical specifications will be evaluated by thestaff based on this guidance.For plants which do not have bypass breakers, technical specification changesare not required at this time. The need for any change to technical specificationswill be identified on a plant specific basis following the staff review oflicensee responses to Item 4.5 of Generic Letter 83-28.

.: f ..TABLE 3.3-1 (Continued)REACTOR TRIP SYSTEM INSTRUMENTATIONFUNCTIONAL UNITD. Low Setpoint PowerRange Neutron Flux, P-10E. Turbine Impulse ChamberPressure, P-1321. Reactor Trip Breakers22. Automatic Trip LogicTOTAL NO.OF CHANNELS422222CHANNELSTO TRIP211111MINIMUMCHANNELSOPERABLE3 .tlAPPLICABLEMODES1, 211, 23*, 4*, 5*1, 23*, 4*, 5*ACTION822222812,14131213IfWaWC

• TABLE 3.3-1 (Continued)IACTION STATEMENTS (Continued)ACTION 9 -With a channel associated with an operating loop inoperable,restore the inoperable channel to OPERABLE status within 2 hour2.314815e-5 days <br />5.555556e-4 hours <br />3.306878e-6 weeks <br />7.61e-7 months <br />sor be in at least HOT STANDBY within the next 6 hours6.944444e-5 days <br />0.00167 hours <br />9.920635e-6 weeks <br />2.283e-6 months <br />. Onechannel associated with an operating loop may be bypassed forup to 2 hours2.314815e-5 days <br />5.555556e-4 hours <br />3.306878e-6 weeks <br />7.61e-7 months <br /> for surveillance testing per Specification 4.3.1.1.ACTION 10 -ACTION 11 -ACTION 12 -ACTION 13 -ACTION 14With the number of OPERABLE Channels one less than the MinimumChannels OPERABLE requirement, restore the inoperable channelto OPERABLE status within 2 hours2.314815e-5 days <br />5.555556e-4 hours <br />3.306878e-6 weeks <br />7.61e-7 months <br /> or reduce THERMAL POWER tobelow the P-8 (Power Range Neutron Flux Interlock) setpointwithin the next 2 hours2.314815e-5 days <br />5.555556e-4 hours <br />3.306878e-6 weeks <br />7.61e-7 months <br />. Operation below the P-8 setpoint maycontinue pursuant to ACTION 11.With the number of OPERABLE Channels one less than the MinimumChannels OPERABLE requirement, operation may continue providedthe inoperable channel is placed in the tripped conditionwithin 1 hour1.157407e-5 days <br />2.777778e-4 hours <br />1.653439e-6 weeks <br />3.805e-7 months <br />.With the number of OPERABLE channels one less than the MinimumChannels OPERABLE requirement, be in at least HOT STANDBYwithin 6 hours6.944444e-5 days <br />0.00167 hours <br />9.920635e-6 weeks <br />2.283e-6 months <br />; however, one channel may be bypassed for up to2 hours for surveillance testing per Specification 4.3.1.1,provided the other channel is OPERABLE.With the number of OPERABLE channels one less than the MinimumChannels OPERABLE requirement, restore the Inoperable channelto OPEARABLE status within 48 hours5.555556e-4 days <br />0.0133 hours <br />7.936508e-5 weeks <br />1.8264e-5 months <br /> or open the reactor tripbreakers within the next hour.With one of the diverse trip features (Undervoltage or shunttrip attachment) inoperable, restore it to OPERABLE status within48 hours or declare the breaker inonerable and apply ACTION 12.The breaker shall not be bypassed while one of the diversetrip features is inoperable except for the time required forperforming maintenance to restore the breaker to OPERABLE status.W-STS3/4 3-9 s vI£CATABLE 4.3-1INSTRUMENTATION SURVEILLANCEREACTOR TRIP SYSTEM-1.9FUNCTIONAL UNIT1. Manual Reactor Trip2. Power Range, Neutron FluxHigh SetpointLow Setpoint3.. Power Range, Neutron Flux,High Positive Rate4. Power Range, Neutron Flux,High Negative Rate5. Intermediate Range,Neutron Flux6. Source Range, Neutron Flux7. Overtemperature AT8. Overpower AT9. Pressurizer Pressure--Low10. Pressurizer Pressure--High11. Pressurizer Water Level--High12. Loss Of FlowCHANNELCHECKN.A.S(9)S(9)N.A.N.A.S(9)S(9)SSSSSSCHANNELCALIBRATIONN.A.D(2,M(3,Q(4,R(4,R(4)R(4)4),4),6),5)R(4)R(4, 5)R(4, 5)RRRRRRANALOGCHANNELOPERATIONALTESTN. A.NNNNS/U(l),M5/Ui ) ,M(9)NNNNNNEQUIREMENTSTRIPACTUATINGDEVICEOPERATIONALTEST.R(11)N.A.N.A.N.A.N.A.N.A.N.A.N.A.N.A.N.A.N.A.N.A.N.A.ACTUATIONLOGIC TESTN. A.N. A.N. A.N. A.N. A.N. A.N. A.N. A.N. A.N. A.N. A.N. A.N. A.I###, 21, 21, 21fff, 2 22##, 3, 4, 51, 21, 211, 21IMODES FORWHICHSURVEILLANCEIS REQUIRED1, 2, 3*, 4*, 5*1, 2C

0II.:-4CA9TABLE 4.3-1 (Continued)M INSTRUMENTATION SURVEILLANCEREACTOR TRIP SYSTEI.-CHANNELFUNCTIONAL UNIT CHECKD. Low Setpoint Power RangeNeutron Flux, P-10 N.A.E. Turbine Impulse ChamberPressure, P-13 N.A.21. Reactor Trip Breaker N.A.22. Automatic Trip Logic N.A.23. Reactor Trip Bypass Breaker N.A.CHANNELCALIBRATIONR(4)RN.A.N.A.N.A.ANALOGCHANNELOPERATIONALTESTM (8)M (8)N.A.N.A.N.A.REQUIREMENTSTRIPACTUATINGDEVICEOPERATIONAL A(TEST UN. A.N. A.M (7X12)N.A.M(13),R(14)TUATION)GIC TESTN. A.N. A.N. A.M (7)N.A.MODES FORWHICHSURVEILLANCEIS REQUIRED1, 21C1,1,2, 3*, 4*, 5*12, 3*, 4*, 5*Ws-co1, 2, 3*, 4*, 54C

TABLEA4.3-1 (Continued)TABLE NOTATION-. With the reactor trip system breakers closed and the control roddrive system capable of rod withdrawal.#1 -Below P-6 (Intermediate Range Neutron Flux 'Interlock) setpoint.#- Below P-10 (Low Setpoint Power Range Neutron Flux Interlock) setpoint.(1) -If not performed in previous 7 days.(2) -Heat balance only, above 15% of RATED THERMAL POWER. Adjust channelif absolute difference greater than 2 percent.(3) -Compare incore to excore axial flux difference above 15% of RATEDTHERMAL POWER. Recalibrate if the absolute difference is greaterthan or equal to (3) percent.(4) -Neutron detectors may be excluded from CHANNEL CALIBRATION.(5) -Detector plateau curves shall be obtained and evaluated. For theIntermediate Range and Power Range Neutron Flux Channels the provisionsof Specification 4.0.4 are not applicable for entry into MODE 2 or 1.(6) -Incore -Excore Calibration.(7) -Each train shall be tested at least every 62 days on a STAGGEREDTEST BASIS.(8) -With power greater than or equal to the interlock setpoint the requiredOPERATIONAL TEST shall consist of verifying that the interlock is inthe required state by observing the permissive annunciator window.(9) -Monthly Surveillance in MODES 3*, 4* and 5* shall also includeverification that permissives P-6 and P-10 are in their requiredstate for existing plant conditions by observation of the permissiveannunciator window.(10) -Setpoint verification is not applicable.(11) -The TRIP ACTUATING DEVICE O"ERATIONAL TEST shall indeoendently verifythe OPERABILITY of the undervolta'e and shunt trip circuits for theManual Reactor Trip Function. The test shall also verify the OPERABILITYof the Bypass Breaker trip circuit(s).(12) -The TRIP ACTUATING DEVICE OPERATIONAL TEST shall independently verifythe OPERABILITY of the undervoltage and shunt trip attachments of theReactor Trip Breakers.(13) -Local manual shunt trip prior to placing breaker in service. (Or forplants that do not actuate the shunt trip attachment of the bypassbreakers on a manual reactor trip): Remote manual undervoltage tripwhen breaker placed in service.(14) -Automatic undervoltage trip.W-STS 3/4 3-15 I- , ...1 --%. i ,W I.0LIST OF RECENTLY ISSUED GENERIC LETTERSGENERICLETTER NO.84-2084-2184-2284-23_84-2485-0185-0285-0385-0485-0585-0685-0785-0885-0985-10SUBJECTScheduling Guidance for Licensee Submittalsof Reloads that Involve Unreviewed SafetyQuestionsLong Term Low Power Operation in PWR'sNot usedReactor Vessel Water Level Instrumentationin BWRsClarification of Compliance to 10 CFR 50.49Environmental Qualification of ElectricalEquipment Important to Safety for NuclearPower PlantsFire Protection Policy Steering CommitteeReportStaff Recommended Actions Stemming From NRCIntegrated Program for the Resolution ofUnresolved Safety Issues Regarding SteamGenerator Tube IntegrityClarification of Equivalent Control CapacityFor Standby Liquid Control SystemsOperator Licensing ExaminationsInadvertent Boron Dilution EventsQuality Assurance Guidance for ATWSEquipment that is not Safety-RelatedImplementation of Integrated Schedulesfor Plant Modifications10 CFR 20.408 Termination Reports -FormatTechnical Specifications for GenericLetter 83-28, Item 4.3Technical Specifications for GenericLetter 83-28, Items 4.3 and 4.4DATE8/20/8410/16/8410/26/8412/27/841/9/854/15/851/28/851/29/851/31/854/16/855/02/855/23/855/23/85I5/23/85

.;; .I .-,r.IThis request for information was approved by the Office of Management andBudget under clearance number 3150-0011 which expires April 30, 1985.Should you have any questions, the staff contact is John Hannon. Mr. Hannoncan be reached on (301)492-8543.Hugh L. Thompson, Jr., DirectorDivision of LicensingEnclosure:Sample TechnicalSpecificationsORAB 1iDLTAlexio annon3/4/85 3/4 /85-* D/DLHThompson3/1 /85Trher/ /5G lahan3/1 /85ICSB/D-FRosa3/3/85ADCtchfield3/ 685 I .N t Aii-2 -This request for information was approved by the Office of Management andBudget under clearance number 3150-0011 which expires April 30, 1985.Should you have any questions, the staff contact is Rudy Karsch. Mr. Karschcan be reached on (301)492-8563.orelgInal SIged by'"t hC 2'.ThRpmpon, Jr., DirectorDivision of LicensingEnclosure:Sample Technical Specifications*PREIVOUS CONCURRENCE SEE DATEORAB:DL*TAlexion:dm3/4/85ORAB:DL*JHannon3/6/85TSRG*EButcher3/5/85C:ORAB:DL*GHolahan3/7/85ICSB:DSI*FRosa3/5/85AD/SA:DL*DCrutchfield3/12/85D/DL rHThompsonV I/85