IR 05000219/1984031

Safety Evaluation Concluding Util Compliance W/Generic Ltr 83-28,Items 3.1.1,3.1.2,3.2.1,3.2.2 & 4.5.1,based on Util 831114,850809,0509,1023 & 871223 Descriptions of Planned & Completed Actions & Insp Rept 50-219/84-31 on 841126-30

ML20196H757
Person / Time
Site:	Oyster Creek
Issue date:	03/04/1988
From:	Office of Nuclear Reactor Regulation
To:
Shared Package
ML20196H753	List: IR 05000219/1984031 ML20196H748
References
GL-83-28, NUDOCS 8803140051
Download: ML20196H757 (5)

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\,...../ - 1 SAFETY EVALVATION BY THE OFFICE OF THE NUCLEAR REACTOR _RJpVLATIONS RELATED TO GENERIC LETTER 83-28, ITEMS 3.1.1, 3.1.2, 3.2.1, 3.2.2 AND 4. GENERAL PUBLIC UTILITIES (GpV) NUCLEAR',,gRp0 RATION OYSTERCREEKNUCLEARGENERATING}*JTION .,

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1.0 Introduction On February 25, 1953, both of the scram circuit breakers at Unit 1 of the Salem Nuclear power Plant failed to open upon an automatic reactor trip signal from the reactor protection system. This incident occurred during V the plant startup, and the reactor was tripped manually by the operator 4 about 30 seconds after the init'tatic7 of the automatic trip signal. The '

I failure of the circuit breakers has been deter.nined to be related to the sticking of the undervoltage trip attachment. Prior to this incident, on i February 22, 1983, at Unit 1 of the. Salem Nuclear Power Plant, an automatic trip signal was generated based on steam generator low-low level during plant startup. In this case, the reactor was tripped .

manually by the operator almost coincidentally with the automatic tri l l

Following these incidents, on February 28, 1983, the NRC Executive {

Oirector for Operations (E00), directed the staff to investigate and report on the generic implications of these occurrences at Unit 1 of the Salem Nuclear power Plant. The results of the staff's inquiry into the I generic implications of the Salem unit incidents are reported in NUREG-1000, "Generic Implications of ATWS Events at the Salem Nuclear Power Plant." As a result of this investigation, the Director Division of Licensing, Office of Nuclear Reactor Regulation requested (by Generic Letter 83-28 dated July 8,1983) all licensees of operating reactors, applicants for an operating license, and holders of construction oermits to respond to certain generic concerns. These concerns are categc,rized into four areas: (1) Post-Trip Reviev, (2) Equipment ClassUtcation and Vendor Interface, (3) Post-Maintenance Testing, and (4) Reactor Trip System (RTS) Reliability Improvements. Within each of these areas, various specific actions were delineate i This safety evaluation (SE) addresses the following actions of Generic Letter 83-28:

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3.1.1 and 3.1.2, P1st Maintenuce Testing (Reactor Trip' System Components)

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3.2.1 and 3.2.2, Post Maintenance festing (All Other Safety-Related Components)

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4.5.1, Reactor Trip System Reliability (System Functional Testing)

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By letter, dated November 14, 1983, August 9, 1985, May 9, 1985,

, October 23, 1985 and December 23, 1987, GPU Nuclear Corporation described their planned and completed actions regarding the above items foa the Oystn Creek Nuclear Generating Station. Certain of these actions were reviewed during Region I inspection conducted on November 26-30, 1934, as

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described in Inspectios P.eport (50-219/84-31).

2.0 Evaluation 2.1 General Generic Letter 83-28 included various NRC staff positions regarding the specific actions. to be taken by operating reactor licensees and operating license applicants. The Generie Letter 83-28 positions and discussions of Ecensee compliance regarding Actions 3.1.1, 3.1.2, 3.2.1, 3.2.2, e.nd 4.5.1 for Oyster Creek Nuclear Generating Station are presented in the tections that follo .2 Actions 3.1.1 and 3.1.2, Post-Maintenance Testing (Reactor Trip

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System Compone g Position .

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Licensees and applicants shall submit the results of their review of test and maintenance procedures and Techntcal Specifications to

, assure that post-maintenance operability testing of safety-related components in the reactor trip system (RTS) is required to be conducted and that the testing demonstrates that the (tquipment is capable of performing its safety functions before being returned te servic Licensees and applicants shall submit the results of their check of vendor and engineering recommendations (regarding safety-related components in the I.TS) to ensure that any appropriate test guidance is included in the test and maintenance procedures or the Technical Specifications, where require Di scu s t.i o The licensee's response dated November 14, 1933 states that following completion of maintenance activities, the Group Shift Supervisor is responsible to assure that post-maintenance tssting adequately demonstrates the operability of equipmenUsyst&7s before returning equipment to service with respect to surveillance test procedures for reactor trir system (RTS) components. The licensee's N3ponse states that these procedures have not been reviewed as part (. ' their response to Generic Letter 83-28. In addition the l'tunste's response states that not all vendor information is cor. trolled to assure integration of information into plant procedure ,, _

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An inspection conducted by Region I (50-219/84-31) found that the licensee did not acdress the specifics of eqdpment classification, vendor interface and post maintenance testing. The inspection also concluded that the licensee's response to Generic Letter 83-28 a ' ,

lacked specificity and completion goal '

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FohlowingtheNovember 14, 1983 response and the Region I inspection (November 26-30,1984) the licensee sut;mitted a letter responding to inspection findings. They described action to be taken with respect to equipment classification, vendor interface and cost-maintenance -

testing. These actions consist of establishing: 1) a component'

level Quality Classification List (QCL) which will identify the ,

Safety Classification of major system, components, and structures at the plant; 2) a .andor interface program and; 3) a post maintenance ]{

testing program. Key elements cf the post maintenance testing ,1 program were statedsto include 1) identification of appropriate QCL components; 2) lievelopment of administrative procedures controlling post main:9 nan:/e testing; 3), identification of the appropriate vendor ang engineering test guidance; 4) develooment of generic post ing requirements and guidelines for their use; and niaintenatet 5) rvjew of ex tep! sting plant procedures relative to tha generic post maintenar te testing requirements and INP,0 Good Practices. The licqsee, in W se daintenance testdng.me program letter, stated that is dependent uponthe thecompletion ofthe completion of the post

/ vendor interface program nd the development.of the QC '

By letter dated December 23, 1987, the licensee described how post maintenance testing requirements have been incorporated into plant procedures znd t.he status of the review of procedures relative to ,

the generic ,sost maintenance testing requirements. The licensee stated Administrative Procedure No. A000-ADM-7175.01, describes the

/ post maintenance The licensee further stated that

/approximately59d:,estingprogra of facility maintenance procedurer lave been

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reviewed and urgraded. The upgrade is to be completed by June 30, 1988. The tirp' frame for completion was stated not to impact the post mainter.nce testing program, sinca.jif post maintenance testing

@ uiremetts.are not specified in the procedure, the maintenance ,

plannerrefety;totheadministrativeproceduresandthenspecifies thepostm-[nnnancetestingrequirementsforthatactivit '

Bised on the dq ve, the staff concludes that the licensee has complied with'the NRC staff position for actions 3.2.1 and 3.2.2 of

N Generic letter 8D-2 , - I

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2.3 Actions 3.2.1 and 3.2.2, Post-Maintenance Testing ( All Other Safety

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Related Components)

Position

,f Licensees and applicants shall submit a report documenting the extending of test and maintenance procedures and Technical Specifications review to assure that post-maintenance operability testing of all safety-related equipment is required to be conducted and that the testing demonstrates that the equipment is capable of

, performing its safety functions before being returned to servic Licensees and applicants shall submit the results of their check of vendor and engineering recommendations (all other safety-related

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. components) to assure that any appropriate tests guidance is included in the test and maintenance procedures or the Technical Specifications, where require Discussion The licensee in letters dated October 23, 1985 and May 9, 1985 stated that GPUN has provisions in place to identify the safety classification of major systems, components and structures as well as provisions for controlling safety related activities associated with these items. Paragrg,h 2.2 describes the licensee's actions relating to post maintenance testing requirements for safety related components which have been incorporated into plant procedures and the status of the review of plant procedures relating to post maintenance testing of safety related component ,/ The licensee's response dated October 23, 1985 describes: 1) the

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'I program which has been established to ensure that vendor documents l are properly reviewed for impact en existing documents (procedures,

/ manuals, policies, etc.) and that the information is disseminated to the appropriate personnel for action; 2) the procedure which is in place for the review and issuance of vendor technical manuals for new equipment; and 3) the technical reviews of selected existing vendor technical manual Based on the above, the staff concludes that the licensee has {

complied with tha NRC staff position for actions 3.2.1 and 3.2.2 of j Generic Letter 83-2 !

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2.4 Action 4.5.1, Reactor Trip System Reliability (System Functional Testina)

Position On-line functional-testing of the reactor trip system, including independent testing of the dtverse trip features, shall be performed on all plant The diverse trip features to be tested include the breaker undervoltage and shunt trip features on Westinghouse, B&W and CE plants; the circuitry used for power interruption with the silicon controlled rectifiers on B&W plants; and'the scram pilot valve and backup scram valves (including all initiating circuitry)

on GE plant Discussion The licensee's response dated August 9, 1985 states that on-line functional testing of the scram pilot valves and associated initiating circuitry is conducted at Oyster Creek Nuclear Generating Statio During normal system operation, each of the two Reactor Protection System (RPS) buses energize one of two three way solenoid operated diaphragm scram inlet and outla :tives. ~0uring routine surveillance testing of the Rt. :.nsors, the RPS is placed in a half scram mode which results in actuwcion of the scram pilot valve The instrument air header to all scram pilot valves has two backup scram pilot valves. Like the scram pilot solenoids, the backup scram solenoids are actuated by the RPS. Functional testing of the backup scram valves would require a plant scram and as a result such testing is not performed. The staff finds that on-line testing of backup scram valves is not required as established in an NRC internal memorandum dated November 16, 1984 for R. W. Houston, Assistant Director for Reactor Safety, Division of Systems Integratio Based on the above, the staff concludes that the licensee's response is in accordance with the NRC staff position for Item 4.5.1 of Generic Letter 83-2 .0 Conclusion Based on the foregoing discussions, the' staff concludes that the licensee has complied with actions 3.1.1, 3.1.2, 3.2.1, 3.2.2, and 4.5.1 of Generic Letter 83-2 Dated: March 4, 1988 Principal Ccntributor: Walter Baunack, Division of Reactor Projects, Region I )

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