B12270, Forwards Reviews of Listed Isap Topics Re Generic Ltr 83-28, Including Topic 1.32, Item 2.1,Equipment Classification & Vendor Interface... & Topic 1.41, Item 4.5.1,Reactor Trip Sys Functional Testing, Per Util 850517 Commitment

Forwards Reviews of Listed Isap Topics Re Generic Ltr 83-28, Including Topic 1.32, Item 2.1,Equipment Classification & Vendor Interface... & Topic 1.41, Item 4.5.1,Reactor Trip Sys Functional Testing, Per Util 850517 Commitment

ML20215K639
Person / Time
Site:	Haddam Neck File:Connecticut Yankee Atomic Power Co icon.png
Issue date:	10/16/1986
From:	Opeka J CONNECTICUT YANKEE ATOMIC POWER CO.
To:	Charemagne Grimes Office of Nuclear Reactor Regulation
References
RTR-NUREG-1000 B12270, GL-83-28, NUDOCS 8610280239
Download: ML20215K639 (16)

Text

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CONNECTICUT YANKEE ATOMIC POWER COMPANY B E R L I N. CONNECTICUT P o Box 270 HARTFORD. CONNECT; CUT 06141-0270

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T ELE PHONE 203-665-5000 October 16,1986 Docket No. 50-213 B12270 Office of Nuclear Reactor Regulation Attn: Mr. Christopher I. Grimes, Director Integrated Safety Assessment Project Directorate Division of PWR Licensing - B U.S. Nuclear Regulatory Commission l Washington, D.C. 20555

References:

(1) 3. F. Opeka letter to C. I. Grimes, dated May 17,1985.

(2) H. L. Thompson !ctter to 3. F. Opeka, dated July 31,1985.

Gentlemen:

Haddam Neck Plant j Integrated Safety Assessment Program In Reference (1), Connecticut Yankee Atomic Power Company (CYAPCO) provided a proposed scope for the Integrated Safety Assessment Program (ISAP) review of the Haddam Neck Plant. In Reference (2), the Staff formally issued the results of the ISAP screening review process, establishing the scope of ISAP for Haddam Neck and initiating issue-specific evaluations. Reference (1) also indicated that for each issue or topic included in ISAP, CYAPCO would provide a discussion of the safety objective and an evaluation of the plant design with respect to the issue being addressed to identify specific items to be considered in the integrated assesstnent. In accordance with this commitment, reviews for the following ISAP topics are attached:

1) ISAP Topic No.1.32 "Iterr i 1, Equipment Classification and Vendor Interface (Reactor Trip Systei ' omponents)"

2) ISAP Topic No.1.33 " Items .l.1 and 3.1.2, Post-Maintenance Testing Procedures"

3) ISAP Topic No.1.34 " Item 3.1.3, Post-Maintenance Testing Technical Specification Changes"

4) ISAP Topic No. 1.35 - " Item 4.1, Reactor Trip System Reliability (Vendor-Related Modifications)"

5) ISAP Topic No.1.36 " Item 2.2, Equipment ClassMication and Vendor Interface (Programs for all Safety-Related Components)"

6) ISAP Topic No.1.37 " Items 3.2.1 and 3.2.2, Post-Maintenance Testing Procedures"

7) ISAP Topic No.1.38 " Item 3.2.3, Post-Maintenance Testing Technical Specification Changes"

8) ISAP Topic No.1.39 " Items 4.2.3 and 4.2.4, Preventative Maintenance Procedures for Reactor Trip" ISAP Topic No. 1.40 " Items 4.5.2 and 4.5.3, Reactor Trip System 9) 10)

Testing" ISAP Topic No. 1.41 " Item 4.5.1, Reactor Trip System Functional h

fs I Testing" i 8610280239 861016 PDR ADOCK 05000213 P PDR

1

_2 If you have any questions concerning the attached reviews, please contact us.

Very truly yours, CONNECTICUT YANKEE ATOMIC POWER COMPANY A-F.Cadu G

3. F. OpeWa Senior Vice President l

Docket No. 50-213 B12270 i

ISAP Topic Nos.1.32 through 1.41 Required Actions Based on Generic Implications of Salem ATWS Events (Generic Letter 83-28) I i

l l

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October 1986

I. Introduction As a result of the February 22 and February 25,1983 anticipated transient without scram (ATWS) events at the Salem Nuclear Power Plant, the NRC initiated an evaluation to determine the generic implications of these events. The results of this evaluation were reported in NUREG-1000,

" Generic Implications of ATWS Events'at the Salem Nuclear Power Plant."

On July 8,1983, the NRC issued Generic Letter 83-28, " Required Actions Based on Generic Implications of Salem ATWS Events." The actions required of licensees by Generic Letter 83-28 were developed based on information contained in NUREG-1000 and address issues related to reactor trip system reliability and general management capability.

The actions covered by Generic Letter 83-28 may be categorized as follows:

(1) post-trip review; (2) equipment classification and vendor interfact ,

(3) post-maintenance testing; and (4) reactor trip system reliability The objective of ISAP Topics 1.26 through 1.28 and 1.30 through 1.35 is to review plant design as well as utility programs and procedures against the requirements of Generic Letter 83-28. For convenience, the following sections have been formatted to address each ISAP topic individually.

II. ISAP Topic No. 1.32 " Item 2.1, Equipment Classification and Vendor Interface (Reactor Trip System Components)"

A. Review Criteria

1. Topic 1.32 corresponds to Position 2.1, " Equipment Classification and Vendor Interface (Reactor Trip System Components)," of Generic Letter 83-28.

B. Related Topics / Interfaces ISAP Topic 1.16, Anticipated Transient Without Scram (ATWS)

ISAP Topic 1.33, Items 3.1.1 and 3.1.2, Post-Maintenance Testing Procedures ISAP Topic 1.34, Item 3.1.3, Post-Maintenance Testing Technical Specification Changes ISAP Topic 1.35, Item 4.1, Reactor Trip System Reliability (Vendor-Related Modifications)

ISAP Topic 1.36, Item 2.2, Equipment Classification and Vendor ,

Interface (Programs for all Safety-Related l Components)

ISAP Topic 1.37, items 3.2.1 and 3.2.2, Post-Maintenance Testing Procedures ISAP Topic 1.38, item 3.2.3, Post-Maintenance Testing Technical Specification Changes ISAP Topic 1.39, Items 4.2.3 and 4.2.4, Preventative Maintenance Procedures for Reactor Trip

m ISAP Topic 1.40, Items 4.5.2 and 4.5.3, Reactor Trip System Testing ISAP Topic 1.41, Item 4.5.1, Reactor Trip System Functional Testing C. Evaluation Generic Letter 83-28 requires licensees to:

(1) Confirm that all components whose functioning is required to trip the reactor are identified as safety-related on documents, procedures and information handling systems used in the plant to control safety-related activities, including maintenance, work orders and parts replacement; and (2) Establish, implement and maintain a continuing program to I ensure that vendor information is complete, current and controlled throughout the life of the plant, and appropriately referenced or incorporated in plant instructions and procedures.

At Haddam Neck, components required for reactor trip are identified as safety-related on documents, procedures and information handling systems used in the plant to control safety-related activities. These components are currently identified on the Category 1 Material, Equipment and Parts List (MEPL) and on the Production Maintenance Management System (PMMS) data base, which supplements the document form of the MEPL.

Haddam Neck considers the Vendor Equipment Technical Information Program (VETIP), as defined in the March 1984 NUTAC report to be a valid response to the requirements of Position 2.2, part 2.2.2. The program, as described in the NUTAC report has been implemented to the extent practical. Although not directly under the purview of the NUTAC, the similarity of the vendor interface requirements of Position 2.1 to those of Position 2.2 indicate the applicability of the VETIP to both positions.

D. Cor,clusions The Haddam Neck response (References 4 and 6) to Generic Letter 83-28 is complete.

At this time, there are no outstanding NRC requests for additional information. Results of the NRC's evaluation of the Haddam Neck response have been received in Reference 7. However, further evaluation by the Staff is necessary to completely resolve this issue.

E. References

1. Section 2.3.1 of NUREG-1000.

2. Section 2.3.2 of NUREG-1000.

3. Generic Letter 83-28, dated July 8,1983.

4. W. G. Counsil letter to D. G. Eisenhut, dated November 8,1983.

5. 3. A. Zwolinski letter to W. G. Counsil, dated March 14,1985.

6. 3. F. Opeka letter to 3. R. Miller, dated May 9,1985.

7. F. M. Akstulewicz, Jr., letter to 3. F. Opeka, dated August 15, 1986.

111. ISAP Topic No.1.33 " Items 3.!.1 and 3.1.2, Post-Maintenance Testing Procedures" A. Review Criteria

1. Topic 1.33 corresponds to Position 3.1, " Post-Maintenance Testing (Reactor Trip System Components)," parts 3.1.1 - and 3.1.2 of Generic Letter 83-28.

B. Related Topics / Interfaces ISAP Topic 1.16, ATWS ISAP Topic 1.32, Item 2.1, Equipment Classification and Vendor Interface (Reactor Trip System Components)

ISAP Topic 1.34, Item 3.1.3, Post-Maintenance Testing Technical Specification Changes ISAP Topic 1.35, Item 4.1, Reactor Trip System Reliability (Vendor-Related Modifications)

ISAP Topic 1.36, Item 2.2, Equipment Classification and Vendor Interface (Programs for all Safety-Related Components)

ISAP Topic 1.37, Items 3.2.1 and 3.2.2, Post-Maintenance Testing Procedures ISAP Topic 1.38, Item 3.2.3, Post-Maintenance Testing Technical Specification Changes ISAP Topic 1.39, Items 4.2.3 and 4.2.4, Preventative Maintenance Procedures for Reactor Trip ISAP Topic 1.40, Items 4.5.2 and 4.5.3, Reactor Trip System Testing ISAP Topic 1.41, Item 4.5.1, Reactor Trip System Functional Testing C. Evaluation Generic Letter 83-28 requires licensees to:

(1) Submit the results of their review of test and maintenance l procedures and Technical Specifications to assure that post- I maintenance operability testing of safety-related components in the reactor trip system is required to be conducted and that the testing demonstrates that the i equipment is capable of performing its safety functions 1 before being returned to service; and I 1

(2) Submit the results of their check of vendor and engineering recommendations to ensure that any appropriate test '

guidance is included in the test and maintenance procedures I or the Technical Specifications, where required.

Technical Specifications and test and maintenance procedures for the trip system components have been reviewed and determined to have

, adequate post-maintenance operability testing requirements for assurance of operability on return to service.

Recommendations on test guidance for. test and maintenance procedures have been incorporated through either procedure revisions or revision of vendor technical manuals referenced in procedures, as appropriate. Implementation of these recommendations is tracked via our internal computerized commitment tracking system. Current Technical Specification requirements envelope any vendor requirements.

D. Conclusions The Haddam Neck response (Reference (3)) to Generic Letter 83-28 is complete. At this time, there are no outstanding NRC requests for additional information. The NRC has evaluated the Haddam Neck response and Reference 4 verifies that the issue is closed.

1 E. References

1. Section 2.3.4 of NUREG-1000.

2. Generic Letter 83-25, dated July 8,1983.

3. W. G. Counsil letter to D. G. Eisenhut, dated November 8,1983.

4. F. M. Akstulewicz, Jr., letter to 3. F. Opeka, dated February 21, 1986.

IV. ISAP Topic No. 1.34 " Item 3.1.3, Post-Maintenance Testing Technical Specification Changes" A. Review Criteria

l. Topic 1.34 corresponds to Position 3.1," Post-Maintenance Testing (Reactor Trip System Components)," part 3.1.3 of Generic Letter 83-28.

B. Related Topics / Interfaces ISAP Topic 1.16, ATWS ISAP Topic 1.32, item 2.1, Equipment Classification and Vendor Interface (Reactor Trip System Components)

ISAP Topic 1.33, Items 3.1.1 and 3.1.2, Post-Maintenance Testing Procedures )

ISAP Topic 1.35, Item 4.1, Reactor Trip System Reliability (Vendor-Related Modifications)

ISAP Topic 1.36, Item 2.2, Equipment Classification and Vendor Interface (Programs for all Safety-Related l Components) l ISAP Topic 1.37, Items 3.2.1 and 3.2.2, Post-Maintenance Testing Procedures ISAP Topic 1.38, Item 3.2.3, Post-Maintenance Testing Technical Specification Changes ISAP Topic 1.39, Items 4.2.3 and 4.2.4, Preventative Maintenance Procedures for Reactor Trip ISAP Topic 1.40, Items 4.5.2 and 4.5.3, Reactor Trip System Testing ISAP Topic 1.41, Item 4.5.1, Reactor Trip System Functional Testing

C. Evaluation Generic Letter 83-28 requires licensees to:

(1) Identify, if applicable, any post-maintenance test requirements in existing Technical Specifications which can be demonstrated to degrade rather than enhance safety.

Appropriate changes to these test requirements, with supporting justification, shall be submitted for staff approval.

No situations were identified wherein existing Haddam Neck Technical Specification requirements will result in degraded safety. The required tests and test frequencies are adequate to ensure component operability while not degrading component performance.

D. Conclusions The Haddam Neck response (Reference (3)) to Generic Letter 83-28 is complete. At this time, there are no outstanding NRC requests for additional information. The NRC has evaluated the Haddam Neck response and Reference 4 verifies this issued is closed.

E. References

1. Section 2.3.4 of NUREG-1000.

2. Generic Letter 83-28, dated July 8,1983.

3. W. G. Counsil letter to D. G. Eisenhut, dated November 8,1983.

4. 3. A. Zwolinski letter to 3. F. Opeka, dated October 16,1985.

V. ISAP Topic No.1.35, " Item 4.1, Reactor Trip System Reliability (Vendor-Related Modifications)"

A. Review Criteria

1. Topic 1.35 corresponds to Position 4.1, " Reactor Trip System Reliability (Vendor-Related Modifications)," of Generic Letter 83-28.

B. Related Topics / Interfaces ISAP Topic 1.16, ATWS ISAP Topic 1.32, Item 2.1, Equipment Classification and Vendor Interface (Reactor Trip System Components)

ISAP Topic 1.33, Items 3.1.1 and 3.1.2, Post-Maintenance Testing Procedures ISAP Topic 1.34, item 3.1.3, Post-Maintenance Testing Technical Specification Changes ISAP Topic 1.36, item 2.2, Equipment Classification and Vendor Interface (Programs for all Safety-Related Components)

ISAP Topic 1.37, items 3.2.1 and 3.2.2, Post-Maintenance Testing Procedures ISAP Topic 1.38, item 3.2.3, Post-Maintenance Testing Technical Specification Changes

ISAP Topic 1.39, Items 4.2.3 and 4.2.4, Preventative Maintenance Procedures for Reactor Trip ISAP Topic 1.40, Items 4.5.2 and 4.5.3, Reactor Trip System Testing ISAP Topic 1.41, item 4.5.1, Reactor Trip System Functional Testing C. Evaluation .

Generic Letter 83-28 requires licensees to:

Review all vendor-recommended reactor trip. breaker modifications to verify that either: (1) each modification has, in fact, been implemented; or (2) a written evaluation of the technical reasons for not implementing a modification exists.

Haddam Neck' has reviewed the list of Westinghouse Technical Bulletins supplied by Westinghouse and ~ determined that the three bulletins applicable to our reactor trip breakers have been addressed ar.d necessary actions completed.

D. Conclusions The Haddam Neck response (References 3 and 4) to Generic Letter 83-28 is complete.

At this time, there are no outstanding NRC requests for additional information. The NRC's has evaluated the Haddam Neck response and Reference 5 verifies this issue is closed.

E. References

1. Section 4.1 of NUREG-1000.

2. Generic Letter 83-28, dated July 8,1983.

3. W. G. Counsil letter to D. M. Crutchfield, dated April 5,1983.

4. W. G. Counsil letter to D. G. Eisenhut, dated November 8,1983.

5. F. M. Akstulewicz, Jr., letter to J. F. Opeka, dated February 21, 1986.

VI. ISAP Topic No.1.36 " Item 2.2, Equipment Classification and Vendor Interface (Programs for all Safety-Related Components)"

A. Review Criteria

1. Topic 1.36 corresponds to Position 2.2," Equipment Classification and Vendor Interface (Programs of All Safety-Related Components)," of Generic Letter 83-28.

B. Related Topics / Interfaces ISAP Topic 1.16, ATWS ISAP Topic 1.32, Item 2.1, Equipment Classification and Vendor Interface (Reactor Trip System Components)

ISAP Topic 1.33, Items 3.1.1 and 3.1.2, Post-Maintenance Testing Procedures ISAP Topic 1.34, Item 3.1.3, Post-Maintenance Testing Technical Specification Changes

ISAP Topic 1.35, item 4.1, Reactor Trip System Reliability (Vendor-Related Modifications)

ISAP Topic 1.37, items 3.2.1 and 3.2.2, Post-Maintenance Testing Procedures ISAP Topic 1.38, item 3.2.3, Post-Maintenance Testing Technical Specification Changes ISAP Topic 1.39, items 4.2.3 and 4.2.4, Preventative Maintenance Procedures for Reactor Trip ISAP Topic 1.40, items 4.5.2 and 4.5.3, Reactor Trip System Testing ISAP Topic 1.41, item 4.5.1, Reactor Trip System Functional Testing C. Evaluation Generic Letter 83-28 requires licensees to:

(1) Describe their program for ensuring that all components of safety-related systems necessary for accomplishing required safety functions are identified as safety-related on documents, procedures and information handling systems used in the plant to control safety-related activities, including maintenance, _ work orders and replacement parts; and (2) Establish, implement and maintain a continuing program to ensure that vendor information is complete, current and controlled throughout the life. of the plant, and appropriately referenced or incorporated in plant instructions and procedures.

Haddam Neck has established criteria to identify the systems, structures and components which are safety-related. The information handling system used to identify these safety-related components is the Category 1 MEPL. The MEPL is currently in document form. The information contained in the MEPL is also identified on the computer, as part of the PMMS, which will eventually replace the MEPL.

Haddam Neck considers the VETIP, as defined in the March 1984 NUTAC report to be a valid response to the requirements of l Position 2.2, part 2.2.2. The program, as described in the NUTAC report has been implemented to the extent practical.

D. Conclusions The Haddam Neck response (References 4 and 6) to Generic Letter 83-28 is complete.

At this time, there are no outstanding NRC requests for additional information. The results of the NRC's evaluation of the Haddam Neck response have not yet been received.

E. References

1. Section 2.3.1 of NUREG-1000.

2. Section 2.3.2 of NUREG-1000.

3. Generic Letter 83-28, dated July 8,1983.

4. W. G. Counsil letter to D. G. Eisenhut, dated November 8,1983.

5. 3. A. Zwolinski letter to W. G. Counsil, dated March 14,1985.

6. 3. F. Opeka letter to 3. R. Miller, dated May 9,1985.

VII. ISAP Topic No.1.37 " Items 3.2.1 and 3.2.2, Po: t-Maintenance Testing Proce~dures" A. Review Criteria

1. Topic 1.37 corresponds to Position 3.2," Post-Maintenance Testing (All Other Safety-Related Components)," parts 3.2.1 and 3.2.2 of Generic Letter 83-28.

B. Related Topics / Interfaces ISAP Topic 1.16, ATWS I ISAP Topic 1.32, Item 2.1, Equipment Classification and Vendor Interface (Reactor Trip System Components)

ISAP Topic 1.33, Items 3.1.1 and 3.1.2, Post-Maintenance Testing Procedures ISAP Topic 1.34, item 3.1.3, Post-Maintenance Testing Technical i

Specification Changes ISAP Topic 1.35, Item 4.1, Reactor Trip System Reliability (Vendor-Related Modifications)

ISAP Topic 1.36, Item 2.2, Equipment Classification and Vendor Interface (Programs for all Safety-Related Components)

ISAP Topic 1.38, Item 3.2.3, Post-Maintenance Testing Technical Specification Changes ISAP Topic 1.39, items 4.2.3 and 4.2.4, Preventative Maintenance Procedures for Reactor Trip ISAP Topic 1.40, items 4.5.2 and 4.5.3, Reactor Trip System Testing ISAP Topic 1.41, Item 4.5.1, Reactor Trip System Functional Testing C. Evaluation Generic Letter 83-28 requires licensees to:

(1) Subriit the results of their review of test and maintenance procedures and Technical Specifications to assure that post-maintenance operability testing of safety-related components in the reactor trip system is required to be conducted and that the testing demonstrates that the equipment is capable of performing its safety functions before being returned to service; and (2) Submit the results of their check of vendor and engineering recommendations to ensure that any appropriate test guidance is included in the test and maintenance procedures or the Technical Specifications, where required.

A review of Haddam Neck test and maintenance procedures and Technical Specifications indicated that post-maintenance operability testing is required in all cases. All known applicable vendor and engineering recommendations regarding testing have been included in test and maintenance procedures. No recommendations were applicable to the Technical Specifications.

D. Conclusions The Haddam Neck response (Reference (3)) to Generic Letter 83-28 is complete. At this time, there are no outstanding NRC requests for additional information. The NRC has evaluated the Haddam Neck response and Reference 4 verifies the issue is closed.

E. References

1. Section 2.3.4 of NUREG-1000.

2. Generic Letter 83-28, dated July 8,1983.

3. W. G. Counsil letter to D. G. Eisenhut, dated November 8,1983.

4. F. M. Akstulewicz, Jr., letter to 3. F. Opeka, dated February 21, 1986.

VIII. ISAP Topic No.1.38 " Item 3.2.3, Post-Maintenance Testing Technical Specification Changes" A. Review Criteria

1. Topic 1.38 corresponds to Position 3.2," Post-Maintenance Testing (All Other Safety-Related Components)," parts 3.2.3 of Generic j Letter 83-28.

B. Related Topics / Interfaces ISAP Topic 1.16, ATWS ISAP Topic 1.32, Item 2.1, Equipment Classification and Vendor Interface (Reactor Trip System Components)

ISAP Topic 1.33, items 3.1.1 and 3.1.2, Post-Maintenance Testing Procedures ISAP Topic 1.34, Item 3.1.3, Post-Maintenance Testing Technical Specification Changes ISAP Topic 1.35, Item 4.1, Reactor Trip System Reliability (Vendor-Related Modifications)

ISAP Topic 1.36, Item 2.2, Equipment Classification and Vendor Interface (Programs for all Safety-Related Components)

ISAP Topic 1.37, items 3.2.1 and 3.2.2, Post-Maintenance Testing Procedures ISAP Topic 1.39, Items 4.2.3 and 4.2.4, Preventative Maintenance Procedures for Reactor Trip ISAP Topic 1.40, items 4.5.2 and 4.5.3, Reactor Trip System Testing ISAP Topic 1.41, Item 4.5.1, Reactor Trip System Functional Testing C. Evaluation Generic Letter 83-28 requires licensees to:

(1) Identify, 'if applicable, any post-maintenance test requirements in existing Technical Specifications which can be demonstrated to degrade rather than enhance safety.

Appropriate changes to these test requirements, with supporting justification, shall be submitted for staff approval.

No situations were identified wherein existing Haddam Neck Technical Specification requireraents will result in degraded safety. The required tests and test frequencies are appropriate to ensure component operability while not degrading component performance.

D. Conclusions The Haddam Neck response (Reference (3)) to Generic Letter 83-28 is complete. At this time, there are no outstanding NRC requests for additional information. The NRC has evaluated the Haddam Neck response and Reference 4 verifies the issue closed.

E. References

1. Section 2.3.4 of NUREG-1000.

2. Generic Letter 83-28, dated July 8,1983.

3. W. G. Counsil letter to D. G. Eisenhut, dated November 8,1983.

4. 3. A. Zwolinski letter to 3. F. Opeka, dated October 16,1985. ,

IX. ISAP Topic No.1.39 " Items 4.2.3 and 4.2.4, Preventative Maintenance i Procedures for Reactor Trip" A. Review Criteria

1. Topic 1.39 corresponds to Position 4.2.3 and 4.2.4, " Reactor Trip System Reliability (Preventative Maintenance and Surveillance Program for Reactor Trip Breakers)."

B. Related Topics / Interfaces ISAP Topic 1.16, ATWS ISAP Topic 1.32, Item 2.1, Equipment Classification and Vendor Interface (Reactor Trip System Components)

ISAP Topic 1.33, Items 3.1.1 and 3.1.2, Post-Maintenance Testing Procedures ISAP Topic 1.34, Item 3.1.3, Post-Maintenance Testing Technical Specification Changes ISAP Topic 1.35, Item 4.1, Reactor Trip System Reliability (Vendor-Related Modifications)

ISAP Topic 1.36, item 2.2, Equipment Classification and Vendor Interface (Programs for a!! Safety-Related Components)

ISAP Topic 1.37, items 3.2.1 and 3.2.2, Post-Maintenance Testing Procedures ISAP Topic 1.38, Item 3.2.3, Post-Maintenance Testing Technical Specification Changes ISAP Topic 1.40, Items 4.5.2 and 4.5.3, Reactor Trip System Testing ISAP Topic 1.41, Item 4.5.1, Reactor Trip System Functional Testing C. Evaluation Generic Letter 83-28 requires licensees to:

Describe their preventative maintenance and surveillance program to ensure reliable reactor trip breaker operation. The program shall include the following:

o

1. . Life testing of the breakers (including the trip attachments) on an acceptable sample size.

2. Periodic replacement of breakers or components consistent with demonstrated life cycles.

Reactor trip breaker (RTB) testing is described in Reference (2) in response to Item 4.5. We believe this response adequately addresses Item 4.2.3 and 4.2.4 by describing the RTB Preventative Maintenance Program.

D. Conclusions

~

The Haddam Neck response to Generic Letter 83-28 is complete. At this time, there are no outstanding NRC requests for additional 1 information. The results of the NRC's evaluation of the Haddam Neck i response have not yet been received. e t

E. References t

1. Generic Letter 83-28, dated July 8,1983.

2. 3. F. Opeka letter to 3. A. Zwolinski, dated October 18,1985.

l X. ISAP Topic No.1.40 " Items 4.5.2 and 4.5.3, Reactor Trip System Testing"  !

A. Review Criteria  :

i

1. Topic 1.40 corresponds to Position 4.5, " Reactor Trip System f Reliability (System Functional Testing)," parts 4.5.2. and 4.5.3 of i Generic Letter 83-28. l k

B. Related Topics / Interfaces l

ISAP Topic 1.16 - ATWS  !

ISAP Topic 1.32, Item 2.1, Equipment Classification and Vendor i Interface (Reactor Trip System Components) [

ISAP Topic 1.33, Items 3.1.1 and 3.1.2, Post-Maintenance Testing i Procedures ISAP Topic 1.34, Item 3.1.3, Post-Maintenance Testing Technical i Specification Changes ISAP Topic 1.35, Item 4.1, Reactor Trip System Reliability (Vendor-  !

Related Modifications) '

ISAP Topic 1.36, item 2.2, Equipment Classification and Vendor i Interface (Programs for all Safety-Related l Components)

ISAP Topic 1.37, items 3.2.1 and 3.2.2, Post-Maintenance Testing  ;

Procedures ISAP Topic 1.38, Item 3.2.3, Post-Maintenance Testing Technical  ;

Specification Changes  !

ISAP Topic 1.39, items 4.2.3 and 4.2.4, Preventative Maintenance l

Procedures for Reactor Trip l ISAP Topic 1.41, Item 4.5.1, Reactor Trip System Functional Testing i

C. Evaluation ,

Generic Letter 83-28 requires licensees to:

(1) Justify not making modifications to permit on-line testing, if the plant is not currently designed to permit such testing; and (2) Review existing intervals for on-line functional testing required by Technical Specifications to determine that the intervals are consistent with achieving high reactor trip system availability when accounting for considerations such as:

1. uncertainties in component failure rates

2. uncertainty in common mode failure rates

3. reduced redundancy during testing

4. operator errors during testing

5. component " wear out" caused by the testing On-line testing can not be performed with the plant's current configuration. Haddam Neck believes this is acceptable for the reasons stated in References 3,4 and 5.

D. Conclusions The Haddam Neck response to Generic Letter 83-28 is complete.

At this time, there are no outstanding NRC requests for additional information. The results of the NRC's evaluation of the Haddam Neck response have not yet been received.

E. References

1. Section 3 of NUREG-1000.

2. Generic Letter 83-28, dated July 8,1983.

3. W. G. Counsil letter to D. G. Eisenhut, dated November 8,1983.

4. W. G. Counsil lette.r to W. A. Paulson, dated October 4,1984.

5. 3. F. Opeka letter to J. A. Zwolinski, dated October 18,1985.

XI. ISAP Topic No.1.41 " Item 4.5.1, Reactor Trip System Functional Testing" A. Review Criteria

1. Topic 1.41 corresponds to Position 4.5, " Reactor Trip System Reliability (System Functional Testing)," part 4.5.1 of Generic Letter 83-28.

B. Related Topics / Interfaces ISAP Topic 1.16, ATWS ISAP Topic 1.32, item 2.1, Equipment Classification and Vendor Interface (Reactor Trip System Components)

ISAP Topic 1.33, Items 3.1.1 and 3.1.2, Post-Maintenance Testing Procedures ISAP Topic 1.34, item 3.1.3, Post-Maintenance Testing Technical Specification Changes

j-l -

l ISAP Topic 1.35, Item 4.1, Reactor Trip System Reliability (Vendor-Related Modifications) j ISAP Topic 1.36, Item 2.2, Equipment Classification and Vendor

} Interface (Programs for all Safety-Related .

Components)

ISAP Topic 1.37, Items 3.2.1 and 3.2.2, Post-Maintenance Testing

• Procedures j ISAP Topic 1.38, Item 3.2.3, Post-Maintenance Testing Technical Specification Changes ISAP Topic 1.39, Items 4.2.3 and 4.2.4, Preventative Maintenance Procedures for Reactor Trip j ISAP Topic 1.40, Items 4.5.2 and 4.5.3, Reactor Trip System Testing i

C. Evaluation Generic Letter 83-28 requires licensees to:

(1) Perform on-line functional testing of the reactor trip

system including independent testing of the diverse trip l features.

1 On-line functional testing of the Haddam Neck reactor trip system can not be performed. Reference 3 documents the acceptability of this configuration.

4 D. Conclusions l The Haddam Neck response (Reference (3)) to Generic Letter 83-28 is

! complete. At this time, there are no outstanding NRC requests for ' i j additional information. The NRC has evaluated the Haddam Neck.

! response and Reference 4 verifies ;his issue is closed.

i l E. References l J

I 1. Section 3 of NUREG-1000. t

2. Generic Letter 83-28, dated July 8,1983. I l 3. W. G. Counsit letter to D. G. Eisenhut, dated November 8,1983.  !

4. F. M. Akstulewicz, Jr., letter to 3. F. Opeka, dated February 21,

! 1986.

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