ML20138P068

Safety Evaluation Accepting Licensee 831107 & 850709 Responses to Generic Ltr 83-28,Items 3.1.1,3.1.2,4.1 & 4.5.1 Re post-maint Testing & Reactor Trip Sys Reliability (vendor-related Mods & Sys Functional Test Description)

ML20138P068
Person / Time
Site:	Davis Besse
Issue date:	10/30/1985
From:	Office of Nuclear Reactor Regulation
To:
Shared Package
ML20138P066	List: ML20138P064 ML20138P068
References
GL-83-28, TAC-52912, TAC-53067, TAC-54058, NUDOCS 8511060354
Download: ML20138P068 (4)

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~ UNITED STATES 8 e NUCLEAR REGULATORY COMMISSION

{ I WASHINGTON, D. C. 20555

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SAFETY EVALUATION BY THE OFFICE OF NUCLEAR REACTOR REGULATION RESP 0tlSE TO GENERIC LETTER 83-28; ITEMS 3.1.1, 3.1.2, 4.1 and 4.5.1 i

TOLEDO EDISON COMPANY AND THE CLEVELAND ELECTRIC ILLUMINATING COMPANY DAVIS-BESSE NUCLEAR POWER STATION, UNTT NO. 1 DOCKET NO. 50-346 1.0 INTR 00VCTIOff AND BACKGROUNO Subsequent to the anticipated transient without scram (ATWS) events at the Salem Nuclear power Plant, the Comission reviewed intermediate term actions to be taken by the licensees. The actions taken were developed on the basis of information contained in NUREG-1000. " Generic implications of ATWS Events at the Salem Nuclear Power Plant." On July 8,1983, Generic Letter (GL) 83-28 was issued by the NRC. The letter identified NRC positions developed from review of the Salem ATWS events. These positions are related to reactor trip system reliability and general management capability. The Toledo Edison Company (the licensee) responded to G. L. 83-28 by letters dated November 7,1983 and July 9, 1985.

The specific G. L. 83-78 items covered by this Safety Evaluation are Sections 3.1.1 and 3.1.2, " Post-Maintenance Testing (RTS Components)";

4.1, "RTS Reliability (Vendor Related Fodifications)"; and 4.5.1, "RTS Reliability (System Functional Test Description)."

2.0 OfSCUS$10N AND EVALUATTON 2.1 Post-Mafntenance Testing (Reactor Trip System comoonents) Item 3.1.1 The Generic Letter stated:

Licensees and applicants shall submit the results of their review of test and maintenance procedures and Technical Specifications tn assure that post-maintenance operability testing of safety related components in the reactor trip system 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.

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t The licensee responded:

4 All maintenance s Work Order (MWO) performed in as delineated atAdministrative 08-1 Station isProcedure controlledAD by1844, a Maintenance

" Maintenance" which was established to ensure that maintenance at the Station is planned, performed, and documented in accordance with the j requirements of the Toledo Edison Nuclear Quality Assurance Manual, and 4

Section XI of the ASME Code.

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' As per Administrative Procedure AD 1844.00, all MW0s on safety related equipment shall have an Enclosure 13, Work Requirements Check-off List,  !

prepared. ,

4 l As per the Technical Specifications for the reactor trip system components, a review has verified that the surveillance tests that are i performed to verify operability after maintenance do demonstrate that the equipment is capable of performing its safety functions before being returned to service. The review criteria supporting this demonstration includes the definitions of operability and the channel functional test j (1.6 and 1.11 of the Technical Specifications).

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The applicable Technical Specifications requirement portions include '

i 3/4.3.1 for the Reactor Protection System (RPS), Control Rod Drive (CRD)

! trip breakers and manual reactor trip pushbuttons and the future.

p 3/4.3.2.3 for the Anticipatory Reactor Trip System (ARTS),

The staff has evaluated the licensea's submittal for this item and has determined it to be acceptable.

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l 2.2 Post-Maintenance Testing (Reactor Trio Systen Coroonents) Item 3.1.2 l

1 The Generic Letter stated:

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} Licensees and applicants shall submit the results of their check of vendor and engineering recomendations to ensure that any appropriate

test guidance is included in the test and maintenance procedures or the

Technical Specifications, where required.

The Itcensee responded

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' All recomendations of G. E. Service Advice 9.3 including the 1983 supplement were included into the Station procedures for maintenance and testing of the CR0 breakers. Modifications were verified tn have been i' completed to the required surveillance tests per B&W Operating Plant Service Bulletin 25-005. Since no other vender recommendations were l discovered during the review, no other modifications were necessary to procedures governing reactor trip system components.

j in their Course of Action Resort, submitted September 10, 1985, the '

licensee stated that: "In tiose cases where vendor instructions manuals i

are being used directly to support maintenance activities, each manual ,

! must receive a technical review by the discipline Technical staff, and '

be approved prior to each use."

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The staff has reviewed the licensee's submittal for this item and has determined it to be acceptable. .

2.3 Reactor Trip System Reliability (Vendor-Related Modifications) Item 4.1 i

j The Generic Letter stated:

] 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

l for not implementing a modification exists. Modifications not l previously made shall be incorporated or a written evaluation shall be j prov'ided.

The licensee responded:

i At DB-1, General Electric Company type AX2A breakers are used for  !

reactor trip breakers. A search was perfanned of any vendor recommended j reactor trip breaker modifications, i j

i Our review verifies that the only vendor recommended reactor trip i

breaker modification is the B&W field change package 128-00, which i changea the undervoltage trip devices because of an assembly problem.

l This modification was completed and tested September 2,1977.

The staff has reviewed the licensee's submittal for this item and has (

determined it to be acceptable, 2.4 Reactor Trip System Reliability (System Functional Testing) item 4.5.1 l'

The Generic letter stated:  !

On-line functional testing of the reactor trip system, including l independent testing of the diverse trip features, shall be performed on +

all plants. The diverse trip features to be tested include the breaker undervoltage and shunt trip festures on Westinghouse, B&W, and CE plants; the circuitry used far power interruption with the silicon controlled rectifiers on B&W plants; and the scram 'ptiot valve and backup scram valves (including all initiating circuitry) on GE plants.

The licensee responded:

i On line testing of the reactor trip system in performed monthly by l Surveillance Test ST 5030.02 (RPS Monthly Functional Test)

Surveillance Test ST 5030.19 (ARTS Monthly functional Test}, and Surveillance Test ST 5030.12 (Channel Functional Test of the Reactor Trip Module Logic and Control Rod. Drive Trip Breakers). The CRD trip breakers are exercised monthly by each surveillance test by deenergization of the undervoltage coil. Independent testing of the shunt trip device will be performed on an eighteen month cycle.

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I The staff has reviewed the licensee's submittal for this item and has determined it to be acceptable.

3.0 CONCLUSION

The staff concludes that the programs outlined in the licensee's submittals adequately address the requirements of Generic Letter 83-28

{ for the areas specified in this Safety Evaluation.

! Dated: October 30, 1985 1

'* The following NRC personnel have contributed to this Safety Evaluation:

T. E. Taylor i

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