ML20127G391

Responds to NRC 850426 Request for Addl Info Re Util Response to Generic Ltr 83-28.Procedure AP.3, Work Request, Does Not Allow for Waiver of Testing of Class 1 Components or Sys

ML20127G391
Person / Time
Site:	Rancho Seco
Issue date:	06/21/1985
From:	Reinaldo Rodriguez, Rodriquez R SACRAMENTO MUNICIPAL UTILITY DISTRICT
To:	Thompson H Office of Nuclear Reactor Regulation
References
GL-83-28, RJR-85-296, TAC-52955, TAC-53091, TAC-53792, TAC-54102, NUDOCS 8506250430
Download: ML20127G391 (4)

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SACRAMENTO MUNICIPAL UTILITY DISTRICT O 6201 S Street. P.O. Box 15830, Sacramento, CA 95813; (916) 452-3211 AN ELECTRIC SYSTEM SERVING THE HEART OF CAllFORNIA RJR 85-296 June 21,1985 DIRECTOR OF NUCLEAR kEACTOR REGULATION ATTENTION HUGH L THOMPSON JR DIRECTOR DIVISION OF LICENSING U S NUCLEAR REGULATORY COMMISSION WASHINGTON D C 20555 DOCKET 50-312 RANCHO SECO NUCLEAR GENERATING STATION UNIT NO. 1 GENERIC LETTER 83-28, REQUEST FOR ADDITIONAL INFORMATION Your letter dated April 26, 1985, requested additional information to complete your review of the District's response to Generic Letter 83-28.

Attached is the District's response to your request.

If you have any questions feel free to contact Robert Roehler of my staff at (9 45 211, extension 4905.

3 R. . . Rodr guez

! Assistant General Manager, Nuclear i

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8506250430 850621 l hDR ADOCK 05000312 PDR l

ATTACHMENT NRC Request:

1. Position 3.1.1 of Generic Letter 83-28 (GL 83-28) states that licensee reviews should "... assure that post-maintenance operability testing of safety-related components in the reactor trip system is reauired to be conducted and that the testing demonstrates that the equipment is capable of performing its safety function before being returned to service" (underlining added). Contrary to this guidance, however, your response to this item (SMUD letter dated November 4,1983), indicates functional testing may or may not be required (depending on the results of Engineering review). Also, it is not clear that if testing is required, the criteria for the test would demonstrate the capability of the component to perform its safety function. Accordingly, please clarify your response so that it may be determined whether or not Rancho Seco conforms to the guidance of Position 3.1.1.

Specifically, please address the following:

a. Please state whether all safety-related components in the reactor trip system will be required to be tested following maintenance.

b. If testing will be waived in some instances, please describe the criteria to be used in granting such waivers.

c. Please state whether the post-maintenance testing will be required to be sufficient to demonstrate the equipment is capable of performing its safety function before being returned to service.

District Response:

AP.3, Work Request, requires a work request to document maintenance on all safety related equipment. It requires engineering review before and after work is performed. It states that:

"Any class 1 component or system removed from service for maintenance requires post maintenance testing to assure that the equipment is capable of performing its safety functions before being returned to service."

It does not allow for waiver of testing for class 1 components or systems.

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l NRC Request:

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2. Position 3.1.2 of GL 83-28 states that licensees should submit the  !

results of- their checks of, vendor and engineering recommendations to ensure that any appropriate test guidance _ is included in the test and maintenance procedures or the Technical Specifications, where required.  ;

Your response,of November,4, 1983,. stated the District would review the )

information: supplied by the Owners' Group for items 3.1.1 and 2.1, and revise. procedures as appropriate. Your response also indicated the Owners' Group would supply this information by March / June 1984. This schedule was subsequently amended to February 1,1985 by your letter of October 5,1984. Since the date of February 1,1985 has now passed, 1 please furnish the information requested by GL 83-28 item 3.1.2.

District Response:

The District has completed'its review of the generic guidance for determining that post-maintenance operability testing demonstrates operability of equipment and the vendor information provided by the 88W Owners Group. Based on this review the District determined that the maintenance and surveillance procedures for the reactor trip system (RTS) do include the test guidance required to demonstrate post-maintenance operability of the RTS.

NRC Request:

3. Position 3.2.1 of GL 83-28 states that licensees should submit a report documenting the extending of test and maintenance procedures and Technical Specification review to assure that post-maintenance operability testing of all safety-related equipment is required to be

! conducted and that the equipment is capable of performing its safety functions before being returned to service. Your response dated November 4,1983, did not provide the requested report. Please submit the report requested by Item 3.2.1.

District Response:

As stated in the District's November 4,1983 response to item 3.2.1 and 3.2.2 our review of all test and maintenance procedures for other safety related equipment would be based on our review of the RTS. Based on the review of maintenance and surveillance procedures for the RTS, the District believes that the maintenance and surveillance procedures specified for performing post-maintenance testing for all safety related equipment, assure that the equipment is capable of performing its safety function. Additionally, maintenance and surveillance procedures are reviewed by engineering on a two year cycle. The checklist required for this review will be revised to require a review of post-maintenance test requirements. The District considers that these actions complete the requirement for a report documenting the extension of this review to all other safety related equipment. The required procedure changes will be completed by August 1985.

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i NRC Request: ,

4 As with Position 3.1.1, your response to position 3.2.1 leaves open the possibility that some components may not be. required to be tested. Your l response also does not address the criteria to be used in specifying testing. For example, is .the demonstration'~ of the capability of safety-related components to perform required safety functions one of the criteria used in prescribing test requirements? Therefore, because of these uncertainties for the components covered by Postion 3.2.1,

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please respond to Items a, b, and c listed under Questions 1, above, for these components.

District Response:

See response to Question 1.

NRC Request:

5. Position 3.2.2 of GL-83-28 states that licensees should submit the .

results of their checks of vendor and engineering recommendations to ensure that any appropriate test guidance is included in the tcit and maintenance procedures or the Technical Specifications, where required.

Your response of November 4,1983, does not describe the results of the cneck of vendor and engineering recommendations that was performed in response to this request but states the review will be performed later.

As indicated in Question 3, it appears sufficient time has passed to allow completion of any necessary reviews. Therefore, please submit the results of your check of this documentation, and describe the corrective action that has been taken, if any; or provide a timely date by which this information will be submitted.

District Response:

As stated in our response to question 3 this review would be based on the review of the RTS. Based on the review of the RTS, the District believes that the appropriate test guidance is included in the maintenance and surveillance procedures for all safety related equipment. Additionally, as stated in our response to question 3, the' e r will be a review of post-maintenance test requirements during the bi-annual procedure review. Also, District procedures require an engineering review of vendor information when it is received to ensure that any changes are included in maintenance and surveillance procedures. The District considers that these actions complete this item.

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