ML20082E403
| ML20082E403 | |
| Person / Time | |
|---|---|
| Site: | Callaway  |
| Issue date: | 11/18/1983 |
| From: | Schnell D UNION ELECTRIC CO. |
| To: | Harold Denton Office of Nuclear Reactor Regulation |
| References | |
| GL-83-28, ULNRC-687, NUDOCS 8311280188 | |
| Download: ML20082E403 (12) | |
Text
r
'm..
UNION ELECTRIC COM PANY 1901 GRATIOT STREET ST. lou ts, MISSOURI November 18, 1983 OON ALD fr. SCHNELL O DOE 149
.r. LOui...u..Ou.u.....
m.
Mr. Harold R. Denton Director of Nuclear Reactor Regulation U.
S. Nuclear Regulatory Commission Washington, DC 20555 ULNRC-687
Dear Mr. Denton:
DOCKET NUMBER 50-483 UNION ELECTRIC COMPANY CALLAWAY PLANT, UNIT 1 RESPONSE TO GENERIC LETTER 83-28
References:
1.
SLNRC 83-0051 dated 9-6-83, Extension of Time for Response to NRC Generic Letter 83-28 2.
SLNRC 83-0015 dated 3-10-83 and 83-0030 dated 5-27-83, SNUPPS EQ Submittal and Revision One 3.
OG-103 dated 9-16-83, WOG-NRC Task Force on Plant Technical Specifications 4.
SLNRC 83-0028 dated 5-23-83, Final 10 CFR 50.55(e) Report:
DS-416 Reactor Trip Switchgear Undervoltage Attachment 5.
OG-101 dated 6-14-83, WOG - Reactor Trip Breaker / Incorporation of Automatic Shunt Trip 6.
NRC (Eisenhut) letter to WOG (Sheppard) dated 8-10-83, SER on Generic STA Design Modifications Since the issuance of the subject generic letter, Union Electric'has directed its efforts toward developing a
~
comprehensive and fully integrated response.
A key element of that response centers on the activities of the Nuclear Utility Task Action Committee (NUTAC) on Section 2.2.2.
As such, we submitted the extension request embodied by reference one per the provisions delineated on page three of the generic letter.
On October 26 we were informed by the Callaway Project Manager that our request'was denied and that we should plan on making a submittal by-November 4.
Subsequent to this informal notification we were granted an extension to November 15 (again informally).
Thus, this submittal provides Union Electric's 1
8311280188 831118 PDRADOCK05000Og
[g i
A l
J.
. response' to certain Staff positions given in the letter and schedular.information for those areas where time did not permit developing a complete response.
Very truly yours, Donald F.
Schnell GGY/efh-Attachment s -
1 1
6
L.
STATE OF MISSOURI )
)
Donald F. Schnell, of lawful age, being first duly sworn upon oath says that he is Vice President-Nuclear and an officer of Union Electric Company; that he has read the foregoing document and knows the content thereof; that he has executed the same for and on behalf of said company with full power and authority to do so; and that the facts therein stated are true and correct to the best of his knowledge, information and belief.
By Donald F. Schnell Vice President Nuclear 9
0 //J day of 1983.
SUBSCRIBED and sworn to before me this MM/b4 BARBA PFA F NOTARY PUBUC. STATE OF MISSOURI MY COMMISSION EXPlRES APRIL 22,1935 ST. LOUIS COUNTY
cc:
Glenn L. Koester Vice President-Nuclear Kansas Gas & Electric P.O. Box 208 Wichita, Kansas 67201 Donald T. McPhee Vice President-Production Kansas City Power and Light Company 1330 Baltimore Avenue Kansas City, Missouri 64141 Gerald Charnof f, Esq.
Shaw, Pittman, Potts & Trowbridge 1800 M. Street, N.W.
Washington, D.C.
20036 Nicholas A. Petrick Executive Director SNUPPS 5 Choke Cherry Road Rockville, Maryland 20850 B. Little Callaway Resident Office U.S. Nuclear Regulatory Commission RRil Steedman, Missouri 65077
1
- 1.1 POST-TRIP REVIEW (PROGRAM DESCRIPTION AND PROCEDURE)
Union Electric is currently in the process of developing a post-trip review program in accordance with this section of the generic letter.
A report describing our program will be submitted prior to fuel load.
' l.2 POST-TRIP REVIEW - DATA AND INFORMATION CAPABILITY A report-is scheduled to be prepared by March 1984 that describes the SNUPPS Utilities' data and information retrieval capability for unscheduled reactor shutdowns.
This report will include the capability for assessing sequence of events, the time history of analog variables, and the functioning of safety-related
- equipment, data and information needed to-assess the cause of unscheduled reactor shutdowns, and any planned
- modifications to tt3 existing data and information capability along with an implementation schedule.
2.1 EQUIPMENP CLASSIFICATION AND VENDOR INTERFACE (REACPOR TRIP SYSTEM COMPONENTS)
The SNUPPS utilities have undertaken a Q-List i.
development to' provide for the identification of safety-related components, including those whose functioning is required to trip the reactor.
This Q-List will be used as a reference document to determine which components are safety-related.
This Q-List development is i
seneduled for completion by fuel load.
Information used to generate documents such as work-I requests and purchase requisitions for safety-related-components (including those in the reactor trip system) l is obtained from approved design documents such as j
drawings, equipment lists, and vendor technical manuals that have received engineering review and approval.
Administrative procedures require that the safety-related status of systems and components be identified on station. work documents for corrective and preventive
~
maintenance.
A Callaway Q-List, which embodies the SNUPPS Q-List, will be developed and used by the Materials Engineering Department at Callaway to ' assign quality classifications l
L to spare and replacement parts and components.
Based on l
an item's assigned quality classification and procurement level, Materials Engineering will specify the technical and quality requirements to be imposed in the procurement documents.
Administrative procedures will be established to control the foregoing activities.
(
i
- n. 3.
.,u
,.e,
,.,..,...m.,.
r THE FOLLOWING DESCRIBES OUR PROGRAM FOR INTERFACING WITH WESTINGHOUSE, THE SNUPPS NSSS VENDOR.
All orders entered are screened by the Westinghouse District Sales Offices, Distributors, Engineering Service Offices, or Repair Plants to determine whether F
safety-related nuclear equipment, parts or services are involved.
Westinghouse has requested us to ensure that procurement documents issued to Westinghouse clearly indicate if the equipment, parts or services are for a nuclear-plant and if so whether or not they are safety-related.
If an order is received by Westinghouse for equipment, parts or services for a nuclear plant without any indication of safety grade the customer will be asked the following question:
Does the customer have any responsibility under 10 CFR Part 21 for reporting defects, as defined in that regulation, which exist in the equipment, parts or services at the time of delivery or which may subsequently occur?
If the answer to this question is yes, the order is entered through an approved order entry channel.
3 If the answer to this question is no, normal commerical practices apply.
All orders for equipment parts identified by the purchaser or through screening for safety-related applications are processed through the Westinghouse Water. Reactor Division (WRD).
All safety-related service orders will be placed with divisions on an approved supplier list for the particular services requested.. If no approved supplier is listed for l
requested services, the order will be processed through I
WRD.
The Westinghouse QA program, described in WCAP-8370 and Section' 17.1 of the SNUPPS PSAR, applies to the design, procurement and fabrication activities involving safety-related structures, systems, and compnents and has been approved. by the NRC.
Westinghouse will ask for any special requirements or instructions f rom the customer when safety-related I _.
equipment, parts or services are involved and will i
ensure conformance to those special requirements or l
instructions.
l Instruction books are provided by Westinghouse divisions supplying equipment or parts.
Such instruction books include information necessary for proper and safe installation, operation, maintenance and repair in l
. ordinary commercial applications of such equipment and parts.
Westinghouse divisions providing services are to obtain copies of applicable instruction books for the equipment and parts which they service from the divisions which originally supplied the equipment or parts.
WRD is to include in its equipment specifications and purchase orders for equipment and parts requirements for copies of instruction books for its customers and for its own use in developing recommendations to its customers for ins tallation, operation, maintenance and repair of the equipment and parts in nuclear applications.
Instruction books for saf ety-related equipment are subject to the quality assurance requirements of 10 CFR Part 50, Appendix B and are to be included on the quality assurance release which accompanies delivery of safety-related equipment or parts.
Substantive errors discovered in instruction books for saf ety-related equipment af ter delivery to the customer are subj ect to the reporting requirements of 10 CFR Part 21.
Correction of errors may be accomplished by WRD Technical Bulletins in lieu of revising the instruction books or, in cases in which WRD is not involved, by supplementary information provided directly to its customers by the involved division.
Information supplementing or revising the instruction
~
books or other similar materials necessary for proper and saf e installation, operation, maintenance or repair of WRD-supplied equipment or parts in nuclear applications is provided by WRD in the form of Technical Bulletins.
Preparation of such Technical Bulletins has.
been centralized within WRD and is subject to the same design control process which applies to the equipment, parts and services to which they relate.
Technical Bulletins which are safety-related are so identified.
All Technical Bulletins will be transmitted by WRD to every Westinghouse NSSS customer, domestic and international, and such other WRD customers as are affected.
Responsibility for this distribution has been centralized for customers with operating plants and for customers for plants not yet in operation in order to ensure that all Technical Bulletins are promptly distributed.
Customers have been requested to provide the necessary distribution lists for their or ganizations.
All distributions of saf ety-related Technical Bulletins are now accompanied by a return receipt.
The return I
. receipts are pre-addressed to a central point in WRD for:
- recording all Technical Bulletins transmitted and their status.
Technical Bulletins for which receipt is not acknowledged within a reasonable time are retransmitted.
A list of current Technical Bulletins will be
- transmitted to all customers periodically but' not less frequently than once per year.
This transmittal is to
- be in the form of a Technical Bulletin and is to be transmitted in the same manner ' as any other Technical i
Bulletin.
In the past, NSD Data Letters provided a second source of technical information distributed by Westinghouse.
Data Letters have been discontinued and are now incorporated into Technical Bulletins.
Union Electric has draf ted a procedure that describes l-the srogram whereby these Technical Bulletins are i
received, screened for applicability, and incorporated in the plant. design (if the bulletin is design in nature) or in maintenance procedures (if operational in nature).
This procedure also provides-for an independent review of proposed responses to applicable Technical Bulletins to ensure acceptability.
A list of valid Technical Bulletins and the individual bulletins themselves are maintained at the Union Electric home of fice and at the plant.
2.2 EQUIPMENT CLASSIFICATION AND VENDOR INTERFACE (PROGRAMS FOR ALL SAFETY-RELATED COMPONENTS) 2.2.1.1 The criteria and methods used for the Q-List and development, as well as validation efforts (e.g.,
2.2.1.2 independent utility working group review), are essentially the same as those described for the SNUPPS electrical equipment list. in Section 2.0 of reference two and ~ in response to NRC-EQB questions 270.1, 270.6, and 270.17.
This. electrical equipment list has been provided on magnetic tape for use in performing preventive maintenance pursuant to Section 8.7 of reference two.
A description of 'the Q-List development and validation efforts will be provided by March 1984.
2.2.1.3 The onsite Computerized History and Maintenance Planning System (CHAMPS) incorporates design information pertaining to the safety classification of systems and com pnents.
The results of the Q-List development will be included in CHAMPS (i.e., all components classified as safety-related on the Q-List are similarly classified on CHAMPS).
This information is used by maintenance 4
9
- ----yv
,,-r
~w
,,==,-y y,,y a
w,-
,yw,-y%y--*,ye.-
a--e-&%~ee-*--n-'
ewe--*ar-3-w+---------*-e---=-m-*-*e---rme--mr-----*------ww--+aw-3----e-w-+vs*---ew
- =
_ - - - =
g planning personnel to determine the requirements of 10 4
CFR 50, Appendix B which apply to maintenance and 4-testing activities.
Minimum requirements such as design i
control, cleanliness control, documentation of work W
performance and parts equivalency are applied in all cases for safety-related components.
Additional requirements are applied, dependent on the degree and complexity of the activity to be performed.
For components which perform an active function, retesting af ter maintenance is required.
This may entail the performance of a Technical Specification Surveillance L
test or a specific component functional test devised by maintenance or system engineering personnel.
Results of maintenance and testing.are documented and retained for future reference or comparison in the. performance of 1
L trending or failure analysis.
Procurement activities
~
were discussed in response to Section 2.1.
2.2.1.4 Preparation and validation of the Q-List will be
- procedurally controlled under.the auspices of the SNUPPS QA program.
Maintenance of the Callaway Q-Lf st will %n administratively controlled.
The SNUPPS QA p'ogram is described in SNUPPS PSAR Section 17.1 - design and j.t-construction phase.
2.2.1.5 This section has been addressed via the SNUPPS EQ L
submittal (reference two) and the NRC-EQB audit during the week of June 20-23, 1983.
This resulted in the issuance of the SER for FSAR Section 3.11.
We are currently in the process of closing out SER open items; i
however, no findings were made relative to-the lack of i-an adequate preventive maintenance (PM) program.
The
(
EQB concluded that our PM program suf ficiently addressed l-their concerns.- This program will be in place prior to
[-
fuel load (as described in Section 8.7 of reference I
two).
The results of our EQ audit indicate that:
1-i a.
Saf ety-related specifications for SNUPPS plants include qualification testing and analysis, as appropriate, for environmental conditions associated with design basis accidents (LOCA, MSLB, HELB).
b.
The SNUPPS utilities have developed EQ files containing test and analysis documentation, r
c.
The qualified lives for equipment located in a harsh I6 environment and preventive maintenance activities required as a result of qualification testing have l
been included in our surveillance and maintenance L
program, as described in Section 8.7 of reference two.
l.
X l
L l
-., _. _.. _.,. _ _ _ _. - _.,... ~.
I Administrative procedures will require Callaway.
Materials Engineering.to spcify the appropriate technical and quality requirements to be imposed on the suppliers of safety-related items.
The requirements considered by Materials Engineering include -
environmental and seismic qualification of the item to be procured.
2.2.1.6~ As described in the SNUPPS response to NRC-EQB question 270.6, the-design philosophy of the SNUPPS plants has always maintained that any component required to
(
i j
accomplish a safety-related function, as defined in
-Section 2.3 of reference two, is classified as safety-i related.
All other components are non-safety-related.
However, SNUPPS FSAR Section 3.2. and Appendix 9.5-A of the Callaway Plant Addendum do address graded QA programs (Group D - Augmented, Seismic II/I, Fire P rotection) for select non-saf ety-related components
. which require high reliability.
I 2.2.2 The SNUPPS utilities are actively participating in the Nuclear Utility Task Action Committee (NUTAC) on Section 2.2.2.
Since the NUTAC's recommendations will not be final until the first quarter of 1984, further s
i discussion on-this section is deferred at this time.
3.1 POST-MAINTENANCE TESTING (REACTOR TRIP SYSTEM COMPONENTS) 4 3.2 POST-MAINTENANCE TESTING (ALL OTHER SAFETY-RELATED COMPONENTS) 3.1.1 Administrative procedures require that each work-and authorizing document be reviewed for retest requirements 3.2.1 and that the required retests be performed prior to returning the item to service.
Thus, the functionality of safety-related equipment is ensured.
3.1.2 Administrative procedures ensure the inclusion of and appropriate guidance in test and maintenance procedures 3.2.2 and in the Technical Specifications.
In addition (re Section 3.1.2 of the generic letter),
the.WOG is currently compiling all existing maintenance information regarding Westinghouse reactor trip 4
switchgear, including lessons learned since the Salem event.
Any new or impr'oved maintenance requirements resulting f rom the WOG cyclic test programs, " Cyclic Life and. Class lE Qualification of the DB and DS Circuit Breaker Shunt Trip Attachments (STA) for Reactor Trip Switchgear; Cyclic Life Testing of the OS Undervoltage Trip Attachment (UVTA)," will.be reviewed and incorporated as applicable.
~
.1
s
.. ' 3.1. 3 '
An NRC Task Force on Plant Technical Specification
~
and.
Surveillance Requirements has been recently chartered 3.2.3 and represents the appropriate forum for addressing these sections.
The SNUPPS utilities are also actively involved in a Technical Specification Optimization Program (TOP).
This involvement and interface with the NRC task force (see ref erence three) will ensure that changes to the Technical Specifications are adequately addressed.
4.1 REACTOR TRIP SYSTEM RELIABILITY (VENDOR-RELATED MODIFICATIONS)
Reactor trip breaker modifications for the SNUPPS plants were described in reference four.
Westinghouse Field Change Notices -(SCPM-10625 for Callaway; SAPM-10630 for
. Wolf Creek) were issued on August 30, 1983.
These modifications will be implemented yrior to f ue] load.
' 4. 2 REACTOR TRIP SYSTEM RELIABILITY (PREVENTIVE D 1.lffENANCE A51D SURVEILLANCE PROGRAM FOR REACTOR TRIP BREAKERS)
Westinghouse recommendations for preventive maintenance
~
of reactor trip switchgear are provided in the technical manual supplied with the original equipment.
Technical Bulletins are issued to clarify and supplement information in technical manuals as needed in lieu of transmitting revisions to technical manuals (see response to Section 2.1).
As described in Section 3.1.2 of this document, the WOG is also compiling all existing maintenance information L
regarding switchgear, including lessons learned since the Salem event.
j In addition, the WOG has undertaken an ef fort to review plant specific histories on Reactor Trip Switchgear performance and perform a reliability assessment of the data obtained.
A draft report has been issued which concludes that the UVTAs are reliable devices suitable
' f o r RPS trip breaker applications when properly ins talled, tes ted, and maintained.
l Lif e cycle testing of the shunt trip attachment and the undervoltage trip attachment of the reactor trip switchgear is being conducted by Westinghouse for the Owners Group.
This program will establish the service life of these devices and substantiate periodic test requirements with proper maintenance.
The results of this program will be f actored into maintenance, l
replacement and qualification programs.
The test L
program is scheduled for completion in the second L
quarter of 1984.
1 l
W Our maintenance department has reviewed vendor manuals and associated literature and has developed a PM program for the reactor trip breakers.
We intend to trend the results of this PM program.
The generic WOG activities described above will be f actored into this program as applicable.
4.3 REACTM TRIP SYSTEM RELIABILITY (AUTOMATIC ACTUATION OF SHUNr TRIP ATTACHMENF FOR WESTINGHOUSE AND B&W PLANTS)
The SNUPPS utilities have. requested Westinghouse to submit a ' proposal for retrofitting automatic actuation of the STA into the SNUPPS design.
Efforts are also i
. underway to address the thirteen plant-specific open items raised by the SER on the generic design (see i
references five and six).
A report describing the modifications required.for automatic actuation of the i
STA will be submitted to NRC prior to fuel load.
~
4.4 REACIOR TRIP SYSTEM RELIABILITY (IMPROVEMENTS IN MAINTENANCE AND TEST PROCEDURES FOR B&W PIANTS)
This section is not applicable to the SNUPPS utilities.
4.5 REACTOR TRIP SYSTEM RELIABILITY (SYSTEM FUNCTIONAL TESTING) 4.5.1 As stated in response to Section 4.3, the SNUPPS utilities have committed to providing automatic actuation of the STA.
Union Electric is currently I
reviewing the WOG procedure for independent verification of the diverse trip features (UVTA and automatic STA) as 4
provided by reference five.
Procedures addressing on-line functional testing of the reactor protection l
system (RPS) will be in place prior to fuel load.
'4.5.2.
The SNUPPS Plants are designed for on-line testability; the'refore, this section is not applicable.
4.5.3 Technical Specification surveillance frequencies are currently under review by the WOG and an NRC task force (see response to Sections 3.1. 3/3. 2. 3).
WCAP-10271 documents an evaluation of the impact on RPS unavailability of current and extended surveillance intervals.. The conclusion of this document and its supplement one is that, although RPS unavailability is increased, less frequent testing of RPS components is warranted and will result in an improvement in overall plant safety and equipment reliability.
Given the i
chartering of an NRC task force on this issue, we request that f urther discussion on Sections 3.1.3, i
3.2.3, and 4.5.3 be deferred.
-.: