ML20138R584

Safety Evaluation Accepting Util Responses to Generic Ltr 83-28,Items 3.1.1,3.1.2,3.1.3,3.2.1,3.2.2,3.2.3,4.1 & 4.5.1

ML20138R584
Person / Time
Site:	Mcguire, McGuire
Issue date:	10/31/1985
From:	Office of Nuclear Reactor Regulation
To:
Shared Package
ML20138R562	List: ML20138R560 ML20138R584
References
GL-83-28, NUDOCS 8511180686
Download: ML20138R584 (5)

Text

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t ENCLOSURE

. SAFETT LVaLUATION REPORT FOR GENERIC LETitM 64-28, ITEMS 3.1.1, 4.1.2, 3.1.3, 3.2.1, J.e.2, 3.2.3, 4.1, AND 4.o.1 mLbulRE NUCLEAR STAT 1on, UNITS 1 AND 2 DOCKET NOS. bu-ao9 AND 370 i

I. INTHuvutTION 2

In February 1903, the Salem Nuclear Power Station experiencea two failures

' of the reactor trip system upon the receipt of trip signal . These railures were attributed to Westingnouse - Type DB-50 reactor trip system (RTS) i circuit breakers. Ine failures at Salem on I-ebruary 22 and 25,1964, were believed to have been causea oy a binding action witnin the undervoltage Trip attachment (UVTA) located inside the breaxer cubicle. Due to proolems with the circuit breakers at Salem and at other plants, NRC issued Generic Letter (bL) 83-28, Required actions Based on Generic implications of Salem 4 Anticipated Transient Without Scram (AlWS) Events, dated July 8,1983. This letter required tne 11censees to respond on immediate-term actions to ensure i reliability of the RTS. Actions to be perfonned included development of programs to provide for post-trip review, classification of equipment, vendor interface, post-maintenance testing, and RTS reliability improve-ments. The Generic Letter stated that for Action items 3.1.1, 3.1.2, 3.2.1, 3.2.2, 4.1, ana 4.5.1 NRC Regional Ottices would perform a post-implementation review and 1ssue Safety Evaluation Neports. Subsequent to GL 83-28, Region 11 was requested to perform the review of responses to Action Items J.1.3 and 3.2.3. This report is the Regional oarety Evaluation of Duke Power Lompany submittals cated November 4, 1983, uecember 31, 1984, i and May 24, 1985, to bL es-28 for McGuire Units 1 and 2.

11. HEVIEW GUIDELINES i

ine licensee's responses were evaluated for compliance to the staff's positions delineatea in GL 83-28 for Action items 3.1.1, 3.1.2, 3.1.4, J.e.1, 3.2.2, 3.2.3, 4.1, ana 4.5.1. The requirements of the above action items, as descrioea in the Generic Letter, are paraphrased below:

3.t rost-Maintenance Testing (Reactor Trip System Lomponents) position

1. Licensees ana applicants shall suomit the results of their review of test ana maintenance procedures and Technical Spec 1tications to assure that post-maintenance operaD111ty testing of safety-related components in the reactor trip system is requirea to oe conducted and that the testing aemonstrates that the equipment is capable or performing its sarety functions before oeing returned to service.

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. Enclosure z

4. L1censees and applicants shall submit tha results of their check a of vendor ano engineering recommenaations to ensure that any appropriate test guidance is included in tne test and maintenance procedures or tne technical Specifications, where required.

3. Licensees and applicants snali identify, if applicaole, any post-maintenance test requirements in existing Technical Spec 1rications which can De demonstrated to degrace rather than enhance rarety.

Appropriate changes to tnese test requirements, with supporting Justification, snali De submitted for starr approval. (Note that action 4.o aiscusses on-line system tunctional testing.)

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

Position 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 ana lechnical Specifications review to assure Inat post-maintenance operability testing of all safety-related Equipment is required to be conaucted ana Inat the testing demonstrates that the equipment is capable of performing its safety functions before being returned to service.

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2. Licensee ano applicants shall submit tne results of their checx of vencor and engineering recommendations to ensure Inat any appropriate test guidance is included in the test ana maintenance procedures or the lecnnical Specifications wnere required.

3. Licensees and applicants shai 1aentify, if applicacie, any post-maintenance test requirements in existing Technical speci-tications which are perceived to degrade ratner than enhance safety. Appropriate changes to these test requirements, with supporting Justification, snail oe submitted for staff approval.

4,1 Reactor Irlp System Reliability (vendor-Related Modifications)

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

tor example, the modifications recommended by westinghouse in NCD-Elec-18 for tne u8-50 breakers and a march 31, 1983, letter for tne DS-416 oreakers shall be implemented or a justification for not imple-menting sna s i be made available. noaifications not previously made shall be incorporated or a written evaluation shall be provided.

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5 Enclosure a 4.5 Reactor irlp System Reliability (System Functional testing) rosition i

l Un-line functional testing of the reactor trip system, including

independent testing or tne diverse trip features, shall be performea on ali plants.

1. The diverse trip features to be tested include the breaker under-voltage and shunt trip reatures on Westinghouse, p6W (see Action j Item 4.3 of GL 83-28) ana Lt plants; the circuitry used for power

interruption with the silicon controlled rectifiers on Baw plants

(see Action item 4.4 of GL 83-28); ano the scram pilot valve and l backup scram valves (including all initiating circuitry) on GE plants.

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III. EVALUniluN AND CONCLUSION i

By letters cated November 4,1983; Uecember 31, 1984; ano May 24, 1985;

! Duke Power Company, the licensee of McGuire Nuclear Station, Units 1 and 2

{ providea information regarding tneir compliance to dections 3.1, 3.2, 4.1, ana 4.5 of GL 83-28. We nave evaluated the licensee *s responses against tne I

NMC positions described in Section II above for completeness and adcquacy.

We conciuced that. the licensee's responses to Action items 3.1.1, 3.1.?,

3.1.3, 3.2.1, J.e.2, 3.2.3, 4.1, and 4.o.1 were acceptable ano met the intent 2

or uL 83-28.

i velineated below are tne results of Region it's evaluation and a brier summary or tne licensee's response:

i l A. Item J.1.1, Review of Test ano maintenance Procedures ana lechnical j Specifications (Meactor Trip System t.omponents)

The licensee's response to tnis item is acceptable ano meets the intent 5 of GL 83-26. ine licensee states in tneir submittal that Mcbuire has '

) existing procedures and programs to assure that post-maintenance j testing or all safety-relateo ano iechnical Specification-related ,

components is conducted and that. sucn testing demonstrates tnat the i Heactor Trip System equipment is capable of performing its intended safety functions. ine licensee further stated in their response Inat  !

i runctional testing is performed on the DS-416 breakers in conjunction i

with the time response verification and incluoes an independent i verification or the UV and shunt trip on a monthly basis. They also i stated Inat they measure time response before and after each six months maintenance. Ine licensee also statea tnat they were reviewing reactor

trip system components other inan the components supp:1ed by Westing-

! house to assure tnat technical information is correct and consistent

! and that any changes are incorporated into plant proceoures.

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u. Item 3.1.2, Check of venaor and Engineering Recommendations for Testing and Maintenance (Reactor Trip dystem Components)

The licensee's responses to this item are acceptable and meet tne intent of GL 83-40. Uuke Power Company stated in their submittas datea november 4, 1983, that tney nad reviewed vendor inrormation and the maintenance manual for tne US-416 reactor trip oreakers and verified that appropriate information nad been incorporatea into plant procedures ana technical Specifications. For other Reactor irip System components, the licensee statea tnat they were reviewing previous Westinghouse recommendations to assure that these recommenaations have been appropriately incorporatea into plant procedures ana lechnical Specifications. Licensee's supplemental response dated May e4, 1985, providea acequate confirmation tnat the licensee had completed their review of recommendations in W Tecnnical Bulletins and vata Letters concerning Heactor Trip System components. The supplemental response also statea Inat plant procedures nave been revised as appropriate.

C. Item 3.1.J, identification or tecnnical Specification Hequired Post-Maintenance tests Proven Detrimental to Safety (Reactor Irip system Components)

The licensee's response to this item are acceptable and meet the intent of GL 83-28. The licensee stated that they have no knowledge of any post-maintenance testing requirements in the tecnnical Specifications wnich can be demonstrated to degrade safety.

u. Item 3.2.1, Review or lest and Maintenance Procedures and Technical Specifications (All Other Safety-Related Components)

The licensee's response to this item is acceptable and meets tne intent of GL eJ-z8. The licensee statea that procedures exist which require functional ver1rication on all safety-related components following maintenance and prior to returning the components to service. The licensee considers tnat these procedures are effective in assuring tnat sarety-related equipment is operable upon return to service and that the equipment is capable of performing its intended safety function.

E. Item J.2.2, Check of Vendor ana Engineering Recommendations for Testing and Maintenance tail Other Safety-Relatea Components)

The licensee's responses to this 1 tem is acceptable ano meets the intent of GL eJ-eu. The licensee statea in their response tnat tney are implementing a substantial review to verify that all vendor instruction manuals are complete and consistent, and that the informa-tion in the vendor manuals is appropriately incorporated into plant  :

procedures. The licensee also stated that administrative procedures had been establisnea and were being implemented to control the distri-oution of vendor instruction manuals and to ensure Inat vendor guidance is appropriately incorporated into plant procedures. The licensee statea that the manual review program involves comparing all in-house copies of vendor manuals, resolving any aitterences, and contacting

tnclosure 5 vendors it needed to resolve prooiems. This program will ensure that all copies of a given manual are complete, consistent, ana that any changes made to tne manuals will be evaluated and appropriately incorporatea into plant procedures.

F. Item 4.e.3, Identification or iechnical Specification Hequired Post-Maintenance iests Proven Detrimental to Safety (All Other darety-Relateat,omponents)

The licensee s response to this item 1s acceptable and meets the intent of GL eJ-ee. The licensee statea Inat Duke Power has no Knowledge of any post-maintenance test requirements in the Technical Spec 1rications whicn can ce demonstrated to degraae safety.

G. Item 4.1, Heactor Trip System Rellaoility (Vendor-Relatea nodifica-tions)

The 11censee's response to tnis item is acceptable anc meets the intent of GL 83-26. ine licensee stated in tneir response that tney nave complied witn the March 31 and April ei,1983 (W) recommenaations to replace the UVTA with devices naving a modified snart groove for the retaining ring ana nave verified critical aimensional tolerances specified by W. vuke also stated that tne potential wire bundle

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problem described in W- Tecnnical Bulletin NSD-Tti-/d-02 dated FeDruary 20, 1975, had been resolved and corrective action taken on the McGuire Reactor Trip System breakers, lhe licensee did not identify any otner breaker modifications.

H. Item 4.5.1, Reactor Trip dystem Reliability (System Functional Testing) ine licensee's response to this item is acceptante and meets the intent of GL 83-28. The licensee confirmed in their response that o.i-line functional survelilance testing is performed on McGuire Unit i ana Unit z neactor Protective Systems as described in tne unit. 2 operating license whicn requires system functional testing. Duke s response dated May z4, 1985, for item 4.2.1 partly discussed the licensee's on-line runctional test and tne licensee stated that tney measure and record time response for each breaker on a monthly basis and tnat tnis includes a verification or the UV trip indepenaent of the shunt trip and vice-versa. The licensee also stated tnat tney were following guiaance resulting f rom the westinghouse Owners Group.

I. Conclusion cased on our reviews, the NRC cancludes that tne licensee's responses to items 3.1.1, 3.1.e, 3.1.3, 3.2.1, 3.2.e, s.2.3, 4.1, and 4.5.1 are acceptable and meet the intent of GL 83-28.

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