ML20078P711

Forwards Response to Generic Ltr 83-28, Required Actions Based on Generic Implications of Salem ATWS Events, Per NRC 831018 Request.General Operating Procedure OP-10-001 Revised to Address post-trip Review Concerns

ML20078P711
Person / Time
Site:	Waterford
Issue date:	11/04/1983
From:	Cook K LOUISIANA POWER & LIGHT CO.
To:	Eisenhut D Office of Nuclear Reactor Regulation
References
RTR-NUREG-0588, RTR-NUREG-588 GL-83-28, GL-83028, W3P83-3318, NUDOCS 8311080200
Download: ML20078P711 (15)

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.ee - e POWER & LIGHT / Nr W OALE ANS LOUSANA 70174 6 8 0 [504)366 2345 MIDDLE SOUTH UTILITIES SYSTEM November 4, 1983 W3P83-3318 Q-3-A20.02.02 3-A1.01.04 L.02 Mr. Darrell G. Eisenhut Director, Division of Licensing Office of Nuclear Reactor Regulation U.S. Nuclear Regulatory Commission Washington, D. C.

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SUBJECT:

Waterford SES Unit 3 Docket No. 50-382 Generic Letter 83-28 Required Actions Based on Generic Implications of Salem ATWS Events

REFERENCE:

NRC Letter dated October 18, 1983 from G. W. Knighton to R. S. Leddick

Dear Mr. Eisenhut:

The referenced letter requested that we transmit our response to Generic Letter 83-28 to the NRC by November 5, 1983. Accordingly, attached is the requested in formation.

Due to our participation in the CE Owners Group and INPO Nuclear Utility Task Action Committee, as well as the extensive nature of certain requirements, a complete status or schedule is not available for all items at this time.

However, the attached response includes the status, schedule for implementation, or plans for development of a schedule for submittal of implementation dates, as appropriate, for each item in the Generic Letter. The responses are numbered in accordance with Generic Letter 83-28.

Future submittals will be made on an individual item basis on the schedules provided herein.

If you have any questions, please advise.

Very truly yours, hd b60 K. W. Cook Nuclear Support and Licensing Manager KWC/ MAL /pj l Opg O

cc:

W. M. Stevenson, E. L. Blake, J. Wilson, G. L. Constable E

y 8311090200 831104 PDR ADOCK 05000382 A

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1.1 POST-TRIP REVIEW (PROGRAM DESCRIPTION AND PROCEDURE)

LP&L is presently revising General Operating Procedure OP-10-001 to address the concerns raised by this section of Generic Letter 83-28.

A report summarizing our implementation of these requirements will be submitted to the NRC by January 16, 1984.

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1.2 POST-TRIP REVIEW - DATA AND INFORMATION CAPABILITY 1.

The Sequence of Events file is scheduled to be integrated into the Plant Monitoring Computer software and tested prior to fuel load.

2.

The Post Trip Review file is scheduled to be integrated into the Plant Monitoring Computer software and tested prior to fuel load.

3.

The Safety Parameter Display System is scheduled-to be integrated into the Plant Monitoring Computer prior to the 5% power plateau of Power Ascension Testing.

4.

A report summarizing our program to implement this item will be submitted February 1, 1984.

2.1 EQUIPMENT CLASSIFICATION AND VENDOR INTERFACE (REACTOR TRIP SYSTEM COMPONENTS)

LP&L is presently conducting a thorough documentation review to 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.

As noted in Section 2.2.2 of this report, LP&L is participating in an INPO program to develop actions necessary to establish a vendor interface program. The results of the INPO program will be used to establish a near-term vendor interface program for reactor trip system components. This program may later be incorporated into the larger vendor interface program for all safety-related components on a schedule consistent with Section 2.2.2.

A final report, detailing our documentation review and vendor interface program for reactor trip system components will be submitted to the NRC by March 30, 1984.

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2.2 EQUIPMENT CLASSIFICATION AND VENDOR INTERFACE (PROGRAMS FOR ALL SAFETY-RELATED COMPONENTS) 2.2.1 A listing of safety-related structures, systems and components is contained in Table 3.2-1 of the Waterford FSAR.

Safety-related systems are further expanded to the component level in other sections of the FSAR, for example, the master equipment list submitted in response to NUREG 0588 as referenced in FSAR Section 3.11; submittals made in accordance with seismic qualification review as referenced in FSAR Section 3.10; and the listing of safe shutdown equipment required for Appendix R cnd detailed in FSAR Section 9.5.1.

In response to Generic Letter 83-28 LP&L has committed to a comprehensive review of our equipment classification scheme in order to develop a refined listing of safety-related components by October, 1985.

The program that will be developed to generate this list will include:

1) criteria for identifying safety related components, 2) a system to identify safety related components using the criteria and a method for development and validation of the data, 3) procedures for use of the data by various plant groups, 4) requirements for appropriate levels of management review and approval of the program and procedure used in the list development, and 5) a priorization of systems to ensure that all safety-related components are included in the listing.

Procedures are presently in place to ensure that design verification and qualification testing are specified for procurement of safety related components. The procedures will be reviewed to ensure actions required by this section are adequately addressed.

With respect to the equipment classification program in use at Waterford 3 for structures, systems and components important to safety, we are participating in the Utility Safety Classification Group and are seeking a generic resolution to the staff's concern in this regard through the efforts of this Group. We do not agree that plant structure and components important to safety constitute a broader class than the safety related set.

We nevertheless believe that non-safety related plant structures, systems and components have been designed, and are maintained, in a manner commensurate with their importance to the safety and operation of the plant.

A report concerning our implementation of the requirements for this section will be submitced by November 15, 1985.

2.2.2 LP&L is actively participating in the INPO Nuclear Utility Task Action Committee (NUTAC) which is exploring actions that can be taken to address vendor interface problems utilizing an industry wide approach.

The results of the NUTAC actions are scheduled for review and approval by member utilities in February,1984.

Upon approval of the NUTAC results LP&L will begin development of a vendor interface program for all safety-related components. This program will be fully implemented upon completion of the safety-related equipment classification.

A description of the program and confirmation of its implementation will be provided to the NRC by November 15, 1985.

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i 3.1 POST-MAINTENANCE TESTING (REACTOR TRIP SYSTEM COMPONENTS)

We are in the process of incorporating post-maintenance testing requirements for Reactor Trip System Components into plant procedures. We are also reviewing vendor and engineering recommendations to ensure appropriate test guidance is included in our test and maintenance procedures. Additionally, we are reviewing our existing technical specifications to determine if any reactor trip system post-maintenance test requirements could possibly degrade rather than enhance safety.

A statement concerning our completion of items 3.1.1 and 3.1.2 will be submitted March 1, 1984 along with a request for any necessary technical specification changes as required by item 3.1.3.

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3.2 POST-MAINTENANCE TESTING (ALL OTilER SAFETY-RELATED COMPONENTS)

The present plant procedures require post-maintenance testing of all identified safety-related equipment to assure that the equipment is capable of performing its safety functions before being returned to service.

Post-Maintenance testing is included in test and maintenance procedures.

The administrative procedures covering control of maintenance requires that the post-maintenance testing requirements be identified and the testing signed off by the Nuclear Operations Supervisor.

In conjunction with the licensing process, the Technical Specifications have been closely reviewed by LP&L. The procedure development prccedure requires procedures to be consistent with all Technical Specification limiting conditions for operation and applicable vendor-recommended operating limits. This is also reviewed as part of the Technical Review Checklist which is completed for all procedures.

Maintenance procedures are reviewed whenever a revision is written or every two years. The post-maintenance operability testing and vendor and engineering recommendations will be reviewed in conjunction with the normally scheduled procedure reviews. The reviews will be completed and documented in a submittal to the NRC by November, 1985.

4.1 REACTOR TRIP SYSTEM RELIABILITY (VENDOR-RELATED MODIFICATIONS)

We have sought the assistance of Ebasco Services and Combustion Engineering to review all vendor-recommended reactor trip breaker modifications.

By Feb ruary 17, 1984, we will submit to the NRC a report that will:

1) verify that each modification has been implemented; or 2) present a schedule for implementing any remaining modifications; or 3) provide a written evaluation of the technical bases for not implementing recommended modifications.

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i 4.2 REACTOR TRIP SYSTEM RELIABILITY (PREVENTATIVE MAINTENANCE AND SURVEILLANCE PROGRAM FOR REACTOR TRIP BREAKERS) 4.2.1 The Technical Specifications require a functional test of the Reactor Trip Breakers monthly during operation, each startup and following maintenance. This functional test (OP-903-006) will independently test the undervoltage and shunt trip devices in accordance with Combustion Engineering Availability Data Program Info Bulletin 81-02 Supplement 1.

Preventive maintenance is performed in accordance with ME-4-155.

This procedure includes inspection and cleaning, contact adjustments, mechanism adjustments, insulation testing and functional testing as recommended by the vendor technical manual, General Electric Service Advice Letter (SAL) 175 dated April 2, 1979 and the Supplement to SAL 175 dated April 15, 1983.

4.2.2, The CE Owners Group is considering a joint effort with the B&W 4.2.3, Owners Group to develop a reliability assurance program for the 4.2.4, reactor trip breakers. This program is intended to gather data on AK2 breakers from in-place surveillance and maintenance programs over a two year period to assess the reliability of the breakers and their subcomponents for the reactor trip function. This program would be in lieu of any life cycle testing of the breakers.

LP&L presently intends to participate in this effort should the CEOG adopt the program. After the next CEOG meeting scheduled for late January, LP&L will be in a position to supply a more definitive schedule and response for these items. This information will be submitted by March 1,1984.

LP&L is also using time response data to trend breaker operation according to the guidance provided by Combustion Engineering ADP Information Bulletin 83-07 dated June 15, 1983. This program may be re-evaluated or combined with the above tasks after their programs and schedules become clear.

4.3 RF. ACTOR TRIP SYSTEM RELIABILITY (AUTOMATIC ACTUATION OF SHUNT TRIP ATTACHMENT FOR WESTINCHOUSE AND B&W PLANTS)

This section is not applicable to Waterford 3, which is a Combustion Engineering plant.

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4.4 REACTOR TRIP SYSTEM RELIABILITY (IMPROVEMENTS IN MAINTENANCE AND TEST PROCEDURES FOR B&W PLANTS)

This section is not applicable to Waterford 3.

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4.5 REACTOR TRIP SYSTEM RELIABILITY (SYSTEM FUNCTIONAL TESTING) i 4.5.1 Procedure OP-903-006, " Manual Reactor Trip Test" is being revised I

to include the required functional testing of the diverse trip

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features. A statement indicating implementation of this item will j

be submitted by January 1, 1984.

4.5.2 The Reactor Trip System is currently designed to permit periodic on-line testing. The FSAR provides adequate information for staff i

review of this item. No further submittals are required, l

j 4.5.3 The C-E Owners Group has proposed a review of the existing i

interval for on-line functional testing as required by Technical Specifications. LP&L presently intends to participate in this effort.

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Further information and schedules will be provided by March 1 j

1984, following the next meeting of the CEOG.

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i STATE OF LOUISIANA) 3 i

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1 K. W. Cook, being duly sworn, states that he is Nuclear Support and Licensing j

Manager of Louisiana Power & Light Company and that he is authorized on the part of said company to sign and file with the Nuclear Regulatory Commission this response to Generic Letter 83-28, i

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K/ W. Cook

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SUBSCRIBED AND SWORN to 1)gf e me, a No,ta/[A/(b,/.M 1983.y Publief in and for the Parish and State above named, this 6/

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UNITED STATES NUCLEAR REGULATORY COMMISSION Docket No. 50-382 In the Matter of LOUISIANA POWER & LIGHT COMPANY l

Response to Generic Letter 83-28

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i Louisiana Power & Light Company, Applicant in the above captioned proceeding, hereby files a response to Generic Letter 83-28, for Waterford SES Unit No. 3.

1 Respectfully submitted, LOUISIANA POWER & LIGHT COMPANY By:

bd Nrk K. W. Cook Nuclear Support and Licensing Manager DATE:

November 4, 1983 l

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