ML20028F558
| ML20028F558 | |
| Person / Time | |
|---|---|
| Site: | Crystal River  |
| Issue date: | 01/24/1983 |
| From: | Office of Nuclear Reactor Regulation |
| To: | |
| Shared Package | |
| ML20028F557 | List: |
| References | |
| TAC-49356, NUDOCS 8302020158 | |
| Download: ML20028F558 (3) | |
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SAFETY EVALUATION BY THE OFFICE OF NUCL' EAR REACTOR REGULATION SUPPORTING AMENDftE!!T NO.61 TO FACILITY OPERATIrlG LICENSE NO. DPR-72 FLORIDA POWER CORPORATION, ET AL CRYSTAL RIVER UNIT NO. 3 NUCLEAR GENERATING PLANT DOCKET NO. 50-302 Introduction By letter dated January 14,1933, as supplemented January 20,1933, Florida Power Corporation (FPC or the licensee) proposed a change to the Crystal River Unit 3 (CR-3) Technical Specifications (TSs). This TS change provides for the deferment of certain montnly channel functional tests of engineered safeguards components until CR-3 is shutdown for Reload IV.
Background
By Special Report dated December 23, 1982, FPC notified the NRC of failure to meet the plant Technical Specification. requirements for monthly testing of the Engineered Safeguard Features (ESF) system. As stated in the FSAR, the plant was designed to comply with IEEE Standard 270 1071 and Regulatory Guide 1.22 so that the channel functional tests could be perfonned at power.
As operating experience was gained, the licensee noted that operating certain ESF equipment at full power was inducing transients, saused at least two shutdowns and introduced several potential adverse conditions.
As a result, the licensee ceased performing monthly fun,ctional tests for most manual initiation and automatic actuation logic testing of the ESF -
systems.
Included with the Technical Specification Change Request FPC provided a proposed program to arrive at a permanent solution to provide an adequate test program. The program includes development'of. appropriate surveillance tests before restart from the next refueling outage to allow safe and reliable testing during the next fuel cycle. Also, a detailed review of ESFAS testability would be conducted to detennine what actions are neces-sary to allow optimum testing of the ESF system on a schedule to support per-fonnance of any needed plant modification in the subsequent refueling outage.
In support of the request, FPC staff met with NRC staf'f in Bethesda on January 17, 1983 to discuss the design of the CB.-3 ESE system and the pro,
posed changes.
Evaluation The licensee has requested a change to the CR-3 Technical
- Specifications so that the channel functional test: for the manual initiation of the Engineered Safeguards System will be performed on a refueling outage frequency in lieu l
of monthly during power operation. Additional 19, the licensee requested that automatic actuation logic testing that actuates equipment be deferred until the next refueling outage.
In support of this request, FPC has provided justification for not opwating EFS actuated equipment during the monthly tests.
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The design of the CR-3 ESF system is such that tasting of automatic actuation
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logic will actuate certain test groups. Thers is no inherent capability to block the test signal to the groups of actuated equipment.
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The design'of the 'CR-3 ESF consists of redundant sensor channels which initiate protective actions on a tri'p of two of the three redundant channels. A channel trip results in deenergizing two _(or more) output relays associated 1
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with each channel. Contacts from three redundant channel output relays are configured in a matrix to actuate equipment for one train for each ESF system.
A separate output relcy from each channel is used to. operate equipment in the-redundant train for each ESF system.
Each sensor channel is tested inonthly in accordance with plant Technical Specification.
These tests confirm the opera-bility of the channel including its output relays, which are con'fimed by a light, actuated by one of the relay's contacts.
The testing that confirms the continui?/ of the matrix logic contacts includes features that permit deenergizing channel output relays associated with one train of an ESF system. The automatic actuation logic testing perfomed in.
this manner includes only a limited numbar of ESF components per test so that full ESF system actuation does not occur. However, since the matrix of sensor l
channel contacts are used directly to actuate individual components, the only verification for operability of the logic is the change in state of each component.' This testing of the automatic actuation logic requires that.each component be operated three times to include each two out of three combination.
When manual initiation testing is included, all components are again operated through a complete cycle. FPC has not conducted the monthly testing of manual 1rt tiation and automatic actuation logic circuits of the ESF systems and has i
requested that these requirenents be waived until the next refueling outage.
presently scheduled for March,1983.
Regulatory Guide 1.22. " Periodic Testing of Protection System Actuation Functions" provides guidance where testing results in operation of equip-ment associated with a protective function that may damage plant equipment or disrupt reactor operation.
In such cases, the staff has allowed excep -
tions to system testing when there are compelling reasons for not testin~g the actuated equipment and when the probability that the protection system will fail is acceptably low.
In its evaluation "f the proposed change, FPC provided an evaluation of potential adverse consequences that testing of actuated components in various groups could have. Based on its review, the !!RC staff concludes that a sufficient basis has been provided for not testing the actuated equipment group in the interim period until the next refueling outage.
l The testing for which relief has been requested involves the protection l
system logic and actuated components. With regard to the actuation logic,.
it is concluded that the most probable failure mode of the logic matrix relays would be revealed during the sensor channel testing which is conducted monthly. With regard to the actuated components, FPC has noted that
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most of those components are tested individually each month under its inservice inspection program for pump and valves. All but two ESF actuated components have been tested to demonstrate their operability as recently as l
December 17, 1982 or January 5,1983.
Further, the current ASME Code for 1
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inservice inspection only requires quarterly testing of components. In that the time to the next refueling outage will not deviate from these requirements, the staff concludes that the probability of failures is acceptably low and that the conthly inservice sinspection program will verify the operability of the least reliable components of the ESFAS.
With regard to the specific form in which the Technical Specifications -
have been modified, the licensee has concurred sdth the changes incorporated.
We conclude the, proposed changes a_re acceptable.
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Environmental Consideration We have detennined that the amendment does not authorize a change in effluent types or total amounts nor an increase in power level and will not result in any significant enviromnental' impact. Having made this determination, we have further concluded that the amendment involves an action which is insignificant from the standpoint of environmental impact and, pursuant to 10 CFR 551.5(d)(4), that an environmental impact statement, or negative declaration and environ-mental impact appraisal need not be prepared in connection with the issuance of this amendment.
Conclusion We have concluded, based on the considerations discussed above, that:
(1) because the amendment does not involve a significant increase in the probability or consequences of an accident previously evaluated, does not create the possibility of an accident of a type different from any evaluated previously, and does not involve a significant reduction in a margin of safety, the amendment does not involve a significant hazards consideration, (2) there is reasonable assurance that the health and safety of the public will not be endangered by operation in the proposed manner, and (3) such activities will be conducted in compliance with the Commission's regulations and the issuance of this amendment will not be inimical to the common defense and security or to the health and safety of the public.
Dated: January 24, 1983 The f6110 wing NRC personne1 have contributed to this Safety Evaluation:
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'M. Fairtile, M. Wigdor, T. Dunning.
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