ML18040A780

Responds to 850319 Request for Addl Info Re Responses to Generic Ltr 83-28,Items 2.1,2.2.2 & 4.5.3.Testing of Backup Scram Valves at Refueling Outage Frequency Added to Preventative Maint Program

ML18040A780
Person / Time
Site:	Susquehanna
Issue date:	05/17/1985
From:	Curtis N PENNSYLVANIA POWER & LIGHT CO.
To:	Butler W Office of Nuclear Reactor Regulation
References
GL-83-28, PLA-2472, NUDOCS 8505230267
Download: ML18040A780 (6)

Text

REGULATU~ INFORMATION DISTRIBUTION ~STEM (RIOS)

CHOATE:

l~ ACCESSiON NOR:8505230267 DOC 85/05/17 NOTARIZED: NO DOCKET ¹ FACILt50-387 Susquehanna Steam Electric Stationi Unit 1~ Pennsylva 05000387

's 50-3o8 Susquehanna Steam Electric Stations Unit 2< Pennsylva 0 AUTH ~ 44t "iE AUTHOR AFFILIATION CURTIS~N ~ 4 REC IP, NAt1E

'ennsylvania Power RECIPIEN l'FF ILIATION 8 Light Co ~

BUTLERgH,RE Licensing Branch 2

SUBJECT:

Responds to 85031'P request for addi info re responses to Generic Ltr 83-28g Items 2~1<2,2.2 8 4.5.3.Testing of backup scram valves at refueling outage frequency added to preventative maint program, DISTRIBUTIOiV CODE: A055D COPIES RECEIVED:LTR ENCL SIZE; 7 ITLE: OR/Licensing Suomittal: Salem ATWS Events GL 83 28 NOTES: 1cy NMSS/FCAF/PM, LPOR 2cys Transcripts. 05000387 OL:07/17/82 1cy NMSS/FC>F/PM'POR 2cys Transcripts'L:03/23/84 05000388 RECIPIENT COPIES RECIPIENT COPIES IO CODE/NAME I.T't R ENCL IO CODE/NAME LTTR ENCL WRR LB2 BC 01 3 3 INTERNAL: ACRS 6 AOM/LFMd 1 ELD/HOSu 0 IE/DI 1 IE/DGAVT 1 1 NRR/OE/EOB 1 NRR/OE/MEB 1 NRR/OHFS/HFEB 1 NRR/OHFS/LQB 1 NRR/DL D IR 1 NRR/DL/ORAd 1 1 NRR/OL/SSPB 1 NRR/OL/T APi~lG 1 NRR/OS I/ASB 1 NRn/OS I/ICSB NRR/OSI/RSB 2 NR D /PSB 1 1 EG L 0< 1 RGi>1 1 1 EXTERNAL: LABOR 0> 2 NRC PDR NSIC 05 1 1 NOTES:

TOTAL NUMBER OF COPIES REQUIRED: LTTR 35 ENCL 33

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Pennsylvania Power 8 Light Company Two North Ninth Street ~ Allentown, PA 18101 ~ 215 l 770.5151 Norman W. Curtis

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t/ice President-Engineering & Construction-Nuclear 21 5/770-7501 NAY I 7 1985 Director of Nuclear Reactor Regulation Attention: Mr. W. R. Butler, Chief Licensing Branch No. 2 Division of Licensing U.S. Nuclear Regulatory Commission Washington, D.C. 20555 SUS(UEHANNA STEAM ELECTRIC STATION RESPONSE TO RE(UEST FOR ADDITIONAL INFORMATION ON GENERIC LETTER 83-28 ER 100450 FILE 841-2 Docket Nos. 50-.387 PLA-2472 50-388

Reference:

Letter, A. Schwencer to N. W. Curtis, "Request for Additional Information - Preliminary Staff Review of Generic Letter 83-28 Responses, Susquehanna Steam Electric Station", dated March 19, 1985.

Dear Mr. Butler:

Attached please find responses to the request for additional information regarding Generic Letter 83-28, items 2. 1, 2.2.2 and 4.5.3 pursuant to the reference. Should you require additional information, please contact R. Woolley (215-770-7869).

Very truly yours, N. W. Curti Vice President-Engineer' 8 Construction-Nuclear Attachment cc: M. J. Campagnone - NRC R. H. Jacobs - NRC 85052302h7 850517 PDR ADOCK 05000387 P PDR

Additional Information in Res onse to Generic Letter 83-28 Sus ue anna team ectrsc tat>on nits an 2 Item 2. 1 (part 2) - Incomplete Licensee needs to describe how his vendor technical information interface program will be extended to include interfaces with all vendors of reactor trip system components, show how the division of responsibility between nuclear and non-nuclear divisions of vendors and licensee is handled, and verify that lists of vendor information and the information itself is available at the reactor site for audit.

Response: As stated in our original response, the SSES reactor protection (trip) system was supplied by General Electric Company.

Consequently, we rely on our excellent interface with General Electric as a continuing source of vendor information related to all reactor protection system components.

In addition, for those reactor protection system components which were not originally manufactured by GE, we supplement the GE interface with the vendor interface program described in our response to item 2.2.2. The above programs provide for continuing vendor interface with both nuclear and non-nuclear divisions of vendors.

We hereby verify that lists of vendor information (Installation, Operating and Maintenance Manuals; and Industry Event Review Program Reports) and the information itself is at the SSES site and available for audit.

Item 2.2.2 - Incomplete Licensee needs to present his evaluation of the NUTAC program and describe how his current program will be modified and supplemented to incorporate it bearing in mind that the staff found the NUTAC program fails to address the concern about establishing and maintaining an interface between all vendors of safety-related equipment and the utility.

Response: The vendor equipment technical information program (VETIP) as defined in the March 1984 NUTAC document is considered a valid response to Section 2.2.2 of the NRC Generic Letter 83-28. PPSL's implementation of the program is described in Attachment A.

Accordingly, it is requested that the NRC reanalyze and reconsider your request for additional information.

Item 4.5.3 - Incomplete Licensee needs to provide description and evaluation of BWROG's analysis of proposed on-line testing intervals. This information should have considered the concerns of sub-items 4.5.3.1 to 4.5.3.5 of the generic letter, show how the intervals result in high reactor trip system availability, and present appropriate Technical Specification changes for staff review.

Response: PLA-2451, "Response to Request for Additional Information Generic Letter 83-28, Item 4.5.3", dated April 12, 1985, formally endorsed the BWR Owners'roup response to this item. The BWR Owners'roup report considers application of the generic results to specific plant applications in Section 4.7. The report gen'erically demonstrates that the current on-line functional testing intervals are adequate. This conclusion is applicable to Susquehanna.

. The concerns of sub-items 4.5.3. 1 to 4.5.3.5 of generic letter 83-28 were addressed in the BWR Owners'roup report. The following paragraph, excerpted from page 2-1 of the report, specifically addresses those concerns:

"The relay RPS failure frequency was determined to be 4.6E-06/year, which is low compared to other published values (Section 4.6. 1). This result was insensitive to changes in individual component failure rates, reduced redundancy during testing and "wearout" caused by testing. But it was found to be sensitive to the likelihood of common cause failure and human errors that can disable the scram contactors. However, even with the upperbound values for these failures rates, the RPS failure frequency was still determined to be low compared to the published values. Therefore, it is concluded that this low RPS failure frequency, which is based on the current on-line functional testing intervals, demonstrates the adequacy of curr'ent test intervals."

As the report demonstrates the adequacy of existing test intervals, no changes to the Technical Specifications are proposed.

The staff finds that modifications are not required to permit on-line testing of the backup scram valves. However, the staff concludes that testing of the backup scram valves (including initiating circuitry) at a refueling outage frequency, in lieu of on-line testing, is appropriate and should be included in the technical specification surveillance requirements. The licensee needs to address this conclusion.

Response: Testing of the backup scram valves at refueling outage frequency has been added to the Susquehanna SES Preventative Maintenance Program for both Unit I and Unit 2. We believe that this testing is inappropriate to include in technical specifications as a surveillance. Inclusion in the technical specifications is contrary to the objectives being pursued by the NRC Technical Specification Improvement Project. As- such, we propose inclusion of backup scram valve testing requirements in our Preventative Maintenance Program in lieu of requesting changes to the technical specifications.

ATTACHMENT A ANALYSIS OF ACTIONS UIRED BY NUTAC REPORT ON VENDOR UIPMENT TECHNICAL INFORMATION PROGRAM (3/84)

NUTAC RECOMMENDATIONS PP&L STATUS

1) NSSS Vendor Contact 1) Currently in compliance A program should be in place PP&L receives information to obtain technical information from General Electric in the from NSSS vendor form of SILs, TILs, SALs, and AIDs

2) NPRDS 2) Werk in Progress Utility should actively PP&L actively involved with INPO participate in NPRDS Utilities should provide internal Procedures are under development to address inputting to NPRDS control of NPRDS input

3) Other Vendors 3) Currently in compliance Utilities should contact other This is normal practice safety-related vendors for assistance when considered beneficial for solving an equipment problem

4) Internal Handling of ETI 4) Currently in compliance (Equipment Technical Information)

Review incoming ETI to provide NDI-QA-6.2.2 "Industry Events warnings and timely in- 'rompt Review Programs" & NDI-QA-15.3.10 corporation into procedures and "IOM Use and Control" training Procedures should cite appropriate NDI-QA-15.3.10 "IOM Use and ETI Control" ETI should be included in procedures NDI-QA-15.3.10 and reviewed and approved with the procedure

ATTACHMENT A NUTAC RECOMMENDATIONS PP&L STATUS

5) Internal Handling of Vendor 5) Currently in compliance Services Safety-related services should be Vendors must be on ASQL per provided by QA approved/qualified NDI-QA-2.4.5 "Evaluation and suppliers Approval of Suppliers of Quality Material and Service" Procedural and QA/QC controls NDI-QA-2.4.7 "Procurement of should be established in the Quality Materials and Services" procurement document Procurement document should NDI-QA-2.4.7 specify QA/QC program to be used.

6) Enhancements to NPRDS 6) Work in progress Incorporate revised reporting Will implement when revised guidance when issued by the guidance is issued NPRDS Users Group Develop internal methods to insure Currently preparing procedures NPRDS reports are clear, complete, and in agreement with the published guidance

7) Enhancement to SEE-IN 7) Work in progress Utilities should report errors NDI-QA-15.3.10, "IOM Use and found in ETI to INFO and other Control," will be revised to utilities via NETWORK assure compliance. NDI 6.2.4 provides vehicle