ML20212K511

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SER Accepting Licensee 831104 Response to Generic Ltr 83-28, Item 4.5.2, Reactor Trip Sys Reliability,On-Line Testing
ML20212K511
Person / Time
Site: North Anna  Dominion icon.png
Issue date: 02/27/1987
From:
NRC
To:
Shared Package
ML20212K503 List:
References
GL-83-28, NUDOCS 8703090335
Download: ML20212K511 (2)


Text

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ENCLOSURE SAFETY EVALUATION REPORT DOCKET NOS. 50-338/339 NORTH ANNA POWFR STATION, llNITS 1,?

GENERIC LETTER R3-78, ITEM A.5.?

REACTOR TRIP SYSTEM RELIABILITY-ON-LINE TESTING INTRODUCTION ANO SilWARY Generic Letter 83-28 was issued by NRC on sluly 8,1083, indicating actions to be taken by applicants and licensees based on the generic implications of the Salen ATWS 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.? requires applicants and licensees with plants not currently designed to pennit this peri-odic on-line testing to,iustify not making modifications to permit such testing.

By letter dated November 4,1983, the licensee, Virginia Electric and Power Company, responded to the staff position regarding item 4.5.? of Generic Letter 83-28.

Our review of this response finds it acceptable.

EVAltlATION The licensee states that the procedures are being revised at North Anna to in-clude independent testing of the diverse trip features of the reactor trip breakers and, therefore, item 4.5.0 of Generic Letter 83-?8 is not applicable.

Further, staff review under item 4.3 of Generic letter 83 78 of the design j

modifications to the reactor trip breakers has found that the design permits i

independent on-line testing of the undervoltage and shunt trip devices.

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DR ADOCK 05000338 PDR

. CONCLIJSTON The staff finds that the North Anna Power Station, Units 1.0, is desianed to permit on-line functional testing of the reactor trio system, including in-dependent testing of the diverse trip features of the reactor trip breakers.

Thus, the applicant meets the staff position of item 4.5.? of Generic Letter 83-28.

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o EGG-NTA-7459 TECHNICAL EVALUATION REPORT REACTOR TRIP SYSTEM RELIABILITY CONFORMANCE TO ITEM 4.5.2 OF GENERIC LETTER 83-28 JOSEPH M.

FARLEY NUCLEAR PLANT UNITS 1 AND 2 R.

E.

GINNA NUCLEAR POWER PLANT HADDAM NECK PLANT INDIAN POINT UNIT NO. 2 INDIAN POINT 3 NUCLEAR POWER PLANT KEWAUNEE NUCLEAR POWER PLANT NORTH ANNA UNITS 1 AND 2 POINT BEACH NUCLEAR PLANT, UNITS 1 AND 2 PRAIRIE ISLAND NUCLEAR GENERATING PLANT UNITS 1 AND 2 F. G.

Farmer i

Published January 9, 1987 j

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Idaho Nationa)l Engineering Laboratory

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EG&G Idaho, Inc.

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 l

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ABSTRACT This EG&G Idaho, Inc. report provides a review of the submittals for coma of the Westinghouse (W) nuclear plants for conformance to Generic Lotter 83-28, Item 4.5.2.

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

Plant Docket Number TAC Number Jc cph M.

Farley Unit 1 50-348 53980 Jcocph M.

Farley Unit 2 50-364 53981 R. E. Ginna Nuclear Power Plant 50-244 53985 H;ddam Neck Plant 50-213 53987 Indian Point Unit 2 50-247 53990 Indian Point 3 Nuclear Power Plant 50-286 53991 Kewrunee Nuclear Power Plant 50-305 53992 North Anna Unit 1 50-338 54003 North Anna Unit 2 50-339 54004 Paint Beach Nuclear Plant Unit 1 266 54013 l

Paint Beach Nuclear Plant Unit 2 50-301 54014 l

Prcirie Island Nuclear Generating Plant Unit 1 50-282 54015 Prcirie Island Nuclear Generating Plant Unit 2 50-306 54016 l

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1 FOREWORD This report is provided as part of the program f or evaluating licensee / applicant conformance to Generic Letter 83-20, " Required Actions Beccd on Generic Implications of Salem ATWS Events."

This work i s conducted for the U. S. Nuclear Regulatory Commission, Of fice of Nuclear Reactor R;gulation, Division of PWR Licensing-A by EG&G Idano, Inc.

The U. S. Nuclear Regulatory Commission funded the work under the cuthorization, B&R 20-19-19-11-3, FIN Nos. D6001 and D6002.

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CONTENTS-ABSTRACT.............................................................

11 FOREWORD.............................................................

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1.

INTRODUCTION....................................................

1 2.

REVIEW REQUIREMENTS.............................................

2 3.

GROUP REVIEW RESULTS............................................

5 4.

REVIEW RESULTS FOR JOSEPH M. FARLEY NUCLEAR PLANT UNITS 1 AND 2...................................................

6 1

4.1 Evaluation................................................

6 4.2 Conclusion................................................

6 5.

REVIEW RESULTS FOR R. E. GINNA NUCLEAR POWER PLANT..............

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5.1 Evaluation................................................

7 5.2 Conclusion................................................

7 4

3 6.

REVIEW RESULTS FOR HADDAM NECK PLANT............................

B 6.1 Evaluation................................................

B l

6.2 Conclusion................................................

B j

7.

REVIEW RESULTS FOR INDIAN POINT UNIT NO. 2......................

9 7.1 Evaluation................................................

9 7.2 Conclusion................................................

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,1 O.

REVIEW RESULTS FOR INDIAN POINT 3 NUCLEAR POWER PLANT...........

10 i

B.1 Evaluation.................................................

10 i

B.2 Conclusion................................................

10 9.

REVIEW RESULTS FOR KEWAUNEE NUCLEAR POWER PLANT.................

11 f

9.1 Evaluation................................................

11 4

i 9.2 Conclusion.................................................

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10.

REVIEW RESULTS FOR NORTH ANNA UNITS 1 AND 2.....................

12 10.1 Evaluation................................................

12 4.

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10.2 Conclusion 12 11.

REVIEW RESULTS FOR POINT BEACH NUCLEAR PLANT, UNITS 1 AND 2.....

13 11.1 Evaluation 13 11.2 Conclusion 13 12.

REVIEW RESULTS FOR PRAIRIE ISLAND NUCLEAR GENERATING PLANT UNITS 1 AND 2...................................................

14 12.1 Evaluation................................................

14 12.2 Conclusion................................................

14 13.

GROUP CONCLUSION................................................

15 14.

REFERENCES......................................................

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TECHNICAL EVALUATION REPORT REACTOR TRIP SYSTEM RELIABILITY CONFORMANCE TO ITEM 4.5.2 OF GENERIC LETTER 83-28 JOSEPH M. FARLEY NUCLEAR PLANT UNITS 1 AND 2 R. E. GINNA NUCLEAR POWER PLANT HADDAM NCCK PLANT INDIAN POINT UNIT NO. 2 INDIAN POINT 3 NUCLEAR POWER PLANT t

KEWAUNEE NUCLEAR POWER PLANT NORTH ANNA UNITS 1 AND 2 POINT BEACH NUCLEAR PLANT, UNITS 1 AND 2 PRAIRIE ISLAND NUCLEAR GENERATING PLANT UNITS 1 AND 2 1.

INTRODUCTION On July 8, 1983, Generic Letter 83-285 was issued by D. G. Eisenhut, Dircctor of the Division of Licensing, Office of Nuclear Reactor Regulation, to c11 licensees of operating reactors, applicants for operating licenses, cnd holders of construction permits.

This letter included required actions bcO d on generic implications of the Salem ATWS events.

These requirements h va been published in Volume 2 of NUREG-1000, " Generic Implications of ATWS Evcnts at the Salem Nuclear Power Plant."*

This report documents the EG&G Idaho, Inc. review of the submittals of come of the Westinghouse plants including Farley Units 1 and 2, Ginna, H ddam' Neck, Indian Point Units 2 and 3, Kewaunee, North Anna Units 1 and 2, Pcint Beach Units 1 and 2 and Prairie Island Units 1 and 2 f or conf ormance to Item 4.5.2 of Generic Letter 83-28.

The submittals from the licensees utilized in these evaluations are referenced in Section 14 of this report.

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REVIEW REQUIREMENTS Item 4.5.2 (Reactor Trip System Reliability - System Functional Tcoting - 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 b3 considered where special circumstances exist and where the objective of high reliability can be met in another way.

Item 4.5.2 may be intcrdependent with Item 4.5.3 when there is a need to justify not p;rforming on-line testing because of the peculiarities of a particular d;cign.

All portions of the Reactor Trip System that do not have on-line tcoting capability will be reviewed under the guidelines for this item.

Maintenance and testing of the Reactor Trip Breakers are also excluded from thio review, as they are evaluated under Item 4.2.

This review of the liccnsee/ applicant submittals 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, no further review is required.

1 2.

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

3.

Evaluate proposed alternatives to on-line testing of the Reactor Trip System for acceptability based on the followings i

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The licensee / applicant submittal substantiates the impracticality of a.

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the modifications necessary to permit on-line testing, and b.

High Reactor Trip System availability (comparable to that which would be possible with on-line testing) is achieved.in another way.

Any 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 f ollowings l

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Demonstration by systematic analysis that testing at I

shutdown intervals provides essentially equivalent i

reliability to that obtained by on-line testing at shorter intervals.

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Demonstration that reliability equivalent to that obtained by on-line testing is accomplished by additional redundant and diverse components or by other features.

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Development of a maintenance program based on early replacement of critical components that compen' sates for the lack of on-line testing.

Such a program would require analytical justification supported by test data.

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Development of a test program that compensates f or the lack of on-line testing, e.

g., one which uses trend analysis and identification of saf ety margins f or critical parameters of l

safety-related components.

Such a program would require l

analytical justification supported by test data.

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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 CE plants.

Information from licensees and applicants with CE plants will be reviewed to verify that they require independent on-line testing of the reactor trip breaker undervoltage and shunt trip attachments.

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GROUP REV!"W RESULTit 1

The relevant subnittals from each of the Westinghouse reactor plants w;re reviewed to determine compliance with Item 4.5.2.

First, the cubaittals frorn each plant we e reviewed to establish that Item 4.5.2 was cp;cifically addressed.

Second, the submittals were evaluated to determine tho extent to which each of f.he Westinghouse plants complies with the staff guidelines for Item 4.5.2.

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REVIEW RESULTS FOR JOSEPH M.

FARLEY NUCLEAR PLANT UNITS 1 AND 2 4.1 Evaluation Alabama Power Company, the license for Farley 1 and 2, provided their roeponse to Item 4.5.2 of the Generic Letter on November 4, 1983.

In that rocponse, the licensee states that Farley performs on-line testing of the undervoltage and shunt trip attachments to the reactor trip breakers.

It is not clear from the licensee response that Farley perf orms on-line t0cting of the reactor trip system; however, the licensee's Technical Cpscifications require monthly operability testing of all portions of the RTS, which implies this testing is performed on-line.

In a Safety Evaluation Report issued on September 20, 1983, the NRC ccnfirmed that the shunt and undervoltage trips are independently tested on-line.

4.2 Conclusion We find that the licensee is required to pericdically test all portions of the RTS on-linc, and that the shunt and undervoltage trips are ind pendently tested on-la.Or which meets the staff *n position and is, we bO11 eve, acceptable.

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REVIEW RESULTS FOR R.

E. GJNNA NUCLEAR POWER PLANT 5.1 Evaluation Rochester Gas and Electric, the licensee for Ginna, provided their rceponse to Item 4.5.2 of the Generic Letter on November 4, 1983.

In that rocponse, the licensee states that Ginna will perform on-line testing of the Racctor Trip System, including independent testing of the undervoltage and chunt trip attachments to thE reactor trip breakers.

The licensee further etctes that the on-line testing will be conducted on an annual or refueling bccis.

5.2 Concl usi on We find the applicant's statement of the extent to which they will p rform on-line testing of the RTS meets the staff position on Item 4.5.2 of tha Generic Letter and is, we believe, acceptable.

The licensee's proposal to conduct such testing at annual or refueling intervals will be evaluated co part of the resolution of Generic Letter 83-28, Item 4.5.3, and Generic LGtter 85-09.

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REVIEW RESULTS FOR HADDAM NECK PLANT 6.1 Evaluation Northeast Utilities, the licensee for Haddam Neck, responded to Itcm 4.5.2 of the Generic Letter on November 5, 1983 and October 18, 1985.

In those responses, the Ifcensee states that Haddam Neck was not designed to pcreit performance of on-line testing of the Reactor Trip System.

The Heddam Neck design does not include bypass breakers, which are necessary to pcrmit on-line tripping of the reactor trip breakers without tripping the rocctor.

The licensee states that installation of the equipment required to modify the plant would be very dif ficult to accomplish because of the lack of cpace in the switchgear room, and that the Haddam Neck design provides cimultaneous operation of both shunt and undervoltage trip attachments.

The liccnsee also states that maintenance and inspection of the RTBs revealed no indications of failure to trip during the past 19 years of operation.

6.2 Concl usi on We find that the licensee's justification for not installing the codifications necessary to permit on-line tacting of the Reactor Trip System ct Haddam Neck is acceptable, in view of the cost and difficulty of installing the necessary equipment and of the satisfactory history of rccctor trip reliability at the plant.

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REVIEW RESULTS FOR INDIAN POINT UNIT'ND. 2 7.1 Eval uati on Consolidated Edison, the licensee for Indian Point 2, responded to Itcm 4.5.2 of the Generic Letter on Novevber 4, 1983.

In that response, the licensee states that Indian Point 2 is designed to permit performance of on-line testing of the Reactor Trip System, including independent on-line tocting 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, including independent on-line testing of the shunt and undervoltage attachments, meets the staff position on Item 4.5.2 of the G;neric Letter and is, we believe, acceptable.

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REVIEW RESULTS FOR INDIAN POINT 3 NUCLEAR POWER PLANT B.1 Evaluation The New York Power Authority, the licensee for Indian Point 3, rorponded to Item 4.5.2 of the Generic Letter on November 7, 1983.

In that rarponse the licensee states that Indian Point 3 is designed to permit parformance of on-line testing of the Reactor Trip System and commits to on-line testing of the reactor protection system, including testing of the und:rvoltage and shunt trip attachments.

However, it is not clear from the rocponse that the licensee can perform independent verification of the epnrability of the diverse trip features.

B.2 Conclusion We find that the licensee's statement that they will perform on-line testing of the RTS meets the staff position on Item 4.5.2 of the Generic Lotter and is, we believe, acceptable. However, the licensee should confirm that the Indian Point 3 on-line testing includes the capability to perform ind: pendent verification of the operability of the diverse trip features.

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REVIEW RESULTS FOR KEWAUNEE NUCLEAR POWER PLANT 9.1 Evaluation i

l Wisconsin Public Service Corporation, the licensee f or Kewaunee, roeponded to Item 4.5.2 of the Generic Letter on December 7, 1983, and April 13, 1984.

In those responses, the licensee states that the Kewaunee plcnt performs on-line testing of the reactor trip breakers, specifically including testing of the breaker undervoltage trip attachment, and that KGwaunee plans to implement a design change which will allow independent vcrification of the operation of the shunt trip attachment.

The licensee's Tcchnical Specifications require that on-line testing of all portions the Racetor Trip System be performed on a periodic basis.

9.2 Conclusion We find that the licensee's responses did not clearly state that the cntire Reactor Trip System could be functionally tested.

However, since the

'Tcchnical Specifications do require that all portions the RTS be p riodically tested, which implies that they are tested on-line, we believe

.thsse requirements and the licensee's commitment to perf orm independent en-line testing of the undervoltage and shunt trip attachments meet the ctoff's position on Generic Letter 83-28, Item 4.5.2, and are, we believe, cccGptable.

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REVIEW RESULTS FOR NDRTH ANNA UNITS 1 AND 2 10.1 Evaluation Virginia Electric and Power Company, the licensee for North Anna, rceponded to Item 4.5.2 of the Generic Letter on November 4, 1983.

In that roeponse, the licensee states that at North Anna, procedures are being revised to include independent testing of the diverse trip features, and thn,t Item 4.5.2 of the Generic Letter is not applicable.

10.2 Concl usi on We find the licensee's statement that Item 4.5.2 is not applicable to b2 confirmation that North Anna performs on-line testing of the RTS, that thic confirmation meets the staff position on Item 4.5.2 of the Generic Latter and is, we believe, acceptable.

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REVIEW RESULTS FOR POINT BEACH _ NUCLEAR PLANT, UNITS 1 AND 2 11.1 Evaluation Wisconsin Electric Power Company, licensee for Point Beach Units 1 cnd 2, responded to the Generic Letter on November 7, 1983.

The licensee's roeponse states that Point Beach will make modifications to permit them to parform on-line testing of the Reactor Trip System, including independent en-line testing of the shunt and undervoltage trip attachments.

11.2 Conclusion We find that the licensee's statement that they will make modifications to permit them to 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 PRAIRIE ISLAND NUCLEAR GENERATING PLANT UNITS 1 AND 2 12.1 Evaluation Northern States Power Company, the licensee for Prairie Island Units 1 cnd 2 submitted a response to Item 4.5.2 of the Generic Letter on November 4, 1983.

In that response, the licensee states that Point Beach is designed to permit on-line testing of the Reactor Trip System, that on-line testing is performed monthly, and that the ability to functionally test the diverse trip features will be in place upon completion of the automatic chunt trip actuation modification.

The licensee's July 6, 1984, letter dsecribing the Prairie Island shunt trip attachment actuation modification confirms that shunt and undervoltage trip attachment testing is both on-line cnd independent.

12.2 Conclusion.

We find that the licensee's statement that Point Beach Units 1 and 2 cra designed to permit on-line testing of the RTS meets the staff position un Item 4.5.2 of the Generic Letter and is, we believe, acceptable.

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GROUP CONCLUSION We conclude that the licensee / applicant responses for the listed W.7ctinghouse plants for Item 4.5.2 of Generic Letter 83-2B are acceptable, with the exception that Indian Point 3 must provide the confirmation cddressed in the plant specific review.

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REFERENCES 1.

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 (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.

Alabama Power letter to NRC, F.

L.

Clayton to Director, Nuclear Reactor Regul ati on, " Response to Generic Letter 83-28," November 4, 1983.

4.

Rochester Gas and Electric letter to NRC, John E.

Maier to Director, Nuclear Reactor Regulation, NRC, November 4, 1983.

5.

Northeast Utilities letter to NRC, W.

G.

Counsil to Darrel G.

Eisenhut, Director, Division of Licensing, November 8, 1983.

6.

Northeast Utilities letter to NRC, W.

G.

Counsil to Darrel G.

Eisenhut, Director, Division of Licensing, October 18, 1983.

7.

Consolidated Edison Company letter to NRC, John D.

O'Toole to D. G. Eisenhut, Director, Division of Licensing, November 4, 1983.

B.

New York Power Authority letter to NRC, J. P.

Bayne to D.

G. Eisenhut, Director, Division of Licensing, " Required Actions Based on Generic Implications of Salem ATWS Events (Generic Letter 83-28, dated July 8, 1983)," November 7, 1983.

9.

Wisconsin Public Service Corporation letter to NRC, C. W.

Geisler to i

D.

G. Eisenhut, Director, Division of Licensing, " Generic ImplicaItions of Salem ATWS Events (Generic Letter 83-28)," December 2, 1983.

10.

Wisconsin Public Service Corporation letter to NRC, C. W.

Geisler to D. G. Eisenhut, Director, Division of Licensing, " Generic Implications of Salem ATWS Events (Generic Letter 83-28)," April 13, 1984.

11.

Virginia Electric and Power Company letter to NRC, W. L. Stewart, to Harold R. Denton, Director, Office of Nuclear Reactor Regulation,

" Response to Generic Letter 83-28," November 4, 1983.

12.

Wisconsin Electric Power Company letter to NRC, C.

W. Fay, to H. R. Denton, Director, Office of Nuclear Reactor Regulation, " Required Actions Based on Generic Implications of Salem ATWS Events,"

November 7, 1983.

13.

Northern States Power Company letter to NRC, D.

M. Musolf, to Director, Office of Nuclear Reactor Regulation, " Generic Implications of Salem ATWS Events," November 4, 1983.

14.

Northern States Power Company letter to NRC, D.

M. Musolf, to Director, Office of Nuclear Reactor Regulation, " Description of Modifications for Automatic Actuation of Scram Breaker Shunt Trip Attachment,"

July 6, 1984.

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