ML20136A846

Safety Evaluation Re Responses to Generic Ltr 83-28,Items 3.1.1,3.1.2,3.2.1,3.2.2 & 4.5.1.Addl Info Requested on Items 3.1.1,3.1.2,3.2.1 & 3.2.2.Item 4.5.1 Acceptable

ML20136A846
Person / Time
Site:	Hatch
Issue date:	12/23/1985
From:	Office of Nuclear Reactor Regulation
To:
Shared Package
ML20136A833	List: ML20136A829 ML20136A846
References
GL-83-28, NUDOCS 8601020326
Download: ML20136A846 (5)

Text

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. ENCLOSURE 1

SAFETY EVALUATION BY THE OFFICE OF NUCLEAR REACTOR REGULATION GENERIC LETTER 83-28, ITENS 3.1.1, 3.1.2, 3.2.1, 3.2.2, 4.1 AND 4.5.1 NOS. OPR-57 AND NPF-5 l

! GEORGIA POWER COMPANY I' OGLETNDIPE PUWRT5NPURITION MUNICIPAL ELECTRIC AUTHORITY OF GEORGIA l CITY OF DALTON GEORGIA l EDWIN 1. HATCH NUCLEAR PLANT, UNIT NOS. 1 AND 2

, DOCKET NOS. 50-321 AND 50-366 i

! I. INTRODUCTION i

l In February 1983, the Salem Nuclear Power Station experienced two failures of the reactor trip system upon the receipt of trip signals. These failures were 4 attributed to Westinghouse.- Type DB-50 reactor trip system (RTS) circuit l breakers. The failures at Sales on February 22 and 25, 1983, were believed to j have been caused by a binding action within the undervoltage trip attachment

! (UVTA) located inside the breaker cubicle. Due to problems with the circuit l breakers at Sales and at other plants, NRC issued Generic Letter (GL) 83-28, Required Actions Based on Generic Implications of Salem Anticipated Transient

. Without Scram (ATWS) Events, dated July 8, 1983. This letter described '

intermediate-term actions to be taken by licensees and applicants as a result l of the Salem anticipated transient without scram events. These actions were

! developed by the staff based on information contained in NUREG-1000, Generic Implications of ATWS Events at the Salem Nuclear Power Plant. Actions to be

performed included development cf programs to provide for post-trip review, classification of equipment, vendor interface, post-maintenance testing, and l RTS reliability improvements. The Generic Letter stated that for Action Items

! S.I.1, 3.1.2, 3.2.1, 3.2.2, 4.1, and 4.5.1 NRC Regional Offices would perform

! a post-implementation review and issue Safety Evaluations. Thh report is the

! Safety Evaluation of Georgia Power Company submittals dated November 7, 1983,

{ and February 29, 1984 responding to GL 83-28 for E. I. Hatch Nuclear Plant-

! Units 1 and 2. An NRC inspection was also conducted at the Hatch facility during January 14-18, 1985 to review the licensee's current program, planned program improvements, and implementation of present procedures associated with '

! post-trip review, equipment classification, vendor interface, post-maintenance  :

i testing, and reactor trip system reliability. The details of the inspection i j findings are discussed in Inspection Report No. 50-321, 366/84-46. 3 1

! II. REVIEW GUIDELINES l 1

I The licensee's responses were evaluated for compliance to the staff's i positions delineated in GL 83-28 for Action Items 3.1.1, 3.1.2, 3.2.1, 3.2.2, l 4.1, and 4.5.1. Item 4.1 is not applicable to Hatch Units 1 and 2, therefore, j a response was not required. The requirements of the above action items, as l described in the Generic Letter, are paraphrased below: l 1 l r

0601020326 051223  !

PDR ADOCK 05000321 l P PDR \

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Enclosure 2 2 3.1 Post-Maintenance Testing (Reactor Trip System Components) l Position

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1. Licensees and applicants shall submit the results of their review j of test and maintenance procedures and Technical Specifications to assure that post-maintenance operability testing of safety-related components in the reactor trip system is required to be conducted i

and that the testing demonstrates that the equipment is capable of performing its safety functions before being returned to service.

2. Licensees and applicants shall submit the results of their check 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.

3.2 Post-Maintenance Testing (All Other Safety-Related Components)

Position j The following actions are applicable to post-maintenance testing:

1. Licensees and applicants shall submit a report documenting the extending of test and maintenance procedures and Technical -

i Specifications review to assure that post-maintenance operability testing of all safety-related equipment is required to be l conducted and that the testing demonstrates that the equipment is j capable of ' performing its safety functions before being returned to service.

! 2. Licensees and applicants shall submit the results of their check l of er. dor and engineering recommendations to ensure that any l appropriate test guidance is included in the test and mainter.ance l procedures or the Technical Specifications, where required.

4.1 Reactor Trip System Reliability (Vendor-Related Modifications)

Position All reviewed vendor-recommended to verify that either:reactor(1trip) breaker each modifications modification has, inshall fact,be been implemented; or (2) a written evaluation of the technical reasons for not implementing a modification exists.

For example, the modifications recosuiended by Westinghouse in NCD-Elec-18 for the DB-50 breakers and a March 31, 1983, letter for the 05-416 breakers shall be implemented or a justification for not imple-menting shall be made available. Modifications not previously made shall be incorporated or a written evaluation shall be provided.

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Enclosure 2 3

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i 4.5 Reactor Trip System Reliability (System Functional Testing)

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i Position 4

On-line functional testing of the reactor trip system, including independent testing of the diverse trip features, shall be perfonned on i

all plants.

1 l 1. The diverse trip features to be tested include the breaker under-voltage and shunt-trip features on Westinghouse, Babcock and Wilcox (B&W) and Combustion Engineering (CE) plants; the circuitry j used for power. interruption with the silicon-controlled rectifiers on B&W plants and the scram pilot valve and backup-scram valves (including all initiating circuitry) on General Electric (GE) plants.

III. EVALUATION AND CONCLUSION 1

l By letters dated November 7,1983 and February 29, 1984, Georgia Power

, Company (GPC), provided information regarding its compliance to Sections

} 3.1, 3.2, and 4.5 of Generic Letter 83-28 for Hatch Units 1 and 2. We have i evaluated the licensee's responses against the NRC positions described in

! Section II above for completeness and adequacy. We concluded that the

licensee's response to item 4.5.1 is acceptable. The licensee's actions in regard to items 3.1.1, 3.1.2, 3.2.1, and 3.2.2 are still in-process and have not been completed; therefore, the acceptability of these items cannot be determined without additional information from the licensee. However, in the February 29, 1984 response GPC comunitted to submit supplemental responses to Action Items 3.1.1, 3.1.2, 3.2.1, and 3.2.2 in August 1986.

Those responses will be evaluated and reported in a Supplement to this Safety Evaluation.

t i Delineated below are the results of our evaluation and a' brief summary of the licensee's responses:

A. Item 3.1.1 - Review of Test and Maintenance Procedures and Technical Specifications (Reactor Trip System Components) i The licensee stated in their response dated February 29, 1984, that they have initiated a review of maintenance procedures to assure that j post-maintenance operability testing is adequate and required for all j components needed to trip the reactor. In conjunction with the above i review, the licensee committed to perfonn a check of available vendor and engineering recommendations as required by Action Item 3.1.2 to verify that they are included or referenced in appropriate procedures.

The licensee comunitted to have both reviews completed by June 1986, and i

i to issue a report to NRC in August'1986. The licensee further stated that the above reviews for items 3.1.1 and 3.1.2 could not be adequately performed until after implementation of the Analog Trip l!

Transmitter System which is scheduled to be completed after the next outage on each unit. We find the licensee's plans and schedules for l

. Enclosure 2 4 completing the above reviews acceptable. However, in order for us to complete the evaluation, GPC needs to complete its review for Action Items 3.1.1 and 3.2.2 by the connitted date of June 1986 and submit the results of their reviews to NRC by the connitted date of August 1986.

We will review the response when received and issue a supplement to this safety evaluation.

B. Item 3.1.2 - Check of Vendor and Engineering Reconnendations for Testing and Maintenance (Reactor Trip System Components)

The licensee stated in their response dated February 29, 1984, that the review initiated to meet the requirements of Action Item 3.1.1 will include a check cf available vendor and engineering reconnendations to verify that they are included or referenced in appropriate procedures.

This review of vendor and engineering reconnendations is scheduled for completion by June 1986. We request that the licensee perform the above review in accordance with its connitments and submit a statement confirming that this action has been completed.

C. Item 3.2.1, Review of Test and Maintenance Procedures and Technical Specifications (All Other Safety-Related Components)

The licensee's response to this item is essentially the same as the response provided to Section 3.1 of GL 83-28. The licensee connitted to conduct a review of maintenance procedures for all safety-related equipment and to include the results along with Section 3.1 response which is due in August 1986. We will review this response, as stated in paragraph A above, and issue a supplement to this safety evaluation.

D. Item 3.2.2 - Check of Vendor and Engineering Recommendations for Testing and Maintenance (All Other Safety-Related Components)

The licensee has connitted to review available vendor and engineering reconnendations to ensure that any appropriate test guidance is included in the test and maintenance procedures or the Technical Specifications, where required. The licensee committed to complete this review by June 1986, and to submit a final report to NRC in August

, 1986. NRC will review this response when received and will issue a

supplement to this safety evaluation.

E. Item 4.1 - Reactor Trip System Reliability (Vendor-Related Modifica-tion)

This item is applicable only to pressurized water reactors, therefore, no response is required by Hatch since it is a~ boiling water reactor.

F. Item 4.5.1 - Reactor Trip System Reliability (System Functional Testing)

The licensee's response to this item is acceptable and meets the intent of GL 83-28. The licensee confirmed in its response dated February 29, I

Enclosure 2 5 1984, that the RPS and its associated logic, sensor channels and ,

actuation devices are tested on-line and that this testing is I consistent with achieving a high scram system reliability. The j licensee stated that each RPS sensor channel functional test includes full actuation of the associated logic, the two output scram contactors in each channel, and the individual CRD scram air pilot valve solenoids for the associated logic division. The licensee also stated that one-half of the backup scram logic is actuated for each valve during channel functional tests, however, on-line testing of the backup scram valves is not possible without scramming the plant. Subsequent to the licensee's response dated February 29, 1984, NRC issued a letter dated April 4,1985, to the licensee requesting additional information for GL 83-28 Items 2.1, 2.2, 3.1.3, 3.2.3, and 4.5.3. In this letter the staff stated that modifications are not required by the licensee to pemit on-line testing of the backup scram valves. However, the staff recomended that the backup scram valves be tested off-line on a refueling outage frequency. Since off-line testing of the backup scram valves is beyond the scope of Action Item 4.5.1, it is not considered a part of this evaluation nor is the required intervals for performing the above tests. Therefore, the licensee's on-line testing program is satisfactory.

G. Conclusion Based on our review, we conclude that the licensee's response to item 4.5.1 is acceptable. The licensee's actions in regard to items 3.1.1, 3.1.2, 3.2.1, and 3.2.2 are still in-process and have not been completed; therefore, the acceptability of these items cannot be determined without additional information from the licensee. In the February 29, 1984 response, GPC comitted to submit responses to Action Items 3.1.1, 3.1.2, 3.2.1, and 3.2.2 in August 1986. We will review the responses when received and will report cur findings in a supple-ment to this Safety Evaluation.

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Principal Contributor: T. E. Conlan Dated: December 23, 1985

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ENCLOSURE 2 REQUEST FOR ADDITIONAL INFORMATION EDWIN 1. HATCH NUCLEAR PLANT, UNITS 1 AND 2 GENERIC LETTER 83-28 ITEMS 3.1.1, 3.1.2, 3.2.1, AND 3.2.2 Items 3.1.1, 3.1.2, 3.2.1, and 3.2.2 - Incomplete The ifcensee's actions in regard to items 3.1.1, 3.1.2, 3.2.1, and 3.2.2 are still in-process and have not been completed; therefore, the acceptability of these itemc cannot be detennined without additional information from the licensee. In the February 29, 1984 response, the licensee committed to perform the reviews required by action items 3.1.1, 3.1.2, 3.2.1, and 3.2.2 and to submit is supplemental response in August 1986. We request that the licensee complete the above reviews by the committed date of June 1986 and submit the results of its assessments to us in a supplemental response by August 1986.

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