ML20138F809

Forwards Status Info on Several Items in 831104 Response to Generic Ltr 83-28 Re Required Actions Based on Generic Implications of ATWS Events

ML20138F809
Person / Time
Site:	Fort Calhoun
Issue date:	12/10/1985
From:	Andrews R OMAHA PUBLIC POWER DISTRICT
To:	Thadani A Office of Nuclear Reactor Regulation
References
GL-83-28, LIC-85-522, NUDOCS 8512160174
Download: ML20138F809 (4)

Text

. a Omaha Public Power District 1623 Harney Omaha Nebraska 68102 2247 402/536-4000 December 10, 1985 LIC-85-522 Mr. A. C. Thadani, Project Director Project Directorate #8 Division of PWR Licensing - B Office of Nuclear Reactor Regulation U. S. Nuclear Regulatory Commission Washington, D.C. 20555

References:

1. Docket No. 50-285

2. NRC Generic Letter 83-28, dated July 8, 1983

3. Letter OPPD (W. C. Jones) to NRC (D. G. Eisenhut) dated November 4, 1983 (LIC-83-267)

4. Letter OPPD (R. L. Andrews) to NRC (J. R. Miller) dated May 24, 1985 (LIC-85-214)

Dear Mr. Thadani:

Required Actions Based on Generic Implications of Salem ATWS Events (Generic Letter 83-22).

The Omaha Public Power District, in Reference 3, responded to the subject Generic Letter. Based on a recent telephone conversation with our NRC Project Manager, status information on several of the Referente 3 items is attached to this letter. If you have further questions, please contact us.

Sinc rely,

,8 ~

R. L. Andrews Division Manager Nuclear Production RLA/me

Attachment l

cc: LeBoeuf, Lamb, Leiby & MacRae 1333 New Hampshire Ave., N.W.

Washington, DC 20036 E. G. Tourigny, NRC Project Manager P. H. Harrell, NRC Senior Resident Inspector i 851220 P Och05000 5 455124 Employment with Equal Opportunity Mate Female lf655 ,

ATTACHMENT

-ITEM: 3.2.1 Licensees and applicants shall submit a report documen-ting the extending of test and maintenance procedures and Technical Specifications review to assure that post-maintenance operability testing of all safety-related equipment is required to be conducted and that'the testing demonstrates that the equipment is capable of performing its safety functions'before being returned to service.

District Response of 11/4/83 "The present system at the Ft. Calhoun Station for controlling post-maintenance operability testing is described in Plant Standing Orders.

This insures the system requirements of the Technical Specifications are translated into the necessary controls, documents,-testing, and main-tenance for safe plant operation.

In general, post maintenance testing will .use a surveillance test or portion of a surveillance test to demonstrate operability. There are, however, cases whe~n, because of-the nature of the breakdown and plant status, a surveillance test cannot be perfonned. In these cases the District will generate test procedures to verify equipment operability using.the Standing Orders as guidance documents.

The District believes that the present system at the Ft. Calhoun Station adequately controls post-maintenance testing. To insure full compliance,

-the District plans to review the plant Standing Orders to insure that the-requirements for post-maintenance testing are clearly defined.

Secondly, the District will review all repetitive maintenance procedures to insure requirements for post-maintenance testing are defined. Thirdly, the District plans to review all preventive maintenance procedures to insure proper control, procedure classification and required testing is

-defined. The District also pla.ns to review all special procedures.

-This effort will be part of the review to be completed October 1, 1984 as part of 2.2.1.3."

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Final Disposition Existing safety-related maintenance procedures have been reviewed to determine the need for post-mai.ntenance testing requirements. It was

, found that the procedures contained requirements for post-maintenance testing where applicable and necessary. Standing Order G-17, Mainte-3 nance Orders, provides additional assurance that post-maintenance testing will be accomplished, by directing the technical reviewer of a mainte-k", J . nance order to specify such testing where applicable. Existing special procedures have also been reviewed and were found to specify post-maintenance testing where applicable and necessary.

The preventive maintenance program was incorporated into the CHAMPS system. Consistent identification of safety-related equipment and incorporation of post-maintenance testing requirements were accomplished concurrent with this effort.

In order to emphasize the need for considering post-maintenance testing of safety-related equipment, Standing Orders G-3, Special Procedures; G-17, Maintenance Orders; M-1, Maintenance Procedures; and M-2, Preventive Maintenance were revised. Any additional training with regard to these changes _has also been completed. These changes fullfill the commitment to Generic Letter 83-28, Items 3.2.1 and 2.2.1.3.

ITEM: 3.2.2 Licensee 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 Specifi-cations where required.

District Response of 11/4/83 "The District presently has Standing Order G-36 which requires periodic review of operating manual procedures. This Standing Order will be reviewed to insure all necessary procedures are included and will also be updated to include vendor and engineering information in the requi' red review.

Standing Order'G-36 will be reviewed and updated as appropriate by September 1, 1984. The initial procedure review will be done in parallel with the vendor information effort established in the response to items 2.1 and 2.2. As was previously noted, this effort may incorporate the programs developed by the INP0 "NUTAC on Generic Letter 83-28, Section 2.2.2." and will be scheduled accordingly."

Final Disposition A review of Standing Order G-36 has been completed to ensure all neces-sary procedures are included. A procedure change was made to improve the quality of the review process and to include necessary vendor infor-mation in the required review.

7 ITEM 4.1 REACTOR TRIP SYSTEM RELIABILITY (VEND 0R-RELATED MODIFICATIONS)

NRC Position All Vendor-recommended reactor trip breaker modifications shall be reviewed to verify that either: 1).

each modification has, in fact, been implemented; or 2) a written evaluation of the technical reasons for not -

-implementing a modification exists.

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

District Response of 11/4/83 "The District has requested that the vendors investigate the equipment history and indicate to the District any recomended modification. The District will then evaluate the recommendations and make modifications if required. The schedule will be provided to the NRC when vendor information be'comes available."

Final Disposition Vendors have been contacted regarding components of the Reactor Trip System (RTS) at Fort. Calhoun Station. The inquiries concerned any modifications to RTS equipment that may have been recommended by the vendors since the equipment was installed. Vendors indicated that no modifications are recommended at this time. Based upon this informa-tion, OPPD plans no modifications to this equipment. Additionally, per f Reference (4), OPPD has reviewed necessary procedures to ensure they are current.