ML20023D749

Requests Confirmation of NRC Understanding That FSAR States That Testing Meets Provisions of IEEE-338 & Reg Guide 1.22 Re ESF Actuation Sys Surveillance Requirements

ML20023D749
Person / Time
Site:	Waterford
Issue date:	05/10/1983
From:	Knighton G Office of Nuclear Reactor Regulation
To:	Maurin L LOUISIANA POWER & LIGHT CO.
References
NUDOCS 8306020687
Download: ML20023D749 (4)

Text

r

' DISTRIBUTION MAY 101983 9

N W2 NRC PDR L PDR NSIC PRC System Docket No.: 50-382 LB#3 Readinn JLee Mr. L. V. Maurin JWilson Vice President - Nuclear Operations Jordan, IE Louisiana Power and Light Conpany Taylor, IE 142 Delaronde Street ACRS (16)

New Orleans, Louisiana 70174 Tl1Novak Attorney, OELD

Subject:

Waterford 3 Engineered Safety Features Actuation Systen Surveillance Requirenents Recent problens that have developed during the cesign review for other CE plants (see background concerning San Onofre, Units 2 & 3 - Enclosure 1) make it necessary for the staff to confirn their understanding of the Waterford 3 design as it relates to compliance with the provisions of R.G. 1.22 and IEEE-338.

The Waterford 3 FSAR (Sections 7.3.1.1.1.9 and 7.3.2.1.3) states that testing neets the provisions of IEEE-338 and R.G. 1.22 and that complete channels can be individually tested without initiating protective action, without violating the single failure criterion, and without inhibiting the operation of the protection systen. Based on these statenents and the staff's audit review,.

It was the staff's conclusion that the Waterford 3 plant complies with the provisions of R.G. 1.22 and IEEE-338. This includes testing at pcwer of all ESFAS actuation devices (subgroup / actuation relays, etc.).

You ::re requested to confirn the staff's understanding as described above.

If, as a result of your reevaluation, it is deternine that various actuation devices (i.e., subgroup relays, etc.) cannot be tested at power in accordance with R.G.1.22 and IEEE-338, then you should provide a list of ESFAS actuation devices'and actuated equipment associated with each that cannot be tested during plant operation.

You should also provide infornation to justify why each actuation device identified above cannot be tested at power and to justify that the actuated equipnent assignnents to each actuation device were nade in a manner to mininize the nuraber of conponents which cannot be tested with the plant in operation.

Please provide the above infornation within 30 days of receipt of this letter 50 that staff review will not inpact the conpletion of the licensing review.

5 8306020687 830510 PDR ADOCK 05000382 A

PDR crnce) sua 4:n >

para >

OFFICIAL RECORD COPY usce mi-=-=

yc ronu s:s oow mcu cuo

l Mr. L. V. !! aurin In order to assurean expedited response we suggest that for any discussion or clarification on tbc inferaation requested, you should contact Mr. R. Stevens, staff reviewer for the Instrunentation and Control Systens Branch, on (301)492-9456.

Sincerely, George W. Knighton, Chief Licensing Branch No. 3 Division of Licensing

Enclosure:

As stated cc: See next page g

lC Wcb n,

DL:LB <

7a)

IT N -

D

..g. h t

" M E'i"'~""" 'd omer)

" " " ' " " " " " " ~ " '

'd'

d g

sun =4= >

..3

...... 7.../83.............. '

4/s.

..../../..f/. 83.......... 4..[.8. 3.........

o4re p anc ronu sia nomi nneu o24o OFFICIAL RECORD COPY usara mi-ms-=

. J

WATERFORD Mr. L. V. Maurin

. Vice President Nuclear Operations Louisiana Power & Light Company 142 Delaronde Street l

New Orleans, Louisiana 70174 cc:

W. Malcolm Stevenson, Esq.

Regional Adminstrator-Reg'on IV 4

Monroe & Lemann U. S. Nuclear Regulatory Commission 1423 Whitney Building

' 611 Ryan Plaza Drive New Orleans, Louisiana 70130 Suite 1000 Arlington, Texas 76012

. Mr'. E. Blake Shaw, Pittman, Potts and Trowbridge 1800 M Street, NW Washington, DC 20036 Mr. Gary L. Groesch 2267 Dayou Road New Orleans, Louisiana 70119 Mr. F. J. Drummond Project Manager - Nuclear Louisiana Power & Light Company 142 Delaronde Street New Orleans, Louisiana 70174 Mr. D. B. Lester Production Engineer Louisiana Power _& Light Company 142 Delaronde Street New Orleans, Louisiana 70174 Luke.Fontana, Esq.

824 Esplanade Avenue New Orleans, Louisiana 70116 Stephen M. Irving, Esq.

535 North 6th Street Baton Rouge, Louisiana '70802 Resident inspector /Waterford NPS P. 0._ Box 822-Killona, ' Louisiana 70066 Dr.-D. C. Gibbs Middle South Service, Inc.

j P. 0. Box 61000 j

- New Orleans, Louisiana 70161 4

4 x

4 m

e w-v r

tc w w

=

r---

w

-w

ENCLOSURE 1 BACKGROUND INFORMATION ON SURVEILLANCE REQUIREMENTS FOR ENGINEERED SAFETY FEATURES ACTUATION SYSTEM During the development of the San Onofre, Units 2 & 3 (SONGS 2 & 3), Tech-nical Specifications, the NRC staff, Combustion Engineering (CE), and SONGS 2 & 3 applicant mutually agreed to a 6-month interval for testing ESFAS subgroup relays (actuation devices). This 6-month interval was incorporated into the SONGS 2 & 3 Technical Specifications and revision 3 to the CE Standard Technical Specifications. Subsequently, the SONGS 2 & 3 applicant requested (references 1 and 2) that the SONGS Technical Specifications be modified to extend the surveillance of ESFAS subgroup relays from the present 6-month interval to each refueling (approximately an 18-month interval).

It appears from references 1 and 2 and discussions between the applicant and staff in a meeting held July 29, 1982, that the assignment of SONGS 2 & 3 ESFAS subgroup relays has compromised to a large extent the capability of testing the complete actuation circuitry at power and, thus, may not fully comply with current regulatory requirements.

It has been fundamental regulatory practice to require that plants be designed to allow the protection system to be tested in its entirety while the plant is at power. The design bases for plant design include the recommendations of Regulatory Guide (R.G.) 1.22 and IEEE 338 which state that protection systems, including the actuation devices, should be designed to be testable during plant operation as well as during intervals when the plant is shut down. The regulatory guidance does allow exceptions in cases where testing actuated equipment at power could cause unsafe plant conditions / operations as long as sufficient justification is provided.

Based on the operating license review of the SONGS 2 & 3 plant design, the staff concluded that all actuation devices within the protection systems could be tested with the plant at power. After being informed (as stated above) by the applicant that this is not correct in all cases, the staff requested (and has now received) additional information to identify and provide justification for those subgroup relays and associated equipment that cannot he tested at power.

Discussions are presently underway with the SONGS applicant to resolve this issue.

References:

1) SCE letter (R. Dietch) to NRC (H. Denton) dated July 23, 1982,

" Docket No. 50-361, Amendment Application No. 8, San Onofre Nuclear Generating Station, Unit 2."

2) SCE Letter (K. Baskin) to NRC (F. Miraglia) dated August 16, 1982, " Docket Nos. 50-361 and 50-362, San Onofre Nuclear Generating Station, Units 2 and 3."

-